Siting of 9 static holiday caravans in lieu of 12 touring caravans together with environmental improvements
LOCAL MEMBERS: Councillor Anne Lloyd Jones and Councillor Mike Stevens
Decision:
To refuse the application
1.
The proposal is very vulnerable to harm and
is located within a C1 flood zone. The
proposal is not part of a regeneration strategy or strategy by the local
authority and neither does it contribute to key employment objectives that are supported by the local authority and other key
partners. The proposal is not located on
previously developed land either and the Flood Consequence Assessment submitted
with the application fails to show that risks and flood consequences can be managed to an acceptable level. Therefore, the
proposal does not meet the justification requirements included in paragraph 6.2
of Technical Advice Note Wales: Development and Flood Risk and, as a result, it
is also contrary to the requirements of Policy PS 6 of the Gwynedd and Anglesey
Joint Local Development Plan.
2.
The increase in the proposed
number of static holiday caravans is not small, or commensurate with the scale
of the proposed improvements for the site and it is above the recommended
increase of 10% in the original numbers on the site, therefore, it is contrary
to the principles of point 4 of policy TWR 3 of the Anglesey and Gwynedd Joint
Local Development Plan and Supplementary Planning Guidance: Tourist Facilities
and Accommodation.
3.
Insufficient consideration was given to landscaping matters as part of the
proposal. In light of this, it is not
considered that the proposal would add towards maintaining or enhancing the
landscape and that the proposal is contrary to the requirements of Policy PCYFF
4 of the Anglesey and Gwynedd Joint Local Development Plan.
Minutes:
The
Development Control Officer highlighted that the proposal involved extending an
existing caravan site in order to site nine static caravans in lieu of 12
touring caravans that had an extant planning permission on the existing caravan
site. It was highlighted that the application site was located outside the
development boundary of the existing caravan site and was located on level land
in the countryside off the A493 between Tywyn and Bryncrug.
The
application was submitted to the Committee at the
Local Member’s request.
It was reported
that the site was within a C1 flooding zone, which was associated with
Technical Advice Note 15: Development and Flood Risk (TAN 15). The proposal was considered as very vulnerable to harm and TAN 15 in
section 6.2 stated that locating such a development within a C1 zone should
only be justified if it could be demonstrated that the proposal met the
relevant criteria. Although discussions had been held
with the applicant's agent regarding these matters, it was highlighted that no
more information regarding the matter would be submitted.
The Flood
Consequence Assessment concluded that the proposal did not comply with TAN 15.
Following Officers' assessment of considerations in paragraph 6.2 of TAN 15, it
was considered that the proposal did not meet the
relevant requirements and was therefore contrary to the requirements of TAN 15
and the flooding matters included in Policy PS 6.
Another consideration that was given to the proposal was that it would increase the
number of static caravans on the site from the original 35 to 55 - an increase
of about 57%, which was way beyond the 10% referred to in Policy TWR 3 of the
LDP. As a result, it was considered that
the proposal was contrary to point 4 iii of Policy TWR 3
as it would not involve a small increase in the number of units on the site.
In response to observations received
from Natural Resources Wales (NRW) expressing concern regarding the visual
impact of the proposal on the landscape, it appeared that the application had
noted an intention to undertake additional native landscaping but no details
had been received. As a result, the impact of the proposal could
not be assessed in full in terms of its setting in the wider landscape
and, as a result, it was not considered that it would add to the maintenance or
enhancement of the landscape and it would be contrary to the requirements of
Policy PCYFF 4 of the LDP.
It was recommended to refuse the application.
b) Taking
advantage of the right to speak, the applicant noted the following points:
In
response to flooding concerns, he noted
·
That the application site was located
on the periphery of a tidal flood risk zone with the majority of the caravan
site, including the access, on dry land.
·
NRW had not considered that static
holiday caravans had a cavity of approximately +750mm underneath the units -
the caravan would not be affected.
·
There was access to dry land within the
site if flooding occurred - this could be managed with
a flood evacuation condition and plan.
·
The development would replace 12
touring caravans throughout the year with 9 static
holiday caravans; therefore, there would be a reduction in the number of
holiday caravans on this part of the site. In that sense, the development was
acceptable in policy terms as it would genuinely
reduce the general number permitted on the site.
In response to Landscape and Visual impact
concerns
·
In contrast to what was
noted in the Committee report, the application site was not prominent in
the wider landscape and it was well screened.
·
He encouraged the Members to visit the
site to see the existing landscape.
·
Should additional landscaping be
required, it would be possible to meet this by way of a planning condition and,
although not necessary, he would be willing do this if needed. Welsh Government
encouraged landowners to plant more trees but in order to set a perspective, a 15 acre solar panel farm, 700 metres from his site was an
eyesore.
·
The aim of the application was to
ensure the long-term sustainability of Pall Mall Caravan Park as a rural
business that would create employment for local people.
·
His daughter had graduated with first
class honours in Tourism and wanted to work in the family business. He noted
that she was passionate about the Welsh language and culture and that he wanted
to give her the best opportunity to stay at home. Approving the application
would assist him to maintain his business.
·
Several points in the report were
totally incorrect and misleading, portraying a negative attitude. He added that
the application was a simple one and that matters causing concerns could be addressed.
·
Tywyn Town
Council supported the application and appreciated the positive economic
benefits that could be received.
c) Taking advantage of the right to speak, the
Local Member made the following points:
·
He was
concerned about some statements in the report.
·
The site had been
screened effectively and, therefore, this was not a reason to refuse.
·
The site was
well-established, mature and well-managed.
·
It would
bring economic benefits to the area.
·
The size of
the site was insignificant considering sites in the north of the County.
·
There had
been no flooding in the area for over 50 years and that past flooding incidents
had not been dangerous.
·
Needed to consider
and encourage caravan sites for visitors in order to try to keep brick and
mortar buildings for local people.
·
Needed to secure sufficient resources
for visitors so that they could enjoy the beauty of the area.
·
If a deferral would
be considered, he encouraged a site visit prior to making a decision.
ch) It
was proposed and seconded to refuse the application.
d)
During the ensuing discussion, the following observations were made by members:
·
In response
to an observation made in the applicant's introduction, there was a need to
research further into the time period of the touring
caravan season.
·
Should flooding occur, siting the
caravans on plinths would address the problem.
·
A detailed assessment and further
information was required to consider potential landscaping.
RESOLVED
To refuse the
application for the following reasons:
1
The proposal was very vulnerable to harm and was located within a C1
flood zone. The proposal was not part of
a regeneration strategy or strategy by the local authority and neither did it
contribute to key employment objectives that were supported
by the local authority and other key partners.
The proposal was not located on previously developed land either and the
Flood Consequence Assessment submitted with the application failed to show that
risks and flood consequences could be managed to an
acceptable level. Therefore, the
proposal did not meet the justification requirements included in paragraph 6.2
of Technical Advice Note Wales: Development and Flood Risk and, as a result, it
was also contrary to the requirements of Policy PS 6 of the Gwynedd and
Anglesey Joint Local Development Plan.
2
The increase in the proposed number of static
holiday caravans was not small, or commensurate with the scale of the proposed
improvements for the site and it was above the recommended increase of 10% in
the original numbers on the site, therefore, it was contrary to the principles
of point 4 of policy TWR 3 of the Anglesey and Gwynedd Joint Local Development
Plan and Supplementary Planning Guidance: Tourist Facilities and Accommodation.
3
Insufficient consideration had been given to
landscaping matters as part of the proposal.
In light of this, it was not considered that the proposal would add
towards maintaining or enhancing the landscape and that the proposal was
contrary to the requirements of Policy PCYFF 4 of the Anglesey and Gwynedd
Joint Local Development Plan.
Supporting documents: