Local Development Framework Consultation

AS11 - Camping, caravan and Visitor Accommodation

Yes

No

The DPD is not positively prepared

The DPD is not consistent with national policy

I am writing on behalf of Holgates Caravan Parks who have significant facilities within the Arnside & Silverdale AONB and at Far Arnside in particular.

My client's two key business interests are a camping and caravan site at Hollins Farm and also the larger Holgates site on Cove Road at Silverdale. Both are significant facilities within the AONB and both have been subject to considerable investment in recent years, including
additions to the accommodation at the site as well as a new swimming pool, alterations to the reception and the addition of a bowling alley. A new toilet block has also been constructed at the Hollins Farm site. All of the work has been carried out in a sympathetic manner and has added significantly to the economic and employment opportunities within the AONB. The swimming pool facility in particular is much used by local people as well as visitors to the site.

I would point out that my client is one of the largest employers within the AONB, employing approximately 160 full and part time staff.

My client has recently won a David Bellamy Gold Award because of the amount of work he has carried out in terms of planting trees and hedgerows in the area. My client is one of only 3 caravan parks in the whole of the UK to receive such an award.

Paragraph 4.8.1 openly acknowledges that the DPD takes a restrictive approach to new development.

The policy itself considers development proposals for new caravan, chalet, cabin or lodge style developments will not be permitted in order to conserve the landscape character and natural beauty of the AONB.

It is argued that this policy is too restrictive and that each case should be dealt with on its own merits. We consider that there is a lack of soundness in the plan in that it does not respond to the NPPF paragraph 28, which points out that planning policies should support economic growth in rural areas in order to create jobs and prosperity by taking a positive approach to sustainable new development. An emphasis is placed on a strong rural economy.

The third bullet point under paragraph 28 of the NPPF considers that:
Plans should:
- Support sustainable rural tourism and leisure developments that benefit businesses in rural areas, communities and visitors which respect the character of the countryside. This should include supporting the provision and expansion of tourist and visitor facilities in appropriate locations where identified needs are not being met by existing facilities in Rural Service Centres.

In light of the above we feel that the Plan does not comply with this bullet point in particular. The sensitive landscape of the AONB is recognised but in our view the policy is too restrictive.

The policy is restrictive towards the use of land for static caravans because of their unsuitable appearance within the protected landscape. However, existing sites do exist and it is considered that the redevelopment of those sites should be considered on their merits on a case by case basis and it is considered that there are ample landscape and environmental protection policies elsewhere within the DPD as a whole to ensure that unacceptable schemes are rejected.

In terms of modification to the policy it is argued that the policy should state that new caravans, chalet, cabin or lodge style development will only be permitted within the approved boundaries of an existing caravan or camping site where it involves the redevelopment of previously developed land.

The AONB has the same level of protection under the NPPF as a National Park and the nearby Lake District National Park runs a policy where new static caravan and camping sites are not acceptable and neither are extensions to them. However, the redevelopment and reconfiguration of existing sites, including additional caravans or chalets, is acceptable.
We do not see why the policy within the AONB should be more restrictive than that in a National Park which has the same restrictions under paragraph 116 of the NPPF.

At paragraph 4.86 the Council appear to welcome low impact visitor accommodation and the point we have been making with the Council is that increasingly visitors are looking for quirky and innovative forms of accommodation. However, the fact that this excludes chalets, cabins and lodges is of concern as the design of such accommodation can be some of the most interesting around. I attach, for instance, some images of the Lazy Duck Hostel located in the Cairngorms National Park where a range of innovative accommodation has been provided and which has actually won a design award with the Park Authority. We would consider that the ability to provide such accommodation within the existing approved boundaries of camping and caravan sites or on brownfield land within the AONB needs to be accepted as part of the policy.

In terms of the issue of brownfield development we are currently running an appeal for the replacement of the former Leeds Children’s Camp building opposite my client’s existing operation, for redevelopment for static caravans. The application was recommended for approval by Planning Officers but rejected by Planning Committee. This is an example where previously developed land can be redeveloped for the benefit of economic purposes to provide tourism income and also to protect the landscape as over 1,000 trees are to be planted as part of this proposal.

As set out above there are ample landscape and natural environment protection policies contained within the remainder of the DPD to make sure that inappropriate schemes are rejected.

We would suggest that the policy allows for redevelopment and additions within the approved boundaries of a site and also for addition on previously developed land or, where appropriate, new sites on previously developed land.

Attachment:
Images of the Lazy Duck Hostel in the Cairngorms National Park. (See attached).

Yes, I wish to participate at the oral examination

To ensure that the plan provides for economic activity within the AONB in line with the NPPF.

Please notify me

Site Omission

Y101 Yealand Redmayne

Yes

No

The DPD is not positively prepared

The DPD is not effective

The DPD is not consistent with national policy

Site: Y101 and Y102 – Silverdale Road, Yealand Redmayne
Mr Miles Proudlove and Mr Michael Holgate
Arnside Silverdale AONB Development Plan Document Publication Version Consultation Response

I am writing on behalf of my clients who between them own sites that were referenced as Y101 and Y102 in the draft Development Plan Document Allocation and Background Papers.

It is noted that the sites have not been taken forward for housing particularly because of concerns about landscape.

As far as I am aware only 9 sites are being taken forward through the process out of 130 submitted.

Policy AS01, Development Strategy, in effect breaks down two categories of development to Local Service Centres and development at small villages. However, with regard to Yealand Redmayne there is reference to development being limited to conversion of buildings, reuse of brownfield land or regeneration opportunities. We feel that this does not go far enough given the limited number of sites put forward and the limited number of dwellings proposed. We have rehearsed elsewhere the arguments regarding viability and affordability and feel that the low number of sites put forward, taken together with their size, raises serious concerns about whether the aspirations of the Plan can be delivered.

Despite the approach of policy AS01, Yealand Redmayne is a specific settlement and will continue to function in tandem with Yealand Conyers and we are aware that the public house has now reopened as a community business. For the Yealands to be sustainable and thriving moving forward it is considered that some level of allocation should be provided. Again, arguments have been rehearsed elsewhere relating to the age of the population and the need for a supply of housing for younger people to ensure that communities can continue to function in a viable manner and retain and foster services such as public houses.

In any decision about an allocation or a planning application balance must be struck between the effects on the natural environment and the effects of not allocating or granting housing within a community, and in this instance we feel that the balance has tipped away from the Yealands being able to be considered as vibrant local communities.

I attach the relevant maps for sites Y101 and Y102.

In terms of policy AS01, Development Strategy, the reference to development on the edge and outside of settlements is welcomed because it is considered that the site has the potential to comply with this generic policy. Given the small scale of allocations we would consider that sites Y101 and Y102 should be allocated to provide a small and sustainable development at Yealand Redmayne to assist in continuing to foster the services that both Yealand Redmayne and Yealand Conyers contain.

Yes, I wish to participate at the oral examination

Site Omission

Y102 Yealand Redmayne

Yes

No

The DPD is not positively prepared

The DPD is not effective

The DPD is not consistent with national policy

Site: Y101 and Y102 – Silverdale Road, Yealand Redmayne
Mr Miles Proudlove and Mr Michael Holgate
Arnside Silverdale AONB Development Plan Document Publication Version Consultation Response

I am writing on behalf of my clients who between them own sites that were referenced as Y101 and Y102 in the draft Development Plan Document Allocation and Background Papers.

It is noted that the sites have not been taken forward for housing particularly because of concerns about landscape.

As far as I am aware only 9 sites are being taken forward through the process out of 130 submitted.

Policy AS01, Development Strategy, in effect breaks down two categories of development to Local Service Centres and development at small villages. However, with regard to Yealand Redmayne there is reference to development being limited to conversion of buildings, reuse of brownfield land or regeneration opportunities. We feel that this does not go far enough given the limited number of sites put forward and the limited number of dwellings proposed. We have rehearsed elsewhere the arguments regarding viability and affordability and feel that the low number of sites put forward, taken together with their size, raises serious concerns about whether the aspirations of the Plan can be delivered.

Despite the approach of policy AS01, Yealand Redmayne is a specific settlement and will continue to function in tandem with Yealand Conyers and we are aware that the public house has now reopened as a community business. For the Yealands to be sustainable and thriving moving forward it is considered that some level of allocation should be provided. Again, arguments have been rehearsed elsewhere relating to the age of the population and the need for a supply of housing for younger people to ensure that communities can continue to function in a viable manner and retain and foster services such as public houses.

In any decision about an allocation or a planning application balance must be struck between the effects on the natural environment and the effects of not allocating or granting housing within a community, and in this instance we feel that the balance has tipped away from the Yealands being able to be considered as vibrant local communities.

I attach the relevant maps for sites Y101 and Y102.

In terms of policy AS01, Development Strategy, the reference to development on the edge and outside of settlements is welcomed because it is considered that the site has the potential to comply with this generic policy. Given the small scale of allocations we would consider that sites Y101 and Y102 should be allocated to provide a small and sustainable development at Yealand Redmayne to assist in continuing to foster the services that both Yealand Redmayne and Yealand Conyers contain.

Yes, I wish to participate at the oral examination

AS01 - Development Strategy

Yes

No

The DPD is not positively prepared

The DPD is not effective

The DPD is not consistent with national policy

Policy AS01, Development Strategy, in effect breaks down two categories of development to Local Service Centres and development at small villages. However, with regard to Yealand Redmayne there is reference to development being limited to conversion of buildings, reuse of brownfield land or regeneration opportunities. We feel that this does not go far enough given the limited number of sites put forward and the limited number of dwellings proposed. We have rehearsed elsewhere the arguments regarding viability and affordability and feel that the low number of sites put forward, taken together with their size, raises serious concerns about whether the aspirations of the Plan can be delivered.

Despite the approach of policy AS01, Yealand Redmayne is a specific settlement and will continue to function in tandem with Yealand Conyers and we are aware that the public house has now reopened as a community business. For the Yealands to be sustainable and thriving moving forward it is considered that some level of allocation should be provided. Again, arguments have been rehearsed elsewhere relating to the age of the population and the need for a supply of housing for younger people to ensure that communities can continue to function in a viable manner and retain and foster services such as public houses.

In any decision about an allocation or a planning application balance must be struck between the effects on the natural environment and the effects of not allocating or granting housing within a community, and in this instance we feel that the balance has tipped away from the Yealands being able to be considered as vibrant local communities.

In terms of policy AS01, Development Strategy, the reference to development on the edge and outside of settlements is welcomed because it is considered that the site has the potential to comply with this generic policy. Given the small scale of allocations we would consider that sites Y101 and Y102 should be allocated to provide a small and sustainable development at Yealand Redmayne to assist in continuing to foster the services that both Yealand Redmayne and Yealand Conyers contain.

Yes, I wish to participate at the oral examination