Abergele South East Strategic Employment/Mixed Use Site: representation regarding replacement local development plan preferred strategy July 2019

We write regarding the above for a family group that has control of part of the Abergele South East Strategic Site.

This letter of representation is submitted for the family group which owns the majority of the parcel identified as area '6' on the attached land ownership plan. So far as it is relevant, this submission should be read in conjunction with the views expressed at Candidate Sites stage by a consortium of landowners that included the family group represented here.

This representation is submitted having regard to the extensive discussions that have taken place between landowners, including the Council, and the local planning authority over an extended period of time.

Support for Proposed Allocation

The family group represented wholeheartedly supports the proposed allocation of some 8.8 hectares for Employment/Mixed Use (business, retail and education uses). This is consistent with the fact that the employment element of the existing local development plan (LDP) allocation for the site is recognised regionally as a Strategic Employment Site. It is identified as such in the North Wales Economic Ambition Board document 'The Growth Vision for the Economy of North Wales.'

The need that the local education authority has for a site capable of amalgamating a number of existing schools into a combined facility (with this site having been identified as appropriate as part of mixed-use development coming forward) is acknowledged.

There is of course frustration that lack of progress on town centre highways works has stymied the prospect of any proposal for comprehensive residential-led development coming forward, consistent with the current LPD policy allocation for the site.

That said, the family group represented understands the complexities of bringing forward town centre highways improvements and that the highway authority is following protocol in pursuing a Welsh Transport Appraisal Guidance (WelTAG) approach to arriving at an ultimate preferred solution for improvement.

It is agreed that the prospects at Examination of an appointed Inspector accepting a repeat housing-led allocation are limited. This is given the limited progress made on site since adoption of the current LDP in 2013, save for delivery by Anwyl Homes on a part of the wider site to which access is taken from St George Road. This, and a number of other planning permissions locally, have seemingly accounted for any existing surplus capacity in the local highway network necessary to support new residential development in Abergele.

It is very encouraging that Atkins, advising the Council on highways capacity matters, has concluded that there is potentially scope for commercial and/or education development at the site coming forward in advance of any town centre highway interventions taking place. The employment land and retail evidence base informing plan preparation also provide justification for an allocation of commercial uses.

This is not the time to determine the precise site composition or distribution of commercial use typologies across the area proposed to be allocated. That demands a masterplanning exercise. The Council should not seek to compartmentalise the proposed allocation, rather leave the distribution of uses across the site to be determined at a later stage.

It is noted that the supporting text to the proposed policy allocation states that:

'Officers are currently in discussions with developers and landowners to produce a masterplan for the northern- most parcels of land'.

The masterplanning exercise should not be limited to the northern-most parcels of land. The proposed allocation is for Strategic Employment/Mixed Use development. Delivery of such demands a comprehensive approach to masterplanning the entirety of the site proposed to be covered by the LDP allocation.

The right to amend, add to or withdraw this representation is reserved