Proposed masterplan comprising the demolition of 56 apartments,
creation of new bases for the siting of static caravans, new team
accommodation, new beach café including terrace and play area, new coastal
defences, minor realignment of All Wales Coast Path as well as associated
landscaping, drainage, access and infrastructure works (amended plans)
LOCAL MEMBER:
Councillor Peter Read
Decision:
DECISION: To defer the decision in order to
undertake a site visit (subject to undertaking a risk assessment that would
consider the appropriateness and safety measures in the context of Covid-19
guidelines)
Minutes:
Proposed master-plan comprising the
demolition of 56 apartments, creation of new bases for the siting of static
caravans, new team accommodation, new beach café including terrace and play
area, new coastal defences, minor realignment of All Wales Coast Path as well
as associated landscaping, drainage, access and infrastructure works (amended
plans)
Attention was drawn to
the late observations form.
a) The Planning Manager elaborated on the application's background. The
development had been divided into parcels:
·
Parcel B - Siting of 27
static caravans.
·
Parcel E - Siting of three
static caravans and construction of 2, two-storey buildings to provide staff
accommodation.
·
Parcel F - Demolition
of 4 apartment blocks (56 apartments / 272 guest spaces) and siting of 26
static caravans.
·
Parcel G - Siting of 80
static caravans.
·
Parcel H -
Redevelopment of the former sewage treatment plant and erection of a
single-storey café with a terrace to the front and car park
·
Parcel I - Siting of 18
static caravans.
·
Parcel J - Coastal
defence works that include work on 320m of the coastline. The proposal entails
landward realignment of the coastline to create sand and gravel beaches in
between four fish tail shaped rock-armour breakwaters. Approximately 120m of the works will replace
the existing linear rock coastal defences. The Wales Coastal Path was also to
be re-aligned.
Due to the size of the site, the application was defined as a 'major
development' and given the scheme comprised of several elements, they were all
assessed separately.
Construction of
single-storey café on the site's eastern boundary that would include car
parking space, landscaping and planting work.
Given that the site was on land that formed part of the former sewage
treatment plant, it was considered to be previously developed land. The use was
also appropriate in the context of the site's wider use as a holiday park.
Although there were larger buildings towards the centre of the holiday park,
the structures seen along the coastline were mainly single-storey chalets and
caravans. It was highlighted that the
scheme had originally consisted of a two-storey café building. Following
discussions with officers, it had been agreed that the building should be
single-storey and given the reduction in scale, the type and character of the
building was now considered appropriate for its coastal setting. It was considered that the design was of a
high quality in terms of its design, layout and appearance and it would extend
the range of facilities in the plan area. The proposal was supported by an
Economic Statement which highlighted that the plan would ensure local
employment opportunities.
It was reported that it was possible to access the site using public
transport, cycling and walking with the site located directly adjacent to the
Coast path - it was noted that the planning support statement confirmed that
the Café was available to Coast Path users. It was considered that the proposal
complied with the requirements of policies MAN 1, MAN 6 and TWR 1 and that the
principle of constructing the café was acceptable.
Defence works to 320m
of the coastline including landward realignment
of the shoreline, the installation of four ‘fish-tail’ shaped rock-armour
breakwaters and the creation of intervening areas of sand/gravel beach.
It was highlighted that the application had been supported by
significant evidence in the Environmental Statement and the Economic Statement
that would justify this work. It was noted that the coastal work would be
located close to the existing built form and would secure the long-term future
of the holiday park. It was considered that the principle of the coastal work
in this location complied with policy AMG 4.
The Shoreline Management Plan (SMP) for this section of coastline was
‘No Active Intervention’ over the next 100 years. However, the policy for this
section stated that this might not preclude local private management of
defences. Given this, it was considered that the principle of replacing and
extending existing defences was acceptable in principle, however, it was noted
that the plan would have to comply with a number of policies including ARNA 1.
Alterations to the
holiday accommodation provision and extending the site
Attention was drawn to the site's planning applications history which was
relevant to this aspect of the application noting that application number
C10D/0141/40/LL giving permission to a scheme which included the demolition of
450 chalets, the creation of bases for 209 static caravans, 75 cabins and
creating a touring caravan site. As a result of this permission there was an
overall decrease in holiday accommodation provision on the site. It was
reiterated that the relevant pre-commencement conditions were discharged and
the consent had been partially implemented. The scheme currently under
consideration sought to alter the consent previously given by retaining 184
existing apartments that were previously given permission to be demolished.
Policies TWR 2 and PS14 seek to provide a range of holiday accommodation and
the retention of the apartments would not create any conflict with regards to
policy and would ensure a wider range of accommodation on the site.
It was reported that Policy TWR 3 (which dealt with
Static Caravan Sites and Chalets) noted that any increase in the number of
static holiday caravans or holiday chalet units was minor and commensurate with
the scale of any improvements to the site. It was explained that paragraph
6.3.74 of policy TWR 3 recognised that minor in terms of site area was not
defined, but in terms of numbers as a general rule an approximate 10% increase
in the number of units at the time of the original application, was considered
minor.
Recent alterations had seen a major investment with
facilities being upgraded and alterations made to the Hafan y Môr accommodation
provision. The initial plans had been permitted through consent C10D/0141/40/LL
(2010) and it was therefore considered reasonable in terms of policy TWR 3 that
consent C10D/0141/40/Ll was the original application in this instance and the
policy recognised that each application should be considered according to its
merits due to the considerable variety in the size, nature and location of
sites.
It was explained that consent C10D/0141/40/LL
permitted the siting of a total of 1,238 static caravans and the current
application sought to site an additional 85 static units, which was below the
10% stated in the policy. However, the overriding policy consideration was to
ensure that the increase in numbers did not unacceptably harm the appearance of
the site.
It was
reported that the Anglesey, Gwynedd and Snowdonia National Park Landscape
Capacity and Sensitivity Study defined 'small' as 11-25 units |(typically below
2 hectares in area). The study also acknowledged that in all cases development
should avoid the undeveloped coastal edge and its immediate setting and should
be clearly separated so that their effects remain local and there is no
collective/cumulative defining influence on the landscape.
It was
explained that parcel G (application C10D/0141/40/LL) originally included
siting static caravans close to the coastal edge however the plan had been
amended and the caravans were now located much further back and in accordance
with the area that was permitted under C10D/0141/40/LL. By now, the area between the shoreline and
the static units was being proposed as an area to be earmarked to provide an
alternative biodiversity area and to be planted as wildflower grassland. The
area was to be fenced off to protect it and to clearly differentiate between
the coastal edge and the holiday park. With the existing landscaping
surrounding the site and the proposed landscaping the visual impacts were
considered to be local in nature (mainly along a brief section of the coastal
path) and given that other visual impacts would be mitigated by distance, it
was not considered that the plan would have a defining impact on the
landscape.
Construction of new
staff accommodation by demolishing three buildings
that currently provided 40 two-bedroom self-contained apartments for staff and
the construction of two new buildings that would provide 76 two-bedroom
units.
It was reported that the site was located in open
countryside and there was no specific policy in the development plan that dealt
with accommodation of this type. It was noted that policy PCYFF 1 stated
proposals would be refused unless their location in the countryside was
essential. However, it was considered that the site already provided on-site
staff accommodation and the area to be developed for the new accommodation was
classed as previously developed land.
It was reiterated that the existing staff units formed
part of the C10D/0141/40/LL planning consent and were managed in the same way
as the holiday accommodation with a condition that restricted occupation to
seasonal use only and the staff had a permanent residence elsewhere. By
managing the units in this way, it was possible to ensure that they were not
the equivalent of providing new housing in open countryside. The net increase
of 24 staff bed spaces was not considered unreasonable and with the imposition
on conditions to ensure that the units did not provide permanent residential
accommodation, it was not considered that the application significantly
departed from planning policy.
In terms of residential and general amenities, the site was a
long-established holiday park located in open countryside. It was reported that
there were scattered residential properties surrounding the site but it was not
anticipated that the impacts upon residential dwellings to the south and west
would be any greater given that the proposed works were primarily within the
existing site and to the east. To the east, the development included the
coastal defence works, constructing the café and developing parcel G and the
nearest residential property was Tydddyn Berth. It was noted that Afon Wen
terrace was also located to the north-east and Sŵn y Don (residential
dwelling and caravan site) was located to the east and although nearby
residents had raised concerns, they did not object to the scheme as a whole.
It was anticipated that the greatest impact would be seen during the
construction of the coastal defences, which would be carried out over a
relatively short period of time - it was suggested that the construction hours
could be controlled by condition to ensure that the amenities of nearby
property were protected during the most noise sensitive times. It was noted that the construction phase
would also affect the amenity and enjoyment of coastal path users. That said, once the scheme was completed it
should have a positive amenity impact on users of the coastal path as Haven
have confirmed that although the café would not be open to non-residents, it
would be available to coast path users. Once the construction phase would be
completed, it was not considered that the development would give rise to an
unacceptable impact on residential or general amenity and the proposal was considered
to be acceptable based on the relevant criteria in policies PCYFF 2 and PCYFF
3.
In relation to Biodiversity and Ecology matters, it was noted that the
Environmental Statement had considered physical and coastal processes, water
and sediment quality, marine ecology and nature conservation; geological
ecology and nature conservation; and coastal protection and flood defence. It was explained
that the initial comments received from the Council’s Biodiversity Unit had
objected to and raised concerns about the scope of mitigation measures for the
impact of the development on otters, lowland meadow grassland, the impacts on
soft maritime cliff-sides, impacts upon the coastal habitat corridor and loss
of cloddiau.
Having consulted and held further discussions, the
proposal had been amended in response to the terrestrial ecology issues raised.
An addendum to the Environmental Statement had been submitted that assessed the
amended scheme and also offered additional mitigation measures. NRW had
confirmed that the recommendations regarding otters in the ecological addendum
were acceptable and reasonable avoidance measures should be set out in a
Construction Environmental Management Plan (CEMP) that could be secured by
condition. The Biodiversity Unit had confirmed that the amended mitigation
proposals for the lowland meadow grassland, including the coastal corridor,
were acceptable and the additional provision of cloddiau was to be
welcomed and the mitigation provided improvements in biodiversity.
The Biodiversity Unit had
objected to losing the soft maritime cliffs, noting that it would not be
possible to mitigate for their loss despite the ecological addendum noting that
the Environmental Statement had concluded that the impact would be neutral. As a mitigating
measure, the proposal would be to implement a management plan for approximately
650 linear metres of existing soft
maritime cliff elsewhere in Hafan y Môr. Additionally, 'bee banks' would be
created in the former car park, and, where possible, the 'bee hotels' would be
constructed in other development parcels. We note the Biodiversity Unit's
observations; however, the findings of the Environmental Statement were
considered reasonable and they provided details on the extent of cliff management
that could be achieved and acknowledged that this can be secured through a
planning condition.
It was highlighted that the maritime environment ran
along the site formed part of the Pen
Llŷn a'r Sarnau Special Area of Conservation (SAC), and the Glanllynnau
and Glannau Penychain to Cricieth Site of Special Scientific Interest
(SSSI). It was reiterated that the
proposed coastal defence included developing within these designations. In
accordance with the Habitats and Species Regulations 2017, the Council had
undertaken a Habitats Regulations Assessment and Appropriate Assessment and
under the provisions of the regulations, there was a statutory duty for a Local
Planning Authority to consult with NRW when undertaking an appropriate
assessment for a new plan or project and are required to have regard to any
representations made by NRW. The response received
had concluded that an adverse effect on the site integrity of the special
conservation area could not be ruled out due to the direct loss of the mudflats
and sandflats feature. However, NRW did
not consider that the proposal would have an adverse effect on the reef feature
due to the distance of the proposal to the reef feature. In addition, they did not consider that the
proposal would have an adverse effect on the otter feature as long as their
advice in relation to securing mitigation (via CEMP) as a condition on any
planning permission.
It was reported that a marine licence would be required for the
development and that the applicants had applied for a licence to NRW in
December 2019. NRW created a Statement of Case and it was referred to Welsh
Government. There was further consultation with Welsh
Government and it was advised that there was no need to repeat the notification
process through the planning process and as such, the HRA considerations and
process had already been met.
Conclusions:
The Environmental Statement had assessed the
impact on the environment and it was concluded that with the imposition of
planning conditions the development impacts could be satisfactorily mitigated
and environmental features protected.
The proposal had also been assessed under the Habitats and Species
Regulations 2017 and considered acceptable.
The visual and landscape
impacts were considered acceptable with the imposition of phasing conditions
and a condition to ensure the proposed landscaping was carried out. With conditions, it was concluded that the
amenities of surrounding residential properties could be satisfactorily
safeguarded.
The site was considered to
be sustainably located, offering alternative methods of transport that placed
less reliance upon use of the motor vehicles.
The highway network was considered suitable to serve the proposal and
the coastal sea defences would help safeguard the coastal path and public
safety.
The proposed development would extend and
improve the quality of the park and would help to maintain Hafan y Môr Holiday
Park as a holiday destination and improve public access to recreational
activities. Economic benefits were
acknowledged and no harm to the Welsh Language was identified.
The proposal had demonstrated that the development
would not cause any increase in risk to life nor any significant risk to
property. It was also
considered that the works would contribute to reducing the
potential for major flood incidents in the area in the future.
It was considered that the principle of
the main aspects of the development, which included work on sea defences,
siting additional static caravans, providing additional accommodation to staff
an constructing a café, was acceptable given all material planning matters,
including local and national planning policies and guidance.
b) Taking advantage of the right to speak, the applicant’s agent noted the
following points:
·
That the application
noted Hafan y Môr's vision over the next ten years.
·
It would provide high
quality accommodation, an attractive beach café, demolish dormant two-storey
flats and create new coastal defences.
·
Welcoming the Officer's
recommendation: the result of three years of significant cooperation with
officers as well as NRW.
·
That Haven wished to
invest to improve the range and quality of accommodation and facilities for
tourists - this followed an investment of over £13 million in 2018 to upgrade
the central facilities.
·
Haven wanted to ensure
that the Park was able to offer high quality provision to all guests including
local people who visited the park and also its employees.
·
That the application
would lead to a moderate increase in accommodation. The areas for the new
accommodation were a combination of brownfield and greenfield sites and a large
section of the greenfield area (Parcel G) had already received permission.
Parcel G was currently screened by thick woodland and further comprehensive
landscaping would be provided as part of this development.
·
As a responsible owner,
Haven wished to invest to upgrade coastal defences.
These defences would provide long-term stability for the holiday park
and the Wales Coastal Path. The path was a popular tourist attraction but it
was being eroded by the sea. A marine licence had been issued by NRW for the
coastal defences, confirming that the environmental impact was acceptable.
·
An attractive beach
café was proposed on the site of the former sewage treatment works. This would
serve guests and any coastal path users who required refreshments. Following advice, the height of the café had
been reduced to a single-storey building. It would sit well within the local
landscape
·
Hafan y Môr was one of
the largest private employers in Gwynedd and was committed to provide stable,
high quality jobs to people in the local area. Currently,
Hafan y Môr employed 460 people with over 50% of the team living within 5 miles
to the park.
·
The proposals would
create 227 construction jobs and once the work was completed they would support
58 additional full-time equivalent jobs. The posts would be advertised locally
through Gwaith Gwynedd, Agoriad an campaigns in the Daily Post and on S4C. Only
if jobs cannot be filled will they be advertised centrally by Haven.
·
Hafan y Môr was proud
of the Welsh Language and recent developments in the park includes public art
that promoted the language.
·
This development would
create further local jobs and would provide opportunities for Welsh speakers to
gain employment without having to move away or travel vast distances.
·
“We trust that you will
agree with your Officers that this application is a sustainable development
that provides social, economic and environmental benefits, satisfying relevant
policies including TWR3.”
·
He hoped that the
Committee would support the application.
c) Taking advantage of the right to speak, the Local
Member made the following points:
·
He supported the
application
·
That Hafan y Môr
offered local employment
·
That the company was
developing and modernising the site
·
That the coastal
defence work was to be welcomed
·
That use of bilingual
signage was visible in the Park
·
Local contractors would
be used to carry out the work
·
That he had developed a
good relationship with the site owner and had worked well with him over the
years. He noted that Mr Blackstone, the owner of Hafan y Môr was to retire soon
after 30 years' service - and wished him a happy retirement.
ch) It was proposed and seconded to approve
the application
d) During the ensuing discussion, the following
observations were made by members:
·
Despite
recognising the 10% formula, the additional number, if there were a thousand
caravans, would be excessive - had refused applications for an increase of 3-4
caravans!
·
Needed to
consider the total area of the site in the context of health and safety and
sufficient space between caravans - if approved, how much further would the
site extend?
·
Concern
that the staffing facilities encouraged employing people from outside the local
area.
·
Why was
there a need to provide 71 units? The offer for staff to stay at the park meant
a reduction in their salaries - local staff would not be able to compete with
this.
·
That
caravan site labour costs were less - no need for joiners, plumbers etc.
·
Landscaping
took time to create an impact - the new developments would be an eyesore until
the vegetation would grow
·
Need to
take note of the Community Council's striking observations which objected to
the application and raised questions
·
That the
work of creating the shoreline was costly - would it be successful?
·
Concern
about loss of habitat - the site area was very beautiful
·
Need to
protect the Pen Llŷn a'r Sarnau conservation area - constructing defences
would have an impact on the cliffs.
·
The proposal
was an over-development and would impact visual amenities
·
The company
wanted more and more! The site was enormous - enough was enough! Did Policy TWR
3 consider the size, location and nature of such a large application?
·
Although
some of the buildings were ugly and would be modernised, seeing a number of
caravans could also be an eyesore
·
There was a
need to improve the standard of the staff building - to modernise it and make
is safe, of quality and comfortable.
·
That a
licence had already been granted for the coastal defence works.
·
That the
café was acceptable as a resource for the public footpath users and not for
residents only.
·
Hafan y Môr
was a good employer, providing local employment and supporting tourism - the
holiday park facilities were very good and the company was investing in those
resources.
·
That work
for local people included maintenance and construction
·
Needed to
consider the Local Member's observations
·
Encouraged
a site visit to gain a better understanding of the site - the application was
unique and therefore there was a need to defer a division to arrange to visit
the site to weigh up elements of the application that were complex.
·
Should
covid guidelines and a risk assessment by the Public Protection Department permit
a site visit, it was suggested that a visit should be arranged on a day that
the Committee was not being held.
dd) In response
to a question regarding ensuring that experts carried out the coastal defence
works and that the silt and the sand were not moved on to the next location
along the coast, the Head of Legal Services noted that appointing contractors
was not a planning matter but that a licence issued by the Crown or Natural
Resources Wales set out stringent guidance for the work. The Planning Manager reiterated that the
assessments had been completed by an expert and that the sea-wall had been
designed to reduce the impact of waves that would in the long run reduce the
broader impact on the coastline.
In
response to a question on the work schedule, likely appeal costs and the need
for a decision the Assistant Head of Environment Department noted that the
applicant would have the option to submit an appeal for a lack of decision and
that the cost would be based on the reasons for refusal if it were to come to
that.
e) Proposed and
seconded - an amendment to hold a site visit subject to undertaking a risk
assessment.
RESOLVED: To defer the decision
in order to undertake a site visit (subject to undertaking a risk assessment
that would consider the appropriateness and safety measures in the context of
Covid-19 guidelines)
Supporting documents: