Carlton Meres Country Park, Carlton, SAXMUNDHAM, IP17 2QP

Carlton Meres Country Park, Carlton, SAXMUNDHAM, IP17 2QP — East Suffolk — Appeal Decision Hearing Held on 21 July 2021 Site Visit made on 21 July 2021 by Graham Chamberlain BA(Hons) MSc MRTPI an Inspector appointed by the Secretary of State Decision date: 6th August 2021 Appeal Ref: APP/X3540/W/20/3259654 Carlton Meres Country Park, Carlton Lane, Suffolk IP17 2QP • The appeal is made under section 78 of the Town and Country Planning Act 1990 against a refusal to grant planning permission. • The appeal is made by Park Holidays UK Ltd against the decision of East Suffolk Council. • The application Ref DC/19/3196/FUL, dated 13 August 2019, was refused by notice dated 1 April 2020. • The development proposed is described as ‘Use of land for the stationing of 50 No. static holiday caravans; children's play area; recreation space and associated facilities'. Decision 1. The appeal is allowed, and planning permission is granted for the use of land for the stationing of 50 No. static holiday caravans; children's play area; recreation space and associated facilities at Carlton Meres Country Park, Carlton Lane, Suffolk IP17 2QP, in accordance with the terms of the application, Ref: DC/19/3196/FUL, dated 13 August 2019, subject to the conditions set out in the attached schedule. Procedural Matters 2.

Carlton Meres Country Park, Carlton, SAXMUNDHAM, IP17 2QP — East Suffolk — Appeal Decision The Council issued a screening opinion stating that the proposal constituted EIA development. As a result, the application was accompanied by an Environmental Statement (ES). This has been supplemented following a request under Regulation 25 of The Town and Country Planning (Environmental Impact Assessment) Regulations 2017. I have had due regard to the ES and other relevant environmental information in determining this appeal. 3. After the hearing, and at my request, the Council and appellant submitted a revised list of suggested planning conditions. Similarly, the Council and appellant provided comments on the recent revisions to The National Planning Policy Framework (Framework). Since the Council issued its decision it has adopted the Suffolk Coastal Local Plan 2020 (LP). This has superseded the policies of the Local Plan Core Strategy and Development Management Policies. Main Issue 4. Through the Statement of Common Ground submitted before the hearing opened, the Council and appellant confirmed that the submission of a planning obligation had addressed the Council’s concerns regarding highway safety and therefore this is no longer a point in dispute.

Carlton Meres Country Park, Carlton, SAXMUNDHAM, IP17 2QP — East Suffolk — Appeal Decision As a result, the main issue in this appeal is the effect of the proposed development on the character and appearance of the area, with reference to the landscape. https://www.gov.uk/planning-inspectorate

Carlton Meres Country Park, Carlton, SAXMUNDHAM, IP17 2QP — East Suffolk — Appeal Decision As a result, the main issue in this appeal is the effect of the proposed development on the character and appearance of the area, with reference to the landscape. https://www.gov.uk/planning-inspectorate

Carlton Meres Country Park, Carlton, SAXMUNDHAM, IP17 2QP — East Suffolk — Appeal Decision Appeal Decision APP/X3540/W/20/3259654 Reasons Landscape baseline 5. The appeal site is located in the Hevingham and Knodishall Estate Claylands Landscape Character Area (the ‘LCA’) as defined within the Suffolk Coastal Landscape Character Assessment 2018 (SCLCA). This is the largest character area and is a landscape of quiet farmland with a simple, unified, and deeply rural character. There are no large villages in the LCA, and the scattered farms and hamlets are linked by a network of quiet lanes. Parts of the LCA away from the main road corridors (A12 and A1120) can feel remote and isolated. 6. The special qualities of the landscape are identified in the SCLCA as the peaceful, deeply rural ‘backwater’ feel, a focus on agriculture and little intrusion from modern development. The most relevant strategic objectives for the LCA are to protect the unspoilt, quiet, and essentially undeveloped rural character of the area. The SCLCA provides a broad description of the LCA and identifies its defining attributes and special qualities. That said, not all parts of the LCA will be as described and the extent to which the attributes and special qualities are evident will vary. 7.

Carlton Meres Country Park, Carlton, SAXMUNDHAM, IP17 2QP — East Suffolk — Appeal Decision Carlton Meres is a large holiday park and therefore can be regarded as an atypical ‘settlement’ in a LCA where there are no large villages. The activity at the park results in some background noise and there was a steady stream of vehicle movements when I visited. Carlton Lane is kerbed with speed bumps, bollard lighting, a proliferation of signage and relatively manicured hedges. It has the appearance of an access drive rather than a country lane. The holiday park is also close to the A12, which provides a background hum. The landscape around the B1119/Rendham Road junction is dominated by a large, white roofed and stark industrial type agricultural complex. There is also sporadic development along Rendham Road. As a result, there is not a strong sense of remoteness on the approach to Carlton Meres and in this respect the local landscape to the south east of the appeal site does not have the deeply rural attribute to the same extent as other parts of the LCA. 8. That said, the holiday park sits in an attractive, rural, and farmed landscape. It is surrounded by small fields, hedges, and woodland. The area is still peaceful despite the A12 and the holiday park.

Carlton Meres Country Park, Carlton, SAXMUNDHAM, IP17 2QP — East Suffolk — Appeal Decision Given its size, the latter is remarkably well contained due to the extent of soft landscaping and the landform. Moreover, the landscape to the north and west of Carlton Meres is very undeveloped and quiet and therefore exhibits the deeply rural attributes of the LCA. Thus, the landscape west of the A12 in the vicinity of the appeal site evolves quickly from the more built-up character of the A12 corridor and edge of Saxmundham to being deeply rural and tranquil. 9. The appeal site encompasses two fields divided by Carlton Lane. They are both given over to meadow grassland with a mown path around the perimeter. The northern field is experienced as part of the holiday park due to the presence of the club house. The southern field is physically subdivided from the park by a strong hedgerow boundary. This hedge screens the holiday park in views from Rendham Road and therefore the field has more visual affinity with the surrounding farmland, including the deeply rural area to the west, than the more developed character of the holiday park.

Carlton Meres Country Park, Carlton, SAXMUNDHAM, IP17 2QP — East Suffolk — Appeal Decision As a result, it is possible to experience the southern field as a continuation of the rural landscape, although the presence of the holiday park is evident due to noise, signage, and activity. https://www.gov.uk/planning-inspectorate 2

Carlton Meres Country Park, Carlton, SAXMUNDHAM, IP17 2QP — East Suffolk — Appeal Decision As a result, it is possible to experience the southern field as a continuation of the rural landscape, although the presence of the holiday park is evident due to noise, signage, and activity. https://www.gov.uk/planning-inspectorate 2

Carlton Meres Country Park, Carlton, SAXMUNDHAM, IP17 2QP — East Suffolk — Appeal Decision Appeal Decision APP/X3540/W/20/3259654 10. Thus, I share the view of the Council and appellant that the appeal site and surrounding landscape has a medium sensitivity to change, in that it exhibits some distinctive characteristics in its attractive rurality and position within a quiet farmed landscape. However, the sense of being deeply rural is slightly degraded by the presence of the A12 and the holiday park. The effect on landscape character 11. The addition of twelve static holiday caravans and associated infrastructure in the northern field would result in the meadow being urbanised. However, the club house and holiday park are very visible and audible from the adjoining public right of way. I therefore share the view of the Council and appellant that the proposed development of the northern field would only have a minor impact on the rural tranquillity of the LCA and thus its landscape character. 12. The development of the southern field would see thirty-eight static holiday caravans sited along with the associated infrastructure, including roads and lighting.

Carlton Meres Country Park, Carlton, SAXMUNDHAM, IP17 2QP — East Suffolk — Appeal Decision The caravans would be sandwiched between the semi-formal access along Carlton Lane and an existing group of caravans to the east, which they would expand slightly further south than. As a result, the development would be a form of rounding off. However, the caravans would have an adverse urbanising impact given the fields visible and spatial affinity with the surrounding rural landscape as opposed to the holiday park. The northern section of the southern field would therefore experience a high magnitude of change because its open rural character would be severely damaged by modern development and this would jar with the strategic priority for the LCA. 13. It was clarified at the hearing that the southern section of the southern field would not become a formal amenity area. This is significant because development of the southern section of the field would be highly injurious to landscape character by expanding the holiday park too far. Instead, the southern half of the field would be retained as rough informal meadow land, albeit with scope for additional planting to create a more interesting and diverse mosaic of natural habitats.

Carlton Meres Country Park, Carlton, SAXMUNDHAM, IP17 2QP — East Suffolk — Appeal Decision The formal footpath link would only be a minor urbanising detractor due to it meandering amongst trees. Overall, there would be a low magnitude of change to the southern part of the southern field. 14. When the proposed changes to the southern field are considered as a whole, there would be a medium magnitude of adverse change as it would experience a partial loss of a key attribute/characteristic of the landscape through the physical urbanisation of its northern section. However, the southern section would retain a rural character that would be enhanced by planting. 15. The proposed expansion of the park would increase vehicle movements and general activity, including noise from occupants. There would also be a package of road improvements. This would all result in creeping urbanisation and an erosion of tranquillity. However, and as already explained, the approach to the caravan park from the A12, although pleasant, is not deeply rural in character. Moreover, the activity associated with the proposal would be hard to differentiate from the existing. Thus, the off-site impacts would result in a low magnitude of change. 16.

Carlton Meres Country Park, Carlton, SAXMUNDHAM, IP17 2QP — East Suffolk — Appeal Decision Overall, the proposal would not result in a high magnitude of change to landscape character because the southern part of the southern field would be retained as natural meadowland and the additional activity would be broadly https://www.gov.uk/planning-inspectorate 3

Carlton Meres Country Park, Carlton, SAXMUNDHAM, IP17 2QP — East Suffolk — Appeal Decision Overall, the proposal would not result in a high magnitude of change to landscape character because the southern part of the southern field would be retained as natural meadowland and the additional activity would be broadly https://www.gov.uk/planning-inspectorate 3

Carlton Meres Country Park, Carlton, SAXMUNDHAM, IP17 2QP — East Suffolk — Appeal Decision Appeal Decision APP/X3540/W/20/3259654 assimilated with that which already exists. As a result, the proposal would have a medium adverse magnitude of change on a landscape of medium sensitivity. The impact would therefore be of moderate significance when applying the criteria in the Landscape and Visual Impact Assessment (LVIA) submitted by the appellant. The Council did not object to this methodology and criteria being used as a means of framing my assessment when I asked at the hearing. The visual effect of the proposal 17. The LVIA contains a visual assessment focussed on representative static viewpoints. These viewpoints are selected to give an indication of how visible the development would be. The Council confirmed at the hearing that it is generally content with the location of the viewpoints as a means of assessing the visual impact, albeit with the qualification that the visual impact is dynamic as one moves between the viewpoints. I am also aware that I visited the site when the existing soft landscaping is at its most effective. It is therefore helpful that the LVIA includes photographs taken in the winter. 18.

Carlton Meres Country Park, Carlton, SAXMUNDHAM, IP17 2QP — East Suffolk — Appeal Decision The appellant and Council agreed at the hearing that the proposal would have a neutral impact significance on VPs 1, 2, 6, 7A and 11 due to existing landscaping and the landform. This would be the case all year round. The proposal would be clearly visible from VP5, but this is a location within the caravan park and is therefore dominated by foreground views of caravans and infrastructure. The impact from VP7 would move from slight adverse in Year 1 to neutral in year 15 as mitigating planting matures. There would be a low magnitude of change from VP9 due to the existing dense landscaping. The highway works would be viewed as a minor urbanising change from this vantage point, albeit experienced in the unescapable presence of large and stark agricultural buildings to the immediate south. The overall impact from VP9 would be neutral. The long-term neutral impact from these viewpoints indicate that the visual envelope of the development would be very localised. 19. As a result, the greatest magnitude of change would be from near distance views along Carlton Lane and Rendham Road. The former is a public right of way and the latter a rural lane that is used by non-motorists as well as motorists.

Carlton Meres Country Park, Carlton, SAXMUNDHAM, IP17 2QP — East Suffolk — Appeal Decision As a result, they are both of high sensitivity to change 20. The impact from VP4 would be negative because caravans would be sited close to the public right of way, which becomes a rural unmade path at this point. The proposal would also be viewed from this vantage point as an extensive urbanisation of the meadow. However, and as already alluded to, the development proposed in the northern field would be seen in the context of the extensive clubhouse complex, and footpath users would have already pass, or would be about to pass, a large body of caravans to the north of the appeal site. This would result in some cumulative impacts, but the context of the northern field is already built-up and caravans are not untypical. Overall, there would be a medium magnitude of visual change from VP4. 21. The development of the northern section of the southern field would appear stark when moving between VPs 10 and 3 because the proposal would be seen as a breakout beyond a natural boundary and a discordant urbanisation of the meadow. That said VP3 is located in a semi-formal drive where there is already a sense of being within the holiday park complex.

Carlton Meres Country Park, Carlton, SAXMUNDHAM, IP17 2QP — East Suffolk — Appeal Decision Furthermore, the dense hedge along Carlton Lane would soften the visual impact and the presence of the ‘open greenspace’ area would ensure that the visual impact only begins to https://www.gov.uk/planning-inspectorate 4

Carlton Meres Country Park, Carlton, SAXMUNDHAM, IP17 2QP — East Suffolk — Appeal Decision Furthermore, the dense hedge along Carlton Lane would soften the visual impact and the presence of the ‘open greenspace’ area would ensure that the visual impact only begins to https://www.gov.uk/planning-inspectorate 4

Carlton Meres Country Park, Carlton, SAXMUNDHAM, IP17 2QP — East Suffolk — Appeal Decision Appeal Decision APP/X3540/W/20/3259654 materialise halfway between VP3 and VP10. Accordingly, there would be a medium magnitude of visual change from the area between VPs 10 and 3. 22. Thus, the proposal overall would result in a medium magnitude of visual change to Carlton Lane, which is of high sensitivity. The impact significance would therefore be substantial/moderate adverse in Year 1. It is unlikely that these impacts would reduce by Year 15 as the proximity of the caravans to the boundary and the route of the proposed footpath link would limit opportunities for further planting. 23. VPs 10 and 8 represent the impacts from Rendham Road to the south of the appeal site. These views are from a rural lane away from the Holiday Park and therefore more sensitive to change than VPs 3 and 4. Highway works, signage and the new path would be visible from VP10 but there is already stark signage at this location. Additional landscaping, including a copse, would screen views of the caravans from this vantage point. Of more concern is views when moving between VPs 10 and 8. This is because the mobile homes would be quite apparent at Year 1, even in the summer, because the existing hedgerow is gappy.

Carlton Meres Country Park, Carlton, SAXMUNDHAM, IP17 2QP — East Suffolk — Appeal Decision The views would be from a distance and filtered by the existing hedge, but unlike at VPs 3 and 4, the caravans would not be seen in the backdrop of existing development or from the drive into the holiday park. 24. As a result, in the short term the proposal would result in a high magnitude of visual change to a viewpoint with high sensitivity. The impact would be substantial. However, there is opportunity to provide considerable mitigation. The hedge along Rendham Road can be supplemented and additional planting could take place along the southern boundary of the appeal site. However, due to a dip in the land levels this may not be effective for some time. 25. Nevertheless, as confirmed at the hearing there is scope for substantial planting in the ‘open greenspace’1 area in addition to that shown on the drawings. There is opportunity for copse planting in addition to the hedgerow and tree planting immediately to the south of the caravans (as shown on the drawings). This would provide layering and depth to the planting. Over time this is likely to screen the development given the low profile of the caravans. The use of dark external colours to the caravans would also provide additional necessary mitigation.

Carlton Meres Country Park, Carlton, SAXMUNDHAM, IP17 2QP — East Suffolk — Appeal Decision Thus, by Year 15 with the mitigation established the magnitude of change from the vicinity of VP8 would be low, resulting in an overall residual impact that would be slight to neutral. 26. To summarise, the proposal with mitigation would generally have a neutral visual impact. The main impact would be from a short section of the Carlton Lane public right of way where a substantial/moderate visual impact would endure. However, Carlton Lane has been subtly urbanised already. It is also important to note that this is a large scheme and therefore the close-range visual impact would be difficult to eliminate. Overall, the proposal would have a slight/moderate visual impact by Year 15. Overall conclusion on landscape impacts 27. Policy SCLP10.4 of the LP states that developments should not have a significant adverse impact on rural river valleys and the Suffolk Coast and Heaths Area of Outstanding Natural Beauty (AONB). It is not clear where the 1 As annotated on the Illustrative Site Layout https://www.gov.uk/planning-inspectorate 5

Carlton Meres Country Park, Carlton, SAXMUNDHAM, IP17 2QP — East Suffolk — Appeal Decision Appeal Decision APP/X3540/W/20/3259654 threshold for a policy conflict rests in respect of other landscapes within the plan area. It seems logical to apply a similar terminology to such areas, albeit mindful that they may be of a lower quality than nationally designated or valued landscapes and perhaps less sensitive to change. I share the view of the | Council that the magnitude of the impact need not be at a significant or high | | --- | | level to amount to a policy conflict. |

Carlton Meres Country Park, Carlton, SAXMUNDHAM, IP17 2QP — East Suffolk — Appeal Decision | Council that the magnitude of the impact need not be at a significant or high | | --- | | level to amount to a policy conflict. | need only be a harmful impact that is sufficiently great or important to be worthy of attention in the public interest. 28. The appellants submitted at the hearing that the scheme’s impact should be judged against the LCA as a whole. In so doing the impact would not be of significance for the purposes of Policy SCLP10.4 because it would not be sufficiently great in the context of the entire LCA. I entirely disagree because to take such an approach would render an assessment of landscape impacts almost meaningless, as very few proposals would be capable of harming the LCA as a whole. Thus, I favour the Council’s approach of considering the impact on a local ‘study area’. This is effectively what the LVIA has done. 29. In the context of this study area the proposal would have a moderate adverse impact on landscape character and an overall visual impact that would be slight/moderate at Year 15 with mitigation. Thus, it would not protect or enhance the special qualities of the area. Therefore, the impact would be

Carlton Meres Country Park, Carlton, SAXMUNDHAM, IP17 2QP — East Suffolk — Appeal Decision | sufficiently great to be worthy of attention. It would be a ‘significant adverse | | --- | | impact’ in the context of Policy |

Carlton Meres Country Park, Carlton, SAXMUNDHAM, IP17 2QP — East Suffolk — Appeal Decision | sufficiently great to be worthy of attention. It would be a ‘significant adverse | | --- | | impact’ in the context of Policy | | The proposal would also be contrary to criteria c) of Policy SCLP6.4 of the LP, | | --- | | which states that tourism development outside of the AONB will be supported | | where the proposal avoids, prevents, or mitigates adverse impacts on | | landscape character. As the proposal would have a residual adverse impact it | | will not achieve this. By harming an attractive rural landscape the proposal | | would be at odds with Policy SCLP6.1, which seeks to manage tourism across | | the plan area in a way that protects the features that make the area attractive. | | The proposal would also be at odds with criteria c) of Policy SCLP6.5 of the LP. |

Carlton Meres Country Park, Carlton, SAXMUNDHAM, IP17 2QP — East Suffolk — Appeal Decision | The proposal would also be contrary to criteria c) of Policy SCLP6.4 of the LP, | | --- | | which states that tourism development outside of the AONB will be supported | | where the proposal avoids, prevents, or mitigates adverse impacts on | | landscape character. As the proposal would have a residual adverse impact it | | will not achieve this. By harming an attractive rural landscape the proposal | | would be at odds with Policy SCLP6.1, which seeks to manage tourism across | | the plan area in a way that protects the features that make the area attractive. | | The proposal would also be at odds with criteria c) of Policy SCLP6.5 of the LP. |

Carlton Meres Country Park, Carlton, SAXMUNDHAM, IP17 2QP — East Suffolk — Appeal Decision Other Considerations 31. The LP sets out a positive strategy for tourism in Policy SCLP6.1 as it delivers notable benefits to the economy. It is estimated that tourism provides about 12% of the areas employment and is worth many millions of pounds. The appellants market overview report explains that the development could add £1.48m to the local economy with an additional multiplier effect. It also explains that market research indicates that 68% of Carlton Meres’ customers said they purchased meals from restaurants or cafes in the local area and 61% visited a pub or bar other than those provided on the park. The same study highlighted that holiday park customers also supported local attractions and nearly 80% said they visited local towns and villages around the holiday park location. The economic benefits would therefore be of a high order. 32. The Council do not dispute that there is a demand for more static holiday caravans in the area and the scheme would help address this. In this instance the adverse impacts of doing so would be of significance but would not be of a high order, being local and contained.

Carlton Meres Country Park, Carlton, SAXMUNDHAM, IP17 2QP — East Suffolk — Appeal Decision There is a strong logic in extending an existing holiday park in this way because it already has facilities and infrastructure and some of the impacts of the new caravans and their https://www.gov.uk/planning-inspectorate 6

Carlton Meres Country Park, Carlton, SAXMUNDHAM, IP17 2QP — East Suffolk — Appeal Decision There is a strong logic in extending an existing holiday park in this way because it already has facilities and infrastructure and some of the impacts of the new caravans and their https://www.gov.uk/planning-inspectorate 6

Carlton Meres Country Park, Carlton, SAXMUNDHAM, IP17 2QP — East Suffolk — Appeal Decision Appeal Decision APP/X3540/W/20/3259654 occupants, such as the activity, can be better assimilated and would not be as noticeable as new development elsewhere. 33. From the information before me, I share the view of the appellant that the quality of the local landscape, and its rural attributes, could make it difficult to find an acceptable location for a new holiday caravan park elsewhere in the LCA which could cater for the number of units proposed. 34. The appeal scheme would not be located sufficiently close to Saxmundham, Carlton and Kelsale to make regular walking to these settlements a likely prospect. That said, journeys by car would be short, direct and along established routes. The proposal can therefore be considered well related to a cluster of existing settlement, including a small town. Furthermore, holiday makers may be more likely to walk and cycle to such facilities given that they have more leisure time, and a country walk can be a pleasant experience. However, I acknowledge that the A12 is a barrier. That said, the Council did not refuse the scheme over concerns about its relationship to existing settlements or ability to enhance the sustainability of the area, both criteria of Policy SCLP6.4. 35.

Carlton Meres Country Park, Carlton, SAXMUNDHAM, IP17 2QP — East Suffolk — Appeal Decision The proximity to the A12, and thus the national road network, means that vehicle journeys on quiet country lanes can be minimised. It also makes access to ‘honey pot’ attractions along the coast easier. Thus, the appeal scheme is strategically well placed given that occupants would likely be using a car. For a rural tourism scheme the proposed development would be reasonably ‘sustainable’ in this regard when considering Paragraph 85 of the National Planning Policy Framework. 36. The ES includes detailed biodiversity surveys, which have been recently reviewed for the purposes of the Regulation 25 request. Subject to mitigation and enhancement, including an offsite great crested newt reserve on land in the appellants ownership, the proposal would result in a net gain to biodiversity. The highway works, especially the arrangements to discourage a left-hand turn onto Rendham Road, would benefit existing users of the public highway by pushing movements towards the B1119. The above points collectively weigh strongly in favour of the proposal. Other Matters, Conditions and Planning Obligation 37.

Carlton Meres Country Park, Carlton, SAXMUNDHAM, IP17 2QP — East Suffolk — Appeal Decision Interested parties have raised concerns regarding past landscaping and tree works at the site, however this is a matter outside the scope of this appeal. There is nothing of substance before me to demonstrate the proposal is likely to have a significant effect on European sites. In fact, Natural England, who are the Statutory Nature Conservation Body, raised no objections. 38. The ES has examined the impacts on surface water drainage. This has been reviewed by the Lead Local Flood Authority, who have not objected subject to the imposition of conditions. Substantive evidence is not before me to justify a departure from this expert opinion. As a result, the conditions recommended are necessary in the interests of preventing surface water flooding. 39. The ES also includes a Transport Assessment that considered the highway impacts of the proposal and identifies mitigation, including a right hand only turn from Carlton Lane amongst other measures. This has been reviewed by the Local Highway Authority, who have not objected. Again, substantive https://www.gov.uk/planning-inspectorate 7

Carlton Meres Country Park, Carlton, SAXMUNDHAM, IP17 2QP — East Suffolk — Appeal Decision Appeal Decision APP/X3540/W/20/3259654 evidence is not before me to justify a departure from this expert view. The LHA have not objected subject to the imposition of a suite of planning conditions, all of which I consider to be necessary in the interests of highway safety. 40. In addition, a planning obligation in the form of a unilateral undertaking is also before me and this secures a financial contribution to be paid to the Local Highway Authority for off-site highway works. It is necessary to make the development acceptable and the contribution would be fairly and reasonably related in scale and kind to the development. There is no reason to doubt that the Local Highway Authority, as a responsible public body, would spend the money in the way it is intended. Accordingly, the contribution is an obligation that can be taken into account. With the obligation and mitigation in place the proposal would not adversely affect the highway safety or have a severe impact on the local road network. 41. In the interests of minimising the impact on the landscape it is necessary to secure the landscape mitigation2, to control the external colours of the caravans and approve a lighting strategy.

Carlton Meres Country Park, Carlton, SAXMUNDHAM, IP17 2QP — East Suffolk — Appeal Decision Similarly, and in the interests of certainty, it is necessary to impose a plans condition3 and to control the number and location of the caravans and to ensure they meet the relevant statutory definition. 42. In the interests of promoting sustainable travel, it is necessary to secure details of cycle parking. To protect the living conditions of existing residents, it is necessary to secure a construction management plan. To protect and enhance biodiversity it is necessary to secure an ecological mitigation and enhancement strategy, a management plan and details of construction management. To protect future occupants, it is necessary to investigate, manage and mitigate any land contamination. 43. To adhere to the development plan and prevent the permanent occupancy of the caravans, it is necessary to limit occupancy. The new local plan, which postdates many of the appeal decision referred to by the appellant, specifies 56 days in any one calendar year. Such a period will make it more likely the caravans are regularly let on a year-round basis to holiday makers and not occupied infrequently as second homes. This would benefit the local economy and safeguard local infrastructure.

Carlton Meres Country Park, Carlton, SAXMUNDHAM, IP17 2QP — East Suffolk — Appeal Decision A condition limiting occupancy to 56 days is therefore necessary. 44. In reaching this view I have carefully considered the appellant’s alternative, but a two-week break could result in the caravans being used as occasional second homes. The Frontline research referred to by the appellant is not before me in full and it’s unclear if it has been independently tested and reviewed. The evidence before me4 does not demonstrate that the caravans at Carlton Meres with permitted occupancy longer than 56 days in any year has resulted in more visitor turnover and/or economic activity in the area. Planning Balance 45. The proposal at its worse would have a moderate adverse impact on landscape character and visual amenity when following the methodology set out in the LVIA. This would be a matter of significance that would result in a ‘significant 2 To include details of plant species, so that discordant coastal or ornamental varieties are not used. 3 I have removed reference to the Transport Statement as the recommendations therein are secured elsewhere. 4 Seasonal and Holiday Occupancy Conditions for caravan and Chalet Parks https://www.gov.uk/planning-inspectorate 8

Carlton Meres Country Park, Carlton, SAXMUNDHAM, IP17 2QP — East Suffolk — Appeal Decision Appeal Decision APP/X3540/W/20/3259654 adverse impact’ and thus a policy conflict. However, the harm to the landscape would not be of high order. The proposal would adhere to some of the criteria of the tourism policies listed above and would not offend others. It would also deliver notable benefits. 46. On balance, it is my judgement that the points in favour of the scheme would outweigh its harm and the subsequent policy conflict. This indicates that the proposal should in this instance be determined otherwise than in accordance with the development plan. Conclusion 47. In conclusion, the proposed development would be contrary to the development plan but there are material considerations which outweigh this finding in this instance. Accordingly, the appeal has succeeded.

Carlton Meres Country Park, Carlton, SAXMUNDHAM, IP17 2QP — East Suffolk — Graham Chamberlain INSPECTOR https://www.gov.uk/planning-inspectorate 9 Appeal Decision APP/X3540/W/20/3259654 APPEARANCES FOR THE APPELLANT Ian Butter Rural and Urban Planning Consultancy Paul Beswick Enzygo James Neville DLP Consultants FOR THE LOCAL PLANNING AUTHORITY Joe Blackmore East Suffolk Council Nick Newton East Suffolk Council DOCUMENTS SUBMITTED ADTER THE HEARING 1. Addendum to the SOCG covering suggested planning conditions https://www.gov.uk/planning-inspectorate 10

Carlton Meres Country Park, Carlton, SAXMUNDHAM, IP17 2QP — East Suffolk — Graham Chamberlain Appeal Decision APP/X3540/W/20/3259654 APPEARANCES FOR THE APPELLANT Ian Butter Rural and Urban Planning Consultancy Paul Beswick Enzygo James Neville DLP Consultants FOR THE LOCAL PLANNING AUTHORITY Joe Blackmore East Suffolk Council Nick Newton East Suffolk Council DOCUMENTS SUBMITTED ADTER THE HEARING 1. Addendum to the SOCG covering suggested planning conditions https://www.gov.uk/planning-inspectorate 10

Carlton Meres Country Park, Carlton, SAXMUNDHAM, IP17 2QP — East Suffolk — Graham Chamberlain Appeal Decision APP/X3540/W/20/3259654 Schedule of Planning Conditions 1. The development hereby permitted shall be begun not later than the expiration of three years from the date of this permission. 2. Subjects to any details or amendments required by other conditions on this permission, the development hereby permitted shall otherwise be carried out in accordance with the following approved plans/drawings: • Red Line Location Plan RUPC.1 • Illustrative Site Layout SHF.201.051.L.D.00.002C • Development Areas Plan SHF.201.051.L.D.00.003 • Block Plan SHF.201.051.L.D.00.008 • Proposed Access Plan SHF.201.051.T.D.003.6 Rev A • Revised Drainage Design SHF.201.051.HY.D.101.P04 • Signage Strategy SHF.201.051.L.D.001.A 3. The development shall be implemented in accordance with the strategy for the disposal of surface water in the Flood Risk Assessment by Enzygo as amended by letters and details submitted 13 February 2020. The strategy shall thereafter be managed and maintained in accordance with the approved strategy. 4. No part of the development shall be commenced until details of the proposed access indicatively shown on Drawing No.

Carlton Meres Country Park, Carlton, SAXMUNDHAM, IP17 2QP — East Suffolk — Graham Chamberlain SHF.201.051.T.D.003.6 Rev A (including the position of any gates to be erected, surface water drainage and visibility splays provided) have been submitted to and approved in writing by the Local Planning Authority. The approved access shall be laid out and constructed in its entirety prior to occupation. Thereafter the access shall be retained in its approved form. 5. No part of the development shall be commenced until details of the proposed highway improvements (including direction road sign strategy) indicatively shown on the 'Proposed Highway Works' drawing and Drawing Ref: SHF.201.051.L.D.001.A have been submitted to and approved in writing by the Local Planning Authority. The approved scheme shall be laid out and constructed in its entirety prior to occupation. 6. The use shall not commence until the area(s) within the site shown on Drawing No. SHF.201.051.L.D.00.008 for the purposes of manoeuvring and parking of vehicles has been provided and thereafter that area(s) shall be retained and used for no other purposes. 7. Before the development is commenced details of the areas to be provided for secure cycle storage shall be submitted to and approved in writing by the Local Planning Authority.

Carlton Meres Country Park, Carlton, SAXMUNDHAM, IP17 2QP — East Suffolk — Graham Chamberlain The approved scheme shall be carried out in its entirety before the development is brought into use and shall be retained thereafter and used for no other purpose. 8. All HGV traffic movements to and from the site over the duration of the construction period shall be subject to a Deliveries Management Plan which shall be submitted to the planning authority for approval a minimum of 28 days before any deliveries of materials commence. No HGV movements shall be permitted to and from the site other than in accordance with the routes defined in the Plan. The site operator shall maintain a register of complaints and record of actions taken to deal https://www.gov.uk/planning-inspectorate 11

Carlton Meres Country Park, Carlton, SAXMUNDHAM, IP17 2QP — East Suffolk — Graham Chamberlain The approved scheme shall be carried out in its entirety before the development is brought into use and shall be retained thereafter and used for no other purpose. 8. All HGV traffic movements to and from the site over the duration of the construction period shall be subject to a Deliveries Management Plan which shall be submitted to the planning authority for approval a minimum of 28 days before any deliveries of materials commence. No HGV movements shall be permitted to and from the site other than in accordance with the routes defined in the Plan. The site operator shall maintain a register of complaints and record of actions taken to deal https://www.gov.uk/planning-inspectorate 11

Carlton Meres Country Park, Carlton, SAXMUNDHAM, IP17 2QP — East Suffolk — Graham Chamberlain Appeal Decision APP/X3540/W/20/3259654 with such complaints at the site office as specified in the Plan throughout the period of construction on the site. 9. No development (including any construction, demolition, site clearance or removal of underground tanks and relic structures) approved by this planning permission, shall take place until a site investigation consisting of the following components has been submitted to, and approved in writing by, the local planning authority: a) A desk study and site reconnaissance, including: - a detailed appraisal of the history of the site; - an inspection and assessment of current site conditions; - an assessment of the potential types, quantities and locations of hazardous materials and contaminants considered to potentially exist on site; - a conceptual site model indicating sources, pathways and receptors; and - a preliminary assessment of the risks posed from contamination at the site to relevant receptors, including: human health, ground waters, surface waters, ecological systems and property (both existing and proposed).

Carlton Meres Country Park, Carlton, SAXMUNDHAM, IP17 2QP — East Suffolk — Graham Chamberlain b) Where deemed necessary following the desk study and site reconnaissance an intrusive investigation(s), including: - the locations and nature of sampling points (including logs with descriptions of the materials encountered) and justification for the sampling strategy; - an explanation and justification for the analytical strategy; - a revised conceptual site model; and - a revised assessment of the risks posed from contamination at the site to relevant receptors, including: human health, ground waters, surface waters, ecological systems and property (both existing and proposed). All site investigations must be undertaken by a competent person and conform with current guidance and best practice, including: BS 10175:2011+A1:2013 and CLR11. Reason: To ensure that risks from land contamination to the future users of the land and neighbouring land are minimised, together with those to controlled waters, property and ecological systems, and to ensure that the development can be carried out safely without unacceptable risks to workers, neighbours and other offsite receptors. 10.

Carlton Meres Country Park, Carlton, SAXMUNDHAM, IP17 2QP — East Suffolk — Graham Chamberlain No development (including any construction, demolition, site clearance or removal of underground tanks and relic structures) approved by this planning permission, shall take place until a detailed remediation method statement (RMS) has been submitted to, and approved in writing by, the LPA. The RMS must include, but is not limited to: - details of all works to be undertaken including proposed methodologies, drawings and plans, materials, specifications and site management procedures; - an explanation, including justification, for the selection of the proposed remediation methodology(ies); - proposed remediation objectives and remediation criteria; and - proposals for validating the remediation and, where appropriate, for future maintenance and monitoring. https://www.gov.uk/planning-inspectorate 12

Carlton Meres Country Park, Carlton, SAXMUNDHAM, IP17 2QP — East Suffolk — Graham Chamberlain Appeal Decision APP/X3540/W/20/3259654 The RMS must be prepared by a competent person and conform to current guidance and best practice, including CLR11. 11. Prior to any occupation or use of the approved development the RMS approved under condition [10] must be completed in its entirety. The LPA must be given two weeks written notification prior to the commencement of the remedial works. 12. A validation report must be submitted to and approved in writing by the LPA prior to any occupation or use of the approved development. The validation report must include, but is not limited to: - results of sampling and monitoring carried out to demonstrate that the site remediation criteria have been met; - evidence that any RMS approved in pursuance of conditions appended to this consent has been carried out competently, effectively and in its entirety; and - evidence that remediation has been effective and that, as a minimum, the site will not qualify as contaminated land as defined by Part 2A of the Environmental Protection Act 1990. 13.

Carlton Meres Country Park, Carlton, SAXMUNDHAM, IP17 2QP — East Suffolk — Graham Chamberlain In the event that contamination which has not already been identified to the Local Planning Authority (LPA) is found or suspected on the site it must be reported in writing immediately to the Local Planning Authority. Unless agreed in writing by the LPA no further development (including any construction, demolition, site clearance, removal of underground tanks and relic structures) shall take place until this condition has been complied with in its entirety. An investigation and risk assessment must be completed in accordance with a scheme which is subject to the approval in writing of the Local Planning Authority. The investigation and risk assessment must be undertaken by competent persons and conform with prevailing guidance (including BS 10175:2011+A1:2013 and CLR11) and a written report of the findings must be produced. The written report is subject to the approval in writing of the Local Planning Authority. Where remediation is necessary a detailed remediation method statement (RMS) must be prepared, and is subject to the approval in writing of the Local Planning Authority.

Carlton Meres Country Park, Carlton, SAXMUNDHAM, IP17 2QP — East Suffolk — Graham Chamberlain The RMS must include detailed methodologies for all works to be undertaken, site management procedures, proposed remediation objectives and remediation criteria. The approved RMS must be carried out in its entirety and the Local Planning Authority must be given two weeks written notification prior to the commencement of the remedial works. Following completion of the approved remediation scheme a validation report that demonstrates the effectiveness of the remediation must be submitted to and approved in writing by the LPA. 14. The approved static caravans shall be used for holiday/tourism accommodation only and for no other purpose unless express planning permission is granted by the Local Planning Authority (LPA). The duration of occupation by any one person, or persons, of any of the units shall not exceed a period of 56 days in total in any one calendar year, unless otherwise formally approved in writing by the LPA. The owners/operators of the holiday units hereby permitted shall maintain an up- to-date register of all lettings, which shall include the names and addresses of all https://www.gov.uk/planning-inspectorate 13

Carlton Meres Country Park, Carlton, SAXMUNDHAM, IP17 2QP — East Suffolk — Graham Chamberlain Appeal Decision APP/X3540/W/20/3259654 those persons occupying the units during each individual letting. The said register shall be made available at all reasonable times to the LPA. 15. No more than 50 static caravans, as defined in the Caravan Sites and Control of Development Act 1960 and the Caravan Sites Act 1968 as amended, shall be stationed on the site at any time. Static caravans shall only be sited on the identified ‘Developable Area’ shown on the approved Development Areas Plan (Drawing Number SHF.201.051.L.D.00.003.) 16. Notwithstanding the submitted details, a landscape and ecological management plan (LEMP) shall be submitted to, and approved in writing by, the local planning authority prior to the commencement of the development. The content of the LEMP shall include the following: a) Description and evaluation of features to be managed. b) Ecological trends and constraints on site that might influence management. c) Aims and objectives of management. d) Appropriate management options for achieving aims and objectives. e) Prescriptions for management actions. f) Preparation of a work schedule (including an annual work plan capable of being rolled forward over a five-year period).

Carlton Meres Country Park, Carlton, SAXMUNDHAM, IP17 2QP — East Suffolk — Graham Chamberlain g) Details of the body or organisation responsible for implementation of the plan. h) Ongoing monitoring and remedial measures. The plan shall also set out (where the results from monitoring show that conservation aims and objectives of the LEMP are not being met) how contingencies and/or remedial action will be identified, agreed and implemented so that the development still delivers the fully functioning biodiversity objectives of the originally approved scheme. The development will be carried out strictly in accordance with the approved detail. 17. No development shall take place (including demolition, ground works, vegetation clearance) until a construction environmental management plan (CEMP: Biodiversity) has been submitted to and approved in writing by the local planning authority. The CEMP (Biodiversity) shall include the following: a) Risk assessment of potentially damaging construction activities. b) Identification of “biodiversity protection zones”. c) Practical measures (both physical measures and sensitive working practices) to avoid or reduce impacts during construction (may be provided as a set of method statements). d) The location and timing of sensitive works to avoid harm to biodiversity features.

Carlton Meres Country Park, Carlton, SAXMUNDHAM, IP17 2QP — East Suffolk — Graham Chamberlain e) The times during construction when specialist ecologists need to be present on site to oversee works. f) Responsible persons and lines of communication. g) The role and responsibilities on site of an ecological clerk of works (ECoW) or similarly competent person. h) Use of protective fences, exclusion barriers and warning signs. https://www.gov.uk/planning-inspectorate 14

Carlton Meres Country Park, Carlton, SAXMUNDHAM, IP17 2QP — East Suffolk — Graham Chamberlain e) The times during construction when specialist ecologists need to be present on site to oversee works. f) Responsible persons and lines of communication. g) The role and responsibilities on site of an ecological clerk of works (ECoW) or similarly competent person. h) Use of protective fences, exclusion barriers and warning signs. https://www.gov.uk/planning-inspectorate 14

Carlton Meres Country Park, Carlton, SAXMUNDHAM, IP17 2QP — East Suffolk — Graham Chamberlain Appeal Decision APP/X3540/W/20/3259654 The approved CEMP shall be adhered to and implemented throughout the construction period strictly in accordance with the approved details, unless otherwise agreed in writing by the local planning authority. 18. Prior to commencement of development a “lighting design strategy for biodiversity” for the site shall be submitted to and approved in writing by the local planning authority. The strategy shall: a) identify those areas/features on site that are particularly sensitive for biodiversity likely to be impacted by lighting and that are likely to cause disturbance in or around their breeding sites and resting places or along important routes used to access key areas of their territory, for example, for foraging; and b) show how and where external lighting will be installed (through the provision of appropriate lighting contour plans and technical specifications) so that it can be clearly demonstrated that areas to be lit will not disturb or prevent the above species using their territory or having access to their breeding sites and resting places.

Carlton Meres Country Park, Carlton, SAXMUNDHAM, IP17 2QP — East Suffolk — Graham Chamberlain All external lighting shall be installed in accordance with the specifications and locations set out in the strategy, and these shall be maintained thereafter in accordance with the strategy. Under no circumstances should any other external lighting be installed without prior consent from the local planning authority. 19. Notwithstanding the submitted details, prior to commencement of development, an Ecological Mitigation and Enhancement Strategy addressing how ecological mitigation and enhancements will be achieved on site, will be submitted to and approved in writing by the local planning authority. The Strategy shall follow the guidance and principles set out in the Preliminary Ecological Appraisal, and relevant Ecology sections of the Environmental Statement. The Strategy shall be carried out fully in accordance with the approved details and delivered and maintained in accordance with the programme to be provided within The Strategy. 20.

Carlton Meres Country Park, Carlton, SAXMUNDHAM, IP17 2QP — East Suffolk — Graham Chamberlain The development shall not in any circumstances commence unless the local planning authority has been provided with either: a) a licence issued by Natural England pursuant to The Conservation of Habitats and Species Regulations 2017 authorising the specified development to go ahead; or b) a statement in writing from the relevant licensing body to the effect that it does not consider that the specified development will require a licence. 21. Notwithstanding the submitted details, no development shall commence until details of both hard and soft landscape works have been submitted to and approved in writing by the local planning authority. These details shall include: • planting plans; • written specifications (including cultivation and other operations associated with plant and grass establishment); • schedules of plants noting species, plant supply sizes and proposed numbers/densities where appropriate; • a statement setting out the design objectives and how these will be delivered; • earthworks showing existing and proposed finished levels or contours; https://www.gov.uk/planning-inspectorate 15

Carlton Meres Country Park, Carlton, SAXMUNDHAM, IP17 2QP — East Suffolk — Graham Chamberlain Appeal Decision APP/X3540/W/20/3259654 • means of enclosure and retaining structures; • boundary treatment[s]; • vehicle parking layouts; • other vehicle and pedestrian access and circulation areas; hard surfacing materials; minor artefacts and structures [e.g. furniture, play equipment, refuse or other storage units, signs, etc.]; • retained historic or other landscape features and proposals for restoration, where relevant; • an implementation, maintenance, and management programme. The landscaping works shall be carried out in accordance with the approved details before any part of the development is first occupied in accordance with the agreed implementation programme. The completed scheme shall be managed and maintained in accordance with the approved programme of management and maintenance. 22. Prior to the siting of any static holiday caravans on the land, a colour scheme/pallete for the external appearance of the static caravans shall be submitted to and approved in writing by the Local Planning Authority. All static holiday caravans sited on the land shall have an external appearance in accordance with the approved colour scheme/palette. End of Schedule https://www.gov.uk/planning-inspectorate 16