Comment

Development and Site Allocations (DaSA) Local Plan - Options and Preferred Options

Representation ID: 22750

Received: 20/02/2017

Respondent: Miss Elizabeth Parker

Representation Summary:

Rename policy "Holiday Accommodation" not "Holiday Sites" as this does not correctly describe the policy application.

A number of detailed suggested amendments are made to policy wording criteria (a), (b), (c) and (d).

Full text:

POLICY DEC2: HOLIDAY SITES
Policy heading/description
Rename policy "Holiday Accommodation" not "Holiday Sites" as this does not
correctly describe the policy application.

Amend (a) (i) to:
Must safeguard the intrinsic and locally distinctive character of the countryside, with particular regard to the conservation of the High Weald AONB, and have an acceptable environmental impact, especially when viewed from public vantage points.
Reason: to align with other policies permitting development in the countryside, for
example the equestrian policy, and properly to reflect the stated policy objective
in the preceding text of promoting sensitive and small-scale tourism accommodation in the countryside whilst protecting and conserving the landscape.

Amend (a) (vi) to add "particularly":
Must not harm the rural character of the area, particularly where there is any increase in the site area or a new structure; and
Reason: no development in the countryside should be permitted to harm rural character.

Add new criteria to (a):
Must seek to re-use existing buildings before proposing new buildings or structures
Reason: re-use of buildings, for example farm buildings, is the established starting
point for accommodating new tourism accommodation in the countryside and there is no reference to this preferred approach in the policy.

Amend (b) (ii) to:
A proposal that comprises a limited amount of low key accommodation to enhance another existing countryside recreational use without accommodation and is wholly ancillary to that use.
Reason: to guard against misinterpretation and repeat applications producing
cumulative aggregate development over the plan period and to have some parity with (b) (i) in terms of the expected low-key nature of the accommodation.

Amend (c) (ii) to add "sensitive":
A proposal for the limited and sensitive extension of that site to a natural boundary and makes a significant improvement in the appearance and quality of accommodation.
Reason: to accord with paragraph 9. 17.

Add footnote to (c):
An "existing site" means the static caravan, chalet or lodge accommodation.
Reason: to ensure the interpretation of an existing site is definite and accords with
the policy intention and is incapable of misinterpretation. To ensure the term "existing site" is not taken to refer to the property/landholding/farm and is
understood specifically to refer to the existing static caravan, chalet or lodge
accommodation.

Amend (d) to:
In relation to a touring caravan or tented camping proposal, it is of a small scale appropriate to the area, is visually contained within the rural landscape and the siting of touring caravans and tents on the land is limited to April to October annually. Any ancillary facilities necessary to serve the site will only be permitted on a similar seasonal basis or, if they are of a permanent nature, are compatible with the local character of the area. Where the temporary use of land is permitted, any ancillary facilities necessary to serve the site will only be permitted on a similar
temporary basis.

Reason: the policy criteria does not match or reflect paragraph 9. 23 which sets out
what the policy intends to achieve. The wording is also unclear. The policy as
worded would appear potentially to permit year-round siting of touring caravans
on land, meaning open winter storage in the open countryside which would be
visually intrusive, harmful and unnecessary.

Note: This is a response to the printed question related to this policy DEC2,
Question 16 (a). There is no question 16 (b)... on DEC2. The following printed
question is Question 17 on the next policy DEC3.