Over the past decade, waterfront schemes have become increasingly important to the regeneration and development of Welsh towns and cities.
Cardiff started the trend and it took the other towns and cities such as Swansea, Newport and Llanelli a while to follow, but follow they did. There are now millions of pounds worth of projects either in the pipeline or in actual development.
But these will be shelved throwing developments into jeopardy if a new planning policy in front of the National Assembly for Wales gets the go-ahead. At a stakeholders meeting of the working group looking at the proposed changes held in the Welsh capital on the inauspicious date of Friday 13 February, concerns were raised about a consultation draft of Technical Advice Note 15, Development and flood risk, which was issued last July.
TAN 15 redefines the areas that must be treated as flood risks. The Welsh TAN is different to PPG 25 in that the high risk zone is divided into defended and undefended areas, and no housing development will be allowed in undefended areas. If planners wish to allocate a site for development in an undefended area, it must meet strict criteria, such as being brownfield.
The draft TAN 15 recommends that local planning authorities review any existing planning applications falling within high risk areas. If adopted, the TAN could mean huge swathes of land sitting undeveloped.
“Unless amendments to the policy are made, which allow for more flexibility in the decision-making process, plans for much-needed residential schemes on previously developed sites could fail, forcing developers to turn to safer greenfield sites as their only alternative,” says Tim Gent, a partner at GVA Grimley.
Some warn that residential developments in large parts of Cardiff Bay and high priority regeneration areas in Swansea and Newport are at risk. Bob Croydon, senior partner at King Sturge, points out that the valleys also have a high flood risk. “The TAN will affect key sites in the valleys and the expansion of the cities on the coastal flood plains,” says Croydon.
What worries bodies such as the RICS Wales and the Welsh House Builders Federation as well as agents and developers, are the maps being used to designate the areas at risk from flooding.
According to Gent and the RICS, the current TAN draft, which could be adopted as early as the end of the year, is based on zoned maps produced by the National Assembly for Wales, but they are not consistent with maps produced by the Environment Agency for Wales. This means that some planning authorities are considering applications under the existing guidance, while others are referring to TAN 15.
“The differences between the TAN 15 maps and those provided by the Environment Agency appear to be the way in which specific geological data have been used,” adds Gent.
“Flood risk is an extremely emotive issue, but unless revisions are made to TAN 15, there is a distinct risk that some very high- profile regeneration schemes could fail, or be substantially delayed. But this cannot be the intention.”
While broadly welcoming the proposed changes to the planning policy, CBI Wales, in its annual conference in November, expressed concerns about the financial implications. “It is unlikely that investment or commercial development in these areas will be encouraged and such developments would not be evaluated by legal and insurance industries.”
Newport is the city which could see the greatest number of waterfront developments curtailed under an unamended TAN 15. As Mike Cuddy of the WDA states: “In Newport, there is clearly conflict between policy and regeneration.”
Urban regeneration company Newport Unlimited, set up in 2002 by the National Assembly and the council, is proposing several big mixed-use schemes that are set to change the face of Newport. But if TAN 15 is accepted as it is, these will be in jeopardy.
John Burrows, development director of Newport Unlimited, says it could have a major impact on several proposed schemes such as the Old Town Dock and the former Pirelli Cables Factory on the west bank of the river Usk and further along the river.
“These areas are not on the flood plain map of the Environment Agency, but they are on the TAN 15 draft because they are on an alluvion. The National Assembly is using maps based on old tidal maps.”
Burrows says that most of the areas identified by the existing TAN 15 have not been flooded in many years. He adds that the company is working with the EA on proposals to tackle the flooding dangers that exist in the town. “We are putting in flood prevention where we are developing proposals,” he says.
“And because we are doing this, the EA should be in a position to withdraw any objections it has to the schemes.
“We expect the working group to have taken on board our concerns because it’s crucial for the development of Newport. They can’t not adopt the suggestions we have made or ignore the contributions we have made to flood works. We want to be assured that we can develop on sites that are free or protected from flooding.”
Lynda Healy, regional planner for Wales at the House Builders Federation, also says that changing TAN 15 is “critical to the development of Newport”. She points out that in coastal areas such as Newport, adhering to the current legislation would mean “the need to demolish 1,960 houses that are in the high-risk undefended area and review a further 6,643 houses that fall within the defended area”. It is a matter of waiting to see what the assembly will make of the comments from the Friday 13 February meeting. Most, however, are confident more flexibility will be put into the final document, expected later in the year.
Gent is even more confident: “The final version of TAN 15 is likely to allow develoers or owners to build when they can show that land is not at risk of flooding. Adjustments to the maps are also rumoured, and a further round of consultation is highly unlikely.”
Comments from an assembly spokesperson have offered more hope: “Concerns have focused on the draft maps and the extent of land in some areas shown as being at high risk. The mapping is being reviewed in the light of the best available information.” Everybody involved in development will be hoping that the best available information will lead to the best decision.
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“When the Cardiff Development Corporation was wound up there was the feeling that its dissolution was premature because of what the organisation did to kickstart development. In the time since, the overwhelming development has been residential. The office schemes haven’t been a great success; they have been carried on the back of residential.” Kevin Booth, partner, Eversheds |
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“Over the past 12 months, Cardiff Bay has enjoyed something of a renaissance, with both indigenous and inward-investment occupiers relocating to the area. It is interesting to note that the London Docklands went through a similar experience.” Matthew Phillips, Knight Frank |
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“The WDA development at SA1 in Swansea is going from strength to strength with several notable developments already contracted. The overall development is being funded by a combination of sales receipts and public monies from various sources.” David Woodward, partner, Eversheds |
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“The regeneration of water-related activity brings with it a potential market for commercial property that would not otherwise exist.” Russell Power, Donaldsons |
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“All the developments happening along Llanelli’s waterfront have shown that getting the private sector to invest works. Normally, companies look at Cardiff, and they have only just started looking at Swansea, but in Llanelli we have something similar, but at cheaper prices.” Huw Thomas, WDA |
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“There is now clear recognition from the Wales Tourist Board, among others, that promoting the maritime industry around the Welsh coastline can provide a significant boost to rural economies.” Richard Gatehouse, partner, Gerald Eve |
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“The main development emphasis in Swansea will shift from enterprise to the waterfront, which can boast a superior infrastructure and is located closer to the city centre. In the long term, this enhanced environment will prove to be the focal point of the city.” Lee Mogridge, director, Lambert Smith Hampton |
