Rother Local Plan 2020-2040 (Regulation 18)
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Rother Local Plan 2020-2040 (Regulation 18)
Proposed Policy GTC1: Net Zero Building Standards
Representation ID: 25886
Received: 22/07/2024
Respondent: Park Holidays UK
Agent: Rural Solutions
Add the word 'built' after (A) All new...
This is an all-encompassing policy requirement apparently relevant to all new development.
Such a proposal can only apply to those forms of development where building performance standards, BREEAM, Home Quality Marks etc apply. A change of use application for example would be encompassed as 'development' but could not satisfy the policy requirement.
Add the word 'built' after (A) All new...
This is an all-encompassing policy requirement apparently relevant to all new development.
Such a proposal can only apply to those forms of development where building performance standards, BREEAM, Home Quality Marks etc apply. A change of use application for example would be encompassed as 'development' but could not satisfy the policy requirement.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
3.48
Representation ID: 25891
Received: 22/07/2024
Respondent: Park Holidays UK
Agent: Rural Solutions
It appears that the arbitary increase in BNG from 10% to 20% has yet to be justified (as indicated by paragraph 3.49). The outcomes of any evidence gathering should inform the final figure. The assumption that "The viability of development is unlikely to be unduly impacted in most cases" appears to be unsupported by any evidence. No provision has been made within this strategic policy for the consideration of those circumstances where viability could very well be affected.
It appears that the arbitary increase in BNG from 10% to 20% has yet to be justified (as indicated by paragraph 3.49). The outcomes of any evidence gathering should inform the final figure. The assumption that "The viability of development is unlikely to be unduly impacted in most cases" appears to be unsupported by any evidence. No provision has been made within this strategic policy for the consideration of those circumstances where viability could very well be affected.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Proposed Policy ECO6: Holiday Sites
Representation ID: 25903
Received: 22/07/2024
Respondent: Park Holidays UK
Agent: Rural Solutions
With particular regard to holiday caravan sites the policy mis-directs itself. A caravan is closely defined in the 1960 and 1968 Acts. The term chalet was used for some time to describe a twin-unit caravan and this term has generally been surplanted by the word lodge. They remain caravans in law if they fulfill the relevant definitions. Otherwise you are seeking to support buildings in replacement of caravans.
With regard to v - how is quality to be assessed. Explain what is considered to be low quality. High quality for some could be insufficiently high for others. It is an undefinable requirement.
There is no guidance on how one might define 'significant improvement' in vii a and b. It is entirely subjective. 'An improvement' might be more realistic and achievable. Similarly, how is one to judge an improvement to the appearance and quality of accommodation - against what criteria?
With particular regard to holiday caravan sites the policy mis-directs itself. A caravan is closely defined in the 1960 and 1968 Acts. The term chalet was used for some time to describe a twin-unit caravan and this term has generally been surplanted by the word lodge. They remain caravans in law if they fulfill the relevant definitions. Otherwise you are seeking to support buildings in replacement of caravans.
With regard to v - how is quality to be assessed. Explain what is considered to be low quality. High quality for some could be insufficiently high for others. It is an undefinable requirement.
There is no guidance on how one might define 'significant improvement' in vii a and b. It is entirely subjective. 'An improvement' might be more realistic and achievable. Similarly, how is one to judge an improvement to the appearance and quality of accommodation - against what criteria?
Comment
Rother Local Plan 2020-2040 (Regulation 18)
9.56
Representation ID: 25906
Received: 22/07/2024
Respondent: Park Holidays UK
Agent: Rural Solutions
9.56 misunderstands and misrepresents the caravan market. Apart from the Pontins / Butlins type holiday parks where built chalets are the predominant accommodation, the vast majority of holiday parks are caravan parks with caravans that fall within the 1960 and 1968 Act definition. The terms Chalet and Lodge have been used for marketing purposes, but for the most part they remain caravans in law.
The holiday parks sector is hugely valuable to local economies in delivering both direct and indirect revenue and jobs.
Whilst the so-called lodge style caravans are popular at the upper end of the market, they are not the predominant type of unit. The following re-wording is suggested:-
9.56 The upgrading of existing holiday park accommodation and facilities will be supported so long as the impact on the wider landscape is not materially affected. This may involve a sensitive, limited expansion where positive benefits can be achieved.
9.56 misunderstands and misrepresents the caravan market. Apart from the Pontins / Butlins type holiday parks where built chalets are the predominant accommodation, the vast majority of holiday parks are caravan parks with caravans that fall within the 1960 and 1968 Act definition. The terms Chalet and Lodge have been used for marketing purposes, but for the most part they remain caravans in law.
The holiday parks sector is hugely valuable to local economies in delivering both direct and indirect revenue and jobs.
Whilst the so-called lodge style caravans are popular at the upper end of the market, they are not the predominant type of unit. The following re-wording is suggested:-
9.56 The upgrading of existing holiday park accommodation and facilities will be supported so long as the impact on the wider landscape is not materially affected. This may involve a sensitive, limited expansion where positive benefits can be achieved.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
9.66
Representation ID: 25908
Received: 22/07/2024
Respondent: Park Holidays UK
Agent: Rural Solutions
The text in brackets should be removed. it is an unnecessary limitation. There may be small sites (touring caravans, tent camping, yurts etc) where use outside of the old March to October season is perfectly practicable nowadays. For example, the growth in Pod Camping of more recent years is a specific response to the availability of suitable accommodation which is useable over a much longer season. If the aim is to ensure the requirements of 9.65 are met then no seasonal limitation is required. The same sort of conditions can be applied.
The text in brackets should be removed. it is an unnecessary limitation. There may be small sites (touring caravans, tent camping, yurts etc) where use outside of the old March to October season is perfectly practicable nowadays. For example, the growth in Pod Camping of more recent years is a specific response to the availability of suitable accommodation which is useable over a much longer season. If the aim is to ensure the requirements of 9.65 are met then no seasonal limitation is required. The same sort of conditions can be applied.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
169. Are there any alternatives or additional points the Council should be considering?
Representation ID: 25909
Received: 22/07/2024
Respondent: Park Holidays UK
Agent: Rural Solutions
You may wish to reflect on the recent 'Pitching the Value' report ( synopsis submitted) which provides an indication of the worth of holiday parks to the national and local economy.
You may wish to reflect on the recent 'Pitching the Value' report ( synopsis submitted) which provides an indication of the worth of holiday parks to the national and local economy.
