Dear Planning Team,
PLANNING APPLICATION REF: 17/00361/MJR | DEMOLITION OF EXISTING COMMERCIAL UNIT & ERECTION OF NEW BUILD DEVELOPMENT TO FORM A3 COMMERCIAL TO GROUND & LOWER GROUND & 6 FLATS OVER | 9 WOMANBY STREET, CITY CENTRE, CARDIFF, CF10 1BR
Please note this is a joint submission.
We are writing to you to object to the planning application (REF: 17/00361/MJR) on behalf of constituents in Cardiff Central and Cardiff North who have contacted us to express their concerns.
Our objection to the planning application is for the following reasons:
Welsh Government Planning Policy guidance on noise:
The Welsh Government’s national planning policy, Planning Policy Wales (Edition 9, November 2016), states that noise is a material consideration in terms of granting planning permission. Para 13.15.1 states that:
“Noise can be a material planning consideration, for example in proposals to use or develop land near an existing source of noise or where a proposed new development is likely to generate noise. Local planning authorities should make a careful assessment of likely noise levels and have regard to any relevant Noise Action Plan before determining such planning applications and in some circumstances it will be necessary for a technical noise assessment to be provided by the developer.”
In addition, Welsh Government Technical Advice Note 11 provides further advice around noise and the planning system. It states:
10. Local planning authorities should consider whether proposals for new noise-sensitive development would be incompatible with existing activities, taking into account the likely level of noise exposure at the time of the application and any increase that may reasonably be expected in the foreseeable future. Such development should not normally be permitted in areas which are, or are expected to become, subject to unacceptably high levels of noise and should not normally be permitted where high levels of noise will continue throughout the night.”
Womanby Street is home to a number of vibrant live music venues including the renowned Clwb Ifor Bach, Fuel Rock Club, Bootlegger, and the annual Swn live music festival. The street is part of what makes Cardiff such a great cultural city.
The proposed development, which includes 6 residential flats, is situated right next to Clwb Ifor Bach, “an existing source of noise,” and in a street that host regular music festivals. This means that noise is very much a material planning consideration in this matter, and the proposed residential development is “incompatible with existing activities.” It should not be permitted in Womanby Street, an area which is “subject to unacceptably high levels of noise” throughout the evening, as per Welsh Government Technical Advice Note 11.
Cardiff Council’s Local Development Plan (LDP)
Situating a proposed development that includes 6 noise-sensitive residential flats in Womanby Street is not compatible with Cardiff Council’s Local Development Plan. The LDP states:
5.181. Noise can have a harmful impact on people’s health and quality of life. Developments such as housing, schools and hospitals can be particularly sensitive to noise, as can areas of landscape, nature or built heritage importance. Where possible, new developments that are particularly noise-sensitive should be located away from existing or proposed sources of significant noise. This assessment can be informed by information on noise complaints being collated by the Council as part of an on-going initiative to reduce noise nuisance.
Economic viability of music venues in Cardiff City Centre
Cardiff lost The Point, which was a great small music venue in the Bay, as a result of complaints about noise from nearby residential accommodation that was developed after the Point was established. The impact of recent residential developments on established music venues in Charles Street also demonstrates how planning permission for residential developments conflicts with the economic viability of music venues for the night time economy in Cardiff City Centre.
A recent survey by UK Music identified a total direct and indirect spend of £52 million generated in Cardiff from music tourism in 2015, with a total of 741 full time jobs generated from the same.
It is important that Cardiff residents, and visitors to our capital city, have the opportunity to hear live music in all types of venues including small, intimate places such as Clwb Ifor Bach. It would be a real blow to musicians and music fans in and around our capital city if our Womanby Street music venues were to suffer the same fate as the Point in Cardiff Bay, and music venues in Charles Street.
Taking into account existing Welsh Government Planning Policy’s guidance on noise, Cardiff Council’s own LDP guidance, and the impact on the night time cultural economy in Cardiff City Centre, the proposed planning application should be rejected.
Jenny Rathbone AM and Julie Morgan AM