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ST DAVID’S LEISURE LTD

PROPOSED USE OF TOURING CARAVAN SITE BY STATIC CARAVANS

ST DAVID’S HOLIDAY PARK, RED WHARF BAY, ISLE OF ANGLESEY

SUPPORTING PLANNING STATEMENT

Prepared by:

Caulmert Limited 8 St Georges Court Altrincham Business Park Dairyhouse Lane Altrincham Cheshire WA14 5UA Tel: 0161-928-6886 Email: [email protected] Web: www.caulmert.com

Doc ref: 3713-CAU-XX-XX-RP-T-9100.A0-C2

November 2018

Caulmert Ltd 3713-CAU-XX-XX-RP-T-9100.A0-C2

APPROVAL RECORD

Title: St David’s Holiday Park, Red Wharf Bay, Isle of Anglesey.

Client: St David’s Leisure Ltd

Project Title: Proposed Siting of Static Caravans.

Document Title: Supporting Planning Statement

Document Ref: 3713-CAU-XX-XX-RP-T-9100.A0-C2

Report Status: Final

Project Director: Howard Jones

Project Manager: Howard Jones

Caulmert Limited: 8 St Georges Court, Altrincham Business Park, Dairyhouse Lane, Altrincham, Cheshire. WA14 5UA

Telephone: 0161-928-6886

DISCLAIMER

This report has been prepared by Caulmert Limited with reasonable skill, care and diligence, in

accordance with the instruction of the above named client and within the terms and conditions of

the Contract with the Client.

The report is for the sole use of the above named Client and Caulmert Limited shall not be held

responsible for any use of the report or its content for any purpose other than that for which it was

prepared and provided to the Client.

Caulmert Limited accepts no responsibility of whatever nature to any third parties who may have

been made aware of or have acted in the knowledge of the report or its contents.

No part of this document may be copied or reproduced without the prior written approval of

Caulmert Limited.

Author Howard Jones Date 7th November 2018

Reviewer Clive Cunio Date 8th November 2018

Approved Clive Cunio Date 8th November 2018

St David’s Leisure Ltd Proposed Siting of Static Caravans November 2018 Supporting Planning Statement


TABLE OF CONTENTS

Page No

1 INTRODUCTION 1

2 DESCRIPTION OF THE APPLICATION SITE 2

3 RECENT PLANNING HISTORY OF THE SITE 4

4 THE PROPOSED DEVELOPMENT 6

5 THE DEVELOPMENT PLAN AND OTHER

MATERIAL CONSIDERATIONS 8

6 REVIEW OF THE PLANNING ISSUES 18

7 CONCLUSIONS 24

APPENDICES

A. Area of land to which the Certificate of Lawful Development relates.

B. Planning application ref 30C16Y decision notice.

C. Planning Officers report on application ref 30C16Y


Caulmert Ltd 3713-CAU-XX-XX-RP-T-9100.A0-C2 1

1 INTRODUCTION 1.1 Caulmert Ltd has been appointed by St David’s Leisure Ltd (“the applicant”), the site owner,

to prepare this Supporting Planning Statement.

1.2 The Statement relates to an application for full planning permission for the use of the

existing touring caravan and camping site area within St David’s Holiday Park for the siting of

35 static holiday caravans, the construction of caravan bases, parking spaces and internal

site access roads and associated landscaping and habitat creation works, following the

demolition of an existing shower block building at St David’s Holiday Park, Red Wharf Bay,

Isle of Anglesey.

1.3 St Davids Leisure Ltd also intends to undertake additional improvement works elsewhere on

the Holiday Park site, but outside of the current planning application site boundary, in

association with the proposed development. These additional improvement works do not

require planning permission.

1.4 The Statement should be considered alongside the submitted Landscape and Visual Impact

Assessment, Ecology Report, Flood Risk Assessment and Transport Statement.

1.5 The application site falls within the administrative are of the Isle of Anglesey County Council.



2 DESCRIPTION OF THE APPLICATION SITE

2.1 St David’s Holiday Park is an established, high quality holiday park, set within well-

maintained grounds and situated on the east coast of Anglesey.

2.2 The coastal hamlet of Red Wharf Bay is located approximately 0.3km to the south of the

Holiday Park and the town of Benllech is situated approximately 1.0km to the north west.

2.3 Vehicular access to the Holiday Park is gained via a short section of minor roads which run in

an easterly direction from the A5025.

2.4 In recent years, St David’s Leisure Ltd has committed substantial investment to the

improvement of the Holiday Park, in response to the rising expectations of its existing and

potential visitors.

2.5 This investment has included improvements to the reception facilities, the development of a

luxury spa and indoor swimming pool complex, extensions to the bar and restaurant and

improvements to the car parking and boat storage areas.

2.6 As a result of its attractive location and the substantial levels of investment that have taken

place, St David’s Holiday Park is now one of the premier static holiday caravan parks on

Anglesey and beyond, attracting significant tourism business to the area.

2.7 Excluding the area which is the subject of the current planning application, St David’s Holiday

Park accommodates up to 200 static holiday caravans and operates between 1st March and

the following 4th January.

2.8 The area to which the current planning application relates is presently used, from 14th March

to 30th September each year, for the siting of up to 45 touring caravan and for an unlimited

number of camping pitches.

2.9 Vehicular access to the application site is gained via the existing road network that runs through the Holiday Park from the public highway

2.10 The application site occupies a coastal location, slightly elevated above the beach and separated by low coastal cliffs.

2.11 The application site rises generally from the south to north before reaching a headland. To

the north west of the headland, the application site falls sharply towards the existing boat

storage area.

2.12 The application site consists predominantly of short mown grassland, with vegetated bunds

which are located alongside sections of the coastal cliffs and cross the headland on a south

west – north east alignment.


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2.13 A series of gravel tracks cross the short mown grassland and a tarmac roadway provides

vehicular and pedestrian access to an existing shower block building and hardstanding,

situated in the western part of the application site.

2.14 The shower block building has a pitched roof and is painted white, whilst the hardstanding

area measures approximately 55m(l) x 16m(w).

2.15 The touring caravans, which are typically white in colour, tend to park on the eastern and

north eastern parts of the application site and on the headland, in particular, where they can

take advantage of the available views along the coast and out to sea.

2.16 The land to the south of the application site is well wooded, with Castell Mawr beyond.

Castell Mawr is a large limestone rock which is included within the designated Trwyn Dwlban

geological Site of Special Scientific Interest (SSSI).



3 RECENT PLANNING HISTORY OF THE APPLICATION SITE

Certificate of Lawful Development 3.1 The application site benefits from a Certificate of Lawful Development which was issued, on

appeal, on 4th May 2012 (Appeal Ref: APP/L6805/X/11/2157618).

3.2 The Lawful Development Certificate applies to the area of land shown edged in red on the plan included at Appendix A.

3.3 The Lawful Development Certificate confirms that, on 22nd June 2010, the lawful use of the

area of land shown edged in red on the plan included at Appendix A was for the: “mixed use of tents and the stationing of touring units defined as dormobiles, caravanettes, camper vans, touring vans, touring caravans and any motor vehicle so designed or adapted for human habitation (excluding static and chalet caravans) at a level that does not result in a material change of use of the land from its use as existing on 22nd June 2010, namely for the stationing of 45 touring units restricted from 14th March to 30th September each year.”

3.4 The Certificate confirms that the use had accrued lawfulness by 27th July 1992 and had

continued since that date.

3.5 The use of the application site has continued without interruption since 22nd June 2010, in accordance with the Lawful Development Certificate.

Application Ref: 30C16Y 3.6 An application for full planning permission for the change of use of the current application

site from touring caravans and camping area to site 31 single unit static caravans and 4 twin-unit static caravans, together with associated works, at St Davids Holiday Park, Red Wharf Bay, was refused by Isle of Anglesey Council on 10th January 2018 (Application Ref 30C16Y).

3.7 The application was refused for the following three reasons: 1. The proposal fails to comply with the provisions of policies TWR1, TWR2, TWR3,

AMG1, AMG2, AMG3 and AMG4 of the adopted Joint Local Development Plan

(Anglesey and Gwynedd), 2017 as it would result in a detrimental permanent

visual impact on the landscape character of the locale, including the coastline

appearance, the special character and appearance of the Area of Outstanding

Natural Beauty and the Special Landscape Area.

2. By virtue of the location of the 4 No twin unit static caravans within a visually

prominent area of headland within the coastline, the proposed development

would result in a significantly detrimental impact on visual amenity and

landscape character which would fail to comply with the provisions of the JLDP

and no justification has been made which would support an exception to the

requirements of the JLDP.

3. The proposal conflicts with the surrounding landscape character and would

result in further incremental erosion of the coastline character as outlined within

the local Landscape Character Appraisal.


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3.8 A copy of the above mentioned decision notice is included at Appendix B.

3.9 Planning application ref 30C16Y was determined by the Council’s Planning Officer, under delegated authority, and a copy of the Officer’s report on the application is included at Appendix C.



4 THE PROPOSED DEVELOPMENT 4.1 The current application seeks full planning permission for the use of the existing touring

caravan and camping site area within St David’s Holiday Park for the siting of 35 static holiday caravans, the construction of caravan bases, parking spaces and internal site access roads and associated landscaping and habitat creation works, following the demolition of an existing shower block building at St David’s Holiday Park, Red Wharf Bay, Isle of Anglesey.

4.2 The proposed use would, upon implementation, replace the lawful use of the application site for the stationing of 45 touring units and an unlimited number of tents during the period from 14th March to 30th September each year.

4.3 The proposed static holiday caravans would comprise 31 single unit caravans and 4 twin unit

caravans and would operate between 1st March and the following 4th January. 4.4 The proposed single unit caravans would be located on the lower, southern part of the

application site, whilst the proposed twin unit caravans would be located on the area of lower ground contained between the headland and the boat storage area.

4.5 No caravans would be sited upon the headland and this area would be established and

managed as an area of calcareous grassland, in accordance with the submitted “Calcareous Grassland - Method Statement for Creation and Long Term Management Plan”.

4.6 Localised land lowering (to 6.7m AOD) is proposed in the area occupied by single unit

caravans Nos 21 – 25, in order to further reduce their potential landscape and visual impact. 4.7 In addition, localised land raising (to 6.3m AOD) is proposed in the area occupied by single

unit caravans Nos 16 – 20, in order to reduce the risk of flooding (NB The slab level of these caravans will be set at 6.7m AOD).

4.8 Native screen planting is proposed along parts of the eastern and western boundaries of the

application site and between the single unit caravans and the proposed area of calcareous grassland.

4.9 Existing vegetation along the eastern boundary of the application site and between the

proposed twin unit caravans and the area of calcareous grassland, would be supplemented, as appropriate, and allowed to reach its full height.

4.10 Amenity soft landscaping will be undertaken within the area of proposed single unit

caravans. 4.11 The proposed static caravans would be served by a tarmac access road, which would tie into

the existing internal site access network within the Holiday Park. 4.12 Each of the proposed single unit caravans would have an adjacent single car parking space,

whilst the proposed twin unit caravans would each have two car parking spaces.


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4.13 Surface water run-off from the proposed development would soakaway, whilst foul flows

would be transferred, by below ground pipework, for treatment at the existing on-site private wastewater treatment works, prior to discharge in accordance with the existing discharge consent.

4.14 In order to facilitate the proposed development, both the existing shower block building and

the existing hard surfaced car park in the western part of the application site would be removed.

4.15 St Davids Leisure Ltd also intends undertake additional improvement works elsewhere on

the Holiday Park site, but outside of the current planning application site boundary, in association with the proposed development. The proposed improvements both within and outside the planning application site boundary are shown on the submitted Proposed Site Landscape Improvements drawing (Ref: 22/18/LMP/01A) and individual Project Sheets.

4.16 Outside of the planning application site boundary the proposed improvements, in summary,

comprise:

• Native scrub vegetation planting adjacent to the existing boat park, car park and section of existing access road (Project 2):

• Native hedge planting alongside the coastal footpath to provide enhanced screening of the Holiday Park (Project 3);

• Management of existing woodland areas A and B (Project 4), in accordance with the submitted Woodland Management Plan;

• Native tree screening alongside the coastal footpath that runs through the site (Project 5);

• Native hedge screening alongside the coastal footpath (Project 6); and

• The provision of a signed permissive footpath from the coastal footpath to a geo-tourism interpretation facility adjacent to Castell Mawr (Project 7).

4.17 The above-mentioned works, outside of the planning application site boundary, do not

require planning permission, but could be secured by a Grampian condition or legal agreement, if required.



5 THE DEVELOPMENT PLAN AND OTHER MATERIAL CONSIDERATIONS Joint Local Development Plan (Anglesey and Gwynedd) 5.1 The statutory Development Plan for the area within which the application site is located is

The Anglesey and Gwynedd Joint Local Development Plan (JLDP), which was adopted on 31

July 2017, with a plan period of 15 years (2011 – 2026).

5.2 A number of key issues to be tackled by the JLDP have been identified and include:

• The need to improve and manage the ‘all year’ tourist provision in the area in a sustainable way whilst at the same time promoting the heritage, the Welsh language and Welsh culture of the area; and,

• The need to protect and whenever possible, improve the natural environment, habitats and species of the area.

5.3 The above-mentioned key issues are reflected in the Strategic Objective of the JLDP which

seek to:

• Manage the area as an alternative and sustainable destination for tourists by providing facilities of a high standard that meet modern day needs and offer benefits throughout the year (SO14); and

• Protect, enhance and manage the natural and heritage assets of the Plan area, including its natural resources, wildlife habitats, and its landscape character and historic environment (SO17).

5.4 The JLDP confirms that Strategic Objective SO14 is reflected, inter alia, in Policies PS 14,

TWR1, TWR 2 and TWR 3 and that Strategic Objective SO17 is reflected, inter alia, in Policies

PS 19, AMG 1, AMG 2, AMG 3, AMG 4 and AMG 5.

5.5 Strategic Policy PS14 addresses The Visitor Economy and states that:

“Whilst ensuring compatibility with the local economy and communities and ensuring

the protection of the natural, built and historic environment the Councils will support

the development of a year-round local tourism industry by:

1. Focusing larger scale, active and sustainable tourism, cultural, the arts and leisure

development in the sub-regional centre, urban service centres, and, where

appropriate, local service centres;

2. Protecting and enhancing existing serviced accommodation and supporting the

provision of new high quality serviced accommodation in the sub-regional, urban and

local service centres and villages;

3. Managing and enhancing the provision of high quality un-serviced tourism

accommodation in the form of self-catering cottages and apartments, camping,

alternative luxury camping, static or touring caravan or chalet parks;

4. Supporting appropriately scaled new tourist provision and initiatives in sustainable

locations in the countryside through the reuse of existing buildings, where

appropriate, or as part of farm diversification, particularly where these would also


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benefit local communities and support the local economy and where they are in

accordance with sustainable development objectives;

5. Preventing development that would have an unacceptable adverse impact on

tourist facilities, including accommodation and areas of visitor interest or their

setting, and maximise opportunities to restore previous landscape damage.”

5.6 Policy TWR1 deals with Visitor Attractions and Facilities and states that: “Proposals to develop new visitor attractions and facilities or to improve and extend

the standard of existing facilities will be encouraged to locate to sites within the

development boundary. Where there are no suitable opportunities within the

development boundary, only proposals that involve the following will be granted:

1. The re-use of an existing building(s) or a suitable previously used site; or

2. The re-use of an existing building(s) or a site closely related to other existing

buildings that forms part of an existing tourist facility; or

3. An activity restricted to a specific location due to its appropriate use of a historical

or natural resource or its proximity to the attraction which it relates.

All proposals will be required to comply with all the following criteria:

i. The scale, type and character of the proposed development is appropriate for its urban/rural setting;

ii. The proposed development is of high quality in terms of design, layout and appearance;

iii. The proposed development will support and extend the range of facilities within the Plan area;

iv. The proposal is supported by evidence to demonstrate that there would be local employment opportunities.

Where appropriate, the development can be accessed by various modes of transport, especially sustainable modes of transport, such as walking, cycling and public transport.”

5.7 The Explanation to Policy TWR1 advises that “this policy aims to encourage the development

of high quality sustainable tourism attractions and facilities in the right place” and that “the

policy also recognises that in exceptional circumstances some attractions and facilities

require an open countryside, non-urban location which could be acceptable where they result

in an all year round tourism facility and rural employment gain. This type of development

would be, for example, those connected with features of the natural or historic environment

or outdoor activity such as, visitor or interpretation centres or development associated with

outdoor activities” .

5.8 Policy TWR2 relates to Holiday Accommodation and states that: “Proposals for:

1. The development of new permanent serviced or self-serviced holiday accommodation, or


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2. The conversion of existing buildings into such accommodation, or

3. Extending existing holiday accommodation establishments, will be permitted,

provided they are of a high quality in terms of design, layout and appearance and

that all the following criteria can be met:

i. In the case of new build accommodation, that the development is located within a development boundary, or makes use of a suitable previously developed site;

ii. That the proposed development is appropriate in scale considering the site, location and/or settlement in question;

iii. That the proposal will not result in a loss of permanent housing stock; iv. That the development is not sited within a primarily residential area or does not

significantly harm the residential character of an area; v. That the development does not lead to an over-concentration of such

accommodation within the area.” 5.9 The Explanation to Policy TWR2 advises that “this policy is not relevant to proposals to

establish new static holiday and touring caravans, holiday chalets or alternative luxury

camping sites. Such proposals will be considered under policies TWR 3 and TWR 5 of this

Plan.”

5.10 Policy TWR3 addresses static caravan and chalet sites and states (inter alia) that: 1. Proposals for the development of new static caravan, holiday chalet sites or

permanent alternative camping accommodation will be refused within the Anglesey Coast AONB, Llyn AONB and the Special Landscape Areas. In other locations proposals for new static caravan or holiday chalet sites and permanent alternative camping accommodation will only be granted where: i. It can be demonstrated that it doesn’t lead to a significant intensification in

the provision of static caravan or chalet or permanent alternative camping sites in the locality; and

ii. That the proposed development is of a high quality in terms of design, layout and appearance, and is sited in an unobtrusive location which is well screened by existing landscape features and/or where the units can be readily assimilated into the landscape in a way which does not significantly harm the visual quality of the landscape; and,

iii. That the site is close to the main highway network and that adequate access can be provided without significantly harming landscape characteristics and features

2. In exceptional circumstances, proposals involving the relocation of an existing static or chalet site already located in the Anglesey Coast AONB, Llyn AONB and the Special Landscape Areas that forms part of the Coastal Change Management Area shown on the constraints map to another site will only be permitted providing that criteria 1 i – iii are met and the new site is located outside the Coastal Change Management Area.

3. Within the Anglesey Coast AONB, Llyn AONB and the Special Landscape Areas proposals to improve existing static and chalet sites by:

i. Minor extensions to the site area and/or, ii. The relocation of units from prominent settings to less prominent

locations,


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will be permitted providing all of the following criteria can be met:

iii. The improvements does not increase the number of static caravan or chalet units on the site, unless, in exceptional circumstances, proposals involve the relocation of existing static and chalet parks that fall within the Coastal Change Management Area;

iv. That the proposed development is part of a scheme to improve the range and quality of tourist accommodation and facilities on the site;

v. In the case of a site located within the Coastal Change Management Area, that the proposed development is also part of a scheme to improve the safety of occupiers of caravans or chalets;

vi. That the proposed development offers significant and permanent improvements to the design, layout and appearance of the site and its setting in the surrounding landscape;

vii. It is appropriate when considered against other policies in the Plan.” 5.11 The Explanation to Policy TWR3 state that “within the Areas of Outstanding Natural Beauty

and Special Landscape Areas an extension of a site, but without an increase in caravan or

chalet numbers, may be permitted if it can be demonstrated that there would be clear

benefits in reducing the impact on the surrounding landscape.” In addition, the Explanation

also confirms that “many existing sites are located in visually sensitive areas, particularly

along the coastline. The aim of this policy is to promote improvements and upgrade the

standard of visitor accommodation on existing sites, and to reduce the impact of these sites

on the landscape”.

5.12 Policy PS19 relates to the conservation and, where appropriate, enhancement of the natural

environment and confirms that:

“The Councils will manage development so as to conserve and where appropriate

enhance the Plan area’s distinctive natural environment, countryside and coastline,

and proposals that have a significant adverse effect on them will be refused unless

the need for and benefits of the development in that location clearly outweighs the

value of the site or area and national policy protection for that site and area in

question. When determining a planning application, consideration will need to be

given to the following:-

1. Safeguard the Plan area’s habitats and species, geology, history, the

coastline and landscapes;

2. Protect or where appropriate enhance sites of international, national,

regional and local importance and, where appropriate, their settings in line

with National Policy;

3. Have appropriate regard to the relative significance of international,

national or local designations in considering the weight to be attached to

acknowledged interests, ensuring that any international or national

responsibilities and obligations are fully met in accordance with National

Policy;


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4. Protect or enhance biodiversity within the Plan area and enhance and/or

restore networks of natural habitats in accordance with the Local

Biodiversity Action Plans and Policy AMG 5;

5. Protect or enhance biodiversity through networks of green/ blue

infrastructure;

6. Safeguard internationally, nationally and locally protected species;

7. Protect, retain or enhance the local character and distinctiveness of the

individual Landscape Character Areas (in line with Policy AMG 2) and

Seascape Character Areas (in line with Policy AMG 4);

8. Protect, retain or enhance trees, hedgerows or woodland of visual,

ecological, historic cultural or amenity value”.

5.14 The application site is situated within a designated Area of Outstanding Natural Beauty

(AONB) and Policy AMG1 confirms that:

“Proposals within or affecting the setting and/ or significant views into and out of the

Areas of Outstanding Natural Beauty must, where appropriate, have regard to the

relevant Area of Outstanding Natural Beauty Management Plan”.

5.15 Policy AMG2 refers to Special Landscape Areas (SPA). The application site is not located within an SPA and the provisions of Policy AMG2 do not apply, therefore, to the proposed development.

5.16 Policy AMG3 relates to the protection and enhancement of features and qualities that are

distinctive to the local landscape character and states that:

“Proposals that would have significant adverse impact upon landscape character as

defined by the Landscape Character Areas included within the current Landscape

Strategy for the relevant authority, must demonstrate through a landscape

assessment how landscape character has influenced the design, scale, nature and

site selection of the development.

A proposal will be granted provided it doesn’t have significant adverse impact upon

features and qualities which are unique to the local landscape in terms of visual,

historic, geological, ecological or cultural aspects. Measures should be taken to

ensure that the development does not:

1. Cause significant adverse impact to the character of the built or natural landscape;

2. Fail to harmonise with, or enhance the landform and landscape;

3. Lose or fails to incorporate traditional features, patterns, structures and layout of

settlements and landscape of both the built and natural environment.

Particular emphasis will be given to the landscapes identified by the Landscape

Character Areas as being of high and outstanding quality because of a certain


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landscape quality or a combination of qualities. Additional consideration will also be

given to development that directly affect the landscape character and setting of the

AONBs or the National Park.”

5.17 Policy AMG4 addresses coastal protection and states:

“In considering a proposal on the coast, including the Heritage Coast, there will be a

need to ensure that the proposal conforms to the following criteria:-

1. The development due to its nature must be located on the coast, or in open

estuaries, or nearby, and that there is an overriding economic and social benefit from

the development

2. It does not cause unacceptable harm to: i. water quality ii. public access considerations iii. the built environment, or the landscape, or seascape character

iv. the area’s biodiversity interests (including European Protected Areas such as marine Special Areas of Conservation and Special Protected Areas) due to their location, scale, form, appearance, materials, noise, or emissions or due to an unacceptable increase in traffic.

3. Priority is given to locations with a close visual connection to current buildings or

existing structures.

4. There are no suitable alternative locations on the coast that have been developed.

5. That the development is consistent with other policies within the Plan including

Policy ARNA1.”

5.18 Policy AMG5 deals with local biodiversity conservation and advises that: “Proposals must protect and, where appropriate, enhance biodiversity that has been

identified as being important to the local area by:

a. Avoiding significant harmful impacts through the sensitive location of

development.

b. Considering opportunities to create, improve and manage wildlife habitats and natural landscape including wildlife corridors, stepping stones, trees, hedges, woodlands and watercourses. A proposal affecting sites of local biodiversity importance will be refused unless they can conform with all of the following criteria:- 1. That there are no other satisfactory alternative sites available for the development. 2. The need for the development outweighs the importance of the site for local nature conservation; 3. That appropriate mitigation or compensation measures are included as part of the proposal. Where necessary, an Ecological Assessment which highlights the relevant local biodiversity issues should be included with the planning application.”


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5.19 The application site is located in a defined Coastal Change Management Area (CChMA) as

identified by the West of Wales Shoreline Management Plan. JLDP Policy ARNA1 addresses development within Coastal Change Management Areas and states, inter alia, that:

“Redevelopment of, or extensions to, existing non-residential property or intensification of existing non-residential land uses on sites within the CChMA, will be permitted where it can be demonstrated by a TAN 15 compliant Flood Consequences Assessment or a Stability Assessment that there will be no increased risk to life, nor any significant risk to property and subject to a time-limited planning permission (where appropriate) and that the development complies with TAN 15 over the period of its permission.”

5.22 Strategic Policy PS5 addresses Sustainable Development and confirms that “Development

will be supported where it is demonstrated that they are consistent with the principles of

sustainable development”. All proposals are required, inter alia, to:

“1. Alleviate the causes of climate change and adapting to those impacts that are unavoidable in accordance with Strategic Policy PS 6;

2. Give priority to effective use of land and infrastructure, prioritizing wherever possible the reuse of previously developed land and buildings within the development boundaries of Sub Regional Centre, Urban and Local Service Centres, Villages or in the most appropriate places outside them in accordance with Strategic Policy PS 17, PS 13 and PS 14;

6. Protect and improve the quality of the natural environment, its landscapes and biodiversity assets, including understanding and appreciating them for the social and economic contribution they make in accordance with Strategic Policy PS 19;

8. ………..managing flood risk and maximizing use of sustainable drainage schemes………;

10. Promote a varied and responsive local economy that encourages investment and that will support Centres, Villages and rural areas in accordance with Strategic Policy PS 13.”

Other Material Considerations

a) Planning Policy Wales 5.23 Planning Policy Wales (Edition 9) (“PPW”) was updated most recently in November 2016 and

sets out the land use planning policies of the Wales Government.

5.24 PPW confirms that there should be a presumption in favour of sustainable development promoting sustainable development, in taking decisions on individual planning applications,

in order to ensure that social, economic and environmental issues are balanced and integrated.

5.25 PPW confirms that the Welsh Government’s objectives for the conservation and

improvement of the natural heritage include that of promoting and conserving landscape and biodiversity, in particular the conservation of native wildlife and habitats. Local planning authorities are required to address biodiversity issues, insofar as they relate to land use planning, in their development management decisions.


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5.26 PPW advises that the primary objective for designating AONBs is the conservation and

enhancement of their natural beauty. In development management decisions affecting AONBs, Local Planning Authorities are required to favour conservation of natural beauty, whilst accepting that it will also be appropriate to have regard to the economic and social well-being of the areas.

5.27 With regard to SSSIs, PPW emphasises the duty placed on local planning authorities to take

reasonable steps, consistent with the proper exercise of their functions, to further the conservation and enhancement of the features by reason of which a SSSI is of special interest.

5.28 PPW acknowledges that Tourism is vital to economic prosperity and job creation in many

parts of Wales. It is a significant and growing source of employment and investment, based on the country’s cultural and environmental diversity and can be a catalyst for environmental protection, regeneration and improvement in both rural and urban areas.

5.29 PPW advises that in determining planning applications for tourism developments, local

planning authorities need to consider the impact of proposals on the environment and local community and that they may seek to reduce the impact of development using arrangements for traffic and visitor management.

b) Technical Advice Note 5 on Nature Conservation and Planning (TAN5) 5.30 TAN5 was published in 2009 and confirms that biodiversity conservation and enhancement

is an integral part of planning for sustainable development.

5.31 It is acknowledged that the use and development of land can pose threats to the conservation of natural features and wildlife but, equally can also present significant opportunities to enhance wildlife habitats and the enjoyment and understanding of the natural heritage.

5.32 TAN5 confirms that the key principles of the planning system in Wales include the

requirements to:

• look for development to provide a net benefit for biodiversity conservation with no significant loss of habitats or populations of species, locally or nationally; and

• help to ensure that development does not damage, or restrict access to, or the study of, geological sites.

c) Technical Advice Note 13 on Tourism (TAN13) 5.33 TAN13 confirms that holiday and touring caravan parks are an important part of the self-

catering holiday sector and can contribute much to the local economy

5.34 However, it is acknowledged that holiday caravan sites can be intrusive in the landscape, particularly on the coast, and that special consideration needs to be given to proposals for new sites especially in Areas of Outstanding Natural Beauty and sites of national and international importance designated for their natural features.


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d) Isle of Anglesey AONB Management Plan Review 2015 - 2020 5.35 The Isle of Anglesey Area of Outstanding Natural Beauty (AONB) Management Plan Review

2015 – 2020 evaluates and determines what the special qualities of the AONB are, then determines what actions are required to ensure that these qualities are conserved and enhanced for future generations.

5.36 The Review notes that employment within the AONB is mainly based upon tourism and agriculture and that Anglesey is a popular area for recreation, with the majority of visitors attracted to the Island by the quality and number of sandy beaches and the beauty of the coastal landscape. As a consequence the presence of caravan and camping sites can place pressures on the AONB.

5.37 The Review also identifies the features and special qualities of the AONB which include:

• The coastal landscape;

• Geological and geomorphological features;

• Broadleaved woodlands; and,

• Lowland coastal heath

5.38 The Review sets out a Vision and Strategy for the AONB and a number of the Objectives and Policies are of particular relevance to the proposed development.

5.39 Policy CCC 1.3 confirms that “there is a need to maintain the accessibility and conservation interest of sites of geological and geomorphological significance”.

5.40 Policy CCC 3.2 requires that “all new developments and re-developments within and up to

2km adjacent to the AONB will be expected to adopt the highest standards of design, materials and landscaping in order to enhance the special qualities and features of the AONB. Proposals of an appropriate scale and nature, embodying the principles of sustainable development, will be supported”.

5.41 Policy CCC 3.3 seeks to “ensure that planning policies reflect the statutory duty of the Council

to conserve and enhance the special qualities and features of the AONB”. 5.42 Policy NE 1.2 aims to “maintain, restore and enhance priority habitats and biodiversity in the

AONB”. 5.43 Policy NE 3.1 looks to “work with site managers to maintain, restore, expand and sometimes

create wildlife habitats”. 5.44 Policy VE 2.1 seeks to “ensure that the tourism industry makes a vital and sustainable

contribution to the Anglesey AONB economy“. 5.45 Policy VE 4.2 aims to “ensure that the Public Right of Way (PROW) network is maintained at

a high standard and that appropriate information and clear signage conserves and enhances the special qualities and features of the AONB and the integrity of European sites”.

5.46 Policy LWL 1.5 confirms its support for “the sound management and appropriate expansion

of woodlands within the AONB for both their commercial and social value”.


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5.47 Management Objective 2 relates to Interpretation and Information and aims to “reveal the meanings and relationships of the areas cultural and natural heritage to promote understanding and appreciation of the AONB through effective interpretation that enhances the special qualities and features of the AONB by involvement with landscapes and sites”.



6 REVIEW OF THE PLANNING ISSUES 6.1 The application site is located within, and forms a seamless and integral part, of the St

Davids Holiday Park.

6.2 Both the application site and the wider Holiday Park:

• Are in the same ownership

• Are administered and operated together, as a single business enterprise

• Share the same vehicular and pedestrian accesses

• Share the same reception facilities, spa, indoor swimming pool, bar, restaurant, car

parking, boat storage, children’s play area and beach access.

For these reasons, the application site is considered to comprise part of the larger St Davids

Holiday Park single planning unit which is used as a holiday caravan and camping site, with

ancillary facilities and uses.

6.3 The lawful use of the application site is for the “mixed use of tents and the stationing of touring units defined as dormobiles, caravanettes, camper vans, touring vans, touring caravans and any motor vehicle so designed or adapted for human habitation (excluding static and chalet caravans) at a level that does not result in a material change of use of the land from its use as existing on 22nd June 2010, namely for the stationing of 45 touring units restricted from 14th March to 30th September each year.”

6.4 The lawful use of the application site and its inclusion within the larger St Davids Holiday Park single planning unit is the baseline against which the proposed development should be considered.

6.5 Strategic Policy PS14 relates to the visitor economy and confirms that the Local Planning

Authority will support the development of a year round local tourism. 6.6 The proposed development and associated works is supportive of Policy PS14, since it will

enhance the provision of high quality un-serviced tourism accommodation, will support existing tourist facilities on site and in the surrounding area, will increase the enjoyment and visitor interest of the coastal path and will serve to reduce significantly the potential adverse landscape impacts arising from the lawful touring caravan and camping use, which will cease.

6.7 There are no policies in the adopted JLDP which relate specifically to the replacement of

existing touring caravans by static caravans. 6.8 Policy TWR1, although cited in the reasons for refusal of planning application ref 30C16Y, is

not applicable to the proposed development. This Policy relates to visitor attractions and facilities and not to visitor accommodation.

6.9 The explanation to Policy TWR1 provides examples of visitor attractions and facilities, in

open countryside/non-urban locations, which include visitor or interpretation centres or development associated with outdoor activities. There is no reference, in either the Policy itself or the explanation to the Policy, to visitor accommodation which is addressed,


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specifically, by the subsequent Policy TWR2. For these reasons, Policy TWR1 is not considered to be relevant to the determination of the current application.

6.10 Policy TWR2, although cited in the reasons for refusal of planning application ref 30C16Y, is

not applicable to the proposed development, since it relates to Holiday Accommodation. The Explanation to the Policy confirms, explicitly, that “this policy is not relevant to proposals to establish new static holiday and touring caravans, holiday chalets or alternative luxury camping sites”. For these reasons, Policy TWR2 is not considered to be relevant to the determination of the current application.

6.11 Policy TWR3 relates to static caravan and chalet sites; however, application of this Policy to the proposed development must take account of the fact that the application site is not, in itself, a single planning unit but is an integral part of the larger St Davids Holiday Park planning unit.

6.12 Part 1 of Policy TWR3 does not apply to the proposed development, as the current

application does not involve the development of a new static caravan site outside of the existing planning unit.

6.13 Nevertheless, if Part 1 of Policy TWR3 was to be applied to the proposed development, then

considerations i – iii of Part 1 would be satisfied:

• The proposed development would replace 45 touring caravans and an unlimited number of tents on the site with 35 static caravans and would reduce, rather than intensify, the level of provision (consideration i).

• The proposed development and associated works is of a high quality of design, layout and appearance and is situated in the visually contained parts of the site which are screened by topography and by existing and proposed landscaping. The proposed static caravans would be assimilated into the surrounding landscape with significantly less visual impact than the current lawful use. The submitted LVIA demonstrates that the proposed development and associated works will have a beneficial landscape and visual impact when compared with the current baseline (consideration ii).

• The Transport Assessment that forms part of the planning application demonstrates that the proposed development benefits from convenient access to the primary highway network. The proposed access roads that will serve the proposed development within the application site will be contained by the topography and will not harm the visual quality of the landscape (consideration iii).

6.14 Part 2 of Policy TWR3 does not apply to the proposed development, as the current application does not involve the relocation of an existing static caravan site.

6.15 With regard to Part 3 of Policy TWR3, the proposed development would improve the existing St David’s Holiday Park as it would not involve any extension to the site area and would relocate units from prominent settings to less prominent locations (considerations i and ii). Considerations iii –vii of Part 3 are not directly relevant to the proposed development as they do not address the proposed replacement of existing touring caravans and tents with static caravans. Nevertheless, the implications of considerations iii –vii for the proposed development are summarised below:

• The proposed development would result in a reduction in the number of caravans on the application site but would give rise to an increase in the total number of


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static caravans on the St David’s Holiday Park site. Overall, the gross number of touring/static caravans on the Holiday Park site would be reduced (consideration iii);

• The proposed development would improve the quality of tourist accommodation on the site and would help to support the considerable investment in facilities that has taken place recently at the Holiday Park (consideration iv);

• The application site is located within a Coastal Change Management Area and would improve the safety of the occupiers by removing all of the lawful 45 touring caravans and the unrestricted number of tents, which tend to locate close to the coast. The 45 touring caravans and the unrestricted number of tents would be replaced by 35 static caravans (tethered as appropriate) all of which would be above predicted flood levels and would benefit from a safe/dry means of escape (consideration v);

• The submitted LVIA and Ecology Report demonstrate that the proposed development and associated works will have a beneficial landscape and visual impact and will deliver significant ecological benefits to the local area, which will offer significant and permanent improvements to the design, layout and appearance of the site and its setting in the surrounding landscape. This will be achieved by restoring previous landscape damage by the removal of touring units from the prominent headland in the northern part of the site, the demolition of the existing shower block building and car park hardstanding, the sensitive siting of a reduced number of static caravans (31 static caravans v 45 touring caravans), appropriate landscaping, the establishment and management of an area of calcareous grassland and other significant off-site improvements to the landscape quality, ecology and enjoyment of the AONB (consideration vi);

• The proposed development and associated works accords with other policies in the

LDP and, in particular, Strategic Policies PS14 and PS19 (consideration vii). 6.16 In addition, it should be noted that the Explanation to Policy TWR3 confirms that “the aim of

this policy is to promote improvements and upgrade the standard of visitor accommodation on existing sites, and to reduce the impact of these sites on the landscape”. Whilst, as indicated above, Policy TWR3 does not apply to the proposed development, it is clear that the proposed development would, nevertheless, be consistent with, and supportive of, the aim of this Policy.

6.17 Strategic Policy PS19 confirms that the Councils will manage development so as to conserve and where appropriate enhance the Plan area’s distinctive natural environment, countryside and coastline. In determining planning applications, the Policy identifies a series of considerations that are to be taken into account.

6.18 The submitted Ecology Report demonstrates that the proposed development and associated

works will not only safeguard, but will enhance the areas habitats and species. The submitted LVIA demonstrates that the proposed development and associated works will have a beneficial landscape impact. In addition, the proposed development will safeguard the adjacent Geological SSSI and will facilitate better interpretation of Castell Mawr, in particular (Consideration 1).


works will protect and enhance sites of international, national, regional and local importance (Consideration 2).


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6.20 Both the submitted LVIA and Ecology Report demonstrate that the proposed development and associated works will conserve and enhance the designated AONB (Consideration 3).


works will protect and enhance biodiversity and will enhance and restore networks of natural habitats (Consideration 4)

6.22 Woodland management measures will be undertaken in association with the proposed

development and will enhance biodiversity through its support for network of woodland infrastructure in the locality and the creation of new corridors for reptiles and red squirrels in particular (Consideration 5).


works will result in notable enhancements to habitats used by bats, reptiles and red squirrels (Consideration 6).

6.24 The submitted LVIA demonstrates that the proposed development and associated works will

have beneficial landscape impacts. (Consideration 7). 6.25 The proposed development and associated works will protect, retain and enhance trees,

hedgerows and woodland of visual, ecological and amenity value (Consideration 8). 6.26 Thus, the proposed development and associated works responds positively to the above-

mentioned development considerations and, therefore, accords full y with the provisions of Policy PS19.

6.27 The proposed development pays due regard to the setting and/ or significant views into and

out of the AONB to the relevant Area of Outstanding Natural Beauty Management Plan. The impact of the proposed development on the AONB has been assessed in both the submitted LVIA and the Ecology Report, which demonstrate that the proposed development and associated works will have a beneficial landscape and visual impact and will deliver significant ecological benefits to the local area. Thus, the proposed development accords with the requirements of Policy AMG1.

6.28 Policy AMG2 refers to Special Landscape Areas (SLA) and, although cited in the reasons for

refusal of planning application ref 30C16Y, is not applicable to the proposed development since the application site is not located within a SLA. The closest SLA to the application site located to the north west of Benllech, at a distance of approximately 3km,

6.29 The submitted LVIA demonstrates that the proposed development will not have have

significant adverse impact upon features and qualities which are unique to the local landscape in terms of visual, historic, geological, ecological or cultural aspects. Indeed, the LVIA confirms that the proposed development and associated works would have a beneficial effect on landscape character. Thus, the proposed development is supported by Policy AMG3 which states that “a proposal will be granted provided it doesn’t have significant adverse impact upon features and qualities which are unique to the local landscape in terms of visual, historic, geological, ecological or cultural aspects”.

6.30 Policy AMG4 confirms that development on the coast must conform to specified criteria. The

proposed development:


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• Requires a coastal location as it involves the direct replacement of lawful touring

caravans and tents by static caravans, within an established coastal Holiday Park site

(Criteria 1);

• The proposed development will have no impact on water quality (Criteria 2i);

• The proposed development and associated works will enhance public access through

associated improvements which involve planting alongside the coastal footpath

through the Holiday Park and the establishment of a permissive footpath to

interpretation facilities relating to Castell Mawr (part of the Trwyn Dwlban SSSSI)

(Criteria 2ii);

• The submitted LVIA demonstrates that the proposed development and associated

works will have a beneficial landscape impact (Criteria 2iii);

• The submitted Ecology Report demonstrates that the proposed development and

associated works will deliver significant ecological benefits to the local area (Criteria

2iv);

• The proposed development and associated works is well related to existing

buildings, caravans and facilities (Criteria 3);

• Within the Holiday Park, the application site has been identified as the most

appropriate to accommodate the proposed development Criteria 4); and

• The proposed development is consistent with other Plan policies and with Policy

ARNA1 (see paras 6.35 – 6.38 below) (Criteria 4).

Thus, the proposed development conforms with the requirements of Policy AMG4.

6.31 The submitted Ecology Report demonstrates that the proposed development and associated works will enhance biodiversity by the creation of and management of calcareous grassland and the management of existing areas of woodland.

6.32 Calcareous Grassland is a habitat that is listed on Section 7 of the Environment (Wales) Act 2016, in recognition of its value as a habitat of Principal Importance in Wales and the coastal fringe is of potential value to common lizard.

6.33 The management of the areas of woodland will ensure that it is of better value to nesting

birds and to protected species including red squirrel and foraging/roosting bats. 6.34 Thus, the proposed development accords with the requirements of Policy AMG5. 6.35 The submitted Flood Consequences Assessment demonstrates that the proposed

development will not be affected by current flooding and that localised land raising to 6.3m AOD will prevent inundation for the predicted water levels associated with the 200-year (0.5% AEP) plus climate change (2116), and the 1000-year (0.1% AEP) flood events, respectively.

6.36 Access and egress routes to/from all of the proposed static caravans are located entirely

outwith present day and future flood outlines.


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6.37 The overall risk to life, consequential to flooding under climate change scenarios, is reduced when compared with the existing situation, due to the removal of all non-fixed structures (45 touring caravans and an unlimited number of tents) which could be affected by flood conditions.

6.38 Thus, the proposed development satisfies the requirements of Policy ARNA1 6.39 The proposed development is consistent with the relevant principles of sustainable

development, as expressed in Strategic Policy PS5, since it will:

• Respond to the unavoidable impacts of climate change by reducing the risk to life,

consequential to tidal flooding, for the predicted water levels associated with the

200-year (0.5% AEP) plus climate change (2116), and the 1000-year (0.1% AEP) flood

events, respectively;

• It will involve the re-use of previously developed land;

• It will protect and enhance the quality of the landscape and will deliver significant

ecological benefits to the local area;

• It will manage flood risk and will utilise SUDS; and,

• It will help promote tourism to the benefit of the economy of surrounding rural area

and existing centres and villages.

Thus, the proposed development benefits from the presumption in favour of sustainable

development expressed on Planning Policy Wales.

6.40 The proposed development and associated works is supportive of relevant policies and objectives expressed in the Isle of Anglesey AONB Management Plan Review 2015 – 2020. In particular, the proposed development:

• Will safeguard the Trwyn Dwlban Geological SSSSI and will enhance interpretation facilities at Castell Mawr (Policy CCC 1.3);

• Will have a beneficial landscape and visual impact on the AONB, will deliver

significant ecological benefits to this part of the AONB and embodies the principles

of sustainable development (Policy CCC 3.2);

• Accords with planning policies that seek to conserve and enhance the special

qualities and features of the AONB (Policy CCC 3.3);

• Will maintain, restore and enhance priority habitats and biodiversity in the AONB

(Policy NE 1.2);

• Will maintain, restore, expand and create wildlife habitats (Policy NE 3.1);

• Will facilitate the further development of tourism in the area by improving the

quality of accommodation provided (Policy VE 2.1);

• Will enhance the public right of way network by enhancing the environment of the

coastal footpath and by providing signed permissive footpath access to Castell Mawr

(Policy VE 4.2);

• Will facilitate the management of existing woodlands (Policy LWL 1.5); and,

• Will facilitate a better understanding of the special qualities of the AONB by the

provision of interpretation facilities at Castell Mawr (Management Objective 2).

6.41 The proposed development and associated works is supportive of the Welsh Government’s

objectives for the conservation and improvement of the natural heritage and for the


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promotion and conservation of landscapes, biodiversity, native wildlife and habitat, as expressed in PPW and TAN5.

6.42 In addition, the proposed development, by virtue of the proposed access improvements and

interpretation facilities at Castell Mawr, within the Trwyn Dwlban SSSI, is also supportive of the duty, imposed by PPW, to conserve and enhance SSSI’s.

6.43 For the reasons outlined above, the proposed development accords with the provisions of and takes support from the provisions of the Anglesey and Gwynedd Joint Local Development Plan, the Isle of Anglesey AONB Management Plan Review 2015 – 2020 and from Planning Policy Wales and associated TAN’s.



7 CONCLUSIONS

7.1 The proposed development will bring greater homogeneity to the St Davids Holiday Park

which, together with the recent investment in the Spa, indoor pool, bar and restaurant, will

enhance the overall quality of the site, increase its attractiveness to higher spending visitors

and contribute to the improvement of the overall tourism offer on the Isle of Anglesey.

7.2 The proposed development is supportive of the principles of sustainable development,

expressed within PPW and JLDP Policy PS5, since it involves the re-use of land that is already

used for the siting of caravans, capitalises on previous investment in infrastructure and

facilities at the Holiday Park, protects and enhances the landscape and visual qualities of the

AONB, results in ecological and biodiversity benefits to the natural environment and

responds to the unavoidable impacts of climate change through the management of flood

risk.

7.3 In particular, the proposed development will:

• Enhance the provision of high quality un-serviced tourism accommodation that meets modern day needs;

• Support the visitor economy and the development of all year round tourism;

• Enhance the landscape character and natural beauty of this part of the AONB by reducing the visual and landscape impact of the Holiday Park on the local landscape;

• Protect and enhance biodiversity and restore networks of priority natural habitats by the creation and management of calcareous grassland and the management of existing areas of woodland;

• Enhance habitats used by protected species, including bats, reptiles and red squirrel;

• Facilitate a better understanding of the special qualities of the AONB by the provision of interpretation facilities at Castell Mawr (part of the Trwyn Dwlban Geological SSSI);

• Enhance the enjoyment and visitor interest for users of the popular coastal footpath through additional planting and the provision of a signed permissive footpath to the proposed interpretation facilities at Castell Mawr; and

• Prevent flood inundation of susceptible parts of the application site for the predicted water levels associated with the 200-year (0.5% AEP) plus climate change (2116), and the 1000-year (0.1% AEP) flood events, respectively, thereby reducing the overall risk to human life.

7.4 The proposed development is fully in accordance with the provisions of the up to date and

recently adopted Joint Local Development Plan for the area, with Planning Policy Wales and

relevant Technical Advice Notes and with the relevant policies and objectives expressed in

the Isle of Anglesey AONB Management Plan Review 2015 – 2020

7.5 The proposed development will not result in any material harm to interests of acknowledged

importance.

7.6 The local planning authority is requested, therefore, to grant planning permission for the

proposed use of the existing touring caravan and camping site area within St David’s Holiday

Park for the siting of 35 static holiday caravans, the construction of caravan bases, parking


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spaces and internal site access roads and associated landscaping and habitat creation works,

following the demolition of an existing shower block building at St David’s Holiday Park, Red

Wharf Bay, Isle of Anglesey.



APPENDIX A Area of land to which the

Certificate of Lawful Development relates.


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APPENDIX B Planning Application Ref 30C16Y Decision Notice.


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APPENDIX C Planning Officers Report on Application Ref 30C16Y

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