Policy EC6: Tourism Activities and Facilities

RVR fully supports the encouragement of Tourism Activities and Facilities.
The RVR Robertsbridge to Bodiam re-connection project will allow tourists to visit Bodiam Castle by train rather than by road.

The K&ESR is a major tourist attraction, economic generator and public transport provider that not only wishes to improve its existing facilities but also extend the existing railway from Bodiam to Robertsbridge. Support Policy EC6 which encourages tourism activities and facilities and, in particular, (i) in providing for the enhancement of existing attractions to meet customer expectations and (vii) where they are capable of access by public transport. Public transport access will be significantly enhanced following the reopening of the railway between Bodiam and Robertsbridge to provide a direct link with main line rail services.

Given the references to the growth in local tourism stated above, we would wish to support the proposals set out in EC6, and in particular would put forward the proposal to support the Rother Valley Railway which would add considerably to the existing tourism attractions in the area.

Greater linkage should be made between the two policies to ensure that the promotion of tourism in EC6 is equally reflected in RA2 for the rural areas. Improved economic activity in the District based on tourism should not be limited to the towns and villages. Whilst Policy RA2 (vii) provides a broad policy direction, it needs to be more positive in seeking to attract better levels and quality of tourism including accommodation and self-catering facilities in rural locations. In addition it should promote the improvement of facilities related to existing tourism facilities or the Core Strategy should include a specific tourism policy reflecting and reinforcing paragraphs 12.28 - 12.30. The policy would be more effective in terms of supporting rural-based tourism and would better reflect the importance that tourism plays in the national, regional and local economies, as reflected in current PPS21 and emerging NPPF policy.

In addition, it is felt that Policy EC6 would be more effective in promoting tourism development if the following was added to the list of opportunities under paragraph 16.32:

" for holiday parks to become hotels in towns, villages and in rural locations"

The extension of the Kent and East Sussex Railway from Bodiam to Robertsbridge can bring a huge advantage to the area.

Please add the consideration to provide opportunities for low carbon and green tourism

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.
EC6
Tourism accommodation and tourism facilities should be subject to two separate policies and cannot be merged into one policy.
For example: the proposed draft policy reads that tourism facilities will be encouraged where they increase the supply of tourist accommodation.
This is poor policy drafting.
EC6 (i)
- Tourist attractions and tourist accommodation should be subject to two different policies.
- The promotion of developments "to meet customer expectations" means this is a developer led policy with no measure or means of constraint.
The existing policy, and policy promoted nationally and adopted by other planning authorities, is that development will be restricted to development essential to the operations of a rural business and where a countryside location is necessary. Outside settlement development boundaries, development will be strictly controlled.
EC6 (v)
How could a proposal to develop new tourist accommodation fail to meet this "criterion"?
All new development proposals will necessarily increase the supply of serviced or self-catering accommodation.
"Quality" is a subjective term and has no quantifiable measure. It is extremely unlikely developers could fail this criterion in proposing new tourist accommodation.
EC6 (vi)
Occupancy conditions limiting annual stays to a maximum of 56 days are the only proven means of ensuring the accommodation is available to genuine tourists and to guard against the use of tourist accommodation as second homes.
This policy suggests year-round use of holiday accommodation will be permitted but fails to specify the means of occupancy control.
The criterion also fails to ensure the removal of touring caravans from the land in the winter months.
EC6 (vii)
Access by public footpaths and cycleways is not relevant to the sustainability of most tourism developments.
National policy promotes sustainable tourism developments located within accessible centres, close to services.
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.
The Sustainability Appraisal concludes with a question mark upon the environmental consequences of EC6 grading the potential adverse consequences of Policy EC6 as unknown.
Unknown consequences are unacceptable in an AONB where the authority's statutory duty is to ensure the conservation and enhancement of natural beauty.
However, the SA is also inadequate.
Proper assessment of EC6 would lead to a conclusion that the policy has the real potential to cause serious adverse environmental impact.
Against SA Objective 15, the SA comments are: "Pressure from visitor numbers balanced by fact that cultural and heritage assets, including townscape and landscape character, are key attractions, thus incentivising their preservation".
This assessment does not look to the Policy itself: it is simply a general assessment of the impact of tourists. It is not visitor numbers but the EC6 permissive approach to new development across the High Weald AONB outside SDBs that threatens serious adverse environmental impact.
It is only development plan policy that has the power to preserve the natural beauty of the district: what other means of preservation could the SA be contemplating?
In conclusion the SA has failed proper assessment of EC6.
The consequence of inadequate appraisal of EC6 is the Council is proposing a policy for submission to the Secretary of State that is unsound and unlawful.
Given the statutory duty to conserve and enhance, RDC has a legal obligation that must to be met in respect of 83% of the district's landscape.
The specific requirement of the SEA Regulations is to monitor the significant environmental effects of policy with the purpose of identifying unforeseen adverse effects at an early stage.
The serious adverse potential of Policy EC6 can be recognised now.

Policy EC6: Tourism Activities and Facilities
Proposals relating to tourism activities and facilities
This policy requires the key addition of how tourism activities and facilities will be managed in terms of pressure on the environment and particularly the Dungeness/Rye Bay / Romney Marsh suite of internationally designated sites. As mentioned, in the supporting text for this policy, the Rye Harbour section (10), the chapter on the environment (17) all require refer as to how tourism pressure will be managed to ensure no adverse impacts on the sites this needs to be translated into policy not just supportive text.

Ticehurst Parish Council agrees the principles of encouraging tourism but it should be sensitive to the AONB. Improved footpaths and cycle routes should be encouraged. The Council would encourage tourism accommodation but should be protected to prevent such accommodation being altered to permanent housing for resale.