This is a permissive developer led and market oriented policy.
It is a radical departure from existing Adopted Local Plan policy and from the published 2008 Strategy Directions.
Nothing in the national policy context explains why this Council is proposing to dispense with the standard development control constraints, essential to the protection of a designated landscape of national importance.
The current relaxation of the planning regime nationally through the NPPF does not affect Areas of Outstanding Natural Beauty: the government has confirmed these areas continue to benefit from the highest levels of policy protection.
None of the "criteria" of EC6 is a policy constraint.
Supporting Text 16.32
This text is seeking to function as policy. Therefore the policy and the text are unsound.
Core Policy EC6 contains no policy criterion save the promotion of market led tourism developments. The deficiency of this policy cannot be remedied by the content of the surrounding text.
Text 16.32 is therefore being used to supplement EC6 (see separate representation on Policy EC6) and this is unsound.
However, the content of 16.32 is also unsound and again signals no constraints:
o "There are particular opportunities for suitable proposals for self-catering and serviced accommodation across the district".
All tourist accommodation is either self-catering or serviced. This statement therefore adds nothing save to promote tourist developments in rural areas and across the district which comprises 83% AONB.
o "Larger self-catering holiday lets and barn conversions"
This statement is meaningless as there is no scale benchmark. Larger than tents or holiday cottages? As large as barns?
Is the statement promoting new development or farm building conversions?
Within settlement development boundaries or outside settlement development boundaries?
The need for this type of development is not evidenced. If promoted outside SDBs the proposal is unsustainable and fails to relate to national policy guidance for the countryside and tourism.
o Replacement of older caravan provision with log cabins/lodges and luxury camping
- This policy fails to distinguish between touring caravans and static caravans.
Policy RA2 promotes touring caravans and yet there is no reference within the Core Policy or paragraph 16.32 to touring caravans.
Is it the intention to promote touring caravans with policy RA2 and promote the replacement of touring caravans with policy EC6? The current state of the plan is capable of this reading.
It is necessary to ensure the tourism policy promotes only the replacement of static caravans with log cabins/lodges of commensurate size to the existing caravans.
To promote the replacement of touring caravan pitches with permanent built development would cause serious harm to the character and appearance of the High Weald AONB. It is assumed it is not the Council's intention to promote the redevelopment of touring caravan pitches.
- Luxury camping or "glamping" is a recent marketing term. There is also reference at 12.56 to the "current trend for yurts".
The use of marketing terms within a development plan is inappropriate.
The lawful interpretation of policy within a development plan is the meaning the policy could reasonably be considered to bear not the meaning it is intended to bear.
Luxury camping is a term with no definable meaning. The Council may intend the term to mean "posh tents" but the term could mean caravan sites with a restaurant and leisure facilities.
o Development in support of activity breaks
The type of activity and the type of development is open and unspecified.
This submission should be read in conjunction with our objection to the Sustainability Appraisal of Policy EC6 and our objection to Policy RA2.