Preferred Strategy

Ended on the 20 September 2019

Healthy and Social Places in Conwy

Introduction

4.1.1 Social Places in Conwy will be contributed to by providing well-connected cohesive communities for all sectors of society. This will be achieved by allowing everyone to have a good quality of life by living in strong and safe communities, promoting inclusive developments and by improving access to key services and recreation facilities. The Preferred Strategy approach will support people to adopt healthy lifestyles, secure socially inclusive development and more cohesive communities. This section sets the strategic direction for Transport, Housing, Retail & Commercial Centres, Community Facilities and Recreational Spaces.

Sustainable Transport and Accessibility

4.2.1 Strategic Objective 6 (SO6): Deliver sustainable development and seek to tackle the causes of climate change by extending the choice of sustainable transport to enable Conwy's communities to access jobs and key services through the promotion of shorter and more active and efficient walking, cycling and public transport use and by influencing the location, scale, density, mix of uses and design of new development.

(1) Strategic Policy SP/14Sustainable Transport and Accessibility

A Sustainable Transport and Accessibility network will be promoted to support sustainable development, encourage a change in travel behaviour, increase physical activity, improve health and tackle the causes of climate change and airborne pollution. The Plan promotes an integrated, accessible, reliable, efficient, safe and sustainable transport network for all in line with the Sustainable Transport Hierarchy. This will be achieved by:

  1. Siting development in line with Strategic Policy 4: Growth Distribution and Hierarchy of Settlements where they can be easily accessed by sustainable modes of travel and without the need for a car;
  2. Prioritising the Sustainable Transport Hierarchy in all developments.
  3. Creating well designed, people oriented schemes that maximise accessibility by walking, cycling and public transport, by prioritising the provision of on-site infrastructure and, where necessary, mitigating transport impacts through the provision of off-site measures, including active travel routes, green infrastructure networks, bus priority infrastructure and financial support for public transport services.
  4. Contributing to a sustainable network management by making the best use of the available and planned capacity over the Plan period.
  5. Influencing how people chose to travel choice by taking a design-led approach to schemes which ensures an appropriate level of car parking is integrated in a way which does not dominate the development. Car parking provision will be informed by the local context, including public transport accessibility, urban design principles and the objective of reducing reliance on the private car and supporting the modal shift to walking, cycling and public transport and the use of Ultra Low Emission Vehicles (ULEVs) charging points.
  6. Prioritising sustainable transport hierarchy through the promotion of Active Travel and the Councils Integrated Network Map. The Plan will identify, safeguard and support delivery of the active travel routes and networks.
  7. Supporting the movement of freight by rail by safeguarding rail fright facilities and land at Llandudno Junction and Penmaenmawr
  8. Working with partners to deliver the North Wales Transport Plan (regional and local priorities for Conwy, in particular, encouraging interchange facilities, park and ride and improving capacity and movement within towns such as Abergele

(1) 4.2.2 Topic Paper 8 introduced the issues relating to Transport within the Plan Area and this stage builds on that piece of work to inform a strategic approach. The provision of sustainable transport infrastructure is essential in order to build prosperity, tackle climate change, reduce airborne pollution, and to improve the social, economic, environmental and cultural well-being of Wales.

4.2.3 The key aim is to enable people to access jobs and services through shorter, more efficient and sustainable journeys, by walking, cycling and public transport. By influencing the location, scale, density, mix of uses and design of new development, the planning system can improve choice in transport and secure accessibility in a way which supports sustainable development, increases physical activity, improves health and helps to tackle the causes of climate change and airborne pollution by:

  • Enabling more sustainable travel choices - measures to increase walking, cycling and public transport, reduce dependency on the car for daily travel;
  • Network management - measures to make best use of the available capacity, supported by targeted new infrastructure; and
  • Demand management - the application of strategies and policies to reduce travel demand, specifically that of single-occupancy private vehicles.

4.2.4 Delivering the Objectives and Strategic Policy

Land use and transport planning must be integrated. The planning system must ensure it enables integration:

  • within and between different types of transport;
  • between transport measures and land use planning;
  • between transport measures and policies to protect and improve the environment; and
  • between transport measures and policies for education, health, social inclusion and wealth creation.

4.2.5 The RLDP will identify and include policies and proposals relating to the development of transport infrastructure and related services (such as public transport interchange facilities, rail facilities and ports), including areas safeguarded for future transport infrastructure / routes. The route of proposed or improved infrastructure will be shown in the RLDP proposals map. When the precise route is not known, a safeguarding policy may be applied to the area of land necessary for the scheme.

4.2.6 Key Strategic Transport Issues

  • 74% of Conwy 's working residents work within the county borough, 94% work within Wales and 6 % out-commute.
  • The amount of traffic on Conwy's roads is increasing, especially seasonally.
  • Travel on rail and bus services has increased from 289,620 (2006-2007) to 313,033 (2016-17)
  • Recreational cycling is increasing as is commuting by bicycle.
  • The population in Conwy is ageing at a faster rate when compared with much of the rest of Wales.
  • North Wales Joint Transport Plan (NWJTP) provides the basis for transport project development in the area and the RLDP seeks to aid in bringing forward those projects with links to new development.
  • The approach to Green Infrastructure is outlined in PPW 10 and will form an integral part of forward planning and site integration.

4.2.7 It is clear that significant contextual changes have taken place in respect of regional transport ambitions since the adoption of the existing LDP, however, this stage allows a complete replacement LDP to put forward an updated evidence base, strategy and provide an opportunity for stakeholder involvement.

4.2.8 What is the Preferred Strategy and RLDP seeking to achieve?

In the case of no LDP then there would be still be transport development in terms of the NWJTP, national-scale schemes and Active Travel requirements. The Preferred Strategy allows for significant integration and aligned working on timescales with other development and strategies resulting in wider benefit in achieving better integration of development, sharing costs and more efficient use of resources.

4.2.9 Integrated Planning and Transport Strategies

The RLDP will set out an integrated planning and transport strategy setting out how the authority will:

  • integrate and co-ordinate sustainable transport and land use planning;
  • facilitate and promote accessibility for all;
  • reduce the need to travel;
  • reduce dependency on private vehicles;
  • prioritise and support walking, cycling and use of public transport;
  • support the uptake of Ultra Low Emission Vehicles;
  • reduce transport related airborne pollution; and
  • facilitate the provision of transport infrastructure and necessary sustainable transport improvements and development.

4.2.10 Strategic Policy 14 will contribute towards this in further detail and criteria based policy will be developed in line with the approach of the PPW Transport Hierarchy ( see Figure 4: Transport Hierarchy. The North Wales Joint Transport Plan (NWJTP) is the Local Transport Plan (LTP) which sets out policies for the promotion and encouragement of safe and efficient transport and the implementation of the Wales Transport Strategy in the Plan Area. The transport planning framework requires an integrated approach between national, regional and local priorities. Transport schemes within the NWJTP which are likely to come forward within the Plan Period will be identified in the RLDP.

4.2.11 Settlements and growth

The RLDP categorises settlements into a hierarchy which reflects their relative sustainability. The Plan's aspiration of minimising the need to travel, particularly by private motor car (especially those using traditional fuels), and its contributory role towards the facilitation of an integrated transport strategy seeks to direct development to appropriate locations which serve to achieve this. The strategy has regard to the highway and rail network along with accessibility to public transport and the potential for growth of settlements reflecting levels of accessibility which will be considered as part of the Deposit LDP.

4.2.12 Careful consideration has been given to the allocation of new strategic sites, which are likely to generate locally significant levels of movement, ensuring that access provisions which promote walking and cycling, as well as by public transport, are included from the outset and that any implications associated with airborne pollution can be addressed.

4.2.13 Due to the diversity of the Plan Area, accessibility and the aim of reducing the need to travel (and associated CO2 emissions) remain a challenge for a large part of Conwy, particularly when addressing the need to sustain rural areas and ensure that their communities do not suffer social exclusion. This must also relate to a realistic acceptance that the motor car remains an important means of travel in such areas. Minimising travel may also be possible through an integrated transport strategy involving local initiatives in order to aid the development of self-sustaining communities (including the availability of services and facilities).

Figure 4: Transport Hierarchy

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4.2.14 Public Transport

The RLDP will promote and facilitate the provision of high quality public transport infrastructure and set out policies to increase the use of public transport. It will identify and facilitate appropriate public transport routes, measures and facilities taking into account proposals in the Local Transport Plan, which could include improved facilities for bus passengers, park and ride schemes, new rail lines (including light rail), the re-opening of rail lines, the provision of new stations, and enhanced passenger services on existing lines.

4.2.15 The Local Transport Plan takes into account the need for additional interchange sites and improvements to existing public transport interchanges, including measures to promote personal safety. In rural areas, interchange sites will be identified at nodes where the transfer between local and long distance public transport services can take place. The Council will also safeguard existing public transport interchanges from development that would compromise their continued use.

4.2.16 Active Travel

The Active Travel (Wales) Act 2013 makes walking and cycling the preferred option for shorter journeys, particularly everyday journeys, such as to and from a workplace or education establishment, or in order to access health, leisure or other services or facilities. In line with the Active Travel Act the Council has produced Integrated Network Maps, identifying the walking and cycling routes required to create fully integrated networks for walking and cycling to access work, education, services and facilities. The Active Travel Act is complemented by statutory Design Guidance. The guidance sets out the standards expected of new and improved active travel infrastructure in Wales, including related facilities, and the considerations to be taken into account when choosing the design solutions for particular routes and sites.

4.2.17 The RLDP and Preferred Strategy identifies and safeguards active travel routes and networks, including those identified in the Integrated Network Maps (INMs) required by the Active Travel Act, and supports their delivery. As part of the selection of future development sites, priority has been given to sites which can be readily connected to existing active travel routes or future networks. New development will aim to be integrated with active travel networks and contribute to their expansion and improvement. This will be achieved through the inclusion of well-designed routes and facilities as part of the schemes and financial contributions to pay for off-site connections.

4.2.18 An Active Travel Plan will be developed through a Background Paper. It will help integrate the delivery of the ERM / INM routes in the LDP process and future development. Additional benefits will also be achieved through Green Infrastructure planning. Active Travel Wales Existing Route Map (ERM) / INM information and routes are available in the links below .

4.2.19 Transport and Direct Health Impacts

Planning authorities have a role to play in the prevention of physical and mental illnesses caused, or exacerbated, by pollution, disconnection of people from social activities (which contributes to loneliness) as well as the promotion of travel patterns which facilitate active lifestyles. The RLDP will consider the impacts of new development on existing communities and maximise health protection and well-being and safeguard local amenity.

4.2.20 Green Infrastructure

This will be covered under key theme: 'Distinctive and Natural Places', in further detail although has linked objectives around how sustainable transport and Active Travel goals can be integrated into the plan area with wider environmental and heath benefits. This will entail collaborative working in line with the SA/SEA, HRA, landscape assessment and a balanced need for sustainable growth and distribution of housing and employment sites. Detailed policy will also be developed and included in the RLDP in relation to bringing forward recommendations outline in the Green Infrastructure Assessment.

4.2.21 The provision of Ultra Low Emission Vehicles (ULEVs) and charging points will be encouraged and supported through the LDP as part of new development. Where car parking is provided for new non-residential development, the LDP will seek a minimum of 10% of car parking spaces to have ULEV charging points. The Council will also prepare a ULEV Strategy which will complement the aspirations of ULEV ambitions in the RLDP.

(1) 4.2.22 Freight

Sustainable freight transport options will be safeguarded and promoted, including the potential for the carriage of freight by rail, water or pipeline rather than by road. The RLDP will identify and protect areas for the sustainable movement of freight. The Council will consider which routes are most suitable for use by road freight and encourage the location or relocation of distribution and operating centres to sites which have good access to these routes. The same applies to other developments generating frequent road freight movements. Wherever possible, new facilities should be located adjacent to railways and/or ports to promote modal transfer. The feasibility of developing HGV hubs along the key main routes will also be considered jointly with neighbouring authorities, where goods would be transferred to LGVs for the last leg of the freight journey.

4.2.23 Car Parking

Car parking provision is a major influence on how people choose to travel and the pattern of development. Where and how cars are parked can in turn be a major factor in the quality of a place.

4.2.24 A design-led approach to the provision of car parking will be taken in the Deposit RLDP, which ensures an appropriate level of car parking is integrated in a way which does not dominate the development. Parking provision should be informed by the local context, including public transport accessibility, urban design principles and the objective of reducing reliance on the private car and supporting a modal shift to walking, cycling and public transport. The Deposit RLDP will provide policy which supports schemes which keep parking levels down, especially off-street parking, when well designed. The needs of disabled people must be recognised and adequate parking provided for them.

4.2.25 The Deposit will require good standards of car parking design, which do not allow vehicles to dominate the street or inconvenience people walking and cycling. Car parking should be overlooked by surrounding properties, to provide natural surveillance.

(1) 4.2.26 Active Travel Allocations

Active Travel Routes as shown on the ERM / INM and LTP will be allocated and developed. These include:

  • Link road from McDonalds to Belgrano
  • Bus lane improvement at Kinmel Bay traffic lights
  • Llandudno Junction railway access improvements including bridge link
  • Gors Road, Towyn Road and Active Travel Improvements
  • A547 active travel improvement between Borth Cross Road and Rhuddlan (joint work with DCC)
  • A470 active travel links between Llanrwst and Betws-y-Coed (joint work with SNPA).

Map 7: Proposed Strategic Projects

map%207

Housing

4.3.1 Strategic Objective 2 (SO2): Promote a holistic and co-located employment and housing growth strategy by delivering new homes, including affordable homes and gypsy and traveller accommodation needs in sustainable and accessible locations, and ensuring that the right range of housing types, sizes and tenure are brought forward alongside the necessary community infrastructure.

(3) Strategic Policy SP/15Housing

  1. Over the Plan Period 2018 - 2033 the RLDP will provide for the future growth of the economy and housing requirement by providing approximately 4,300 (+20% contingency) new homes to meet an identified need.
  2. Strategic Sites are identified in the following locations for residential and mixed-use development;
  • Llanrhos
  • Llanfairfechan
  • Old Colwyn
  • Llanrwst

Further sites will be allocated in the Deposit plan to meet the total housing requirement.

  1. The RLDP will seek to maximise contribution to Affordable Housing (AH) delivery (1,800 affordable homes over the Plan Period comprising 1000 new-build affordable homes, policy mechanisms and Council initiatives) through the use of a split policy based on housing market areas, and a flexible approach to supporting AH in smaller settlements linked to evidenced needs and sustainability of villages as identified in the settlement hierarchy.
  2. Land will be allocated to meet the identified need for Gypsy & Traveller accommodation. A criteria based policy for assessing additional sites, subject to need, will also be included.
  3. The Deposit RLDP will include further policies relating to rural conversions, rural enterprise dwellings and sites for Self-Build Wales.

(1) 4.3.2 Delivering the Objective and Strategic Policy

The existing LDP used a period of exceptionally high growth to project forward despite the impact of the subsequent recession on house prices and completions in Conwy being clear. This was an unrealistic target bearing in mind the state of the housing market in North Wales and, therefore, with each year that CCBC has failed to reach the housing target, the annual housing requirement for the remainder of the CLDP period increases, much the same as many LPA's in Wales.

4.3.3 In creating active and social places in Conwy the RLDP will align with the Well-Being of Future Generations Act 2015, National Sustainable Placemaking Outcomes, SA/SEA, Equality and Welsh Language impacts. In addition, the RLDP will consider the implications of the most up-to-date population and household projections, the Local Housing Market Assessment (LHMA) and the jobs growth impacts associated with the Conwy Employment Land Review (ELR) and the regional economic drivers promoted in the North Wales Growth Deal in determining sustainable levels of housing and employment growth.

4.3.4 The delivery of housing, both open market and affordable, has been the main housing issue since the adoption of the CLDP, as annual housebuilding has consistently fallen below targets. This has been highlighted in JHLAS reports and AMRs over several years and has been caused by a number of factors including the national economy and local factors such as land disposal, site delivery/viability and house building capacity. Such factors have resulted in Conwy currently having a 3.1 year housing land supply figure.

(1) 4.3.5 Many of Conwy's coastal towns are constrained by flood risk areas as identified by TAN15: 'Development & Flood Risk' Development Advice Maps and within which new, highly vulnerable development, such as housing, is restricted. Whilst the precautionary principle and approach to development in flood risk areas is still overriding, PPW 10 includes flood risk in its definition of 'de-risking development' and there is further recognition of the role that naturalistic flood defence can play. Further policy strengthening of de-risking development would enable technically unconstrained, suitable sites to come forward providing regeneration benefits in areas that were previously sterilised and enabling natural growth of such communities.

4.3.6 To assist and inform the Growth Distribution Options CCBC commissioned a study to look at 'Development Potential in the East of the County Borough' to assess flood risk and the potential to deliver innovative design solutions to accommodate housing growth to the East of the County Borough. The study concludes that vulnerable development in known flood risk areas is unlikely to come forward without significant flood defence work. Therefore, presently it is unlikely that any Flood Consequence Assessment would demonstrate that the onset of flooding when taking into account climate change and possible breaches of defences would be compliant with TAN15.

4.3.7 The key strategic areas to be addressed are:

Housing Growth
The RLDP will provide for the future growth of the economy and housing requirement by providing approximately 4,300 (+20% contingency = approx. 5,150) new homes to meet an identified need.

4.3.8 The Conwy RLDP growth strategy is consistent with PPW10, the Well-Being of Future Generations Act, the Conwy & Denbighshire Well-being Plan and the background evidence and Sustainability Appraisal report which have identified the priority issues, aspirations and objectives that the Plan will be working to.

4.3.9 In addition, the WG Minister confirmed that Local Planning Authorities must provide for a level of housing that is based upon all sources of evidence rather than just WG household projections. The Council is therefore required to determine a figure based on the emerging evidence base and a variety of relevant issues and considerations. For example, the growth options need to consider how they can contribute sustainably to delivering the jobs requirement and the identified affordable housing needs. In addition, the growth options need to be considered against past delivery and the overall capacity of the construction industry to deliver growth.

4.3.10 The Growth Level Options Report (BP/01 - 2018) examines Conwy's demographic trends and sets out the options for growth and how these potentially affect population totals and structures and housing and employment land requirements. A number of factors were scrutinised in the Report including demographic profile, economic growth, past housing completion rates and the Council's aspirations for the RLDP.

4.3.11 The proposed housing growth level will be in the region of 4,300 houses (+ 20% contingency = 5,150). Taking into account windfall and current supply of committed housing sites, we are looking at approximately 2,550 new dwellings on allocated sites. In terms of Affordable Housing this will equate to approx. 1800 new affordable homes over the Plan Period, consisting of new build, policy mechanisms and Council initiatives.

Table 5: Housing supply for the Conwy RLDP
(Position at 1st April 2018, refer to BP07: Housing Land Supply for further detail).
Please note: Figures are rounded to avoid implications of precision that do not exist in practice. Numbers are summed before rounding, so individual figures in tables may not add to the row or column totals.

Windfall

Allocations

Strategy Area

Sub Area

Commitments

Small

Large

Strategic

Non-strategic

TOTAL

Coastal Development Strategy Area

West

50

100

50

400

50

600

Creuddyn

200

350

150

250

550

1,550

Central

250

400

250

450

450

1,800

East

300

100

150

0

150

700

Total

800

950

600

1,100

1,200

4,650

Rural Development Strategy Area

50

250

0

200

50

500

GRAND TOTAL

850

1,200

600

1,300

1,250

5,150

(2) 4.3.12 Evidence shows that out-migration of the early working age population in Conwy presents an issue with retaining its young adult population. As a result there is a need to ensure that the RLDP seeks to deliver the housing needs of an aging population, but at the same time ensuring that new homes seek to retain the younger population. The housing types (including adapted living), sizes and tenure set out in the LHMA will be examined and promoted through the Plan.

4.3.13 Every effort will be made to ensure that the RLDP contains sufficient housing land to meet the anticipated housing requirements over the Plan Period, however in the event that the land supply should fall below 5 years, the LDP will set out an approach to increasing housing land supply.

4.3.14

Allocated Housing Sites

Strategic Sites are identified in the following locations for residential and mixed-use development;

  • Llanrhos
  • Llanfairfechan
  • Old Colwyn
  • Llanrwst
Further sites will be allocated in the Deposit plan to meet the total housing requirement.

Residential development is to be focussed on the strategic growth area(s) of Llanrhos, Old Colwyn, Llanfairfechan and Llanrwst as a Key Service Centre, with further development distributed across the Plan Area in line with the Growth Strategy and Settlement Hierarchy. The Plan will also allocate further sites in the Tier 1 Main Villages to meet the identified housing need.

4.3.15 The settlement hierarchy option reflects the Wales Spatial Plan approach together with the accessibility and sustainability of current rural locations to urban areas, especially those in close proximity to the A55 corridor. These settlements may not have a full suite of facilities themselves however their close proximity to key and secondary settlements allows considerable interrelations for services. The approach reflects the constraints to the east of the County and promotes a new Settlement Hierarchy that would potentially have the necessary capacity and available infrastructure to contribute to sustainable development. Llanrwst is considered unique within the county being a Key Service Centre which is a main town for several outlying villages, both within and outside of the Plan Area.

4.3.16 The average annual delivery, as identified in Conwy Housing Land Availability Studies, over the past 5 years is 244 homes, with highest delivery being 320 new homes in 2017-18. Higher levels have been achieved in pre-recession years as shown in the diagram below. The growth level applied in the RLDP takes into account the capacity of the home building industry to deliver and is in line with BP14: Capacity of the Housebuilding Industry and historic build trends.

graph%201

(1) 4.3.17 The existing CLDP includes allocated sites for which there is uncertainty over when they may come forward, and in some instances whether they will be realistically able to be delivered during the Plan Period. The reasons for this uncertainty are varied, and may include:

  • Landowner intentions;
  • Publicly owned land (including local authority and WG) for which there is no disposal strategy or for which disposal is likely to be outside of a five year period;
  • Sites that have been 'rolled over' from Unitary Development Plans; and
  • Sites that are included for their wider regenerative role, but which are likely to be complex and costly in terms of bringing forward.

4.3.18 Therefore, in line with PPW, any existing housing allocations that have experienced deliverability issues may be excluded from the RLDP and more appropriate sites considered.

(1) 4.3.19 Site delivery, and particularly site viability, has been a national problem as highlighted by WG's Longitudinal Viability Study of the Planning Process (2017) and PPW10. To address this, CCBC will require site promoters/landowners to submit viability appraisals based on methodology and requirements identified by the LPA as part of a phased candidate site assessment process of the RLDP. Background Paper (BP) 06 - 'Site Delivery Assessment' includes a full assessment of all 'candidate sites' submitted to identify the most suitable and deliverable sites for inclusion in the RLDP.

4.3.20 The success of the RLDP policy approach to deliver affordable housing requires not only flexibility from the LPA but also a greater awareness from landowners and developers when negotiating land purchase or option costs in the future. The RLDP includes a policy assumption that land has been purchased at the right price, taking account of all development costs including policy requirements. Deviation from policy would only be agreed in exceptional circumstances and subject to the submission of viability evidence in an open book approach.

4.3.21 Recent changes to the Acceptable Cost Guidance (ACG) from WG will affect the viability and therefore delivery of affordable housing going forwards. The ACG has increased for all units, and has been split with a higher value for smaller sites of 10 and fewer dwellings than for larger sites. This change should work to improve financial viability on sites, allowing private developers to build more affordable dwellings within housing sites, and encourage landowners to bring forward sites for affordable housing.

(1) 4.3.22 In contrast, changes to Building Regulations Part M have increased build costs, requiring all new dwellings, including conversions, to have fire sprinklers installed. The recent introduction of mandatory sustainable drainage systems (SuDS) for surface water disposal will also increase development costs.

(1) 4.3.23 The above considerations are relevant to all developments nationally, however the impacts of these changes on viability and housing delivery will need to be considered at a local level. The Affordable Housing Viability Study takes account of these, and other relevant viability issues.

(2) 4.3.24

Affordable Housing

Within the boundaries of the urban settlements, Tier 1 Main Villages and the Key Service Centre, all residential developments providing a net gain of 3 or more dwellings will be required to contribute to affordable housing.

The preference is normally for on-site delivery of affordable housing, but this may not always be possible or appropriate. For sites of 3-5 dwellings, a commuted sum in lieu of on-site affordable housing will be accepted. For sites of 6-9 dwellings, a commuted sum may be acceptable subject to sufficient justification. On-site affordable housing is expected on all sites for 10 or more dwellings, except in exceptional circumstances due to viability, or when a commuted sum is requested by CCBC Housing Strategy in lieu of on-site AH.

On-site affordable housing should be provided in accordance with a split policy approach which will be detailed in the Deposit Plan, and will be based on the viability assessment linked to the variations in the housing market across the authority.

Lower levels of affordable housing will only be allowed in exceptional circumstances. Such exceptions could include instances where land development costs are significantly higher than other sites, even allowing for lower land value, or where additional, unknown and significant abnormal costs are uncovered during development.

On suitable sites outside but adjoining the settlement boundaries of the urban settlements, Tier 1 Main Villages and the Key Service Centre, small-scale residential development will be permitted, subject to a minimum provision of 50% affordable housing, and a maximum site size of 20 dwellings.

To support the delivery of affordable housing, small sites delivering a minimum of 50% AH units will be permitted on suitable sites within Tier 2 Main Villages, Minor Villages and Hamlets. Such sites must be well located in relation to the existing settlement, comprising infilling or rounding off. The sites should provide a maximum of 15 dwellings in Tier 2 Main Villages; 10 dwellings in Minor Villages and 5 dwellings in Hamlets. The AH proposed as part of such a scheme should be provided to meet an evidenced local need for affordable housing in the settlement. The affordable housing must be subject to a legal agreement to control occupancy in perpetuity. Where open market housing is provided on the site, the legal agreement must also ensure timely delivery of the affordable housing.

Single open market units may be permitted in exceptional cases on infill plots in Tier 2 Main Villages, Minor Villages and Hamlets, which due to their size or site-specific constraints are incapable of providing more than one dwelling, and would be unviable to develop as a single affordable dwelling. They must otherwise be suitable for development in line with local and national policies and permission will be subject to payment of a commuted sum in lieu of on-site affordable housing.

As an exception to the housing policy, small sites for 100% AH will be permitted outside of, but adjoining existing Tier 2 Villages, Minor Villages and Hamlets. Such sites must reflect the type and tenure of affordable housing need in the local area and comply with all other LDP policies.

The provision of affordable housing is a complex problem with many elements that affect new build deliverability being outside the sphere of influence of the local planning authority. Even within the planning system, the powers of local planning authorities are limited. However, RLDP evidence identifies a need for approximately 1800 affordable homes over the Plan Period (approx. 120 pa). The Plan proposes to deliver approximately 1000 new affordable homes from new build and a further 800 from policy mechanisms and Council initiatives as shown in table 6 (table below):

Table 6: Affordable Housing Supply for the Conwy RLDP

RLDP Strategic Areas

Affordable Housing Percentages

Commitments

Windfall

Allocations

TOTAL

Small

Large

Strategic

Non-strategic

West

20%

0

20

10

80

10

120

Creuddyn

30%

66

105

45

75

165

456

Central

20%

8

80

50

90

90

318

East

15% (Abergele)

16

15

22

0

22

75

COASTAL TOTAL

90

220

127

245

287

969

Rural

20% in Llanrwst and higher in other rural areas as per policy)

0

100

0

40

10

150

TOTAL FOR NEW BUILD

90

320

127

285

297

1119

SUPPLY FROM POLICY MECHANISMS AND COUNCIL INITIATIVES

681

GRAND TOTAL

1800

4.3.25 The affordable housing requirement for Conwy is based on the evidence in Background Papers 10: Affordable Housing Viability Study and BP11: Affordable Housing Need Calculation and the Local Housing Market Assessment (LHMA). The Affordable Housing Need Calculation considers both the affordable needs calculation as laid out in the Council's 2017-22 Local Housing Market Assessment (LHMA) and the potential outcomes from adopting the new Welsh Government methodology for calculating housing need.

4.3.26 A percentage split affordable housing requirement, as informed by the Affordable Housing Viability Study, will be included in the RLDP, taking account of the variation in house prices across the Plan Area, viability considerations and PPW guidance. The Study advises on achievable and viable targets and thresholds for affordable housing which fully reflect the availability of a range of finance towards affordable housing and reflects priority infrastructure needs. The Study also assesses other potential options for increasing affordable housing levels which will inform later policy.

Sub Market

Target

Conwy & Conwy Valley

30%

Llandudno, Penrhyn Bay, Llandrillo & Rhos-on-Sea

30%

Rural South, East & West

20%

Colwyn Bay & Old Colwyn

20%

Penmaenmawr & Llanfairfechan

20%

Abergele

15%

Towyn & Kinmel Bay

0%

(1) 4.3.27 It is acknowledged that the affordable housing need requirement isn't just reliant on building new homes. As well as providing new affordable housing, there are a variety of other ways of helping these households which don't require new building - for example through placement within existing social housing stock; the provision of supported purchase schemes such as that provided through the First Steps register; the conversion or adaptation of existing stock to better meet tenants' needs and through financial support to rent within the private sector (housing benefit). This does not negate the need to provide a significantly greater number of affordable housing options but suggests that methods other than building new housing for social and intermediate tenure need to be employed to meet this need.

4.3.28 The policy outlines housing delivery in Tier 2 Main Villages, Minor Villages and Hamlets. The approach proposes a flexible policy to permit residential development on suitable small sites within and/or adjoining rural settlements. Development proposals should be driven by affordable housing to meet identified local need. Market units will be permitted to support delivery of the site, but AHLN must form at least 50% of housing built on the site and there must be secure mechanisms in place to ensure timely delivery of the AH units and retained thereafter.

4.3.29 Whilst PPW10 says that 'affordable housing exception sites are not appropriate for market housing' it also states 'the provision of affordable housing exception sites must be considered to help meet identified requirements and ensure the viability of the local community'. It is clearly apparent in Conwy that without a flexible approach allowing an element of open market units on suitable sites within or adjoining Tier 2 Main Villages, Minor Villages and Hamlets such sites are unlikely to come forward due to being unviable resulting in an identified need remaining unmet.

(1) 4.3.30 The RLDP Rural Development Strategy Area will promote a sustainable rural economy and aims to contribute to the provision of AHLN in the main villages, minor villages and hamlets. Low market value areas and difficulties obtaining finance for affordable housing have been two of the issues restricting the delivery of rural housing. It is anticipated that new and improved housing policies will assist with rural housing needs whilst at the same time conserving the natural and built character.

(2) 4.3.31

Gypsy & Traveller provision

Land will be allocated to meet the identified need for Gypsy & Traveller accommodation.

A criteria based policy for assessing additional sites, subject to need, will be required.

Conwy needs to ensure that appropriate mechanisms are in place to accommodate any identified need for gypsies and travellers. The current residential Gypsy & Traveller need for Conwy has been met through the construction of a permanent site on the outskirts of Conwy town. The Conwy GTAA (2017 - 2022) concludes that the RLDP should promote land to accommodate a transit site for 7 pitches. Planning Authorities are required to allocate suitable sites to meet an identified need to be included at deposit stage of the RLDP (i.e. January 2020). CCBC have undertaken a 'call for sites' and the Deposit Plan will include an allocated transit site for Gypsy & Travellers; in addition a criteria-based policy will support the provision of other sites to meet newly arising need as may be identified in future Gypsy & Traveller Accommodation Needs Assessments.

Retail and Commercial Centres

4.4.1 Strategic Objective 3 (SO3): Achieve vibrant, attractive and viable town and commercial centres in Conwy by redefining their role and by encouraging a diversity of activities and uses.

(2) Strategic Policy SP/16Retail

Retail and commercial centres in Conwy will be the hubs of social and economic activity and the focal point for a diverse range of services which support the needs of local communities. This will be encouraged by:

  1. Establishing a hierarchy for retail centres, which will guide the location of new retail development;
  2. Allocated land for retail use to meet identified need set out in the Conwy Retail Study;
  3. Providing criteria based policies for new retail proposals on unallocated sites and for changes of use in town centres;
  4. Designating Primary Shopping Area and Shopping Zone boundaries;
  5. Encouraging the retention of retail facilities outside of the Sub-Regional and Town Centres will be encouraged;
  6. Safeguarding the specific retail function of Parc Llandudno and Mostyn Champneys Retail Parks and the leisure function of Llandudno Junction Leisure Park
  7. Encouraging high quality Shopping Street Frontages and Shop Front Security.

4.4.2 Retail centres are social and economic hubs of activity. They contain a wide range of services and uses, including employment, education, civic identity and opportunities for social interaction. These support both the needs of the local community, and in the case of the larger centres, the wider community too.

(1) 4.4.3 Para 4.3.10 of PPW requires planning authorities to establish a retail and commercial centre hierarchy. The centres in the RLDP area are identified below. They have been categorised according to guidance in para 4.3.12 of PPW and Section 4 of TAN4, based on the level of facilities and services that they provide, the catchment areas of their retail offer and the level of population that shop there. Please see Background Paper 26 for more details.

Retail hierarchy

The following retail hierarchy is established:

Sub-Regional Shopping Centre

Llandudno

Town Centres

Abergele

Colwyn Bay

Conwy

Llandudno Junction

Llanrwst

Local Centres

Deganwy

Kinmel Bay

Llanfairfechan

Old Colwyn

Penmaenmawr

Rhos on Sea

West End (Colwyn Bay)

The retail hierarchy is illustrated in Map 8.

Proposals for retail development will be considered in accordance with this hierarchy. Llandudno, as a Sub-Regional Shopping Centre is the favoured location for new retail development, followed by the Town Centres and then the Local Centres.

Any retail proposals outside of these centres will be assessed using a criteria based policy.

4.4.4 New development in the retail centres will need to be in keeping with the scale and function of that centre, and have regard to the centre's position in the hierarchy. Proposals for uses appropriate for a town centre, as defined in PPW para 4.3.21, will need to adopt a sequential approach to development, giving preference to sites in the centre of the Sub-Regional and Town Centres, followed by edge-of-centre sites, and then the Local Centres.

4.4.5 Llandudno is the largest retail centre in the RLDP area and attracts a large number of shoppers and visitors. The sub-regional role of Llandudno will be protected and enhanced to ensure that it remains a sustainable place to live, work and visit.

Meeting retail need

The Abergele Strategic Site is allocated for Mixed-Use including Retail.

Further sites will be allocated in the RLDP Deposit stage to meet identified retail need.

4.4.6 Should evidence base indicate that allocations are required, para 4.38 of PPW requires the most appropriate form, scale and location of provision to meet this need be considered. Improving social, economic, environmental and cultural well-being should also be considered.

Map 8: Retail Hierarchy

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4.4.7 The Conwy Retail Capacity Study (Background Paper 24) outlines that there is a need for further retail development during the RLDP period. The following need is required by area:

Convenience

Comparison

Conwy East

35,000 sq ft (3,252m2)

Conwy Central

20,000 sq ft (1,858m2)

25,000 sq ft (2,323m2)

Conwy North

5,000 sq ft (465m2)

Conwy West

10,000 sq ft (929m2)

Conwy South

15,000 sq ft (1,394m2)

4.4.8 This need has previously been met through the permission granted on the Brickworks site for a retail superstore. This permission, however, expired in May 2019 and has not been renewed. The need identified in the west area of the County Borough has been met by the new Lidl development currently underway in Llandudno Junction.

4.4.9 Allocations will be required in the other areas to meet this identified need. These will be identified at Deposit stage. The location of these allocations will be guided by the sequential approach and the RLDP retail hierarchy. The floorspace proposed on these sites will be flexible, as required by PPW para 4.3.22, to ensure that changing retail demand and opportunity can be accommodated for.

4.4.10

Retail proposals on unallocated sites

Applications for new retail floorspace on unallocated sites will be assessed via a criteria based policy. Applicants will be required to adopt a sequential approach to site selection and, for applications outside of town centres, demonstrate a need for the additional floorspace.

In areas where no retail sites be allocated, PPW para 4.3.9 states that to allow for flexibility, a criteria based policy should be included in development plans which proposals can be assessed against. This approach also allows for any changes to need arising from unanticipated changes in the retail market.

4.4.11

Town centre uses

Boundaries for Primary Shopping Areas and Shopping Zones in the Sub-Regional Centre and Town Centres will be detailed at Deposit stage.

Proposals for a change of use in these designated areas will be subject to a criteria based policy, which will ensure their vibrancy, viability and attractiveness.

Additional guidance is likely to apply for proposals for new hot food takeaway units.

Paras 4.3.30-32 of PPW encourages a mix of uses to deliver vibrant, viable and attractive retail centres, as A1 uses are only part of what secures a centre's vibrancy. Boundaries for Primary Shopping Areas and Shopping Zones will be reviewed and published in Background Paper 27 at Deposit RLDP stage. These will reflect national guidance, where primary areas contain a high proportion of A1 retail uses, and secondary areas a mix of uses. Policies will be included at Deposit stage, which will guide the type of uses that will be considered acceptable in these areas (reflecting guidance in paras 4.3.30-39 of PPW).

(1) 4.4.12 Leisure and entertainment and food and drink uses can benefit retail and commercial centres. Careful regard must be paid to safeguarding amenity when contributing towards an evening economy. Para 3.3.34 of PPW encourages mixed use schemes, which are planned in an appropriate way. It also encourages a vibrant and viable evening economy and night-time economy, and cultural experiences and spaces, which have the potential to contribute positively towards regenerating a centre (paras 4.3.43-48).

4.4.13 Additional guidance for hot food takeaway units could include criteria such as mitigation or protection for neighbouring uses, limitations on the number of units located adjacent each other and exclusion areas around secondary schools.

4.4.14 PPW para 4.3.36 requires that the health of our retail centres be assessed, so that the retail strategy can be informed, and intervened with where necessary. Background Paper 25 has further details. If a centre is considered to be in decline, non-A1 uses can play a role in reducing vacancies and increasing diversity.

4.4.15

Safeguarding retail facilities outside of the Sub Regional and Town Centres

The retention of retail facilities will be encouraged outside of the Sub-Regional and Town Centres. Proposals for the change of use of convenience stores, post offices, petrol stations and public houses will be subject to a criteria based policy.

Local and rural facilities such as those mentioned above play a vital role in sustaining smaller centres and reduce the need for residents to travel to meet every day needs. They contribute towards a sense of place, impacting positively on well-being and amenity of local communities. In smaller villages they also play an important role in supporting those who have difficulty travelling further afield and forming a hub to village life. The Council will encourage the retention of such facilities, in-line with para 4.3.41 of PPW.

4.4.16

Retail park and leisure designations

Proposals at Parc Llandudno and Mostyn Champneys retail parks will be subject to a criteria based policy to protect their specific retail function and the vibrancy, viability and attractiveness of Llandudno town centre.

Proposals at Llandudno Junction Leisure Park will be subject to a criteria based policy to protect its leisure function.

Parc Llandudno and Mostyn Champneys retail parks typically perform a different retail function to Llandudno town centre. Since LDP adoption, there have been proposals to amend goods sold and for A3 units at Mostyn Champneys. The RLDP policy will need amending to ensure clarity for these applications. The retail parks need to be able to attract retailers, but not risk the vibrancy, viability and attractiveness of Llandudno town centre.

4.4.17

Shop front design

There will be a criteria based policy guiding proposals for changes to or new shop fronts.

Shopping street frontage security

There will be a criteria based policy guiding proposals for changes to or new shopping street frontage security.

Shop fronts are critical in forming the character and appearance of shopping frontages. The Council attaches considerable importance to suitably designed shop fronts, not only to preserve the character of buildings, but also to retain the overall attractiveness of streets and to maintain their commercial viability. Inappropriate developments can have a severe detrimental effect not only on the building but also the street scene, and the street's trading potential.

4.4.18 Both customers and shopkeepers benefit if the environment of the street scene is enhanced by well-designed and maintained shop fronts. In villages it will be important to respect the existing street and village character, while in major shopping centres within the urban settlements the emphasis will be on creating and maintaining a quality and vibrant environment. It should be acknowledged that many shop fronts will be located within conservation areas. See Section 5.4 for details.

Community Facilities

4.5.1 Strategic Objective 4 (SO4): Contribute to a sense of place and overall health, wellbeing and amenity of local communities by ensuring that the existing and future population groups have access to a sustainable mix of community facilities.

(1) Strategic Policy SP/17Community Facillities

To contribute to the health, well-being and amenity of local communities the RLDP will:

  1. Enhance and protect Community facilities;
  2. Allocate land for new schools sites will be allocated, and proposals will be supported to meet identified need subject to set criteria.
  3. Protect rural facilities from other uses.
  4. Allocate land for allotments and providing criteria based policies to meet identified need and supporting proposals subject to set criteria
  5. Allocate land for burial grounds and meeting identified need, and proposals supported subject to set criteria.

(1) 4.5.2 Community facilities are key to creating viable and sustainable places. These include schools, cultural facilities, health services, libraries, allotments, burial grounds, leisure centres and places of worship. They can be owned by the public, private and third sector parties.

4.5.3 Para 4.4.2 of PPW requires development plans to take a strategic and long-term approach to the provision of community facilities, ensuring that the requirements of the community continue to be met. Population projections show that Conwy County Borough has an ageing population. The RLDP will support community facilities to accommodate their needs. In addition, new house building will need to ensure that the needs of the new residents for community facilities are met.

4.5.4 Community facilities contribute to a sense of place which is important to the health, well-being and amenity of local communities and their existence is often a key element in creating viable and sustainable communities. Access to these facilities provide an opportunity to be a part of community life helping to create a sense of belonging, which contributes towards cohesive communities. Supporting existing and new community facilities is a key factor in creating active and social places.

4.5.5
New schools sites and allocations
Land is allocated for the purposes of new school sites in the following locations:
  1. Llanfairfechan
  2. Llanrhos
  3. Abergele
Further allocations may be identified for inclusion in the Deposit RLDP.
Proposals for new school sites or extensions to existing schools will be determined in accordance with a criteria based policy to be included in the Deposit Replacement LDP.

The Council is currently working in partnership towards delivering the 21st Century Schools Programme. Band A has been completed and has delivered new schools. Band B is underway and covers April 2019 to March 2024. Bands C and D will follow. The Band B sites will be allocated where land is required. Additional land is likely to be required during the plan period to deliver Bands C and D. For this reason, a criteria based policy will be included.

4.5.6 The capacity of schools proposed under the 21st Century Schools Programme will reflect any new growth in school pupils caused by the RLDP. The change in the population of children proposed in the RLDP and the potential impact on the capacity of primary schools will be assessed and where required, mitigated for, when allocating residential sites.

4.5.7

Health

Proposals for new and extensions to existing primary and secondary care sites, will be supported subject to accordance with a criteria based policy.

Primary and secondary health care sites will need to be able to accommodate the changing population over the RLDP period. Our population is ageing, which puts different pressures on the health service. The population growth proposed in the RLDP and the potential impact on the physical capacity of primary and secondary health care sites will be assessed and where required, mitigated for, when allocating residential sites.

4.5.8

Safeguarding rural facilities

Proposals for the change of use of village and church halls will be determined in accordance with a criteria based policy to be included in the Deposit RLDP.

Rural facilities, including village and church halls can come under threat for other uses and face economic challenges. Access to these is vital to rural communities. To address this, a criteria based policy will be developed as part of the Deposit RLDP. Retail facilities will be covered under a separate section. Please see Section 4.4 Retail for more detail.

4.5.9

New allotments

Land is allocated to meet identified need for allotments in the following locations:

  1. Llanfairfechan
  2. Llanrhos
  3. Old Colwyn
  4. Llanrwst

Further allocations may be identified for inclusion in the Deposit RLDP.

Proposals for further sites or extensions to existing sites will be determined in accordance with a criteria based policy to be included in the Deposit RLDP.

Allotments are an important community resource, which have a wide range of positive benefits. As outlined in para 4.4.3 of PPW, these range from environmental, health, social to economic. They can contribute towards a sense of place and community, can help regenerate community and open spaces, contribute towards food production, provide a habitat for wildlife and have health and wellbeing benefits.

4.5.10 Local authorities have a statutory duty to provide land for allotments to meet locally identified demand. PPW para 4.4.3 states that land should be allocated for allotments. BP30 Allotment Site Demand and Supply Report details that there are a significant number of Conwy's residents on the waiting list for an allotment in all areas of the County Borough. Land is allocated to meet this need as part of the Preferred Strategy.

4.5.11 Further allotment sites may become available during the RLDP period. These sites will be assessed at the time for their suitability using a criteria based policy.

4.5.12

Safeguarding allotments

Existing allotment sites will be protected. Proposals for the change of use of these sites will be determined in accordance with a criteria based policy to be included in the Deposit Replacement LDP.

Para 4.4.3 of PPW requires allotments to be retained and protected, particularly where they are an important part of the green infrastructure or have community value. Statutory allotments have legal protection and Welsh Ministers must consent to their disposal.

4.5.13

New burial grounds

Land will be allocated in the Deposit RLDP to meet identified need for burial grounds.

Proposals for further sites or extensions to existing sites will be determined in accordance with a criteria based policy to be included in the Deposit Replacement LDP.

The initial evidence base for Burial Grounds outlines that there is a need additional burial grounds in the County Borough. Land will be allocated in accordance with this evidence base.

Recreational Spaces

4.6.1 Strategic Objective 5 (SO5): Encourage physical and mental wellbeing through provision and protection of high quality, accessible green spaces and recreation space networks.

Strategic Policy SP/18Recreational Spaces

New residential development will be required to provide for recreational spaces via a criteria based policy.

Land is/will be allocated for recreational spaces, in-line with need identified in the evidence base.

A criteria based policy in the Deposit Plan will apply for the protection of existing recreational spaces.

4.6.2 Recreational spaces serve a dual role, of providing a place for play, sport, activity and relaxation and contribute positively towards quality of life, health and well-being. They also promote nature conservation and biodiversity and contribute towards an areas green infrastructure.

4.6.3 Section 4.5 of PPW requires the RLDP to support the development of sport and recreation, and other forms of public open space. They provide a wide range of leisure pursuits, provide a place to relax and contribute towards quality of life. They encourage physical activity, which contributes towards securing a healthier Wales (goal three in the Well-being of Future Generations Act).

4.6.4 PPW requires that Green Infrastructure network to be identified, managed and expanded in development plans. Recreational spaces are part of this infrastructure. It is important that the RLDP recognises the importance of green infrastructure in delivering local environmental, socio economic and health benefits, which are identified as key issues in the Conwy and Denbighshire Wellbeing Plan.

4.6.5 PPW para 4.5.2 states that standards should be established as part of the RLDP. Local deficiencies should be identified and met through the RLDP standards. Standards below are a guide only and may be higher to reflect the findings of the Recreational Space Assessment once it is complete.

4.6.6

Recreational spaces on new residential developments

Residential development will be required to make provision for recreational spaces. Standards will be developed, based on the Recreational Space Assessment for inclusion in the Deposit RLDP, but they will reflect those recommended by Fields in Trust:

Playing pitches

1.2 hectares per 1,000 population

Outdoor sports

0.4 hectares per 1,000 population

Equipped/designated play areas

0.25 hectares per 1,000 population

Other outdoor provision*

0.3 hectares per 1,000 population

Parks and gardens

0.8 hectares per 1,000 population

Amenity greenspace

0.6 hectares per 1,000 population

*Multi use games areas and skate parks

A threshold of dwelling numbers will be set in the Deposit RLDP that will detail when and which recreational spaces should be delivered on-site.

Fields in Trust guidance also recommends a standard of 2.0 hectares per 1,000 population for natural and semi-natural greenspace. It is likely that there is sufficient levels of this typology in the County Borough, and therefore, additional provision will not normally be required. This will be confirmed through Background Paper 28: Recreational Space Assessment.

4.6.7 To secure on-site delivery or improvements to off-site recreation spaces, the Council may use the following measures:

  • Planning obligations via Section 106 Agreements;
  • Community Infrastructure Levy; and/or,
  • Planning conditions.

(1) 4.6.8 Financial viability will be a consideration. The developer will be responsible for the maintenance of any new recreational spaces in perpetuity.

4.6.9

Recreational space allocations

Land is allocated to meet additional need for recreational spaces on the Strategic Sites in Llanfairfechan, Llanrhos, Old Colwyn, Abergele and Llanrwst.

Further allocations may be identified for inclusion in the Deposit RLDP.

Proposals for further sites or extensions to existing sites will be determined in accordance with a criteria based policy to be included in the Deposit RLDP.

Preliminary findings from the new Recreational Space Assessment indicates that there are deficits of some typologies in the County Borough. To address this, land will be allocated, where available, in the Deposit RLDP. This will be supported by the production of a background paper detailing findings of the Recreational Space Assessment. Land in public, private and third sector ownership will be included in the Assessment, in-line with advice in Fields in Trust guidance and national planning policy.

4.6.10

Safeguarding recreational spaces

Existing recreational space sites will be protected. Proposals for the change of use of these sites will be determined in accordance with a criteria based policy to be included in the Deposit RLDP.

PPW para 4.5.3 states that formal and informal open green spaces should be protected from development. Development of these sites to other uses will not be permitted, unless there is a surplus of that recreational space type in the local community. This is to protect their role in contributing towards the natural environment and health and wellbeing. Parks and gardens may have additional protection if they are an historic asset and listed.

4.6.11 Development of a recreational space in areas of a deficit may be permitted in exceptional circumstances. For example, if alternative provision of equivalent community benefit can be provided in the same community, which reflects the recommended travel times established in Fields in Trust guidance. Or, the development of a small part of the recreational space may be permitted, where it secures the future of that recreational space, and the facilities are improved, providing a community benefit.

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