Testun llawn:
Following the representations made in 2020, Seasons Holidays plc welcomed the report made to the County Council in January 2021, that presented the proposed focused changes to the Deposit Plan and which included the proposed allocation of part of the expansion land to the east of the existing Dylan Coast Resort (Phase 1 expansion). Seasons Holidays welcomes the subsequent formal inclusion of phase 1 expansion as a mixed use allocation through draft Policy SeC20/MU1, within the second Deposit Plan. However, they are disappointed to see that Phase 2 of the proposed expansion has not been included within the second Deposit Plan.
As a result, phase 2, which delivers 160 high quality year round units of holiday accommodation could only be delivered against policy, without the added certainty an allocation brings. Without certainty like this, it limits Dylan Coastal Resort’s ability to assist the Council in meeting its policy objectives for growth of the tourism industry. Phase 2 would result in significant economic benefits to the economy of Carmarthenshire including:
• c. 118 direct (plus c. 13o indirect spin off) jobs during construction
• £6.4 million of direct GVA generated per annum through construction (plus £7.7 million indirect)
• £3 million in direct (on and off site) spending per annum;
• £1.4 million in indirect spending per annum;
• c. 53 new direct jobs (and c. 25 indirect job) during operation; and
• Operation GVA of £1.6 million per annum
Failure to allocate means these may not be
delivered and the policy targets cannot be evidenced as being able to be met.
Future Wales; the national plan 2040
Future Wales, the National Development Framework (NDF), sets out a direction of travel for growth in Wales, with an active support for the tourism industry, given its vital contribution to local economies. The Framework sets out 11 outcomes that are overarching ambitions of the NDF, of which outcome 6 is a direct requirement on Development Plans to have a:
“…forward thinking, positive attitude towards enabling economic development, investment and innovation. Increased prosperity and productivity will be pursued across all parts of Wales, building on current activity and promoting a culture of innovation, social partnership, entrepreneurialism and skills-development in sustainable industries and sectors. The culture, heritage and environment of Wales will play a positive, modern role in the economy by attracting the interest and expenditure of tourists, and providing a distinctive and trusted brand for Welsh businesses.” (pg. 55)
Policy 29 of the NDF, focuses on the region of Carmarthen and the Haven Towns, and identifies the very important role tourism plays in the local economy. Noting that Local Development Plans should support and facilitate growth of these activities:
“The South West supports a large and diverse tourism industry and the sector is important to the region’s economy. Opportunities to develop the visitor economy, to promote the world-class coastal areas and beaches and major leisure attractions should be explored. The national parks are a major asset for the region, attracting visitors from around the world. Strategic and Local Development Plans should consider the main existing and potential new tourism areas, the type of visitors they attract and the infrastructure required to support growth. They should provide a positive framework to enable growth and ensure that communities across all parts of the region are able to benefit from their landscapes, natural and historic environment, heritage assets and visitor attractions to support and grow their economies. It is important the region’s distinctive heritage is preserved and enhanced by high quality development.” (pg. 149-150)
The value and importance of tourism to Wales (and Carmarthenshire) and the need to plan effectively for it is at the heart of the Welsh Government’s strategic thinking.
Planning Policy Wales and the Technical Advice Notes
Planning Policy Wales
Planning Policy Wales 11th Edition (2021) (PPW), supplemented by Technical Advice Notes, sets out land use planning policies for Wales and provides a national planning policy framework for Wales. The primary function of the document is to ensure that “the planning system contributes towards the delivery of sustainable development and improves social, economic, environmental and cultural wellbeing of Wales”.
PPW, through a series of key themes, seeks to guide plan making and decision taking to meet its overall objectives. Among these themes is the ‘Productive and Enterprising Places’, which seeks to maximise the economic potential of Wales through placemaking.
This section of PPW acknowledges the important role that tourism plays in the Welsh Economy, reflecting the NDF. Tourism is integral in creating a resilient and more equal Wales as well as in supporting our vibrant culture and Wales’ distinctiveness (pg. 74).
PPW also puts a requirement on Local Planning Authorities to ensure that they are “capitalising on our distinctive tourism offer to promote Wales to the world, creating high quality jobs in this sector which enhance skills and provide employment year-round” (pg. 75)
Section 5.5 of PPW deals specifically with tourism. This section defines Tourism as being “vital to economic prosperity and job creation” (para 5.5.1) and emphasising that the planning system should “encourage tourism where it contributes to economic development” and support the continued success of existing tourist areas (para 5.5.2).
The section concludes by setting a clear direction to Local Authorities:
“Planning authorities should provide a framework for maintaining and developing well-located, well designed, good quality tourism facilities. They should consider the scale and broad distribution of existing and proposed tourist attractions and enable complementary developments such as accommodation and access to be provided in ways which limit negative environmental impacts as well as consider the opportunities to enhance biodiversity” (Para 5.5.6)
TAN 13: Tourism
Whilst approaching 25 years old, TAN 13 still provides additional guidance on tourism in support of PPW. The document broadly echo’s PPW, as well as the WSP and the NDF, highlighting the important role tourism plays. For example:
“It makes a major contribution to the Welsh economy, provides employment in a wide variety of occupations and can bring benefits to local economies and communities in urban and rural areas” (para 4).
The same Paragraph also notes that development plans can provide guidance on opportunities for large scale or innovative projects and/or appropriate facilities for the countryside.
TAN23: Economic Development
TAN 23 provides guidance in economic development principles more generally. It requires Local Authorities to prepare an economic vision in their Development Plan, as per para 4.3.1 below:
“In producing Local Development Plans, planning authorities are expected to develop a broad vision for their Plan which must be consistent and coherent so that the economic, social and environmental considerations support each other and point in the same direction. The economic vision must therefore be consistent with other aspects of the Local Development Plan such as housing and transportation. An economic vision is part of the LDP vision; it is not separate to it. The vision should also be consistent with the aims of other local authority strategies such as the Community Strategy and Single Integrated Plan…”
TAN 23 also requires that “Local planning authorities should recognise market signals and have regard to the need to guide economic development to the most appropriate locations, rather than prevent or discourage such development.” (para 1.2.5)
TAN 6: Planning for a Sustainable Rural Community
TAN 6 provides more specific guidance on how Local Authorities should plan for the prosperity of their rural communities. Tourism being one such enterprise that forms an important part of the rural economy. As per para 3.1.2, Local Authorities should support diversification, particularly where it creates local jobs and improves the local economy. The documents also note that when opportunities arise, Local Planning Authorities should support the expansion of existing businesses in rural areas including where they are located in the open countryside (para 3.1.3).
Carmarthenshire’s Corporate Strategies
At a local level, the strategy for growth in Carmarthenshire is set via a series of specific corporate strategies and plans.
Carmarthenshire’s Corporate Strategy (updated April 2021), sets the Councils overarching strategy for growth through a series of well-being objectives and should be used to guide the strategic objectives of the Development Plan. The Strategy, through well-being objective 6 ‘Live well – create more jobs and growth throughout the County’, sets a framework for promoting economic growth, opportunities for the workforce and investing in the infrastructure that connects the County to encourage tourism.
Further to the Corporate Strategy, Carmarthenshire has a Strategic Regeneration Plan (2015-2030). The Plan provides more detail on the growth objectives and strategies for achieving them. Tourism and the leisure industry feature highly within the regeneration strategy (pg 20), which employs 5,500 full time equivalent jobs throughout the County, noting that “A strong tourism industry and visitor economy will support a more prosperous economy overall and will help to sustain existing and create new jobs”.
The strategy sets out 5 key priorities to achieve economic growth in tourism as follows:
i. Raising the profile of Carmarthenshire
ii. Improving the tourism infrastructure
iii. Enhancing the tourism experience
iv. Enhancing the Sense of Place
v. Invest in people
With the vision summarised as:
“To develop a prosperous visitor economy in Carmarthenshire based on its unique strengths and character, which generates higher spend and local income, enhances its image and reputation and improves the quality of life for local communities”
The strategy also identifies the Coastal Belt in Carmarthenshire (within which Laugharne sits), as being integral to the growth in tourism with the core objectives being:
“General increases in visitors; square footage; quality offerings and visitor spend are the main objectives along the belt.”
The focus on Tourism is working for the Council, with over £400m generated in the Carmarthenshire economy by tourist in 2021, with a 50% increase in economic impact on the preceding decade .
Second Deposit Plan Policy approach
The Second Deposit Plan promotes tourism development though Strategic Objective 13 and Strategic Policy SP11. The policy supports development related to the visitor economy and acknowledges the very important role tourism plays in the economy of Carmarthenshire County. Despite this (and the clear national and strategic acknowledgement of tourisms importance) allocation ref: SEC20/MU1 (at Dylan) is the only tourist accommodation led allocation in the Plan and has been curtailed by the failure to promote phase 2. This amounts to an allowance, in the plan period, of c. 100 additional accommodation units in an industry that grew by 50% in the last 10 years. It is simply not sufficient to support objectives.
Failure to optimise the delivery of visitor accommodation, in a logical location, in the emerging Plan that is located on a deliverable site with a willing landowner and experienced operator means that the Plan is inconsistent with national Policy and its own Strategic growth objectives.
The policy that supports SP 11 (Policies VE1-VE4) set a series of requirements on tourism development proposals. The Policy is not positively worded and does not offer sufficient confidence or certainty that new visitor accommodation scheme (or extensions to existing) will be acceptable. It cannot be readily relied upon to deliver the growth required to meet SO13 and SP11, and therefore if Phase 2 is not allocated it significantly reduces the chances of it coming forward and will likely stifle the Plans ability to deliver on its objectives.
The failure to include Phase 2 within allocation ref: SeC20/MU1, means the Plan would fail to meet its own strategic objectives for growth of the tourism industry, would not be supported by credible and robust evidence, would not be positively prepared nor sufficiently aspirational, it will fail to be effective nor will it be sufficiently flexible.
On this basis, it would fail to meet the test of soundness as set out in Development Plans Manual.
