FINAL PLANNING STATEMENT - St Mary Warden Accommodation

PLANNING STATEMENT
APPLICATION FOR THE SITING OF A CARAVAN/RESIDENTIAL PARK
HOME FOR USE AS OWNERS/WARDENS ACCOMMODATION
IN RESPECT OF
ST MARY’S CARAVAN AND CAMP SITE, MOSTYN ROAD, GRONANT,
PRESTATYN, LL19 9TB
FEBRUARY 2012
BY
ON BEHALF OF
WENDY SOCKETT
WEST REGISTER (REALISATIONS) LTD
COLLIERS INTERNATIONAL UK PLC
Company registered in England and Wales no. 4195561
Registered Office:
9 Marylebone Lane
London W1U 1HL
Tel: +44 (0) 20 7935 4499
www.colliers.com/uk
COLLIERS INTERNATIONAL UK
Planning Statement
2 of 26
TABLE OF CONTENTS
1
Introduction
4
2
Site Location and Context
5
3
Planning Policy
6
Local Planning Policy
6
National Planning Policy
8
Planning Policy Wales, Version 4 February 2011
10
Other Material Considerations
10
4
Analysis
11
5
Conclusion
18
APPENDICES
1
CONFIDENTIAL Business Plan & Accounts (freestanding document)
2
Brynich Park Appeal P63/247
3
Greenacres Appeal T/APP/L1765/A/96/273670
4
Blossom Park Appeal APP/E6840/A/10/2135514
5
Austerfield Appeal APP/F4410/A/01/1072952
6
Facilities Building As Existing Floorplan
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1
INTRODUCTION
1.1
Colliers International has been instructed by West Register (Realisations) Ltd to prepare this application at St
Marys Caravan and Camp Site (St Mary’s) for the provision of a residential caravan. This will provide year
round accommodation for the Park Warden and allow there to be a 24 hour presence on site in case of
emergencies, ensure that health and safety requirements are maintained on site, and improve site security, to
assist with the management of late bookings and to provide a high standard of service for customers.
1.2
The caravan and camp site has suffered a number of break-ins and thefts over recent times. On a number of
occasions the facilities building has been broken into and items such as building materials, copper piping and
other materials for the renovation of the site have been stolen.
1.3
It is proposed that an appropriate planning condition which controls the occupancy of the residential units is
attached to any forthcoming permission in order to ensure that it remains in use for the purpose intended. The
suggested wording would be:
The occupation of the dwelling shall be limited to a person solely or mainly employed or last employed in the
business occupying the site edged red on the attached plan or a widow or widower of such a person or any
resident dependents
1.4
If the proposed planning condition set out above is not felt to be acceptable, the applicants agree that they can
accept a temporary permission for a period of three years.
1.5
The proposed unit would be a residential caravan or ‘park home’. Should the application be approved and the
unit sited, it can be easily removed and the land restored should it no longer be required.
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2
2.1
SITE LOCATION AND CONTEXT
The application site extends to approximately 40sqm and is situated adjacent to the site entrance off the A548.
The camping and caravanning site currently accommodates up to 56 touring caravan and tent pitches and a
st
th
rally field with existing permission for hosting up to six four day rallies per annum between 1 March and 14
January.
2.2
The application site is surrounded by agricultural and undeveloped grassland to the west, the north and the
east.
2.3
The existing park is accessed directly from the A548, Mostyn Road and the existing internal roads provide direct
access to the application site.
2.5
The site benefits from good accessibility, being situated along the A548 Prestatyn to Flint road and is located
within a general area which is popular with camping and caravanning customers. A number of sites are located
to both the east and west as well as in more coastal sites to the north.
2.6
A detailed assessment of the planning history has been undertaken. The use of the site for holding caravan
rallies commenced some decades ago and a Certificate of Lawful Existing Use was issued in January 1996. A
further application (P-98-23-00906) was made to allow the use of the site for holding the rallies over an
st
th
extended season which runs from 1 March to 14 January. This decision notice also removed the permitted
development rights of land associated with camping and caravanning uses.
2.7
The site benefits from an existing facilities building which provides a number of essential services to the park
and business. The building contains a reception and office, male and female toilet and shower facilities, a
washing up area, laundrette and plant room. A detailed floor plan is provided at Appendix 6.
2.8
The Environment Agency Flood Maps have been inspected and the site is located in an area which is deemed
to have a low risk of flooding and has the benefit of flood defences.
The site is unlikely to flood except in extreme conditions. The chance of flooding each year is 0.5% (1 in
200) or less. This takes into account the effect of any flood defences that may be in this area, whether or
not these are currently illustrated in the flood map.
2.9
The site is situated within close proximity of a number of statutory and non-statutory ecological assets the
details of which are provided within the accompanying ecological assessment.
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3
PLANNING POLICY
3.1
Section 38 (6) of the Planning and Compulsory Purchase Act 2004 requires planning applications to be
determined in accordance with the Development Plan unless material consideration indicates otherwise.
LOCAL PLANNING POLICY
THE FLINTSHIRE UNITARY DEVELOPMENT PLAN SEPTEMBER 2009
3.2
The Flintshire UDP was adopted in September 2011.
3.3
Policy HSG4 provides guidance on the provision of new dwellings outside settlement boundaries advising that
permission will only be granted where it is essential to house a farm or forestry worker who must live at or very
close to their place of work and not in a nearby dwelling or settlement, provided that:
A.
the proposal is accompanied by an appropriately completed questionnaire, which will be the subject of
an independent assessment of the functional and financial need for the dwelling in relation to the
enterprise;
B.
the need cannot be met through the economic conversion and reuse of existing buildings on site;
C.
there has been no prior disposal of a dwelling or existing building suitable for conversion on the
farm unit which could have been used to meet this need;
D.
the dwelling is sited so as to relate to buildings on the existing farm or forestry complex and that its
design, scale, and appearance takes into consideration the landscape setting of the surrounding area;
and
E.
the size, floorspace and type of proposed dwelling should be appropriate to that which the farm/forestry
enterprise can sustain.
3.4
Policy HSG4 further advises that such dwellings will be subject to an occupancy condition.
3.5
Policy GEN1 sets out the general requirements for development and advises that proposals should be in
buildings or locations which meet a number of requirements including:
•
The development should harmonise with the site and surroundings in terms of the siting, scale, design,
layout, use of space, materials, external appearance and landscaping;
•
The development should not have a significant adverse impact on recognised wildlife species and
habitats, woodlands, other landscape features, townscapes, built heritage, features of archaeological
interest, nor the general natural and historic environment;
•
The development should not have a significant adverse impact on the safety and amenity of nearby
residents, other users of nearby land/property, or the community in general, through increased activity,
disturbance, noise, dust, vibration, hazard, or the adverse effects of pollution.
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•
The development should not have an unacceptable effect on the highway network as a result of problems
arising from traffic generation, and should incorporate traffic calming measures where appropriate;
•
The development should have, where appropriate, convenient access to public transport, and wherever
possible is well related to pedestrian and cycle routes;
•
The development should not result in/be susceptible to problems related to drainage, land stability,
contamination, or flooding, either on or off site.
3.6
Policy GEN3 provides guidance on development proposals in the open countryside and advises that
development will not be supported unless it meets one of a range of specified criteria which includes:
•
Development related to agriculture, minerals extraction, rural diversification, tourism, leisure and
recreation, and existing educational and institutional establishments, provided there is no unacceptable
impact on the social, natural and built environment;
•
Other development which is appropriate to the open countryside and where it is essential to have an open
countryside location rather than being sited elsewhere.
3.7
Policy GEN4 has regard to green barriers and advises development will only be permitted in specific
circumstances including:
3.8
•
Justified development in association with forestry or agriculture;
•
Essential facilities for outdoor sport and recreation, or cemeteries;
•
Small scale farm diversification;
•
Other appropriate rural uses/development for which a rural location is essential provided it would not:
°
Contribute to the coalescence of settlements; and
°
Unacceptably harm the open character and appearance of the green barrier.
Policy D1 provides guidance on design quality, location and layout and is supportive of development which:
a
It respects the scale of the surrounding development, its location, siting, and layout make the best use of
land, minimise the need to travel, and provide a safe and attractive environment;
b
It is of the highest net density appropriate to its setting and function;
c
It relates well to local topography, aspect, microclimate, street pattern, orientation and views;
d
It creates positive and attractive building alignments and frontages;
e
Adequate provision is made for space around buildings, setting of buildings, imaginative parking and
landscaping solutions;
f
Maximises the efficient use of resources, minimises the use of non-renewable resources and minimises
the generation of waste and pollution;
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g
It is accompanied by design information commensurate with the scale and type of development
proposed;
3.9
Policy WB3 advises that SSSI’s will be protected through a presumption against development either within or in
the vicinity of a site which would have a significant adverse effect on the nature conservation interest of that
SSSI.
3.10
Policy EWP17 has regard to development and flooding and advises that development in areas at risk of flooding
will only be permitted where the authority can be satisfied that:
•
the consequences of a flooding event can be effectively managed;
•
It would not increase the risk of flooding elsewhere;
•
Appropriate alleviation and mitigation measures are incorporated;
•
It would not impact on the integrity of fluvial and tidal flood defences;
NATIONAL PLANNING POLICY
TECHNICAL ADVICE NOTE 6: PLANNING FOR SUSTAINABLE RURAL COMMUNITIES, JULY 2010
3.11
Section 4.3 provides the general guidance on the provision of rural enterprise dwellings, which relates to new
isolated residential development in the open countryside which is required to enable rural enterprise workers to
live at, or close to, their place of work.
3.12
Section 4.4 relates specifically to the provision of new dwellings on established rural enterprises and advises
that the following criteria should be met for planning permission to be forthcoming:
•
There is a clearly established existing functional need (as defined by para 4.8.1 of TAN6);
•
The need relates to a full-time worker, and does not relate to a part-time requirement; (as set out in para
4.7.1 of TAN6 and exemptions set out in paras 4.5.1 – 4.5.3);
•
The enterprise concerned has been established for at least three years, profitable for at least one of them
and both the enterprise and the business need for the job, is currently financially sound, and has the clear
prospect of remaining so (as set out in paras 4.10.1 – 4.10.3 of TAN6);
•
The functional need could not be fulfilled by another dwelling or by converting an existing suitable building
already on the land holding comprising the enterprise, or any other existing accommodation in the locality
which is suitable and available for occupation by the worker concerned (as set out in paras 4.11.1 –
4.11.2 of TAN6); and
•
3.13
Other normal planning requirements for example siting and access are satisfied
Section 4.6 relates specifically to the provision of new dwellings on new enterprises and advises that proposals
should satisfy the following criteria:
•
Clear evidence of a firm intention and ability to develop the rural enterprise concerned (significant
investment in new buildings and equipment is often a good indication of intentions);
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•
Clear evidence that the new enterprise needs to be established at the proposed location and that it
cannot be accommodated at another suitable site where a dwelling is likely to be available;
•
Clear evidence that the proposal has been planned on a sound financial basis;
•
That there is a clearly functional need and that need relates to a full time worker, and does not relate to a
part time requirement;
•
The functional need could not be fulfilled by another dwelling or by converting an existing suitable building
on the enterprise, or any other existing accommodation in the locality which is suitable and available for
occupation by the workers concerned; and
•
3.14
Other normal planning requirements, for example siting and access, are satisfied.
Paragraph 4.6.2 advises that when a case is not completely proven, planning permission should not be granted.
However, the local authority could test the evidence through the granting of permission for temporary
accommodation for a period of three years and allow a reassessment of the business and need at a later date.
3.15
Paragraph 4.7.1 advises that applications for rural enterprise dwellings should be accompanied by an appraisal
which should address the following:
•
The functional test to provide evidence of whether there is a need for a resident worker for the proper
functioning of the enterprise (see section 4.8 of TAN6);
•
The time test to provide evidence of whether there is a need for the worker who is working on the
justifying enterprise (see section 4.9 of TAN6);
•
The financial test to provide evidence of the economic sustainability of the justifying enterprise and
identify the size of the dwelling that the enterprise can sustain, ensuring that the size of the dwelling is
commensurate with its functional need and financial justification (see section 4.10 of TAN6).
•
The other dwellings test to identify whether there is an existing dwelling or building suitable for conversion
on the enterprise or dwelling in the locality that could meet the identified functional need (see section 4.11
of TAN6);
•
Other normal planning requirements test to demonstrate that the dwelling is suitably located to fulfil its
identified need and to minimise impact on the wider environment (see section 4.12 of TAN6).
3.16
The functional test is set out in Section 4.8 and advises that this test is to establish whether it is essential for
one or more workers to be readily available at most times. This test should provide evidence which relates to
unexpected situations which might arise, need for workers outside of normal working hours.
3.17
Section 4.9 looks at the time test. When it has been demonstrated that the functional test has been met, the
time test seeks to establish the number of workers required to meet the identified business needs. Applications
for accommodation must relate to a full time worker, not part time workers.
3.18
Section 4.10 provides guidance on the financial test and advises that the rural enterprise for which residential
accommodation is sought, must be financially sound and should have a good prospect of remaining financially
sound for a reasonable period, usually at least five years. Evidence of the financial performance of the rural
enterprise must be provided. Businesses must be able to demonstrate a market return for operators for a
period of five years. The size of the dwelling permitted will be related to the need of the enterprise.
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PLANNING POLICY WALES, VERSION 4 FEBRUARY 2011
3.19
Para 9.3.6 has regard to the provision of housing in the open countryside and advises that such housing is
subject to special justification, such as an identified need and as rural enterprise housing and should conform to
the requirements set out in TAN6.
OTHER MATERIAL CONSIDERATIONS
3.20
As part of the background research for the resubmission of this application, due consideration has been given to
other touring caravan sites of similar or smaller size situated within the open countryside throughout the UK
where it has been deemed acceptable to provide onsite wardens accommodation.
A selection of appeal
decisions have been identified and are discussed in brief in Section 5 of this Statement, copies are provided
within the appendices.
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4
ANALYSIS
4.1
This section of the report considers the specific policies identified in Section 3 in the context of the application
proposals.
HOUSING IN THE COUNTRYSIDE
4.2
Policy HSG4 of the Flintshire UDP is the principle policy for assessing applications for dwellings in the open
countryside. The policy appears to relate specifically to dwellings associated with agricultural and forestry
businesses, however national policy TAN6 (discussed later) provides a wider scope enabling the provision of
dwellings within the open countryside, providing it is associated with a rural enterprise that requires an open
countryside location.
The policy sets out specific criteria which proposals should meet prior to achieving
approval.
4.3
Criterion A advises that proposals should be accompanied by an appropriately completed questionnaire which
will be utilised to assess the functional and financial need for the proposed enterprise dwelling.
The
questionnaire seems relates solely to agricultural businesses and is not relevant to this proposal and the rural
enterprise it is associated with. Further information relating the functional and financial tests, along with other
information required by TAN6, is provided later and demonstrates that the proposal is in line with the
requirements of criterion A.
4.4
St Mary’s does not have any existing buildings which can be converted to residential use. The floor plan of the
existing facilities building at Appendix 6 illustrates that the building does not have sufficient space to provide
suitable living accommodation. The uses contained within the building are essential services for the park and
business, and would need to be provided elsewhere on site if this building was to be converted to living
accommodation. It is therefore considered that the proposal meets the requirements of criterion B.
4.5
It is the understanding of the current owners and operators of the camp site that there have been no sale or
disposal of any building over recent years which could have met the current need and the proposal is therefore
compliant with criterion C.
4.6
The proposed static caravan is to be sited adjacent to the entrance to the caravan and camp site and will be in
close proximity to the existing facilities building which accommodates the site office, reception, toilets and
laundrette.
The proposed static caravan is relatively small and will provide a good level of modest site
accommodation. The proposed caravan will be in character with the existing use of the land as a caravan and
camp site. It is therefore considered that the proposal meets the requirements of criteria D and E.
4.7
Policy HSG4 also advises that any residential accommodation approved under this policy will be subject to an
occupancy restriction. The requirement for such a condition is not disputed with a selection of acceptable
conditions discussed in Section 1 of this Statement.
4.8
It is therefore our opinion that the proposal in wholly in line with the requirements of Policy HSG4 of the
Flintshire UDP.
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FUNCTIONAL TEST
4.9
The need to pass the functional test is noted in Policy HSG4 of the Flintshire UDP and Section 4.4, 4.6 and 4.7
of TAN6.
The functional test is described in detail in Section 4.8 of TAN6 and requires the applicant to
demonstrate whether it is essential for one or more workers to be readily available at most times.
4.10
St Mary’s is a long established business, despite recent issues with new ownership, refurbishment requirements
and historical planning issues; the intention is for the continued operation of the site as a touring caravan and
camp site. It is common practice for touring caravan parks to provide on-site accommodation for the owners or
site wardens.
4.11
There are many tasks which are undertaken by site owners/wardens throughout the working day/week. These
include meeting and greeting customers (which can arrive throughout the day and night), taking bookings in the
late evening, assisting with siting caravans, landscape works, cleaning facilities, maintenance, gas sales, refuse
collection, dealing with customer queries, allowing access for owners to remove seasonal caravans, provision of
first aid and day to day administration. During the evening and night time period it is very useful to have a
member of staff available on site to manage incidents and noise levels. In respect of the Brynich Appeal
(Appendix 2) the Planning Inspector was:
satisfied that there is a need for a warden to live on the caravan site in order to control it and to respond to
the needs of the caravanners and campers throughout the whole period of the day. I am also of the opinion
that it would not be practical for the warden to live in Brecon and occupy modest accommodation attached
to the shop for the nine month period in which the site is open. Such an arrangement could involve a
married warden in possibly having to live apart from his/her family for quite long periods and is in my view
an unworkable arrangement. The circumstances surrounding this case are in my judgement sufficient to
justify allowing the appeal as a departure from the National Park Plan.
4.12
It is understood that the facilities building has been broken into on a number of occasions whilst the site has
been closed. During these incidences the facilities building has been vandalised and building materials and
equipment for the site renovation have been stolen. Once the site is operational continued low levels of security
could result in vandalism or theft of customer’s valuable touring caravans and future damage to the new
equipment installed on site.
4.13
During busy periods it is essential to ensure that customers behave appropriately, sometimes customers can
create noise late into the night disturbing not only other customers but also the local community. The benefits of
having an owner/warden on site 24 hours would increase the effectiveness of the site management and
prevention of such disturbances.
4.14
There are a number of events that can occur which would be more manageable if the site had the benefit of an
on-site manager.
One example would be a faulty/damaged sanitary item, such as a shower or toilet.
Customers feel much more comfortable approaching someone who resides on site, as opposed to making a
phone call and hoping someone arrives on site. Should the current owners have to live off site, say some, 3
miles from the site, customers are more likely to avoid reporting any incidences (be it malfunctioning items or
other nuisance customers) until the someone has arrived on site the next morning. This could result in a waste
of resources such as water and unhappy customers. This concept was understood by the Planning Inspector
for the Blossom Park appeal (Appendix 4) who stated:
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I am mindful of the importance placed by the site operator on securing a full time presence as a crucial
element of establishing a successful business on the site, which in turn would contribute to supporting a
sustainable and vibrant rural economy…. A continual on-site presence is seen as facilitating a superior
quality of customer service which would encourage return visits and enable a higher tourist rating to be
achieved.
4.15
It is understood that the size of the existing caravan and camp site may be of concern and not be large enough
to require a continuous staff presence. There are numerous sites throughout the UK which accommodate a
similar number of pitches with a similar, or even shorter operational season, that have dedicated on-site warden
accommodation, however it is recognised that the circumstances for each site may differ. We have undertaken
some initial research for appeal decisions which relate to proposals and circumstances which are similar to that
at St Mary’s. Copies of four appeal decisions are provided in the appendices, all of which relate to the provision
of dedicated on-site wardens accommodation for touring caravan parks located within the open countryside, all
of which have been allowed by the Planning Inspector. The sites in question range from 16 to 120 pitches and
have seasons which run between 7 and 12 months, some sites are relatively new and some are well
established. This above demonstrates that the site is well within the size identified as suitable for the provision
of on-site owners/warden accommodation.
4.16
It is therefore our opinion that the proposal passes the functional test as set out in TAN6.
TIME TEST
4.17
The need to pass the time test is noted in Sections 4.4 and 4.7 of TAN6. Additional information relating to the
time test is set out in Section 4.9 of TAN6.
4.18
The caravan park is currently run and managed by two members of staff (warden couple), who manage the day
to day running of the site including bookings, managing the office, dealing with enquiries, bookkeeping, general
maintenance, landscaping, cleaning and site management.
4.19
During the operational period, both members of staff are required throughout the day for general site
management and greeting visitors. During the evening one member of staff is required for greeting late arrivals
and dealing with any customer’s queries or complaints, though the presence of two members of staff through
the evening and night would result in a better work environment/job share for the staff. The need for a staff
presence during the closed season (mid-January to end of February) is reduced, however this closed period still
requires general maintenance works, office management, bookings management and continued site security.
Whilst this could be undertaken with one member of staff, the role is undoubtedly more manageable with two.
4.20
It is possible to implement a rota system and employ additional members of staff, all of whom would live off site,
however, this would place additional financial strains on the business through increased wages in addition to
increased management problems.
4.21
It is therefore our opinion that the proposal passes the time test as set out in TAN6.
FINANCIAL TEST
4.22
The need to pass the financial test is noted in policy HSG4 of the Flintshire UDP and Section 4.6, 4.6 and 4.7 of
TAN6. Additional information on the financial test is set out in Section 4.10 of TAN6.
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4.23
St Mary’s has until recently been an operational business. The current owners acquired the property in 2010
and sought to continue the operation of the site further to undertaking the necessary refurbishment and upgrade
works required.
Whilst such works on caravan and camp sites are normally categorised as permitted
development, the Article 4 direction removing the permitted development rights meant that formal planning
permission would be required for all the upgrade works in addition to resolving the outstanding issue of the
facilities building which had been constructed without the appropriate planning permission. Further to lengthy
discussions and exchanges of information with the Flintshire Council Planning Department, and application for
these works was submitted in January 2011 and approved in July 2011. Subsequently the delay in resolving
the planning issues and undertaking the necessary works delayed the re-opening of the site. The business plan
st
and projected figures attached as Appendix 1 confirm that the site is now due to become operational on 1
March 2012.
4.24
The enclosed business plan and the efforts and investment exerted to date clearly demonstrate that the owners
of the site have every intention of operating a fully functioning and viable business.
ALTERNATIVE DWELLINGS/ACCOMMODATION
4.25
The need to assess the availability of alternative accommodation either on site or in the locality is set out in
Policy HSG4 of the Flintshire UDP and Sections 4.4 and 4.7 of TAN6.
4.26
St Mary’s does not have any existing buildings which could be converted to residential use to accommodate the
site wardens. The existing facilities’ building accommodates all the essential facilities for the operation of the
park and business and as the floor plan at Appendix 6 illustrates, there is no room to provide appropriate living
accommodation. Consequently this application has been made to seek permission for the siting of a static
caravan on the site for this purpose.
It is our opinion that a single static caravan will provide adequate
accommodation for a warden couple and would not be out of place or character on this existing caravan and
camp site. There is potential, in the future, once the business is operational again and stable visitor numbers
have been established, for the extension of the facilities building to provide accommodation. However such an
approach at this stage is not feasible.
4.27
4.28
A detailed search of available properties within the area, both for rental and to buy has been undertaken.
The search identified 5 rental properties within a 0.5 radius of the application site, all situated within the village
of Gronant. Whilst the properties are within a 0.5 mile radius, the true travel distance to the site is close to 1
mile.
4.29
•
2 Bedroom House, £480 pcm
•
2 Bedroom House, £495 pcm
•
3 Bedroom House, £475 pcm
•
3 Bedroom House, £550 pcm
•
4 Bedroom House, £800 pcm
The search identified a further rental property within a 1 mile radius of the application site in the village of
Gwespyr. Whilst the property is within a radius of 1 mile, the actual travel distance, when accounting for the
road system, is approximately 2.5 miles.
•
3 Bedroom House, £575 pcm
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4.30
The search identified a further 27 rental properties within a 3 mile radius of the site:
No of
Bedrooms
4.31
Total
Properties
Available
£200-£300
£300-£400
£400-£500
£500-£600
£600 -
£700-£800
pcm
pcm
pcm
pcm
£700 pcm
pcm
1
4
1
3
0
0
0
0
2
13
0
1
4
6
2
0
3
9
0
0
0
6
3
0
4
1
0
0
0
0
1
0
The search identified a total of 27 rental properties consisting of four 1 bedroom properties, 13 2 bedroom
properties and nine 3 bedroom properties and one 4 bedroom property within 3 miles of the application site.
Whilst this search does provide alternative options for accommodation, they are all some distance from the site
and the need for the wardens to travel to and from the site would impede on the levels of customer service and
security provided.
4.32
Details of properties to buy are set out below:
4.33
There are 16 open market properties identified within a 0.5 mile radius broken down as below.
In excess of
£250,000
Available
4.34
£200 £249,999
£150 £199,999
£100 £149,999
Less than
£100,000
Studio flat
0
0
0
0
0
0
1 bedroom
0
0
0
0
0
0
2 bedroom
4
0
0
0
4
0
3 bedroom
5
0
0
2
2
1
4 bedroom
7
4
3
0
0
0
5 + bedroom
0
0
0
0
0
0
Development Land
0
0
0
0
0
0
There are 30 open market properties identified between a 0.5 and 1 mile radius broken down as follows:
In excess of
£250,000
Available
£200 £249,999
£150 £199,999
£100 £149,999
Less than
£100,000
Studio flat
0
0
0
0
0
3
1 bedroom
0
0
0
0
0
0
2 bedroom
5
0
0
0
5
0
3 bedroom
12
0
1
6
4
1
4 bedroom
11
7
3
1
0
0
5 + bedroom
2
2
0
0
0
0
Development Land
0
0
0
0
0
0
COLLIERS INTERNATIONAL
page 15 of 18
4.35
The search within a 3 mile radius identified a total of 375 properties broken down as follows:
Available
Studio flat
4.36
0
In excess of
£250,000
£200 £249,999
£150 £199,999
£100 £149,999
Less than
£100,000
0
0
0
0
0
1 bedroom
7
0
0
0
0
7
2 bedroom
111
1
3
11
63
33
3 bedroom
148
20
13
37
64
14
4 bedroom
84
46
22
14
3
0
5 + bedroom
25
14
3
7
1
0
Development Land
0
0
0
0
0
0
The tables above demonstrate a good supply of available properties to buy, however the camp site operator is
not in a position to acquire an off-site property to provide wardens accommodation. Furthermore the current
economic climate and increasingly restrictive mortgage application conditions are not conducive for potential
employees to purchase a property at this time.
4.37
As stated with the rental properties, the need for the wardens to travel to and from the site would impede on the
levels of customer service and security provided.
OTHER NORMAL PLANNING REQUIREMENTS
4.38
In addition to the main principal of the development proposal which is dealt with under Policy HSG4 of the
Flintshire UDP and TAN6, the proposal must also comply with relevant local policies.
Consequently the
following section will look at the specific spatial, landscape, design, ecological and environmental policies which
are relevant to this proposal, namely policies GEN1, GEN3, GEN4, D1, WB3 and EWP17.
LOCATION, DESIGN AND LAYOUT OF DEVELOPMENT
4.39
The proposal is for the provision of on-site warden’s accommodation for an existing caravan and camp site and
consequently the most appropriate location is on the existing caravan and camp site. The location of the camp
site is in line with the aims and requirements of UDP policies GEN3 and GEN4.
The precise location for the
proposed static caravan is adjacent to the site entrance; this location has been selected as this will enable
continued effective monitoring of the site in security terms as well as ensuring that the development on site
remains focused around one area and avoids unnecessary sprawl of development.
It is our view that the
proposal is in line with the first criterion of policy GEN1 and criteria A, B, C, D, E and G of Policy D1.
4.40
The proposed location and residential use, within the existing caravan and camp site is unlikely to impact on
nearby residents and is therefore compliant with the third criterion of policy GEN1.
ECOLOGY
4.41
The application site is an established caravan and camp site. The proposed additional development which will
result in the presence of one residential static caravan on site throughout the year is unlikely to result in any
impact on the identified ecological assets within the area, namely the River Dee Estuary RAMSAR, SPA and
SSSI sites. The proposal is therefore compliant with the second criterion of policy GEN1 and Policy WB3.
COLLIERS INTERNATIONAL
page 16 of 18
HIGHWAYS
4.42
The proposed development will result in an increase of one in terms of permitted caravans on the existing
caravan and camp site. The proposed unit will be a static unit which will remain on site throughout the year.
The proposed development will not impact on the existing traffic levels of the A548. The proposal is therefore
compliant with the fourth criterion of policy GEN1.
4.43
The application site is located within easy walking distance of bus stops on both the east and west bound
carriageway of the A548. The bus stops are serviced by the number 11 and 11C Rhyl to Holywell bus service
which runs every 30 mins Monday to Saturday and provides eight services on a Sunday. The number 18 Rhyl
to Flint service runs twice a day during the week and three times on a Saturday. Works to provide the North
Wales Coast Cycle path is on-going, once finalised will make a significant contribution to the cycle opportunities
within the locality. It is therefore concluded that the proposal meets with the requirements of the fifth criterion of
Policy GEN1 s far as is practically possible for this location.
FLOOD RISK
4.44
The application site is located within an area at risk from tidal flooding but does have the benefit of flood
defences protection.
A flood consequences assessment is provided with the application as is a flood
evacuation procedure which has been approved for the evacuation of the camp site. The flood evacuation
procedure will be managed by the wardens who would reside in the warden’s accommodation which is the
subject of this planning application. The proposal is therefore considered to meet the requirements of the sixth
criterion of Policy GEN1 and Policy EWP17.
COLLIERS INTERNATIONAL
page 17 of 18
5
CONCLUSION
5.1
The application is for a residential caravan to provide on-site accommodation for the operation of this business
which is due to re-launch in March 2012 further to the acquisition of the site by new owners and the resolution of
outstanding planning issues which prevented the operation of the business during 2011.
5.2
The opportunity to reside on site at this touring caravan park will help secure the future of this rural business.
Should the park owners be forced to reside off site in a property more than 1 mile from the business it will
impact on the levels of customer service, preventing this existing business achieving its full potential.
5.3
The siting of one caravan for use as residential wardens accommodation on a site which has permission for
accommodating up to 56 touring caravans is unlikely to result in any negative impact on rural amenity which is
st
significant enough to warrant refusal. The site can accommodate caravans for holiday purposes between 1
th
March and 14 January. The actual visual impact would be the siting of one caravan outside of this permitted
holiday season.
5.4
A continuous presence of a site warden on site will assist with the effective monitoring of the flood risk and
enable effective and efficient evacuation of the site should a flood event occur.
5.4
The proposal is in line with the requirements of UDP Policy HSG4 and also TAN6 in that there is a clearly
identified need for the provision of on-site accommodation for an established business. The proposal also
meets the tests set out in Section 4 of TAN6.
5.5
There are a number of precedent cases whereby parks of a similar size have been deemed enough of a
significant business interest to warrant the provision of on-site warden accommodation.
5.6
The applicants are happy to accept a temporary planning permission with a view for the need to be re-assessed
in the future.
5.7
On behalf of West Register Realisations Ltd I respectfully request that the planning application be approved.
COLLIERS INTERNATIONAL
page 18 of 18
APPENDICES
1
CONFIDENTIAL BUSINESS PLAN &
ACCOUNTS (FREESTANDING
DOCUMENT)
2
BRYNICH PARK APPEAL P63/247
3
GREENACRES APPEAL
T/APP/L1765/A/96/273670
4
BLOSSOM PARK APPEAL
APP/E6840/A/10/2135514
5
AUSTERFIELD APPEAL
APP/F4410/A/01/1072952
6
FACILITIES BUILDING AS EXISTING
FLOORPLAN
CONTACT DETAILS
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Dir: 0113 200 1873
Fax: 0113 2001840
Wendy.sockett@colliers.com
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