Appendix 1

NOPi Detailed Response

1. The site, the proposals and Planning Policy

Pembrokeshire Coast National Park Local Development Plan (PCNP LDP)

allocates the Glasfryn Road site for housing, HA737 under Policies 44 and

45, and identifies the site as delivering 90 houses; a mix of market and

affordable housing. The allocation has been modified since the LDP was

adopted in 2010 by the Technical Update to appendix 4 of the Affordable

Housing Supplementary Planning Guidance (SPG), August 2016, and now

identifies the requirement for a lower number of affordable homes to be

provided at the site. Notwithstanding the lower percentage of affordable

houses that are required, the site remains an extant LDP allocation for

housing.

The latest Joint Housing Land Availability Study (JHLAS) 2017, which

provides an up to date statement of housing delivery and land availability

in the PCNPA, confirms that 90 houses are proposed to be developed at

the site. Additionally, the JHLAS concludes that the National Park

Authority is currently failing to meet its national policy requirement for a 5

year housing land supply, and only has 1.2 years of housing land supply

remaining until the end of the LDP period in 2021.

The amount of new housing in the National Park is limited by the

landscape capacity of the Park to absorb it without significant impact on

the special qualities of the Park. It is therefore important that land

identified and examined as being sound for housing in the context of the

National Park and its special qualities should be retained as such until the

LDP is replaced. This is currently of greater material importance given the

deficiency in the supply of housing land availability in the Park, unless

there is a clear justification to depart from the LDP.

No clear justification has been provided with the planning application to

demonstrate why a 63 bedroom hotel needs to displace valuable housing

land (a particularly scarce resource in the National Park), and why the

hotel could not be located elsewhere in the Park or in the vicinity of it, as

for example at the vacant motel site in Roch. The hotel proposal is

therefore contrary to Policy 20, Scale of Growth, and Policies 44 and 45,

Housing and Affordable Housing, of the LDP.

Although the site is allocated for housing, proposals are still required to

satisfy tests set out in the LDP and Planning Policy Wales to ensure a

satisfactory form of development is delivered. These include the impact of

the proposals on National Park purposes and duties, and ultimately the

conservation and enhancement of the natural beauty of the National Park.

As proposed there are a number of deficiencies in both the social and

market housing schemes resulting in cramped layout and form of

development.

The affordable housing scheme has a deficient parking layout rendering

some of the spaces unusable and totally omits any disabled parking

spaces, and visitor parking. This will lead to visitors parking in an ad hoc

and likely unsafe manner. Disabled residents and visitors will be required

to transfer to wheelchairs in the road when parking bays are occupied, as

there will be inadequate space for them to transfer to a wheelchair/buggy

in a normal parking space. This will result in an unsafe and unsatisfactory

solution for both disabled residents/visitors, and other road users

accessing the site, and fails to comply with guidance and standards for

inclusive design. The proposal is therefore contrary to LDP Policy 52,

Sustainable Transport and PPW and TAN 12 on inclusive design.

The market housing attempts to develop a mixture of housing designs and

sizes at the site, but fails to provide the necessary space and storage for

the larger dwellings. This is likely to lead to demand at the 3 and 4

bedroom properties, particularly, for additional extensions and storage

space to accommodate the residential paraphernalia associated with

family sized dwellings, e.g. garden equipment, bicycles, surf boards, toys.

Alternatively, it could lead to garages being converted for additional living

space and storage. Neither is a satisfactory solution, and will result in a

cramped overdevelopment of the site, or to the houses being used as

holiday accommodation as they are too small for families with children to

live in. As currently submitted, the market housing is contrary to LDP

Policies 29 Sustainable Design, 8 Place and Local Distinctiveness, and

Policy 30 Amenity.

As stated above, NOPI fully support the principle of housing at the site.

They consider these problems could be overcome and the scheme

addressed to comply with national and local planning policy, by deleting

the hotel proposal and amending the site layout to provide:

• additional housing to meet the 90 units required in the LDP and

JHLAS 2016,

• the space required to provide a safe and satisfactory parking

layout and road infrastructure to all dwellings that provide the

necessary level of disabled parking spaces

• satisfactory visitor parking for the social housing

• realistic dwelling sizes and storage facilities for the number of

residents likely to occupy 3 and 4 bedroom dwellings and their

paraphernalia.

2. Economic Impacts of a 63 bedroom hotel on the tourist

economy/economy of St Davids

The Turley report (Premier Inn St Davids Economic Impact Statement,

July 2017) commissioned by Premier Inn examines the case for a Premier

Inn in St Davids. It is not clear what the qualifications of the Turley

report’s authors are, but in the independent economic report (attached),

Professor Oswald and Dr Priddy, do not believe that the Turley report’s

conclusions or the numbers predicted in the report are reliable (An

Independent Economic Assessment of the Proposed St Davids Premier Inn

Appendix 2). The Turley report fails, for example, to use any clear

demand-and-supply analysis. Professor Oswald and Dr Priddy point out

that a hotel is not an ‘attraction’ in an area. Thus, a Premier Inn would not

be like a new St Davids maritime museum, say, or a new extension to the

art gallery in Oriel y Parc. A hotel offers accommodation to people who

already wish to visit because of an area’s intrinsic attractions. In the

jargon of business and economics, the proposed hotel would shift out the

supply curve of accommodation (not alter the demand curve to visit, i.e. it

would increase the supply of bed spaces in the area, and not increase the

demand for those bed spaces). The principal outcome would thus be a

switch of trade away from existing suppliers of accommodation.

How would St Davids be affected?

Forecasting future impacts is always difficult. In the judgement of the

independent report’s authors the following effects are likely to be

experienced.

1. The main effect of a Premier Inn would be to undercut existing

accommodation prices in the area. This would damage the livelihoods

of those residents who currently run bed-and-breakfast and other

kinds of accommodation in St Davids.

2. There would be a knock-on set of harmful consequences for the jobs

and incomes of those who currently make a living by servicing the

existing bed-and-breakfast and other kinds of accommodation -

cleaning, repairing, providing food supplies, and so on.

3. If the hotel went ahead, a substantial amount of the area’s current

tourist income would inevitably be transferred out of Pembrokeshire to

shareholders in the Whitbread corporation, the ultimate owner of

Premier Inn.

Would there be any gains from a Premier Inn?

In the medium term, there might be a small net increase in the number of

low-paid and part-time jobs, particularly in cleaning and bar work,

available in St Davids. This would occur if low prices charged by a Premier

Inn led to a slightly larger number of visitors (mainly those on a tight

budget) to the local area. The extent of extra jobs would, in the

professional opinion of the independent assessors, be far fewer than

implied by the Turley report. In their judgment the forecasts in that report

are not credible. This is primarily because the Turley report fails to grasp

the likely large amount of job-displacement away from the existing

suppliers of accommodation. The report by Turley says that it follows what

is called the government’s Homes & Community Agency (HCA)

Additionality Guide. Yet Professor Oswald and Dr Priddy have examined

that Guide and it contains no analysis of a hotel’s displacement

consequences.

Are there any long-term risks?

There is a significant risk, point out Professor Oswald and Dr Priddy. The

potential long-run concern is that a Premier Inn, especially at the entrance

to this tiny city, might deter future visitors and tourism. It is likely that

many people currently visit St Davids, and the local Pembrokeshire area,

because it is famous for being unspoiled and traditional. If that reputation

began to disintegrate, it is hard to forecast how deeply the economy of St

Davids and the local area might be affected. Evidence from the on-line

petition comments indicate that a significant number of visitors to the city

visit because of the independent and individual nature of the

accommodation providers and businesses. (See figures and comments in

Appendix 10)

Environmental impact

The Turley report provides no environmental-impact analysis.

External assessors

A full detailed analysis of the Turley report is included in Professor Oswald

and Dr Priddy’s report (attached at appendix 2). The report also contains

letters of assessment from three UK specialists in economic geography

and public policy (professors from the London School of Economics, Bath,

and Cambridge). Their letters set out a number of substantial criticisms of

the Turley report.

Pricing Policy of Premier Inn

Premier Inn has the ability to implement an extreme variable, or demand

based, pricing policy. High prices are evidenced, when demand is high,

and their prices are cut when demand is low or to boost brand awareness

and exposure. Prices quoted are also for room only. Breakfast is an

additional charge, ranging between £6.99 for a continental breakfast and

£8.99 for a full breakfast.

Most accommodation providers employ a variable pricing approach to

some degree. In and around St Davids most, if not all providers, offer

high, shoulder and low season rates. Most of the prices advertised by the

St David’s accommodation providers also include breakfast, making them

in many cases an attractive alternative to Premier Inn. However, small,

independent providers are unable to vary their prices to such extremes as

Premier Inn, due to much lower profit margins and little ability, if any, to

carry losses.

Smaller, independent accommodation providers will be unable to compete

with the price variables that Premier Inn can implement. Nor will they be

able to compete in any way with the marketing and advertising power of

Premier Inn / Whitbread. Many people use online searches to identify

accommodation providers and search for places to stay. Premier Inn has

the power to ensure their online presence is dominant, ensuring they are

at the top of search engine results. See screen shots at appendix 3. Local

businesses do not have the ability to operate on a level playing field with

such a large, dominant presence in the market place.

The potential negative impact that such dominant variable pricing strategy

and marketing power would have on existing local businesses should be

considered in conjunction with the findings of the independent economic

report prepared by Professor Oswald and Dr Priddy.

Economic Impacts, Visitor Economy and Planning Policy.

The LDP strategy for visitors ‘is to attract an optimal number, origin, type,

duration of stay and spend of visitors all year round while ensuring that

National Park environment continues to hold its attraction as a landscape

of national and international importance’. It sets out that this is ‘best

achieved …. by not adding substantively to the overall provision of visitor

accommodation, as this could encourage further ‘peaking’ and cause

damage to the National Park landscape and special qualities, both in terms

of the impacts of the additional development and increased activity in

some ‘hot spot’ locations.’ (para 4.152)

Instead, the LDP strategy seeks to have at the end of the Plan period a

range of quality holiday accommodation, similar to the level and

distribution of provision at the beginning of the LDP period, to suit a range

of pockets. This does not prohibit upgrading and new development, but

seeks to ensure that more accommodation can be made suitable for the

off-peak season and that the quality of the offer for the visitor is also

improved. The Plan seeks to safeguard hotels and guesthouses that can

provide accommodation and employment all year round unless they are

no longer viable.

Policy 35 Visitor Economy seeks to attract visitors outside the peak season

while ensuring that National Park environment is conserved and enhanced

as a landscape of national and international importance by a number of

criteria.

A survey of local tourist accommodation in St Davids undertaken by NOPi

in 2017 and attached as appendix 4 Accommodation survey has identified

that a number of hotels chose to close during the winter months as they

have a very low bed occupancy rate, and it makes it financially unviable

for them to remain open. As has been identified above, a hotel is not a

visitor destination or attraction. It is not evident what the current proposal

would offer to attract visitors in the off-peak season, other than offer

more bed spaces to an already depressed market that has excess supply

over demand out of season.

The submission for the proposed hotel fails to demonstrate how it would

attract visitors to St Davids outside the peak season thereby extending

the tourist season and boosting the economy of St Davids. For that

reason, and by reason of its design, lighting and layout, the hotel would

fail to conserve and enhance the National Park environment, and is

contrary to Policy 35 of the LDP.

Planning Policy Wales (PPW) provides Welsh Government Policy on how

sustainable development (SD) should be delivered to meet the objectives

and well being goals set out in the Wellbeing of Future Generations Act

2016. In delivering SD there will sometimes be conflict between the

various strands that combine together to deliver SD, and the pros and

cons of the various elements will need to be balanced and integrated to

deliver SD.

PPW translates Welsh Government’s Strategy for Tourism 2013-2020, and

recognises that tourism is vital to economic prosperity and job creation in

many parts of Wales. (11.1.1). It states further that the ‘Welsh

Government’s aim is for: tourism to grow in a sustainable way and make

an increasing contribution to the economic, social and environmental well

being of Wales.’

As already stated, the proposed hotel does not provide additional tourist

attractions for St Davids and Pembrokeshire, and provides no additional

reason for people to visit the area. It will not add to the economic well

being of the area, but will add accommodation to a market where there

are already surplus beds, particularly during low season. This will further

depress the low season market, possibly forcing further accommodation

businesses to close seasonally or even permanently. This will have a

knock-on effect for local businesses and those employed in the supply

chain prejudicing the economic and social well being of St Davids and its

environs, and ultimately the character and appearance of the city if a

number of businesses are forced to close.

The proposal is therefore contrary to the aims of PPW to deliver SD and

make a positive contribution to the economic, social and environmental

well being of Wales.

3. Impacts on landscape, visual amenity and the special qualities

of the National Park

There are a number of inadequacies in the Landscape and Visual Impact

Assessment (LVIA) (prepared by the Environmental Dimension

Partnership Ltd (EDP)). This leads to an under representation of the

effects that the proposed development will have on the conservation and

enhancement of the Pembrokeshire Coast National Park - the test against

which development in the Park should be assessed. The under

representation of landscape and visual impacts is particularly severe in

regard to the small settlement of St Davids and its hinterland. These

issues are set out below.

Methodology

We consider that the methodology employed for the LVIA is not consistent

with best practice, particularly for the assessment of the impact of a

major development proposal in a National Park. This weakness in the LVIA

report has been compounded by a number of omissions, errors and

inconsistencies which make it more difficult for both the planning

authority and the community to fully understand the impacts and to have

confidence in the applicants’ conclusions.

The assessment seems to have been prepared to support an outline

application, and not a full planning application. When considering an

outline application, it is best practice to present a worst-case scenario

which does not appear to have been done in this instance. Consequently

the LVIA has neither assessed the worst-case scenario for an outline

application nor gone into the kind of detail required for the amended full

application. The assessment is therefore significantly flawed and should be

re-assessed and re-submitted to the Planning Authority.

We also have concerns that the assessment puts undue emphasis on the

residential development stating (LVIA 1.3) that it discusses issues

‘pertinent to the acceptability of predominantly residential

development.’ This characterises the proposed development incorrectly.

The proposed hotel is likely to be more prominent than the housing.

Whilst the effect of 2 storey housing and its associated infrastructure on

landscape and visual receptors might be acceptable, a 3 storey hotel with

its associated parking, deliveries and noise and disturbance will have very

different and possibly unacceptable impacts on receptors. Although the

consultant methodology correctly sets out the theoretical standards in

A2.43, and states that heed should be taken of the development type

proposed when considering susceptibility, we consider that the

methodology employed has led to a significant under representation of the

landscape and visual effects of the hotel, in particular.

Visual Assessment

The Visual baseline presented in Section 3 Landscape and Visual Baseline

Conditions is confusing, with vital elements omitted, leading to a lack of

information on which to base a reasoned judgement of effects. Plan EDP

L3 Topographical relief shows the site outlined with a red line with

distances from it indicated by concentric rings at 1km intervals up to 5km,

but no Zone of Theoretical Visibility (ZTV) is presented.

Section 3 3.41 of the report ‘Landscape and Visual Baseline Conditions’

states that digital terrain modelling was used; we consider it an error that

it was not used to construct a ZTV to use as part of the visual analysis.

The consultants correctly recognise the limitations of a computer

generated ZTV, in that it presents a worst-case bare-ground scenario, but

it is widely recognised professionally that attempts to present an

apparently more accurate picture of actual visibility by including visual

barriers within the analysis can wrongly include an element of subjectivity

into what ought to be an objective study.

For a development of this size and scale, in such a sensitive location, we

would expect a comprehensive assessment using all available analytical

tools. A ZTV might have helped with the location of additional viewpoints,

and would have given the assurance that a worst-case scenario had been

assessed. The inadequacy of the approach adopted by the applicants’

consultant is discussed in more detail in Appendix 5 (Section 3, point 6).

The LVIA only selects and analyses seven viewpoints, which are described

in full in Appendix EDP 7 Table of Assessment of Visual Effects. Of these

viewpoints, three are described as ‘close’, three as ‘medium’ and one as

‘long’ range, but it is not made clear from where in the site these

distances are measured.

The information provided for the viewpoints lacks enough technical data to

be confident that the assessment could be replicated in order to check

that its conclusions are correct. (See Appendix 5 point 20).

We do not consider that the applicants selected enough viewpoints of

different types to be able to assess thoroughly the possible impacts of the

development, particularly the proposed hotel. To have been able to assess

the full impact of the development there should be additional viewpoints

from well used public spaces, public rights of way and local minor roads.

Night time effects should also have been included.

The LVIA states that the visual envelope of the site is limited to:

• Close range views from all cardinal directions;

• Medium range views from the north, north west and the west; and

• Long distance views from hills (Carn Llidi and Carn Perfedd) to the north

west.

Without a comprehensive ZTV it is difficult to judge that this is indeed the

case. For instance, extensive areas of open access land are missing from

the landscape designations on Plan EDP1 Landscape Related Designations.

These areas, defined under The Countryside and Rights of Way Act 2000,

give people the right to roam freely – without being confined to a footpath

or bridleway - over land defined as Open Access Land. Much of the Open

Access Land in the vicinity of the site is owned by the National Trust and

is well used by residents and visitors. Important medium range views

from the east of the site are also missing, including the potential for views

from the old St Davids airfield.

The LVIA does not state clearly if the effects on landscape character and

resources and visual amenity have been assessed for the development

upon completion, i.e. in year 0, before planting becomes established and

buildings age, or if the subsequent residual effects are presented, i.e. the

effect of development in year 15 following the establishment and

maturation of planting etc. The impacts of both year 0 and year 15

scenarios should be clearly presented in the assessment. The description

of the methodology is not explicit, being given only in a table (Table A7.1)

Effects on Visual amenity) which bases the magnitude (of change) on a

ten years scenario. This does not assess the initial impact of the proposals

at year 0, i.e. immediately upon completion of the proposed development.

The result of this is to under represent the landscape and visual impact of

the proposals if there is no assessment upon immediate completion, which

is presumably the worst-case scenario. There is additionally, confusion in

the text as to whether a 10 year or 15 year assessment is proposed, as

both time frames are mentioned: ten years in the table but 15 years in

Appendix EDP 2 A2.6. The latter, correctly adds ‘Residual effects are those

which are likely to remain on completion of the development and are to be

given the greatest weight in planning terms.’

Photomontages

No photomontages have been carried out as part of the LVIA. The absence

of photomontages from the LVIA is a serious omission, particularly in a

development of this size and scale in such a sensitive location. Without

photomontages it is not possible to reach a fully informed and

objective conclusion on the visual impacts of the proposals, and

have confidence in the conclusions on magnitude of change and visual

impact that have been reached in the discussion under each viewpoint in

the report. We consider that a range of these from representative

locations/viewpoints are necessary for the decision makers in the

Pembrokeshire Coast National Park Authority and the City Council as well

as for the residents of the St Davids peninsula and our many visitors to be

able to fully understand the proposals’ impacts.

Night time views

No night time views of the proposed scheme and its lighting and

advertising are included as part of the visual baseline, and have been

neither described nor modelled. This is a major omission because night

time views are essential to assess the impact of the lighting of the

residential elements of the proposal and of the hotel and its car park. The

potential impact of light at night from built and well-lit development is

disproportionately high when compared with other features in the

landscape, as light sources can generally be seen for a very great

distance. The visibility of the site is indicated on EDP’s Plan EDP4

(Findings of Visual Appraisal and Viewpoint Locations) and, as discussed

above, we recommend that a ZTV is undertaken to ensure a worst case

scenario is considered. The Rugby Club lights, opposite the site, on lower

ground and 10m high, when on for a couple of nights a week are very

obvious over a great distance but are practically invisible when switched

off.

The issue of the night time impacts of light pollution has become more

important over recent years with a recognition of the adverse impact

lighting can have in urbanising rural areas and compromising the sensitive

landscapes of National Parks, and their promoted Dark Skies. The LDP

(4.58) notes that visitors value highly both the Park’s tranquillity and

remoteness, including dark skies free from light pollution.

Residential amenity assessment

Given the potential impacts, particularly of the proposed hotel on

neighbouring and overlooked properties, we consider that a residential

amenity assessment should have been undertaken and submitted in

support of the application. As part of its scope, it should have included a

visual effects assessment. In ‘Section 6 - Assessment of Effects,’ the

consultants have noted the significant adverse impact on residents.

Despite this, and the consultants regarding the major/moderate adverse

effect as significant, no residential amenity assessment was undertaken..

Properties to be assessed should have included not only close neighbours

in Heol Dewi etc, but the residents in the many scattered cottages and

farmsteads on the peninsula.

Mitigation

Mitigation measures to avoid, reduce, remedy or compensate for the

predicted significant effects of a development on the environmental

baseline quote best practice guidelines in several places (Stage 5

Mitigation) and are defined in Appendix EDP 1 Glossary Measures. In this

assessment, however, best practice is not followed, and mitigation

measures are limited to some comments on additional planting in Glasfryn

Road and within the site, and statements asserting, without supporting

evidence, the suitability and quality of the new buildings.

As far as we are able to assess, given the shortcomings of the

assessment, the LVIA fails to consider avoidance or reduction of the

undoubted substantial visual and landscape effects of the proposal,

particularly the hotel and its associated infrastructure, in any meaningful

way. There is no mention of any possible compensation.

Landscape assessment

A number of landscape receptors, which should have been included in

order to understand the nature of the wider landscape around the site and

to fully assess the impact of the proposals, have been omitted from the

assessment. Notable omissions are:

• WEST & NORTH PEMBROKESHIRE COAST - covers the St Davids

Peninsula and recognises the cultural and spiritual significance of

the village city of St Davids and the ecological richness, open views

and dramatic igneous outcrops which form its hinterland. (National

Landscape Character Areas NRW (2014) LCA43).

• St Davids Peninsula and Ramsey Island (Penrhyn Tyddewi ac Ynys

Dewi): Register of Landscapes of Outstanding Historic Interest in

Wales HLW4; /Cadw/ICOMOS/Countryside Council for Wales a

registered cultural landscape of national importance,

• LCA 18 St Davids Headland, LCA 15 Dowrog and Tretio Commons

and LCA 16 Carn LLidi,

• LANDMAP Historic Landscape aspect area Tyddewi PMBRKHL42275.

We consider the omission of the Registered Historic Landscape to be

serious; the assessment lacks any understanding of, or reference to, the

fragile and precious nature of this landscape. An understanding of its

significance and value is vital in arriving at a reasoned decision on the

impact of the proposals, particularly of the hotel element, on St Davids

and its hinterland.

The adopted PCNPA supplementary planning guidance Landscape

Character Assessment (2011) draws on the attributes of the Registered

Historic Landscape to define the Special Qualities (Key Landscape

Characteristics) of St Davids and the peninsula, noting that St Davids and

its environs are of international cultural and heritage significance as the

home of the patron saint of Wales and a place of pilgrimage. The city and

its cathedral have a unique character whose setting, as recognised in the

LCA, is in some need of ‘rehabilitation’ to restore and enhance its historic

and cultural importance. We do not consider that the hotel does anything

to rehabilitate this landscape, and in fact detracts from it.

The LCA Management Guidance promotes a ‘smooth transition from the

urban edge to the open countryside’ in the context of the Registered

Landscape of Outstanding Historic Interest. The consultants recognise the

opportunity to round off the city at this location (3.38). We are strongly of

the opinion that inserting a 3 storey building at this location is contrary to

this guidance and does not provide the appropriate transition between the

urban edge and open countryside. (See further comments below in section

5 on the Design and Access Statement).

The impact of the development on LCA 18 St Davids Headland, LCA 15

Dowrog and Tretio Commons and LCA 16 Carn LLidi, which are connected

visually and physically, should also have been included in the assessment.

In considering landscape character during their baseline assessments the

consultants have made limited use of LANDMAP in describing the local

character of the site. Where they have used it, however, it has been

limited to the overview of the few aspect areas which contain the site –

the red line area. No use has been made of the themed aspect layers for

understanding a landscape character area approach for assessing impacts

on the site’s setting and surroundings.

LANDMAP aspect areas omitted include Historic Landscape Landmap

aspect area Tyddewi, evaluated as outstanding and whose boundary runs

along the western edge of the development site. Moreover, the validated

entry for this aspect area rates the Integrity as Outstanding ‘Character not

significantly altered by limited modern development on the fringes of the

historic core’. The modern development in this case is Heol Dewi and

Maen Dewi.

The landscape impact of the proposed development, particularly the hotel

element, has been underestimated, and undue reliance and incorrect

emphasis put on the perceived negative landscape and visual effects of

housing at Heol Dewi and Maen Dewi next door to the site. The LVIA

describes this housing undeservedly as ‘degraded ex council estate’

(applicant’s terminology 6.10).

Defining Landscape Effects

Although reference is made to both the scale of change and geographical

extent in the methodology (e.g. Table EDP A2.3: Scale of Change Criteria

for Landscape Receptors) the theory is not reflected in the conclusions on

landscape effects reached in the brief discussion in LVIA Section 6 (Effects

upon the Landscape Resource), which defines the landscape receptors

with the potential to experience effects. It would have been useful to

tabulate this information for consistency with the visual effects. In the

assessment several significant receptors are either missing or

misinterpreted, as outlined above, and therefore the conclusions reached

are flawed.

In assessing the special qualities of the National Park the applicants’

consultants have included qualities which are not relevant in landscape

terms. The way that they have been set out in Section 6 quoting the

PCNPA LDP policy in relation to each of the special qualities is very

confusing. Although the proposals may be compatible or not with

individual special qualities, in the context of the LDP and PPW which

translate the requirements of the Environment Act 1995, the ultimate test

is whether or not the development conserves or enhances the natural

beauty, wildlife and cultural heritage of the Park.

The applicants’ arguments for the beneficial landscape effects of the

proposals are roughly the same for each class of receptor and lack the

reasoned reference to evidence to be convincing; the statement that there

would be a general improvement to the character of the area through the

implementation of the scheme assessed (6.10) is unsupported by the

assessment.

We disagree strongly with the applicants’ conclusions, particularly as they

relate to the hotel element of the scheme. We consider that both the

magnitude of change and the sensitivity of the landscape receptors have

been underestimated, misinterpreted or omitted leading to an

underestimate of the landscape effects of the development, particularly

the hotel, on the conservation or enhancement of the natural beauty of

the National Park.

Visual Effects

The applicants have undertaken an assessment of the effects at each

viewpoint (see LVIA Appendix EDP 7). We find the table unreliable and

self contradictory, consistently underestimating magnitude of change

leading to an underestimation of effects. We consider the applicants

findings in more detail in Appendix 5 Landscape and Visual Assessment

additional comments, point 26.

A summary table (Table EDP 6.1: Summary of visual effects) sets out

the results for each of the seven selected viewpoints, stating that only

one, VP1, has effects which are judged as significant, (significance matrix

(Table EDP A2.7)). Another summary table (EDP 6.2) ascribes high

sensitivity to users of all PROW, a medium/low magnitude of change and a

level of effect of moderate /minor. To be meaningful the analysis should

have considered each receptor separately. It is another instance of

inconsistency, as in paragraph 6.23, the sensitivity of the Glasfryn Lane

PROW is considered medium. As well as being inconsistent with table

EDP6.2, it is wrong. It is the visual receptors of the route that are

sensitive, not the route itself.

Conclusions on LVIA

We disagree strongly with the conclusions reached by the applicants in

their Section 6 Assessment of Effects and Section 7 Discussion Opinion

and Conclusion on the level of magnitude of effects, and the significance

of these effects. The applicants have failed to make a credible assessment

because they have underestimated the sensitivity of receptors and

incorrectly ascribed magnitude of change.

The LVIA (7.9) states that, the development of the site …., is not

considered to create an unacceptable effect in terms of landscape

character or visual amenity. Some effects are considered beneficial

although such effects would be mostly experienced at a local level, such

as on the approach to St. David’s from the north east.

Having examined the methodology and premises upon which the

applicants’ conclusions are based, we find that an underestimation of

effects and misuse of baseline data has led to considerably flawed

conclusions. The flawed approach to assessment, the lack of

photomontages, night time views and underestimated conclusions of

impact in the LVIA, means that there can be no confidence that the

proposals will be compatible with the conservation and enhancement of

the natural beauty of the National Park. We therefore consider the

application as proposed is contrary to Policy 1 of the PCNP LDP and

national policy set out in PPW.

4. Transport Impacts and Comments on the Transport Assessment

submitted in support of the planning application

TAN18 (Annex D, paras D1, D2, D11, fig 1) provides detail as to what a

transport assessment should include. The statement/assessment

submitted in support of the application is substantially deficient. As well as

lacking a clear baseline against which to measure additional traffic and

other impacts, the document doesn't consider the likely catchment area of

additional traffic and the area to be affected by these impacts. NOPi’s

concerns are expanded more fully below.

Existing traffic, public transport, roads and site access

The development has been enabled by the widening and improvement of

Glasfryn Road, which was completed at the beginning of 2017. This road

in effect now by-passes the centre of St David’s, linking the two main

approach roads to the city, High Street and Fishguard Rd, both A487

(3.20). To the extent that the road directly serves the proposed adjacent

development, its safety and usefulness as a by-pass is reduced. A 30mph

speed limit operates at present along Glasfryn Road and the adjoining

stretches of the A487 (3.21), but it is not self-reinforcing; speed bumps

could be introduced; the recent road improvements included introducing a

roundabout at the junction of Glasfryn Road and the A487 to

Haverfordwest but not at the corresponding junction with the A487 to

Fishguard, which is next to the proposed development. The Assessment

does not note this, nor does the planning application propose further

improvements to the existing roads and junctions, as might be necessary

if the hotel, especially, were to generate much additional traffic.

Existing public transport provision to St Davids is barely adequate and

highly seasonal, contrary to misleading statements in paragraph 3.17 and

the impression given by Tables 2 and 3 in the Assessment.

The Transport Assessment and the application in general pay no heed to

the possibility, and likely desirability, of a travel plan in connection with a

development of the proposed size and scope. This is considered a serious

omission, in view of both the local and Welsh policies to promote

sustainable travel, and the size and scope of the proposed development in

relation to existing traffic and road use. The transport assessment is

therefore seriously defective, and is simply not an assessment as specified

in TAN18 annex D, which explains how transport impacts should be

assessed, mitigated (normally with the use of a travel plan), and

monitored during the operational stages of the development.

The Assessment, in describing the local road network (3.19−3.23), does

not take account of difficulties of access on the A487 at Solva and

Newgale. Whilst the traffic manages currently, it is not a good road for

heavy vehicles or a heavy vehicular flow. Diversions sometimes operate

which go by minor rural roads, which are wholly inadequate for heavy

two-way traffic or large vehicles. The existing poor conditions would be

exacerbated with the additional vehicular traffic proposed with the

development, but particularly with the increased lorries and goods

vehicles from outside the area, servicing the hotel.

The Assessment and the application in general do not separate the

construction phase from subsequent use of the proposed development.

Given the existing road conditions, it is likely that heavy vehicles may

often have to access the site by the A40 and A487 via Fishguard, rather

than directly from Haverfordwest. This would add an extra 15 miles to

one-way journeys between Haverfordwest and St Davids. No assessment

has been made of such journeys and their impacts.

Proposed roads, access, parking and waste collections

The application states that the roads in the housing development are not

to be adopted, but does not say who is to be responsible for maintaining

them or how that maintenance is to be arranged and paid for.

We presume that the roads in the housing development are to be

accessible to weekly lorries collecting waste and materials for recycling,

which householders normally put out at the front of their own property.

The Assessment includes a swept path analysis (Appendix B) only for

vehicles servicing the hotel, but pays no special attention to large vehicles

on the residential roads, although these roads include dead-ends and tight

turns (compare 4.4−4.7 with 4.8−4.10).

One proposed group of houses, in the market-price element of housing, is

only accessible by a dead-end road running directly off the A487

Fishguard Road, on the northern boundary of the site. The Highways

Authority, in their Pre Application Consultation (PAC) comments,

questioned the safety and desirability of this direct access from a main

road. No subsequent revision has been made to the proposed plan to

address the Highways Authority’s concerns.

Provision of car parking spaces is barely adequate for the proposed

housing elements, although it does appear to be just about compliant with

PCNPA SPG ‘Parking Standards’ 2011. It is noticeable that provision is

about half per dwelling for the affordable flats and houses than for the

market-price houses, for no obvious reason that can be connected with

the residents’ likely travel needs. The Manual for Streets (Department for

Transport 2007) recommends having some unallocated parking which

visitors can use as well as residents, and that 5% of the spaces should big

enough for disabled people to park in. The master plan (included as

Appendix A of the Assessment) and the text of the Transport Assessment

do not make clear where visitors are expected to park, or which are

spaces for disabled people to park. The assumption is that visitors are

expected to share available car parking spaces with residents or park

along Glasfryn Road, neither of which is satisfactory in terms of highway

safety and the visual amenity of the area.

The Assessment, and design and layout of the parking areas and roads,

fail to take satisfactory account of inclusive design and the needs of

disabled people with respect to parking and getting in and out of vehicles.

This is a serious deficiency in the layout of the scheme, as some of the

affordable housing has been designed to mobility standards and is likely to

be occupied at some time by people with impaired mobility. The proposal

is therefore contrary to PPW and TAN 12, which require designs to protect

the interests of all vulnerable road users and to promote the consideration

of inclusive design at the outset of a scheme.

Sixty-six car parking spaces are proposed for the hotel, which is the

required minimum for a hotel with 63 bedrooms and possibly 9 non-

resident staff (4.8). The spaces include a proportion (6%) for disabled

people’s parking, which is the required minimum. The application states

that the proposed hotel will give employment to 22 ‘full-time equivalent’

staff, which may mean more than 22 people being employed at the hotel.

The application does not make clear the number of staff who might

actually be in the hotel at any one time and could require car parking

spaces. In reality there are likely to be more than 9 non-resident staff

present on site at any one time, who would require more parking spaces

than are proposed.

A number of hotel car parking spaces in the north-west of the layout

would be blocked off whenever goods vehicles back in to, and are

stationary at, the service entrance of the hotel (Appendix B).

Although racks for bicycles are provided in the parking layout for the

hotel, they are at the entrance to the hotel car park from Glasfryn Road,

remote from any direct surveillance or security and at risk from potential

theft and vandalism. With greater emphasis being placed on low impact

modes of transportation by the Welsh Government, and national parks

being promoted as exemplars of sustainability and reduced environmental

impacts, if cycling is to be encouraged for short distance commuting and

cycle tourism in the Park, secure covered cycle storage facilities are

required at the hotel.

The Planning Statement assumes that most of the proposed hotel’s

customers will arrive by car (and provides car parking accordingly). The

amount of car traffic the proposed hotel would therefore generate, both

travelling to and from the hotel and then around the peninsula, is

incompatible with the basic aim of the Development Plan to limit private

car use, especially by visitors. A recent Planning Inspector’s decision to

disallow an appeal against closure of a car park near St Justinian’s, a

coastal attraction 2 miles from St David’s and the base for most local boat

trips (APP/ L9503/ C/ 17/ 3176032, 4th December 2017), was predicated

on this aim, which would be much more difficult to achieve were the

proposed hotel to be built.

Estimates of future traffic

The traffic surveys that have been undertaken for the Assessment are

poorly detailed and contain a number of deficiencies which are described

below.

The Transport Assessment lacks any precise survey, or even a rough

estimate, of current vehicle and pedestrian traffic around the site and to

and from St Davids. There is thus no baseline against which to assess the

full impact of the estimated additional traffic that the development would

generate.

The Assessment estimates the amount of different types of traffic that the

development is likely to generate by using the well-established TRICS

database and software. This should give reliable figures on which to base

an estimate, but to see how reliable the figures are it is essential to be

able to check the use of the data and the software, as recommended by

the TRICS Good Practice Guide (latest edition 2016).

The TRICS Good Practice Guide, to which the Assessment does not refer,

emphatically recommends that the criteria for selecting survey sites for

their data and the method of filtering these sites and their data should be

clearly described and explained. The survey sites themselves should also

be clearly identified, so it should then be possible to see how comparable

they are to the proposed development and how representative the

resulting dataset is likely to be. This basic information and these essential

explanations are missing from the Transport Assessment.

The detailed TRICS results are presented in two appendices to the

Assessment. The estimates of future traffic in the text of the Assessment

simply summarise these results (for the housing, 4.14−4.19, and Tables

4, 5 and 6; for the hotel, 4.21−4.23, and Tables 7, 8 and 9). These

results appear not to have been checked for statistical soundness, as the

Good Practice Guide recommends, nor has any attempt been made to

further interpret or qualify them, although there would seem to be some

good reasons to do so and to consider some simple ‘reality checks’. For

example, the proposed development is within easy walking distance of the

rest of St Davids, with its shops and other facilities. Assuming most of the

dwellings are occupied, it might be thought that a total of 123 pedestrian

trips per day in and out of the 70 houses (Table 5) was low. The same

consideration might apply to pedestrian trips from and to the proposed

hotel (Table 8). Similarly, the determination of peak hours might have

been questioned, in view of the likelihood that people leaving for work

might have to depart relatively early in the morning (before 0800) to

travel to work from a relatively remote place such as St Davids. These are

considerations that, at an early stage in the process of using TRICS,

should have informed the selection of the survey sites and the dataset.

Residential traffic

Looking at the 43 housing survey sites and survey days selected (in

Appendix C) it is immediately noticeable that all are in TRICS land use

category 03-A ‘privately owned housing’. The Assessment candidly admits

that this category does not, in fact, reflect the varied and mixed character

of the housing that is actually proposed, which includes affordable housing

and flats for rent as well as detached and semidetached private houses.

The reason given for this discrepancy is that the category used will

produce an overestimate rather than an underestimate of the traffic likely

to be generated by the actual households. However, in reality it has

simply produced an unreliable estimate, and not the ‘robust estimate’

claimed, and does not inspire confidence that the sites have been chosen,

or their data analysed, with care. The survey days selected are only

weekdays (4.14; Appendix C, page 2); this is probably acceptable for

domestic households, which may perhaps be expected to generate more

traffic on weekdays than on weekends, but the filter should have been

explained. No explanation is provided about the use of public transport as

a possible filter.

Hotel traffic

In the case of the 18 (or 19) hotel survey sites and survey days selected,

the selection criteria are briefly referred to (4.19; Appendix D, page 2). It

is immediately apparent that survey data was sought only for weekdays,

omitting Saturdays and Sundays altogether, which for estimating trips

generated by a hotel may be regarded as a serious defect unless it is

proposed to be used by business customers, and not tourists to the area.

The smaller number of sites used and the more limited choice of sites in

the TRICS database (427 hotel sites as of January 2018) allow some

deeper investigation to be made, even though the Assessment does not

identify these sites (see Appendix 6). The data should be accessible to a

TRICS audit, which would confirm the identity of the sites.

The compatibility of the survey sites with St David’s is not explained, but

they suggest a variety of sites that are unlike Glasfryn Road. The date of

each survey should also have been provided, to establish the likely

relevance of the data to the possible seasonality of use of the proposed

hotel in St Davids.

More generally, how survey sites were filtered, or not filtered, for local

population and public transport may also affect the resulting dataset, for

both the proposed housing and the proposed hotel.

Of course, it may be that not enough TRICS survey data exists to meet

the criteria of St Davids very closely, in which case there is all the more

reason to state this fact, and to explain the choice of data actually made.

The conclusion is that unfortunately, the estimates of traffic likely to be

generated by the proposed hotel are even less reliable than those for the

proposed housing.

For the reasons set out regarding the potential traffic impacts of the

development and the flawed assessment of impacts that has been

undertaken, the proposals are contrary to Policies 52 and 53 of the LDP,

and National Planning Policy as set out in PPW 9, chapter 8, Tan 12,

Design and TAN 18, Transport.

5. Comments on the Design and Access Statement (DAS)

The DAS is not part of the Glasfryn Road planning application, but is

required to accompany it because the application proposes a ‘major

development’ (as defined in TAN12) References in the following

paragraphs are to the Glasfryn Road DAS, unless otherwise stated. The

following comments cover all of the DAS but concentrate on the proposed

hotel.

The main purpose of a DAS is to explain how a major development has

been designed progressively, taking account of the background and

context of the site, and other constraints and opportunities, as well as the

aims of the development. The guidance assumes that a DAS is written

initially to assist pre-application consultations and is then expanded as the

design process progresses (set out in Design and Access Statements in

Wales, (DASW) DCFW Appendix 1; Site and Context Analysis (SCA),

DCFW 3.6; Guidance on DAS (GDAS), Appendix to TAN 12 A1.6). This

DAS does not appear to have been written in this way, suggesting a

flawed design process.

Fundamental defects of the DAS

If the DAS had followed the guidance it would have clearly and briefly

explained, among other things:

(a) why St Davids was thought to need a new hotel of the size and type

proposed; and

(b) why this hotel had to be built on land in St Davids allocated in the

Local Development Plan for housing (LDP, HA737).

Although these questions are crucial to understanding the proposal for a

hotel, the DAS fails to answer them in a satisfactory way, or at all.

The absence of an explanation of a need for the hotel is in marked

contrast to the reference in the DAS (page 28) to a strong need for

affordable housing expressed, for instance, in the St Davids Community

Action Plan (CAP, pages 3, 9 and 19). This Action Plan, produced as a

result of extensive community consultation since at least 2003 and

updated most recently in 2012, contains up to 74 proposals to improve

employment, the environment and the life in general of residents of St

Davids and the area around, but none of these proposals nor the CAP’s

‘Vision for the future’ (pages 9−10) expresses a need or desire for a new

hotel.

The guidance for a DAS recommends that, alternatively, if certain

explanations are regarded as unnecessary for a particular development,

the DAS should explain why they are unnecessary (GDAS, A3.10). The

DAS fails to do this.

The DAS is therefore seriously defective on the two fundamental issues,

(a) why St Davids was thought to need a new hotel of the size and type

proposed; and

(b) why this hotel had to be built on land in St Davids allocated in the

Local Development Plan for housing (LDP, HA737).

The design process

Describing the evolution of the proposed design, the DAS frankly reveals

that what is proposed is not a single integrated development scheme: the

‘design journeys’ of the housing and the hotel are described entirely

separately. These two elements of the development were evidently

designed, from the start, without any reference to each other, and in the

proposed scheme they are treated as virtually separate elements.

The two lengthy descriptions of ‘design journeys’ fail to mention that, in

fact, the hotel was added to the proposed development as late as the

autumn of 2016. The description of many years of design, and of public

consultation and support, with respect to the housing (page 31) is

therefore completely inapplicable to the hotel.

The housing element of the proposed scheme, despite constant public

support for housing and regardless of the merits of its design, was not

previously submitted for planning permission for two reasons: (a) the

inability of its promoters to raise funds, and (b) poor access to the site,

which was remedied by the widening and improvement of Glasfryn Road

in early 2017. The road improvement, was planned in the LDP (4.237,

map C29), and is not an improvement that has happened out of the blue.

The DAS acknowledges that this road improvement has enabled the

development (page 19). As the DAS states, the hotel is a late addition to

the development and practically irrelevant to the housing element in

terms of design and access. Consequently, removing the hotel from the

scheme will not adversely affect the housing and may actually benefit it,

by allowing for an improved housing layout, and additional housing

numbers to meet the number required in the LDP.

Appraisal of site background and context

The guidance expects a DAS to take account of the social, cultural and

economic background and context of a development but this DAS neglects

to do this, except for passing references to the history of St Davids and

superficial descriptions of layout and some architectural features with,

consequently, the fundamental deficiencies in it that have been noted

above. The DAS makes no mention of market research in connection with

the proposed hotel.

Of particular concern is that the DAS underplays a very significant aspect

of the development site; the fact that it is at one of the highest points of

the local terrain, on a slight ridge on the east edge of St Davids. Buildings

on the development site that are any higher than one-and-a-half or two

storeys, which is the norm for St Davids, will therefore be conspicuous on

the skyline wherever the city is viewed from a distance. The Conservation

Area SPG acknowledges the importance of this when it refers to the

skyline of St Davids when seen from the north-west (CA SPG, page 12,

map of prominent views) and identifies the ridge as one of several

‘outlying areas important to the setting and character of the conservation

area’ (CA SPG, page 32, area C on map).

The policy of protecting the character of the historic landscape in which

Glasfryn Road is situated extends to details, such as appropriate signage,

which is especially important on a commercial building like the proposed

hotel (TAN12, 5.6.2, 5.8, 5.16.1). The DAS does not acknowledge that the

signage of the proposed hotel and the housing should be bilingual (LDP,

4.68, Policy 12).

Access and layout

The housing and hotel elements of the site are almost completely

unrelated to each other, and each appears to have been designed without

reference to the other. Furthermore, there are no cross-references with

the Transport Assessment in the application, suggesting that each has

been prepared without close knowledge of the other, contrary to good

practice (TAN12, 5.9.2; SCA, 2.3).

Neither the DAS nor the Transport Assessment takes realistic account of

the constraints on road and public transport connections to St Davids.

Both assume that the road network and public transport are adequate to

meet the demand that a hotel of the size proposed may be expected to

place on them (e.g. DAS pages 13 and 17), whereas the LDP clearly

shows in its Key Diagram the relative paucity of transport links to St

Davids compared with those to, for example, Haverfordwest, Tenby or

Fishguard and Goodwick.

Appearance and scale

In the course of designing the proposed hotel its architects reduced its

height from wholly three storeys to mainly two storeys because they

realised that ‘a three-storey building would be too dominant in the

landscape’ (DAS, page 62, caption). Nevertheless, the northern block has

three storeys. The architects, contradicting themselves, have kept a third

storey there for purely aesthetic reasons, ‘to make the arrival corner of

Glasfryn Road a more dominant gateway requiring a grander scale’ (DAS,

page 62). Subsequent alterations to the roofline and enlargement of the

ground-floor windows in that block (DAS, page 65), and the Planning

Statement’s reference to the proposed hotel building as a ‘cornerstone’

(5.87), confirm this aesthetic purpose.

The idea that the north-eastern approach to St Davids requires a

noticeable building stems from comments in the relevant Landscape and

Character Assessment that ‘poor design and siting of buildings at the

edges’ of St Davids arouses ‘little sense of arrival at a city of such

historical and cultural importance’ in Wales (LCA). This opinion is

reinforced by a passing reference in the Design Commission for Wales’s

comments to ‘what people see when driving into’ St Davids (3.20;

Appendix B) and remarks in the Planning Officer’s pre-application advice

(Appendix C), both the latter apparently based on partial information.

The Design and Access Statement states that the proposed hotel

‘modestly enhances the gateway location… without dominating the area’

(DAS, page 69): we contend that it would not be an enhancement

precisely because it would be immodest and over-dominant. The DAS

implies an acknowledgement of a risk that the height and bulk of the

proposed hotel may be too big and out of keeping with the rest of St

Davids. We concur, and say that the hotel would indeed be too big and

out of keeping.

The LCA recommends, in its management guidance, that the edges of the

settlement should be rehabilitated ‘so as to be more sympathetic to the

surrounding Landscape of Outstanding Historic Interest in Wales, with

particular emphasis on achieving a smooth transition from the urban edge

to the open countryside.’ It is NOPI’s view that, if a ‘gateway building’ of

any kind was felt to be desirable at Glasfryn Road, a building of the size

and type of the proposed hotel would not be appropriate to the character

of St Davids. Furthermore, the proposed design is counter to the

recommendation of a ‘smooth transition’ from the urban edge to the open

countryside and would not result in an enhancement of a gateway location

to the historic city of St Davids.

The DAS does not explain arrangements for lighting the proposed hotel

and its car park, which would presumably have to operate 24 hours a day.

Under these circumstances we would have expected the application to

include a full lighting scheme, in accordance with the LDP (Policy 9, 4.61).

As noted in comments on the LVIA, a poorly-designed scheme to light the

hotel has the potential to have ‘a significant adverse effect on the

character of the area, local residents and the visibility of the night sky,’ as

well as on wild fauna. It is therefore important that a lighting scheme is

submitted prior to determination of the application, so that all aspects of

the proposals can be fully assessed.

The DAS examines local buildings to determine characteristics of the local

townscape and vernacular architecture with which the design of the

proposed buildings should be in keeping. The lengthy analysis of other

buildings in St Davids borrows without acknowledgement from the

Conservation Area SPG, and is limited in scope by comparison with other

accounts of the architecture of St Davids (e.g. in the Buildings of Wales

series). Two examples of buildings are chosen as ‘precedents’ for the

design of the hotel (pages 66, 69 and 70), apparently a new building and

a conversion of a farm building, although they are unidentified and do not

appear in the previous description of buildings characteristic of St Davids.

The ’palette of materials’ for the proposed hotel (page 73) are all modern

and do not derive from materials previously noted as characteristic of St

Davids buildings; the brief list of materials is illustrated by a photograph

of lichen-covered ‘local stone’, although this is not on the list.

The LDP, emphasising the requirement for sustainable design, states that

a development must be ‘well designed in terms of place and local

distinctiveness’, and a footnote clarifies that this applies to ‘landscapes

and townscapes’ (LDP, Policy 29 (a)). The LDP goes on to state

categorically that development will not be permitted that is ‘of a scale

incompatible with its surroundings’ or ‘visually intrusive’ (LDP, 4.135 and

4.136, Policy 30, (b) and (d)). We contend that, in size and design, the

proposed hotel fails to meet these requirements, and is therefore contrary

to LDP policies 29 and 30.

In its summary, the DAS extols the proposed hotel as utilising ‘its gateway

position to enhance the status of the city’ (page 76). We regard this as a

ridiculous boast. The patron saint of Wales, the ancient cathedral and the

prominent chapels endow St Davids with more status than a mere hotel,

however big, could ever reasonably claim to do. Yet the statement

inadvertently sums up what the DAS reveals about the proposed hotel:

that the hotel has been added to a long-demanded housing scheme in

order to exploit a commercial opportunity that would otherwise not exist;

it is extremely unlikely that a hotel of this size and design considered on

its own merits and in any other circumstances, would be considered

acceptable in St Davids. The details in the DAS show that the proposed

hotel has been designed, despite assertions to the contrary, in an

insensitive and uncaring way, with scant regard for the context of the site,

its cultural background, the economic interests of the resident population

or the limitations of access to, from and around the site.

Further detail on the limitations and flaws in the DAS, and references are

provided in Appendix 7.

6. Comments on the Ecological Appraisal

NOPi have not had the resources to engage an ecologist to fully consider

the content of the ecological report submitted by the applicants. However,

a professional ecologist has submitted comments which are included in

Appendix 9. As with the other assessments prepared in support of the

application, it is evident that there are a number of flaws in the ecological

appraisal, such as the various references to Pembrokeshire County Council

and their LDP, instead of the National Park Authority and the correct LDP

to be taken into consideration.

Notwithstanding, should Pembrokeshire Coast National Park Authority be

minded to approve the application, NOPi request that conditions be

attached to the permission in line with the recommendations in the

Appraisal contained in paragraphs:

5.20 (planting and litter bins), 5.21 (Ecological construction method

statement, and landscape and ecological management plan), 5.31

(Ecological Construction Method Statement), 5.32 (Bird Boxes), 5.36

(Planting up of banks and hedgerows), 5.37 (sensitive lighting strategy),

5.40 (badger sett closure licence and further surveys), 5.41 (machinery,

no night working, covering up trenches/excavations and means of escape,

5.45 (Methods to avoid harm to reptiles etc, long term maintenance and

management of the site etc.).

7. Comments on the Planning Statement

The Planning Statement considers national policy contained in Planning

Policy Wales and the PCNP LDP and how the applicants consider the

planning application proposals comply with national and local policy. As

with the Assessments and Statements reviewed above, again there are

many flaws in the Statement, and many of the conclusions reached are

inaccurate; for example, the statements that the hotel is required as a

catalyst for housing at the site. The improvement of Glasfryn Road acted

as a catalyst for the development of the site, but that was already planned

for in the LDP. As noted in section 4 DAS above, Pembrokeshire Housing

Association has confirmed that subject to the necessary planning

permission they will be developing housing at the site with or without the

hotel.

Other examples of flawed conclusions include the economic impacts of the

hotel and its associated job creation; the failure to take on board the

Design Commission for Wales’s comments on the integration of affordable

and market housing; visual and landscape impacts; as the site is allocated

for housing development in the LDP the assumption that a hotel is

therefore also acceptable at the site; and the considerable

misrepresentation of numbers of comments received in the pre-application

consultations that were undertaken with PCNPA, DCfW and other statutory

consultees.

Many of these points are addressed by NOPi in the preceding sections of

this response, so it is not proposed to repeat them here. Further

comments particularly on the disingenuous behaviour of the applicants

and the misleading statements made during the development,

consultation and planning process are provided in Appendix 9 Comments

on Planning Statement.

List of Appendices

Appendix 1 Detailed Response of NOPi

Appendix 2 Oswald Priddy Premier Inn Economic Assessment 24 2 18

Appendix 3 Premier Inn Variable Pricing Strategy

Appendix 4 Accommodation Survey 2017

Appendix 5 Comments on Landscape and Visual Impact Assessment

Appendix 6 Comments on Transport Assessment

Appendix 7 Comments on Design and Access Statement

Appendix 8 Comments on Ecological Appraisal

Appendix 9 Comments on Planning Statement

Appendix 10 Petition Numbers & Comments