Application No W/34187

Application Type Full Planning

Proposal &Location

PROPOSED 10 NEW & 2 RELOCATED STATIC CARAVANS AT WAUNYGROES CARAVAN SITE, LLANYBRI, CARMARTHEN, SA33 5AN

Applicant(s) MR ALAN EVANS, WAUNYGROES CARAVAN SITE , LLANYBRI, CARMARTHEN, SA33 5AN

Agent GERALD BLAIN LTD - MR GERALD BLAIN, TEGFRYN TAF, SPRING GARDENS, WHITLAND, SA34 0HP

Case Officer Stuart Willis

Ward Llansteffan

Date of validation 26/07/2016

CONSULTATIONS

Head of Transport – Has requested the imposition of a number of conditions on any approval.

Head of Public Protection– Has made the following comments:-

If approved a condition requiring a desktop study (Preliminary Risk Assessment), contamination report and remediation and verification report be imposed.

Reference has also been made to separate legislation as an informative for the applicant/developer.

Home Improvement/Health Assessment Officer – Has commented that the only site licence is from 2006. This was for Holiday Static Caravans, 1st April – 31st Oct not to exceed 40 caravans. If when they receive permission for alterations to the site then a new licence may be required.

Hydrology Section – Requested further information in relation to the proposed culvert and bridge. Following the receipt of the additional information they have responded stating they are now satisfied with the pipe size and offer no adverse comments to their proposal. The report provided recommends an upstream and downstream headwall and associated apron which will prevent scour. They would endorse this

approach and have confirmed that prior consent of the Land Drainage Department will be required in addition to the planning permission for the construction of the culvert.

Llansteffan and Llanybri Council – Has asked that the Authority in its determination of W/34187 to give due consideration to:-

(i) the local objections raised, and to assess whether these objections constitute material planning considerations; in particular the impact of increased traffic generation on heavily used minor country roads and the effect on environmental sustainability and landscape quality;

(ii) whether the grounds for refusing planning consent for W/33381 have been adequately addressed within this new application;

(iii) the arguments presented in support of this new application in terms of sustaining more local employment and increasing trade for local businesses;

(iv) the comments and conditions recommended by statutory consultees which we trust will be imposed rigidly should any planning consent be given.

Local Member - County Councillor D B Davies has requested that the application be presented to the Planning Committee in view of public interest regarding visual impact and increased traffic on the road.

Dwr Cymru/Welsh Water – Has acknowledged that a private drainage system is proposed and therefore has no comment.

Natural Resources Wales (NRW) – Has made the following comments:-

Foul water flows for the above proposal are to be connected to the existing non-mains system. Given the increases in volumes that would result from this development, the applicant may require a new or modified permit or registration as exempt from the requirement for a permit from NRW.

Notes the recommendations made in Part Five of the Ecological report and advise that these measures are discussed and agreed with the Authority’s Planning Ecologist.

Recommends the production of a site specific Construction Management Plan, with particular reference given to silt control / prevention, and the protection of the surrounding land & water environments.

Neighbours/Public - The application has been publicised by the posting of Site Notices with 30 letters of objection being received to date. A petition against the development with 11 names has also been submitted. The following issues have been raised:-

Visual impact on the countryside; Impact on views; Caravans proposed is highest part of the site so most visible; Caravans now proposed closer to nearby properties than the previous refusal;

Caravans visually unsightly; Impact on the landscape; Proposed landscaping/screening will take several years and not protect views in

winter months; Impact in wildlife and their habitats; Impacts on the watercourse; Impacts from the construction of the bridge; Loss of agricultural land; Removal/reduction of hedgerow already taken place at the site; Concern any ecological/landscape recommendations will not be followed; Development would not bring significant economic; Questioning of the staff required indicated, particularly when site is closed for

several months; Caravans vacant for long periods but visual impact all year/low occupancy rates; Site is closed for 5 months of the year; Visitors unlikely to use local shops; Little impact on tourism and possible negative impact on tourism; Little if any additional employment required with the extra caravans; No need for additional caravans; Lack of facilities on site; Additional facilities needed rather than more caravans; Traffic generation; Highways safety; Concern over future applications to expand if this is approved; Precedent if approved for other sites; Application field could accommodate further statics; Site has expanded in recent years; Impact on exiting tourism locations; Loss of privacy and disturbance; Noise; Contrary to policy; Site is not related to any settlement and is distant from settlements, services and

facilities; Refused previously and no major changes so reasons should still stand; Site is outside development limits; Priority for the village is housing rather than further tourism; Affordable housing needed; Less “eco planning regulations” for caravans than houses; No renewable energy proposals as part of the scheme; Concerns over the proposed septic tank and drainage system; The applicant does not live on or near the site; Site too large for the village; Smaller size of the site is preferable for those staying; Impacts on broadband and power supply if more users in the area; Lack of contact with the local community by the applicant; Letters of support from those not living/working near the site; Dog mess from animals relating to the site;

Occupants of the site parking in nearby properties; Drain on the already stretched local services; i.e. police, ambulance; Lack of construction management plan.

We have received a letter stating that one of the objections received was not from the person it was said to be. That letter has therefore been discounted.

The application was also accompanied by 10 letters of support and one further letter of support was received during the processing of the application raising the following matters:-

Businesses referring to work related to the site;; Reference to the site not being widely visible is made; No pollution in the stream; Comment regarding alleged works from objectors; Site is quiet; Proposal will add to tourism in the area and benefit rural businesses;

RELEVANT PLANNING HISTORY

The following previous applications have been received on the application site:-

W/33381 Proposed 12 new and 2 relocated static caravans and site improvements Full planning refused 04 April 2016

W/05834 Install new road and concrete bases for static caravans Withdrawn 15 March 2004

D4/23568 Electricity supply Full planning permission 12 June 1993

D4/23517 Electricity supply Full planning permission 08 June 1993

D4/23474 Electricity supply Full planning permission 20 May 1993

R1/6902 Site for caravans on part field 537 and field 540 Full planning permission 1969

APPRAISAL

THE SITE

The application site is a field located adjacent to the existing caravan site known as Waunygroes. The site is located approximately 600m north east of Llanybri. The existing site is located either side of a country land/road which runs between U2127 and C2039. These roads then run alongside the existing caravan site. The north

section of the site is the large area and is of a triangular shape. This area contains 24 caravans. To the south west of the minor road is the remainder of the site. This is a trapezium shaped area of land accommodating 16 caravans at present. The land slopes to the south west. There is a watercourse running between the south western edge of the existing site and the application site. At present there is a single access/exit for the southern part of the site. This is located towards the eastern side of the site near the junction with the C class road. There is a separate access for the northern part of the site more centrally located off the lane. The application site itself is part of a larger field located to the south west of the existing caravan site. There is an existing field access off the U class road near the northern part of the field.

The site is located in open countryside and some 600m from any settlement limits.

An application for a similar development was refused earlier this year. That proposal was for 12 additional units rather than the 10 now proposed. The layout of the site at that time ran along the north eastern boundary across the whole field. The application was refused due to concerns over the principle of the development in this location, the impact on the character of the area and the proposal including conflicting and/or inappropriate information in relation to ecology and landscaping.

THE PROPOSAL

The application seeks full planning permission for an extension of the caravan site to accommodate 10 additional caravans and the relocation of 2 existing caravans.

The caravans to be relocated are both currently within the northern triangular part of the site. These would be removed and relocated to the larger part of the site to the site.

The 10 new and 2 relocated static caravans would be located in the field to the south west of the watercourse, extending the site in to a new field. The proposal puts forward a one way system for the southern part of the existing site and new caravans. The access near the C road to the east would serve as an entrance only. Vehicles would travel north west through the existing site before crossing a new bridge over the watercourse to the new area of caravans. The existing access in the currently undeveloped field was to be altered and used as an exit only. Due to visibility requirements the location of the access has been moved further south with the existing access to be closed up. The new site for the caravans would be in the north western part of the field. There would be a new road running south west through it with a turning head at the end.

As part of the previous application landscape and ecology details were provided however contradicted each other in places or were not sufficient to address the relevant issues at the site. Amended details were provided as part of this submission. An “eco-zone” buffer area is proposed around the site. This is 5m wide at the southern and western ends, 15m to the eastern side and 10m wide to the northern end. Further amended information was provided in relation to ecology and landscaping.

Two parking spaces are shown for each of the 12 caravans to be located in the field.

A Business Plan was provided. This refers to a possible future conversion of the unused toilet block into a laundry and reception office (subject to planning permission). It makes reference to an onsite sewerage treatment plant and that this will be upgraded to cater for the additional pitches. The report states that the agents “are confident that a strong market exists for the services provided by Waunygroes Caravan Park”. In relation to job creation the report states “Since Waunygroes is a small site with all its caravans privately owned, current site maintenance is performed by one part time contractor. This will increase marginally with the additional pitches for owner occupied caravans and two new long season jobs for management and maintenance of the letting caravans. There will be considerable benefit to the local contractors who will be doing the development work”. it goes on to comments on the landscape scheme stating “the planting of trees and shrubs will provide significant environmental enhancement”. General comments are made regarding the contribution of tourism and caravan site to the Welsh economy. It is said that the 4 caravans are to be sold and the other 6 new ones to be rented out. There would be an income from the initial sale, rental and then ground rent. In terms of other sites in the area the report states “The Park has little competition in the immediate locality, the only other holiday parks being the larger coastal locations of Sunrise Bay and Laugharne Park, which are both approximately three miles away as the crow flies but in much busier locations and so offering no direct competition in either direction. They are very different in size and in concept”.

PLANNING POLICY

In the context of the current development control policy framework the site is located outside the defined development limits as contained in the adopted Carmarthenshire Local Development Plan Adopted December 2014.

LDP Policy TSM1 is relevant to the proposal. This relates to Static Caravan and Chalet Sites and states that proposals for new static caravan and chalet sites will only be permitted within the Development Limits of a defined settlement (Policy SP3).

It also refers to proposals for the enhancement and extension of existing static and chalet sites stating they will only be permitted where the development will increase the vitality, sustainability and environmental quality of the site, it will not result in an unacceptable increase in the density of units and/or the overall scale of the site, it enhances the surrounding landscape and townscape and it provides (where appropriate) for the significant improvement of the overall quality, appearance and setting of the site.

Policy GP1 of the Local Development Plan (LDP) sets out the general requirements of the Local Planning Authority to ensure sustainability and high quality design through new development. In particular, that “it conforms with and enhances the character and appearance of the site, building or area in terms of siting, appearance, scale, height, massing, elevation treatment, and detailing”, “it would not have a significant impact on the amenity of adjacent land uses, properties, residents or the community” and “an appropriate access exists or can be provided which does not give rise to any parking or highway safety concerns on the site or within the locality”.

Policy TR3 Highways in Developments - Design Considerations outlines a number of matters to be considered included suitable access and parking and to ensure highway safety is not adversely affected for users of the roads/streets.

Policy SP1 Sustainable Places and Spaces states that proposals for development will be supported where they reflect sustainable development and design principles. This relates to a number of factors including by distributing development to sustainable locations in accordance with the settlement framework, supporting the roles and functions of the identified settlements; promoting, where appropriate, the efficient use of land including previously developed sites; integrating with the local community, taking account of character and amenity as well as cultural and linguistic considerations; respecting, reflecting and, wherever possible, enhancing local character and distinctiveness; creating safe, attractive and accessible environments which contribute to people’s health and wellbeing and adhere to urban design best practice; promoting active transport infrastructure and safe and convenient sustainable access particularly through walking and cycling; utilising sustainable construction methods where feasible; improving social and economic wellbeing; and protect and enhance the area’s biodiversity value and where appropriate, seek to integrate nature conservation into new development.

Policy SP2 Climate Change states that development proposals which respond to, are resilient to, adapt to and minimise for the causes and impacts of climate change will be supported. In particular proposals will be supported where they: adhere to the waste hierarchy and in particular the minimisation of waste; promote the efficient consumption of resources (including water); reflect sustainable transport principles and minimise the need to travel, particularly by private motor car; avoid, or where appropriate, minimise the risk of flooding including the incorporation of measures such as SUDS and flood resilient design; promote the energy hierarchy by reducing energy demand, promoting energy efficiency and increasing the supply of renewable energy; and incorporate appropriate climate responsive design solutions including orientation, layout, density and low carbon solutions (including design and construction methods) and utilise sustainable construction methods where feasible.

Policy SP3 Sustainable Distribution – Settlement Framework states that the provision for growth and development will be at sustainable locations in accordance with the Settlement Framework identified in the LDP.

Policy SP14 Protection and Enhancement of the Natural Environment states development should reflect the need to protect, and wherever possible enhance the County’s natural environment. It goes on to say that all development proposals should be considered in accordance with national guidance/legislation and the policies and proposals of this Plan, with due consideration given to areas of nature conservation value, the countryside, landscapes and coastal areas and refers to the type of areas to be considered.

Policy SP15 Tourism and the Visitor Economy states that proposals for tourism related developments and for appropriate extensions to existing facilities will be supported where they are in accordance with the locational hierarchy set out in the policy and are acceptable in terms of scale, type of development, siting and general impact:

i. Within the development limits of Growth Areas and Service Centres - major tourism proposals, including high level traffic generators;

ii. Within the development limits of Local Service Centres and Sustainable Communities – smaller scale proposals which reflect the character of the area which are appropriate in terms of size, scale and impact;

iii. Open Countryside – small scale location specific developments that must satisfy policy TSM3, except where they are subject to the provisions of TSM2 and/or TSM5.

Extensions to existing facilities should be subordinate in scale and function to the existing facility and proposals that constitute substantive extensions should be construed as new development.

Policy TR3 Highways in Developments - Design Considerations states that the design and layout of all development proposals will, where appropriate, be required to include an integrated network of convenient and safe pedestrian and cycle routes (within and from the site) which promotes the interests of pedestrians, cyclists and public transport; suitable provision for access by public transport; appropriate parking and where applicable, servicing space in accordance with required standards; infrastructure and spaces allowing safe and easy access for those with mobility difficulties; required access standards reflective of the relevant Class of road and speed restrictions including visibility splays and design features and calming measures necessary to ensure highway safety and the ease of movement is maintained, and where required enhanced and provision for Sustainable Urban Drainage Systems to allow for the disposal of surface water run-off from the highway.

Proposals which do not generate unacceptable levels of traffic on the surrounding road network and would not be detrimental to highway safety or cause significant harm to the amenity of residents will be permitted.

Proposals which will not result in offsite congestion in terms of parking or service provision or where the capacity of the network is sufficient to serve the development will be permitted. Developers may be required to facilitate appropriate works as part of the granting of any permission.

Policy SP14 Protection and Enhancement of the Natural Environment states development should reflect the need to protect, and wherever possible enhance the County’s natural environment. All development proposals should be considered in accordance with national guidance/legislation and the policies and proposals of this Plan, with due consideration given to areas of nature conservation value, the countryside, landscapes and coastal areas, and refers to a number of sites/designations, including the open countryside.

Technical Advice Note (TAN) 23: Economic Development (2014).

THIRD PARTY REPRESENTATIONS

Turning to the representations received to date.

Flooding, foul and surface water drainage

The proposal involves the construction of a bridge over the watercourse and the application indicates that a package treatment plant would be used for the drainage, which is said to be the existing method of drainage. Surface water would be dealt with by soakaway.

No objection has been received from NRW on this matter and they have referred to the potential need for a separate permit being required. This would be separate to any planning permission. The Land drainage officer has made comments in relation to the watercourse and bridge rather than the foul drainage on the previous application. On this application initially requested further information and justification regarding the bridge and culvert. This has now been provided and is satisfied with the information and raise no objection.

Size of site and demand/need for further caravans

A number of objection felt that there was sufficient provision at the site, and the wider area in terms of caravans. There were also comments that the size of the site was beneficial as opposed to larger sites elsewhere. The impact of the extended area on the character and appearance of the area is a consideration and one where there is an issue. These concerns form part of the refusal reasons. In terms of the need or demand for an extended site this is not a consideration. Each case is assessed on its own merits and against the relevant policies. These do not make reference to the level of provision in the area. There was comment made that the site extended site would be too large in comparison to the village of Llanybri. The site as extended would comprise 49 units. There are issues in terms of the visual appearance and other matters. The scale of the site is not of a nature that would dominate the settlement of Llanybri.

Visual/landscape impacts

A number of the objections highlighted the impacts of the proposed on the landscape, views and the countryside. While impacts on views are not a material consideration the impacts on the landscape are a consideration. The previous application was refused in part due to the landscape and visual impacts of the proposal. This application has amended the location of the proposed caravans and has also proposed a buffer area around them.

The site is visible from certain public vantage points in the surrounding landscape. The land falls from the existing site towards and across the application field. The location of the caravans is in the northern part of the field. The existing sites prominence appears to have been increased with the removal/reduction of a section of hedgerow and trees along the southern boundary with the proposed site adjacent to the watercourse. Due to the relief of the land and the size of the open area within this field the proposed site would also be visible from certain areas. The site would be visible from approaches along the public roads. The removal/reduction of the vegetation along the northern boundary has made the existing units more visible and this has been detrimental in itself. The removal of this has only served to show the harm there

would be with further development in the field adjacent. The proposal would have an impact on the character of the area. The existing site is contained within fields to the north and fills the respective enclosures. These areas have the defined boundaries of the road and the watercourse along their edge. This proposal is to expand in to the far larger field below. The development would appear a disjointed incursion in to the field, even when taking in to account the buffer areas proposed. The amended scheme forming part of this submission does not resolve this issue. The introduction of further static caravans would detract from the character of the area. While landscaping is proposed it is not felt that this would sufficient address the issue. Any features would take some time to reach a sufficient size to be of benefit in terms of screening and the sloping nature of the site reduces the effectiveness of any screening in parts. Even if totally screened the fact a site is not visible does not mean the principle of the development is acceptable.

The Landscape Officer has comments that the “proposed development involves fragmentation of the existing field pattern and expansion of man-made, rectilinear elements in the form of caravan units and associated access areas into the wider rural landscape. …..the observation remains in that the proposed development does not demonstrate overall enhancement to the character and appearance of the site or landscape”.

Impacts on amenity

Issuing relating to noise, loss of privacy and traffic has been raised. The amended location of the caravans from the first application was also highlighted as this has brought them closer to properties to the west of the site. At the nearest point there would be a property approximately 35m from one of the caravans in the proposed extended site. For properties to the east of the site the revised scheme moves caravans further from those. There would be impacts on the amenity levels of those living near the site. It needs to be considered whether these impacts are sufficient to warrant being a reason for refusal of the application. Land levels and the orientation of the site also means that the site and properties would be visible from each other. Many of the caravans run along the western part of the site where for the majority of this boundary there are no properties immediately opposite. The caravans nearest to the existing properties are still set some distance from the nearest property, a distance where if a new dwelling were proposed it is likely would be considered sufficient separation. It is not felt that the overlooking would be of a significance to warrant refusal of the application due to the separation. There is also landscaping proposed along the boundaries of the site. The one way system would mean that vehicles would only enter the site from the existing access in the existing part of the site. This is not directly adjacent to any properties. Again while there would be some additional traffic at the site it is not felt this warrants a reason for refusal. The only exit for the lower part of the existing site and the proposed site would be off the western side of the application site. This is located approximately 75m from the nearest dwelling. Therefore while there is likely to be some additional disturbance from traffic it is not felt this warrants a reason for refusing the application.

Precedent and future expansion

Concern has been raised over any approval setting a precedent for further applications for the rest of the field and in general across the county. Comment was also made over the sites previous expansion and that additional static caravans could be accommodated in this site.

The application is for 12 static caravans. Two of these would be in place of existing ones in the northern part of the site. Each application needs to be assessed on its individual merits against the relevant policies. Any decision here does not set a precedent for future applications. The application is for part of the field only and that is how the submission is being assessed. Each application is assessed on its own merits. However it is noted that allowing the development of part of the field would potentially reduce the justification for raising concerns with the development of the remainder of it in terms of certain aspects. An assessment of whether development in this location in acceptable in terms of impacts on the landscape etc. may have relevance to a future application for a further extensions. In relation to the number of caravans that could be accommodated on site there could be conditions imposed regarding this if the application were approved.

Landscape features/works

Comment has been made in relation to landscape features already removed and harm to landscape features. Support letters give a contrary view. There does appear to have been works undertaken to the boundary vegetation along the boundary with the watercourse. As mentioned above this has increased the visibility of the existing site in the landscape. Impacts on landscape features was an issue with the previous application, including where the landscape scheme had not taken in to account the requirements of the visibility splay needed.

A revised landscape scheme has been submitted as part of this application however it was not considered to be appropriate or sufficient and did not take in to account requirements of the ecology assessment of the conditions requested by the Highways Officer. Further revisions were provided along with associated amended ecology details. It is felt that in terms of the level of detail provided for a landscape scheme the details are sufficient.

The concerns regarding the principle of the development in terms of its impact on the character of the landscape still remains. The Landscape Officer has commented that “The proposed development involves fragmentation of the existing field pattern and expansion of man-made, rectilinear elements in the form of caravan units and associated access areas into the wider rural landscape. ….. the observation remains in that the proposed development does not demonstrate overall enhancement to the character and appearance of the site or landscape”

Impacts on ecology, biodiversity and habitats

Several concerns were raised over the potential impacts on ecology, species and their habitats. Impacts on the watercourse were also raised, partly in connection with the

construction of the proposed bridge during the first application and during this application.

In the previous application the Planning Ecologist has identified a number of areas where the recommendations of the ecological assessment have not been reflected in the scheme as shown on other plans/documents. As such it was felt that there was not sufficient or accurate information in regard to ecology and therefore appropriate compensation was not provided.

A revised ecology report and layout was provided with this application. The Planning Ecologist has again raised concerns over the information provided in the ecology report not being reflected elsewhere in the scheme. Questions were also raised requesting clarification of the proposals suggested and which were to be provided. As such as with the first application the details provided are not appropriate in that they contradict other elements of the scheme. After further revisions amended information was provided for the site and also the area to the east where an improved visibility splay is required. The Planning Ecologist is satisfied with the level of information now provided in relation to ecology.

Concerns were raised over the ability and desire of the applicant to comply with any ecology or landscape requirements were the application approved. If there was approval the decision could include conditions requiring compliance with the relevant details. If these were not complied with that would be a matter for the Planning Enforcement Team to investigate.

NRW have requested a construction management plan be provided. This would need to look at silt control / prevention, and the protection of the surrounding land & water environments. The lack of this was raised in objections. If approved the submission and agreement of such a plan could form part of the conditions imposed. The Land Drainage Section has not responded to date.

Highway matters

A number of areas of concern were raised as with the first application. These included highway safety, insufficient road capacity and the condition of the road network, existing problems exacerbated, parking in nearby properties, insufficient visibility and creation of a new gate elsewhere in the field.

In terms of the application the Head of Transport has not raised any objection to the application. A one way system is proposed from the existing site to the new one. Several conditions are recommended in relation to improvements of the visibility at the amended access part of the new extended area and also to the junction near the access to the one way system. Conditions could be imposed with an approval relating to highways matters. The Head of Transport feels that the additional traffic could be accommodated on the road network subject to these improvements. There will be impacts associated with the improvements on landscape features which were not addressed in the initial application. These have now been resolved with amended details having been provided.

Economic impacts

The type and level of impact that the proposal would have on the economy are matters that have been raised by both objections and supporters of the application. Letters from businesses in the area have indicated the site and its extension would be beneficial to them. Objectors have questioned the benefits, if any, that the proposal would bring. Objectors have specifically raised concern over the level of staffing it is said the proposal currently has and would in the future create. The issue of the site being closed for several months each year has been raised in terms of jobs and economic benefits to the area. The need to balance the perceived temporary benefits this brings against the permanent landscape and visual impacts was also highlighted. They have questioned whether the nearby facilities would actually be used, particularly with the proposal being for static caravans which would be self-catering. Some objections refer to the proposed development having potential negative impacts on the local economy. This is due to the visual/landscape impacts making the area less appealing to visitors. This, it is said, would impact on existing tourism facilities and places to stay in the area.

Chapter 7 of Planning Policy Wales applies and was revised to strengthen the emphasis given to economic considerations and also clarifies economic development as development of land and buildings for activities that generate wealth, jobs and incomes. Economic land uses include the traditional employment land uses (offices, research and development, industry and warehousing), as well as uses such as retail, tourism, and public services. It is clear from this statement that the Welsh Government regards tourism as major contributor to the Welsh economy.

It stresses the need for local planning authorities to give increasing weight to job creation, PPW states in Chapter 7:

7.6.1 Local planning authorities should adopt a positive and constructive approach to applications for economic development. In determining applications for economic land uses authorities should take account of the likely economic benefits of the development based on robust evidence. In assessing these benefits, key factors include:

• the numbers and types of jobs expected to be created or retained on the site;

• whether and how far the development will help redress economic disadvantage or support regeneration priorities, for example by enhancing employment opportunities or upgrading the environment;

• a consideration of the contribution to wider spatial strategies, for example for the growth or regeneration of certain areas.

Chapter 11 specifically looks at tourism, sport and recreation and is therefore also relevant to the considerations of this application.

It states that “Tourism is vital to economic prosperity and job creation in many parts of Wales. It is a significant and growing source of employment and investment, based on the country’s cultural and environmental diversity. Tourism can be a catalyst for

environmental protection, regeneration and improvement in both rural and urban areas”. (11.1.1)

It goes on to say that “Tourism involves a wide range of activities, facilities and types of development throughout Wales. The planning system should encourage sustainable tourism in ways which enable it to contribute to economic development, conservation, rural diversification, urban regeneration and social inclusion, recognising the needs of visitors and those of local communities. In addition to supporting the continued success of existing tourist areas, appropriate tourist-related commercial development in new destinations, including existing urban and industrial heritage areas, should be encouraged”. (11.1.4)

In 11.1.7 PPW says that “In rural areas, tourism-related development is an essential element in providing for a healthy, diverse, local and national economy. It can contribute to the provision and maintenance of facilities for local communities. Here too development should be sympathetic in nature and scale to the local environment and to the needs of visitors and the local community”. And goes on at 11.1.9 to state that “Development for tourism, sport and leisure uses should, where appropriate, be located on previously developed land. The sensitive refurbishment and re-use of historic buildings presents particular opportunities for tourism and leisure facilities”.

TAN6 relates to sustainable rural communities and again is a consideration of the proposal. Paragraph 3.1.1 highlights that “Strong rural economies are essential to support sustainable and vibrant rural communities. A strong rural economy can also help to promote social inclusion and provide the financial resources necessary to support local services and maintain attractive and diverse natural environments and landscapes”.

It is not felt that the proposal complies with the relevant LDP policies. Therefore these concerns need to be balanced against any economic benefits of the development.

In updating economic development planning policy the Welsh Government recognised that there was also a requirement for a Technical Advice Note to provide further detail. TAN23 Economic Development was issued in 2014.

The TAN states that “Where economic development would cause environmental or social harm which cannot be fully mitigated, careful consideration of the economic benefits will be necessary. There will of course be occasions when social and environmental considerations will outweigh economic benefit. The decision in each case will depend on the specific circumstances and the planning authority’s priorities”. (2.1.2)

In relation to the rural economy the TAN says “There are two kinds of special contribution that are particularly relevant to rural development. Firstly, an economic development could make communities more sustainable, by improving the alignment of housing and jobs, encouraging people to work close to home. Secondly, the needs of established businesses or clusters may be very specific. When businesses expand or modernise, they may need to do so in situ; it may be highly inefficient or impracticable for them to relocate to a sequentially preferable site. Similarly new

businesses aiming to join existing clusters may need to be close to existing businesses if they are to derive the benefits.”

The TAN requires local planning authorities to assess the economic benefit associated with allocating sites and determining planning applications for economic development. Where a planning authority is considering a site allocation or planning permission that could cause harm to social and environmental objectives the TAN proposes an approach where three questions that should be asked -

• Are there alternative sites for the proposal? • How many direct jobs will result from the proposal? • And would such a development make a special contribution to policy objectives?

in order to help balance the economic, social and environmental issues.

Alternatives: If the land is not made available (the site is not allocated, or the application is refused), is it likely that the equivalent demand could be met on a site where development would cause less harm, and if so where?

The TAN cites an example of where some existing firms may not be able to grow unless they are allowed to expand on their existing site, or close to it. Before concluding that ‘there is no alternative’ local planning authorities are encouraged to try to assess whether competing firms, serving the same markets, could generate the same development and jobs.

The site is located in rural Carmarthenshire. There are other caravan sites in the wider area such as the static caravan site Sunrise Bay in Llansteffan and it is not felt that there is any specific shortage of such accommodation in the County as a whole or in this area. While it is the applicants desire to expand the existing site this does not imply that any extension is acceptable or that any economic benefits imply a development is appropriate. No detailed breakdown of the level of provision in the area or detailed assessment of the demand in the area is provided. The application refers in general to benefits to the wider area from expenditure from those staying at the site.

Jobs accommodated: How many direct jobs will be based at the site?

This provides a rough-and-ready measure of a development’s contribution to the wider economy. Economic growth is worthwhile wherever it is located, and in the interests of economic growth the planning system should generally aim to provide land where there is demand for it. There may be good reasons why jobs in some places are even more worthwhile than in other places. The third test below deals with this.

The application indicates that the site currently employs 1 full time and one part time person. With the proposed extension there would be 2 full time staff according to the application form. Therefore the development involves the potential creation of ½ a job. The business plan provided refers to an increase in work load for the employee maintaining the site and now says there would be 2 further staff and “two new long season jobs for management and maintenance of the letting caravans”, of which there are 6 caravans for letting.

Any employment is welcomed however this needs to be balanced against any harm the development would cause. It is not felt that the proposal would provide significant benefits in terms of job creation to outweigh the harm.

Special merit: Would the development make any special contribution to policy objectives?

Such policy contributions may relate to the objectives listed in PPW, or to more general policy objectives set out elsewhere in PPW and Chapter 11 of PPW is particularly relevant in this case

The proposal also falls into some of the sectors targeted by Welsh Government, particularly Tourism. However the site is not one that is unique. While economic development is an important consideration it is not felt that this scheme provides any significant or unique benefits or any justification for overriding the concerns raised here and in the previous application.

Therefore it is not felt that the refusal of the application would be to the detriment of the wider economy or tourism in the area.

Location of the site/sustainability

Objectors have referred to the site being outside of the development limits of any settlement. The distance from any services and facilities was also raised. Llanybri is the nearest settlement to the site. There are some facilities in the settlement however these are limited to a public house. A lack of facilities on site has been raised as an issue and with the lack on site and in the nearest settlement it is likely that people would need to travel to access facilities. Members will be aware of a recent decision at Planning Committee relating to a RV site near Idole (W/33310). The application was refused due to the site not being considered to be in a sustainable location, not being accessible by foot and that it would be wholly dependent on motorised vehicles to access services and facilities. The roads at and near the site have no public footways either. As has been referred to elsewhere there are no on site facilities for holiday makers and other than a public house no other facilities or services in the area. For example the nearest shops would be Llansteffan or Johnstown.

Some objectors refer to the need to develop more facilities on site rather than additional caravans however this would be a commercial decision and the policies do not require facilities on site. The lack of facilities on site would be likely to increase the need for travel to reach such facilities and the implications this has for sustainability. The proposal is for caravans alone and that is what is being assessed. There is a toilet/shower block in the northern field.

The lack of sustainable features and reference to eco standards for caravans has been raised. Again there is no requirement for such elements to be included in the scheme. No details of any such features are referred to in the application.

LDP Policies

Objectors raised a number of areas where they felt the proposal was contrary to LDP policy. The previous application was refused against a number of LDP policies and they feel these have not been addressed. While amended/additional information has been provided in this submission it is not considered the proposal has addressed matters. TSM1 requires extensions to existing site to improve the environmental quality of the site. This is not achieved with the proposed development. It is an incursion in to a currently undeveloped field. The existing site is tightly contained with 2 enclosures whereas this proposal would extend in to a new wider and more open field. While there may be some small economic benefit it does not outweigh this harm. It would also therefore cause an unacceptable increase in the overall scale of the site. The development proposes some landscape and ecology mitigation however insufficient details have been provided of these. Where they have it is felt that this is not sufficient to mitigate the harm and does not take in to account the ecological or highways requirements of the proposal.

It is not felt that it has been shown that other considerations should outweigh the policy objections and as such the recommendation remains one of refusal.

Other matters

Some issues raised are not considered to be material considerations. These include the applicant not residing in the area, the distance supporters of the proposal are from the site and dog mess relating to pets from the site. A lack of contact with the local community was raised but this does not affect the assessment of the proposal. Public notification was carried out as part of the application.

Objectors have indicated they feel that a priority for the area is housing, particularly affordable housing rather than the proposal to extend the caravan. The application relates to the caravan site, not housing and it should be assessed against the relevant policies.

The loss of agricultural land was referred to however it is not felt that the loss of this area of land is significant if the in this regard. Impacts on broadband and power supply from more users in the area were raised. It is not felt that the additional units would be a significant issue in this regard and it would be a matter for the providers to consider. Objectors also referred to the development being a strain on local services; such police and ambulance. Again the size of the development is not considered to be of a scale where impacts of this nature would be significant.

CONCLUSION

After careful consideration of the site and its surrounding environs in the context of this application, together with the representations received to date it is considered that on balance the proposal is not acceptable.

As such the application is put forward with a recommendation of refusal for the following reasons.

RECOMMENDATION – REFUSAL

REASONS

1 The proposal is contrary to Policy TSM1 “Static Caravan and Chalet Sites” of the Carmarthenshire Local Development Plan:-

Policy TSM1 Static Caravan and Chalet Sites

Proposals for new static caravan and chalet sites will only be permitted within the Development Limits of a defined settlement (Policy SP3).

Proposals for the enhancement and extension of existing static and chalet sites will only be permitted where:

a. The development will increase the vitality, sustainability and environmental quality of the site;

b. It will not result in an unacceptable increase in the density of units and/or the overall scale of the site;

c. It enhances the surrounding landscape and townscape;

d. It provides (where appropriate) for the significant improvement of the overall quality, appearance and setting of the site.

In that:

The proposal does not provide significant improvement of the overall quality, appearance and setting of the site. It is an incursion in to a currently undeveloped field. The existing site is tightly contained with 2 smaller enclosures whereas this proposal would extend in to a new, larger and more open field. While there may be some economic benefits from the scheme and additional landscaping of the new element of the site it is not considered to outweigh this harm in this instance and there is little improvement to the existing parts of the site. The proposed development involves fragmentation of the existing field pattern and expansion of man-made, rectilinear elements in the form of caravan units and associated access areas into the wider rural landscape. It would harm the character and appearance of the landscape.

2 The proposal is contrary to Policy SP1 “Sustainable Places and Spaces” of the Carmarthenshire Local Development Plan:-

SP1 Sustainable Places and Spaces

Proposals for development will be supported where they reflect sustainable development and design principles by:

a. Distributing development to sustainable locations in accordance with the

settlement framework, supporting the roles and functions of the identified settlements;

b. Promoting, where appropriate, the efficient use of land including previously developed sites;

c. Integrating with the local community, taking account of character and amenity as well as cultural and linguistic considerations;

d. Respecting, reflecting and, wherever possible, enhancing local character and distinctiveness;

e. Creating safe, attractive and accessible environments which contribute to people’s health and wellbeing and adhere to urban design best practice;

f. Promoting active transport infrastructure and safe and convenient sustainable access particularly through walking and cycling;

g. Utilising sustainable construction methods where feasible;

h. Improving social and economic wellbeing;

i. Protect and enhance the area’s biodiversity value and where appropriate, seek to integrate nature conservation into new development.

In that:

The proposal would go against the principle of distributing development to sustainable locations in accordance with the settlement framework, supporting the roles and functions of the identified settlements. The site is located outside of development limits and is distant from many services and facilities. Due to location of the site and the nature of the route between the site and the nearest settlements, services and facilities the journeys to and from the site to would heavily reliant on private transport and therefore be unsustainable. The site is not in a sustainable location accessible by foot and would be wholly dependent on motorised vehicles to access services and facilities.

The proposal does not respect, reflect or enhance the local character

and distinctiveness. It is an incursion in to a currently undeveloped field. The existing site is tightly contained with 2 smaller enclosures whereas this proposal would extend in to a new, larger and more open field. While there may be some economic benefits from the scheme and additional landscaping of the new element of the site it is not considered to outweigh this harm in this instance and there is little improvement to the existing parts of the site. The proposed development involves fragmentation of the existing field pattern and expansion of man-made,

rectilinear elements in the form of caravan units and associated access areas into the wider rural landscape. It would harm the character and appearance of the landscape.

3 The proposal is contrary to Policy GP1 “Sustainability and High Quality Design” of the Carmarthenshire Local Development Plan:-

Policy GP1 Sustainability and High Quality Design

Development proposals will be permitted where they accord with the following:

a. It conforms with and enhances the character and appearance of the site, building or area in terms of siting, appearance, scale, height, massing, elevation treatment, and detailing;

b. It incorporates existing landscape or other features, takes account of site contours and changes in levels and prominent skylines or ridges;

c. Utilises materials appropriate to the area within which it is located;

d. It would not have a significant impact on the amenity of adjacent land uses, properties, residents or the community;

e. Includes an integrated mixture of uses appropriate to the scale of the development;

f. It retains, and where appropriate incorporates important local features (including buildings, amenity areas, spaces, trees, woodlands and hedgerows) and ensures the use of good quality hard and soft landscaping and embraces opportunities to enhance biodiversity and ecological connectivity;

g. It achieves and creates attractive, safe places and public spaces, which ensures security through the ‘designing-out-crime’ principles of Secured by Design (including providing natural surveillance, visibility, well lit environments and areas of public movement);

h. An appropriate access exists or can be provided which does not give rise to any parking or highway safety concerns on the site or within the locality;

i. It protects and enhances the landscape, townscape, historic and cultural heritage of the County and there are no adverse effects on the setting or integrity of the historic environment;

j. It ensures or provides for, the satisfactory generation, treatment and disposal of both surface and foul water;

k. It has regard to the generation, treatment and disposal of waste;

l. It has regard for the safe, effective and efficient use of the transportation network;

m. It provides an integrated network which promotes the interests of pedestrians, cyclists and public transport which ensures ease of access for all;

n. It includes, where applicable, provision for the appropriate management and eradication of invasive species.

Proposals will also be considered in light of the policies and provisions of this Plan and National Policy (PPW: Edition 7 and TAN12: Design (2014)).

In that:

The proposal would go against the principle of distributing development to sustainable locations in accordance with the settlement framework, supporting the roles and functions of the identified settlements. The site is located outside of development limits, and is distant from many services and facilities. Due to location of the site and the nature of the route between the site and the nearest settlements, services and facilities the journeys to and from the site to would heavily reliant on private transport and therefore be unsustainable. The site is not in a sustainable location accessible by foot and would be wholly dependent on motorised vehicles to access services and facilities.

The proposal does not protect or enhance the landscape. It is an incursion in to a currently undeveloped field. The existing site is tightly contained with 2 smaller enclosures whereas this proposal would extend in to a new, larger and more open field. While there may be some economic benefits from the scheme and additional landscaping of the new element of the site it is not considered to outweigh this harm in this instance and there is little improvement to the existing parts of the site. The proposed development involves fragmentation of the existing field pattern and expansion of man-made, rectilinear elements in the form of caravan units and associated access areas into the wider rural landscape. It would harm the character and appearance of the landscape.

4 The proposal is contrary to Policy SP14 “Protection and Enhancement of the Natural Environment” of the Carmarthenshire Local Development Plan:-

SP14 Protection and Enhancement of the Natural Environment

Development should reflect the need to protect, and wherever possible enhance the County’s natural environment.

All development proposals should be considered in accordance with national guidance/legislation and the policies and proposals of this Plan, with due

consideration given to areas of nature conservation value, the countryside, landscapes and coastal areas, including those outlined below:

a. Statutory designated sites including Ramsar sites, SPAs, SACs, SSSIs and National Nature Reserves;

b. Biodiversity and Nature Conservation Value, including protected species and habitats of acknowledged importance as well as key connectivity corridors and pathways; (Policy EQ4 and EQ5)

c. Regional and Locally important sites (and their features) including Local Nature Reserves and RIGS; (see Policy EQ3)

d. Areas of identified Landscape and Seascape quality; (including SLAs)

e. Features which contribute to local distinctiveness, nature conservation value or the landscape; (see Policy EQ5)

f. The Open Countryside; (see Policy GP2)

g. The best and most versatile agricultural land; (Grade 2 and 3a)

h. Natural assets: including air, soil (including high carbon soils) controlled waters and water resources. (See Policies EP1 and EP2)

In that:

The proposal does not protect or enhance the local character and distinctiveness. It is an incursion in to a currently undeveloped field. The existing site is tightly contained with 2 smaller enclosures whereas this proposal would extend in to a new, larger and more open field. While there may be some economic benefits from the scheme and additional landscaping of the new element of the site it is not considered to outweigh this harm in this instance and there is little improvement to the existing parts of the site. The proposed development involves fragmentation of the existing field pattern and expansion of man-made, rectilinear elements in the form of caravan units and associated access areas into the wider rural landscape. It would harm the character and appearance of the landscape.