Parc Cybi Roadking Hotel. Sequential Assessment Planning Statement Appendix One

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1 Parc Cybi Roadking Hotel Sequential Assessment Planning Statement Appendix One April 2018

2 Contents 1. Introduction 2 2. Planning Policy Framework 3 Planning Policy Framework 3 3. Sequential Assessment Methodology 5 The Sequential Sites Area of Search 5 Identification of Alternative Locations 5 Assessment of Locations 6 4. Sequential Site Assessment 7 Site Identification and Assessment 7 5. Summary and Conclusions 9 Draft Final Draft v1 Author Ellie Philcox MRTPI PIEMA Issued 18 April of 9

3 1. Introduction 1.1 This Sequential Assessment (referred to hereafter as the Assessment ) has been prepared by Euan Kellie Property Solutions on behalf of our client Roadking Holyhead Limited ( the Applicant ) in respect of land is located adjacent to the North Wales Expressway (A55) in Holyhead, to the north west of the RoadKing Truck Stop ( the Site ) which is located within the administrative boundary of Isle of Anglesey County Council ( IoACC ). 1.2 The application proposes the erection of a hotel development within a ground plus 2 storey building comprising 78 bedrooms (Use Class C1) and associated works including the creation of 80 car parking spaces and landscaping (the Proposed Development ). 1.3 The purpose of this Assessment is to provide a clear justification for the Proposed Development by demonstrating compliance with the relevant national and local policies relating to new retail and commercial development. Contact Details 1.4 For further information in respect of this Statement please contact: Ellie Philcox MRTPI AIEMA Associate Director Euan Kellie Property Solutions Landmark House Station Road Cheadle Hulme SK8 7BS Tel: ellie@euankellie.co.uk 2 of 9

4 2. Planning Policy Framework 2.1 The relevant planning policies relating to town centre development is set out below. Planning Policy Framework Planning Policy Wales - Edition Planning Policy Wales Edition 9 ( PPW9 ), published in November 2016, sets out the Welsh Government s approach to town centre development. 2.3 Paragraph sets out that the Welsh Government's objectives for retail and, commercial centres are to: Promote viable urban and rural retail and commercial centres as the most sustainable locations to live, work, shop, socialise and conduct business; Sustain and enhance retail and commercial centres' vibrancy, viability and attractiveness; and, Improve access to, and within, retail and commercial centres by all modes of transport, especially walking, cycling and public transport. 2.4 Paragraph stated that the Welsh Government adopts the town centres first principle whereby consideration should always be given in the first instance to locating new retail and commercial development within an existing centre. 2.5 Paragraph goes on to state that although retailing (A1 uses) should continue to underpin retailing and commercial centres, it is only one of the factors which contribute towards their vibrancy. Policies should encourage a diversity of uses in centres. Other appropriate retail and commercial centre uses are financial and professional services (A2), food and drink (A3), offices (B1), hotels (C1), educational and other non-residential establishments (D1), leisure (D2) and certain other sui generis uses such as launderettes and theatres. 2.6 Paragraph outlines that these uses are complementary to the retail function of retail and commercial centres and should be subject to the sequential test in consideration of development plan policies and development management decisions. Anglesey and Gwynedd Joint Local Development Plan The Anglesey and Gwynedd Joint Local Development Plan ( JLDP ), adopted in July 2017, sets out the relevant local policies regarding town centre developments. 2.8 Policy Man 1 Proposed Town Centre Developments outlines that proposals for new retail, commercial and leisure development will be directed towards town centres in the first instance, provided that they are of a scale and type appropriate to the size, character and function of the centre in the retail hierarchy. 2.9 Retail and commercial proposals outside the defined town centres will need to be supported by evidence of need for additional provision and satisfy the sequential approach set out in national planning policy and accord with other policies in the Plan. 3 of 9

5 Technical Advice Note 4 (TAN 4) Retail and Commercial Development 2.10 Technical Advice Note 4 (TAN4) provides further guidance on retail and commercial development Section 7 of the guidance outline the requirements of the sequential test, and states that sequential location of development plan allocations or planning applications should be considered as follows: Firstly, within retail and commercial centres identified in the retail hierarchy where suitable sites, or buildings for conversion are available. Where this relates to a development plan allocation, they must be available for development within the plan period. If no suitable sites are available in retail and commercial centres then edge-of-centre locations should be considered, with preference given to brownfield sites that are or will be well connected to the existing centre and accessible by a variety of means of transport, particularly walking, cycling and public transport. Only when retail and commercial centres and edge of centre locations have been considered and found to be unsuitable can out-of-centre options within, and then outside, a settlement area be considered. Where out of centre sites are concerned preference should be given to brownfield sites which are or will be well served by a choice of means of transport and are close to an established retail and commercial centre Paragraph 7.5 of TAN4 also states that developers and retailers should be flexible and innovative about the format, design and scale of proposed development and the amount of car parking needed, tailoring these to fit local circumstances. In particular, developers proposing large scale retail and/or leisure developments with a large quantity of car parking are encouraged to consider whether or not elements of their proposal could be located on a site or number of sites in a centre, rather than automatically seeking to locate on a single edge of centre or out-of-centre site. Such an approach could take advantage of shared parking facilities Chapter 2 will now outline the proposed sequential assessment methodology. 4 of 9

6 3. Sequential Assessment Methodology 3.1 This Chapter sets out the proposed methodology to be adopted and the variables to be taken into consideration for the sequential site assessment. The Sequential Sites Area of Search 3.2 In accordance with planning policy framework set out in Chapter 1 the proposed area of search first extends to Holyhead Town Centre. The extent of the Town Centre is defined by the Anglesey and Gwynedd Joint Local Plan as shown in Figure 2.1 below. ^ Figure The area of search is then to be extended to include edge-of-centre sites within Holyhead. Guidance set out in TAN4 (paragraph 7.4) defines edge of centre sites as follows: Wherever possible edge of centre site allocations or development proposals should be located adjacent to a designated retail and commercial centre boundary, where this is not the case it should not normally be more than 200 to 300 metres from the edge of the centre. Factors such as the size of the retail and commercial centre, local topography and presence of physical barriers to access may influence any assessment. It may be appropriate to use a shorter acceptable distance between the centre and the development proposal if the centre is small. 3.4 In the case of Holyhead, it is considered that an extended search area of 200 metres from the defined town centre boundary is appropriate given the relatively small size of Holyhead Town Centre. Identification of Alternative Locations 3.5 The assessment essentially considers two types of alternative locations: Existing vacant units within the area of search; and, Vacant / allocated / identified Development Sites within the area of search. 5 of 9

7 3.6 Alongside the identification of sites by location we have also identified the minimum unit size to accommodate the proposed hotel. The proposed hotel has a gross internal area of 2,522 sqm., and along with the proposed servicing and car parking space covers an area of 0.5ha. 3.7 In terms of disaggregation, the nature of the proposed development means that its various elements could not be reasonably and successfully located across a number of separate sites for operational and viability reasons. 3.8 The nature of the proposed hotel use means that it would not be appropriate for it to be separated and developed over a number of locations. The target market for the proposed hotel are truck drivers, who already use the existing facilities at the Roadking Truckstop. The proposed hotel includes bedrooms only, and does not include restaurant and bar facilities, with the intention being that guests would use the existing facilities within the adjoining Roadking. Many guests of the proposed hotel will also require appropriate car parking facilities for trucks / lorries. This is already available at the Parc Cybi site. 3.9 It is clearly therefore not the intention of the policy to seek the arbitrary subdivision of proposals but rather to consider whether there are elements which could reasonably and successfully be located at a separate sequentially preferable site or sites The nature of the proposed hotel development means that it needs to be located within close proximity of car parking facilities for trucks / lorries and restaurant / bar facilities. It is clear that the proposed hotel could not be reasonably and successfully located away from the existing Roadking Truckstop. In the circumstances the applicants have clearly demonstrated the flexibility sought by TAN4. Assessment of Locations 3.11 The assessment of the individual sites / vacant premises / units has been based on their suitability, availability and viability for redevelopment to accommodate the proposed retail uses, along with their sustainability credentials in accordance with most recent local and Government thinking This assessment is based on a review of detailed criteria for each location including: Size of the site and capacity to accommodate the type of development proposed; Location in proximity to appropriate parking and restaurant/bar facilities; Current use and availability for development; Current ownership and the ease with which the site could be assembled (where known); Site Allocation; Accessibility by foot, bus and cycle as well as by car (including the supply of nearby truck / lorry parking); Other sustainability characteristics; Physical constraints of the site / unit; and, Existing planning permissions and commitments In terms of availability, given the timescales for the development (assuming planning permission is granted), the proposals would be completed by the end of 2019, availability has been assessed based on a 5 year period (i.e. by 2024) Chapter 3 will now set out the sequential site assessment. 6 of 9

8 4. Sequential Site Assessment 4.1 As set out in Chapter 3, the sequential site assessment considers two types of alternative locations within Holyhead Town Centre, or within 200 metres of the town centre: Existing vacant units within the area of search; and, Vacant / allocated / identified Development Sites within the area of search. Site Identification and Assessment Sites being actively marketed 4.2 A search has been undertaken to identify existing units or sites which are currently being actively marketed for sale or let in Holyhead Town Centre, or within edge-of-centre locations. 4.3 An online search was undertaken on 29 March 2018 utilising the Rightmove and Zoopla websites, looking for sites or units within or on the edge of Holyhead Town Centre which were available for either sale or let. 4.4 None of the sites / units was of a sufficient size to accommodate the proposed hotel (2,522 sqm. / 0.5ha.) which immediately renders them unsuitable for the proposed development. Allocated Sites 4.5 The Anglesey and Gwynedd Joint Local Development Plan ( JLDP ), adopted July 2018, is the current statutory development plan for the Holyhead area. 4.6 The JLDP allocates Holyhead Port as a Reserve Employment Site under Policy C(wg) 37. This allocation is shown in Figure 4.1 below. ^ Figure The site covers a total area of 41.9 hectares, although only 6.4 hectares is within an edge of centre location. 4.8 Policy C(wg) 37 of the JLDP identified that the site is allocated for employment uses under Use Classes B1, B2 and B8, however the JLDP also identifies that the Reserve Employment 7 of 9

9 Sites are not for local market demand for general industrial or business uses, but are to accommodate business and employment uses that would initially cater specifically for the needs of Wylfa Newydd or other Energy Island / Enterprise Island development. 4.9 Whilst the site is of sufficient size to accommodate the proposed development, it is clear that the site is not suitable for the proposed hotel use (Class C1) by virtue of the site allocation, nor does it relate to the identified reserved uses Whilst parts of the site are located close to Holyhead Town Centre as shown in Figure 4.1 above, the site is also not located within such close proximity to the necessary truck / lorry parking facilities as the application site, nor is it located adjacent to the restaurant / bar facilities associated with the Roadking Truckstop The site is also subject to a number of environmental constraints. The parts of the site which lies within an edge of centre location are identified by Natural Resources Wales to be located in an area at High risk of flooding, as shown in Figure 4.2 below. In these locations, TAN15 states that development classified as highly vulnerable, which includes hotel (Class C1) uses, are not appropriate. ^ Figure It is therefore evident that the site is not suitable for the proposed hotel development and is therefore less sequentially preferable than the application site Chapter 4 will now set out the summary and conclusions. 8 of 10

10 5. Summary and Conclusions 5.1 This Sequential Assessment has taken a comprehensive approach to the identification of alternative locations for the accommodation of the proposed development in line with PPW9, JLDP and TAN It has been demonstrated that none of the vacant units or sites identified are either suitable, available, viable or sequential preferable to the application site. 5.3 Therefore, the proposal accords with the sequential approach to site selection required by national and local planning policy. 9 of 9