These representation been prepared on behalf of Seasons Holidays plc in response to the Second Revised Carmarthenshire Deposit LDP (2018 – 2033) consultation which is inviting responses until 14th April 2023. This letter concerns land owned by Seasons Holidays plc which includes the existing Dylan Coastal Resort and adjoining land, which is detailed in the plan in Appendix 1.

Seasons Holidays Plc made representations in March 2020 to the first deposit LDP which sought the ‘mixed-use’ allocation of the land adjoining Dylan Coastal Resort to enable the delivery of an extension to the existing park consisting of high quality visitor accommodation alongside ancillary leisure uses, recreation space and a new principal access road.
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, Seasons Holidays have instructed Lichfields to prepare representations to the second Deposit Plan on their behalf, objecting to the failure to allocate phase two. Ultimately, the decision not to allocate phase 2 is not supported by credible evidence, it means that the Plan fails to contribute to the achievement of sustainable development, does not have sufficient flexibility and will fail to be effective. The Second Deposit Plan is neither appropriate nor will it deliver and as such will fail to meet the tests of soundness set out by The Planning and Compulsory Purchase Act 2004 and as detailed by the Local Development Plan Manual.

It is also noted that the draft criteria based policy in respect of tourism has changed very little since the first deposit draft LDP. Whilst these policies are supportive of investment in tourism at a strategic level the detailed policy is less supportive and should be redrafted in a more positive light to encourage investment in the visitor economy, given its strategic importance to Carmarthenshire (Draft policies VE1-VE4).

Seasons Holidays and Dylan Coastal Resort

Seasons Holidays have been operating for over 30 years, providing high quality and high end luxury holiday accommodation in 10 venues globally, employing over 550 staff across their resorts.

The Company began in Laugharne (Dylan Coast Resort), which lies immediately adjacent to the existing Laugharne settlement, outside of the existing development limits. Adjacent to the existing site is an area of vacant farm land (as shown in the plan in Appendix 1) which has recently been brought into the ownership of the Estate.

Dylan Coastal Resort, including the additional land, is bounded to the north by agricultural land. To the east and south of the site lies the Carmarthen Bay estuaries Special Area of Conservation (SAC) and the Taf Estuary Site of Special Scientific Interest (SSSI). To the west is the settlement of Laugharne Town and further agricultural land.

At Dylan Coastal Resort, Seasons Holidays plc have undertaken a series of improvements, refurbishments and new build projects over the last 5 years, under outline planning permission (W/24265 ), including a new central facilities building which houses a restaurant and spa and up to 100 new and refurbished lodges. In combination, the work has resulted in c. £30million of investment in the estate and the creation of 50 new jobs. Seasons Holidays Plc continues to deliver on the planning permission it’s estimated upwards of £30million will be spent in the next 3 yrs.

Dylan Coastal Resort is the only significant site of luxury holiday lodge accommodation in Carmarthenshire that offers this form of high-end, all-year-round visitor accommodation. In fact, in the eyes of Landal Green Parks/Hoseasons, the biggest booking agent in Europe for self-catering higher end holiday accommodation, it ranks as one of the premier visitor accommodation locations in the entire UK and no. 1 in Wales – with a scope to attract guests from all over Europe:

“We are incredibly excited to be partnering with Dylan Coastal Resort and to have it as part of our Landal GreenParks/Hoseasons portfolio. Landal/Hoseasons offer over a hundred of some of the best resorts across Europe, and Dylan represents the first of a next generation of holiday resorts; that offer amazing luxurious accommodation, set in breathtaking surroundings, with first class facilities, and underpinned by a real focus on guest experience to ensure guests have an unforgettable holiday here in the UK.
The Landal/Hoseasons philosophy is very much about holidaying in the heart of nature, but also the local area itself and its important that guests can go and explore the local area as part of their overall holiday experience. Dylan Coastal Resort is blessed with an abundance of activities and places to see locally, to help guests have an amazing holiday experience. We hope the addition of more holiday lodges for rent brings real economic value to the local area by allowing us to send more guests to the resort.
In our opinion, Dylan Coastal Resort is one of the top three resorts in Europe and really puts this part of Wales on the map, making it a destination of choice not just to guests from the UK, but from across Europe.”

Paul Hardingham, Managing Director, UK, Landal GreenParks

On March 25 2020, the applicant made representations to Carmarthenshire County Council Deposit LDP (2018-2033) consultation, in particular requesting the inclusion of land adjacent to Dylan Coastal Resort as an allocation within the Plan for additional tourism accommodation and facilities (see Appendix 2). Officers presented the consultation responses at the County Council meeting on 13 January 2021, including proposed modifications (‘Focused Changes’) to the Deposit Plan. Among the proposed Focused Changes was the allocation of phase 1 of Dylan Coastal Resort expansion (see plan in Appendix 3 for details of phase 1 and phase 2).

This amendment, allocating phase 1 of Dylan Coastal Resort, has been reflected within the second revised deposit LDP with the site now allocated under policy SG1, as site SEC20/MU1. The allocation also includes the existing Dylan Coast Resort. The inclusion of the land within the Plan and officer’s recognition of the clear contribution that the Resort has and can continue to have to the year round tourism and the local economy in Carmarthenshire is welcomed by Season Holidays plc. Phase 1 could deliver in the region of 100 holiday accommodation units.

However, the land constituting phase 2 of the proposed expansion of Dylan Coastal Resort was not included within the proposed allocation, due to concerns over the ability to deliver the site within the plan period. Despite this, when reporting to Council, officers did not challenge the principle of development of phase 2 of the site and it was noted that under the proposed policy adopted within the new LDP (and not amended in the Second Deposit Plan) the subsequent phase would be considered against emerging policy. The report to Council stated:
“…the Plan will be amended to include Phase 1 (to be delivered during the Plan period) as identified within the representation. The remainder of the site as identified within the representation is subject to a longer term deliverable aspiration.

As such there is no certainty on its delivery and will not be included within the Plan. The policy framework set out within the revised LDP allows the potential development for tourism and the visitor economy where it is appropriately located. Any proposal submitted will be considered against the revised LDP policies.”

Phase 2 would comprise of c. 160 units of accommodation alongside a range of ancillary leisure and recreational facilities (see appendix 4 for further details)
Seasons Holidays Plc object to the non-inclusion of the second phase of Dylan Coastal Resorts expansion, particularly in relation to the reasons stated by the officer for its non-allocation which are:

1 Ability to deliver within the Plan Period;
2 Certainty of deliverability of the Phase; and
3 Policy framework being sufficient to enable tourism development.

1. Ability to Deliver Phase 2 within the Plan Period

Seasons Holidays Plc were granted outline permission for the delivery of 212 holiday lodges and 48 serviced apartments in 2012 (ref: W/24265). Since this time, a number of reserved matters applications have been granted in relation to the delivery of parcels of land associated with development of the resort, the most significant of which enabled the delivery of phases C to E in 2017 (ref: W/34546). Since the approval of the RM, approximately 100 units have been delivered on site (or part delivered) alongside a fully operational clubhouse spa.

The current rate of development has seen approximately 3 lodges delivered a month over the period of September to April (off peak). At this rate, it is anticipated that the remaining 40 lodges within the planning permission would be delivered and installed on site by the end of 2024.
To ensure that the site did not have a supply issue, work on Phase 1 (the current draft allocation) would have to begin before all units were delivered on the original site, to allow for a smooth transition (i.e. enabling works would have to begin and be completed in the final year of works to the original permission). Of the anticipated 100 units delivered in phase 1, at a similar delivery rate of c. 25 per year (commencing in 2024), Phase 1 would be fully delivered 4 years later, by 2028.

Working on the same assumption, Phase 2 would have to commence development in 2027, to enable the site to begin the delivery of units once phase 1 was complete. This build out process would then continue for the next six to seven years, with the first lodges on Phase 2 available from 2028. What is clear is that planning permission for phase 2, and the first delivery of units on site would have to commence well within the Plan period (i.e. by 2033) and indeed the entire Phase 2 development would largely be complete within the Plan period.

Given the track record of the delivery of the reserved matters applications on site, there is clear evidence to support the view that Phase 2 will commence before the end of the Plan period and, despite the comments of officers in their report to Council that this is an aspiration without certainty, the development will come forward.

It is considered that the non-allocation of phase 2 of Dylan Coastal Resort will impact on the operators ability to expand during the Plan period to meet the needs of the market. In turn, this will mean that the Council will fail to capitalise on an opportunity to deliver on their own Strategic Objectives (as set out in point 3 below).

2. Certainty of Delivery

Seasons Holidays Plc have so far invested £30million into Dylan Coastal Resort. As a well-established, UK based business managing 10 luxury resorts both in the UK and overseas, Seasons Holidays have a proven track record of investing and optimising their parks. The expansion of Dylan Coastal Resort to date demonstrates more than anything else their commitment to the area and their ability to deliver on a planning approval and with it create substantial benefits for the local economy. Indeed, as is presented in Lichfields study within Appendix 5, the delivery of Phase 1 and 2, would amount to the following benefits:
Phase 1:

• c. 110 direct (plus c. 120 indirect spin off) jobs during construction
• £5.9 million of direct GVA generated per annum through construction (plus £7.1 million indirect)
• £1.8 million in direct (on and off site) spending (by guests) per annum;
• £0.8 million in indirect spending per annum;
• c. 33 new direct jobs (and c. 16 indirect job) during operation; and
• Operation GVA of £1 million per annum.

Phase 2:

• 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

The Council consider that Phase 2 could not be delivered – however have offered no evidence to support their position.
The Development Plan Manual (DPM) sets the guidelines for the appraisal of potential sites to allocate within a local plan. These guidelines are set to ensure that any site included within a Plan can be relied upon for delivery within the Plan period and that the site is the most effective to meet the strategic objectives of the wider Plan. Paragraph 3.47 sets some high-level principles that each site should be scrutinised against at the candidate stage, These tests are written predominantly in relation to housing sites, however, can be applied in relation to visitor accommodation developments such as Dylan Coastal Resort. The key principles of a deliverable site, set out within across the DPM are:

A Deliverable Site:

1 Is the site in a sustainable location;
2 Is the site available now, or will be available at an appropriate point within the plan period,
3 Is the site generally free from physical constraints, such as land ownership, infrastructure, access, ground conditions, biodiversity, landscape, heritage, flood risk issues and pollution
4 If the site is in public ownership is it identified in a published disposal strategy and/or through Council resolution if the land is to be retained/or sold by the Council.
5 What is the planning history and/or does it benefit from an extant planning permission, or is it identified as an allocation?
6 Where appropriate, a clear explanation and justification of how and when any barriers to delivery can be overcome should be identified.

The land in Phase 2 is a sustainable location, in so far as it immediately adjoins an existing Holiday Park (or planned extension to – i.e. Phase 1 allocation). It is under the ownership of Seasons Holidays and is available now and would be built out in accordance with the timeframes identified previously. It is free from significant constraints, with no physical conditions that would prevent delivery. It is not in public ownership and whilst it has no formal planning history (other than a temporary access track provision to deliver lodges to the current development at Dylan Coastal Resort) it is currently proposed to lie adjacent to an allocated site for holiday accommodation.
To meet the test set out for a deliverable candidate site, no further justification is required, as there are no other barriers to delivery. On this basis there is no evidence to support the decision not to include it within allocation ref: SEC20/MU1.

3. Policy framework being sufficient to enable tourism development.

Strategic Policy Context

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.

Conclusions on the failure to allocate Phase 2

As has been demonstrated above, there is a clear timeline for deliverability at Dylan Coastal Resort, which is based on current on site trends and the need to continue to deliver accommodation on site. This shows that planning permission for phase 2 would be secured within the current Plan period and works on site would commence, including the erection of units. Furthermore, the land in question is deliverable, by an experienced holiday park operator which is fully invested in the area. There are no constraints to its delivery however there are considerable losses to the local economy should it not come forward.

Furthermore, failure to allocate would mean the Council would be forced to consider a planning application in due course for the development at Phase 2, within the Plan period. The policy, as currently drafted, is not sufficiently supportive to give certainty in investment if an overriding allocation is not first present. Failure to allocate is also a failure to support national policy objectives, leading to an inconsistency between the various levels of spatial policy in Wales.
All combined, 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.

Whilst the inclusion of phase 1 of Dylan Coastal Resort within the Deposit Plan is welcomed, Seasons Holidays Plc consider that the decision to exclude Phase 2 is unsound. The reasoned justification is not evidenced and the result is a Plan that fails to reflect and support national and local strategic objectives. The Plan also fails to be properly evidenced, justified or sufficiently flexible.

The evidence set out in this response demonstrates that Phase 2 is deliverable in the plan period and is required by the operators to meet demand in line with current growth. Dylan Coastal Resort is in the hands of an established and experience operator with a track record in delivering high quality, year round tourist accommodation. The expansion of Dylan Coastal Resort is estimated to generate up to £37 million in GDV (per annum) into the economy during construction and £2.6 million (per annum) during operation. Including creating c. 130 additional jobs during operation.

To leave such growth, investment and benefits to general development management policy when an option exists to secure certainty through allocation is not appropriate and the Plan fails to be positively prepared as a result. People and interpretation of policy change over time and as a result the reliance on these policies is not an effective means of delivering on such an important area of growth for the economy. It is considered that by allocating phase 2 of Dylan Coastal Resort, the revised Local Development Plan will be able to firmly secure both the speed and certainty of delivery of levels of tourism related investment in Carmarthenshire to reflect the strategic objectives within the Plan.

However, as drafted, the Second Deposit Local Plan does not adequately plan for growth within the tourism economy in Carmarthenshire as is specifically detailed as necessary by policy 29 of the National Development Framework, Future Wales 2040.

We therefore urge the Council, at this stage and before examination, to reconsider the allocation of Phase 2 at Dylan Coastal Resort and include it within SeC20/MU1.