Pecyn Dogfennau

Mark James LLM, DPA, DCA Prif Weithredwr , Chief Executive, Neuadd y Sir, Caerfyrddin. SA31 1JP County Hall, Carmarthen. SA31 1JP

DYDD LLUN, 11 IONAWR 2016

AT: HOLL AELODAU’R PWYLLGOR CYNLLUNIO

YR WYF DRWY HYN YN EICH GALW I FYNYCHU CYFARFOD O’R PWYLLGOR CYNLLUNIO A GYNHELIR YN Y SIAMBR, NEUADD Y SIR AM 1.00 PM, DYDD MAWRTH, 19EG IONAWR, 2016 ER MWYN CYFLAWNI'R MATERION A AMLINELLIR AR YR AGENDA SYDD YNGHLWM

Mark James

PRIF WEITHREDWR

AILGYLCHWCH OS GWELWCH YN DDA Swyddog Democrataidd: Kevin Thomas Ffôn (llinell uniongyrchol): 01267 224027 Ffacs: (01267) 224911 E-bost: [email protected] Cyf: AD016-001

PWYLLGOR CYNLLUNIO 19 AELOD

Y GRŴP PLAID CYMRU – 7 AELOD 1. Y Cynghorydd J.M. Charles Aelod o Gyngor Cymuned Llanegwad 2. Y Cynghorydd W.T. Evans Aelod o Gyngor Cymuned Llangyndeyrn 3. Y Cynghorydd J.K. Howell 4. Y Cynghorydd W.J. Lemon Aelod o Gyngor Tref Llanelli 5. Y Cynghorydd A. Lenny Aelod o Gyngor Tref Caerfyrddin 6. Y Cynghorydd J. Owen 7. Y Cynghorydd J.S. Williams Aelod o Gyngor Cymuned Pontyberem

Y GR ŴP LLAF UR – 6 AELOD 1. Y Cynghorydd A.P. Cooper Aelod o Gyngor Cymuned Llandybïe 2. Y Cynghorydd T. Davies Aelod o Gyngor Cymuned Gors-las 3. Y Cynghorydd D.C. Evans Aelod o Gyngor Tref Rhydaman 4. Y Cynghorydd A.W. Jones 5. Y Cynghorydd K. Madge Aelod o Gyngor Tref Cwmaman 6. Y Cynghorydd M.K. Thomas Aelod o Gyngor Cymuned Llannon

Y GR ŴP ANNIBYNNOL – 6 AELOD 1. Y Cynghorydd D.B. Davies Aelod o Gyngor Cymuned Llansteffan 2. Y Cynghorydd I.W. Davies 3. Y Cynghorydd J.A. Davies 4. Y Cynghorydd I.J.Jackson Aelod o Gyngor Tref Llanymddyfri 5. Y Cynghorydd H.I. Jones Aelod o Gyngor Cymuned Bronwydd 6. Y Cynghorydd T. Theophilus Aelod o Gyngor Cymuned Cilycwm

DIRPRWYON ENWEBEDIG

Y Grŵp Plaid Cymru (4) 1. Y Cynghorydd M.J. A. Lewis 2. Y Cynghorydd D.J.R. Llewellyn 3. Y Cynghorydd G.B.Thomas 4. Y Cynghorydd J.E. Williams

Y Grŵp Llafur (4) 1. Y Cynghorydd R. Bartlett 2. Y Cynghorydd P.M. Edwards 3. Y Cynghorydd J.D. James Aelod o Gyngor Tref Pen-bre a Phorth Tywyn 4. Y Cynghorydd P.E.M. Jones Aelod o Gyngor Tref Pen-bre a PhorthTywyn

Y Grŵp Annibynnol (4) 1. Y Cynghorydd S.M. Allen Aelod o Gyngor Tref Hendy-Gwyn 2. Y Cynghorydd W.J.W. Evans Aelod o Gyngor Cymuned Llanddarog 3. Y Cynghorydd P.M. Hughes 4. Y Cynghorydd D.W.H. Richards

Aelod Lleol a gwahoddir i fynychu’r cyfarfod:- Eitem 3. 2 – Cyngh orydd S.M. Allen

A G E N D A

1. YMDDIHEURIADAU AM AB SENOLDEB

2. DATGAN BUDDIANNAU PE RSONOL

3. YSTRIED ADRODDIADAU' R PENNAETH CYNLLUNIO YNGHYLCH Y CEISIADAU CYNLLUNIO CANLYNOL [YR YMWELODD Y PWYLLGOR A'U SAFLEOEDD YN FLAENORAL] A PHENDERFYNU AR Y CEISIADAU

3 .1 W/32670 - GOSOD UN TYRBIN GWYNT BACH (85 5 - 22 CILOWAT) YNGHYD Â CHABINET CYSYLLTIEDIG AR GYFER OFFER A GWAITH ATEGOL, AR DIR TRIOL BACH, CYNWYL ELFED, CAERFYRDDIN, SA33 6SU 3 .2 W/33032 - SAFL E BYCHAN AR GYFER PODIAU 23 - 32 GWERSYLLA SY'N GYDNAWS Â'R AMGYLCHEDD, GAN GYNNWYS PEDWAR POD GWERSYLLA AC UN LLAIN I BABELL, UN POD SYDD Â THOILED AR WAHÂN I DDYNION AC I FERCHED A CHAWOD, UN TOILED I'R DDWY RYW A CHEGIN YNGHYD Â LLECYN BARBECIW, AR DIR WEST WALES CAMPING PODS, PLASBACH, HENLLAN AMGOED, HENDY-GWYN AR DAF, SA43 0SE

Mae'r dudalen hon yn wag yn fwriadol Eitem Rhif 3.1

Application No W/32670

Application Type Full Planning

Proposal & INSTALLATION OF SINGLE SMALL SCALE WIND TURBINE Location (85KW) TOGETHER WITH ASSOCIATED EQUIPMENT CABINET AND ANCILLARY WORKS AT LAND AT TRIOL BACH, CYNWYL ELFED, CARMARTHEN, SA33 6SS

Applicant(s) EMYR DAVIES, TRIOL BACH, CYNWYL ELFED, CARMARTHEN, SA33 6SS

Agent PLAN-A PLANNING & DEVELOPMENT LTD - ANDREW PYWELL, SUITE D, SWAN YARD, 9-13 WEST MARKET PLACE, CIRENCESTER, GLOUCESTERSHIRE, GL7 2NH

Case Officer Richard Jones

Ward Cynwyl Elfed

Date of validation 15/09/2015

CONSULTATIONS

Head of Transport and Engineering – No adverse comment raised.

Head of Public Protection – More information has been requested by Environmental Health officers on the following grounds - The noise emission data submitted with the application stipulates that the test has been undertaken with regards to a turbine with a hub height of 22.6m, however the proposed wind turbine has a hub height of 36.6m. The noise predictions need to include a correction to account for this difference in hub heights.

Also the roughness factor that has been used in the calculations is 0.01, however IEC 61400-11 recommend using ground roughness of 0.05m, therefore this also need to be accounted for.

Further information has been submitted by the applicant following the case officer’s request for the above details. This information is currently being assessed by Public Protection Officers.

Cynwyl Elfed Community Council – Have responded and requested that more information is submitted with the application, however, the community council have not specified in their response what information is required.

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Local Member - County Councillor H Irfon Jones has requested for the application to be reported to planning committee, to assess the economic benefit of the proposal to agriculture enterprise.

Ministry of Defence – No objection subject to the MoD standard condition relating to the submission of details once the turbine has been constructed.

Spectrum Licensing – No adverse comments raised.

The Joint Radio Company Ltd – No interference predicted from proposed turbine.

NATS – No safeguarding objection to the proposal.

Civil Aviation Authority – No adverse comments raised.

CADW – Have assessed the proposal’s impact upon the setting of scheduled ancient monuments in the area and consider the impact of the proposed turbine on settings of these monuments will be, at worst, very slight.

Dyfed Archaeological Trust – No response received to date.

Natural Resources Wales – We have no objection to the proposal subject to the turbine being sited in accordance with the guidance in Natural England Technical Information note TIN051 ‘Bats and Onshore Wind Turbines’ 3rd Edition (March 2014).

Neighbours/Public - The application has been publicised by the posting of Site Notices adjacent to the site. Five letters of objection have been submitted and these are summarised below:-

• Impact upon the landscape and visual amenities of surrounding occupiers and users of the area. • The proposal will have an unacceptable cumulative landscape and visual impact. Turbines are becoming the defining feature in the landscape. • The Inspector’s decision letter raised concerns in respect of W/29252 which are still valid in the case of this proposed turbine which has been re-sited to the north west and close to the two existing turbines on the holding. • Noise impact. • Residents at Glanrhyd consider that the separation distance of 500m from the proposed turbine is too close. • Concern regarding the lack of publicity. • Impact on wildlife.

RELEVANT PLANNING HISTORY

The following previous applications have been received on the application site:-

W/26149 Two 50kw wind turbines Full planning permission 16 July 2013

W/29252 Single turbine (50kw) Appeal dismissed 2nd September 2015

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APPRAISAL

The application was reported to Planning Committee on 15 th December 2015. Members of the Committee unanimously agreed to a site visit following a request by the local member. The report has been updated in response to the local member’s comments on the report’s assessment of economic benefits and landscape and visual impacts. The report has been amended following further details received in respect of noise impact. Details of the formal responses of the Council’s Landscape Officer and Head of Transport and Engineering have also been included. Finally a further refusal reason has been added given that the proposal is also contrary to the Council’s Farm Diversification policy.

THE SITE

The application site is an area of agricultural land located to the north west of settlement of Hermon and to the south of Cmwpengriag. The site is located off the western flank of the B4333 Road leading from Cynwyl Elfed to Newcastle Emlyn. The site is located outside of development limits in the open countryside. The nearby area has a few sporadic developments generally in the form of farmsteads. The land slopes from the road to the site. The area has no specific designation and is considered to be located in open countryside. The holding relating to the application is known as Triol Bach. The turbine is located to the western end of the land within the applicant’s ownership. The closest property to the turbine (non-financial interest) is Maes y Pwll located to south west approximately 497m from the turbine.

Planning permission was refused by the Council (W/29252) and later dismissed at appeal in September 2015 (APP/M6825/A/15/3005586) for a turbine on the applicant’s land some 500m to the south east of the current application site. The appointed Inspector agreed with the Council’s original refusal reasons on cumulative landscape and visual grounds.

Approximately 182m and 211m respectively from the application site and on the applicant’s land permission was given for two turbine in July 2013 (W/26149 refers). These are now operational and measure 45m in height and have a rating of 50kw each. To the north west of these operational turbine (approximately 190m-204m) is the location of a consented single turbine pertaining to the Ysgubor Gwair holding. This is not currently operational but once erected will measure approximately 45m

A further operational turbine is located approximately 1.18km to the south east of the application site at Clynmaenllwyd farm (Application Number W/26298 refers). This measures approximately 34.5m to blade tip and has an installed capacity of 50kw.

THE PROPOSAL

The application seeks full planning permission for the construction of a single wind turbine on the Triol Bach holding. The turbine would measure 36.6m to hub and would have 3 x 11.8m blades, creating a maximum height of 48.4m to the tip of the blades at their highest point. The turbine would have a 23.5m blade diameter. The previously refused turbine was 2m shorter in term of blade tip height and had a smaller blade diameter of 19.2m. The current proposal has a blade diameter some 4m longer. The turbine will be sited approximately 600m to the north west of the complex of farm buildings associated with the holding.

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The turbine will have an installed generating capacity of 90kw. The application states that the turbine would generate energy for the holding with excess energy feeding back to the national grid. In the supporting documents it is apparent that the turbine is required to generate electricity for the farm’s ongoing milking enterprise (paras. 7.4 – 7.6, Design and Access Statement). The applicant considers that this will reduce energy bills and increase income streams that strengthen the viability of the business. Any excess energy produced by the turbine will be sold to the local network operator.

The proposed turbine is the Endurance E-4660. It has fibreglass/epoxy blades in white, with the nacelle being painted, galvanised, welded, steel in white, with a painted, galvanised steel sectional welded tubular mast also being white. The application states visually the turbines are smooth and sleek with a non-industrial look mitigating many negative visual impacts some associated with larger scale wind farm installations. The transformer would be located in existing buildings at the main part of the holding with cabling running from there to the site.

The proposal would involve the construction of a concrete foundation on which the turbine mast will be mounted. It also involves the laying of underground cabling between the turbine and the farm complex and grid. The base for the turbine would measure 10m by 10m.

Excavations for the foundation and cable trenches will be carried out by a small, tracked mini-digger. The turbine would be delivered to site on a flat bed articulated lorry. One crane is used to construct the turbine. The construction of the turbine would involve a small number of HGV movements for the concrete which will be the most intensive aspect of the delivery. No new permanent access track is shown as being required as an existing track will be utilised for delivery of the turbine components.

The application has been accompanied by a suite of documentations and plans that include: a planning, design and access statement, a landscape and visual assessment containing wire lines, photomontages and Zone of Theoretical Visibility (ZTV), cumulative assessment, a noise assessment, and an ecological assessment,

PLANNING POLICY

Proposals for wind turbines must comply with the criteria of Policy RE2 (Local Community and Small Scale Wind Farms) of the Carmarthenshire Local Development Plan (LDP) (December 2014). Proposals will be permitted provided the development will: not have an unacceptable impact upon the visual amenity or landscape character through: the number, scale, size, design and siting of turbines and associated infrastructure; the development will not have an unacceptable cumulative impact in relation to existing wind turbines and other renewable energy installations and those which have permission; the siting, design, layout and materials used should be sympathetic to the characteristics of the landform, contours and existing features of the landscape; the development would not cause demonstrable harm to statutorily protected species, and habitats and species identified in the Local Biodiversity Action Plan; turbines and their associated structures will not be sited will not be sited in, or impact upon archaeological resources, the setting and integrity of Conservation Areas, Listed Buildings, or other areas of historical value; Proposals will not cause an unreasonable risk or nuisance to, and impact upon the amenities of,, nearby residents or other members of the public; No loss of public accessibility to the area, and existing bridleways and footpaths will be safeguarded from development with no permitted loss of their length and quality; Turbines and associated infrastructure will, at the end of

Tudalen 8 the operational life of the facility, be removed and an appropriate land restoration and aftercare scheme agreed; The development will not result in significant harm to the safety or amenity of sensitive receptors and will not have an unacceptable impact on roads, rail or aviation safety; the development will not result in unacceptable electromagnetic interference to communications installations; radar or air traffic control systems; emergency services communications, or other telecommunications systems.

At the more strategic policy level Policy SP11 (Renewable Energy and Energy Efficiency) of the LDP states that “development proposals which incorporate energy efficiency measures and renewable energy production technologies will be supported in areas where the environmental and cumulative impacts can be addressed satisfactorily. Such developments will not cause demonstrable harm to residential amenity and will be acceptable within the landscape. Each proposal will be assessed on a case by case basis”.

National Policy is provided by Planning Policy Wales Edition 6 February 2014 as follows:-

12.8 Sustainable Energy

12.8.1 The UK is subject to the requirements of the EU Renewable Energy Directive. These include a UK target of 15% of energy demand from renewables by 2020. The UK Renewable Energy Roadmap sets the path for the delivery of these targets, promoting renewable energy to reduce global warming and to secure future energy supplies. The Welsh Government is committed to playing its part by delivering an energy programme which contributes to reducing carbon emissions as part of our approach to tackling climate change (see 4.5) whilst enhancing the economic, social and environmental wellbeing of the people and communities of Wales in order to achieve a better quality of life for our own and future generations. This is outlined in the Welsh Government’s Energy Policy Statement Energy Wales: A Low Carbon Transition (2012).

12.8.2 Planning policy at all levels should facilitate delivery of both the ambition set out in Energy Wales: A Low Carbon Transition and UK and European targets on renewable energy. The Renewable Energy Directive contains specific obligations to provide guidance to facilitate effective consideration of renewable energy sources, high-efficiency technologies and district heating and cooling in the context of development of industrial or residential areas, and (from 1 January 2012) to ensure that new public buildings, and existing public buildings that are subject to major renovation fulfil an exemplary role in the context of the Directive. The issues at the heart of these duties are an established focus of planning policy in Wales, and in this context both local planning authorities and developers should have regard in particular to the guidance contained in Technical Advice Note 8: Planning for Renewable Energy, TAN22 and Planning for Renewable Energy – A Toolkit for Planners. The Welsh Government will however consider the preparation of further targeted guidance where appropriate.

12.8.6 The Welsh Government’s aim is to secure an appropriate mix of energy provision for Wales which maximises benefits to our economy and communities, whilst minimising potential environmental and social impacts. This forms part of the Welsh Government’s aim to secure the strongest economic development policies to underpin growth and prosperity in Wales recognising the importance of clean

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energy and the efficient use of natural resources, both as an economic driver and a commitment to sustainable development.

12.8.9 Local planning authorities should facilitate the development of all forms of renewable and low carbon energy to move towards a low carbon economy (see 4.4.3) to help to tackle the causes of climate change (see 4.7.3). Specifically, they should make positive provision by:

• considering the contribution that their area can make towards developing and facilitating renewable and low carbon energy, and ensuring that development plan policies enable this contribution to be delivered;

• ensuring that development management decisions are consistent with national and international climate change obligations, including contributions to renewable energy targets and aspirations;

• recognising the environmental, economic and social opportunities that the use of renewable energy resources can make to planning for sustainability (see Chapter 4); and

• ensuring that all new publicly financed or supported buildings set exemplary standards

12.8.10 At the same time, local planning authorities should:

• ensure that international and national statutory obligations to protect designated areas, species and habitats and the historic environment are observed;

• ensure that mitigation measures are required for potential detrimental effects on local communities whilst ensuring that the potential impact on economic viability is given full consideration; and

• encourage the optimisation of renewable and low carbon energy in new development to facilitate the move towards zero carbon buildings (see 4.11 and 4.12).

12.10.1 In determining applications for renewable and low carbon energy development and associated infrastructure local planning authorities should take into account:

• the contribution a proposal will play in meeting identified national28, UK and European targets and potential for renewable energy, including the contribution to cutting greenhouse gas emissions;

• the wider environmental, social and economic benefits and opportunities from renewable and low carbon energy development;

• the impact on the natural heritage (see 5.5), the Coast (see 5.6) and the Historic Environment (see 6.5);

• the need to minimise impacts on local communities to safeguard quality of life for existing and future generations; Tudalen 10

• ways to avoid, mitigate or compensate identified adverse impacts;

• the impacts of climate change on the location, design, build and operation of renewable and low carbon energy development. In doing so consider whether measures to adapt to climate change impacts give rise to additional impacts (see 4.5);

• grid connection issues where renewable (electricity) energy developments are proposed; and

• the capacity of and effects on the transportation network relating to the construction and operation of the proposal

Consideration is also given to Planning Policy Wales - Technical Advice Note (TAN) 8 - Planning for Renewable Energy. Para 2.12 states -The Assembly Government expects local planning authorities to encourage, via their development plan policies and when considering individual planning applications, smaller community based wind farm schemes (generally less than 5MW).

The proposal is considered by the developer in his supporting statement as a means of supporting the farm enterprise, therefore Policy EMP4 is relevant. This policy states that proposals for farm diversification projects will be permitted, subject to a number of criteria. Those which are of relevance to this application are as follows: a)“It is subordinate to, compatible with and supports the continued operation of the agricultural activity of the existing working farm; b) It is of a scale and nature appropriate to the existing farm operation; c) The scale and nature of the activity is compatible with its accessibility to public transport and the need for local highway improvements; and e) It would not have an adverse impact on the character, setting and appearance of the area and the surrounding landscape and where appropriate, townscape.”

The following sections will assess the proposal against specific material planning considerations and will be followed by a balancing exercise which will conclude whether the proposal is acceptable or not at this location.

Landscape and Visual

The Council’s landscape officer has been consulted on this application and a summary of his response is provided below:

Physical landscape impacts

Physical landscape impacts are caused by direct effects arising from construction of the proposed development. Impacts may arise from the removal, reduction in scale or changes to existing landscape elements. Impacts may also arise from the effects of excavation, filling and disturbance of existing ground through construction phase management and final proposals for excavated material.

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Observations and Advice

It is considered that the scale of the turbine model is such that, potential impacts to existing landscape elements and features may be expected to challenge the relevant policy objectives of the Carmarthenshire County Council LDP [December 2014].

Landscape character impacts

Indirect impacts to landscape character are caused by the physical presence of the proposed development in views, and the resultant effects upon the existing landscape character.

Wind turbine development inevitably results in changes to local landscape character through the introduction of new, manmade moving landscape elements. The significance of these changes in terms of magnitude and extent of effect have been assessed through appraisal of the submitted information, consideration of LANDMAP and landscape designations, and site visit.

Observations

i) It is advised that the proposed scheme will have an adverse impact upon the landscape character of the immediate area. ii] Whilst it is acknowledged that the individual effect of the proposed turbine is not considered to result in significant additional impact, it is considered that the combined cumulative effects with the other Operational, Consented and in-Planning (OCP) developments particularly the two operational turbines at Triol Bach [W/26149] and the individual turbine at Land at Ysgubor Gwair [W/29340] would create a cluster of four small scale turbines which would challenge the capacity of the receiving landscape, such that the immediate landscape will start to become characterised by wind turbine development. It is considered that introduction of the proposed turbine would result in wind turbines forming a key characteristic of the local landscape, hence changing the landscape to that of a ‘landscape character area with wind turbines’

It is advised that the DMO consider the proposed scheme in the context of the implicit objective of TAN 8 [Annex D; para 8.4]; to maintain the landscape character in landscapes outside the strategic search areas; and to avoid significant change in landscape character from wind turbine development.

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Whilst it is acknowledged that the proposed turbine is located at a closer spacing to three other OCP turbines of a similar model, than the appeal site, it is considered that the Planning Inspector’s observations particularly with regard to ‘the capacity of the immediate landscape’ be fully addressed as a material consideration in determination of the current application.

Advice

In this case, it is advised that the location and scale of the turbine model and its relation to topography, other OCP development, and the predicted magnitude of effect in relation to the sensitivity of the receiving landscape, are such that the significance of impacts to landscape character, or areas designated for their landscape value, are considered to represent a significant challenge to the relevant policy objectives of the Carmarthenshire County Council LDP [December 2014]. Impacts are of a significance to constitute a justifiable reason for refusal on the grounds of impacts to landscape character in the context of the planning balance and should be fully addressed by the DMO against the benefits of the application. i] Impacts to residential visual amenity Address points of residential properties within an initial search area of 10x the blade tip height of the proposed turbine location have been identified through review of CCC MAPInfo data. A desk top appraisal using aerial photography and broad scale site visit observations from publicly accessible points near to the identified properties has been undertaken. Properties at a separation greater than the initial search area with particularly open views and direct orientation are included in the appraisal if identified through site visit observation. Individual properties have not been visited. Observations The appraisal of impacts to residential visual amenity has addressed the following: - - orientation of the main fenestrated elevations of identified properties in relation to the proposed turbine development. - location of primary amenity space associated with the property in relation to the proposed turbine development. Primary amenity space includes evident garden areas, and any conservatories or external decking areas. - presence of close range screening by vegetation or landform in the direction of the proposed development . - extent of other available views from the property and primary amenity space - relative elevation between the turbine development and residential properties

Advice

It is advised that the location of the scheme, scale of the turbine model and its relation to the topography; other OCP development; and the proximity and orientation in relation to the identified properties, and any intervening screening elements, is such that the proposal is considered to result in impacts to residential visual amenity at Maespwll, Highgate, Black Lion, Bryn Lwyd and Triol Bach.

It is acknowledged that the interpretation of relevant policy, is ultimately the responsibility of the case planning officer, as such, it is recommended that the officer fully consider the impacts to residential visual amenity as identified in the Impact Table along with any additional information submitted as part of representations by local residents in the context of the relevant policy objectives. It should be noted that although the significance of Tudalen 13

impacts upon residential visual amenity may not be considered to be against relevant policy, the significance of any identified impacts upon individual residential visual amenity should be fully considered against the benefits of the proposed scheme in the context of the planning balance.

Impacts to visual amenity from areas accessible to the public Impacts upon the visual amenity of users of publicly accessible areas have been considered through review of CCC MAPInfo data and through site visit to address impacts to publicly accessible points.

Observations and Advice In this case, it is advised that the proposed scheme will form new, manmade moving elements within some views from publicly accessible areas. The location and scale of the turbine model and its relation to the topography, other OCP development, and proximity to roads and footpaths, and other areas accessible to the public, is such that the impacts are considered to represent a significant challenge to the relevant policy objectives of the Carmarthenshire County Council LDP [December 2014]. Specifically: -

i] Users of the local public footpath network with views of the proposed development specifically PRoW routes 6/46, 6/43 and 6/45

It is advised that the proposed scheme be considered fully in the context of the appeal; decision [APP/M6825/A/15/3005586] for the initial planning application [W/29252] at Triol Bach, at a location to the south of the proposed scheme which states at para 17 that ‘There would be close up views of the proposed turbine from the public footpath that crosses the field to the west of the site and more distant views from the paths to the north and north west. Whilst I acknowledge that users of these paths will already experience views of existing turbines I find the proximity of the turbine to the path to the west would result in it being an imposing and overbearing feature to the open characteristics of this section of the path. I find the combined effect of several turbines along the route would alter the characteristics of this rural path network through an open plateau landscape to an extent that would be harmful to the overall enjoyment of the network of public rights of way in the area.’ Whilst it is acknowledged that the proposed turbine is located at a greater separation from the PRoW network than the appeal site, the combined cumulative impact with the three other OCP turbines of a similar model, is such that the Planning Inspectors observations particularly with regard to impacts to the ‘overall enjoyment of the network of public rights of way in the area’ be fully addressed as a material consideration in determination of the current application.

ii] Users of the B4333

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particularly evident and I consider that the combined effect of the turbines would be a dominating and defining feature of the landscape to those using the road and would adversely affect the visual amenities of road users’.

Whilst it is acknowledged that the proposed turbine is located at a closer spacing to three other OCP turbines of a similar model, than the appeal site, it is considered that the Planning Inspectors observations particularly with regard to ‘the combined effect of the turbines as a dominating and defining feature of the landscape to those using the road’ be fully addressed as a material consideration in determination of the current application.

Impacts are of a significance to constitute a justifiable reason for refusal on the grounds of impacts to landscape character in the context of the planning balance and should be fully addressed by the DMO against the benefits of the application.

Based on the above advice from the Council’s Landscape Officer and the conclusions drawn by the Planning Inspector that presided over the previous turbine application to south west, an assessment of the proposal’s impact upon landscape character and visual amenity will now follow:

Despite the differences in the turbine’s amended position being some 500m to the north west it is considered that the proposal will still result in unacceptable impacts which are contrary to local planning policy. It is acknowledged that the proposed turbine will form a closer relationship with the two operational turbines and consented turbine at Ysgubor Gwair, thus forming a more cohesive cluster than the previously refused site location (W/29252), however, the proposal will introduce an additional turbine into the landscape to the extent that its rural character will be eroded further. This proposal will lead to the area becoming characterised by turbines. This was noted by the Planning Inspector that dealt with the previously refused turbine to the south west whereby it would exceed the capacity of the immediate landscape to absorb further turbines thus fundamentally altering its character (para 16 of Inspector’s decision letter refers):

16. Whilst acknowledging the presence of other existing and consented turbines, I do not consider that at present their scale and spacing make them a defining characteristic of the landscape. However, the addition of a further turbine approximately mid-way between those existing and consented would increase the number of turbines in a relatively small area and would result in a number of them being viewed together. I consider that the proposed turbine would change the balance and result in the scale and spacing of turbines within the area and visible from the surroundings exceeding the capacity of the immediate landscape to absorb them without fundamentally altering its character. I find this would be harmful to the character and appearance of the area.

Her conclusions infer that more turbines of the scale previously refused in this vicinity would be harmful to the character and appearance of the area. On this basis it is considered that the proposal will have an unacceptable impact upon landscape character in combination with other OCP developments.

The previously refused turbine was sited closer to an existing public footpath and due to its siting and scale the Inspector considered the proposal an imposing and overbearing feature when viewed from a section of the footpath approximately 50m away from the turbine (para 17 refers):

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17. There would be close up views of the proposed turbine from the public footpath that crosses the field to the west of the site and more distant views from the paths to the north and north west. Whilst I acknowledge that users of these paths will already experience views of existing turbines I find the proximity of the turbine to the path to the west would result in it being an imposing and overbearing feature to the open characteristics of this section of the path. I find the combined effect of several turbines along the route would alter the characteristics of this rural path network through an open plateau landscape to an extent that would be harmful to the overall enjoyment of the network of public rights of way in the area.

In the case of the current proposal, this distance from the footpath is approximately 250m away and whilst the effect from the turbine will be less imposing upon users there are public rights of way encircling the proposed turbine to the south, west and north and as such the proposal in combination with operational and consented turbines in the immediate vicinity will have an unacceptable adverse cumulative impact upon the open plateau landscape the footpath network crosses to the detriment of the visual amenity of its users.

In terms of the impact upon residential visual amenity the Inspector considered that properties along the B4333, in particular those at elevated levels to the site (Black Lion and Brynllwyd) would have direct views of the W/29252 turbine. Her concerns are referred to below:

18. The turbine would also be visible from a number of residential properties in the vicinity. I am satisfied that views from properties closer to the site including Dychwelfa that is currently under construction, would be partially screened by the topography and screening and I do not find the proposed turbine would be harmful to the visual amenities of occupants within close proximity to the proposal. Nonetheless, properties on the B4333, and in particular Black Lion Farm and Brynllwyd are situated at an elevated level to the site and have direct views towards the site and the surroundings that already contains several turbines. The additional turbine would add a further moving dimension into this open landscape in direct view of these properties and their views would become dominated by wind turbines. I find this would be harmful to their visual amenities.

The current proposal would be within the same field of vision to that previously refused when seen from these dwellings, and although the proposal will appear to form part of a larger grouping, it will nevertheless introduce a further turbine into the view. Therefore it is considered that the outlook from these properties would become dominated by turbines to the extent the visual amenities of their occupiers will be unacceptably harmed.

Moreover there is a suggestion in the Inspector’s conclusions that a further turbine of similar scale in the vicinity of this existing grouping of operational and consented turbine developments would have unacceptable cumulative visual impacts.

The previously refused turbine was adjudged by the Inspector to have a harmful impact visually upon users of the B4333 heading north from Hermon (para 19 refers):

19.The turbines would also be visible to receptors using the section of the B4333 that passes the site. Whilst I acknowledge that these views are screened to a certain extent by hedgerows and are therefore intermittent, there would be clear views of the proposed turbine and those already existing and consented when travelling along sections of the road. Views when exiting Hermon in a northerly direction are particularly evident and I

Tudalen 16 consider that the combined effect of the turbines would be a dominating and defining feature of the landscape to those using the road and would adversely affect the visual amenities of road users.

The effect of the proposed turbine located in a marginally different location when viewed from the south will have a similar impact to that described by the Inspector, if not more harmful on account of the greater blade diameter in this instance. Therefore it is considered that the proposal will have unacceptable visual impacts upon the amenity of users of the B4333.

Based on the above assessment it is concluded that the proposal will be unacceptable and in conflict with Policies RE2, EMP4 and SP11 of the Carmarthenshire LDP.

Ecology

The site consists of improved grassland bounded by hedgerows, as confirmed by the habitat survey. An area of improved grassland will be permanently lost, although the site is considered to be of negligible ecological significance. The LPA’s Planning Ecologist has not responded to date and given that there could be implications upon bat populations in the area it is considered the position on ecological impact cannot be concluded until a response has been received.

Noise

In terms of the potential noise impact, the submitted application has been accompanied by a noise assessment which includes predicted noise levels that would be experienced at adjacent properties. These levels are based on a report which has also been submitted detailing the noise emissions however these relate to a different turbine model. Further information has been requested from the applicant. This has now been received and is currently being assessed by the Council’s Environmental Health Section.

Transportation and Highway Safety

The applicant has submitted details of the proposed access for the construction phase of the development. Given the scale of the proposal, deliveries of components are not considered excessive or likely to cause unacceptable disruption along the local road network. No off site highway widening or improvement works are proposed for the delivery of turbine components and materials. Furthermore it is considered that the vehicles accessing the site and their associated movements will be similar to those involved with existing farm deliveries. On this basis it is not considered that the proposal will give rise to any significant highway safety concerns. The Head of Transport has not responded and raised no adverse comments regarding the proposal’s impact upon highway safety.

Historic Environment and Cultural Heritage

Cadw are satisfied that the turbine maintains adequate distance from the nearest SAMs so as to ensure no significant adverse impacts on their setting. Dyfed Archaeological Trust, the Council’s advisers on archaeological matters have been consulted but have not responded to date.

Tudalen 17

Other Issues

Under certain combinations of geographical position and time of day, the sun may pass behind the rotors of a wind turbine and cast a shadow over neighbouring properties. When the blades rotate, the shadow flicks on and off; the effect is known as 'shadow flicker'. There is no specific guidance in Wales in relation to shadow flicker distances and the distance at which it would have an impact. Annex C of TAN8 states “the problem is seasonal and only lasts for a few hours per day, but needs to be investigated where any potential exists. Developers should provide an analysis of the potential for shadow flicker impacting upon any nearby properties”. However TAN45 “Renewable Energy Technologies” 2002 refers to the issue of shadow flicker. This state’s “In most cases however, where separation is provided between wind turbines and nearby dwellings (as a general rule 10 rotor diameters), "shadow flicker" should not be a problem”. In relation to shadow flicker there are no properties within 130 degrees of the turbines within the 10 x blade diameter distance.

The Ministry of Defence have raised no objection to the proposed turbine from a radar and aviation perspective, although will expect to be kept informed by the applicant in the event that the turbine’s location and dimension change. Other bodies with aviation interest (CAA and NATS) have raised no objections to the proposal. No objections have been raised by telecommunication companies operating in the area.

The applicant’s Deign and Access Statement describes how the proposed turbine will feed the electricity it produces directly to the farm for use by the dairy operation. Any excess electricity will be sold back to the grid. The applicant also considers that this will in turn help to ensure the long term future of the farm unit for future generations and enable growth and diversity in the business with consequent opportunities for additional employment.

The above economic justification is noted, however, it has not been backed up by figures which detail the financial benefit of the electricity from the turbine to the farm enterprise. Notwithstanding this it is considered that the proposed turbine is sited at an unacceptable location given its proximity to other operational and consented turbines and will have an adverse landscape and visual impact at this location. This impact overrides the economic benefit that the proposed turbine will have in addition to the renewable energy benefits. On this basis the proposal is contrary to Policies RE2 and SP11 of the LDP.

Furthermore, whilst it is accepted that the proposed turbine will have an economic benefit on the holding it is not considered that the proposal meets the criteria set out in the Council’s Farm diversification policy (Policy EMP4), namely criteria e) “ It would not have an adverse impact on the character, setting and appearance of the area and the surrounding landscape and where appropriate, townscape.”

THIRD PARTY REPRESENTATIONS

The application has been advertised on site by the posting of a site notice. Five letters of objection have been submitted raising concerns regarding landscape and visual impacts as well as cumulative impact with other approved and in-planning turbines and impact on wildlife. These concerns have been addressed in the main body of the report.

Impact on wildlife will be commented upon following the response of the Council’s Planning Ecologist.

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Regarding the noise impact objection this cannot be dealt with at present as the additional information submitted by the applicant will need to be assessed by the Council’s Public Protection Section. The issue of noise will be addressed following a response from Public Protection officers.

CONCLUSION In conclusion and having regard to all planning policies and material considerations, the proposed scheme will form a new, manmade moving element within some views from residential properties and associated amenity space and from roads/footpaths in the area. The location of the scheme, scale of the turbine model and its relation to the topography and other OCP development; and the proximity and orientation in relation to the properties is such that the proposal will result in significant adverse impacts upon the landscape and visual amenities of the area. The proposal’s positive contribution towards national renewable energy targets / aspirations and reducing carbon emissions, along with the lack of objection in relation to highways, cultural heritage and radar/telecommunications is not considered sufficient to outweigh the impacts described in the report. Furthermore any benefits to the agricultural enterprise underway at the holding will not override the harm incurred upon the landscape and visual amenities of the area. If responses from the Council’s Planning Ecologist and Environmental Health officers raise concerns regarding the proposal’s impact upon biodiversity and residential amenity, further refusal reasons will be added to those listed below. Refusal is recommended.

RECOMMENDATION – REFUSAL

REASONS

1. The proposed development is contrary to Policy RE2 of the Carmarthenshire Local Development Plan:

Policy RE2 Local, Community and Small Wind Farms Local, Community and Small wind farms or individual turbines will be permitted provided the following criteria can be met in full:

a) The development will not have an unacceptable impact on visual amenity or landscape character through: the number, scale, size, design and siting of turbines and associated infrastructure; b) The development will not have an unacceptable cumulative impact in relation to existing wind turbines and other renewable energy installations and those which have permission; c) The siting, design, layout and materials used should be sympathetic to the characteristics of the land-form, contours and existing features of the landscape; d) The development would not cause demonstrable harm to statutorily protected species, and habitats and species identified in the Local Biodiversity Action Plan; e) Turbines and their associated structures will not be sited in, or impact upon archaeological resources, the setting and integrity of Conservation Areas, Listed Buildings or other areas of historical value; f) Proposals will not cause an unreasonable risk or nuisance to, and impact upon the amenities of, nearby residents or other members of the public;

Tudalen 19

g) No loss of public accessibility to the area, and existing bridleways and footpaths will be safeguarded from development with no permanent loss to their length and quality; h) Turbines and associated infrastructure will, at the end of the operational life of the facility, be removed and an appropriate land restoration and aftercare scheme agreed; i) The development will not result in significant harm to the safety or amenity of sensitive receptors and will not have an unacceptable impact on roads, rail or aviation safety; j) The development will not result in unacceptable electromagnetic interference to communications installations; radar or air traffic control systems; emergency services communications; or other telecommunication systems.

• In that The proposed development in combination with other approved, consented and ‘in planning’ wind turbine developments in the area will introduce further man made elements into the immediate and surrounding landscape to the extent that that the landscape character will become that in which wind turbines start to form key characteristics in the landscape, resulting in significant adverse impacts upon that landscape.

• In that the location and scale of the turbine scheme and its relationship with the topography, other operational, approved and in planning development; and proximity to roads and footpaths, and other areas accessible to the public, is such that the proposal represents an unacceptable distracting man made element in the landscape leading to significant adverse impacts upon the visual amenities of members of the public.

• In that the location and scale of the turbine and its relationship with the topography and other operational, approved and in planning development is such that the proposal represents an unacceptable distracting man made element in the landscape that will have a significant adverse visual impact upon the amenities of neighbouring residential occupiers when viewed from habitable room windows and amenity areas.

• On balance the scheme’s renewable energy benefits will not outweigh the harm caused to any of the interests identified above.

2. The proposed development is contrary to Policy SP11 of the Carmarthenshire Local Development Plan

SP11 Renewable Energy & Energy Efficiency

Development proposals which incorporate energy efficiency measures and renewable energy production technologies will be supported in areas where the environmental and cumulative impacts can be addressed satisfactorily. Such developments will not cause demonstrable harm to residential amenity and will be acceptable within the landscape. Each proposal will be assessed on a case by case basis.

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Large scale wind farms will only be permitted within Strategic Search Areas.

• In that the proposed development in combination with other approved, consented and ‘in planning’ wind turbine developments in the area will introduce further man made elements into the immediate and surrounding landscape to the extent that that the landscape character will become that in which wind turbines start to form key characteristics in the landscape, resulting in significant adverse impacts upon that landscape.

• In that there is insufficient survey data regarding noise impact from the proposed turbine upon surrounding neighbouring occupiers and therefore this impact cannot be adequately assessed.

• On balance the scheme’s renewable energy benefits will not outweigh the harm caused to any of the interests identified above.

3. The proposed development is contrary to Policy EMP4 of the Carmarthenshire Local Development Plan:

Policy EMP4 Farm Diversification

a) It is subordinate to, compatible with and supports the continued operation of the agricultural activity of the existing working farm; b) It is of a scale and nature appropriate to the existing farm operation; c) The scale and nature of the activity is compatible with its accessibility to public transport and the need for local highway improvements; and d) The scale and scope of any retail use (where planning permission is required) would not have an adverse impact on the vitality and viability of retail facilities in nearby settlements, or would undermine the retail hierarchy (see policy RT1); e) It would not have an adverse impact on the character, setting and appearance of the area and the surrounding landscape and where appropriate, townscape.

Tudalen 21

In that:

• The proposed development in combination with other approved, consented and ‘in planning’ wind turbine developments in the area will introduce further man made elements into the immediate and surrounding landscape to the extent that that the landscape character will become that in which wind turbines start to form key characteristics in the landscape, resulting in significant adverse impacts upon that landscape.

Tudalen 22 Eitem Rhif 3.2

Application No W/33032

Application Type Full Planning

Proposal & A SMALL ENVIRONMENTALY FRIENDLY CAMPING POD SITE, Location INCLUDING FOUR CAMPING PODS AND ONE TENT PITCH, ONE POD WITH SEPARATE MALE AND FEMALE TOILET AND SHOWER, ONE UNISEX TOILET AND KITCHEN AND BARBECUE AREA AT WEST WALES CAMPING PODS, PLASBACH, HENLLAN AMGOED, WHITLAND, SA34 0SE

Applicant(s) MRS ELIZABETH HERMITAGE, PLASBACH, HENLLAN AMGOED, WHITLAND, SA34 0SE

Case Officer Stuart Willis

Ward Whitland

Date of validation 02/12/2015

CONSULTATIONS

Head of Transport – Has not responded to date

Henllanfallteg Community Council – Has responded stating it has no objections as this application is already a successful business which is helping to support the community.

Local Member - County Councillor S Allen is a substitute member of the Planning Committee has requested that this application be presented to the Planning Committee as “there is a lot of local support for the business and it has been an anomaly when the camping pods were first introduced since they did not fit into the usual categories of camping or caravans”.

Neighbours/Public - The application has been publicised by the posting of a Site Notice with no responses having been received as a result

RELEVANT PLANNING HISTORY

W/11644 Proposed two storey extension Full planning permission granted 4 January 2006

D4/23896 Change of Use to a dog breeding establishment Full planning permission granted 15 October 1993

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APPRAISAL

The application is as a result of action taken by the Planning Enforcement Team.

THE SITE

The application site consists of a field at land associated with a property known as Plas Bach. The site is located off a track leading south east from the county road. The application field slopes to the south east and is located approximately 75m from the farm house and complex of buildings. The site is located outside of development limits. The nearest settlements with limits to the application site are Llanboidy (3.6km), Cwmfelinboeth (2.9km) and Llanfallteg (2.9km).

The site is located between Llanfallteg and Llanboidy. The use is already in place and the application is following action taken by the Planning Enforcement Team.

THE PROPOSAL

The proposal is for the proposed use of the agricultural field as a small environmentally friendly camping pod site, including four camping pods and one tent pitch, one pod with separate male and female toilet and shower, one unisex toilet and kitchen and barbecue area

The pods and other structures are located along the north eastern and north western boundary of the site. The access track runs along the north western boundary of the site. There are 5 pods, 4 of which are used for accommodation with the other being the toilet and shower facilities. They each measure 2.83m by 4.75m. There are electricity points for the pods and a gravelled parking area adjacent to them. There are other wooden structures in the field used for storage and as a cover for the barbeque area. In terms of the pods themselves they state that they are temporary structures and were delivered in one piece and placed on the ground.

The details with the application indicate that the site is a 50 acre farm. The supporting information also makes reference to what the applicant sees as negligible increase in traffic. It is stated that the holding is a working farm with sheep, beef cattle and goats. They also refer to an equine business at the site and that the camping pods supplement the income from the farm as a way of farm diversification. It is stated that the camping pods have made the “struggling farm into a thriving family business which will ensure the long term survival of the agricultural use” of the farm. The submission indicates that the pods have been at the site and the business operated since 2012 and that they have become increasingly popular. They also refer to the visitors spending money in local businesses such as nearby public houses. Local facilities in Whitland and train and bus connections at other settlements are referred to. Details of the pods themselves and the facilities they include such as fridges are provided.

Excerpts from travel review websites have also been provided.

The submission refers to pre-application advice in 2011 where the applicants feel it was advised that planning permission was not required for the pods.

Tudalen 24

The application refers to the pods being made from sustainable timber and insulated with sheep’s wool. The composting outlets are also put forward to support sustainability. They comment that the site is dependant on the attributes of the site and that to counter the distance form settlements facilities are provided such as a fridge in the pods to reduce the need for travelling.

The supporting information refers to visitors coming to explore Carmarthenshire and West Wales but that some also stay on site reducing the need to use a car. Walking and cycling by visitors is also said to reduce the use of vehicles. A pick up service is also offered to guests with pick up from Whitland train station which they say has been “used on a few occasions”.

The access track is described as existing however this appears to have been added in recent years. There is no record of planning permission or an agricultural notification having been submitted for it.

PLANNING POLICIES

Policy GP1 Sustainability and High Quality Design. This states that development proposals will be permitted where they accord with a number of criteria including the following, it conforms with and enhances the character and appearance of the site, building or area in terms of siting, appearance, scale, height, massing, elevation treatment, and detailing, utilises materials appropriate to the area within which it is located; it retains, and where appropriate incorporates important local features (including buildings, amenity areas, spaces, trees, woodlands and hedgerows) and ensures the use of good quality hard and soft landscaping and embraces opportunities to enhance biodiversity and ecological connectivity; an appropriate access exists or can be provided which does not give rise to any parking or highway safety concerns on the site or within the locality

Policy EQ4 Biodiversity The policy states that proposals for development which have an adverse impact on priority species, habitats and features of recognised principal importance to the conservation of biodiversity and nature conservation, (namely those protected by Section 42 of the Natural Environment and Rural Communities (NERC) Act 2006 and UK and Local BAP habitats and species and other than sites and species protected under European or UK legislation) will not be permitted, except where it can be demonstrated that the impacts can be satisfactorily mitigated, acceptably minimised or appropriately managed to include net enhancements; there are exceptional circumstances where the reasons for the development or land use change clearly outweighs the need to safeguard the biodiversity and nature conservation interests of the site and where alternative habitat provision can be made in order to maintain and enhance local biodiversity.

Policy TR3 Highways in Developments - Design Considerations The policy requires the design and layout of all development proposals to, where appropriate, to include an integrated network of convenient and safe pedestrian and cycle routes (within and from the site) which promotes the interests of pedestrians, cyclists and public transport; suitable provision for access by public transport; appropriate parking and where applicable, servicing space in accordance with required standards; an infrastructure and spaces allowing safe and easy access for those with mobility difficulties; required access standards reflective of the relevant Class of road and speed restrictions including visibility splays and design features and calming measures necessary to ensure highway

Tudalen 25

safety and the ease of movement is maintained, and where required enhanced; and provide for Sustainable Urban Drainage Systems to allow for the disposal of surface water run off from the highway.

Proposals which do not generate unacceptable levels of traffic on the surrounding road network and would not be detrimental to highway safety or cause significant harm to the amenity of residents will be permitted.

Proposals which will not result in offsite congestion in terms of parking or service provision or where the capacity of the network is sufficient to serve the development will be permitted. Developers may be required to facilitate appropriate works as part of the granting of any permission.

Policy SP1 Sustainable Places and Spaces This policy states that proposals for development will be supported where they reflect sustainable development and design principles and refers to a number examples including distributing development to sustainable locations in accordance with the settlement framework, supporting the roles and functions of the identified settlements; respecting, reflecting and, wherever possible, enhancing local character and distinctiveness; creating safe, attractive and accessible environments which contribute to people’s health and wellbeing and adhere to urban design best practice; promoting active transport infrastructure and safe and convenient sustainable access particularly through walking and cycling; utilising sustainable construction methods where feasible; improving social and economic wellbeing; and protect and enhance the area’s biodiversity value and where appropriate, seek to integrate nature conservation into new development

Policy TSM1 Static Caravan and Chalet Sites This policy states proposal for new static caravan and chalet sites will only be permitted within the Development Limits of a defined settlement (Policy SP3). Proposals for the enhancement and extension of existing static and chalet sites will only be permitted where:

a. The development will increase the vitality, sustainability and environmental quality of the site; b. It will not result in an unacceptable increase in the density of units and/or the overall scale of the site; c. It enhances the surrounding landscape and townscape; d. It provides (where appropriate) for the significant improvement of the overall quality, appearance and setting of the site.

Policy TSM2 Touring Caravan and Tent Sites This states that proposals for new touring caravan and/or tent sites, and for extensions/improvements to an existing site, will be permitted where it is directly related to an identified Growth Area, Service Centre, Local Service Centre or a Sustainable Community which exhibit appropriate services and facilities, it will not have an unacceptable adverse effect upon (and where appropriate enhances) the surrounding landscape and townscape, it will provide (where appropriate) for the significant improvement of the overall quality, appearance and setting of the site and the site will not result in an over concentration of sites within the area.

It goes on to state that proposals which include a need for ancillary structures should demonstrate that a sequential approach has been considered commencing with the re-use of existing buildings, followed by the need to construct new buildings. New buildings will

Tudalen 26 only permitted where they are appropriate in terms of their siting, need and scale. Proposals for the conversion of an existing touring caravan and/or tent site to a static caravan and/or chalet site will not be permitted unless it accords with Policy TSM1

Policy TSM3 Small Scale Tourism Development in the Open Countryside This states that proposals for small scale attractions/facilities in the open countryside; including appropriate extensions to existing facilities, will be approved where there is no suitable site available within the Development Limits of any nearby defined settlement, the site is directly related to a defined settlement, the countryside location is essential and the proposal is highly dependant on the attributes of the site, the proposal includes a supporting statement demonstrating a clear and justifiable need for the development to be located at that given location, where appropriate, the development will increase the vitality, sustainability and environmental quality of the site and there will be no adverse effects on the surrounding landscape/townscape or the setting and integrity of the historic environment.

Proposals which include a need for ancillary structures should demonstrate that a sequential approach has been considered commencing with the re-use of existing buildings, followed by the need to construct new buildings. New buildings will only permitted where they are appropriate in terms of their siting, need and scale.

Policy EMP4 Farm Diversification This policy states that proposals for farm diversification projects will be permitted where it is subordinate to, compatible with and supports the continued operation of the agricultural activity of the existing working farm, it is of a scale and nature appropriate to the existing farm operation, the scale and nature of the activity is compatible with its accessibility to public transport and the need for local highway improvements, the scale and scope of any retail use (where planning permission is required) would not have an adverse impact on the vitality and viability of retail facilities in nearby settlements, or would undermine the retail hierarchy (see policy RT1) and it would not have an adverse impact on the character, setting and appearance of the area and the surrounding landscape and where appropriate, townscape.

It goes on to state that proposals should give priority to the conversion of suitable existing buildings on the working farm. Where justified new building should be integrated with the existing working farm complex and not detrimental to the respective character and appearance of the area and surrounding landscape.

THIRD PARTY REPRESENTATIONS

There have been no adverse representations received to date and the application is presented to the Planning Committee at the request of the Local Member.

The site is already be used for camping pitches with temporary structures on site at the time of the site visit and from the submission these have been in place for several years. However there is no existing planning permission for the site. The applicant refers to pre- application advice where they feel they were informed that planning permission was not required. However the advice was that no planning permission is required where a licence from the Caravan and Camping Club is obtained. No such licence is in place for the site and therefore planning permission is required.

The pre-application advice given is repeated below

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“The site is located outside the development limits of any recognised settlement and approximately 2.3km from the nearest recognised settlement as delineated by the Carmarthenshire UDP. The site would be located to the north of the existing yard.

The proposed camping pods appear to be temporary structures however additional information would be needed in order to confirm this. The comments below are based on the assumption that they would be considered temporary structures.

The site would be considered against policies relating to touring caravans and camping sites. Policy TRS9 of the Carmarthenshire UDP relates to such proposals. This requires sites to be related to a settlement. As mentioned above the site is distant from any recognised settlement. The proposal also refers to permanent structures being required such as shower and toilet blocks. The policy states that such sites should not include any new buildings and therefore this would be a concern.

As part of the application the Authority would assess whether access arrangements at the site were appropriate and the surrounding road network could accommodate any additional traffic. Ponds are shown and it is unclear if these are existing structures. The visual impact of the proposal and its impact on ecology would also be assessed as part of the proposal. If new ponds are proposed these would also require planning permission.

If a licence is obtained from the Caravan and Camping Club then the provision of a small number of temporary accommodation facilities can be allowed without requiring planning permission. This would not include any permanent buildings or the ponds and would be dependent on the proposed structures being considered temporary .”

It is considered clear that the applicant was aware that there would be concerns with any application at that time due to the location of the site and also that further information.

The use is of a nature that can be difficult to provide within a settlement. However this does not mean that any location is appropriate. The relevant LDP, as did the equivalent policy in the UDP refers to such sites being “related” to a settlement for touring caravan and tent sites. The classification of the development was an issue raised by the Local Member. The pods on site however are not considered to fall in to the category of touring caravans or tents. They have been placed on site, do not have wheels and have remained on site for a number of years. Therefore it is considered that the assessment of them should fall under the static caravan and chalet policy TSM1. This states that such uses should only be permitted within development limits. The site is not located within any development limits. The nearest settlement to the site is some 2.9km. This is the “as the crow flies” distance and the actual distance is greater than this. Even if the development were considered to be within the tent and touring caravan policy it is not felt that it would be considered “directly related” to any settlement due to the separation and still contrary to LDP policy.

The issues of sustainability of the site were raised during pre-application discussions. It is considered relevant that the route from the site to the nearest settlement, services and facilities is along narrow country lanes. There are no dedicated pedestrian facilities and limited visibility for vehicles to see pedestrians along parts of the route. This would be likely to further discourage people from walking or cycling from the site to any settlements. The relief of the land in parts of the surrounding area would also serve to discourage more sustainable modes of transport during peoples stay at the site. The applicant has referred to a pick up service however indicated that this is not overly used. The application also

Tudalen 28 refers to people travelling away from the site during their stay. The site is some distance from a settlement and is not well served by public transport. The applicant refers to the countryside location being a key part of the attraction of the site however this could be said of numerous rural locations. As such the development is not unique and therefore could be repeated. The Local Development Plan is based on a sustainable settlement basis where the aim is to locate development in accordance with this sustainable framework distributing development to sustainable locations.

Reference is drawn to a previous appeal for a similar development in the Pembrey area. This site was located adjacent to an existing caravan site (S/15038). This site was approximately 1km from the settlement of Pembrey, closer than the current application site. Again there were no on site services or facilities. This development was for a development which was considered to fall within the touring caravan and tent policy which is less restrictive in terms of its location requirements. The Inspector considered that the site was not within easy walking distance at 1km to the settlement stating that “ whilst people may be more willing to walk further distances on holiday I do not consider that journeys for basic essentials and in periods of inclement weather can reasonably be regarded as leisure walks. In such circumstances people staying at the site would use their cars for journeys to and from the village ”. The Inspector also comments that although it was acknowledged that there would be economic benefits “ the development would be poorly related” to the settlement and that they did not consider the proposal would amount to a sustainable form of development given its location and would be contrary to national planning policy ”. As with the site referred to in the appeal there are not sufficient reasons to justify the proposal as an exception to the policies aimed at achieving sustainable forms of development. The inspector also referred to it being difficult to refuse other similar applications if that appeal had been allowed. Again here if this proposal were approved there would be likely to be similar future difficulties.

There have been some changes to policy since the previous appeal however that stance on sustainable forms of development and the location of development has not been reduced. The appeal site was also previously developed land which would have added weight towards allowing the proposal. Here the site is a Greenfield location and therefore no such additional support is given.

The applicant has made reference to the farm diversification policy in support of the development. The policy refers to a preference for the conversion of existing buildings and the site being located on the existing farm complex. This proposal would not fit with either of these. There is a need to balance the economic benefits of development against any harm it may cause. Planning Policy Wales and various Technical Advice Notes make reference to such considerations. However as stated above this is not a unique form of development and it is one that could be repeated elsewhere. The repetition of such proposals would lead to excessive sporadic developments where the LDP aims to follow a sustainable framework. It is acknowledged that the business brings benefits to the holding however it is not considered that these outweigh the harm.

The existing access to the site is used for the camping pods and is currently used for the farm. A response is awaited from the Head of Transport. If improvements are proposed then conditions could be imposed if the application were recommended for approval to require a detailed landscape design scheme for any works to the roadside hedge and to achieve any improvement required.

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The site is largely screened from near views to the north due to the relief of the land and the boundary vegetation. The site is also some distance from any settlements. The site can be viewed from some wider views to the south where the land slopes away. Permanent use is sought rather than seasonal and it appears the pods and other structures have been in place since 2012. There are ancillary structures in the form of sheds and also one of the pods as a toilet/shower facility. The fact that a site is not overly visible does not mean that the location is acceptable.

CONCLUSION

After careful consideration of the site and its surrounding environs in the context of this application, together with the representations received to date it is considered that on balance the proposal is not acceptable and does not accord with policy.

In light of the above, this application is put forward with a recommendation for refusal.

RECOMMENDATION – REFUSAL

REASONS

1 The proposal is contrary to Policy TSM1 Static Caravan and Chalet Sites of the Carmarthenshire Local Development Plan:-

Policy TSM1 Static Caravan and Chalet Sites Proposals for new static caravan and chalet sites will only be permitted within the Development Limits of a defined settlement (Policy SP3).

Proposals for the enhancement and extension of existing static and chalet sites will only be permitted where:

In that:

• The site is located outside of development limits, is not related to any settlement and is distant from settlements, services and facilities. Due to location of the site and the nature of the route between the site and the nearest settlements, services and facilities the journeys to and from the site to would heavily reliant on private transport and therefore be unsustainable.

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2 The proposal is contrary to Policy SP1 Sustainable Places and Spaces of the Carmarthenshire Local Development Plan:-

SP1 Sustainable Places and Spaces Proposals for development will be supported where they reflect sustainable development and design principles by:

a. Distributing development to sustainable locations in accordance with the settlement framework, supporting the roles and functions of the identified settlements; b. Promoting, where appropriate, the efficient use of land including previously developed sites; c. Integrating with the local community, taking account of character and amenity as well as cultural and linguistic considerations; d. Respecting, reflecting and, wherever possible, enhancing local character and distinctiveness; e. Creating safe, attractive and accessible environments which contribute to people’s health and wellbeing and adhere to urban design best practice; f. Promoting active transport infrastructure and safe and convenient sustainable access particularly through walking and cycling; g. Utilising sustainable construction methods where feasible; h. Improving social and economic wellbeing; i. Protect and enhance the area’s biodiversity value and where appropriate, seek to integrate nature conservation into new development.

In that:

• The proposal would go against the principle of distributing development to sustainable locations in accordance with the settlement framework, supporting the roles and functions of the identified settlements. The site is located outside of development limits, is not related to any settlement and is distant from settlements, services and facilities. Due to location of the site and the nature of the route between the site and the nearest settlements, services and facilities the journeys to and from the site to would heavily reliant on private transport and therefore be unsustainable.

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Tudalen 32