Site Alternative Deliverability Report. SALT 033 Former Mid Wales Hospital, Talgarth Resubmission: Undeliverable. Local Development Plan

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1 Local Development Plan Site Alternative Deliverability Report Brecon Beacons National Park Authority SALT 033 Former Mid Wales Hospital, Talgarth Resubmission: Undeliverable

2 SALT 033 Former Mid Wales Hospital Talgarth (Talgarth) Existing use Proposed use Previous CS/DBR Number Former Mid-Wales Hospital Mixed use CS111

3 Previous site survey Taken from LDP Settlement Assessment: Talgarth Cricket Pitch Chapel Central Reception Northern Frontage

4 From viewpoint fields at rear of hospital Cricket Pitch Poor state of repair Viewpoint From viewpoint Rear of hospital

5 CS ID no CS111 Site Name TALGARTH HOSPITAL Current use of area Site has certificate of lawful use for class C2 use. The site is previously developed land. Proposed use Are there natural Constraints preventing development Mixed Use (Candidate site submission proposes employment, community uses, care home and extra care facility, significant element of residential use, leisure use, tourism/hotel, education facilities, live work accommodation, open space (including retention of cricket pitch) No natural constraints. Are there any other constraints preventing development of the site The existing buildings are not listed. Several of the buildings are in a poor state of repair. This reduces the potential for a re-use of current buildings. Access: Further information is required from the Highways Authority as to whether a suitable access can be achieved to the site. The site lies outside the development limits of the Town. Development immediately adjacent? Impact on settlement if development were to proceed n/a Careful consideration should be given to the relationship between development on this site and the need to attract investment and regeneration of the Town Centre. Further information from highways on the potential traffic impacts of directing significant traffic flows along Hospital Road. Officers therefore recommend that the site is passed through to the next phase of assessment in order that information about the deliverability of development may be assessed. The site s location away from the settlement and its status as a previously developed site must also be carefully considered. A separate issues paper will be prepared to consider these issues.

6 DEPOSIT Key Stakeholder Responses Consultee Score Comment Environment Agency -1 The Talgarth area is especially vulnerable to flooding. It is important that future development does not increase runoff, exacerbating flooding in the local watercourses. Therefore, we would expect all new development in this area to incorporate sustainable drainage techniques with an agreed limited "Greenfield" discharge derived in conjunction with the Local Authorities/ Land Drainage Board. CCW -1 Buildings within site support bat roosts, including lesser horseshoe bats Proposals will need to take into account roosting needs & landscape features which may be important for feeding or flightlines. Sensitive use of existing buildings would be helpful to long term maintenance of bat roosts. BBNPA Ecologists Dwr Cymru Water Provision -1 Off site mains required Dwr Cymru Sewerage Provision -2 Please be advised that there are no public sewers in close proximity to the development. Development of these sites may be constrained by the performance of our public sewerage network for which there are no planned improvements within our current capital investment programme. Should this land be allocated for development then we would request that the allocation be released in the latter part of your plan. To allow us the time to undertake improvements or alternatively developers may need to fund the work Where the proposed development will result in a new or amended trade effluent discharge, then the written approval of the sewerage undertaker is required. Dwr Cymru Sewerage Treatment -2 Our Waste Water Treatment works for this area has limited capacity to accommodate all of the planned growth without further improvement. Our Capital Investment programme(for the period ) is currently being assessed by our Regulator and approval is expected in December However, the investment does not include this Works and we would request that our organisations meet to discuss and agree to a phased and agree to a phased release of land in this area. Request phasing towards the end of the LDP period Archaeological Trust -1 Cadw Highways -2 The access roads serving this site are both narrow with poor quality junctions, alignment, gradients and both feed through the centre of Talgarth. The scale of redevelopment previously approved was based on much earlier traffic figures attributed to the site as a hospital. However permissions implemented subsequent to the hospital use render that base line of traffic volumes invalid and further consideration will be required as to an appropriate scale of redevelopment based on the suitability accesses. A limit on the scale of re-development is essential due to the substandard nature of the access arrangements The surrounding highway capacity is strained and all junctions are below standard Trunk Road Agency Environmental Health Land Drainage +1 Standard advice-surface water from the dwellings & other impermeable areas of the site shall

7 discharge to soakaway systems designed & constructed in accordance with BS EN or BRE Digest 365 Soakaway design (or other best management practice-suds) The authority would encourage the adoption of surface water control techniques whereby attenuation to the 100yr standard is achieved whilst limiting continuation flow to the existing 1 in 1 year Greenfield run-off for the connected impermeable areas. Rural Housing Enabler Waste Authority +1 At this stage any sites identified for residential use will need to take account at some point of both the storage of household waste and the access of the relevant collection vehicles to service the houses. Contaminated Land -1 This site is on land formerly used as a hospital & may be subject to potential contamination. The Council's contaminated land condition A is likely to be requested for any future planning permission. Candidate Site Consultation Responses: 6 Objection to loss of Cricket Pitch and Roads Serving the Development are Inadequate Objection to loss of surrounding Greenfield, and Protection of Amenities Objection based on problems with supporting infrastructure capacity and no proven demand for development Site Development Potential Analysis Score -9 Comment The site is not located near to any public sewers. Even if this issue could be overcome, the public sewerage network in Talgarth may constrain future development. Any development would have to be phased towards the latter part of the Plan period. The substandard nature of current access arrangement both directly at the site and surrounding junctions within the Town will be a key constraint on the scale of redevelopment Community Comment Recommendation No representation from key stakeholder stage Candidate Site individual responses highlight issues with infrastructure to support development including concerns over highways capacity and safety There are strong constraints that could affect the viability and deliverability of development of this site. Account needs also to be taken of the potential misfit with the Preferred Strategy which seeks to locate the majority of development within the key settlements. Should the site not be allocated then the LDP needs to think carefully about what future it can enable for this site. If residential development cannot reasonably be supported by then alternative uses should be considered.

8 SALT Key Stakeholder Responses Consultee Score Comment Highways Concern - The access roads serving this site are both narrow with poor quality junctions, alignment, gradients and both feed through the centre of Talgarth. The scale of redevelopment previously discussed was based on much earlier traffic figures attributed to the use of the site as a hospital. The base line of those traffic volumes are rendered questionable by the permissions implemented subsequent to the hospital use and further consideration will be required as to an appropriate scale of redevelopment based on the suitability of the accesses and improvements proposed Dwr Cymru Welsh Water Sewerage Please be advised that there are no public sewers in close proximity to the development. Development of these sites may be constrained by the performance of our public sewerage network for which there are no planned improvements within our current capital investment programme. Should this land be allocated for development then we would request that the allocation be released in the latter part of your Plan to allow us the time to undertake improvements or alternatively developers may need to fund the works in advance of our Regulatory requirement. Where the proposed development will result in a new or amended trade effluent discharge, then the written approval of the sewerage undertaker is required. Sewerage Treatment Our Waste Water Treatment Works for this area currently has limited capacity but improvements are planned in our Regulatory Capital Investment Programme for 31st March Water A water supply can be made available to service the proposed development site. However, this would require off-site mains to be laid to the proposed development to ensure customer service standards is maintained. Where it is proposed to utilise water for non-potable use, then please be advised that there I no obligation on a water undertaker to provide this water. CCW This site lies within an elevated area outside of Talgarth that is evaluated as outstanding under the visual and sensory aspect of Landmap, and is located within the Middle Wye Valley Landscape of Outstanding Historic Interest. Given its location, size, poor access to the site and the necessary highway improvements that would be required to develop this site for mixed use, CCW has serious concerns regarding the potential impact of such a development/allocation on the character and general amenity of Talgarth and its setting. The proposed site is located in an area identified as countryside in the BBNPA Deposit LDP. We therefore consider that an allocation of this size is contrary to the Deposit LDP Strategy for development in the countryside. Notwithstanding the above, if it is intended to allocate this site within the LDP, given its proximity to the River Wye Special Area of Conservation (SAC), it will need to be assessed in the context of the HRA of the LDP, and a project level HRA undertaken at the planning application stage. The requirement for a project level HRA to be undertaken should be identified in the LDP. Additionally, some of the buildings within this

9 site also support bat roosts, including lesser horseshoe bats, and a hazel dormouse nest has recently been found within the site. As the wider area is also known to support the hazel dormouse, any proposals for the site will therefore need to fully take into account the landscape features within the site which may be important for these species, particularly trees and hedgerows connected to hedgerows and woodland in the wider landscape. Should it be decided to allocate the site, the LDP should clearly state that proposals for this site will need to take into account the roosting, nesting and foraging needs of the species, landscape features within the site which may be important as foraging areas or flight-lines for bats, and outline how these features will be managed for the longterm. Ecology -1 Description Buildings known to support bat roosts for lesser horseshoe bats, pipistrelle bats, brown long-eared bats and one or two other species; grounds likely to support dormouse; within an area of known importance for great crested newts; likely to be amphibians and reptiles within the rough grassland surrounding the site. S42 Habitats Scrub, hedgerows, woodland S42 Species Bats, dormouse, great crested newt (?), hedgehog. Protected Species Bats, dormouse, great crested newt (?), other amphibians and reptiles Protected Sites Close to Pwll y Wrach SSSI (woodland, known stronghold for dormouse) Connectivity Via hedgerows Recommendations A minimum specification for ecological surveys on site has already been provided by the Authority and would be made available to any subsequent developers too. Full ecological survey plus retention and enhancement of existing features and mitigation, compensation and enhancements required, in particular for all the protected species involved. Great, great care and attention to detail is required here. All ecological data generated MUST be made available to BIS as a condition of any planning permission. Brecknock Wildlife Trust The site contains areas of woodland. I would like to recommend further survey of these parts of the site, possibly to exclude woodland areas if they are of reasonable wildlife quality, and to protect ancient and veteran trees. Talgarth Town Council General support see Appendix 1 Mid Wales Hospital Adjoining Adjacent Neighbours Group We continue to support this site to be included in the plan as mixed use with a small element of housing upon its 4.5 hectare development zone as shown on the UDP map. The comments made in the previous candidate site consultations we now slightly revise by adding the following under the original headings. 1) GHG Emissions 4) Sustainable Transport Upon reflection we have slightly revised our thoughts in regard to GHG Emissions and Sustainable Transport. The site is in fact 0.8 km from the town centre. We now agree with the BBNPA who say the site will create a reliance on private car use". It is half way up a steep hill on a very exposed road with a good pavement. However, as local residents we know that only a few of us walk this distance into town and back for errands, shopping or school. It is not a 400 meter or 5 minute walk to the town centre. Neither does it have the benefit of flat terrain as would the alternative sites of

10 "Land north of the Doctor's Surgery 038" or "Land adjacent to Aldersend 065 ". Therefore the hospital site is not as sustainable as sites within or adjoining the town's boundary. 2) Landscape (impact) The BBNPA have stated Development of this site in open countryside would have significant adverse affects on the Park landscape". In January 2011 the Parks produced and adopted the Talgarth Conservation Area Appraisal which includes the former hospital site. It was then too early for us to consider the implications when commenting on the candidate sites last January. Paragraph 10.8 of the Appraisal gives a good synopsis of the buildings with guidance of what needs to be addressed and conserved. Then the Welsh Office Circular 61/ 69 gives further guidance. All in all it would seem any development on this site is highly sensitive and will have to be very well considered in terms of its setting, conservation, heritage and how it will relate and complement the town. CONCLUSION In addition to our previous conclusion we add this update. Since the candidate site consultation the ownership of the site has changed hands but the site is still accelerating into a massive ruin. It is now a conservation area making the development of the site even more critical. If it is not included in the LDP then it would return to a Greenfield site or just remain a ruin in the open countryside. Levelling the site or condemning it would be a practical way of dealing with the aesthetics and health and safety issues, but that would seem contrary to the purposes of conservation, the principles, legislation and guidelines. Therefore the new conservation status appears to be making it unavoidable for the site not to be developed. At the same time it would be a contradiction if a conservation area was created merely to preserve dilapidation. Therefore and furthermore this seems to reinforce the notion of the site being included in the plan and that a development brief or SPG is written for it. The site is fraught with many difficulties and complexities which will only compound if left to general policies

11 Deliverability Assessment Is the site deliverable? No Highways comments question feasibility of achieving necessary access and highways improvements based on the scale of development. Lack of public sewers. Visual impact on area regarded as outstanding landscape. Serious concern regarding feasibility of allocation given its location, scale, and the poor access to the site in order to develop this site for mixed use.

12 Local Development Plan Site Alternative Assessment against LDP Strategy Brecon Beacons National Park Authority SALT 033 Former Mid Wales Hospital Not Compliant with Strategy

13 Is the site located within a community where there is a defined need for growth? Are the growth need adequately met through current Deposit Allocation. Yes Pre-Deposit Consultation with Talgarth TC has clearly set out the importance of future growth to the Town to enable regeneration. Talgarth TC are supportive of development on this site Yes Talgarth has 2 LDP allocations providing up to 63 to meet the needs of the community during the plan period. Findings of Deliverability Assessment Compliance with Strategy Undeliverable. Site fails Highways Safety, Water, and Landscape Deliverability Criteria. Not Compliant Site does not provide a viable development option for Talgarth. Site does not form a logical extension to Talgarth. Development here would amount to development in the Open Countryside placing more pressure on the existing road network. Site does not support the Strategy. Officer Recommendation Site Site is not considered suitable as a development option for the National Park Community. No change to the LDP as a result of deposit allocation representation. Site to remain as countryside during LDP period (subject to findings of any subsequent review) Officer Recommendation Settlement No alteration to Talgarth Settlement Hierarchy Position.

14 Appendix 1 Talgarth Town Council We would further assert that the developable area of the site is the 4.5 hectares as identified within the UDP, and not the full 13.5 hectare site as indicated in all Alternative Site listings. In respect of our detailed comments, we would refer the Brecon Beacons National Park Authority to our detailed submission in response to the Deposit LDP document, which for ease of reference is reproduced below The town council do not understand why this site does not have a visible presence and is not integrated into the development plan for the area. T was included within the UDP as an important mixed use sites and later identified in the adopted Talgarth Planning Brief 2008 as a site with good potential employment. Then again it scores highly in the LDP Sustainability Appraisal Report Appendix G and is mentioned as the sole provider for Talgarth employment. In addition to this it is now included in the Talgarth Conservation area. There is no doubt that this site is very important to Talgarth and its regeneration but whine it comes to the Deposit LDP, the authority appears to ignore its existence and does not seem to provide reasoned justification for doing so. The planning constraint on the site are well documented in terms of its location, being well outside the town s boundary and 1km from the town centre. In addition to this, there are access and traffic volume issues on the two roads that lead to the sit form the centre of Talgarth that serve over 100 homes. Since the hospital closure in 1999/2000 there have been about 15 extra new homes created around and above the hospital site which need to be factored in to any new development. The planning context for the site as identified in PPW is brown field / previously developed land (see attached UDP extract Map for footprint of available site for development). A mixed use classification, with some low density housing, could be seen as appropriate development within its parkland type setting, also enabling appropriate mitigation for the biodiversity issues associated with the known bat roosts, feeding and flight lines. This could well accommodate some live work / studio / workshop units which would limit daily traffic movements. It would also be appropriate for a small scale employment zone to create inward investment and prevent further loss of local business from Talgarth (Alzeim serves as an example of such loss following their relocation to Brecon in 2010) Contrary to the Site Assessment, such a low density site design would have minimal traffic impacts. Furthermore, the serious concerns expressed and identified within the site assessment, about there being major adverse effects in respect of Development of this site in the open countryside, does not appear to be based in reality, the status quo, or in what buildings are currently there and have been so for the last 100 years. Recently the built area of the site has been subject to progressive and deliberate dismantling, along with the consequent decay, when it could add a vital component to the regeneration and enhancement of this site, now within the Conservation Area of Talgarth. The sensitivity and appropriateness of both density and design will be the critical factors and should be linked to a very carefully written Supplementary Planning Guidance (SPG), or Development Brief which the UDP had committed itself to in the first place. However, a development brief needs to be written. Presumably without the site being given policy context and clarification in the LDP, it is not appropriate to write SPG or a Development Brief within the site first being in the LDP. We understand that it is a pre-requisite. Therefore for the reasons stated above the Town Council requests that this site is included in the LDP with clarification on policy and a positive statement on its development direction

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