3 - gwynus caravan park and golf course, pistyll · 1/12/2015 · from part of field 472 to part...

PWYLLGOR CYNLLUNIO DYDDIAD: 12/01/2015ADRODDIAD UWCH REOLWR GWASANAETH CYNLLUNIO AC AMGYLCHEDD

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Number: 3


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REPORT TO THE PLANNING COMMITTEEREFER TO A COOLING OFF PERIOD

DATE OF THE PLANNINGCOMMITTEE:

12 January 2015

DESCRIPTION AND LOCATIONOF APPLICATION:

Application Number C14/0653/43/LL – Upgrade anexisting static caravan park and relocate it from part of field472 to a part of field 470

REPORT BY: Senior Manager, Planning and Environment Service

RECOMMENDATION: To accept the recommendation, which is to refuse theapplication.

1. PURPOSE

1.1 The application was submitted to the Planning Committee on 24 November 2014 andthe Committee’s intention was to approve the application contrary to the officers’recommendation. In the view of the Senior Manager – Planning and EnvironmentService, there is a significant risk to the Council in respect of the decision to approvethe application contrary to officers’ recommendation; therefore, the matter wasreferred to a cooling off period in accordance with the committee’s standing orders.The purpose of reporting back to the Committee is to highlight the planning policyissues, the possible risks and the possible options for the Committee before it reachesa final decision on the application.

2. DESCRIPTION

2.1 The application relates to upgrading the existing static caravan site and relocating itfrom part of field 472 to part of field 470 that currently has permission to be used as agolf course. The proposal would include relocating the entire static caravan site (10 innumber), to the new site and exchanging the static caravans for twin static holidaycaravans. The area of the site that is the subject of the application is 4.96 hectares(namely field no. 470), and the surface area of the existing Gwynus caravan parkwhich contains static and touring caravans is 1.69 hectares.

2.2 Policy D17 of the GUDP approves proposals to upgrade existing static holidaycaravan and holiday chalets sites through:-

i. Small extensions to the area of land.ii. Relocating static holiday caravan units or holiday chalet sites from

prominent settings to less prominent locations.iii. A small increase in the number of units.iv. Exchanging touring pitches for static holiday caravan units.

2.3 The applicant has already been granted planning permission C13/0532/43/LL forupgrading the existing caravan park by means of:-

i. Relocating the static caravans to field 471.ii. Moving the touring units from field 471 to the field of the static caravans.iii. Formalising the use of part of field 4942 for locating touring caravans where

previously there had been no permission and therefore the application alsoincluded extending the boundary of the touring caravan site.

iv. Constructing a new reception with a counter for selling small goods.


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This planning permission has been implemented by virtue of the fact that touringcaravans have been sited on part of field 4942 where previously there was noplanning permission for this. The relocation elements which were the subject of thatapplication were located within the definite boundaries of the existing caravan park,with only a small extension to field 4942 for locating touring caravans.

2.4 In respect of the current planning application, this would mean exchanging theexisting 10 static holiday caravans for 10 twin static holiday caravans and relocatingthem entirely to a part of the land of the golf course. It must be emphasised that theentire golf course is located outside the boundaries of the existing caravan park.

2.5 As noted in 2.2 Policy D17 is supportive of the principle of upgrading whichproposes small extensions to the land area of existing static holiday caravan sites.However, the current planning application is not considered eligible to be consideredas a small extension to the land area of existing static caravan site. The land area ofthe extension, namely the planning application, is 4.96 hectares compared with 1.69hectares which is the land area of the existing caravan park in its entirety (static andtouring units). Furthermore, it must be questioned whether the proposal is eligible tobe considered as an extension at all. It is proposed here to relocate all of the 10existing static caravans which therefore means relocating the static holiday caravansite in its entirety to a new location. Also, there is no physical connection betweenthe element of the existing holiday caravan park and the proposed location, and it isalso proposed to create a completely separate access and track. The proposal wouldmean that the caravans are distributed over a wider area than the size of the existingstatic and touring holiday caravan site and it does not appear that there would bedefinite boundaries to the new site. It is therefore considered that the proposal wouldbe tantamount to establishing a new static holiday caravan site. It is emphasisedtherefore that the application would be entirely contrary in principle to criterion 1 ofPolicy D17, which supports small extensions to the current land area.

2.6 Approving the current application would significantly increase the current size of thecaravan site in Gwynus, since the surface area of the application site is over threetimes larger than the area of the existing caravan park. The relevant information inrespect of the size of the application site and the size of the existing caravan park isnoted below:

The size of the existing caravan park at Gwynus including touring and staticcaravans is 1.69 hectares as approved under application C13/0532/43/LL.

Out of the 1.69 hectares the size of the static caravan site before approvingapplication C13/0532/43/LL is 0.19 hectares.

Out of the 1.69 hectares the size of the static caravan site approved inapplication C13/0532/43/LL is 0.4 hectares.

The size of the static caravan site that is the subject of the current applicationis 4.96 hectares.As can be seen the size of the site within the current application issubstantially larger than the current situation, and it can be seen thatpermission was granted to double the size of the static caravan site under theprevious application C13/0532/43/LL. The proposal would also increase thesize of the entire caravan park:-

The size of the caravan park including the site of the current application andthe existing site that was approved under application C13/0532/43/LL is 6.65hectares.


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2.7 It can be seen that policy D17 supports the relocation of static holiday caravan unitsor holiday chalets sites from prominent sites to less prominent locations. Theadvantage of this principle is to enable existing caravan sites that are located invisually prominent sites, particularly within the AONB, to be relocated to lessprominent locations and thus reduce the visual impact on the landscape. Contrary tothe previous application, the current application means relocating the existing staticholiday caravans from a fairly concealed position within the boundary of the existingcaravan park to a much more visible and open site outside the boundaries of theexisting caravan park. This is considered to be in complete contravention of theprinciple of Policy D17 in respect of relocation, as it is not proposed to relocate theunits from a prominent site to a less prominent location. Also, it is not proposed hereto relocate a few static caravans but to relocate the entire static caravan site from itscurrent location to a site that is located outside the existing boundary of the caravanpark. To all intents and purposes this would be tantamount to establishing a new staticholiday caravan park.

2.8 Policy D17 also seeks that the proposal is part of a development that offerssubstantial and permanent improvements to the design, layout and appearance of thesite and its position in the surrounding landscape. The proposal would relocate thestatic holiday caravans to a site that is more prominent in the landscape and which isoutside the existing boundaries of the caravan park. Therefore, it is not consideredthat the proposal would comply with criterion 2 of Policy D17 as the proposal wouldhighlight the site in the landscape rather than make improvements to its appearancewithin the protected landscape.

2.9 Therefore, as a result of the above, it is not considered that the proposal complieswith the principles or the criteria of policy D17 of the GUDP. Indeed, it could beargued that the proposal in question is to create a new static caravan site which wouldbe completely contrary to the requirements of Policy D16 of the GUDP, which statesthat proposals to develop new sites for static holiday caravan units or holiday chaletswill be refused. It must be noted that this policy has been strictly implemented withinthe Local Planning Authority since its adoption.

2.10 Policy B8 of the GUDP assesses the impact of developments on the AONB. Theproposal would involve relocating the static caravan units to a part of the existing golfcourse. Although a number of trees have been planted within and around theperiphery of the golf course, these have not matured and are not as thick as thelandscaping that has been undertaken around the existing caravan site. Although thereare different land forms and gradients within the site of the golf course which couldassist in landscaping the proposed development, the site that is the subject of theapplication is considered to be more open in nature than the existing caravan site.The site would be visible from the byway that runs along the boundary of the golfcourse. It is also considered that the site would be visible from public footpaths thatare located on higher ground and further away from the site. It is considered that theproposed location would be more visible than the existing caravan site because of themore open nature of the field. Consequently, it is not considered that the proposalwould ensure that the character of the AONB is protected, maintained or enhancedand, therefore; the proposal would significantly harm the rural landscape of theAONB contrary to the requirements of Policy B8 of the GUDP.

2.11 In terms of the background of reporting on this application, the application was firstsubmitted to the Planning Committee on 22 September 2014 and was deferred inorder to undertake a site visit. The site visit was held on the morning of theCommittee meeting on 24 November 2014 when the application was re-submitted to


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the Committee. The members voted to approve the application contrary to theofficers’ recommendation at the Committee on 24 November 2014.

2.12 The officers’ recommendation had been to refuse the application for two reasons,namely:

That the proposal meant relocating the static caravan site in its entirety to amore prominent and visible location in the landscape, and it was notconsidered that the site that is the subject of the application was a smallextension to the existing site, therefore it was contrary to the requirements ofPolicy D17 of the GUDP (and consequently also contrary to Policy D16).

That the proposed location is more visible than the existing caravan site andconsequently, it was not considered that the proposal would ensure that thecharacter of the AONB was protected, maintained or enhanced and thereforethe proposal would cause significant harm to the rural landscape of theAONB, contrary to the requirements of Policy B8 of the GUDP.

A copy of the report and the plans submitted to the Planning Committee on 24November 2014 are attached in appendix 1, which further explain the background ofthe application. Since submitting the application to the Planning Committee on 24November 2014, a tree planting scheme has been received from the applicant. Thisscheme shows a proposal to plant a band of trees (Italian Alder) on higher ground tothe north of where it is proposed to site the caravans. A copy of the tree plantingscheme is attached in appendix 2. However, it was confirmed to the applicant thatthere were significant concerns in terms of the principle of the application and thatplanting trees would not overcome these concerns.

3 POLICY CONTEXT

3.1 Paragraph 5.3.5 of Planning Policy Wales (Edition 7, July 2014) states that theprimary objective for designating AONBs is the conservation and enhancement oftheir natural beauty, and that development plan policies and development controldecisions affecting AONBs should favour conservation of natural beauty.

3.2 Paragraph 11.1.1 of Planning Policy Wales states that tourism is vital to economicprosperity and job creation in many parts of Wales and that tourism can be a catalystfor environmental protection, regeneration and improvement in both rural and urbanareas. However, paragraph 11.1.6 states that in some places there may be a need tolimit new developments to avoid damage to the environment or to the amenities ofresidents and visitors.

3.3 Paragraph 11.2.1 of Planning Policy Wales states that development plans shouldestablish a strategic framework for the provision and enhancement of tourism, sport,recreation and leisure facilities, and that they should consider the scale and broaddistribution of existing facilities and activities. They should do this in ways whichprotect the landscape, biodiversity, the coast, the historic environment and areas ofspecial interest, as well as the interests of local communities. Paragraph 11.3.1 furtherstates that, when determining planning applications for tourism developments, localplanning authorities need to consider the impact of the proposals on the environmentand the local community.

3.4 Paragraph 12 of Tan 13: Tourism states that holiday caravan sites can be intrusive inthe landscape, particularly on the coast. It also states that special consideration needs


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to be given to proposals for new sites, especially in National Parks, Areas ofOutstanding Natural Beauty, the Heritage Coast and sites of national and internationalimportance that have been designated for their natural features.

3.5 Paragraph 13 of TAN 13 further states that new and extended sites should beeffectively screened, and planned so as not to be visually intrusive.

3.6 Paragraph 14 of TAN 13 states that local planning authorities should examine thescope for encouraging holiday caravan site operators to improve the quality of theirsites and to relocate sites away from particularly sensitive areas, such as the HeritageCoast. Policies to this effect should be included in development plans. In some cases,to facilitate improvements or relocation, local planning authorities may need toconsider some expansion of the area covered by a site, so that improved layouts andbetter landscaping can be implemented.

3.7 The adopted Development Plan is the Gwynedd Unitary Development Plan (July2009) and the relevant policies are policy B8 (The Llŷn and Anglesey Areas of Outstanding Natural Beauty) and policy D17 (Upgrading of Existing Static HolidayCaravan and Holiday Chalet Sites). Because of the substantial size and the separatenature of the ‘extension’ to the existing caravan site which forms part of theapplication, it is also considered that policy D16 (Provision of New Static HolidayCaravan and Holiday Chalet Sites) is relevant.

3.8 Policy B8 states that the aim will be to protect, maintain and enhance the character ofthe Areas of Outstanding Natural Beauty and that development proposals that wouldcause significant harm to the area’s landscape and coastline (including views into andout of the area), wildlife, historic remains and buildings, language and culture and itsquiet, unpolluted nature will be refused.

3.9 In terms of assessing the principle of the application, Policy D17 is the main policy.Policy D17 states that proposals to upgrade existing static holiday caravan andholiday chalets sites will be approved, through:-a) minor extensions to the land areab) the relocation of units from prominent settings to less prominent locationsc) a minor increase in the number of unitsch) proposals to exchange touring pitches for static units.

However, the above will only be approved they comply with a series of criteria aimedat securing improvements to the site and its setting in the surrounding landscape.

3.10 The explanation to Policy D17 in paragraph 6.3.16 states that many sites are locatedin visually sensitive areas, particularly along the coastline, and that the aim of thispolicy is to promote improvements and upgrade the standard of visitoraccommodation on existing sites, and to reduce the impact of these sites on thelandscape, including views out of the Snowdonia National Park. The explanation alsostates that a proposal to replace single unit holiday caravans with twin unit holidaycaravans will be regarded as insufficient justification for permitting applicationsunder Policy D17.

3.11 Policy D16 states clearly that proposals for the development of new sites for staticholiday caravan units (single or twin caravans) or holiday chalets will be refused. Inthe policy explanation in paragraph 6.3.15 it states that the proliferation of staticcaravan and chalet parks, particularly along the coastline, has had a detrimental effecton the appearance of the landscape. It also states that the high number of existing


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sites means that the Plan area is already well served by such uses, with the staticholiday caravan and holiday chalet sector providing the majority of all visitoraccommodation bed spaces within the County, and consequently there is nojustification for the provision of new static holiday caravan sites.

3.12 In the Public Inquiry into the UDP the Inspector stated, based on the evidence, that hehad no reason to reach a different opinion to that of the Council that the Plan areacontained a good provision of static caravan and holiday chalet sites. He also statedthat there were sites within the area that needed improving and that a policy ofpreventing the establishment of new sites was more likely to lead to investment in theexisting provision. This would lead to upgrading facilities and better landscaping,which would bring economic and environmental advantages to the area.

3.13 Figures show that there are a total of 267 static holiday caravan sites within Gwyneddas a county. 83 of these sites are located within the boundaries of the SnowdoniaNational Park, therefore the remainder, a total of 184 static holiday caravan sites, arelocated within the boundaries of the Gwynedd planning authority.

3.14 In addition, the Supplementary Planning Guidance: Holiday Accommodation (July2011) is a material planning consideration and supplements the relevant policies ofthe UDP. Considerable weight can be applied to it as it was subject to a publicconsultation and was approved as guidance at the Council Board meeting on 26 July2011.

3.15 Section 38(6) of the Planning and Compulsory Purchase Act 2004 and paragraph2.1.2 of Planning Policy Wales emphasise that planning decisions should be inaccordance with the Development Plan, unless material planning considerationsindicate otherwise. Planning considerations include National Planning Policy and theUnitary Development Plan. The proposal is contrary to the direction given in thenational and local policies in respect of the policy principles that must be taken intoconsideration with applications to upgrade static caravan sites. Further to this theapplication would not protect, maintain or enhance the AONB.

4. RISKS TO THE COUNCIL OF APPROVING

4.1 As has been outlined above, approving the application would undermine policies on anational and local level in respect of extending static caravan sites.

4.2 Approving the application would create inconsistency in terms of implementingplanning policies when determining applications for upgrading static holiday caravansites and providing new static holiday caravan sites, and would undermine relevantlocal and national policies.

4.3 There is a risk attached to approving an application that involves exchanging theexisting 10 static holiday caravans for 10 twin static holiday caravans and relocatingthem entirely to a part of the land of the golf course which is located entirely outsidethe existing boundaries of the caravan park. Whilst Policy D17 is supportive of theprinciple of small extensions to the land area of existing static holiday caravan sites,the application does not constitute a small extension, and it is questioned whether thecurrent planning application is eligible to be considered as an ‘extension’ since itinvolves relocating the entire static holiday caravan site to a new location. In additionto this it is proposed to create a completely separate access and track to the site that isthe subject of the application. The proposal would also involve distributing thecaravans over a much broader area than the size of the existing static holiday caravan


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site on field 472 and it does not appear that there would be definite boundaries to thenew site.

4.4 Approving the current application would significantly increase the size of the staticcaravan site. The original static caravan site had an area of 0.19 hectares. ApplicationC13/0532/43/LL was approved which increased the size of the static caravan site to0.4 hectares. This doubled the size of the static caravan site but the currentapplication would significantly increase the size, making the land area of the staticcaravan site 4.96 hectares, which is nearly three times the size of the entire existingcaravan park of Gwynus (static and touring units).

4.5 Furthermore the current application would mean relocating the existing static holidaycaravans from a fairly concealed location within the boundary of the existing caravanpark to a more visible and open site outside the boundaries of the existing caravanpark. This is contrary to the principles of Policy D17, as they would not be relocatedfrom a prominent setting to a less prominent location. In turn, this would haveimplications for the designated landscape of the AONB and the need to protect,maintain and enhance the character of the AONB and ensure that the proposal wouldnot cause significant harm to it.

4.6 There are 267 static holiday caravan sites within Gwynedd as a county. Of these 267sites 184 are located within the boundary of the Gwynedd planning authority. Therewould therefore be a significant risk and implications in terms of implementing theplanning policies when determining applications for upgrading static holiday caravansites and creating new static holiday caravan sites on alternative sites within thecounty should the current application be approved. Approving the application wouldundermine those relevant local and national policies to be implemented on similarapplications on other static holiday caravan sites within the county. Considering thenumber of sites within the County and within the AONB, consistent application of theplanning policies is essential. Approving the application, which is unacceptable inprinciple, would undermine planning policies and the Council's integrity, and wouldcreate substantial risks for the Council.

4.7 There is a risk of the application being called in by the Welsh Government to bedetermined. As well as the risk of individual applications being called in, the WelshGovernment has powers to intervene formally in the way the Council provides thePlanning Service. This would be the greatest risk to the Council ultimately.

4.8 A risk of a complaint of maladministration to the Ombudsman.

5. OPTIONS TO THE COMMITTEE

5.1 The options open to the Committee in determining the application include thefollowing. The risks to the Council noted in section 4 of this report are relevant to theoptions which include approving the application:

i. Refuse the application in accordance with the recommendation below.There will be an opportunity for the applicant to submit an appeal to thePlanning Inspectorate in accordance with the standard procedure.

ii. Refuse the application in accordance with the recommendation and suggestthat the applicant discusses alternative upgrade options which would meet therequirements of the relevant planning policies and include a small extensionwhich incorporates the existing site.


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iii. Approve the application subject to signing a section 106 agreement to deletethe previous permission C13/0532/43/LL and to relevant planning conditions.

6. RECOMMENDATION

6.1 To refuse in accordance with the recommendation in the report (Appendix 1) and inorder to avoid any doubt, refer also to Policy D16:

1. The proposal would mean relocating the static caravan site in its entirety to a moreprominent and visible position in the landscape and it is not considered that the sitewhich is the subject of the application is a small extension to the existing site and,therefore, it is considered that the proposal is contrary to the requirements of PolicyD17 of the GUDP. Also, and because of the size and the relationship of the proposalin the context of the existing site, it is considered that the proposal is contrary toPolicy D16 of the GUDP.

2. It is considered that the proposed location would be more visible than the location ofthe existing caravan site and consequently, it is not considered that the proposalwould ensure that the character of the AONB is protected, maintained or enhancedand that the proposal would therefore cause significant harm to the rural landscapeof the AONB contrary to the requirements of Policy B8 of the GUDP.

7. APPENDICES

7.1 Appendix 1 – A copy of the report and the plans that were submitted to the PlanningCommittee on 24 November 2014

7.2 Appendix 2 – Tree planting scheme.

PLANNING COMMITTEE DATE: 24/11/2014REPORT OF THE SENIOR PLANNING AND ENVIRONMENT SERVICE MANAGER

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APPENDIX 1

Application Number: C14/0653/43/LLDate Registered: 11/07/2014Application Type: Full - PlanningCommunity: PistyllWard: Llanaelhaearn

Proposal: UPGRADE EXISTING STATIC CARAVAN SITE AND RELOCATE IT FROM PART OF

FIELD 472 TO PART OF FIELD 470Location: GWYNUS CARAVAN PARK AND GOLF COURSE, PISTYLL, PWLLHELI,

GWYNEDD, LL536LY

Summary of theRecommendation:

TO REFUSE

1. Description:

1.1 The application was postponed at the request of the Planning Committee Members atthe Committee on 22 September 2014 in order to undertake a site visit.

1.2 The application relates to upgrading the existing static caravan site and relocating itfrom part of field 472 to part of field 470 that currently has permission to be used as agolf course. The proposal would include relocating the entire static caravan site (10 innumber), to the new site. The proposed holiday units would measure approximately12.2 metres by 6.1 metres and they would be finished with a timber effect appearance.No details were received to explain what the proposal is in terms of field 472, namelythe exiting static holiday caravan site

1.3 There is currently permission to site a total of 10 static and 55 touring caravans on thecaravan site. The static caravans are located on part of field 472 and the touringcaravans on fields 471 and 475. There is also permission for storing 40 touring caravanson the northern part of field 472 during the winter months. At the moment, there isplanning permission to use field 470 as a golf course. Application C13/0532/43/LL wasapproved in November 2013 to upgrade existing static caravans for holiday lodges andrelocate them to field 471, move touring units from that field to static caravan field 472,together with the demolition of pigsties and construct a new reception in its place withcounter to sell small goods. When dealing with the application, the use of part of field4942 was formalised to locate touring caravans where previously there had been nopermission and therefore the application also included extending the boundary of thetouring caravan site. This planning permission has been implemented by virtue of thefact that touring caravans have been located on part of field 4942 where previously therewas no planning permission for this. This application was a proposal to upgrade the siteby relocating the static caravan site to field 471. However, it is understood thatfollowing receipt of this permission, the applicant contacted the manufacturers of thestatic units and he was given to understand that only five or six units at most would bepossible to locate on field 471. Also, it is understood that it will only be possible tolocate around two units on the existing static caravan site on field 472.

1.4 From the information submitted as part of the application, it is understood that the GolfCourse is no longer viable as a consequence of competition from other courses and alsoas a result of poor seasons for sport. Therefore, it is the applicant’s intention to make


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alternative use of the golf course. In the information submitted with the application, theapplicant considers that this would be a means of:-

Upgrade the provision offered on site. Separating the static units from the touring units. Provide a unique resource by combining the holiday units with the greens of the golf

course and market them with private putting greens. Ensure that the family business continues.

He also considers that the site in question is the best site in terms of its needs associatedwith the proposal. The logic for choosing to locate the static units on part of field 470 assubmitted in the application includes the following:-

Offers sufficient space between units Views A separate site from the touring caravans. A location near the existing greens. Hundreds of trees have been planted around and in the centre of the field and they are

indigenous, deciduous trees that form natural boundaries.It is hopeful that this proposal will create one additional full-time job. It is also proposedto use a local company to produce the units along with local contractors to undertake thepreparatory work.

1.5 The site is situated in the countryside and lies within an Area of Outstanding NaturalBeauty (AONB). The site lies within the Llŷn and Bardsey Island Landscape of Outstanding Historic Interest. The site is served by an unclassified road off the secondclass county road to the north west. There are public footpaths in the vicinity. A staticand touring caravan park is located on the site and a golf club and a number of treeshave already been planted and established around and within the site boundary so as toreduce the impact of the site on the landscape.

1.6 The application is submitted to Committee as the site is owned by a Council member.

2. Relevant Policies:

2.1 Section 38(6) of the Planning and Compulsory Purchase Act 2004 and paragraph 2.1.2of Planning Policy Wales emphasise that planning decisions should be in accordancewith the Development Plan, unless material planning considerations indicate otherwise.Planning considerations include National Planning Policy and the Unitary DevelopmentPlan.

2.2 Gwynedd Unitary Development Plan 2009:

B8 - THE LLŶN AND ANGLESEY AREAS OF OUTSTANDING NATURAL BEAUTY (AONB) - Safeguard, maintain and enhance the character of the Areas ofOutstanding Natural Beauty by ensuring that proposals conform to a series of criteriaaimed at protecting the recognised features of the site in accordance with the statutoryrequirements of the Countryside and Rights of Way Act 2000.

B12 – PROTECTING HISTORICAL LANDSCAPES, PARKS AND GARDENS -Safeguard landscapes, parks and gardens of special historical interest in Wales fromdevelopments which would cause significant damage to their character, their appearanceor their setting.

B27 – LANDSCAPING SCHEMES - Ensure that permitted proposals incorporatesoft/hard landscaping of a high standard which is appropriate for the site and which


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takes into consideration a series of factors aimed at avoiding damage to recognisedfeatures.

CH33 – SAFETY ON ROADS AND STREETS - Development proposals will beapproved provided they comply with specific criteria relating to the vehicular access, thestandard of the existing roads network and traffic calming measures.

CH36 – PRIVATE CAR PARKING FACILITIES - Proposals for new developments,extensions to existing developments or change of use will be refused unless off-streetparking is provided in accordance with the Council’s current parking guidelines, andhaving given due consideration to the accessibility of public transport, the possibility ofwalking or cycling from the site and the proximity of the site to a public car park.

D16 – PROVISION OF NEW STATIC HOLIDAY CARAVAN AND HOLIDAYCHALET SITES - Proposals for the development of new sites for static holiday caravan(single or twin caravan) units or holiday chalets will be refused.

D17 – UPGRADING OF EXISTING STATIC HOLIDAY CARAVAN ANDHOLIDAY CHALET SITES Proposals to upgrade existing static holiday caravan andholiday chalet sites using specific methods will be approved provided they conform tocriteria regarding improving the range and quality of accommodation and facilities;substantial and permanent improvements to the design, setting, and appearance of thesite and its setting in the surrounding landscape; together with increasing the number ofunits.

Supplementary Planning Guidance – Holiday Accommodation (2011)

2.3 National Policies:

Planning Policy Wales (Issue 7), July 2014Technical Advice Note 13 – Tourism

3. Relevant Planning History:3.1 95/00260/COU - Extend static caravan site and increase the number from 6 to 10 –

Approved 10 January 1996.

3.2 C00D/0446/43/LL – Establish a nine-hole golf course including engineering works,parking provision and landscaping, site static caravan for use as reception, establish atouring caravan park including associated access road, changes to access junction, andinstallation of new septic tank for the existing touring caravan site – Approved 12March 2001.

3.3 C02D/0079/43/LL - Construct a toilet block for a caravan site and provision ofchildren’s play area – Approved 20 May 2002.

3.4 C03D/0391/43/LL – Amend condition 10 on planning permission no.C00D/0446/43/LL to exchange four touring caravans for four additional static caravans– Refused 26 September 2003.

3.5 C03D/0578/43/LL - Use part of a touring caravan site to store eight touring caravansbetween 31 October and 1 March – Approved 11 March 2004.


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3.6 C04D/0624/43/LL - Retain and continue to use a field to site 10 touring caravans,construct a new toilet block for the disabled and change of use of agricultural field toplaying field – Approved 22 February 2005.

3.7 C06D/0017/43/LL - Siting of eight pine cabins – Refused 14 March 2006.

3.8 C06D/0285/43/LL - Siting of six pine cabins – Refused 18 April 2007.

3.9 C06D/0441/43/LL – Increase the number of touring caravans from 18 to 25 by sitingseven additional touring caravans on field number 471 and increasing the number oftouring caravans to be stored over the winter on field number 471 from eight to 18 –Approved 20 March 2007.

3.10 C07D/0496/43/LL – Change of use of land to create a site for 12 touring caravans –Approved 3 January 2008.

3.11 C08D/0371/43/LL – Create a site for nine additional touring caravans on field no. 475and four passing places on the access road – Application withdrawn on 12 July 2010.

3.12 C010D/0303/43/LL - Increase the number of touring caravans on the site from 37 to 55by locating 16 additional caravans on field 475 and two additional caravans on field 471and increase the number of touring caravans to be stored over winter on field 472 from18 to 40 and change of use of a part of field 4942 to create a football and games area forthe site – Approved 29 September 2010.

3.13 C12/1467/43/CR - Demolish existing pig-sties and site a new timber building for use asa reception – Withdrawn 28 January 2013.

3.14 C12/1508/43/CR - Demolish existing pig-sties and site a new timber building for use asa reception – Withdrawn 28 January 2013.

3.15 C13/0302/43/LL – Exchange four touring caravans on field 471 for two holiday cabins– Withdrawn 23 April 2013.

3.16 C13/0532/43/LL - Upgrade existing static caravans for holiday lodges and relocate tofield 471, move touring units from that field to static caravan field 472, together withthe demolition of pigsties and construct a new reception in its place with a counter tosell small goods.

3.17 C13/0533/43/CR - Demolish existing pigsties and erect a new building for use as areception – Approved 16 January 2014.

4. Consultations:

Community/Town Council: Not received.

Transportation Unit: No recommendation as it is assumed that the proposeddevelopment would not have a detrimental impact on anyroad or proposed road.

Caravans Officer: Need to ensure that the application is based on the 1989 ModelStandards requirements (licence conditions) and that it alsocomplies with the requirements of health and safety requirementswhen using the golf course.


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AONB Unit: Gwynys is a historical farm located in the countryside on the outskirtsof Pistyll. The house, the outbuildings and the surrounding land arewithin the Llŷn AONB, which is an area that was designated for national conservation. The AONB is protected by national and localpolicies. The site is also within an area that is included on theRegister of Landscapes of Outstanding Historic Importance in Wales.There have been several developments on the site over the years,including the golf course and sites for static and touring caravans.The most recent application approved was to exchange static units forcabins on field 471 in 2013. The intention with the current applicationis to exchange 10 static caravans for chalets measuring 12.2m by 6.1mand to locate them on field 470. Currently this field, which is of asubstantial size, is part of the golf course and is outside the boundaryof the existing caravan site. Field 470 is in quite a prominent positionin the rural landscape although as noted by the applicant, severalindigenous trees have been planted on the site recently. A publicbyway runs along its boundary and the chalets would be prominentfrom this road. The development would also be clearly visible fromthe road between Pistyll and Pentreuchaf and some other places. Noinformation has been included in the Design and Access Statementregarding the proposal in terms of field 472. Having considered thatrelevant matters, there is concern that extending the site by siting 10chalets of a substantial size on field 470 would have a detrimentalimpact on the rural landscape of the Area of Outstanding NaturalBeauty of this part of Llŷn.

Footpaths Unit: No observations on the application as it does not directlyaffect rights of way.

Welsh Water: Not received.

Public Consultation: A notice was placed on the site and in the press. The consultationperiod has ended and two letters were received supporting theproposal on the following grounds:

The business supports and employs local companies toundertake work on the caravan site.

5. Assessment of the material planning considerations:

The principle of the development

5.1 Policy D17 approves proposals to upgrade static holiday caravan sites and existingholiday chalets by:-

Small extensions to the area of land. Relocating static holiday caravan units or holiday chalet sites from prominent sites to

less prominent locations. A small increase in the number of units. Exchange touring pitches for static holiday caravan units.

5.2 The application proposes to upgrade the site by relocating the touring caravan site in itsentirety from part of field 472 to part of field 470 that currently has permission to be


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used as a golf course. The applicant has already received planning permissionC13/0532/43/LL for upgrading by means of:-

Relocating the static caravans to field 471.

Moving the touring units from field 471 to the field of the static caravans. Constructing a new reception with a counter for selling small goods.

The relocation elements that were the subject of that application were located withindefinite boundaries of the existing caravan site. In contrast to that application, theproposal now in question involves with exchanging 10 existing static holiday caravansfor 10 double static holiday caravans and relocate them on part of the land of theGwynus golf course which is above and beyond the boundaries of the existing caravanpark As a consequence of this development, the golf course would not be available tothe public but it is intended for it to be set-aside for the sue of users of the static holidaycaravans. The caravans would be distributed over a wider area than the size of theexisting static holiday caravan site on field 472 and it does not appear that there wouldbe definite boundaries to the site.

5.3 As can be seen, Policy D17 approves proposals to upgrade static holiday caravan sitesand existing holiday chalets. It can be seen that the policy supports relocating staticholiday caravan units or holiday chalets from prominent sites to less prominent sites.The advantage of this principle is to enable existing caravan sites located in prominentvisible sites, especially within the AONB, to be relocated to less prominent sites andthus reduce the visual impact on the landscape. In contrast to the previous application,the current application means relocating the existing static holiday caravans from a fairlyconcealed location within the boundary of the existing caravan park to a more visibleopen site outside the boundaries of the existing caravan site. It is considered that this iscontrary to the principle of Policy D17 in terms of relocating as it is not proposed torelocate the units from a prominent site to a less prominent location. Also, it is notproposed here to relocate a few static caravans but to relocate the whole static caravansite from its current location to a site that is located outside the current boundary of thecaravan park.

5.4 Policy D17 also supports the principle of small extensions to the areas of land ofexisting static holiday caravan sites. However, it is not considered that the existingplanning application is eligible to be considered as an ‘extension’. It is proposed torelocate all of the 10 existing caravans and, therefore, relocate the static holiday caravansite in its entirety to a new location. Also, there is no physical connection between thatelement of the existing holiday caravan park and the proposed location.

5.5 Policy D17 also seeks that the proposal is part of a development that proposessubstantial and permanent improvements to the design, setting and appearance of the siteand its setting in the surrounding landscape. The proposal would relocate the staticholiday caravans to a site that is more prominent in the landscape and that is outside theexisting boundaries of the caravan park. Therefore, it is not considered that the proposalwould comply with criterion 2 of Policy C17 as the proposal would highlight the site inthe landscape rather than making improvements to its appearance within the protectedlandscape.

5.6 Therefore, as a result of the above, it is not considered that the proposed proposalcomplies with the principle or the criteria of policy D17 of the GUDP. Indeed, it couldbe argued that the proposal in question is to create a new static caravan site and thatwould be completely contrary to the requirements of Policy D16 of the GUDP, that


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states that proposals to develop new sites for static holiday caravan units or holidaychalets will be refused.

Visual amenities5.7 Policy B8 of the GUDP assesses the impact of developments on the AONB. The

proposal would mean relocating the static caravan units to part of the existing golfcourse. Although a number of trees have been planted around the periphery of the golfcourse as well as in its centre, these have not matured and are not as thick as thelandscaping that has been undertaken around the existing caravan site. Therefore, it isconsidered that the site that is the subject of the application is more open than theexisting caravan site. The site of the golf course has also various landforms and slopeswithin it and this could be of assistance in terms of landscaping the proposeddevelopment.

5.8 The observations of the AONB unit were received on the application and they state thatthe site forms part of the golf course and it is outside the boundaries of the existingcaravan site and it is quite a prominent site in the rural landscape, although as noted bythe applicant, several indigenous trees have been planted on the site recently. A publicbyway runs along its boundary and the chalets would be prominent from this road. Thedevelopment would also be clearly visible from the road between Pistyll andPentreuchaf and some other places. Having considered the relevant issues, there isconcern that extending the site by locating 10 chalets of quite a substantial size on field470 would have a detrimental impact on a rural landscape in the Area of OutstandingNatural Beauty in this part of Llŷn.

5.9 As noted above, the landforms within the site along with the planted trees are ofassistance in terms of landscaping the site. The landscaping that has been undertakenaround part of the existing caravan site would also assist in landscaping the site.However, the site would be visible from the byway running along the boundary of thegolf course. Also, it is considered that the site would be visible from public footpathslocated on higher ground and further away from the site. It is noted that the AONBUnit have stated that the development would be clearly visible from the road betweenPistyll and Pentreuchaf. Although it is agreed that a glimpse of the site can be seen fromparts of this road it is not considered, as a result of the planting that has been undertakenover the years that the proposal can be seen clearly from the road between Pistyll andPentreuchaf or from other roads in the locality. However, it is considered that theproposed location is more visible in terms of location than the existing caravan sitebecause of the more open nature of the field. As a result, it is not considered that theproposal would ensure that the character of the AONB would be protected, maintainedor improved and. therefore, the proposal would significantly harm the rural landscape ofthe AONB contrary to the requirements of Policy B8 of the GUDP.

5.10 The site also lies within the Llŷn and Bardsey Island Landscape of Historic Interest. As stated above, there are concerns about the impact of the site on the visual amenities ofthe area and its impact on the landscape. However, it is not considered that the proposalwould be contrary to Policy B12 of the GUDP as it would not be a development on sucha large scale that it would not have more than a local impact on the historical landscape.

5.11 The proposed plan shows details of the existing woods and hedges. It is considered thatthe trees/hedgerows are suitable to the site and are in keeping with the current characterof the area, and therefore comply with policy B27 of the GUDP. It would also bepossible to impose a condition for more landscaping. Despite this, because of the natureand lay of the land, the landscaping measures are unlikely to conceal the developmentcompletely from distant views.


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Transport and access matters5.12 It is proposed that the existing entrance to the site be used to serve the site from the

county road. A new track will be constructed from the existing road that serves thecaravan site and the golf course to the point where it is proposed to locate the staticcaravans. The Transportation Unit submitted observations confirming that they had noobjection to the plans. In light of this, the proposal is considered acceptable in terms ofroad safety and policy CH33 of the GUDP. Sufficient informal parking spaces would beavailable near the units for the vehicles which complies with the requirements of policyCH36 of the GUDP.

6. Conclusions:

6.1 Permission has already been granted to upgrade and relocate the static holiday caravanswithin the boundaries of the existing caravan park along with extending the boundariesof the touring caravan park to part of field 4942. This application has been implementedsince caravans have been sited on part of field 4942. The current application is forrelocating the static caravan site in its entirety to the golf course that is situated outsidethe current boundary of the caravan park. Relocating the static holiday caravan site tothis location means siting the caravans in a more visible location than the existing siteand as a result, it does not comply with the requirements of policy D17 from theperspective of relocation. Also, because of the separate location of the application site,it is not considered that the proposal is appropriate to be considered as an extension tothe existing site and, therefore, this element of policy D17 is not relevant to the proposedproposal. It is also considered that the proposal would not offer substantial andpermanent improvements to the design, setting and appearance of the site and its settingin the landscape but rather it would make the site more prominent in the landscape and itwould be located beyond the existing boundaries of the caravan park. It is thereforeconsidered that the proposal is contrary to policy D17 of the GUDP.

6.2 It was considered that the proposed location was more visible in terms of its locationthan the existing caravan site. As a result, it is not considered that the proposal wouldensure that the character of the AONB would be protected, maintained or improved and.therefore; the proposal would significantly harm the rural landscape of the AONBcontrary to the requirements of Policy B8 of the GUDP.

7. Recommendation:

To refuse -

1. The proposal would mean relocating the static caravan site in its entirety to amore prominent and visible site in the landscape and it is not considered that thesite that is the subject of the application is an extension to the existing site and,therefore, it is considered that the proposal is contrary to the requirements ofPolicy D17 of the GUDP.

2. It is considered that the proposed location would be more visible in terms of itslocation than the existing caravan site and consequently, it is not considered thatthe proposal would ensure that the character of the AONB is protected,maintained or enhanced and therefore, the proposal would cause significantharm to the rural landscape of the AONB contrary to the requirements of PolicyB8 of the GUDP.

3 - gwynus caravan park and golf course, pistyll · 1/12/2015 · from part of field 472 to part...

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