A proposal to allow year-round occupancy of static caravans at Amroth Castle Holiday Park in south Pembrokeshire has been refused by Pembrokeshire Coast National Park Authority, following concerns about the implications of removing longstanding seasonal restrictions at the site.
Amroth Castle Holidays Ltd, through agent Laister Planning Limited, had applied for a Certificate of Lawfulness seeking confirmation that static caravans at Amroth Castle Holiday Park could be occupied throughout the year, including as a sole or main place of residence.
The application centered on the interpretation of planning permissions granted for the site in 1967, 1970, and 1985.
According to the Western Telegraph, a condition attached to the 1985 approval stated that the authority “does not authorise” occupancy of caravans between January 10 and February 28 each year. The applicant argued that this wording did not impose a prohibition on occupancy but instead clarified the extent of the authorization granted.
The supporting statement said: “Therefore, going beyond this occupancy would not be a breach of condition and any attempt to enforce it as a prohibition would struggle to identify a breach of planning control. Therefore, it is the applicant’s position that the seven week out-of-season period is not enforced by a planning condition and would be possible to extend such occupancy, provided that it does not amount to a material change use.”
The proposal drew objections from Amroth Community Council, which argued that allowing 12-month occupancy could alter the site’s function from a tourism-based holiday park to one accommodating permanent residential use.
In its objection, the council stated that a 12-month use license “would open the park to residential occupation rather than tourism and this was to be resisted.”
The council also expressed concern that approval could create wider implications for other holiday parks in the area.
It said: “No other caravan/lodge or chalet holiday parks in the Amroth community area of the National Park are allowed to offer 12 months residency on site and so approving this application would set up a precedent for other holiday parks to follow and operate without restriction.”
Additional concerns raised by the council included the possibility that the proposal could create “an opportunity to change the caravans to chalets/lodges which are larger in size and will take up more room, potentially extending the area of the park and increasing density”.
Planning officers recommended refusal of the application. In a report, officers noted that the site’s use as a caravan park had been established through earlier planning permissions but that those approvals also established limitations on both occupancy and use.
The report stated: “The use of the land as a caravan site was established in the previous planning consents, as mentioned above.
“It was further established through these permissions that the caravans would be limited in number and locations within the site and would be occupied only as temporary accommodation, and not for any period between January 10 and February 28 in any year.”
Addressing the applicant’s interpretation of the occupancy restriction, officers emphasized the long-standing planning purpose of seasonal conditions.
The report said: “Seasonal occupancy conditions are a long-established tool used by planning authorities to distinguish between holiday use and permanent residential occupation.
The underlying principle is that a mandatory period of non-occupation breaks the continuity required for a property to be considered a permanent residence. This approach has historically been favoured by many local authorities because it is perceived as readily enforceable through simple site inspections during the specified closed period.”
Officers concluded that allowing year-round occupancy would exceed the scope of the permissions granted in 1965, 1967, 1970, and 1985.
The report found that all-year caravan occupation at the park “would go above and beyond existing authorisations as established by the 1965, 1967, 1970 and 1985 planning consents,” adding it would “result in a definable character change to the site of a magnitude that would be sufficient to amount to a material change of use requiring planning permission”.
As a result of the refusal, any future attempt to introduce year-round occupancy at Amroth Castle Holiday Park would need to be pursued through a formal planning application process rather than through a Certificate of Lawfulness.
For owners and operators in the outdoor hospitality sector, the decision highlights the continued importance of occupancy conditions in distinguishing holiday accommodation from residential use.
It also illustrates how planning authorities may view efforts to extend operating seasons, particularly within protected landscapes, where changes in occupancy patterns can be considered a material change of use requiring additional planning scrutiny.