FULL PLANNING APPLICATION FOR EXTENSION TO EXISTING STATIC CARAVAN PARK FOR ELEVEN ADDITIONAL CHALETS AT TAN Y BRYN CARAVAN PARK, BRYN PYDEW ROAD, BRYN PYDEW, LL 31 9JH.

Design and Access Supporting Statement

Peter Jones-Hughes MRTPI;MIHBC. 9/26/2016

This statement is required in accordance with Planning Regulations to support applications. The contents assist in identifying the primary planning issues of the proposal and the site and explain the development of the design of proposals for an extension to the existing static caravan park and how landscape and other planning interests are to be safeguarded.

Contents

Page 3 - Background

Page 4- Introduction

Page 5 - The Proposals

Page 6- Planning History

Page 6 - Current Planning Policies and Guidance

Page 13 - Description of the Site and Surroundings

Page14 - Adopted Concept and Principles Applied to the Proposal

Page15 - How the Proposal Complies with the Adopted Concept, Principles and Policies

Page 15 - Character, Scale and Layout

Page 15 -Landscape Impact

Page 19 - Biodiversity Impact

Page 22 - Movement to and from the Site

Page 26 - Environmental Sustainability

Page 26 - Water Quality and Drainage

Page 26 - Archaeological Impact

Page 27 - Impact on Amenities

Page 27 - Hard Rock Reserves

Page 27 - Summary

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Background

The submission of Design and Access Statements to accompany certain planning applications became mandatory in Wales from 2009. From the 16thMarch 2016 the Town and Country Planning (General Development Management Procedure) (Wales) (Amendment) Order 2016 only requires the submission of a Design and Access Statement for major development planning applications or for proposals within some designated sites. The guidance contained in Technical Advice Note 12: Guidance on Design and Access Statements has also been followed.

Following consultations at pre-application stage with the LPA and other potential consultees this supporting statement has been prepared to appraise and assess the final proposed schemes where material planning considerations have been identified.

In this instance pre-application consultations have been carried out with:

Conwy County Borough Council Ecology, Planning - Management, Policy and Highways; Cadw; Natural Resources Wales and the Gwynedd Archaeological Trust. These discussions have indicated that the scope of the supporting statement should cover potential impacts, mitigation and enhancement measures for biodiversity, visual landscape, archaeology and highway factors.

A supporting statement is a communication tool to show how good design has been integrated into the formulation of the proposed development. The Regulations emphasise that the principle of proportionality should apply in relation to the nature and level of detail required by a DAS. The information provided in a statement should be proportional to the importance of the site/asset in question and the nature and complexity of the impacts f the proposed scheme.

The purpose of this statement is to identify potential issues arising from proposals in relation to the constraints and opportunities presented by current planning policies, conservation interests, access/movement and environmental sustainability guidelines.

In this case the appraisal has assisted in achieving an understanding of the particular landscape impact and biodiversity context of the application site and other planning considerations such as highway and access considerations. This understanding has in turn informed and influenced the design of the eventual scheme presented for Local Planning Authority (LPA) consideration.

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The proposal has been considered in relation to the Environmental Impact Assessment Regulations and current guidance contained in Welsh Circular 11/99. It is appreciated that the Local Planning authority (LPA) will undertake its own scoping opinion of the application, but the proposal and application site have been assessed and are not considered to meet the selection criteria listed in the 1999 Regulations.

Introduction

Tan y Bryn Caravan Park was established in 1972 by the Hughes family and is still a local family based business. The park was originally implemented close to the family farmstead to diversify and broaden their business and has expanded in two phases up to the present day. Although the applicant still farms the remainder of the land by keeping a small herd of cattle, he acknowledges that farming the land would not be viable without the added income provided by the caravan park.

The existing park is immaculately kept and managed and is well assimilated into the local landscape with good road links. The present caravan park is relatively tightly developed with 24 static caravans stationed within a relatively confined area next to the former Tan y Bryn farmhouse. The applicant has commissioned the application in order to create a small additional number of attractive holiday units in a much more spacious layout. This development will enable the family business to grow over the next thirty years.

The management and control of the existing caravan site has been refined over the years to maintain a high standard of environment and accommodation. This has resulted in a low turnover of unit occupiers with a settled clientele. The applicant has confirmed that one couple have leased their pitch for over 44 years. The present conditions attached to caravan unit agreements prohibit sub-letting and limit occupation of units to ten and a half months in any year is. Additionally unit owners must renew their caravans after seventeen years on site. These conditions are scrupulously applied and monitored.

The applicant plans to continue this management approach with the extended site but with an improved layout that will not adversely affect his existing visitors. The present caravan park enterprise employs one full time and one part time worker. The plan is to increase the number of people engaged in the enterprise by an additional full time employee if planning permission is granted for the proposed extension.

The present proposal is to sensitively extend the existing static caravan site with an attractive and more spacious arrangement of high quality lodge type

4 accommodation units. The number of new units proposed is less than half the number of existing statics and this represents an increase in units of approximately 45%. The density of the new lodge units will also be significantly lower than that of the existing park.

The Proposals

The application site measures about one hectare in area and the application proposal is to create a high quality eleven unit extension directly to the north east of the existing static caravan site that will sit sensitively in the local landscape. The proposed holiday units will be attractive units of contemporary design and materials. Each unit will be a maximum of 6.00 metres wide by 12.00 metres long and will provide approximately 70.00 square metres of holiday floor space.

The design, appearance and layout of the units take account of the topography of the area and viewpoints of the site. The scale of the units reflects the objective of the application to minimise the impact of the development in this distinctive local landscape. As the new holiday units will be serviced by existing park facilities no new communal buildings are proposed for the application site.

The proposed holiday accommodation units will be stationed on permeable bases that require the minimum of ground re-modelling and the proposed drive and chalet layout take advantage of the level ground between the gentle banks that generally run from east to west across the application site. The units are to be located in a much lower density arrangement with units spaced between 8.00 and 14.00 metres apart. This compares with an average separation distance of 5.00 metres for the existing caravan park.

The new access drive to serve the units will be 5.00 metre wide and will have a permeable compacted surface and will incorporate individual parking spaces for chalet occupiers. The proposed drive within the extension site has been designed to complement the contours of the land and will not require any significant ground re-modelling. From the north the access drive will be unobtrusive as it utilises the existing banks that cut across the site to obscure views.

The highway access to the proposed extension of the caravan park will be via the existing 4.00 metre wide metalled private lane of the existing caravan park to the improved junction of the Bryn Pydew Road. There are proposals to alter the junction of the access drive with the public highway by improving the visibility splay to the east when leaving the site. By incorporating this enhancement in the application proposals the junction with the highway is

5 considered to be capable of serving the traffic generated by the proposed extension.

The Movement section of this statement describes pre-application work carried out to assess the usage of the present site and a forecast of the likely future journeys if the application is approved. The low volumes of traffic using the Bryn Pydew Road at peak daily times have also been monitored.

Landscaping proposals are based upon the natural vegetation and tree cover pattern of the open countryside in the locality. Tree and other planting of indigenous species is proposed in groups to break up the visual impact of the chalets and a new hedgerow is to be planted along the north, east and elevated southern boundaries of the application site. These proposals are designed to also have a biodiversity benefit as well as landscape impact mitigation benefits.

A biodiversity statement accompanies the application and this demonstrates that the development of the application site will not harm the nature conservation interest of the site itself and its adjacent areas. The proposal also includes enhancements to the landscape within the applicant’s wider ownership that will benefit biodiversity of the locality in the future.

There are photographs of the existing caravan park and the application site in Appendix 1 of this statement.

Planning History

The farm and farmhouse at Tan y Bryn have been in existence since the nineteenth century. Early editions of the Ordnance Survey from 1893-1915 show the historic development of the farmstead. The applicant retains ownership of approximately 110 acres of land mainly to the south and east of the caravan park.

Planning permission was granted for 16 static caravan units to the immediate south of the farm house in 1972. An additional 8 static caravans were granted planning permission in 1984. The adjoining 100 acres of land comprising the applicant’s present agricultural holding is in pasture and used for low level seasonal cattle grazing by the applicant.

Current Planning Policies and Guidance

In relation to the proposal at Tan y Bryn for an extension of the existing static caravan park the Development Plan for the area comprises the adopted Conwy Local Development Plan. (LDP) The following priority issues are relevant:

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 Encouraging sustainable tourism – Priority Issue SO 7 - “There is a need to encourage and, where possible, safeguard the tourism sector, particularly in the coastal resorts, and exploit tourism potential, especially relating to the natural and built environment, in order to encourage year round tourism.”  Promoting high quality design – Priority Issue SO 9 -“A need to insist on high quality sustainable design to sustain and enhance the character of Conwy.”  Protecting and enhancing Conwy’s natural environment - Priority issue SO12 - “There is pressure on wildlife species and habitats (biodiversity) from development. Where appropriate all new development should help enhance the biodiversity resource within the Plan Area and protect natural environment designations...”

Spatial strategies on tourism, sustainable design, encouraging the strengthening and diversification of the rural economy, safeguarding the character and appearance of the countryside and ensuring the conservation of protected species and biodiversity are all relevant to the consideration of this application.

The Bryn Pydew area, which contains the application site, is within the Llandudno, Llandudno junction and Conwy Rural Development Strategy Area. Paragraph 3.10.2 states “Over the years there has been some diversification from the traditional rural activities primarily by the re-use of farm and other buildings for business purposes. This has not only helped to retain employment within rural areas but has also enabled some farms to remain operational as the diversified activity supports the farming business...... By allowing...... live/ work enterprises, including tourism, the Council aims to support the rural economy.”

The LDP also contains topic/land use-related policies that are relevant to the consideration of these planning applications:

The following LDP policies that support development management and are relevant to this proposal:

LDP Policy DP/1 states that development will only be permitted if it is demonstrated to be consistent with the following criteria:

1a) Accords to national guidelines contained in DP/6 ‘National Guidance’.

1e) Conserves or enhances the quality of biodiversity and wildlife habitats, and safeguards protected species in line with strategic policy NTE/1 - ‘The natural Environment.’

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1g) Makes efficient and effective use of resources by employing sustainable building techniques incorporating energy and water conservation measures and, wherever possible, the use of renewable energy, in line with Policy DP/3 and Strategic Policy NTE/1.

2a) Provide safe and convenient access by sustainable forms of transport.

2d) Designed to a high standard, being attractive, adaptable, accessible, safe and secure.

2f) Conserves or enhances ...... the character and quality of local landscapes and the wider countryside in line with Strategic Policy NTE/1 and CFS/1 ‘Community Facilities and Services’.

LDP Policy DP/3 is formulated to promote high quality sustainable design that protects local character and distinctiveness and responds well to its particular context. In line with this policy developments are expected to comply with six criteria, seven of which are relevant to this application proposal:

1a) Should be appropriate and enhance its locality in terms of detailed aspects such as scale and materials.

1b) Meets parking standards

1c) Meets standards of accessibility for all.

1d) Takes account of the impact of the proposal on wildlife and habitats.

2a) Enhances the local character....and open spaces.

2c) Incorporates landscaping appropriate to the scale and impact of the development.

2g) Retains and enhances features of biodiversity.

LDP Policy DP/4 re-iterates the above criteria and seeks to avoid adverse impacts upon residential amenity, traffic generation and parking, ecology and wildlife interests and landscape character and the quality of ground and surface water.

LDP Policy DP/6 requires developments to meet the relevant guidance contained in Planning Policy Wales, Technical Advice notes and Circulars.

Policy TOU/4 of the LDP is directly relevant to this proposal as it covers developments relating to chalet, caravan and camping sites. The policy makes a presumption against the development of new static sites, however proposals

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for the extension or improvement of existing sites within the RDSA will be permitted provided that the development meets the following criteria: a) Providing the site is within or adjacent to, and would form part of, an existing chalet ...... site.

b) Any increase in the number of pitches or accommodation units proposed over the plan period is small in scale, relative to the scale and extent of the existing provision within the same chalet.....site. c) The scheme would not result in an unacceptable concentration of sites or pitches at any one locality or area.

d) Suitable access can be achieved and the development does not result in an unacceptable risk to highway safety. e) Requires compliance with other criteria that seek to promote high quality holiday facilities, would not be visually obtrusive and is accompanied by a detailed landscaping scheme and a landscape impact assessment where appropriate and is also accompanied by a biodiversity statement that indicates the gains that can be achieved.

Tourism related policies in the Development Plan emphasise that the natural and built environment assets are key factors in attracting tourists. Paragraph 4.4.2.2 adds that tourism in Conwy is currently experiencing a change in demand from traditional summer family holidays to an increasing emphasis on a wider range of activities spread throughout the year. Growth areas such as marine, special and short activity holidays need quality accommodation to ensure that tourism continues to play an important role.

Paragraph 4.4.6.1 emphasises that static and caravan sites are an important offer of holiday accommodation, which can be crucial to the success of the tourism economy. “In some areas the Council will encourage landscaping schemes to improve and screen sites as well as reducing density. The Plan seeks to ensure proposals do not result in an over-concentration of similar uses in the locality and significant enhancement of biodiversity is achieved”.

Paragraph 4.4.6.3 refers to the need to keep strict control of new static proposals - “...... the Council also believes that, given the right location the development of small scale groups of high quality, purpose built holiday chalets can be acceptable in the rural area.”(...... if it relates to an existing facility)

Policy NTE/1 requires the conservation and enhancement of the plan area’s countryside and biodiversity interests when considering new developments. The application site is not designated for its natural/wildlife interest however

9 there are designated nature /geological sites in the vicinity. The applicant has made it clear that he wishes to enhance the biodiversity of the site and its connectivity through improved planting, landscape and management specifications and to comply with the principles contained in criteria c) and d) of policy NTE/1. The application site is classified as grade 3b agricultural land and is not subject to policies designed to safeguard the best and most versatile farm land.

Policy NTE/3 states that new development should aim at conserving and, where possible enhancing biodiversity through sensitive siting, layout and design, creating enhancing and managing habitats and natural landscapes and connectivity and integrating biodiversity measures into the development proposal: Thereby contributing towards targets in the Local Biodiversity Action Plan (LBAP) All proposals should have a biodiversity Statement detailing the impact of a development on natural/wildlife conservation interests.

Policy NTE/9 makes it clear that the Council will not give planning permission for any development where it may prejudice the quality of ground or surface water or watercourses.

The application site lies at the very south eastern fringe of the Conwy and Creuddyn Landscape of Outstanding Historic Interest as defined by Cadw/ ICOMOS. This is not a statutory designation and the impacts of larger scale proposed developments on the wider character and appearance of the landscape are normally meant to be assessed. Policy CTH/2 of the LDP states that development proposals should preserve, and where appropriate enhance historic environment assets such as outstanding historic landscapes and their settings. The small number of locations where distant views of the application site are possible have been identified. The proposal includes mitigation and enhancement planting. Details are described later in this statement.

There are no known archaeological remains within the application site and its vicinity.

Also of relevance is Policy STR/1 that requires developments to meet the Council’s adopted maximum car parking standards.

Finally the site lies in an area that is safeguarded for hard rock resources and policy MWS/6 is relevant. The application proposal as an extension to an existing static caravan park is included within a category of development that is considered to have a nil or negligible impact on the safeguarded resource.

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Planning Policy Wales (Edition 7, July 2014)[PPW]

The objectives of PPW is to achieve sustainable development and to reconcile the needs of development and conservation, securing economy, efficiency and amenity in the use of land, and protecting natural resources and the environment.

In its chapter on economic development PPW states in paragraph 7.1.3 that alongside social and environmental considerations, the planning system should support economic and employment growth within the context of sustainable development.

Paragraph 7.3.1 of PPW states that many commercial activities can be located in rural areas without causing unacceptable adverse affects. New businesses have a vital role in promoting healthy economic activity in rural areas. LPAs should encourage their growth. Paragraph 11.1.7 echoes this advice and states that “.... (tourist related development) ...... should be sympathetic in nature and scale to the local environment and to the needs of visitors and the local community.”

Paragraph 11.2.7 of the chapter on Tourism, Sport and Recreation states that planning policies should encourage the diversification of farm enterprises and other parts of the rural economy for appropriate tourism and leisure uses, subject to adequate safeguards for the character and appearance of the countryside, particularly its landscape, biodiversity and local amenity value.

Technical Advice Note 5: Nature Conservation and Planning (2009)[TAN 5} provides advice about how the land use system should contribute to protecting and enhancing biodiversity and geological conservation. The proposed development has been designed in compliance with the principles listed in section 2 of TAN 5. Lengthy pre-application discussions have been held with the County Ecologist and a comprehensive biodiversity statement has been prepared which accompanies this application.

The site and immediately adjoining land within the applicant’s ownership is not the subject of nature conservation designations and has no significant wildlife interest. Nevertheless it lies in an elevated local landscape that is attractive with woodland and grassland in the vicinity being considered to be of high potential interest. The biodiversity report has examined the existing biodiversity interest of sites within the applicant’s land holding, including the application site itself. Its conclusions support the development of this site and the application also includes measures to positively enhance the biodiversity of the locality. The resulting proposals are consequently in line with the above

11 tourism and nature conservation policies and the relevant development management criteria of the LDP.

Technical Advice Note 6: Planning for Sustainable Rural Communities defines rural enterprises as including tourism and leisure operations. Rural diversification, particularly in farming is acknowledged and encouraged. The existing caravan park is a good example of early farm diversification that has created a strong and successful rural business. The present application seeks to expand the business in a small scale sustainable manner.

Technical Advice Note 12: Design [TAN 12] - offers advice on creating high quality sustainable design in context. Understanding the site and its immediate context is the basis of achieving meaningful development solutions. Of particular relevance to this proposal is section 4 of TAN 12 which provides guidance on appraising the context of a site.

Appraisals of landscape - “should focus on its quality in terms of geology and geomorphology, vegetation and habitats, visual and sensory quality and historic and cultural quality”. (paragraph 4.11)

Technical Advice Note 13: Tourism states in paragraph 12 that - “Holiday and touring caravan parks are an important part of the self-catering holiday sector and can contribute as much to the local tourism economy as serviced holiday accommodation, whole using less land for the purpose. Holiday caravan sites can be intrusive in the landscape, particularly on the coast.” Paragraph 13 continues - “....although there is increasing demand( for caravan sites) inland. New and extended sites should be effectively screened, and planned so as not to be visually intrusive.”

TAN 23: Economic Development (2014) paragraph 3.1.1 states -

“ A wide range of economic activities may be sustainably accommodated in rural areas....”

According to TAN 23 when rural businesses expands or modernise, they may need to do so in situ. Such aspects as the economic benefit of a development should be carefully weighed by local planning authorities. If the land is not made available for the proposal local planning authorities are advised to apply the following tests to clarify and balance economic, social and environmental issues. Such aspects whether the development could be provided in a location where it would create less harm? How many jobs can the enterprise sustain and create? Would the development make a special contribution to policy objectives?

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In respect of the three above questions posed by TAN23 the answers in respect of the present proposal are all positive - The application is well related to the existing caravan park as an extension and will enhance its tourist offer whilst not causing environmental harm. In fact the proposal is designed to result in overall positive biodiversity and landscape benefit. Existing jobs will be safeguarded and there will be additional employment arising from the expansion of the tourism operation. The proposal also falls in line with priority policy objectives to encourage sustainable tourism.

Description of the Site and its Surroundings

The existing Tan y Bryn Caravan Park is located in an unobtrusive elevated site within an attractive upland landscape. The park takes advantage of an historic quarry working and as a result the caravans that are located in the existing park cannot be readily seen from the local highway network or from many more distant viewpoints to the south, east and west.

The proposed extension site is approximately rectangular in shape and is an enlargement of the existing park in a north eastern direction. Although the site is slightly elevated above most of the existing caravan park and occupies more open ground, this site is also not visible from the local roads. The extension site lies in a grassland area that is interspersed with isolated mature native trees. There are natural low grassy banks that cross the north side of the site in an east to south west alignment. The site rises gently to the crest of the Bryn Pydew hill to the south.

The biodiversity statement describes the site as part of an improved upland limestone grassland area that contains the remnants of semi-ancient broadleaved woodland. The application site and adjoining pasture grass is closely grazed. The historic landscape along the Bryn Pydew hill and its escarpments has been characterised by denser areas of broadleaved woodland as can still be seen to the south west of the site. Farming practice and clearance have resulted in the thinning of woodland belts in localities such as those in the vicinity of the application site. There are attractive carboniferous limestone outcrops nearby particularly to the south of the former quarry site that is now occupied by the caravan park.

The Bryn Pydew area is one of several low limestone hills in this part of the county that provide an attractive landscape backdrop to the key tourist destinations along the coast. Other distinctive upland areas include Bryn Euryn and Bryn y Maen to the east and south and Penrhyn Side and the Little Orme to the north. From the main road networks and lowland settlements in the wider

13 area in all directions the application site is either not visible or is at a distance that would not create a visual impact in the landscape.

Access to the site will be via a wide metalled roadway from the Bryn Pydew Road. A public footpath which is unaffected by the application proposal crosses the existing caravan park and ascends the rising land to the south of the existing caravan park in a north- south direction.

Adopted Concept and Principles Applied for the Proposals

The concept behind the application proposal is:

To create a sensitive enlarged holiday accommodation site that can provide a template for improved facilities for Tan y Bryn in the future and can be assimilated attractively into the local landscape without damaging biodiversity interests. Furthermore the proposal will meet LDP policy aspirations to enhance the natural environment and landscape quality of the local area without causing other planning issues.

The following principles have been applied to the evolution of the design of the application scheme:

1. To create an up to date and attractive holiday facility that improves the current holiday accommodation offered by the park. 2. To create a proposed layout for units that will be of high design quality and will look unobtrusive in the landscape. 3. To formulate a less densely arranged layout with attractive planting/landscaping that will help to make the development blend into the existing surrounding countryside and will also screen the development from distant viewpoints. 4. To carefully consider the present context of the site and its surroundings in terms of its biodiversity interest. To avoid damage, and if possible enhance existing nature conservation interests within the applicant’s wider land holding. 5. Design the proposal to avoid creating highway, amenity, or other planning related adverse impacts and to facilitate access provision for all.

The methodology for the preparation of this planning application has been to compile a list of key planning issues that may be relevant to the planning consideration of an application to extend the present site. This scoping exercise revealed the following principal issues that needed to be addressed:

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 Biodiversity impact and enhancement opportunities.  Viewpoint assessment and landscape impact.  Highway impact.  Archaeological implications.  Creating a high standard of design that matches the applicant’s aspiration to add an improved up to date enlargement to the present park offer.

Initially two/three alternative extension sites were identified for consideration in relation to the above issues. These were located on the elevated land to the south and east of the present park. Two sites to the south were discounted in favour of the presently proposed site, mainly in view of their relative adverse impact in biodiversity and landscape terms.

The gentler plateau levels of the proposed site and its physical relationship with the existing park also allow the site to be laid out on a flatter area of pasture without large scale ground re-modelling. The site requires a shorter length of driveway to serve the new site that will increase the open space and benefits to nature conservation.

How the Proposals Comply with the Adopted Concept, Principles and Policies

Character, Scale and Layout

The proposed layout and scale of the extension has been carefully designed in relation to the above concept. The number of new holiday units proposed is considered commensurate and of subsidiary scale to the existing park. The majority of the accommodation units are shown orientated in a south to north direction. The units are much more widely spaced apart and the new drive and pitches within the extension is routed to take advantage of the natural terraces and flatter contours of the site.

The applicant will continue to manage the site to the high standard that has been achieved for the present static caravan site. Similar conditions relating to the monitoring of occupation, maintaining a high standard of maintenance and renewing units at intervals will be imposed on the extension development if permission is granted.

Landscape Impact

A comprehensive assessment has been carried out of the visual impact of the existing caravan park and the proposed extension site within the

15 surrounding landscape. The zones of visibility of the site are relatively small in area and those areas that provide distant views are restricted mainly to higher ground in a short arc to the north of the site. (see Zone of Visibility Plan below) The areas are accessible by public footpath and comprise the elevated parts of Penrhyn side and the Little Orme. (see photographs below)

Magnified Photograph of the site from the top of Penrhyn side looking south.

Magnified view of the caravan park and site glimpsed from lower road in Penrhynside.

Looking south from the Little Orme ‘s Head summit. Tan y Bryn middle right off photograph.

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Site on the right when looking south from the Little Orme’s eastern top

At lower level the site can be discerned at the bottom of the little Orme hill travelling towards Penrhyn Bay. There are glimpses of the site also when travelling in a south west direction towards Glanwydden fronm Penrhynside . However these are fleeting glimpses and the site is barely discernible from these points. (see the Zone of Visibility Plan below) are very distant views that can only be fleetingly glimpsed. The site is seen in an elevated position, amongst interspersed trees and intervening development from these points that prevent clear/prominent or prolonged views.

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There are no views of the site from lower or elevated positions along the northern areas in the vicinity of Penrhyn Bay , Gloddaeth Lane and Glanwydden. Similarly there are no views of the caravan park or application site from higher or lowland vantage points within the southern arc between Bryn Euryn to the east and Conwy/ Conwy Mountain and the Great Orme to the north and west. Some of the main views are shown below.

Views from the west from Bryn Euryn summit and elevated position to the south of Mochdre.

Closer views of the application site are very restricted and the only views that could be identified are from the existing caravan park itself and the public footpath that runs in a north south alignment through the existing park. From this footpath the main view of the application site would be from an elevated position travelling northwards above the existing

18 caravan park. These are closer views and the site would appear from these positions as a continuation of the established static caravan site.

From the local road network, including the Bryn Pydew Road the intervening rising land that plateaus to the north of the application site hides the proposed development.

The proposed landscaping scheme has been positioned and designed to mitigate the full impact of the above distant views of the site and views from close by on the public footpath. This landscaping scheme has been designed with reference to the Enfys Ecological Report that has also been submitted with this application.

The applicant’s brief for the above report requested recommendations for planting to mitigate possible landscape impact and also asked for detailed options to enhance the biodiversity interest in the area. Section 6 of the Biodiversity Statement lists species of native origin that could be used to screen the proposed development which would also have positive impacts on local biodiversity. The objective of the planting within the site is to create open rides and pathways, rather than a dense hedgerow, forming an open area of scrub woodland, as described in paragraph 6.1.3 of the statement.

The applicant has also examined options for off-site enhancements. One suggestion is to establish a section of new mixed native planting to establish a north and south aligned wildlife corridor between the existing woodlands on the upper area of the applicant’s land holding. This suggestion has been taken on board and details of this measure are shown on plan ref: PJH/22/2016/04

The Natural Resources Wales have been consulted on the proposal and requested that an assessment of the landscape impact of the development would be advantageous.

The effect of the above measures will be significantly beneficial to the visual impact of the site from the limited number of identified viewpoints previously identified. The site is a small scale extension of the existing caravan park and will be barely visible from a few distant elevated viewpoints. The development of the application site will not affect the character of the Cadw Outstanding Landscape of Historic Interest. Cadw have been consulted on the proposal and raised no objection.

The proposal is considered to comply with criteria e) of policy TOU/4 and criteria 2f) of policy DP/1 and criteria 2a) and 2c) of policy DP/3 together

19 with policies DP/4 and DP/6 of the LDP. The proposal will also satisfy policy CTH/2 on Historic landscapes together with relevant guidance in circular 61/96, PPW and TAN 12 aimed at protecting and enhancing the landscape.

Biodiversity Impact and Enhancement

The affect of the proposals on wildlife and protected species and upon nearby designated biodiversity sites have been considered in the Enfys Ecology Biodiversity Statement (BS) dated 08/06/2016 that accompanies this application. The surveys for the BS were carried out at optimum times for the identification of floral species.

The applicant is very much aware that, although the application site itself, and the majority of his land holding, do not contain designated nature sites the wider Bryn Pydew area possesses botanical and entomological interest and also geological, woodland, limestone grassland and invertebrate significance.

There are four statutory designated nature conservation areas that are part of the Creuddyn peninsula Sites of Special Scientific Interest (SSSI) within two kilometres of the site. One of these is and Special Area of Conservation (SAC) and one is the Liverpool Bay Special Protection Area (SPA) There are two SSSIs at a distance to the north of the caravan park on the opposite side of the Bryn Pydew Road. The ‘Coed Bron Garth woodland’ SSSI is located within the applicant’s landholding some way to the south and south east of the application site. Mr Hughes has worked with the North Wales Wildlife Trust to maintain the designated woodland to the south within his ownership.

The Statement has assessed the existing biodiversity interest of the site and its environs and has considered the potential impact of the proposal on the application site itself and the potential effects of the proposed development upon the adjoining land and designated sites in the locality. In view of the LDP policy requirement to enhance wildlife interests where possible when proposing new development the BS has identified options to create overall benefit to wildlife interests in this wider area. There are also recommendations for precautionary measures to be taken during the course of the work.

The major features of ecological value in the Pydew locality are the large woodland area, calcareous grassland and limestone exposures. The conclusion of the BS on the direct impact on the nature conservation

20 interest of the application site itself is that the area of least existing biodiversity value has been chosen for the development. The proposal will lead to a loss of an area of improved grassland that is relatively species poor. Although there are areas of higher quality calcareous grassland on adjoining land, particularly on the south facing slopes and around existing limestone outcrops, these will not be affected by the application proposal.

The overall conclusion of the BS is that nature conservation features and interest will not be harmed by the extension of the existing caravan park. This application goes further than merely ensuring a neutral impact upon biodiversity however and the applicant has endeavoured to incorporate proposals in the application that will positively accentuate the characteristic natural assets and habitats of the locality.

The landscaping and planting scheme that has been designed to mitigate the visual impact of the proposed development when viewed from a distance has been designed in line with recommendations contained in paragraph 6.1.2 of the BS. Native species that are appropriate to the local habitat, such as birch, rowan etc with a suitable alkaline meadow grassland mix will be planted within the site. These areas will be fenced to exclude stock and managed under a mowing regime. When established, this planting will not only enhance the distinctive visual character of the site and its setting, but will also improve the botanical and entomological value of the site.

Having concluded that the immediate effect of the proposal on these aspects will be negligible, the report states that there is potential to increase overall biodiversity value through off site enhancement.

Having examined the options advanced in the BS for wider mitigation the applicant is proposing to re-establish a native hedgerow to the south of the site/improving the management of neighbouring grassland areas in line with an on-going management plan.

The County Ecologist has received a copy of the final BS and has confirmed that its methodology, contents and recommendations are sound. The Ecologist has raised no objection to the development.

In view of the above the proposal is considered to be compliant with LDP policies TOU/4, NTE/1 and NTE/3 as well as the relevant biodiversity criteria listed in policies DP/1, DP/3, including criteria 2g) and DP/4 and DP/6.

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Movement to and from the Site

The site is on level to gently sloping ground. The proposals do not create any difficulties as a result of the movement of vehicles or pedestrians to and from the site. There is adequate space within the site for motor vehicle/bicycles and pedestrians to move freely. Vehicles can turn within the site to exit in forward gear. The application site is located within distance of a comprehensive network of public footpaths. There is sufficient parking proposed to allow at least one vehicle space for each holiday unit.

The proposed holiday unit will all be low single level structures. The new units will be purchased and arranged to be brought onto the site by their prospective owners. Persons with disabilities, including wheelchair users will be catered for at the site.

The area is rural and characterised by narrower than standard width lanes with few pedestrian footways. This is an attractive feature of the area that has, and will continue to be of an advantage to the marketing of the extended caravan park as a holiday destination.

The site is easily accessible by car and could be attractive to cyclists and walking enthusiasts in the future. It is appreciated that the road network in the vicinity of the application site is rural and does not conform to present highway standards. Nevertheless access by vehicles to and from the site will not present any difficulties or dangers to road users.

The existing caravan park benefits from an access to the Bryn Pydew Road that has been improved. The access drive is wide enough for cars to pass and there are already improved visibility splays to the east and west. It is anticipated that the additional volumes of vehicular traffic generated by the use will be very low. Most users would want to minimise their time in the car during their stay. There are attractive walks in the locality that also connect to a wider network of paths.

The pre-application consultation with the Conwy Council Highway section expressed a concern that the access point from the public highway may not be suitable to cater for the additional traffic that may be generated by the enlarged site. Whilst it is appreciated that the present access has a more restricted visibility when looking to the east on entering and leaving the site, there are several factors that would indicate improvements works would overcome the Highway sections concerns.

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The present sight lines at the junction of the existing caravan park with Bryn Pydew Road are 2.50 metres from the edge of the carriageway x 15.00 metres to the east and approximately 60.00 metres to the west. However in the latter direction there is a more distant view of approaching cars at over approximately 90.00 metres away from the junction where a bend in the road allows early visibility of approaching vehicles from the west.

Occupancy rates for existing park units, records of daily journeys and statistics for the traffic flows on the Bryn Pydew Road during peak periods have been monitored between 7th June and 30th August, 2016. (see Table No 1 below)

These show:

 The average occupancy rate for the existing caravan units is relatively low and even in the summer season does not approach 100% occupancy.  The total number of daily car journeys made by the occupiers of the existing 24 caravan units during peak hours is low in number during the comparatively busy summer season.  The total number of car journeys recorded travelling on Bryn Pydew Road at peak times were similarly low in number and traffic speeds were below the local 30mph speed limit.

The figures shown in Table 1 below show that 100% occupation of the units on any one particular day or period never occurred. Analysis of the information indicates that overall the average occupancy rate for units is about nine units out of the total 24. This is approximately a 37.5% occupancy rate. This figure increases over weekend and bank holiday periods when an average of 11.50 units are occupied. (48%) Between 7 and 9 units up to a high of 15 to 17 units were occupied at these peak weekend/bank holiday periods. The highest occupancy rate achieved this summer at the caravan park was 17 units but this occurred on only one day.

The applicant has been operating the existing caravan park since its initial opening and identifies the periods of 8:00am until 10.00am and 4:00pm until 6:00pm as being the periods of peak journey numbers by occupiers.

The recent monitoring exercise of the daytime journeys shows that existing holiday park visitors made average total daily journeys of 16.5 trips during these periods. This equates to only about four trips per hour to and from the site. The average number of journeys to and from the site

23 on a weekend/Bank Holiday was 20 per day. (an average of 5 journeys per hour) For weekdays the equivalent figure was 13. (This equates to an average number of weekday peak period journeys of just over 3 trips per hour)

If these figures are extrapolated for the extended operation comprising a total of thirty five holiday units the anticipated average number of journeys to and from the site per hour will be in the order of 6 trips. For weekdays the equivalent figure is an average of 4.5 per hour, with a figure of just over 7 trips for weekends and bank holidays. These are considered to be representative and show trip generation during the busiest summer holiday period.

The numbers of car journeys travelling in both directions along Bryn Pydew Road during the peak periods of 8.00am -10.00am and 4.00pm and 6.00pm in the last summer months have been recorded and are also shown in Table 1 below. These figures indicate that the stretch of highway approaching the application site is not heavily used by vehicles. The total recorded cars on the road per day ranged from 15 on 17/08/2016 (less than 4 per hour) to a high of 36 on 27/08/2016. (9 trips per hour) On average over the 40 recorded days 981 trips were noted travelling on the highway during the peak morning and late afternoon periods. This equates to an average of approximately 24.5 vehicle journeys per day. (or just over 6 vehicles per hour)

The record for accidents at this access junction in the last forty years is exemplary. The existing caravan park has been operating since 1984 with 24 units and there has not been any highway incidents recorded at the access point. The existing junction was improved in 1984 and, bearing in mind the extremely low level of traffic using the road (averaging one vehicle every 10 minutes) the applicant is satisfied that the existing arrangements have not created hazardous traffic conditions.

Nevertheless the applicant has agreed to include an enhancement to the existing visibility splay to the east of the site access junction to achieve a 10.00 metre improvement in the visibility distance. This involves re- positioning the existing low dry stone wall so that a splay of 2.50 metres x 25.00 metres can be achieved.

The proposed improvements at the access junction are shown on drawing reference number: PJH/22/2016/02 that accompanies this application.

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TABLE 1

Existing Traffic Flow Information

Journeys made to Tan y Bryn Caravan by Journeys made using Bryn Pydew Occupants Road passing Rofft Bryn Pydew

DATE No of Journeys over 12 DATE 8.00am- 4.00pm- Occupants hrs Forward & 10.00am 6.00pm Return 07/06/2016 13 19 07/06/2016 14 9 01/07/2016 9 18 01/07/2016 16 16 02/07/2016 7 12 02/07/2016 12 12 03/07/2016 7 9 03/07/2016 12 13 04/07/2016 6 12 04/07/2016 15 12 05/07/2016 12 25 05/07/2016 10 10 06/07/2016 12 20 06/07/2016 9 10 29/07/2016 8 20 29/07/2016 12 15 30/07/2016 9 19 30/07/2016 15 17 31/07/2016 9 15 31/07/2016 10 12 01/08/2016 9 18 01/08/2016 16 16 02/08/2016 7 12 02/08/2016 12 12 03/08/2016 7 9 03/08/2016 12 13 04/08/2016 6 12 04/08/2016 15 12 05/08/2016 12 25 05/08/2016 10 10 06/08/2016 12 20 06/08/2016 9 10 07/08/2016 13 19 07/08/2016 14 9 08/08/2016 9 15 08/08/2016 12 12 09/08/2016 7 10 09/08/2016 17 14 10/08/2016 8 20 10/08/2016 8 13 11/08/2016 8 17 11/08/2016 12 13 12/08/2016 10 15 12/08/2016 13 9 13/08/2016 11 20 13/08/2016 10 11 14/08/2016 11 18 14/08/2016 9 9 15/08/2016 6 10 15/08/2016 10 12 16/08/2016 7 14 16/08/2016 12 13 17/08/2016 8 14 17/08/2016 5 10 18/08/2016 8 19 18/08/2016 14 8 19/08/2016 12 18 19/08/2016 10 10 20/08/2016 13 22 20/08/2016 14 16 21/08/2016 13 19 21/08/2016 7 12 22/08/2016 6 12 22/08/2016 11 13 23/08/2016 4 10 23/08/2016 15 8 24/08/2016 3 4 24/08/2016 13 15 25/08/2016 5 10 25/08/2016 8 12 26/08/2016 8 12 26/08/2016 10 16 27/08/2016 15 28 27/08/2016 16 20 28/08/2016 17 36 28/08/2016 11 19 29/08/2016 15 31 29/08/2016 8 16 30/08/2016 3 7 30/08/2016 12 12

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The application proposals are considered to meet policy DP/1 criteria 2a) and 2d) and policy DP/3 criterion 1c) and the access requirements of PPW.

Environmental Sustainability

The applicant is keen to employ a local workforce to carry out the proposed works. New construction materials will be locally sourced wherever possible to minimise the carbon footprint of the scheme and products will be researched to be from a sustainable source.

The present caravan park is supplied by electricity power by a 4.5 Kwh array of solar panels installed upon an outbuilding roof that provide for the general purpose electrical energy use of the communal facilities of the site.

The new holiday units will be of improved thermal performance. The applicant has agreed to the preparation of an energy/sustainability audit and regular reviews to ensure that optimum efficiencies are achieved during the on-going commercial use of the site.

Measures will be included in the operation of the holiday use to promote re-cycling and to reduce the amount of waste generated by users. Information and literature will continue to be provided on site to inform park occupiers about local bus services and cycle hire and walking routes.

The proposal will consequently comply with LDP policies DP/1, DP/3 and DP/6

Water Quality and Drainage

The applicant has great experience in managing the existing caravan park and has not experienced any problems with ground or surface water pollution/contamination to date. The proposal is to improve the septic tank serving the combined development if permission is granted. A Balmoral Hydro Clear treatment plant with suitable soakaways is to be installed to serve the extra capacity if the proposed extension to the park is granted consent.

The proposal meets the requirements of policy NTE/9 of the LDP.

Archaeological Impact

The Gwynedd Archaeological Trust was consulted at pre-application stage. The Trust examined their records and conducted an inspection of

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the site and confirmed that the application site and adjoining areas, belonging to the applicant, showed no evidence of any archaeological interest.

The proposal is consequently considered to be compliant with relevant criteria listed in policies of the LDP.

Impact on Amenities

The impact of the proposal on the amenities enjoyed by nearby residents has been considered. The locality surrounding the application site is sparsely developed with housing. The nearest dwelling to the application site (that is not connected to the caravan park) is ‘Ty Canol’. This dwelling is located approximately 60 metres from the application site boundary. It is not anticipated that any noise and disturbance will result from the use/occupation of the proposed holiday units or traffic movements to and from the site.

Other houses situated on the south side of the Bryn Pydew Road are also sufficiently distanced from the proposed site to ensure that these will not be affected in any way by the development.

There are a no dwellings that front onto the north side of Bryn Pydew Road in the vicinity of the site. The nearest houses to face this side of the road are a considerable distance to the north east and north west. And consequently will not be affected by the development.

As a result the proposal is considered to be in full compliance with relevant criterion of the policies DP/1 and DP/3 of the Conwy LDP.

Impact on Hard Rock Reserves

The proposal is categorised as a non-permanent form of development and therefore it will not adversely affect the ability to source hard rock reserves if there is a need for these minerals in the future.

The proposal is therefore compliant with LDP policy MWS/6. Summary

The present caravan park is well established but in need of enlarging and upgrading in order to sustain the enterprise in the future. The existing facility is located in an attractive landscape that is not designated for its landscape value but is inland and in a sought after position for holiday-makers.

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The extension is commensurate, and of ancillary scale to the existing caravan park and is therefore supported by Development Plan tourism policy. The proposal has been thoughtfully designed There are no adverse impacts on archaeology or biodiversity as has been demonstrated and proposals to mitigate the limited effect of the extension on the landscape will create biodiversity benefits in the locality.

There is safe access to the site at present and the application proposes to improve visibility in order to ensure that the additional traffic generated by the extended site can be accommodated with causing highway hazards. The location is considered sustainable in holiday/leisure facility terms. There are no anticipated adverse effects from the proposal on the amenities of the closest residential occupiers. There will be no ill-effects upon the Welsh language.

The proposed use is considered to be a suitable and sensitive modern low impact. The proposal is considered to meet all the relevant LDP policies and criteria listed in the Policy and Guidance section of this statement.

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APPENDIX A

Photographs of the Existing Caravan Park and Application Site

Photo 1 - View of existing Tan y Bryn Caravan Park from the east.

Photo 2 -.Application site looking north.

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Photo 3 - The south area of the application site looking south west

towards the existing caravan park.

Photo 4 - looking south from Bryn Pydew Road. Application site hidden by rising ground.

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Photo 5 - Looking to the south east from the access junction.

Photo 6 - Looking west from the site access junction prior to regular trimming of highway hedge.

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Photo 7 -Looking east along Bryn Pydew Road.

Photo 8 - Looking north from the plateau above and to the south of the application site.

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Photo 9 -Looking towards Penrhynside from the south part of the application site.

Photo 10 - Proposed reinstatement of degraded hedgerow to the south of the site.

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Photo 11 - Looking in a north east direction across the level area of the application site.

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