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Playing Fields (Community Involvement in Disposal Decisions) (Wales) Regulations 2015Notice of Proposed Disposal Land adjacent Ball Road and fronting Llanrumney Hall, Llanrumney, Cardiff
Notice is hereby given that Cardiff Council proposes to dispose of land comprising of part of playing fields adjacent to Ball Road and fronting Llanrumney Hall, Llanrumney, Cardiff, which are considered by the Council to be surplus to requirements.Details of the proposed disposal are available for public inspection in the polytunnels at Llanrumney Hall, Llanrumney, Cardiff, CF3 4JJ during normal office hours for a period of six weeks from 6th January 2021.
Representations relating to the proposed disposal may be made in writing and addressed to Giles Parker, Strategic Estates Manager, Cardiff Council, The Courtyard, County Hall, Cardiff, CF10 4UW or via email to
firstname.lastname@example.org to arrive no later than 4:30pm on 19th February 2021.
Date of Notice: 6th January 2021 Giles Parker, Strategic Estates Manager, Cardiff Council, The Courtyard, Cardiff, CF10 4UW
1.1 Cardiff County Council is proposing to dispose of land comprising playing fields, located adjacent to Llanrumney Hall and Ball Road, Llanrumney. 1.2 Where a Council proposes to dispose of land containing a playing field or part of a playing field, it must have regard to the Playing Fields (Community Involvement in Disposal Decisions) (Wales) Measure 2010 and comply with the procedure set out in the Playing Fields (Community Involvement in Disposal Decisions)(Wales) Regulations 2015. The Regulations require the Council to undertake a process of public consultation and to consider any responses prior to the making of a decision to dispose.
1.3 The primary purpose of the Measure and associated Regulations is to:
1.4 The regulations require that the details of the proposed disposal must be available for inspection and sent to specified consultees or other persons with an interest in the potential disposal.
1.5 If consultees are to respond effectively the regulations require that sufficient information should be provided to enable them to gain a good understanding of the underlying rationale for the proposed disposal and the intended future use of the site. As a minimum, the details of the proposed disposal must include information about the effect a proposed disposal of a playing field would have on any relevant strategies, plans or assessments for the area. 1.6 The assessment should consider how the proposed disposal would impact upon achieving the outcomes contained in these strategies, plans and assessments for the area. 1.7 This statement represents the Council’s underlying ‘rationale’ for the proposed disposal and makes reference to the impact the disposal would have to achieving the outcomes of the following key strategies, plans and assessments for the area:-
2.1 The underlying rationale for the disposal of the playing fields adjacent to Llanrumney Hall is to develop the site for up to 90 new open market dwellings and use the resulting capital receipt to contribute towards the costs of a proposed new link road and bridge connecting the Llanrumney ward to the A48 alongside the Pentwyn Park and Ride site, and to improve local sports facilities at a proposed new Outdoor Sports Complex off Mendip Road Llanrumney.
2.2 The East Cardiff Industrial Strategy was approved by Cardiff’s Cabinet in October 2019. The Strategy identifies transport improvements as a key driver to unlocking access to employment opportunities for local communities in the east of Cardiff.
2.3 The Strategy recognises that economic outcomes in the east of the city, including in the ward of Llanrumney lag behind the rest of Cardiff. Unemployment rates here are substantially higher, with the Llanrumney ward suffering from the highest rate of unemployment in Cardiff - 50% higher than the city average. East Cardiff and Llanrumney also suffer from other high levels of deprivation, as measured by the Welsh Index of Multiple Deprivation – falling within the 10% most deprived areas in Wales. 2.4 Llanrumney is recognised as being significantly disadvantaged by poor road connectivity, particularly constrained at peak times, with all commuter traffic funnelled through Newport Road. Although Llanrumney is located alongside the A48 communities are unable to access this key arterial route – despite there being a dedicated junction (which currently only serves Pentwyn to the north). Llanrumney is also cut off from the City’s main Park and Ride facility adjacent to the same A48 junction. Furthermore, the area has no access to rail services and journeys to the city centre can take up to 1 hour at peak times. 2.5 Set within the context of the East Cardiff Industrial Strategy’s objective of improving connectivity in the east of the city, and in particular, road connectivity in Llanrumney, Cabinet approved the Llanrumney Development Strategy in December 2019. This Strategy proposes the disposal of 3 plots of Council owned land to fund new transport improvements, one of which is the circa 3ac plot adjacent to Ball Road and fronting Llanrumney Hall, which is currently used as a playing field by Llanrumney Rugby Club. It is proposed to dispose of this site to provide up to 90 new open market residential units. This site is the subject of this consultation and assessment, in accordance with the regulations relating to the Playing Fields (Community Involvement in Disposals Decisions) (Wales) Measure 2015.
2.6 In connection with implementing the Llanrumney Development Strategy a further Cabinet report was approved in November 2020 which gave authority to commence the required statutory consultation to dispose of the site and to ring fence the residual capital receipt (over and above the costs of delivering the new link road and bridge) towards delivery of the new Outdoor Sports Complex off Mendip Road (as well as the funding other community initiatives). This proposal involves the relocation of Llanrumney Rugby Club and the building of a new club house / changing rooms at this new sports facility. 2.7 As part of the Llanrumney Development Strategy an informal Masterplan has been produced which illustrates the concept of development relating to 3 earmarked sites for potential development and disposal. The Masterplan delineates the new link road and bridge, the potential residential development on land adjacent to Llanrumney Hall and the location of the replacement playing fields at the new Outdoor Sports Complex off Mendip Road. The Illustrative Masterplan is attached as Appendix 2 to this document.
3.1 The proposed disposal would result in the loss of an existing area of functional open space. As such its potential loss would need to be assessed against Policy C4 of the LDP, relating to the protection of existing open space.
3.2 Policy C4 of the LDP states that:- Development will not be permitted on areas of open space unless:-
3.3 In the context of Policy C4 and in assessing any proposal that involves the loss of open space, the LDP states that regard will also be given to whether the space serves a purely local function – or has more strategic value. Regard will also be given to the ‘quality’ of the open space, in terms of such factors as accessibility, biodiversity, on-site facilities, management and maintenance, its contribution to recreation and its strategic importance.
3.4 Also in the context of Policy C4, where a development involves the loss of open space that would ‘exacerbate’ a deficit in provision of functional open space, then compensatory provision for open space or alternative provision of equivalent community benefit may be acceptable.
3.5 In this regard, the LDP states that appropriateness of the compensatory provision, will be considered in connection with the importance of the resource being lost and the needs of the locality. Any new provision should contribute to community needs and aspirations and be related to the original site, serving the population affected by the loss.
3.6 Additional detailed guidance, in the form of Supplementary Planning Guidance (SPG) informs Policy C4 of the LDP; this is provided in Cardiff’s adopted Green Infrastructure SPG, the Protection and Provision of Open Space Technical Guidance Note and the Planning Obligations SPG. The Planning Obligations SPG states that where a development proposal involves the loss of functional open space, the loss will be mitigated by in-kind provision of and/or a financial contribution towards the provision of compensatory open space / replacement facilities.
3.7 In the context of national planning policy advice, Planning Policy Wales Edition 10, at paragraph 4.54 also states that:- All playing fields, whether owned by public, private or voluntary organisations should be protected from development except where;
3.8 Planning Policy Wales is supplemented by national guidance contained in Technical Advice Note (TAN 16), which provides guidance on the role of planning in providing sport and recreational facilities and informal open spaces. TAN 16 recognises the value of playing fields and open spaces, stating that only where it can be clearly shown there is no deficiency, should the possibility of their use for alternative development be considered and that playing field loss will need to be justified in relation to LDP policies and the findings of local Open Space Assessments.
3.9 TAN 16 recognises that in some circumstances better, or at least equivalent alternative provision can be made available to provide for an area’s needs and that consideration should be given to the proximity and nature of any replacement facility – in particular where the loss affects disadvantaged communities.
3.10 The proposed disposal site is identified as ‘functional open space’ within the ward of Llanrumney. Comprising of (in part) a formal playing field and area of informal recreation by the 2020 Open Space Audit, conducted by the Strategic Planning Department as part of Cardiff Council’s Open Space Assessment.
3.11 Cardiff’s Open Space Standard is 2.43 ha per 1000 population. Of this, the standard for outdoor space suitable for formal sport is 1.2 ha per 1000 population.
3.12 Set against these standards, the Open Space Assessment Audit 2020 for the Llanrumney ward identifies 34.84 hectares of recreational open space (this includes existing formal, informal and children’s play but excludes formal recreational land associated with schools). This open space compares with a requirement of 28.02 hectares, thereby demonstrating an overall surplus of provision in Llanrumney of 6.82 hectares.
3.13 As a subset of this overall assessment, 16.84 hectares of open space in Llanrumney is identified as formal recreational land suitable for outdoor sport, whereas the requirement based on the population of the ward for formal recreation is 13.84 hectares. As such there is a quantitative surplus of 3.00 hectares of formal recreational land. This would be reduced however to approximately 1.8 hectares if the potential disposal site is developed for residential purposes.
3.14 Notwithstanding that the proposed disposal would not exacerbate an existing open space deficiency within the ward of Llanrumney, the loss of the 3 ac (1.214 hectares) disposal site would be more than compensated for by the provision of approximately 12 acres (5 hectares) of additional formal outdoor sport facilities at the proposed new Outdoor Sports Complex at Mendip Road and increase the overall open space surplus for the ward. In addition the replacement facilities would be located less than 600 m from the original playing field.
3.15 This proposal is therefore likely to satisfy the requirements of Policy C4 of the LDP and be consistent with advice contained within Cardiff’s SPG, by providing appropriate replacement and enhanced modern sporting facilities, in accordance with the aspirations of the local community and directly serving the population and facility users affected by the loss.
3.16 In addition to these compensatory measures to be provided off Mendip Road, Policy C5 of the LDP and the Planning Obligations SPG will also ensure that any new residential development at the disposal site will provide additional open space, outdoor recreational and children’s play space facilities, secured through the planning system via a S106 agreement. This provision will be on-site and / or adjacent to the proposed disposal site on land fronting Llanrumney Hall.
3.17 In terms of the acceptability of the redevelopment of the site for residential purposes, this is also likely to be acceptable in the context of Policy H6 of the LDP, as the site is located within the settlement boundary of Cardiff and it can be demonstrated that there is no overriding need to retain the existing playing field, given the new compensatory proposals for its loss off Mendip Road.
3.18 The development of the site for residential purposes will also contribute to meeting the Council’s existing and future housing requirements thereby reducing the need to develop additional alternative greenfield sites in the countryside outside Cardiff’s settlement boundaries.
3.19 The Play Sufficiency Assessment (Wales) Regulations 2012 places a duty on Cardiff Council to assess and secure sufficient play opportunities for children in their area. This duty is delivered through the Play Sufficiency and Assessment and Action Plan delivered from 2019 -2022.
3.20 The Council’s Corporate Plan and Cardiff’s Public Service Board’s Well-being Plan, includes the well-being objective ‘Cardiff is a great place to grow up’. The plans recognise the value of children’s play and the importance of providing rich play opportunities as a contributing factor to the well-being of the city’s communities.
3.21 In recognition of the value of play and the right of children to play the Council and Cardiff’s Public Service Board has also committed to making Cardiff a child friendly city with Cardiff’s Child Friendly City Strategy which was approved in 2018. The strategy aims to prioritise children, young people and partner organisations working together to ensure access to safe outdoor environments for formal and informal play.
3.22 In the context of these plans and strategies there is no detrimental impact to children and young people’s play opportunities as a result of the loss of the proposed disposal site. As demonstrated, the loss of the playing field would be more than compensated for by the increase in accessible outdoor playing space and wider community access to this space, at the proposed new Outdoor Sports Complex at Mendip Road. The replacement facilities will include the relocation of the existing user Llanrumney RFC, with provision of new changing and club facilities. The sports complex will also include an all-weather 3G pitch, which would be available to the local community and at community rates.