Swansea LDP Examination - Appendix to Hearing: Session 9, Section 8: Tourism Employment, Retail and Tourism - Residents
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Swansea LDP Examination Appendix to Hearing: Session 9, Section 8: Tourism Employment, Retail and Tourism Hearing Session 9: 28 February 2018 Published: 12 February 2018 1|Page
Contents Contents ..................................................................................................................... 2 2.0 Background and Context .................................................................................. 3 3.0 National Planning Policy and Technical Advice ................................................ 5 4.0 Supplementary Planning Guidance .................................................................. 7 9.0 Review of the Article 4 Direction ..................................................................... 39 10.0 Conclusions .................................................................................................... 40 Annex A: Calendar of Rallies and Festivals ............................................................. 41 Annex B: Caravan and Camping Survey Letters and Forms 2012 & 2013 .............. 52 Annex C: RDP Leader Approved Projects ............................................................... 66 2|Page
1.0 Introduction 1.1 The purpose of this Evidence Paper is to provide background information and baseline data for the City and County of Swansea Deposit Local Development Plan (LDP) in relation to camping and caravanning accommodation sector in the County. 1.2 The paper includes the planning context of the sector, setting out national planning policy, national and local tourism strategies and other relevant legislation. It also outlines evidence gathered to support the caravan and camping policies contained within the Deposit LDP. 2.0 Background and Context 2.1 The City and County of Swansea has long been a popular area for tourists to visit. Tourism is very important for the economy of the County. Since 1992, Swansea has been using STEAM (Scarborough Tourism Economic Activity Model) to monitor the scale of tourism and trends in Swansea Bay. In 2016 there were over 4.5 million visitors to the area, a 0.6% increase from 2015 and tourism expenditure was £400.3 million, a 1.6% decrease from 2015. Tourism supported 5,674 jobs in the Swansea Bay area in 2016, which is a 0.8% decrease from the 2015 figures. 2.2 The County’s natural environment makes up over 80% of the County’s total area and is of outstanding quality and beauty. The diversity of landscapes and habitats which include upland moorland, coastal cliffs, sandy beaches, heathland, woodland, wetlands, river valleys and estuaries, make it one of the most attractive and ecologically rich counties in the UK, with over half of the County’s area being of significant ecological importance. Nearly 70% of the habitats and 20 % of species identified as being a priority for biodiversity conservation in the UK can be found in the County and approximately 17% of County’s area is protected by designations at a European (SAC, SPA, RAMSAR) or National (SSSI, NNR) level. In total there are approximately 180 international, national or locally designated sites throughout the County. All areas of semi-natural green space will have some value for wildlife and the spatial distribution and interrelationship of sites is important, both for wildlife and for people. The natural environment of the City & County of Swansea also contains a wealth of important geological sites, areas of highly attractive landscape and many valuable archaeological sites. These are all in need of protection and sensitive management. Collectively, these unique natural qualities make Swansea a special place to live and visit. They contribute significantly to quality of life, and the economy of the area. Gower Area of Outstanding Natural Beauty 2.3 Many of the tourists and day visitors who come to Swansea are attracted by the beautiful Gower Peninsula, which was designated as Britain’s first Area of Outstanding Natural Beauty (AONB) in 1952. Over three quarters of the 3|Page
camping and caravan pitches within the county are situated within the AONB, the majority on the coastal strip. Many campsites have been established for a number of years, most on what were once working farms but now are primarily camping and caravanning sites, with only a few working farms remaining on Gower. It is also clear that this area is under constant pressure for further developments for additional chalet, static caravan and touring unit sites. However, the coastal strip of the AONB is also an area where conservation and enhancement of the natural beauty of the landscape and seascape is most important. The statutory purpose of the AONB designation is the conservation and enhancement of the natural beauty. The Countryside and Rights of Way Act 2000 requires local planning authorities to have ‘regard to the purpose of conserving and enhancing the natural beauty of the area…’ when exercising their functions. Heritage Coast 2.4 The non-statutory "heritage coast" designation is aimed to protect coastline of special scenic and environmental value from undesirable development and to improve access for visitors. The Gower heritage coast runs for 33 miles from Caswell Bay in the south to Salthouse point on the north shore of the Gower Peninsula and was designated in 1970. Rural Economy 2.5 The County has secured funding via the Rural Development Plan (RDP) for Wales in order to promote the economic regeneration of rural areas. The programme is a 7 year European Agricultural Fund for Rural Development (EAFRD) programme funded by the European Union and Welsh Government. 2.6 Eight wards have been designated as Rural: Gower, Penclawdd, Pennard, Bishopston, Fairwood, Mawr, Pontarddulais, and Llangyfelach. These wards have a combined population of 29,354 (12% of the population of the County) and a total land area of 248.98km2 (over 60% of the total land area) (2011 census). The wards are supported by three Service Centre wards: Gorseinon, Gowerton and Clydach (with a combined population of 17,016) and 6 Host wards Dunvant, Killay North, Killay South, Newton, Oystermouth and Penllergaer (with a combined population of 14,733). 2.7 To support the implementation of the RDP a Local Action Group (LAG) made up of people from the third, public and private sectors was established. The LAG secured funding for The Rural Local Development Strategy 2014-20201 and manages the programme via sub-groups: - Economy and community - Tourism - Transport and infrastructure. 1http://www.swansea.gov.uk/media/18561/Rural-local-development-strategy-2014- 2020/pdf/Rural_local_development_strategy_2014-2020.pdf 4|Page
2.8 Looking specifically at employment in the tourism industry, one quarter of employment in rural Swansea (1500 jobs) are based within tourism. Tourism accounts for 54% of employment in the Gower ward, highlighting the importance of this sector to the rural economy. Annex C details RDP Leader Approved Projects in 2017. 3.0 National Planning Policy and Technical Advice Wales Spatial Plan (2008 update) 3.1 The Wales Spatial Plan (WSP) provides the context for local development plans. It aims to balance sustainable economic growth whilst protecting and enhancing the environment. Swansea forms part of the Swansea Bay Waterfront and Western Valleys Region as seen in Figure 1. Figure 1 3.2 One of the WSP’s key priorities for the region is ‘Developing a strong leisure and activity based tourism industry. The WSP states that a challenge in the tourisms sector is to raise the quality of the product in order to attract high yielding visitors, while also increasing off-peak business. The WSP regional plan indicates that the area to the north of the County has inland tourism potential (Figure 1). 5|Page
3.3 The WSP also recognises the need to manage important landscape and geological features sensitively and seeks to ‘maximise the tourism and recreation opportunities provided by our high quality environment without causing it damage’. Planning Policy Wales, 9th Edition, 20162 3.4 Planning Policy Wales (PPW) seeks to promote diversification of the rural economy, stating that small-scale enterprises have a vital role in promoting healthy economic activity in rural areas, which can contribute to both local and national competitiveness. Tourism is acknowledged as being vital to economic prosperity and job creation and can be a catalyst for environmental protection, regeneration and improvement in both rural and urban areas. National planning policy seeks to support the Welsh Government’s aim for tourism to grow in a sustainable way and to make an increasing contribution to the economic, social and environmental well-being of Wales. The planning system should encourage sustainable tourism in ways which enable it to contribute to economic development, conservation, rural diversification, urban regeneration and social inclusion, recognising the needs of visitors and those of local communities. 3.5 Whilst seeking to support sustainable tourism, national planning guidance recognises that in some places there may be a need to limit new development to avoid damage to the environment (for example in undeveloped coastal areas), or to the amenity of residents and visitors. Development plans should consider the scale and broad distribution of existing facilities and activities and provide for the accommodation and management of future needs in ways which limit negative environmental impacts (including the consequences of climate change), protecting the landscape, biodiversity, the coast, the historic environment and areas of special interest, and the interests of local communities. 3.6 With regard to AONB’s, PPW guides Policies and development management decisions affecting AONBs to favour conservation of natural beauty, although it will also be appropriate to have regard to the economic and social well-being of the areas. AONBs are of equal status to National Parks in terms of landscape and scenic beauty and must be afforded the highest status of protection from inappropriate developments. The duty to have regard to AONB purposes applies to activities affecting these areas, whether those activities lie within or outside the AONB designation (PPW, paragraph 5.3.7). Technical Advice Note 13, Tourism (1997) 3.7 The TAN states that tourism comprises a range of different but interdependent activities and operations which overlap with sport, entertainment, the arts, 2 http://gov.wales/docs/desh/publications/161117planning-policy-wales-edition-9-en.pdf 6|Page
recreation and leisure activities. The TAN provides advice regarding caravan and camping and should be taken into account by the LPA during the preparation of the LDP. 3.8 Paragraph 12 states that “when preparing development plans, local planning authorities (LPA’s) should investigate the adequacy of facilities for both the static and touring caravanner and reconcile these needs with the protection of the environment. 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, while using less land for the purpose. Holiday caravan sites can be intrusive in the landscape, particularly on the coast. Special consideration needs to be given to proposals for new sites, especially in….Areas of Outstanding Natural Beauty, Heritage Coast and sites of national and international importance designated for their natural features.” 3.9 Paragraph 14 states that “LPA’s should examine the scope for encouraging holiday caravan site operators to improve the quality of their sites and to relocate sites away from particularly sensitive areas, such as the Heritage Coast. Policies to this effect should be included in development plans. In some cases, to facilitate improvement or relocation, local planning authorities may need to consider some expansion of the area covered by a site, so that improved layouts and better landscaping can be implemented. LPA’s may also need to consider dividing large sites into smaller units to reduce the overall environmental impact. In these circumstances, to ensure the overall scale of the operation is not increased, LPA’s should consider the use of planning conditions to limit the number of pitches on a site. Authorities should also give sympathetic consideration to applications to extend the opening period allowed under existing permissions”. Technical Advice Note (TAN) 14 – Coastal Planning (1998) 3.10 The TAN recognises that “In areas designated for nature conservation purposes, or for their natural or historic landscapes, development should be limited” (paragraph 11) 4.0 Supplementary Planning Guidance The Gower AONB Design Guide (CCS, 2011) 4.1 The Design Guide is intended for use by all involved in the design and development process, whether planning permission is required or not. The Guide sets out design objectives to ensure that development respects the distinctive character of both the natural and built environment of Gower. Gower ANOB Management Plan (CCS 2016) 4.2 The Plan was produced under the provisions of the countryside and Rights of Way Act 2000 and provides the policy reference point for the Council and other 7|Page
public bodies to exercise their duties by having regard to conserving and enhancing the natural beauty of the Gower AONB. The overall aim of the strategy is to work toward the 20-year vision for the AONB. The Management Plan vision is: “Gower is recognised by residents and visitors as a protected landscape of international importance were the interaction of people and nature over time has produced an areas of distinct character with significant aesthetic, ecological and cultural diversity. Its natural beauty will be sustained by the conservation and enhancement of its natural special qualities, whilst at the same time supporting a sustainable local economy and maintaining culturally rich communities and is reflected in the quality and scale of the built environment.” 4.3 The Strategy contains 14 key themes and identifies a series of policies and objectives for each of them. Theme 10 is ‘Tourism’ and the associated 20 year vision is: “A vibrant tourism economy based on the principles of sustainable tourism offering a quality experience, in which the conservation and enhancement of the special qualities of the AONB, and their quiet enjoyment have top priority. A dynamic tourist industry, which creates economic benefits, and helps support community facilities and infrastructure.” 4.4 The accompanied objective (number 27) is: ‘Support the development of a sustainable tourism industry on Gower’. 4.5 In relation to highway infrastructure, the AONB Management Plan states that the Gower road network is all single carriageway and consists of one A class road, four B roads and a number of unclassified roads. Many of the roads are narrow and bounded by hedges or stone walls that contribute to the character of the AONB. Council policy is not to widen or carrying out improvements to Gower roads, unless necessary for road safety. A Highways Works Good Practice Guide supports management of highways assets on Gower that conserves and enhances the AONB. 4.6 Paragraph 3.37 of the Plan highlights that travel by car is the typical mode of transport for residents and visitors and states that some routes to the more popular beaches become congested at peak times. ‘Narrow road sections – particularly around Parkmill and Kilvrough – can lead to severe delays when buses interact with cars/caravans, motor homes, freight vehicles and coaches. Traffic counter figures suggest a slower increase in volumes in recent times than the national average. Several of the car parks serving the more popular coastal destinations are Council owned, but others are private enterprises. Car parks for the beaches nearest to Swansea (such as Bracelet Bay, Langland Bay and Caswell Bay) tend to get full at peak periods’. Lighting Scheme Guidance for Area of Outstanding Natural Beauty (CCS 2010) 4.7 The guidance provide general advice on the use of outdoor lighting in the Gower AONB and to act as supplementary planning guidance when planning 8|Page
permission is required. The guidance sets out recommended standards for various types of lighting scheme for holiday caravan and camping sites. There should not be a presumption that any lighting on new development is necessary. Light which is excessive, energy inefficient or badly designed can have a negative impact upon the special qualities of the AONB and its tranquillity. 5.0 Tourism Strategies The Welsh Government Strategy for Tourism 2013- 2020 ‘Partnership for Growth’ 5.1 The Strategy provides the basis for the Welsh Government, the tourism industry and other organisations to focus on the priorities that will offer a more prosperous and competitive sector. The Strategy acknowledges that ‘those qualities that attract visitors to Wales such as the landscape, culture, language and heritage need to be safeguarded for future generations, creating long term value and jobs for communities’ 5.2 The Strategy has the following vision for tourism: ‘Wales will provide the warmest of welcomes, outstanding quality, excellent value for money and memorable, authentic experiences to every visitor.’ 5.3 The goal is for: ‘Tourism to grow in a sustainable way and to make an increasing contribution to the economic, social and environmental well-being of Wales’. 5.4 With regard to sustainable tourism the Welsh Government states that ‘tourism relies on the integrity of the natural environment. In Wales, beautiful landscapes and coastlines are the very foundation of tourism. To be sustainable, tourism development needs to consider the needs and quality of life of local communities; enhance and respect culture and local traditions; contribute to local economic prosperity as well as minimising damage to the environment.’ Coastal Tourism Strategy, 2008, Welsh Assembly Government 5.5 Tourism Strategy is to identify a clear way forward for the development of Coastal Tourism, which realises and builds on the economic potential of the coastline of Wales whilst respecting its environmental quality and recognising the importance of achieving community benefits. 5.6 The strategy is based on an analysis of the current coastal tourism offer, the quality of the coastal environment, including a detailed analysis of the 9|Page
environmental designations on the Welsh coastline, and trends that will affect future markets for coastal tourism activities and products. 5.7 The Strategy acknowledges that many resorts are dominated by caravan accommodation. Much of the caravan stock is used by individual families and their friends rather than being available for holiday letting. The larger sites often provide shopping and recreational facilities on site which reduces local spend (Caravan Holiday Homes in Wales Joint Tourism Board/BH & HPA Study 2003). Destination Swansea Bay 2017-2020 5.8 The Destination Management Plan for Swansea - 'Destination Swansea Bay 2017-2020' addresses the vital role tourism plays in the economy and sets a strategic direction for Swansea Bay as a visitor destination. It is produced in consultation with major tourism stakeholders and is regarded as a shared statement of intent between the public, private and third sectors on how to manage, develop and promote Swansea Bay. It replaces the previous Management Plan ‘Destination Swansea Bay 2013-2016’. 5.9 The Plan’s Vision is to: “Create a world class tourism destination, which delivers a high-quality visitor experience in a pleasant, clean and well-maintained environment. This will be achieved by building on the existing working partnership that will, in turn, drive improved tourism provision, effective management and high-quality promotion of Swansea Bay, Mumbles and Gower as a destination”. Sustainable Tourism Strategy 5.10 The 2006 Gower AONB Management Plan contained an objective to seek EUROPARC Federation Sustainable Tourism Charter for Sustainable Tourism in Protected Areas. As part of the Rural Development Plan (RDP) programme a draft Sustainable Tourism Strategy was produced in 2014. The document has never been adopted or used as a formal Council document, but has been used as an evidence base for supporting RDP projects. Carmarthen Bay, Gower and Swansea Bay Local Seascape Character Assessment, Final Report, June 017 5.11 The local seascape character assessment for east Carmarthen Bay, the Burry Inlet/Loughor Estuary, Gower, and Swansea Bay was finalised in 2017. The City and County of Swansea was lead client on behalf of a steering group of authorities and groups including Carmarthenshire County Council, Neath Port Talbot County Borough Council, Bridgend County Borough Council and Natural Resources Wales (NRW). The study should be read in conjunction with the relevant LDPs' landscape, coastal and conservation policies and the Gower AONB Management Plan. It should also be considered with other guidance and baseline information including, LANDMAP and Gower Landscape Character Assessment (2013). The study seeks to provide further information on the 10 | P a g e
character of seascape in general and special qualities in particular areas, such as the Gower AONB and Heritage Coast. The Council intends to adopt the document as SPG to the adopted LDP. 5.12 Caravan and Camp sites around Gower’s coast are identified as main detractors for a number of Special Character Areas 2, 3, 4, 6 & 7 and includes that ‘the potential expansion of leisure facilities such as caravan parks which can be visually intrusive and reduce tranquillity’. Furthermore, their detrimental visual impact is recognised from the offshore Special Character Area as impacting on views and tranquillity. 6.0 The Gower Landscape Character Assessment and Landscape Sensitivity and Capacity Study for Caravan and Camping Sites on Gower The Gower Landscape Character Assessment3 (Gower Landscape Partnership, 2013) 6.1 The document (EB015) provides an impartial assessment of the landscape character of the area, using the Countryside Council for Wales’s LANDMAP as a foundation. Forty-one discreet Landscape Character Areas (LCA’s) of varying size are identified within the AONB and that area of Swansea which is contiguous with the AONB to the north of the boundary. Each LCA is described, an assessment of the strengths, weaknesses, opportunities and threats is outlined, management guidelines are suggested and the special qualities and key characteristics of each area are highlighted. 6.2 The assessment clearly shows that the presence of some caravan and camping sites can, in certain circumstances, be detrimental to the natural landscape beauty of the AONB. 3https://www.swansea.gov.uk/media/1523/Gower-Landscape-Character-Assessment- 2013/pdf/Gower_Landscape_Character_Assessment.pdf 11 | P a g e
Gower Landscape Sensitivity and Capacity Study for Caravan and Camping Sites4 (CCS, 2014) 6.3 The Study (EB017) followed on from, and was based upon, the Landscape Character Assessment, in order to try and obtain a better understanding of the issues raised in relation to caravan and campsites. 6.4 The methodology was based upon the guidance set out in The Countryside Agency and Scottish Heritage’s Topic Paper 6 – Techniques and criteria for judging capacity and sensitivity5. Although this is guidance produced for England and Scotland, there is no equivalent guidance for Wales. Topic Paper 6 notes in paragraph 3.5 that 'capacity studies must be specific to a particular type of change or development.' It was therefore necessary to specify key aspects of the specific change or development that are likely to have an impact on the landscape. 6.5 The potential effects arising from caravan and camping sites on the Gower landscape relate directly to the siting, massing, scale and colour of caravan sites and the duration of their positioning at the respective site. The assessment of the landscape capacity of any given Landscape Character Area to accept caravan and camping sites requires a judgement to be made which requires no detriment to landscape character, or to the identified AONB Special Qualities. This assumes that significant adverse landscape and visual effects result from larger caravan sites which have the biggest caravans, closely spaced within the site, finished in pale colours and reflective finishes, and placed permanently on the site (though not necessarily occupied all year round). These include so-called 'static caravans' - which would encompass chalet-type developments - where the form of such structures is effectively the same as a small bungalow, with the consequence that they have the potential for an urbanising effect if closely spaced. Larger touring caravans placed on sites for several weeks or months at a time have similar potential impacts, whereas small touring caravans parked for limited periods - and tented camp sites - have far less potential for adverse landscape and visual impacts and can be more widely accommodated with-out adverse impacts, depending upon their individual scale, siting and designed mitigation measures. 4 https://www.swansea.gov.uk/media/1520/Stage-I--II-Gower-Landscape-Capacity-Study-for-Caravan- and-Camping-Sites-2014/pdf/Stage_I- II_Gower_Landscape_Capacity_Study_for_Caravan_and_Camping_Sites_FINAL_Edited_Issued_07 _04_20.pdf 5 http://publications.naturalengland.org.uk/file/5769353077194752 12 | P a g e
6.6 The Capacity Study had three main purposes: i To assess the landscape capacity for caravan and camp site provision on and around Gower; ii To provide a background paper for the Swansea Local Development Plan (LDP), which will inform the preparation of policy relating to caravan and camp site provision within Gower; iii To provide baseline data, in conjunction with the Gower LCAS, to facilitate future monitoring of caravan and camp site provision and the assessment of its impact on the Gower land-scape 6.7 The Study identified those areas that are at landscape capacity (in terms of camping and caravanning sites) and which areas have potential for planned expansion of facilities, whilst taking into account of the landscape capacity and suitability of the areas to accommodate such expansion. Of the 41 discreet LCA’s, 11 were considered as having some potential capacity for the provision of additional planned caravan and/or camping facilities without general detriment to their landscape character. 6.8 Observations on existing sites affecting landscape character led the Study to recommend remedial landscape treatments, and identified the most appropriate locations (from a landscape perspective only) for any expansion of existing sites/development of new sites. 6.9 The following points summarising the key landscape and visual issues arising from existing caravan sites: - Massing – caravans frequently packed into fields with no internal structure planting to break up the mass; caravans and chalets are often sited had up against the boundaries, affording no buffering effects against adjacent land. - Stacking of units up hill sides increasing the incongruous and intrusive landscape and visual effects that can occur. - Creation of an urban-type sprawl, with no defined settlement edge - Creation of significant light pollution in otherwise ‘dark-sky’ areas - Pale colours and reflective finishes which draw the eye and stand out in contrast to the muted colours of land or vegetation backdrops - Sites not being assimilated into the surrounding topography, or sited poorly without suitable landform design as mitigation - No use of natural or planted screening. Where vegetated boundaries do exist – these are often in poor condition, poorly managed and lacking hedgerow trees and appropriate evergreen components - Sited too near to the coastal edge so that they form the skyline in coastal views, especially when viewed from lower elevations such as on beaches and lower cliff paths - Over-engineered entrances which are discordant in relation to local landscape character or scenic quality 6.10 This provides important background evidence to support the Council’s policy position and attempts made over many years with caravan and camping 13 | P a g e
operators (for example the Caravan and Camping Task Group) to reconcile their demands for growth with landscape protection. 7.0 Legislation: Control Over Caravan and Camping 7.1 The legal basis for local authority control over caravan and camping sites is complicated by the fact that two different forms of control operate in tandem: that based on the Town and Country Planning Act 1990 and that derived from the Caravan Sites and Control of Development Act 1960 (The ‘1960 Act’). The Mobile Homes (Wales) Act 2013 does not apply to holiday or touring caravan sites, although it does affect mixed use sites, i.e. sites used for a combination of residential and holiday purposes as far as the residential parts are concerned. 7.2 Historically the Government did not consider it necessary to apply many conditions restricting caravan site development or unit numbers, and little control was possible over changes within established sites, many of which dated from the pre-war period. Some regulation was possible under the Public Health Act 1936, but operators of caravan parks, be they for residential or holiday purposes, enjoyed relative freedom from public control. The UK experienced a boom in camping and caravanning in the late 1950s but many sites were of a poor standard and it was considered that planning regulations were inadequate to deal with the problem so a system of site licensing was introduced via the ‘1960 Act’. 7.3 The original definition of a “caravan” in the ‘1960 Act’ includes “any structure designed or adapted for human habitation which is capable of being moved from one place to another (whether by being towed, or by being transported on a motor vehicle or trailer) and any motor vehicle so designed or adapted, but does not include - (a) any railway rolling-stock which is for the time being on rails forming part of a railway system, or (b) any tent” 7.4 This definition was amended by the Caravan Sites Act 1968 to embrace double-unit mobile homes but size maxima were set. 7.5 The Town and Country (General Permitted Development) Order 1995 (GPDO) defines a “caravan site” as meaning land on which a caravan is stationed for the purpose of human habitation and land used in conjunction with land on which a caravan is so stationed 7.6 Caravan sites require both a planning permission and a site licence, unless exempted under the 1960 Act. Exemptions from site licensing, are stated in Section 2 Schedule 1 of the 1960 Act to apply in the conditions summarised below: 1 if the use as a caravan site is incidental to the enjoyment as such of a dwellinghouse within the curtilage of which the site is situated; 2 if the use of land as a caravan site is by a person travelling with a caravan who brings the caravan onto the land for not more than 2 nights, provided 14 | P a g e
no other caravan is stationed on the land and that the number of days in any year that this takes place does not exceed 28; 3 it the site is over 5 acres and for not more than 3 caravans, and not so used for more than 28 days in the past year; 4 if the site is occupied and supervised by an exempted organisation (such as the Caravan Club and the Camping Club of Great Britain); 5 if the site is used by not more than 5 caravans and approved by an exempted organisation; 6 if meetings occur of not more than 5 days duration organised by an exempted organisation; 7 if the use is for a caravan site for the accommodation of persons engaged in farming during a particular season; 8 if the use is for a caravan site for the accommodation of persons engaged in forestry during a particular season 9 if the caravan site is used for the accommodation of persons employed in connection with building or engineering operations; 10 if the site is used by bona fide travelling showmen for the purposes of his business or for winter quarters; (note: the use of land as winter quarters is not permitted development authorised by the GPDO); and 11 if the site is occupied by a local authority or as a local authority gypsy site. 7.7 The GPDO and Schedule 1 to the Caravan Act 1960 together allow the following permitted development: - Use of land by a person travelling with a caravan for one or two nights, up to an annual limit of 28 days on that or any adjoining land; - Use by up to three caravans for up to 28 days a year on holdings of 5 acres or more; - Use of any land for up to five touring caravans at once by members of the Caravan Club, the Camping and Caravanning Club and other recognised recreational organisations; - Stationing a caravan on agricultural land to accommodate a person or persons employed in farming operations ‘during a particular season’; - Use of land as a caravan site for the accommodation of workers employed in carrying out building or engineering operations; and - Use of land as a caravan site by a travelling showman who is a member of an organisation of travelling showmen which holds a certificate and who is travelling for the purpose of his business. 7.8 Planning permissions should be issued mainly on the basis of the principle of the use of the land and its external effects, and that site licenses should be concerned with internal arrangements. However associated operational development of electrical hook-ups, hardstandings and water stand pipes are not permitted development and require planning permission, whereas site layout and amenity provision required by a license are permitted development in the absence of any conditions to the contrary on a planning permission. 15 | P a g e
The Article 4 Direction 7.9 A report of the Director of Planning to the Chairman and members of the Planning Committee, 15th March 1977 of the then Swansea City Council highlighted the problems of unregulated tent and caravan sites on Gower and recommended that the Council apply to the Welsh Office for a Direction under Article 4 of the General Development Order 1977. The Article 4 Direction was requested in relation to the environmental impact of uncontrolled camping and caravan expansion within the AONB, particularly visual impact and traffic congestion. A further factor which increased the detrimental impacts of camping and caravanning were that some land owners were frequently allowing camping and caravanning on their land longer than allowed under permitted development rights. 7.10 The Article 4 was sought for the AONB as a whole rather than selected pressure areas, as otherwise the pressures would simply be shifted from the areas where controls applied to areas which were less congested (at the time). The impact on the southern and western coastal areas, which form part of the Heritage Coast, was viewed as particularly problematic, as the majority of camping and caravan sites are located in attractive and vulnerable coastal areas. The prime consideration was that existing and future levels of tent and caravan development were of a scale and nature which did not significantly detract from the quality of the area and could be adequately accommodated in Gower. 7.11 The Article 4 Direction was confirmed on 19th December 1979. The Welsh Office accepted that the heavy camping pressures and abuses of permitted development rights justified the removal of permitted development rights and the bringing of the uses previously granted permission by the General Development order back within normal planning control. The benefits of Class XXII and certain benefits of Class IV of Schedule 1 of the General Development Order 1977 were withdrawn thereby necessitating a planning application to be made. The withdrawal of the benefit conferred by the Order and of the exemptions under the Act of 1960 is regarded as an exceptional course of action to be taken only in the most compelling circumstances, where specific control over development is required, primarily where the character of an area of acknowledged importance would be threatened. 7.12 It was accepted that the benefits conferred by paragraphs 2 and 3 of the GDO Class XXII: “..has proved to be both difficult to monitor and impossible to enforce and is therefore frequently abused... In view of the need to avoid the scattered location of caravans in the Gower and the fact that the limit on caravanning is often exceeded it is considered that these paragraphs should be covered by the Direction.” 7.13 In relation to Paragraphs 4 and 5: “The original intention was to avoid the need to place undue restrictions on bodies which could show themselves to be responsible and were thus in a position to relieve the local authority of a considerable administrative burden. 16 | P a g e
In general this still holds good although there is some evidence that sites permitted under paragraph 5 do sometimes exceed their limits, but taking into account the serious problems created for the Area by the heavy camping usage there is need for the Council to be given overall control of caravan sites and the view is taken that the Direction should be approved in relation to paragraphs 4 and 5” 7.14 In relation to paragraph 6: “It is accepted that there is some evidence of a problem of “over-rallying”. It is noted that means of resolving this problem have been suggested but the view is take that against the background of the general camping pressures in the Gower Peninsula the best solution is to bring rallying within the normal planning control. Accordingly this paragraph should also be covered by the Direction.” 8.0 Evidence Gathering 8.1 In order to meet the requirements of paragraph 12 of TAN 13, the Council reviewed data relating to caravan and camp sites within the County and sought to collect new evidence to inform the LDP. Caravan and Camping Task Group 2005-2006 8.2 A Caravan and Camping Task Group was established following a meeting of the Culture, Recreation and Tourism Cabinet Advisory Committee with caravan site operators on 15th February 2005. The Group consisted of representatives from site operators, Swansea Tourism Trade Association and the City and County of Swansea and met on a number of occasions between 2005 and 2006. The group re-established as a Caravan and Campsites Consultative Forum in 2006 but ceased to meet. 8.3 The Task Group agenda largely reflected the views and requirements of those operators who were represented, including: - A request to remove the Article 4 Direction on established sites; - A review of planning policies through the UDP process and preparation of SPG; - Obtaining accurate up to date baseline data about supply; - Site visits to Gower and sites in West Wales; - In addition the Task Group gave the opportunity for a number of operators to bring specific planning problems/development control issues to the attention of Council staff and enabled planning officers to explain policy and encourage operators to work within the planning system. 17 | P a g e
City and County of Swansea Tourism Scrutiny Panel, 20136 - 20147 8.4 In recognition of the importance of the tourism to the County’s economy, the Scrutiny Work Planning Conference chose to undertake a review of the sector to ensure that the Council was making the most of promoting and aiding the tourism sector. The main aim and resulting inquiry question for the review was: ‘Are we making the most of Swansea’s potential as a destination for tourists including maximising the economic benefits for Swansea?’ 8.5 The Panel reviewed evidence documents, met with industry and Council representatives and undertook site visits. The Panel made 14 recommendations to Cabinet including a need to address seasonality, and the encouragement of a higher spend market by upgrading the quality of local holiday accommodation. The findings of the Inquiry were reported in 2014. 8.6 A survey was conducted amongst trade/providers in 2012, which identified the beaches, landscape/scenery and Gower as the top three most valuable assets from a tourism and trade perspective. The Tourism Trade body considered that the planning process was very restrictive in some areas, preventing some businesses from growing and improving quality. The Panel felt there needed to be a better balance between planning requirements/restrictions and possible potential for economic growth. Inquiry fed into the evolving Destination Management Plan. STEAM Data 8.7 Since 1992, the County has been using the Scarborough Tourism Economic Activity Monitor (STEAM) to monitor the scale of tourism and trends in the County. STEAM quantifies the local economic impact of tourism from both staying and day visitors by factoring in figures such as bed stock analysis and accommodation offer, revenue and visitor estimates, and amount of employment supported. This Model is used by all 22 Welsh Unitary Authorities and the 3 National Parks in Wales, so can provide a meaningful comparison of the value of the tourism economy between counties. STEAM approaches the measurement of tourism at the local level from the supply side, which has the benefit of immediacy and relative inexpensiveness. STEAM is not designed to provide a precise and accurate measurement of tourism in a local area, but rather to provide an indicative base for monitoring trends. 8.8 The following table provide a seven year summary comparing expenditure, revenue, number of tourist days, tourist numbers and employment by sector for the County. STEAM analysis for the County between 2004 and 2015 can be 6https://www.swansea.gov.uk/media/1063/Tourism-in-Swansea-Are-we-making-the-most-of- Swanseas-potential-as-a-destination-for-tourists/pdf/04Ai_- _FINAL_COPY_Final_review_report_template_2012-13_FINAL_7_May.pdf 7https://www.swansea.gov.uk/media/9185/Tourism-Inquiry-Panel-Follow-up---Meeting-agenda-pack- 17-November-2014/pdf/Tourism_Follow_up_agenda_pack_Nov_14.pdf 18 | P a g e
found on the Council’s website8. Tourism numbers increased once again in 2016, however tourism expenditure fell slightly against 2015, but is still increased on 2007-2014 figures. 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 Tourism 328.4 339.0 335.1 346.4 348.4 337.1 390.3 390.3 401 400 Expenditure (£’s millions) Tourist 3,817 4,102 4,112 4,104 4,235 4,182 4,470 4.47 4.5 4.6 Numbers (Millions) Number of 5,184 5,341 5,398 5,539 5,602 5,390 5,910 5,910 5.7 5.6 FTE jobs supported by tourism spend (Thousands) Bedspace Data 2016 8.9 The latest accommodation bedspace figures supplied by the Tourism section of the Council are shown in Table 2. It is a live database, updated as and when information is received by the Council and is correct to date. The table clearly identifies that caravan and camping is the largest accommodation offer within the County. Table 2: Number of Establishments and Bedspaces in Swansea 2014 and 2017 Number of Number of Bedspaces Establishments Year 2014 2017 2014 2017 Serviced 166 157 5,916 6055 Non-Serviced 367 383 4,424 4822 Caravan and Camping 53 54 21,355 21,401 TOTAL 586 594 31,695 32,278 8.10 Since the adoption of the Unitary Development Plan in 2008 to December 2017, the total number of new tourist accommodation bedrooms created through the conversion of existing buildings, barn conversions, change of use, or new build holiday accommodation granted planning permission within the County was 185 (of these 80 were within the AONB). The figure includes planning permissions granted but not implemented, such as 80 golf lodges at Royal Fern. The total number of hotel bedrooms granted planning permission within the County over the same period within the County is of 521 bedrooms (although some permissions have not been implemented, such as for a 42 bedroom hotel at Fairwood Park Golf Course, Gower). 8 http://www.swansea.gov.uk/media/20030/STEAM-Analysis-2004-2015/pdf/Headlines_04-15.pdf 19 | P a g e
NUMBER OF CARAVAN AND CAMPING SITES AND PITCHES Tourism Swansea Bay Survey 2006 – Number of Pitches 8.11 In 2006, the Caravan and Camping Task Group agreed a set of baseline data for existing camping and caravan provision within the Gower AONB (excluding rallies). Council Site licensing figures and a survey undertaken by Tourism Swansea Trade Association were compared in order to reach agreement (the results can be viewed in Table 3). The table did not include all sites and is not an accurate record of the numbers of units in the County at that time. It does however, demonstrate the disparity between the permitted license numbers and surveyed number of units at the time. Latest Figures 2017 8.12 In order to provide accurate figures to inform the LDP, caravan and camping planning application and permissions have been reviewed and sites within the County are listed in Table 4. The table shows the number of caravan and camping units permitted or licensed within the County is 5795 units, comprised of static caravans, touring caravans (including seasonal pitches), tents, yurts and glamping pods. Permitted licensing figures are also shown on the table, together with the results of the Gower Society Aerial Survey undertaken on the 19th August 2017 and information obtained from operators’ websites. 8.13 Some 5396 units are located within the Gower AONB, with almost half being static caravan provision (2322). The majority of these static caravans are not available as short term holiday let, but are privately owner occupied (e.g. Grenways, Bank Farm, Whiteford Bay, Nuttalls, Newpark, Llanrhidian Holiday Park, Hillend, Carreglwyd, Burrows, Broughton Briarwood, Blackhillls, Fairfield and the Beeches). They are not therefore available to meet short term demand. 8.14 The number of small sites (i.e. 10 units or less) has increased, offering 141 pitches in 2017 (increasing from 85 in 2000 and 90 in 2006). Many of the small sites are certified locations and these offered 85 pitches throughout the AONB in 2017. 8.15 The caravan and campsite total excludes the residential ‘Park Home’ sites of Mill Gardens, Balckpil, Oaklands Park, Ystrad Road, Cannistan Park, Parkmill, and Woodland Park, Swansea Road. It does, howeve,r include sites with established use certificates for 12 month holiday or residential use: Bank Farm (2 fields), Greenways (fields 93 and 158), and Whiteford Bay Holiday Park. Furthermore, a planning application is currently being determined for a seasonal motorhome/caravan site for 8 vehicles in Swansea Marina. 8.16 Table 4 clearly shows that, in most cases, sites are clearly operating within their permitted numbers, with a very small number exceeding. The table also indicates that not all sites are ‘full to capacity’ as stated by many operators in response to the caravan and campsite operator surveys, though it is recognised 20 | P a g e
that the aerial survey is a ‘snapshot’ and numbers may well increase or decrease on site. Nevertheless, aerial surveys undertaken over repeated years indicate that capacity exists on sites. The industry is obviously weather dependant and visitor numbers vary considerably depending on the weather. The Council recognises that operators need to respond to an influx of visitors due to good weather and the Policy of allowing temporary ‘overflow’ areas on sites for visitors who have not pre-booked, is a way to ensure sudden demand can be met. 8.17 Many sites, particularly the large static caravan sites, are deemed ‘Established Uses’. Without the cooperation of site owners and operators there is little that the planning regime can do in order to influence their design and layout and improve their landscape impact, so policies which allow for a small increase in numbers in association with reduced densities and improved landscaping seek to address this issue. 21 | P a g e
Table 3: Caravan and Camping Task Group 2006 Agreed Baseline Data (A) CCS LICENSE RECORD (as agreed 2006) (B) TSTA SURVEY (as agreed 2006) (C) PROPOSED FIGURES (as shown in Committee Report Feb 2006) SITE NAME STATICS SEASONAL TOURING STATICS SEASONAL TOURIING STATICS SEASONAL TOURING TOURERS UNITS TOURERS UNITS TOURERS UNITS 1. BANK FARM 100 230 100 70 201 100 70 201 2. BAYHOLME 10 10 10 3. BAYVIEW FARM 5 5 5 4. BEECHES FARM 7 7 7 5. BLACKHILLS 120 90 170 170 6. BRIARWOOD 20 20 20 7. BROUGHTON 250 250 259 8. BURROWS 86 86 86 9. CARREGLLWYD 82 198 94 180 94 180 10. EASTERN SLADE 20 20 20 11. FAIRFIELD 62 62 62 12. GOWER FARM 100 30 70 100* 13. GOWER HOLIDAY VILLAGE 12 12 14. GREEN MEADOW 106 106 106 15. GREENWAYS 100 430 118 70 115 85 16. HIGHFIELD 137 112 106 112 106 112 17. HILL END 250 250 256 250 250 250 18. HORTON FARM 151 150 150 19. KENNEXSTONE 240 80 20. LLANRHIDIAN 197 220 340 240 21. LLANMADOC 275 30 250 30 250 22. NICHOLSTON FARM 25 95 25 23. NEWPARK 257 172 172 24. NORTON FARM (1&2) 8 8 8 25. NUTTALS 35 35 35 26. OXWICH BAY 10 10 10 27. OXWICH BAY CAMPING PARK 180 180 180 28. PITTON CROSS 100 19 81 19 81 29. RIVERSIDE 132 132 100 210 132 100 210 30. SEALANDS 12 12 12 31. SCURLAGE CASTLE 5 5 5 32. THREE CLIFFS 95 95 95 33. WHITEFORD BAY 245 240 240 34. GOWERTON 130 TEMPORARY CONSENTS 90 TOTALS 2110 2602 2302 373 2134 2202 343 2169 4712 4809 4624 22 | P a g e
Table 4: Caravan Original Figures (2006) updated to include Aerial Survey August 2017 and Campsites in any permitted increase in numbers since that date the City & County of Swansea SITE statics Touring Seasonal other total statics Touring units Seasonal other total Licensing Website Information units tourers tourers Bank Farm, Horton 100 70 201 400 100 100 101 Rally for 301 230 tents/ 230 caravans Seasonal touring pitches (approx.) (approx.) 70 units & (1 January - 1st March – 6th January permitted 28 31 December) (Some located on on this in 2 glamping pods rally fields where date (28 rally no rally permitted units sited on this date) during survey) The Bank Farm, 5 5 5 caravans (1 April-31 Scurlage October) The Barn, Tycoed Farm, 5 Caravan and Motorhome Stembridge Certified Location. Members Only Barraston Hall, 5 5 Caravan Club Certified Llangennith Location Member Only Bayview Farm, Overton 5 5 5 caravans (1 April-31 October) Beach Walk Park, 10 10 10 statics (1 January - Oxwich Bay 31 December) Beeches The, Horton 7 7 7 statics (1 April-31 October) Blackhills Caravan Park, 196 196 196 Statics (1st March – No commercial letting. Blackhills 31st October) 1st March – 1st December Blackhills Lane, Field 5 5 7 statics (1 March - 7924, Fairwood 31 October) Briarwood Caravan 25 25 20 statics (1 April-31 Park, Reynoldston October) Broughton Farm 259 259 255 250 statics (1 January - Caravan Park, 31 December) Llangennith Burrows Caravan Park, 86 86 87 86 statics (1 February - Horton 31 November) Carreglwyd Farm 94 494 95 130 (approx.) 39 264 400 caravans/tents A total of 400 pitches for Caravan Site, Port (1 January - tents/caravans Eynon 31 December) Separate license for static Channel View, Port 3 3 3 static caravans For sale. 12 month Eynon occupation 23 | P a g e
Table 4: Caravan Original Figures (2006) updated to include Aerial Survey August 2017 and Campsites in any permitted increase in numbers since that date the City & County of Swansea SITE statics Touring Seasonal other total statics Touring units Seasonal other total Licensing Website Information units tourers tourers Eastern Slade Farm, 10 10 5 caravans/20 tents Slade (mixed) (1 January - 31 December) Eastmoor Farm, 5 5 Caravan Club Certified Rhossili location Members Only Fairwood Corner Farm 5 5 Caravan Club & Caravan and Motorhome Club Certified location Members Only Fairfield Caravan Park, 62 62 57 57 62 caravans (1 March - No commercial letting. Southgate 31 October) Gelli Hir Farm, Three 5 5 Crosses Gower Farm Caravan 100 100 164 (many 164 100 caravans (1 April - Seasonal pitches Park, (Llandewi Farm) seasonal?) 31 October) available Reynodston 10 tents Gower Holiday Village, 19 19 3 tents 20 Static 24 12 caravans (1 January - Scurlage 1 touring caravan tourers 31 December) (removed in winter) Gowerton Caravan Club 130 130 Site, Gowerton Great Lunnon Farm, 5 5 Caravan Club & Caravan Parkmill and Motorhome Club Certified location Members Only Great Meadow Caravan 106 106 100 1 vacant 100 106 statics (1st April – 31st Open 1st March – 10th Park, Oxwich base October) January Greenway, Oxwich 119 430 549 117 83 (approx.) 2 vacant 430 tents (1 March - tourers mix bases 31 October) and tents/campervans 100 statics (1 January - 31 December) Heather Brae, Penmaen 5 5 Caravan Club & Caravan and Motorhome Club Certified location Members Only Highfield 106 112 218 102 131 (approx.) 112 caravans/ 137 statics tents/campervans (1 April - 31 October) 24 | P a g e
Table 4: Caravan Original Figures (2006) updated to include Aerial Survey August 2017 and Campsites in any permitted increase in numbers since that date the City & County of Swansea SITE statics Touring Seasonal other total statics Touring units Seasonal other total Licensing Website Information units tourers tourers Hillend Caravan Park 250 250 500 264 130 (approx.) 250 tents/ 250 statics 300 tents /motorhomes tents/campervans (1 April - 31 October) 250 statics (1st March – 30th October) Hillside, Llangennith 6 6 Horton Farm Caravan 150 150 149 151 statics (1 March - Park, Horton 31 December) Ivy Cottage Farm 5 5 Caravan Club & Caravan and Motorhome Club Certified location Members Only Kennexstone Farm, 240 240 7(lodges/pods) 100 (approx.) 11 118 240 pitches Kennexstone mixed tents/vans (approx.) ‘pods’ and shepherds huts/lodges Lagadranta Farm, 250 30 280 1 36 250 tents (1st April – 30th (Llanmadoc Camp site) Sept) 25 caravans (1st March – 31 October) Little Reynoldston Farm, 5 5 Caravan Club & Caravan Reynoldston and Motorhome Club Certified location Members Only Llanrhidian Holiday 378 378 359 10 vacant 196 statics (1 April - Park, Llanrhidian bases 31 October) Mewslade View,Rhossili 5 5 Caravan Club Certified location Members Only Moor Corner Farm, Port 5 5 Eynon Mumbles Hill Caravan 63 63 Site, Mumbles Nant y Wrach, 5 5 Caravan Club & Caravan Llanrhidian and Motorhome Club Certified location Members Only Newton Lodge, Rhossili 5 5 Caravan Club Certified location Members Only 25 | P a g e
Table 4: Caravan Original Figures (2006) updated to include Aerial Survey August 2017 and Campsites in any permitted increase in numbers since that date the City & County of Swansea SITE statics Touring Seasonal other total statics Touring units Seasonal other total Licensing Website Information units tourers tourers Nicholston Farm, 120 120 1 static and 2 107 (approx.) 25 caravans (1 April - Penmaen glamping units tents/motorhomes 31 October) 26 caravans North Hills Caravan 95 95 29 (approx.) 6 yurts 121 75 tents/20 caravans Park, Penmaen touring caravans (1 April – 31 October) 86 tents (approx.) Newpark Holiday Park, 1 172 173 92 8 tents 145 tents/ 112 caravans Port Eynon (1 April - 31 October) 1 Norton Farm, Oxwich 5 5 6 1 5 caravans (20 March - 30 September) 2 Norton Farm, Oxwich 5 5 3 3 caravans (1 April - 31 October) Nuttalls Caravan Park, 35 35 35 statics (1 January - Horton 31 December) Oldwalls, Llwynbwch 10 10 Farm, Oldwalls Orchard Park Farm, 5 5 Caravan Club & Caravan Llanmadoc and Motorhome Club Certified location Members Only Oxwich Bay Camping 180 180 180 tents (1 April - Park, Owxich 31 October) Pantlasau Isaf Farm, 3 3 Llangyfelach Perriswood Farm, 5 5 Caravan Club & Caravan Nicholston and Motorhome Club Certified location Members Only (awaiting certification renewal) 26 | P a g e
Table 4: Caravan Original Figures (2006) updated to include August 2017 and Campsites in any permitted increase in numbers since that date the City & County of Swansea SITE statics Touring Seasonal other total statics Touring units Seasonal other total Licensing Website Information units tourers tourers Phillistone Farm, 5 5 Llanmadoc Pilton Moor Stables, 5 5 10 6 4 Seasonal pitches Pitton Cross, Rhossili shepherd available huts Pitton Cross Farm, 81 19 100 11 (shepherds 23 caravans and 100 tents/ caravans Rhossili huts) 26 (approx.) tents (mixed) (1 January - 31 December) Riverside Caravan Park, 252 120 372 210 caravans/ 132 statics Ynysforgan (1 March - 31 December) Sealands Farm Caravan 12 12 15 1 vacant 12 statics (1 April - Park, Oxwich base 31 October) South Gower Sports 5 5 Club Springfield, Crickton 5 5 Caravan Club & Caravan Farm and Motorhome Club Certified location Members Only (awaiting certification renewal) Stavel Newydd (formerly 5 5 Caravan Club & Caravan Dene), Llanrhidian and Motorhome Club Certified location Members Only Stembridge Farm, 5 5 Caravan Club & Caravan Llanrhidian and Motorhome Club Certified location Members Only Sunnyside Farm, 5 5 Llandewi White Springs, 6 18 24 Pontarddulais Whiteford Bay Leisure 245 245 240 245 statics (1 March - Park, Llanmadoc 31 December) TOTAL 2580 5795 In Gower AONB 2322 5,051 27 | P a g e
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