Establish a touring caravan site (19 unit)
with toilet block and associated works
LOCAL MEMBER: Councillor Rhys Tudur
Decision:
To refuse
the application, contrary to the recommendation
Reason:
The proposal would establish a new touring caravan site in a location
where there is an excess of existing
touring and static caravan sites, causing harm to the visual quality of the landscape and causing noise
disturbance that would have an
unacceptable detrimental impact on the amenities
of neighbouring residents, contrary to the objectives of policies TWR 5 and PCYFF2 of the
Gwynedd and Anglesey Joint
Local Development Plan.
Minutes:
Establishing a touring caravan site (19 units) with a toilet block and
associated works
Some members had visited the site and the area
surrounding Afonwen on the morning of 27 February
2023
a)
The
Planning Manager explained that this was an application to change the use of
agricultural land, to establish a touring caravan site for 19 units, extend an
existing building to create a toilet block and associated works on land at Ty'n Lôn, Afonwen.
The application was deferred at the Planning Committee
on 16 January 2023 for the Members to undertake a site visit. Since the
application was submitted to the meeting of 16 January 2023, one letter of
objection has been received.
The Manager noted that since the proposal entailed
creating a site for touring caravans, the application had been considered under
Policy TWR 5 of the Anglesey and Gwynedd Joint Local Development Plan (LDP)
that sets out a series of criteria for approving such developments. It was explained that criterion 1 of the
policy stated that any new touring caravan developments should be of a high
quality in terms of design, layout and appearance, and
well screened by existing landscape features and / or positioned where the
touring units can be readily assimilated into the landscape in a way that does
not significantly harm the visual quality of the landscape.
It was explained that the proposed development would
be located on a level field with mature trees along the boundaries and would
therefore be concealed from public places. It was reiterated that it was
proposed to reinforce the screening of the site by planting a new hedge of
native trees as the new western boundary to separate the caravan field from the
wider field. This site was not within
the Area of Outstanding Natural Beauty (AONB) nor within a Special Landscape
Area and it was not believed that it would cause significant harm to the
quality of the landscape. It was highlighted that the proposal had been
designed to meet licensing requirements in terms of space and facilities – it
was accepted that the development was up to standard.
At the committee meeting in January 2023, concerns had
been expressed about the 'cumulative impact' because of the site's proximity to
other static caravan sites such as Hafan y Môr and Ocean Heights, and the Afon
Wen touring site opposite and Sŵn y Môr to the rear. Although there were several static and
touring sites in the vicinity, the area in question was not considered to be an
example of a location that was under extreme pressure from such tourism
developments. Contrary to Policy TWR 3 that related to static caravan sites,
the cumulative impact was not a consideration in the criteria of policy TWR 5,
as touring use constituted a temporary use which had less of an impact than
static structures. However, the criteria themselves responded to the cumulative
impact in the sense that sites in obtrusive places that were not close to the
main roads network should not be permitted.
Paragraph 6.3.81 of the policy was referenced, which
notes that caravans should not be permitted in open locations near the coast
nor within an AONB – this site was situated away from an open coastal location
and there were no landscape designations in its vicinity.
In the context of general and residential matters, it
was noted based on the distance and the hidden nature of the field that the
proposal was not considered to have a significantly harmful effect on or cause
disruption to any nearby residents. It was considered that the proposal was
acceptable in terms of Policy PCYFF 2 of the LDP that related to protecting the
amenities of nearby land users.
With regard to biodiversity matters, the Biodiversity Unit had been consulted on the
application because the field in question as well as land to the north and west
of the site had been identified as a Local Wildlife site. In response to the
observations, the developer had been asked to submit an Initial Ecological
Assessment, and in light of the survey's results and a
request for further assessments, a Botanical Survey, a Badger Survey and a
Wildlife Mitigation Measures Plan were later submitted on the application. It
was noted that the Biodiversity Unit had confirmed that the reports had been
produced to a good standard, and they advised that the proposal should follow
the mitigation measures and enhancements proposed.
The Planning Officers remained of the opinion that the
proposal was acceptable and that it would not have a significantly harmful
impact on the landscape, amenities of local residents
or on road safety.
b)
Taking
advantage of the right to speak, the Local Member made the following comments:
·
Whether it
was a static or touring caravan site – the opinion was the same – it created a
high density throughout Gwynedd
·
The sites
of Hafan y Môr and Abererch Sands were very large sites, let alone other
nearby sites. What other circumstances would therefore be classed as an
'excess'?
·
He accepted
that TWR3 referred to static sites and not touring sites, but this was the
weakness of TWR 5 – there was not a clear definition of 'excess' – this was
carelessness in the Development Plan of failing to set a criterion for touring
caravans as existed for static caravans.
·
The aspects
of policy interpretation must be considered appropriately – a clear definition
must be set for excess in policies, to include touring sites.
·
He
encourages the committee to refuse the application based on excess and to
create a better policy definition in future
c)
It was
proposed and seconded to approve the application in accordance with the
recommendation.
ch) During the
ensuing discussion, the following observations were made by Members:
·
The
application met with current policy requirements
·
The site
was tidy – the buildings and the toilets were of a high standard
·
One
application had been permitted contrary to policy requirements in Dwyfor – need consistency
·
The
comments by the Local Member and Community Council must be considered, who
objected to the application based on excess
·
Some
touring caravan sites did not comply with the regulations which stated that
caravans must be removed over the Winter – there were too few enforcement
officers to monitor the situation
·
The
'cumulative effect' criterion should apply to both touring and static units
·
There were
many caravan sites in the area – in future, the coastline between Cricieth and Pwllheli would be one large caravan park
·
Why was the
policy so slack in defining 'excess'? There was a need to create a new policy
·
The
cumulative impact was unacceptable
·
The numbers
of caravans should be listed. There were too many caravans in this area
·
An excess /
over-tourism affected the culture, language, support for services and caused
disruption to neighbours
d)
In response to the observations, the Assistant Head of Planning and the Environment stated
that the application corresponded with the current policy requirements of the
JLDP – the report was clear and stated the relevant policies for touring
caravans. The application satisfied the requirements. Reference was made to an
application that had been approved contrary to the recommendation, for 32
touring caravans in an area within an AONB – there was a need to ensure that
the Committee was consistent in how it applied policies. He highlighted the
risks that the Council would face should the application be refused.
In response to the comments, the Monitoring Officer
noted that the application met the criteria and if the members suggested
refusing based on the cumulate impact, they would require evidence to highlight
the impact from the situation. He added that the Committee must demonstrate
consistency in applying and interpreting policies and criteria.
dd) Following a
registered vote, the proposal to approve fell.
e) It
was proposed and seconded to refuse the application on grounds of excess and
visual disturbance
RESOLVED: To refuse the application, contrary to the recommendation
Reason: The proposal would establish a new touring caravan
site in a location where there is an excess
of existing touring and static caravan
sites, causing harm to the visual quality of the landscape and causing noise
disturbance that would have an
unacceptable detrimental impact on the amenities
of neighbouring residents, contrary to the objectives of policies TWR 5 and PCYFF2 of the
Gwynedd and Anglesey Joint
Local Development Plan.
Supporting documents: