The following is a copy of the response to the Local Development Plan by the chair and committee of the Save Brynhir Green Space and Wildlife Group.

Sir,

Re: public consultation on Local Development Plan Preferred Strategy - request to remove Brynhir site from the Local Development Plan.

Thank you for the opportunity to comment on the ‘Preferred Strategy’ section of the replacement Local Development Plan - end date 2031.

This is the authorised response on behalf of Save Brynhir Green Space and Wildlife Group. As you will be aware, this group was formed in protest to proposed development of the Brynhir area and is overseen by a chair, Rebecca Nelson and a committee of committed local residents who are opposed to building on this site. In addition, over 1,000 supporters are members of a closed group on Facebook. The group’s aim is to persuade the planning authority and the landowners (Pembrokeshire County Council) that this area should be removed from the Local Development Plan and not be built upon, thus protecting the local environment and wildlife.

The ‘Preferred Strategy’ document is built upon newly gathered evidence in support of a vision for Tenby and we would argue that the Brynhir site does not have strategic fit with the vision for Tenby and surrounding areas from 2021-2031.

Our arguments against the inclusion of Brynhir in the next development plan are:

1. Unnecessary Over-development - this proposed site consists of a very large number of new houses, putting undue strain on local resources, including health, police, social care and education services and strain on fragile infrastructure such as sewerage, drainage, water supplies. We are concerned that a flooding risk exists if this development were to go ahead. Added to this is an overwhelming burden on already congested roads and parking especially in the summer months.

The strategy illustrates that the population of Tenby is in decline, the current estimate of population is 4,500, the population of the Pembrokeshire Coast National Park is declining and assumptions within the development plan over 20 years ago when this site was first identified were that population would grow. Against a national backdrop of increasing populations, in the National Park area and also reflected in Tenby itself, since 2001 the population has declined by over 10 per cent. The proposed housing development is currently assumed to be around 168 houses, this could mean around 600 more residents, which equates to increasing the local population by 13 per cent. We argue that this is disproportionate and unnecessary. As readily admitted by the National Park in letters to the group, there is no market demand for more houses and this is evidenced by the development of new executive homes on the opposite side of Narberth Road which have been reduced a number of times and are not selling. We could also point to various failing housing developments in the wider local area. To lose this beautiful area in order to build houses that are not needed and for which there is no economic case would be a tragedy indeed. We understand that the economic model for the development of affordable homes (for which there is demand) depends on market housing. This renders this plan unworkable.

2. Visual impact - the group has been actively seeking support from like-minded bodies in the area who seek to maintain Tenby’s unique character, in a meeting with the Civic Society, they share our view that this site is unsuitable for development because of the topography - the slope of the land means that it is readily seen from the coast, Caldey Island and from the estuary. They also raised their concerns about the relaxation of rules establishing a ‘green wedge’ between Tenby and New Hedges. This is being slowly eroded by permission being given for other developments.

The group is also concerned about the visual impact of such a large housing estate on the main road into Tenby, changing the visual welcome to visitors to the town and potentially impacting on the local economy.

3. Environmental impacts - this area is habitat to many protected species. Regularly spotted are foxes, badgers, birds of prey, slow worms, toads, voles and other small mammals. It is a travesty that the National Park whose role it is to protect such heritage is prepared to develop this area. Although we recognise that it is the job of the National Park to balance economic growth with environmental issues, new housing does not of itself bring economic prosperity. This is an important green space within a town with very little, losing it is unthinkable.

4. Economic aspects - jobs in the area are largely low -paid seasonal jobs, many people working at two or three part-time jobs in order to make ends meet, making house purchase an unattainable dream for many. Even affordable homes at 20 per cent below market value is not affordable and will be sold as second homes, a large proportion of the housing stock is Tenby is not lived in all year round. It is counter-intuitive to build more houses when there is such under occupancy. Policy needs to be developed around securing low cost homes for local people when they come up for sale.

Tenby’s future (as evidenced in the Preferred Strategy document) is largely dependent on tourism. Tourism depends on attractive venues and amenities. There are a number of camping and caravan sites in the area and people love to bring their dogs on this type of holiday. These holidaymakers need open space in which to exercise their dogs, at present they use the Brynhir fields extensively for this purpose, should this amenity be lost then dogs will be taken on the beaches (which have summer dog bans) and park areas in Tenby resulting in potential risks to public health. As being able to bring pets on holiday is a main reason for camping and caravanning holidays, on which Tenby has such dependence, holidaymakers will go to other places where their dogs are welcome losing this income from the local shops and businesses. Local residents also need open space in which to take their animals and the fields are used all year around.

It is argued by the council that the fields are development land previously let for agriculture and that people shouldn’t be using these places for amenity, however, the council has allowed the placing of seating near the footpath for people to sit when walking their dogs, thus reinforcing the impression of the area as amenity land. The group believe that the Brynhir site should be removed from the LDP and held in perpetuity as amenity land managed under agricultural tenancy as it was before the land was put up for sale.

Tourism depends on the favourable impression of visitors entering the town, as the Brynhir site adjoins the main road into the town, it will be very visible to people on the Narberth Road and could also readily be seen from the coast and Caldey Island. The additional huge increase in population will add to the road congestion which is already putting off visitors especially during the summer when parking is at a premium.

5. Feasibility - previous criticism had been levelled at the National Park LDP by experts, doubting that the Brynhir site was suitable for inclusion in the plan because of the prohibitive costs of bringing the housing to fruition. Using the model of private development enabling affordable homes to be built does not work in a depressed housing market and is further complicated in this case by the need to build in expensive infrastructure in order to overcome the issues in point one above. There is no demand for more market property apart from as second homes. We would now argue that, as Pembrokeshire County Council has been trying to negotiate the sale of the land for development since August 2015 and failed, this site has been thoroughly market tested. It is now time for the planning authority to remove this site from the LDP to be in place for 2021 and lift the damaging planning blight on existing homes in the area whose saleability and value are negatively impacted whilst there are so many unknowns about any potential development. It is argued that as development has not been feasible over the past 30 years or so the planning authority should revise its plans accordingly and cease to cite this area as a potential development site. Other smaller, brown field sites (perhaps not directly in Tenby) need to be found for social housing and affordable homes. There are numbers of empty homes in evidence in the area and the council has powers to take these on and let them as social housing if they so wish, we would like to see these empty houses return to use as family homes within existing estates rather than build on a beautiful greenfield site. Numbers need to be revised downwards in light of the latest population decline and future trends. Tenby is unique and is the jewel in Wales’ crown protected by National Park status, it is time for that protection to be exercised and small scale, creative solutions to be found if there is sufficient will for it to happen.

As a group, we are more than willing to meet with any representative of the planning authority and discuss these matters further.

The chair and committee of the Save Brynhir Green Space and Wildlife Group