Monmouthshire County Council Local Development Plan Appendix C6

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					Appendix C6- Raglan CS/0213 Land to the west of Raglan                                                                                       Monmouthshire County Council Local Development Plan
               by: Representation No
Filtered to show: (all of) Stage=S; Document=Preferred Strategy; Site=Land to the west of Raglan
Rep'n No        Representor                                                   Agent                                    Accession No        Date Lodged Late? Source Type             Mode   Status       Status Modified

167.S5           Broadhall Limited                                            Powell Dobson Urbanists                                           17/07/2009              P        C          W        M

Document:Preferred Strategy General Comments                              Site: 213/CS0213 Land to the west of Raglan


Question                                                                                                                                                                       Representation Text & Council Response
                   Candidate Site
    Representor This representation on the Monmouthshire Local Development Plan Preferred Strategy supplements the Candidate Site submission (your reference CS213) which was made on behalf of
                Broadhall Ltd in respect of land to the west of Raglan.

                   The above candidate site submission set out the following:
                   It proposed that a site of 26.5 hectares, adjoining the western edge of the settlement of Raglan, was allocated for a sustainable mixed used use development to respond to local needs. The
                   proposed allocation comprised an agricultural park, business park, hotel, park land / open space, a hospice, retirement village, and residential uses (with a focus on first time buyers).

                   The site is ideally located close to transportation routes and, although it is not designated for its landscape value, it would provide an attractive setting for the proposed uses, which could be
                   enhanced through a strategic landscaping scheme. A detailed case for the allocation was made within the aforementioned candidate site submission.

                   Since that submission, it is not now necessary to include a Regional Agricultural Park, a Hospice, or a retirement village, as potential land uses due to various changes in circumstances. A
                   key consideration in a future allocation at this location is the need for flexibility to take account of the long-term changing economic, environmental and social demands and conditions (such
                   as, possibly, a review of residential requirements in the area). This could affect both the form and amount of development, plus phasing also.

                   A further important change since the candidate site submission and the assessment of potential site allocations is the emergence of the consultation draft Technical Advice Note 6 Planning
                   for Sustainable Rural Communities.

                   The site and mixed use allocation being proposed would facilitate, and contribute to the key aims of the draft TAN nsofar as it would respond to the need to support living and working rural
                   communities in order that they are economically, socially and environmentally sustainable; would increase the sustainability of the community; encourage people to live and work in the same
                   area; support a strong and sustainable rural economy; allow the diversification of the rural economy through traditional industries and new enterprises; enhance infrastructure networks; and
                   provide
                   housing to meet local need (including affordable housing).
                   Council Response
           Council Comments noted and will be taken into account in the candidate site assessment process.




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Appendix C6- Raglan CS/0213 Land to the west of Raglan                                                                                   Monmouthshire County Council Local Development Plan
              by: Representation No
Filtered to show: (all of) Stage=S; Document=Preferred Strategy; Site=Land to the west of Raglan
Rep'n No        Representor                                                 Agent                                    Accession No    Date Lodged Late? Source Type       Mode   Status       Status Modified

167.S6          Broadhall Limited                                           Powell Dobson Urbanists                                        17/07/2009      P         C          W        M

Document:Preferred Strategy App C. Candidate Sites Compatible           Site: 213/CS0213 Land to the west of Raglan


Question                                                                                                                                                         Representation Text & Council Response
         11       Preferred Strategy further comments
    Representor Appendix C
                List of candidate sites that are potentially compatible with the Preferred Strategy CS/0213 Land to the west of Raglan

                  Proposed use should also include retirement village, residential (first time buyer focus) and hospice.
                  These potential land uses were set out in the Candidate Site submission.
                  Council Response
           Council Comments noted.




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Appendix C6- Raglan CS/0213 Land to the west of Raglan                                                                      Monmouthshire County Council Local Development Plan
              by: Representation No
Filtered to show: (all of) Stage=S; Document=Preferred Strategy; Site=Land to the west of Raglan
Rep'n No       Representor                                              Agent                               Accession No   Date Lodged Late? Source Type       Mode   Status       Status Modified

167.S7         Broadhall Limited                                        Powell Dobson Urbanists                                17/07/2009        P         C          W        M

Document:Preferred Strategy App G. Asst potential strategic CS      Site: 213/CS0213 Land to the west of Raglan


Question                                                                                                                                               Representation Text & Council Response




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Appendix C6- Raglan CS/0213 Land to the west of Raglan                                                                                        Monmouthshire County Council Local Development Plan
             by: Representation No
Filtered to show: (all of) Stage=S; Document=Preferred Strategy; Site=Land to the west of Raglan
Rep'n No      Representor                                                    Agent                                      Accession No        Date Lodged Late? Source Type       Mode     Status     Status Modified

       11        Preferred Strategy further comments
    Representor Appendix G
                Assessment of potential strategic candidate sites
                Site 20 Land to the west of Raglan
                The assessment states that development of the site would have adverse landscape impact and could create highway capacity issues. It rejects the candidate site as a Strategic site on the
                grounds of it being:
                • an inappropriate scale of development;
                • out of proportion with the existing village environment; and,
                • having a detrimental effect on countryside

                 Overall the candidate site assessment scores the following:
                 Assessment Number of criteria Percentage of total
                 Positive (green) 11 41%
                 Mixed (amber) 13 48%
                 Negative (red) 3 11%

                 It is assessed positively (green) in terms of:
                 (i) Access to frequent public transport;
                 (ii) It is located close to schools, community facilities and recreation open space;
                 (iii) It would not result in a loss of public open space;
                 (iv) The site is located within 100m of statutory services;
                 (v) Is proposed as mixed use without ‘bad neighbour’ uses;
                 (vi) Is not within an area which is designated as being of landscape importance at a local or national level;
                 (vii) Is not within or close to an area which is designated for biodiversity importance an at a local, national or international level; and,
                 (viii) There are no listed buildings within or adjacent to the site which would be affected if the site was developed.

                 It was assessed as mixed (amber) in terms of:
                 (i) It adjoins an existing settlement, as opposed to being within one;
                 (ii) It would result in the loss of Grade 3 and 4 agricultural land, the lowest grades;
                 (iii) The site benefits from immediate proximity to a main public highway (A40) but would require physical access improvement works as part of a development;
                 (iv) The surrounding highway network is assessed as being likely to be adequate for the site development but some junction improvements may be required, although these are not
                 determined at this stage;
                 (v) The site is not close to adjacent employment / industrial uses (see comment below);
                 (vi) The proposal has the potential to impact on bat foraging area and or water shrew habitat. This would need to be properly assessed including a consideration of appropriate mitigation if
                 found to be required. The amber rating is clearly a
                 precautionary measure in the absence of evidence to the contrary;
                 (vii) The site is located in proximity of off-site archaeological resources although the potential impact of a potential allocation or development is not quantified. Again, the precautionary
                 approach is being taken in the assessment as an allocation would have a potential impact, (whether positive or negative), and hence this criterion receives an ‘amber’ rating. The likely
                 impacts can only be quantified, through a coherent masterplanning process, which should allow any potential negative impacts to be minimised or removed;
                 (viii) The site is 100m from the Raglan Conservation Area, however, it is not certain how development of the site might affect the character and appearance of the Area. It should not be
                 concluded that the principle of development on the candidate site would have a detrimental impact on the Conservation Area by virtue of proximity as, clearly, appropriate development could
                 preserve and enhance the character and appearance of the Area; and,
                 (ix) Part of the site falls within flood zone C2. Again it would need to be determined through a masterplanning process whether or not development would be proposed in this zone, and
                 whether or not this would be acceptable (having regard to TAN15 etc.).

                 It should be noted that the assessment under Criterion 11 may be incorrect (referred to in (v) above). The criterion is “If the site is proposed for residential development, how does it relate to
                 any industrial / employment uses adjacent to the site” to which the commentary is simply “No”, and it is graded as ‘amber’ being “Not close to employment uses”. The proposed land uses
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Appendix C6- Raglan CS/0213 Land to the west of Raglan                                                                                       Monmouthshire County Council Local Development Plan
               by: Representation No
Filtered to show: (all of) Stage=S; Document=Preferred Strategy; Site=Land to the west of Raglan
Rep'n No        Representor                                                   Agent                                    Accession No        Date Lodged Late? Source Type             Mode   Status       Status Modified
                   include residential uses and a retirement village which, although not being close to significant existing employment uses, would be immediately adjacent to new employment uses as part of
                   the proposed land use allocation.

                   The only criteria which are considered to warrant a negative rating are:
                   (i) The site is not brownfield land;
                   (ii) The area has a high / medium landscape sensitivity as it is currently open countryside which is visible from outside the site; and,
                   (iii) The landscape capacity is considered to be medium / low capacity.

                   The last criterion relating to landscape capacity acknowledges that impact can be mitigated through structural planting.

                   Overall, the site meets a significant number of the criteria (41%). Those criteria which are scored as amber (mixed / neutral) follow the precautionary principle, i.e. assuming that there could
                   be an impact unless proven otherwise. Development of the candidate site through a masterplanning process, taking into account site opportunities and constraints, should allow potential
                   negative impacts to be mitigated or removed, and would bring considerable benefits. These were set out in detail in the Candidate Site submission and reference should be made to that
                   submission.

                   In conclusion, there is clearly a need for new housing allocation sites in the vicinity of Raglan and there is also demand for employment uses. The allocation of this site, in whole or part, will
                   help to address this. It is adjacent to the existing settlement, is ideally located in terms of highway infrastructure, would represent a logical extension of the existing settlement, and would
                   give the opportunity to significantly address shortfalls in the aforementioned land uses. The primary benefit of accepting the whole site allocation is the greater potential for economies of
                   scale which would accrue through a comprehensive masterplanning process thereby leading to enhanced community and environmental benefits, both locally and for the wider County.
                   Council Response
           Council Comments noted and will be taken into account in the candidate site assessment process.

800.S1           Raglan Village Hall                                                                                                            17/07/2009              P        C          W        M

Document:Preferred Strategy General Comments                              Site: 213/CS0213 Land to the west of Raglan


Question                                                                                                                                                                       Representation Text & Council Response
         11        Preferred Strategy further comments
    Representor I wish to see Raglan retain its village status and not become a small town. To this end I reject site CS/0213 as being too large, outside the current confines of the village and in a dangerous
                location
                   Council Response
           Council Comments noted and will be taken into account in the candidate site assessment process.




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Appendix C6- Raglan CS/0213 Land to the west of Raglan                                                                                  Monmouthshire County Council Local Development Plan
               by: Representation No
Filtered to show: (all of) Stage=S; Document=Preferred Strategy; Site=Land to the west of Raglan
Rep'n No        Representor                                                Agent                                   Accession No       Date Lodged Late? Source Type            Mode   Status       Status Modified

1121.S7          Bradly, Mrs Clare M                                                                                                       17/07/2009             E        C          W        M

Document:Preferred Strategy General Comments                           Site: 213/CS0213 Land to the west of Raglan


Question                                                                                                                                                                 Representation Text & Council Response
                   Candidate Site
    Representor Site CS/0213 is far too big for any development of the village. It would almost double the current size of the village. The proposed use seems to cover virtually anything, but being on that
                side of a fairly busy road would tend to cut off any development on this site from the current village. Unless access was via a bridge over the A40 from the old Abergavenny Road, which I
                think is now called Groesonen Road, B4596, it would be very difficult for most of the suggested uses, and once that road has the increase in traffic from the intended new Cattle Market at
                Bryngwyn access via that road would become far more difficult.
                   Council Response
           Council Comments noted and will be taken into account in the candidate site assessment process.




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Appendix C6- Raglan CS/0137 Land adjacent to Usk Road                                                                                   Monmouthshire County Council Local Development Plan
               by: Representation No
Filtered to show: (all of) Stage=S; Document=Preferred Strategy; Site=Land adj Usk Road
Rep'n No        Representor                                                Agent                                   Accession No       Date Lodged Late? Source Type            Mode   Status       Status Modified

1121.S5          Bradly, Mrs Clare M                                                                                                       17/07/2009             E        C          W        M

Document:Preferred Strategy General Comments                           Site: 137/CS0137 Land adj Usk Road


Question                                                                                                                                                                 Representation Text & Council Response
                   Candidate Site
    Representor A development on site CS/0137 is in my opinion, slightly too far out of the village, and residents of such a development would probably choose to use their cars to access the villlage rather
                than walking, thereby increasing the traffic congestion within the village centre.
                   Council Response
           Council Comments noted and will be taken into account in the candidate site assessment process.




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Appendix C6- Raglan CS/0170 Land to the east of Hill House                                                                               Monmouthshire County Council Local Development Plan
               by: Representation No
Filtered to show: (all of) Stage=S; Document=Preferred Strategy; Site=Land to the East of Hill House
Rep'n No        Representor                                                Agent                                   Accession No        Date Lodged Late? Source Type            Mode   Status       Status Modified

1121.S3          Bradly, Mrs Clare M                                                                                                        17/07/2009             E        C          W        M

Document:Preferred Strategy General Comments                           Site: 170/CS0170 Land to the East of Hill House


Question                                                                                                                                                                  Representation Text & Council Response
                   Candidate Site
    Representor The adjacent site CS/0170 is reasonable infil, although I had been given to believe that building on this site was unlikely to be permitted as it would block the view of Raglan Castle from
                travellers on the A449 approaching Raglan from the South.
                   Council Response
           Council Comments noted and will be taken into account in the candidate site assessment process.




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Appendix C6- Raglan CS/0171 Site of Tennis Court and immediate Curtilage                                                         Monmouthshire County Council Local Development Plan
              by: Representation No
Filtered to show: (all of) Stage=S; Document=Preferred Strategy; Site=Site of Tennis Court and immediate Curtilage
Rep'n No        Representor                                             Agent                                  Accession No    Date Lodged Late? Source Type       Mode   Status       Status Modified

1121.S2         Bradly, Mrs Clare M                                                                                                  17/07/2009      E         C          W        M

Document:Preferred Strategy General Comments                         Site: 171/CS0171 Site of Tennis Court and immediate Curtilage


Question                                                                                                                                                   Representation Text & Council Response
                  Candidate Site
    Representor The small site CS/0171 seems reasonable
                  Council Response
           Council Comment noted.




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Appendix C6- Raglan CS/0246 Land at Brooks Holdings                                                                                        Monmouthshire County Council Local Development Plan
               by: Representation No
Filtered to show: (all of) Stage=S; Document=Preferred Strategy; Site=Land at Brooks Holdings
Rep'n No        Representor                                                  Agent                                    Accession No       Date Lodged Late? Source Type             Mode   Status       Status Modified

721.S1           Spencer, Donald                                                                                                               22/06/2009              P       C          W        M

Document:Preferred Strategy General Comments                             Site: 246/CS0246 Land at Brooks Holdings


Question                                                                                                                                                                      Representation Text & Council Response
                   Candidate Site
    Representor Site CS 0246 – Land at Brooks Holding, Station Road.
                I strongly object to the proposal for this site to be considered as a site for residential development.

                   It should be designed for community use, including a site for a new school - or at least a site for the replacement of the dilapidated Infant School building, which is now considered to be
                   totally unsuitable on health and safety grounds.

                   Alternatively, the whole site should be used for a new school for Infants and Juniors, thus releasing the existing Junior School building for community use. Please register these comments
                   as part of the consultation process
                   Council Response
           Council Comments noted and will be taken into account in the candidate site assessment process.

1121.S6          Bradly, Mrs Clare M                                                                                                           17/07/2009              E       C          W        M

Document:Preferred Strategy General Comments                             Site: 246/CS0246 Land at Brooks Holdings


Question                                                                                                                                                                      Representation Text & Council Response
                   Candidate Site
    Representor Site CS/0246 I do not consider suitable for residential development. Station Road is too narrow to provide access to a development of that size, particularly as it is used by council lorries
                travelling to and from the council depot at the bottom of Station Road. I also think that this should be retained for possible extensions to the school and village hall facilities in the future.
                   Council Response
           Council Comments noted and will be taken into account in the candidate site assessment process.




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Appendix C6- Raglan CS/0247 Land at Chepstow Road                                                                                     Monmouthshire County Council Local Development Plan
               by: Representation No
Filtered to show: (all of) Stage=S; Document=Preferred Strategy; Site=Land at Chepstow Road
Rep'n No        Representor                                               Agent                                   Accession No      Date Lodged Late? Source Type            Mode   Status       Status Modified

1121.S4          Bradly, Mrs Clare M                                                                                                     17/07/2009              E       C          W        M

Document:Preferred Strategy General Comments                          Site: 247/CS0247 Land at Chepstow Road


Question                                                                                                                                                               Representation Text & Council Response
                   Candidate Site
    Representor I have long recognised that building on site CS/0247 is more or less inevitable, so although I cannot say that I am happy about this, I am more or less resigned to it. Access on to Chepstow
                Road would need careful handling as this is already a busy road, and the visibility on this stretch is not particularly good.
                   Council Response
           Council Comments noted and will be taken into account in the candidate site assessment process.




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Appendix C6- Raglan CS/0160 Land north of A40 Raglan                                                                             Monmouthshire County Council Local Development Plan
              by: Representation No
Filtered to show: (all of) Stage=S; Document=Preferred Strategy; Site=Land North of A40
Rep'n No        Representor                                               Agent                                  Accession No   Date Lodged Late? Source Type       Mode   Status       Status Modified

800.S2          Raglan Village Hall                                                                                                 17/07/2009        P         C          W        M

Document:Preferred Strategy General Comments                          Site: 160/CS0160 Land North of A40


Question                                                                                                                                                    Representation Text & Council Response
         11       Preferred Strategy further comments
    Representor I wish to see Raglan retain its village status and not become a small town., CS/0160 is not necessary.
                  Council Response
           Council Comment noted.




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Appendix C6- Raglan                                                                                                                             Monmouthshire County Council Local Development Plan
                by: Representation No
Filtered to show: Stage=S; Document=Preferred Strategy; Policy=S3
Rep'n No          Representor                                                   Agent                                     Accession No        Date Lodged Late? Source Type             Mode   Status       Status Modified

252.S6            Tribe, Mrs Anna                                               RPS Group plc (Cardiff)                                            17/07/2009               P       C          W        M

Document:Preferred Strategy Strategic Sites, p.52
Policy: S3
Summary: Raglan

Question                                                                                                                                                                          Representation Text & Council Response
         7          Strategic Site
     Representor Strategic Sites Question 7: Neither Agree nor Disagree

                    Agree subject to these sites having sufficient capacity to accommodate the requirement based upon the WAG 2006 population projection and the advice of MIPPS 01/2006. If they do not
                    have sufficient capacity then additional strategic sites may be necessary.

                    Also, however, there are serious concerns on the viability and deliverability of the Deri Road (Mardy, Abergavenny) site. Alternative options need, therefore, to be considered to take account
                    of the possibility that the site at Deri Road will not come forward during the Plan period as predicted.

                    If alternative land to the scale needed is not available in Abergavenny then Raglan should be considered as a viable and convenient alternative.
                    Council Response
             Council Comments noted.

                    Housing Provision:
                    While regard has to be given to the latest projections, it is for the LDP to determine the level of growth that is appropriate for the County. A supporting paper will explain further the reasons
                    for selecting the level of growth put forward in the LDP and why the figure departs from the WAG 2006-based population and household projections.

                    Deri Farm:
                    With regard to the deliverability of Deri Farm, it should be noted that each strategic site will be subject to a full viability appraisal before any decision is made on allocations in the Deposit
                    Plan.




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Appendix C6- Raglan                                                                                                                           Monmouthshire County Council Local Development Plan
                by: Representor No
Filtered to show:   (all of) with representations: (all of) Stage=S; Document=Preferred Strategy; tag selected
                                                                                                                                  Consultee                  Contact                        Record          Representor
Repr No     Name                                                 Town                   Agent                                   Type             Status         Method                    Source           Status

1121        Bradly, Mrs Clare M                                  Usk                                                             Private Individu Active              E-mail                Email              Made represen




                                                                                                            TREAT      EVIDENCE NO FRTHR EVID.
Rep'n No       Accssn No Date Lodged         Late? Source Type Mode Status Modified           Petition of     in parts Add'l SA/SEA Repr Council Officer              Recommendation                Response
1121.S1                         17/07/2009           E       C      W      M
Document:Preferred Strategy General Comments                               Site:                                                                                           PEX Hearing:
Policy:                                                     Map:                                                     Issue:
Summary: Development in Raglan

  Item Question      Representation Text
    10 11           Preferred Strategy further comments
         With regard to the Candidate sites around Raglan which are included in the plan, I consider that the amount of housing proposed of 74 units, in particular the 40 new sites, is excessive for a village the
         size of Raglan. Including the windfall of 10 and the 40 new sites, this would increase the size of the village by 10% or thereabouts. The infrastructure of the village is already beginning to creak. The
         school is at maximum capacity, so that families with young children are being put off coming to the village. Carparking in the village centre is difficult to near impossible at certain times of the day, and
         Chepstow Road is almost impassable at the beginning and end of the school day or if there is an event on at the school. Most adults already have to commute out of the village to work, and public
         transport only gets one to Monmouth, Abergavenny, Usk and Newport. Working in Cwmbran for example is not feasible without a car.

         While recognising that some additional housing within the village is inevitable, I feel that the designated candidate sites are not all in any way viable.

  Item Question Council Responses
    15              Council Response
          Comments noted and will be taken into account in the candidate sites assessment process. Comments on the capacity of Raglan for further growth are noted and will be addressed in a specific section
          of the Report of Consultation.




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