Non Site Allocation Representations Report.pdf

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SPATIAL POLICIES, KEY DIAGRAMS AND SUPPORTING DEVELOPMENT CONTROL POLICIES Policy EMP/8 Holiday Accommodation Zone Rep No Name People Type 61 Mr Robert Longmire-Bowns [125] 1 Object Summary The Holiday Accommodation boundary with respect of the Pier Pavilion Site should be changed. It has nver been zoned for habitation and should therefore be excluded from the Holiday Accommodation Zone. Change Sought: The Holiday Accommodation boundary with respect of the Pier Pavilion Site should be excluded from the Holiday Accommodation Zone. 9 Mr Simon Hanson [25] 1 Object Summary EMP/8 and area shown on Map2. I consider the change to be unsound. This area has been a popular Holiday and letting area since 1950's and classed as a Class 2 Trading Area. Soundness tests C2, CE2 AND CE4 apply. Change Sought: Include area within Tourism accommodation zone 31 Mrs Deborah Thompson [97] 1 Object Summary St Davids Rd should be classed as a primary serviced accommodation because of high proportion of guesthouses of mainly 4 star and should be dealt with accordingly. Change Sought: Include in primary holiday accommodation zone. EMP/8 Map 2 need changing. 1493 Community Development Services - Conwy County Borough Council (Mr Robert Dix) [1878] 1 Object Summary Policy EMP/8 and the Holiday accommodation zone needs to be reconsidered in light of the accommodation survey currently underway and also must make reference to Supplementary Planning Guidance which needs to be established as a priority. Change Sought: Reconsider in light of accommodation survey currently underway. Refer to SPG - establish document as a priority. The boundaries of the holiday zone as currently drawn are insufficient and should include areas such as St Davids Road, St Mary's Road, Carmen Sylvia Road, Roseberry Avenue etc. 1488 Community Development Services - Conwy County Borough Council (Mr Robert Dix) [1878] 1 Object Summary In analysing Llandudno, para 3.20, the significance of the serviced accommodation sector is recognised, again spoken of in terms of protection, but not the need to improve and develop facilities. Change Sought: Restaurants, pubs, clubs, attractions are all needed to support the accommodation and sectors of the industry which will bring all year tourism. Policies relating to Holiday Accommodation and Shopping Zones within resorts such as Llandudno need to consider the needs of facilities such as these and more strongly support the intent of SO6. 128
SPATIAL POLICIES, KEY DIAGRAMS AND SUPPORTING DEVELOPMENT CONTROL POLICIES Policy EMP/9 Chalet, Caravan and Camping Sites Rep No Name 1567 Countryside Council for Wales (Mr Richard Ninnes) [1948] Summary CCW supports the policy. We recommend para 4.132 is amended to refer to the "natural heritage, including Natura 2000 sites". People Type 1633 cyng William Edwards [614] 1 Object Summary Policy EMP/9, 1b and 1c in particular, appear to be unduly rigid and contradictory. See attachment for personal example from Uwchaled. Change Sought: I believe that a link with a tourist attraction such as we have in Bala or Llyn Brenig is more than adequate to prevent new caravan parks and extensions from proliferating in the countryside. We also need to define 'small' in a sensible way. Compared to the massive sites we have in coastal areas, anything under 50 vans would be small in my view. Planners who think of small sites in terms of a maximum of say 10 vans simply aren't living in the real world where costs, such as we must now incur to upgrade our access road can be crippling. It is worth noting that on the coastal strip between Abergele/Pensarn and Rhyl, there are literally thousands of caravans. In my ward of Uwchaled, which is probably 40 times bigger in area, there are 3 static caravan parks with the total number of caravans standing at approximately 63. A section of para 4.131 appears to be have been removed in the final glossy LDP document (see attachment for full response). 519 Leonard Jinks Architecural Consultants Ltd (Leonard Jinks) [789] 1 Object Summary Page 110 EMP/9 Change Sought: The policy is unrealistic in that it does not allow any expansion of sites or increase in units. This may be justified for static sites but there should be flexibility for modest expansion of touring caravan sites otherwise no improvements are likely. In most cases existing touring caravan sites have had the benefit of planning permission therefore they should be in the right location and have adequate services. Modest appropriate expansion should be allowed for touring sites and the policy should change to reflect this or an additional policy included. 666 Rossisle Ltd [833] Summary There is a very strong objection to this policy and especially clause 2 The policy needs to respect and respond to changing patterns and trends in tourism in order to maximise the economic benefit of such proposals and to ensure good sustainable design and quality of provision. Change Sought: Planning permission will be given for new, resource efficient design (RED) and well designed self catering accommodation where it is appropriate in scale and size of the community it lies within. 428 Gorse Hill Caravans Ltd [698] 1 Object Summary LDP accepts that chalet/caravan sites are important source of holiday accommodation, can be crucial to the tourism economy and that the problem of saturation does not apply in the rural area. Policy EMP/9 is too restrictive and should not preclude an increase in the number of static caravan/chalet units on existing sites or an overall increase in the site area in the Rural Area, where this can be achieved without detriment to the rural character and appearance of the area. Policy EMP/9 should differentiate between the improvement of existing sites in the urban and rural areas. Change Sought: In Line 1, after "existing sites" add "in the Urban Development Strategy Area". Insert new Part 2 stating: "Proposals for the improvement and extension of existing sites in the Rural Area will be permitted provided that the development: a)Results in the overall improvement of the facilities, layout and landscaping; b)Safeguards the rural character and appearance of the area; c)Accords with the Development Principles and other related policies within the Plan." Re-number Part 2 of EMP/9 as Part 3. 421 Tir Prince Raceway Ltd [697] 1 Object Summary WAG is promoting the regeneration of Rhyl/Colwyn Bay. New chalet/caravan park development may be an essential and integral component of forthcoming comprehensive mixed use regeneration schemes. The overall concept and viability of potentially significant regeneration schemes which the LPA would, in principle, wish to encourage may be severely prejudiced if new chalet/caravan park development is excluded from the range of potentially acceptable uses. Policy EMP/9 is too inflexible, does not have sufficient regard to either PPW or the SRA. The policy should permit, exceptionally,new chalet/caravan park development which is integral to major regeneration schemes in the SRA. Change Sought: At the end of the policy, after "will not be permitted", add "unless they form an integral component of significant, mixed use regeneration schemes within the SRA" 877 Mr A Townsend [1010] Summary The above site has recently been purchased by Otmatold Ltd., and I have been instructed to write to you on their behalf. The site is presently used to store caravans but my clients wish to register their interest in converting the site into a caravan holiday park at sometime in the future and would like you to bear this in mind when preparing your Unitary Development Plan. Change Sought: Allow sites to convert to caravan holiday parks 97 British Holiday and Home Parks Association (Clwyd Branch) (Mr J McAllister) [160] 1 Object Summary The LDP is unsound in relation to tests C1 and 2, CE1, 2 and 4. The plan is extremely negative and inflexible. Some parks (outside the Towyn coastal stretch) do have the potential to improve by utilising adjoining land. Flexibility should enable the parks to reduce caravan density to improve facilities and should be allowed through extensions. There is no reason why a policy approach could not be adopted which is the same as that in the 'recently adopted' Gwynedd UDP which allows for upgrading of accommodation and reducing the impact upon the landscape. Change Sought: Provide a range of tourism policies which will secure its future by enabling existing parks to improve their range of accommodation, reduce densitities, improve landscaping and reduce the parks impact on landscape. 1010 Environment Agency Wales (Mrs Deborah Hemsworth) [1036] 1 Object Summary EMP9 Change Sought: Cross-reference should be made to policy DP/1 and in particular to paragraph 1e to ensure the flood risk is taken into consideration prior to development of such sites. EMP9 Cross-reference should be made to policy DP/1 and in particular to paragraph 1e to ensure the flood risk is taken into consideration prior to development of such sites. 1461 Denbighshire County Council - Planning Policy (Martha Savage) [1843] 1 Object Summary The LDP will not allow new chalet, static caravan, touring caravan or campsites to be permitted within the County. This could potentially have an impact on Denbighshire due to the proximity of Conwy to Denbighshire. This may place pressure on Denbighshire as developers are not able to locate in Conwy by virtue of the policy. Change Sought: Review policy and consider potential cross boundary issue. 1613 Lyons Holiday Parks [1961] 1 Object Summary Objection to policy EMP/6 crierion d and EMP/9 1b. It is not supported by any evidence base justifying the approach taken or the alternative spatial options. There is no background paper or survey data supporting the policy stance to prohibit either extensions to existing or the provision of new sites. Lyons Holiday Parks objects to the policy as it would restrict customer choice, stifle innovation in delivery, prevent caravan parks from responding and adapting to changing markets and standards as well as placing the Companies parks in an uncompetitive and unfavourable position when compared to sites in neighbouring North Wales Authorities and nationally. Change Sought: This part of the policy should be amended to allow for enhancement and extension of sites in appropriate circumstance. A policy based criteria could suffice and provide flexibility. 1 1 1 Support Object Object 129
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CYNLLUN DATBLYGU LLEOL CONWY I’W
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Policy CTH/3 Buildings and Structur
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LDP - Deposit Plan INTRODUCTION 1.2
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INTRODUCTION 1.5 Rep No Name 1434 L
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INTRODUCTION 1.19 Tests of Soundnes
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INTRODUCTION 1.24 Policy Framework
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INTRODUCTION 1.26 Plan Area context
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INTRODUCTION 1.32 Rep No Name Peopl
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VISION AND OBJECTIVES 2.1 A Vision
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VISION AND OBJECTIVES 2.8 Rep No Na
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THE SPATIAL STRATEGY AND KEY DIAGRA
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IMPLEMENTATION AND MONITORING FRAME
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SECTION ONE - INTRODUCTION 1.2 The
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SECTION ONE - INTRODUCTION 1.3.3 Re
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SECTION ONE - INTRODUCTION 1.8 Coll
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SECTION TWO - VISION AND OBJECTIVES
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SECTION THREE - THE SPATIAL STRATEG
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SECTION FOUR - SPATIAL POLICIES, KE
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SECTION FIVE - IMPLEMENTATION AND M
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