Agenda item

7.1 - OP/2025/3 – Ty’n Llain, Malltraeth

OP/2025/3

7.2 – OP/2025/1 – Llanfawr Road, Holyhead

OP/2025/1

7.1  OP/2025/3 – Outline application for the erection of a dwelling with all matters reserved on land adjacent to Tyn Llain, Malltraeth

The application was presented to the Planning and Orders Committee at the request of a Local Member.  At its meeting held on 2 July, 2025 the Committee recommended a site visit, and this subsequently took place on the 30 July, 2025.  At the Planning and Orders Committee held on 3 September, 2025 it was resolved to approve the application, contrary to the Officer’s recommendation as it was considered that the site is an area with no flooding history and is an infill site between existing residential properties.  The site is in a flood zone at risk from sea flooding, but Malltraeth has flood prevention measures that are maintained by NRW. 

The Planning Development Manager reported that the application site lies predominantly within Flood Zone C2 on the Development Advice Map, for the purposes of TAN 15 (2004).  The whole application site also falls within Flood Zone C3 Seas, on the more up to date Flood Maps for Planning referenced in the recent TAN 15 (2025).  Welsh Government published a new TAN 15 during the process of this application.  The document confirms that it should be read in conjunction with Planning Policy Wales (PPW) and the Welsh National Marine Plan and that it replaces TAN 14 and the previous TAN 15.  However, the Ministerial Written Statement dated 31 March, 2025, which accompanied the publication of the new TAN, shall continue to be assessed against the previous version.  Flood Zone C2 is defined as areas of the floodplain without significant flood defence infrastructure and TAN 15 (2004) makes it clear that ‘highly vulnerable development’ which includes all residential premises, should not be permitted in such zones.  This principle is particularly important considering climate change, which Planning Policy Wales (Edition 12) notes is likely to increase the risk of flooding due to seal level rises.  Planning Policy Wales also advises that planning authorities should adopt a precautionary approach of positive avoidance of development in areas of flooding from the sea or from rivers.  These principles are reflected in policy PS6 of the Local Development Plan which, among others, seeks to ensure that development is located away from flood risk areas, in order to adapt to the effects of climate change.  Highly vulnerable development is classed as being all residential premises, public buildings, especially vulnerable industrial development and waste disposal sites.  Paragraph 7.4 of TAN 15 states that before deciding whether a development can take place an assessment, which examines the likely mechanisms that cause the flooding, and the consequences of the development on those floods, must be undertaken, which is appropriate to the size and scale of the proposed development.  Natural Resources Wales object to the application as the Flood Consequences Assessment fails to demonstrate that the risks and consequences of flooding can be managed to an acceptable level in line with TAN 15.  It fails to demonstrate that the entire development site has been designed to be flood free in the 0.5% (1 in 200 years) tidal event plus climate change.  The flood assessment is also considered outdated having been written 19 years ago with only recent addendum.  Natural Resources Wales also have significant concerns regarding the vehicular access and egress to the site which would be significantly compromised in flood conditions and the lack of information regarding the pedestrian access/egress route to the north of the development site.  Any Flood Consequences Assessment should consider appropriate breach assessments, specifically considering projected velocities given the proximity to the development site to the embankments at Malltraeth Marsh.  Natural Resources Wales are aware that the Afon Cefni has breached on numerous occasions and state that it should be considered as part of any amended documents.  The applicant was given the opportunity to revise the Flood Consequences Assessment in light of Natural Resources Wales’s comments, however, no further information was received such that Natural Resources Wales object to the development on flooding grounds. 

Whilst the Flood Consequences Assessment concludes that the flood risk to the proposed development can be managed to meet all the recommendations of Natural Resources Wales and TAN 15.  TAN 15 (2004) is clear that residential uses which are highly vulnerable development in Zone C2 should not be permitted.  Paragraph 11.7 of TAN 15 (2004) states that where the planning authority is minded going against the advice of the Environment Agency, it should inform the Agency prior to granting consent, allowing sufficient time for further representations to be made, to ensure consequences can be managed acceptably.  If Members approve the application, despite the Officers recommendation, the Local Planning Authority must refer the decision to Natural Resources Wales before releasing any decision, however, there is no need to present the application to Welsh Ministers, as would have needed to be done if it was presented after 1 April 2025. The recommendation continues to be that the application should be refused for the reasons given.

Councillor Arfon Wyn, a Local Member said that when the application was presented in March 2025, Natural Resources Wales used the Development Advice Maps to categorise the risk of flooding in the proposed development site.  The site was classed within the C2 flood zone.  He noted that there are flood defences in Malltraeth and Natural Resources Wales continually maintain the flood gates.  The area was classed at C1 flood zone in 2006 which is defined as an area protected from flooding.  He questioned as to what has changed and if there was flooding in the area in hundreds of years the occupants could deal with the situation.  He considered that David’s Street could be used as an escape route.  Councillor Arfon Wyn further said that the application needs to be considered at the present time.   He considered that the defences are more than sufficient to prevent any flooding.   The Planning Development Manager responded that the application site needs to be assessed at the present time, and the site is within a C2 flood zone. 

Councillor John Ifan Jones said that Malltraeth Marsh has existed since over 200 years, and the flood zone maps refer that there is risk from flooding from the sea.  He noted that there has been no flooding from the sea and the existence of Malltraeth Marsh is to protect any flooding with flood gates.  The location of the proposed dwelling is 300 yards up on the drive between two other properties.   Councillor John Ifan Jones proposed that the application be approved contrary to the Officer’s recommendation.

Councillor Robin Williams said that there was a similar application in the Valley area, with a conversion of a Capel into a dwelling that was surrounded by other dwellings.  He considered that this application is also surrounded by other dwellings, and he questioned as to why Natural Resources Wales were insisting that the proposal should be refused as it was in a flood zone C2.    Councillor Williams seconded the proposal of approval of the application.

Councillor Roberts Ll Jones said that he considered that the application needs to be refused as there is potential that the defences will fail.  The level of seas is becoming high each year due to climate change.  Councillor Robert Ll Jones proposed that the application be refused in accordance with the Officer’s recommendation. 

Councillor Jeff Evans seconded the proposal of refusal and noted that any approval of the application will be forwarded to Welsh Government, and it is likely that the application will be refused. 

The Planning Development Manager said that when the updated TAN 15 was published on 31 March 2025 the application site in within C3 which needs to be assessed by Welsh Government Ministers, however, the application was presented before the updated TAN 15 was published, therefore, there is no duty on the Local Planning Authority to refer the application to Welsh Government.   He further said that it must be considered that whilst no flooding has occurred in the area this could change in the future and Natural Resources Wales’s opinion needs to be complied with.  He noted that the applicant was given the opportunity to present a Flood Consequence Assessment which they declined which could have addressed the flooding requirements. 

Councillor Kenneth P Hughes said that he supported the application due to consistency as their numerous houses been built in the village of Valley which has similar flood zone criteria. 

Councillor John Ifan Jones said that Natural Resources Wales continuously monitor and carry out maintenance on a regular basis at Malltraeth Marsh to protect the area from the sea.  Residents living near the river have not experience any flooding in decades and have no problems in attaining house insurance. 

Councillor Robert Ll Jones requested a recorded vote on the proposal.  Councillor Jeff Evans seconded the proposal. 

Following the vote of 2 in favour of a recorded vote and 9 against, there was not recorded vote taken.

It was RESOLVED to reaffirm the decision to approve the application contrary to the Officer’s recommendation.

7.2  OP/2025/1 – Outline application for the erection of 9 affordable dwellings which includes full details of access, appearance, layout and scale on land near Llanfawr Road, Holyhead

Councillor Glyn Haynes declared a personal and prejudicial interest in the application as he is a Member of the Holyhead Town Council who is the applicant.  Councillor Haynes left the meeting during discussion and voting thereon.

Councillor Trefor Ll Hughes MBE declared a personal and prejudicial interest in the application as he is a Member of the Holyhead Town Council who is the applicant.  Councillor Haynes left the meeting during discussion and voting thereon.

The application was presented to the Planning and Orders Committee at the request of a Local Member.  At its meeting of the Planning and Orders Committee held on 3 September, 2025 the Committee recommended a site visit, and this subsequently took place on the 17 September, 2025.

Public Speakers

Ms Charolette Morrison, opposing the application, said that she was representing  32 local resident who will be negatively affected by the application to build on the Cae Braenar park.   She said that she has spoken to 33 residents in Morawelon, Cae Braenar, Llanfawr Road and 32 people were against the plans to build homes on field.  Concerns were expressed as to where will they park their cars?  Is it going to be safe? This play park is a necessity for the local people. Will this mean drains overflowing even more? Where will the children to play?  It is a large area, and most would not believe that the whole space is being used, but as a resident in the area, she is aware that this whole green space is being used daily. This area is one of the only green spaces left in the already built-up area of Morawelon. It is a space that is used by residents of all ages, used widely throughout the year, getting more than 100+ people visit each day during the dryer months. As she lives opposition the site, she can see this field and play area being used daily. It promotes health and wellbeing in the residents of the area. Without this area, the young children and families would have to walk to London Road to use a play park, which for most is not accessible as there is an extremely busy road between their homes and this play park.  She noted that some people would say that Beibio field could be used. Beibio field is very wet field, and the play park is only suitable for children who can climb trees.  She noted that her 4-year-old son is one of the many children who play at Cae Braenar park daily, meeting other children from his school class and encouraging their social development. Cae Braenar park is a meeting place for most of her son’s school and their families and friends, this a way for parents to relax knowing that their children are playing safely. They use the football field up the top, the field behind the old police houses and the play park below. Cae Braenar field is one of the only green spaces available for the young children and families in this heavily built-up area. Where would they go when this space is gone? The proposed location for the road is another concern by residents,  as they live and are already affected by the busy road. Most residents already find it difficult to get down this road during busy periods, which does cause accidents. There have been numerous accidents involving other cars and children on this road in the past few years, and most residents who live on the road have photo proof of these accidents and most probably police reports about them.   Residents were informed that speed calming humps could potentially be put on the street but in this case, it is not the speed, but the quantity of cars in this area which make it unsafe. The new estate built in Cae Braenar will create additional vehicles to this already busy road.  Drainage uses were also of concerns as the drains from 10 Llanfawr Road all the way down to the end of the street by the Prince of Wales Pub already fill up and overflow during the wetter months, this creates overflow into gardens, will this worsen when the proposed estate and their drainage is created?  It is understood that there are issues with water to the new estate in Cae Braenar which is already built, Welsh Water was at the end of Cae Braenar approximately 4 weeks ago fixing pipes. Is the drainage able to support another estate in this area? She expressed that there is a need for social housing, but due to the numerous concerns about safety, drainage and traffic, it is considered that this location is not suitable for this application, this green space provides a safe area for local families to gather and grow.

Councillor Robert Ll Jones questioned as to how many years has the playing field existed on the site and the variety of ages of children playing on the field.  Ms Morrison responded that the playing field has existed on the site for many years and a variety of ages of children play daily on the playing field.   She said that the playing field is used by the whole community of Morawelon. 

Mr Ian Roberts, in support of the application, said that he was representing the Town Council and said that this application is an important proposal that seeks to address a need for safe, high-quality, and genuinely affordable housing. The proposed site is currently owned and maintained by the Town Council and has been identified as a suitable location for this development following careful consideration, community engagement, and adherence to the policies and processes set out by both local and national planning frameworks.  The Town Council undertook a comprehensive 12-week public consultation, in accordance with Welsh Government guidance. As part of this process, a public meeting was held and a letter of intent was delivered to all nearby properties, ensuring residents were fully informed of the proposal.  Resulting from that consultation, 15 formal responses was received with most concerns centred around the potential for increased traffic on the Llanfawr Road.  However, it is worth noting that during the pre-planning process, the Highways Department did not raise any objection or concerns about the potential traffic increase associated with this proposal.  The traffic volumes in the area have reduced significantly in recent years, particularly following the downsizing of operations at Kempston Controls Manufacturing, formerly known as M.E.M. Electrics, a large local employer whose footprint on daily traffic flow has now diminished substantially.  Several homes along Llanfawr Road do not currently make use of their off-street parking, driveways and garages, and instead choose to park on the road. This can create an impression of congestion that may not accurately reflect the capacity or reality of traffic usage on this road.  The Town Council does not dismiss community observations, but  it is important to place them in context, supported by both professional input and data where available.  The land in question is a piece of scrubland, which, while green in appearance, is not designated as public open space, nor is it actively used by the local community for recreation or amenity purposes. It is maintained by the Town Council and over time, it has become clear that the land is underutilised in its current form.  By developing this site, it is considered that it delivers real, long-term benefit to the community, providing homes, enhancing the area’s infrastructure, and contributing to overall social wellbeing.

Across the UK, and particularly in Wales there is a well-documented housing crisis. Local authorities everywhere are struggling to meet the demand for social and affordable homes, and this area is no exception.  Waiting lists in the local area are at an all-time high with families waiting months, sometimes years, for secure, affordable accommodation. This development will not solve the problem overnight, but it is a meaningful step in the right direction. It aligns with the housing targets set by both the Welsh Government and the UK Government, and represents a responsible, sustainable, and locally led solution.  As a Town Council, it is considered a moral duty, as well as a practical one, to take positive steps that support the resident and especially those most in need.  In addition to the proposed homes, the Town Council is committing to a £30,000 investment in the local play area and surrounding green spaces which is a clear and direct benefit to the wider community. This funding will help improve outdoor recreational facilities, increase biodiversity, and provide safe and attractive spaces for children and families to enjoy.  It is believed that it is important that this development delivers net gains not just in housing but in community wellbeing.  The Town Council has worked closely with planning officers, who have recommended approval of this scheme which reflects the strength of the application, its policy compliance, and the clear public benefit it brings.  This application meets the criteria outlined within the Local Development Plan, Affordable housing policy, Sustainable development principles and Community engagement standards.

The Planning Development Manager reported that the proposal is an outline application for the erection of 9 affordable dwellings (social rented) with the access to the site, appearance, scale and layout being considered as part of the current application. The proposal is for the erection of 6 bungalows, one pair of two storey semi-detached properties and one detached dwelling. Access to the site will be via Llanfawr Road and will run along the side of the property known as 32 Llanfawr Road.  The site is located within the development boundary of Holyhead and on land that has been allocated as open space within the Anglesey and Gwynedd Joint Local Development Plan. The site lies between Bryn Glas Road and Cae Braenar Estate with a mixture of houses surrounding the site.  The application complies with the Local Development Plan as it sits within the development boundary of Holyhead and there is capacity within the indicative supply for houses in Holyhead. The Housing Department have confirmed that the mixture of housing is appropriate and complies with TAI 8, and as some are affordable it also complies with the requirement of policy TAI 15.  Despite the intention being to provide 100% affordable dwellings, as the policy requires 10% in Holyhead, 1 dwelling will be affordable within the Section 106 agreement, and the remaining 90% will be to the developers’ discretion.  The site is designated as a protected open space under Policy ISA 4 of the Anglesey and Gwynedd Joint Local Development Plan andthere is a commitment to improving play facilities in the area and will be fully conditioned with any approval of the application.  The Town Council has set the annual rate of £30,000 towards improving the existing facilities. He further said that the northeast of the site, located between Cae Braenar and the coast, is an open space. Whilst the proposal does not fully comply with the requirements of Policy ISA 4 the proposal will provide affordable social housing for the community and will improve the existing play facilities. Concerns have been raised that the means of access to the proposed dwellings will run alongside the 32 Llanfawr Road. Screening by way of planting is proposed along the border of the site with the property which will act as a visual and noise barrier, and a detailed landscaping plan will be conditioned with any approval of the application.  It is not considered that the application will have a negative effect on the amenities of neighbouring residential properties, and the distances comply with the relevant Planning Guidance.  The Highway Authority has been consulted and raised no objection to the proposal. Whilst it is acknowledged that the erection of 9 new dwellings may generate additional traffic, the site lies within the development boundary of Holyhead which is designated as an Urban Service Centre. The additional 9 dwelling will not generate significant additional traffic on one of the main roads to the Town, that runs from Penrhos Stanley Hospital to the Port on the other side.   Concerns have been raised by a Local Member of the impact of the proposed scheme on ecology. The Ecological Advisor has received a copy of the issues raised and confirmed that there was no objection to the scheme.

The application site does not encroach onto the neighbouring scrubland to the west of the application site. The landscaping scheme and Green Infrastructure Statement has been submitted stating the number of trees to be planted as part of the proposal, however, it is considered that a detailed landscaping scheme will be required to show the number of each native species, and the location of the proposed bee box will be required as part of any future detailed or full application. The recommendation was of approval of the application subject to a Section 106 legal agreement that one of the properties will need to be affordable.

Councillor Pip O’Neill, a Local Member said that whilst a small proportion of the play area will be lost as part of the development, he supported the application as there is a need for social housing and the dire need for bungalows as there is 118 people on the housing list for dwellings.  He noted that there will be limited loss of biodiversity and natural habitats as part of the development.  He further said that following consultations on the development a public meeting arranged and the main concerns of residents were additional traffic issues in the area.  He considered that speed calming humps should be considered and especially with the additional development within the Cae Braenar estate. 

Councillor Jeff Evans, and a Local Member said that it is accepted that there is a need for such a development, however Welsh Government’s Playing and Community Involvement Measure and Disposal Regulations (Wales) 2015 highlights the importance of playing fields and states that sports and recreation contribute to the quality of life.  Welsh Government supports the development of sports and recreation and a wide range of leisure pursuits which encourages physical activity for the health and wellbeing of children and adults.  Local Authorities should recognise the importance of play area for community use.  Planning Policy Wales indicates that all playfields should be protected from development.  He noted that the concerns of the residents are increase traffic from the development, loss of open space, footpath that runs through the site, drainage issues, impact on the value of neighbouring properties together with the effect on ecology and biodiversity.  Councillor Evans expressed that as a Local Member he considered that such a development should be developed on an alternative site without the impact on the limited open spaces and playing fields.  Councillor Jeff Evans proposed that the application be refused for the reasons given. 

The Planning Development Manager referred to the Playing and Community Involvement Measure and Disposal Regulation (Wales) and noted that whilst part of the playing field will be used there will still be a playing field on the site.  He said that the contribution of £30k by the Holyhead Town Council will be used to improve the playing facilities on the site.  He referred to the concerns as regards to traffic issues and noted that whilst there are parking spaces outside the dwelling opposite the site, the residents are parking their vehicles on the roadside. 

The Legal Adviser referred that the decision of this Committee is to consider the planning policies as regards to the application and not the disposal of the playing field regulation. 

Councillor Jackie Lewis referred that NRW have expressed concerns as regards to the drainage on the site and she questioned whether the development negative effect on the land.

The Planning Development Manager responded that NRW had initial objected to the application that the drainage system was to be connected to a private sewerage system.  The Agent of the application confirmed that the application form was completed incorrectly, and the proposed dwellings were to be connected to the mains sewer system and amended the application form.  Welsh Water has not objected to the application.  He further said that the surface water will be considered by Welsh Water under the SAB process before construction on the site and the legislation ensure that there is no effect on neighbouring properties and the whole site.   He reiterated that NRW have not objected to the proposal.  

Councillor Neville Evans said that during the site visit it was evident that the site was near a busy road with cars parked on the road.  He ascertained as to how many recorded accidents had occurred in the area.  The Group Engineer (Development Control) & Traffic Management responded that there have been no recorded accidents reported in the last five years in the area.  However, he said that this does not mean that there no accidents have occurred. 

Councillor Kenneth P Hughes said that he was disappointed that the Holyhead Town Council have submitted the application as there will be a loss of the half of the playing field.  He noted that playing field needs to be protected for children.  Councillor Hughes seconded the proposal of refusal of the application. 

The Planning Development Manager responded that whilst accepting that half of the playing field will be taken there was a requirement in considering the need for affordable dwellings against the playing field facilities and there is justification to designate the site for development.   

Councillor Robert Ll Jones said that he was also disappointed that the Holyhead Town Council have submitted the application as it is important that developing such a proposal will take more than half of the playing fields.  He referred to the Welsh Government’s Playing and Community Involvement Measure and Disposal Regulation (Wales) 2015 and noted that local authorities need to protect playing fields for the wellbeing of children within a safe environment.  He considered that there are other sites in the area that would be more suitable for such a development. 

The Planning Development Manager reiterated that the playing field will still exist on the site and the Welsh Government’s Playing and Community Involvement Measure and Disposal Regulation (Wales) 2015 is not relevant as part of the application.  He noted that a 12-week public consultation, together with a public meeting was undertaken by the Town Council, which was not a statutory requirement. 

Councillor Geraint Bebb ascertained whether the £30k contribution by the Town Council will be specifically for the playing field on the site or will it be shared with other playing fields in the area.  The Planning Development Manager responded that it is considered that the £30k contribution will be for this area but discussions will need to be undertaken when the full application is submitted. 

Councillor John Ifan Jones ascertained as to the footpath on the site and whether children will have to walk into the road to get to the play field, he further questioned as to how the play area is to be developed.  He noted that there has been no response to the application by the Environment Officer nor the Public Rights of Way Officer.    The site plan was shown on the screen to the Committee and the Planning Development Manager referred to the two footpaths in blue on the site plan with one footpath leading from the Stanley Monument and with then join the new footpath towards the playing area.  He noted that the details of the proposed play area will be afforded when the full application will be submitted and a condition as part of the approval will need to be submitted by the applicant. 

Councillor John Ifan Jones further ascertained whether the affordable element of the proposed application is for the whole site.  The Planning Development Manager responded that as the site is within the development boundary of Holyhead the requirement is that 10% of the dwellings need to be affordable.  Therefore, one unit can only be safeguarded as affordable through the Section 106 legal agreement, and the remainder of the dwellings will be at the discretion of the developer. 

Councillor Neville Evans ascertained that whilst the Town Council wishes to 9 dwellings to be affordable, which has been agreed with the Housing Department,  planning policies are unable to condition that all the dwellings should be affordable.  The Planning Development Manager responded that the Town Council are in discussion with the Housing Department and other Housing Associations and all the dwellings will be rented accommodation. 

Councillor Dafydd Roberts proposed that the application be approved in accordance with the Officer’s recommendation as the proposal complies with planning policies.  Councillor Robin Williams seconded the proposal of approval. 

Following the vote of 5 in approval of the application and 5 for refusing the application, the casting vote of the Chair was to approve the application. 

It was RESOLVED to approve the application in accordance with the Officer’s recommendation, subject to the planning conditions contained within the report.