Combehead Farm, Bridford, Exeter, Devon, EX6 7LQ

Combehead Farm, Bridford, Exeter, Devon, EX6 7LQ — Dartmoor — Appeal Decision Hearing held on 29 February 2024 Site visit made on 29 February 2024 by Lewis Condé BSc, MSc, MRTPI an Inspector appointed by the Secretary of State Decision date: 15th April 2024 Appeal Ref: APP/J9497/W/23/3333517 Coombehead Farm, Bridford, Exeter EX6 7LQ • The appeal is made under section 78 of the Town and Country Planning Act 1990 (as amended) against a refusal to grant planning permission. • The appeal is made by Mr B Denison against the decision of Dartmoor National Park Authority. • The application Ref is 0223/23. • The development proposed is siting of temporary rural workers dwelling, erection of agricultural building and yard. Decision 1. The appeal is dismissed in so far as it relates to the siting of the temporary workers dwelling, erection of agricultural building and yard, as well as an agricultural track and new pond. 2.

Combehead Farm, Bridford, Exeter, Devon, EX6 7LQ — Dartmoor — Appeal Decision The appeal is allowed, however, insofar as it relates to the existing pond and planning permission is granted for a pond at Coombehead Farm, Bridford, Exeter, Devon EX6 7LQ in accordance with the terms of the application, Ref 0223/23, and subject to the following condition: 1) The development hereby permitted relates to only the existing pond installed on the site that is shown as Section C-C on the following submitted drawings: ‘Location Plan’, Drawing no. BD-JH-01 A; and ‘Pond Sections’ Drawing no.BD-JH-110. Preliminary Matters 3. The description of development in the banner heading above follows that on the original planning application form. Although not referenced within the description of development the appellant’s original submission refers to permission also being sought for ancillary works to the rural enterprise. It was clarified during the hearing that this consists of an existing unauthorised access track and pond that have been installed at the site, as well as a proposed pond, each of which are shown on the submitted plans. I have determined the appeal on this basis. 4.

Combehead Farm, Bridford, Exeter, Devon, EX6 7LQ — Dartmoor — Appeal Decision I have been made aware of an enforcement case relating to the unauthorised occupation of the existing agricultural building at the appeal site. However, this is not a consideration for this appeal. 5. In December 2023, a revised version of the National Planning Policy Framework (the Framework) was issued. Where comments were made with regards to the most recent Framework, I have taken these into account in my decision. https://www.gov.uk/planning-inspectorate

Combehead Farm, Bridford, Exeter, Devon, EX6 7LQ — Dartmoor — Appeal Decision I have been made aware of an enforcement case relating to the unauthorised occupation of the existing agricultural building at the appeal site. However, this is not a consideration for this appeal. 5. In December 2023, a revised version of the National Planning Policy Framework (the Framework) was issued. Where comments were made with regards to the most recent Framework, I have taken these into account in my decision. https://www.gov.uk/planning-inspectorate

Combehead Farm, Bridford, Exeter, Devon, EX6 7LQ — Dartmoor — Appeal Decision Appeal Decision APP/J9497/W/23/3333517 6. At the hearing the appellant highlighted that the proposed new pond has solely been put forward to provide bio-diversity enhancements required to mitigate the proposed new build development. For reasons that follow, I have found the proposed temporary residential dwelling and agricultural building to be unacceptable, I have therefore not considered the proposed pond further. Main Issues 7. The main issues are: i) The effect of the development on the character and appearance of the area, having particular regard to the location of the site within Dartmoor National Park; ii) Whether the agricultural enterprise justifies the proposed temporary dwelling, having regard to local and national policies which seek to avoid isolated new homes in the countryside; iii) Whether the proposal could provide suitable foul and surface water drainage systems so as to minimise the risk of flooding or pollution of watercourses; and iv) The effect of the proposal on biodiversity. Reasons Character and Appearance 8. The appeal site predominantly comprises part of an agricultural field, which is part of a wider holding that measures approximately 9.3ha across steeply sloping land.

Combehead Farm, Bridford, Exeter, Devon, EX6 7LQ — Dartmoor — Appeal Decision It is located within Dartmoor National Park (DNP) to the east of the village of Bridford. 9. The site forms part of an expansive surrounding landscape that is heavily undulating, with a strong rural character consisting of irregular, medium sized field patterns that appear to largely be used for pastoral farming. From my observations, the site and surrounding fields are largely interspersed by rich hedgerow and woodland which provide the rather dramatic valley slopes with a treed character. The site therefore aligns with many of the key characteristics of the ‘Upper Farmed and Wooded Slopes’ Landscape Character Area (LCA) in which it lies, as set out in the Dartmoor Landscape Character Assessment (2017). It therefore contributes positively to the character and appearance of the area. 10. The Framework requires that great weight should be given to conserving and enhancing landscape and scenic beauty in National Parks, which have the highest status of protection in relation to these issues. This requirement is also reflected in several of the policies of the Dartmoor Local Plan (2018 – 2036) (adopted 2021) (the Local Plan). 11.

Combehead Farm, Bridford, Exeter, Devon, EX6 7LQ — Dartmoor — Appeal Decision Although the appeal site already contains some limited built form, it remains that the site is largely undeveloped and has a very rural, tranquil, and verdant character. The proposed temporary dwelling would be highly divorced from the https://www.gov.uk/planning-inspectorate 2

Combehead Farm, Bridford, Exeter, Devon, EX6 7LQ — Dartmoor — Appeal Decision Although the appeal site already contains some limited built form, it remains that the site is largely undeveloped and has a very rural, tranquil, and verdant character. The proposed temporary dwelling would be highly divorced from the https://www.gov.uk/planning-inspectorate 2

Combehead Farm, Bridford, Exeter, Devon, EX6 7LQ — Dartmoor — Appeal Decision Appeal Decision APP/J9497/W/23/3333517 existing farm building at the site. Due to its separated position a considerable extent of new access track is also proposed to reach the dwelling. Together, the siting of the proposed temporary dwelling and the extent of new track, would result in significant encroachment of development into the landscape. This would degrade the verdant and rural character of the presently undisturbed land. 12. During the hearing the appellant raised that the proposed siting of the temporary dwelling is considered the most suitable position to enable views of paddocks containing alpaca. The appellant also indicated it to be the flattest area of the site for rearing cria, which can be susceptible to Ricketts. However, no detailed evidence of the likelihood that cria are to suffer from Ricketts has been provided and I am unconvinced that suitable supporting aid could not be provided to relevant cria on other areas of the site. 13.

Combehead Farm, Bridford, Exeter, Devon, EX6 7LQ — Dartmoor — Appeal Decision Although other areas of the site may not provide the same extent of visibility over alpaca paddocks, there are less exposed locations for the proposed temporary dwelling, whereby it could be more closely clustered with existing built form, whilst still providing appropriate surveillance opportunities. 14. The appellant also outlined at the hearing that the scale and nature of the proposed temporary dwelling was selected with a mind towards its more permanent retention. A condition could be attached to the grant of permission requiring its eventual removal and for the land to be restored to its former condition, but there would remain harm to the character and appearance of the area for the temporary period. Whilst it has not been suitably justified that the proposal could not take place in a less harmful position on the site. 15. Turning to the proposed agricultural building, I am content that through appropriate management practices it would be suitable to use for the storage of hay and livestock. Nevertheless, the proposed building would have a highly industrial appearance due to the combination of its scale, materiality, and the incorporation of a sizeable roller shutter door.

Combehead Farm, Bridford, Exeter, Devon, EX6 7LQ — Dartmoor — Appeal Decision The design of the proposed agricultural building would not sit well against the far more traditional form of the existing agricultural building. Indeed, I find that the industrial character of the building would fail to harmonise with the simple, traditional vernacular form of development presently on the site. In the hearing the appellant made reference to agricultural buildings often having an industrialised appearance, but no similar examples in the local area have been provided. 16. The appellant has indicated a willingness to accept a condition that the proposed building is instead clad in timber. In the absence of any details to show how the cladding may appear, the extent of its application, and how areas such as the roller shutter doors may be treated, I am not convinced this would overcome my concerns with the building’s design and appearance. 17. Based on the agricultural activities described, I am satisfied that there is a functional need for an additional barn at the site, whilst there is no compelling evidence to contest the appellant’s justifications for the scale of the proposed building.

Combehead Farm, Bridford, Exeter, Devon, EX6 7LQ — Dartmoor — Appeal Decision The provision of an associated yard area around the building would also be needed to enable the movement of vehicles, machinery, and hay bales around the site, thereby allowing the enterprise to function efficiently. However, these matters do not overcome my above concerns with regards to the proposals design and appearance. https://www.gov.uk/planning-inspectorate 3

Combehead Farm, Bridford, Exeter, Devon, EX6 7LQ — Dartmoor — Appeal Decision The provision of an associated yard area around the building would also be needed to enable the movement of vehicles, machinery, and hay bales around the site, thereby allowing the enterprise to function efficiently. However, these matters do not overcome my above concerns with regards to the proposals design and appearance. https://www.gov.uk/planning-inspectorate 3

Combehead Farm, Bridford, Exeter, Devon, EX6 7LQ — Dartmoor — Appeal Decision Appeal Decision APP/J9497/W/23/3333517 18. In terms of the existing pond, it appears as a rather naturalistic feature that was highly inconspicuous on the site, with very limited views available. Therefore, it does not cause harm to the character or appearance of the site or wider landscape. This element of the proposal is also clearly severable both physically and functionally from the wider elements of the appeal scheme. 19. With respect to the track, the appellant highlights that a former owner of the site built over a previous stone track that led from the site’s entrance to the existing agricultural building. The appellant has stated that the existing track has been in place for several years and is immune from enforcement action. However, there is no certificate of lawfulness before me to demonstrate this, whilst it remains part of the appeal proposal. 20. The existing access track largely incorporates a loose hardcore/crushed stone finish. It is extensive in length, and rather winding in nature, primarily skirting around the edges of the site to navigate the gradient.

Combehead Farm, Bridford, Exeter, Devon, EX6 7LQ — Dartmoor — Appeal Decision The appellant states that the hardcore that has been laid down merely changes the surfacing of a longstanding track, but I have no robust evidence to verify the presence of the original track, its extent, route, or appearance. 21. From my observations on site the hardcore surfaced track has an urbanising effect on this rural site. Whilst its harm may be limited, I cannot conclude that it conserves or enhances the landscape or scenic beauty of the site. 22. I accept that given the operations of the enterprise and the topography of the site, there is also a functional need for an access track to the existing agricultural building, but this does not overcome my above concerns. 23. In reaching the above views, it is recognised that public views of any of the proposed development are likely to be extremely limited due to the surrounding topography, presence of mature vegetation, and the distances to nearest public vantage points. As such, the appeal proposals would not result in visual harm. Nevertheless, the proposed development, would still adversely affect the landscape character of the site. 24.

Combehead Farm, Bridford, Exeter, Devon, EX6 7LQ — Dartmoor — Appeal Decision I therefore find the appeal proposal to have an unacceptable effect on the character and appearance of the area, with particular regard to the location of the site within Dartmoor National Park. Accordingly, the proposals would be contrary to Local Plan Policies SP 1.1, SP 1.2, SP 1.5, SP 2.1, P 2.6, and P 5.8, as well as the Design Guide. Together these policies and guidance, amongst other matters, require that development conserves and enhance the landscape and scenic qualities of DNP, whilst also setting out detailed design expectations, to ensure that new developments reinforce the local character and vernacular of the National Park. 25. Additionally, and for the same reasons, these elements of the scheme would conflict with Paragraph 182 of the Framework, as well as the advice of the English National Parks and the Broads UK Government Vision and Circular 2010 (the Circular), in relation to conserving and enhancing the natural beauty of National Parks. 26. However, for reasons outlined above, I am satisfied that the pond that has already been installed at the site does not cause harm to the character and appearance of the area.

Combehead Farm, Bridford, Exeter, Devon, EX6 7LQ — Dartmoor — Appeal Decision It therefore conserves the landscape and scenic beauty of the National Park and complies with the above detailed policies. https://www.gov.uk/planning-inspectorate 4

Combehead Farm, Bridford, Exeter, Devon, EX6 7LQ — Dartmoor — Appeal Decision It therefore conserves the landscape and scenic beauty of the National Park and complies with the above detailed policies. https://www.gov.uk/planning-inspectorate 4

Combehead Farm, Bridford, Exeter, Devon, EX6 7LQ — Dartmoor — Appeal Decision Appeal Decision APP/J9497/W/23/3333517 Whether the agricultural enterprise justifies the proposed temporary dwelling 27. The appeal site lies in a rural area within the open countryside. Local Plan Policy SP 1.2 seeks to promote sustainable development, including through ensuring development takes place where it minimises the need to travel. Building on this, Local Plan Policy SP 1.3 establishes the spatial strategy for development within DNP, it focuses housing development towards specified local centres, settlements, villages, and hamlets. The policy further details limited circumstances whereby development will be acceptable in principle in the open countryside, this includes where it relates to farming, forestry, or other land-based rural businesses with a proven need to locate in the open countryside. 28. Meanwhile, Local Plan Policy 3.9 sets out detailed criteria against which proposals for rural workers housing will be assessed. Criterion 4 of the policy outlines that to support the establishment of a new farm or other rural land- based business, permission for a residential caravan will be granted for a temporary period of three years.

Combehead Farm, Bridford, Exeter, Devon, EX6 7LQ — Dartmoor — Appeal Decision It further highlights that new enterprises will need to demonstrate that there is a justified essential need for a full-time worker to live permanently at or near their place of work (i.e. a functional need), whilst also demonstrating that there is a realistic prospect of developing a viable enterprise through appropriate business planning (i.e. the financial test). 29. I find the central thrust of the above policies to be consistent with Paragraph 84 of the Framework. This seeks to avoid the development of isolated homes in the countryside, unless certain circumstances apply, including that there is an essential need for a rural worker to live permanently at or near their place of work in the countryside. Functional Need 30. In respect of demonstrating an essential need for rural workers dwellings, the supporting text to Local Plan Policy 3.9 outlines that it will entail specific management activities which require a worker’s presence at most times and which cannot be achieved by other means. The Authority’s Housing Supplementary Planning Document (Housing SPD) (adopted December 2023) provides further guidance on what may result in an essential need.

Combehead Farm, Bridford, Exeter, Devon, EX6 7LQ — Dartmoor — Appeal Decision It notably highlights that it is about ensuring an enterprise can function properly, as opposed to ease or convenience. 31. The supporting text to Local Plan Policy 3.9 (at paragraph 3.9.6) further sets out that a temporary dwelling will be allowed for three years in order to demonstrate the need and the viability of the business (subject to meeting policy tests). I therefore find the appellant’s assertions that the functional need for the proposed dwelling should be demonstrated as needed within the trial period, rather than at the outset of establishing the business, to be compelling. Especially as without first having temporary accommodation available, the activities that would necessitate a functional need may not be capable of taking place, whilst it would also potentially limit further investment and growth of an enterprise with implications for its viability. 32. The appellant owns the land outright and has begun developing an agricultural enterprise that currently is based upon breeding and rearing of alpacas for sale, the sale of alpaca bi-products, the keeping and breeding of pedigree https://www.gov.uk/planning-inspectorate 5

Combehead Farm, Bridford, Exeter, Devon, EX6 7LQ — Dartmoor — Appeal Decision Appeal Decision APP/J9497/W/23/3333517 pygmy goats for onward sale, the keeping of bees and sale of honey, as well as hay making. 33. There are currently in the region of 30 breeding female alpaca, 3 stud male alpaca, 2 cria, 15 pygmy goats (including 2 in kid), 2 kids and 2 beehives kept on the site. The appellant has also purchased 3 sows which are expected to produce pork in the coming months, while 300 chickens and a mobile chicken shed have been purchased, which I am informed have been delayed from arriving at the site pending the outcome of the appeal. 34. During the hearing, the appellant detailed how he is working full-time on the agricultural enterprise. It was also explained that he has taken on a new director for his existing groundworks business so is no longer involved in its day-to-day management, thus enabling him to fully commit his time and energy to the agricultural enterprise. I have no reason to disbelieve this. From the discussions it was also clear that he grew up on a smallholding and tended to animals such as alpacas, chickens, and goats. He therefore displayed knowledge of these animals, whilst also showing passion for working with them.

Combehead Farm, Bridford, Exeter, Devon, EX6 7LQ — Dartmoor — Appeal Decision It seems credible that this is a long-term lifestyle choice for the appellant. 35. Having regards to a theoretical Standard Man Day assessment (SMD)1, the main parties dispute whether the level of labour required to run the enterprise would equate to that of a full-time worker. However, even if I were to determine that SMD were to fall slightly short of the requirement of a full-time worker it would still represent a sizable number of working days. Moreover, the theoretical total labour requirement is not the same as demonstrating an essential need for a rural worker to live at or near their place of work. Instead, based on the evidence presented, in this case I find that the functional need for a worker to live at the site hinges upon the needs and welfare of the livestock. This was a view shared by the main parties. 36. The principal argument for the appellant to reside at the site relates to the husbandry activities associated with the alpaca, particularly ensuring that there are no complications during the birthing of cria, as well as providing after-birth care.

Combehead Farm, Bridford, Exeter, Devon, EX6 7LQ — Dartmoor — Appeal Decision As indicated, the appellant already has approximately 30 breeding female alpacas at the site, this already exceeds the numbers that were anticipated to be kept by year 3 onwards of the appellant’s business plan. The size of the herd, together with the animal’s characteristics and needs provide notable circumstances as to why residential presence at the site may be required. 37. The gestation period for alpacas is roughly 330 days, while there may be variations by up to 30 days either side of this. I accept that this may make it difficult to closely predict the timing of births, whilst there is a need for someone to be on hand during birthing periods to manage emergencies that may arise. Although birthing may typically occur during the daytime and may not entail complications, it is reasonable that births can occur at any time during the day or night. Having a worker live on site would therefore increase the likelihood of any birthing difficulties being noticed. 38. The appellant has detailed how mating of alpacas is not necessarily straightforward and can require human intervention as well as observation. It therefore may not be possible for each female to be put to stud simultaneously.

Combehead Farm, Bridford, Exeter, Devon, EX6 7LQ — Dartmoor — Appeal Decision 1 As published in the John Nix Farm Management Pocketbook, 52nd Edition. https://www.gov.uk/planning-inspectorate 6

Combehead Farm, Bridford, Exeter, Devon, EX6 7LQ — Dartmoor — Appeal Decision 1 As published in the John Nix Farm Management Pocketbook, 52nd Edition. https://www.gov.uk/planning-inspectorate 6

Combehead Farm, Bridford, Exeter, Devon, EX6 7LQ — Dartmoor — Appeal Decision Appeal Decision APP/J9497/W/23/3333517 Furthermore, due to the scale of the enterprise and its dependency upon the sale of alpaca, where conception does not materialise or needs to be aborted, it would be necessary to return alpacas to stud at the next available opportunity (approx. 20 days slippage each time). I therefore accept that the grouping of pregnancies and births for a herd of approximately 30 breeding females would be very challenging and it is likely that births may take place throughout the year. 39. Although alpaca may be generally hardy animals that are relatively easy to keep, the cria remain prey for predators such as badgers and foxes. The appellant also highlights that cria can often require artificial rearing. Typically, this would involve two hourly feeds day and night for the initial first weeks, 3- hourly feeds up to eight weeks and potentially 3 times daily up to around four months. From the evidence before me, I have no robust reasons to dispute this. It is therefore conceivable that there would need to be a sustained on-site presence for a prolonged period after birthing has occurred, especially if there are several cria that require hand-rearing. 40.

Combehead Farm, Bridford, Exeter, Devon, EX6 7LQ — Dartmoor — Appeal Decision The pygmy goats on site are likely to produce a further 18 – 20 kidding events a year, which are non-seasonal. Although new to the business proposal the introduction of sows would also likely lead to additional birthing periods throughout the year. Whilst these livestock may not have the same requirements as the alpacas, a worker on-site would still be able to respond promptly to emergency situations arising during birthing or resulting from the presence of predators. 41. The appellant’s business plan, which I will return to later, is largely predicated on the high-value sales of the alpaca, with the profit mainly driven from the birth of cria. As such, even the loss of a small number of alpaca or cria could therefore be highly damaging to the business. 42. The nearest villages of Bridford and Christow remain a fairly considerable distance from where livestock are kept at the appeal site, whilst rural roads/tracks would need to be navigated in the event of emergencies at the site. Accordingly, properties in these locations would not allow effective monitoring of alpaca, where close proximity around birthing and rearing periods is likely to be essential. 43.

Combehead Farm, Bridford, Exeter, Devon, EX6 7LQ — Dartmoor — Appeal Decision Additionally, I do not consider that the use of mobile surveillance such as CCTV would provide a reliable or effective means of monitoring the condition of livestock. This is due to the likely extent of coverage required and the level of close attention needed to spot behavioural changes in the animals. 44. The conflicting nature of other appeals involving alpaca farms that have been put before me, highlights the importance of determining each case on its own merits. In fact, this is a point that was specifically raised by the Authority’s agricultural consultant (Mr. Meek of South West Norse Ltd). 45. Nonetheless, at the hearing the Authority stressed the potential for the enterprise to be appropriately managed through a combination of living nearby to the site and utilising permitted development rights for temporary accommodation, as per the findings of the Inspector in the ‘Bird Farm Appeal’ (ref: APP/F1230/W/19/3220377). https://www.gov.uk/planning-inspectorate 7

Combehead Farm, Bridford, Exeter, Devon, EX6 7LQ — Dartmoor — Appeal Decision Appeal Decision APP/J9497/W/23/3333517 46. However, the Bird Farm Appeal related to a small, but unspecified herd of alpaca and I do not have details of the breeding arrangements amongst other things. Therefore, I cannot be sure it is directly comparable with this current appeal scheme. 47. From the evidence before me, it would seem that the appellant has a fairly sizeable herd of alpaca in the context of other UK alpaca farms. Additionally, the appellant has outlined credible reasons why the alpaca would have an extended birthing period which, together with the birthing of other livestock (namely pygmy goats and pigs), I find could not be reasonably fulfilled through a combination of living nearby to the site and utilisation of permitted development rights. 48. It was also detailed at the hearing that as the business expands there will be an increased need for the existing agricultural building to be used in connection with storage of hay, livestock and equipment associated with the proposal, such that it is unlikely to remain suitable to accommodate the appellant. 49.

Combehead Farm, Bridford, Exeter, Devon, EX6 7LQ — Dartmoor — Appeal Decision In this instance, I therefore find that the successful and proper management of the enterprise would reasonably require a rural worker to be available at the site at most times, including overnight, throughout most of the year. Overall, I am therefore satisfied that the appeal proposal meets the functional test as outlined under Policy 3.9. Financial Test 50. Turning to the financial test, the appellant’s submitted Agricultural Appraisal (June 2022) includes a business plan demonstrating projected future operations over an initial 3-year period and then onwards. It suggests that, after accounting for land, labour and capital costs, the business should be generating sufficient taxable profits to meet a reasonable return by Year 3 and onwards. 51. The business plan includes a detailed breakdown of estimated revenue streams, with gross margin figures for the sale of produce based upon widely accepted industry sources2. The business plan also includes seemingly sensible estimates of both variable and fixed costs, whilst also including a contingency allowance. 52. Since the preparation of the business plan, the appellant has purchased the alpaca and pygmy goats previously referred to.

Combehead Farm, Bridford, Exeter, Devon, EX6 7LQ — Dartmoor — Appeal Decision It is also evident that there has been further investment in creation of grazing paddocks, while perimeter fencing has been installed. The land is also understood to be registered with the Rural Payment Agency, with the appellant claiming Basic Payment Scheme Entitlements on the net farmable area. As such, there has been a clear financial commitment to the enterprise. 53. At the hearing, it was made apparent that since the business plan was initially prepared, the appellant’s intentions have somewhat evolved, including an intent to add additional revenue streams, such as, breeding of sows for pork products. However, fundamentally the potential success of the enterprise is still largely aligned to achieving the outcomes identified in the business plan. From the evidence before me it seems, that the success of the enterprise will largely 2 The John Nix Pocketbook 2022 (52nd Edition); and AlpacaSeller website database. https://www.gov.uk/planning-inspectorate 8

Combehead Farm, Bridford, Exeter, Devon, EX6 7LQ — Dartmoor — Appeal Decision Appeal Decision APP/J9497/W/23/3333517 be dependent upon the sale of alpacas, as well as the sale of eggs and pygmy goats. 54. The financial viability of the enterprise was not cited in the Authority’s reasons for refusal on its decision notice, nor were issues raised within the original officer’s report. Nonetheless, during the appeal the Authority indicated concerns about the submitted business case. 55. At the hearing, Mr Meek highlighted that although there were not material concerns regarding the overall business plan, based on the available information and activity he witnessed at the site when his advice to the application was provided (i.e. July 2023), he held doubts about the business forecasts. He therefore could not deem the enterprise to have been planned on a sound financial basis. It was indicated that the anticipated sales figures within the appellant’s business plan were the key area of contention, particularly those relating to alpacas. No specific wider concerns relating to the proposed business plan were outlined by the Authority during the hearing. 56.

Combehead Farm, Bridford, Exeter, Devon, EX6 7LQ — Dartmoor — Appeal Decision The appellant’s explanation that he was able to reduce his purchase costs through buying herds of alpacas is credible for explaining identified discrepancies between purchase prices and anticipated sales figures. 57. I also understand that the appellant has already secured a contract for the sale of eggs, albeit planning permission has yet to be secured for the chicken shed. However, I can understand why certain elements of the business plan have not yet progressed further, including greater advertisement of the business, given the additional investment and risks they would involve. Particularly given the continued uncertainty surrounding the acceptability of this current appeal scheme. 58. Doubts have also been raised about the evidence to support the income that would be derived from the sales of other produce, including alpaca wool, dung for fertiliser, and honey. However, the appellant’s income estimates suggest that once the business is established these will comprise a relatively small component of its overall revenue. As such, some moderate variances to the forecasted profit margins on these products are unlikely to make a significant difference to the viability of the enterprise. 59.

Combehead Farm, Bridford, Exeter, Devon, EX6 7LQ — Dartmoor — Appeal Decision Although the success of the business may depend upon its further expansion, nothing I have heard or read leads me to believe that the business is not planned on a sound financial basis. It is also evident to me that the appellant is committed to trying to make a success of the business, whilst he has an appropriate background that would aid the likelihood of success. 60. Furthermore, the appellant has commented that the proposal for a dwelling for a temporary 3-year trial period would enable the business to develop and grow and provide opportunity to prove the business case. This sentiment was somewhat shared by Mr Meek who also recognised that a trial period is ultimately key to proving whether the figures contained within the business plan could be achieved. 61. Consequently, I find that the potential viability of the business has been suitably demonstrated through business planning and that a trial period is appropriate to determine whether the enterprise is likely to remain viable in the https://www.gov.uk/planning-inspectorate 9

Combehead Farm, Bridford, Exeter, Devon, EX6 7LQ — Dartmoor — Appeal Decision Appeal Decision APP/J9497/W/23/3333517 longer-term. Accordingly, the appeal scheme passes the financial test outlined under Local Plan Policy 3.9. Nature and Scale of the Proposed Temporary Dwelling 62. Local Plan Policy 3.9 specifically refers to the provision of a ‘caravan’ to help support the establishment of new farm or rural businesses. The supporting advice at paragraph 7.2.1 of the Housing SPD, however, states that temporary rural worker’s dwellings should typically be in the form of a caravan or mobile home, thereby suggesting some flexibility. Furthermore, through discussions at the hearing it was clear that the intent behind a temporary dwelling being provided in the form of a caravan was the ability to easily remove the structure and return the land to its original condition following any trial period. 63. The appellant has confirmed that the proposed building was selected, as its dimensions and configuration, would satisfy the definition of a caravan as outlined under the Caravan Sites and Control of Development Act 1960, and as further detailed under the Caravan Sites Act 1968. I have no robust reasons to reach an alternative view. 64.

Combehead Farm, Bridford, Exeter, Devon, EX6 7LQ — Dartmoor — Appeal Decision However, the appellant explained at the hearing that for ease of access it would be preferable for it to be delivered in more than two sections, in which case it would no longer meet the definition of a caravan having regard to the terms of Section 13 of the Caravan Sites Act 1968. 65. Only limited details of any necessary engineering operations required to position the structure on the land have been presented by the appellant. Nevertheless, I am satisfied that a condition could be attached to any grant of permission requiring the approval of the precise details. Furthermore, the grant of a temporary permission could also be subject to a condition which requires the land to be restored to its original condition following the expiry of the temporary permission. Under such circumstances, I am satisfied that regardless of whether the proposed temporary dwelling was delivered to the site for assembly in two sections, or more, it would still meet the relevant aims of Policy 3.9 and the associated Housing SPD. Namely it’s degree of permanence would remain temporary in nature, and it could be removed without any lasting effects being perceptible. 66.

Combehead Farm, Bridford, Exeter, Devon, EX6 7LQ — Dartmoor — Appeal Decision Turning to the size of the proposed temporary dwelling, Local Plan Policy 3.9 (Criterion 2) and its supporting text set out limits on the gross internal floorspace for new agricultural dwellings. These build upon Strategic Policy 3.2 which requires that all housing in the National Park does not significantly exceed nationally described space standards due to issues of housing affordability. 67. There is some debate between the main parties as to whether the identified floorspace standards equally apply to a temporary caravan/dwelling, with the appellant noting that the maximum gross floorspace allowance of 116sqm under Local Plan Policy 3.9 falls below the maximum size of a caravan. In any case, the proposal’s internal floor area would still measure 116 sqm. 68. The appellant has indicated that this size was sought, to provide a comfortable level of living accommodation, whilst being mindful that if any trial period was successful, the proposal may need to be used on a more permanent basis. Given the nature of the enterprise’s operations I also consider it would be https://www.gov.uk/planning-inspectorate 10

Combehead Farm, Bridford, Exeter, Devon, EX6 7LQ — Dartmoor — Appeal Decision Appeal Decision APP/J9497/W/23/3333517 reasonable to include a small on-site office. Accordingly, the proposal’s internal floorspace would align with the 116sqm size restriction detailed under Local Plan Policy 3.9 and the Housing SPD. 69. I appreciate that this level of floorspace is set out as a maximum threshold in both the relevant policy and guidance, nonetheless, the proposed dwelling’s floorspace does not appear to be excessive for the likely needs of the occupiers or the running of the enterprise, nor do I consider that its size would jeopardise the future affordability of the farm holding. Conclusion on whether the agricultural enterprise justifies the proposed temporary dwelling 70. Bringing all of the above matters together, and having regard to local and national policies that seek to avoid isolated new homes in the countryside, I find that the agricultural enterprise justifies the proposed temporary dwelling.

Combehead Farm, Bridford, Exeter, Devon, EX6 7LQ — Dartmoor — Appeal Decision Accordingly, in respect of this main issue, the proposal complies with Local Plan Policies SP1.1, SP1.2, SP1.3, SP3.1 and P3.9, in so far as these policies set out the spatial strategy for housing and sustainable development, including the provision of temporary workers dwellings, within the National Park. 71. In respect of this main issue, the proposal would also comply with Paragraph 84 of the Framework, as well as the advice of the Circular in relation to fostering and maintaining thriving rural communities. Foul and Surface Water Drainage 72. The proposed development would be located within close proximity to an existing watercourse, as well as woodland. Potential therefore exists for any polluted waters to find a pathway and cause harm to these features, should the proposed development not be served by adequate drainage systems. 73. In respect of foul water drainage, the appellant has provided manufacturers details that illustrate unit sizes for package sewage treatment plants and provide an overview of how such systems dispose of foul effluence. No specific details of the precise plant or its proposed siting have been provided.

Combehead Farm, Bridford, Exeter, Devon, EX6 7LQ — Dartmoor — Appeal Decision Nor do I have any detailed drainage report or appropriate information before me to verify that the proposed use of a package sewage treatment system would be effective or suitable at the appeal site. 74. Despite the appeal site’s location within Flood Zone 1, I have no specific details of the surface water drainage conditions at the site, or the likely size and location of proposed soakaways. As such, I cannot be sure that their proposed use would be successful in minimising surface water flood risk or avoiding pollution of groundwater or watercourses. 75. At the hearing the appellant indicated that the existing agricultural building has been served by a soakaway for a considerable period, whilst a sewage package treatment system is already in use in association with its unauthorised occupation as a dwelling. However, I have no detailed evidence to verify the precise arrangements, or that they have been working effectively and that flood risk on the property is minimised, or that soil and water quality are not being harmed. 76. The Authority has agreed to suggested draft conditions with the appellant as part of the Statement of Common Ground, including pre-commencement https://www.gov.uk/planning-inspectorate 11

Combehead Farm, Bridford, Exeter, Devon, EX6 7LQ — Dartmoor — Appeal Decision Appeal Decision APP/J9497/W/23/3333517 conditions in relation to the approval and subsequent installation of foul and surface water drainage systems. However, suggested conditions have only been agreed in the event of the appeal being allowed and without prejudice to the Authority’s case. 77. I must be satisfied that foul and surface water drainage to serve the proposed development is feasible and acceptable. There is however a severe lack of information before me as to existing drainage conditions on site and the potential related implications. Furthermore, whilst it may be appropriate to condition the precise detailed design of the drainage systems, the onus remains on the appellant to demonstrate that the proposals will work in principle. 78. Due to the lack of adequate information before me, I am not satisfied that the appeal scheme could be served by suitable foul or surface water drainage systems, which would minimise flood risk or the pollution of watercourses. Nor would it be appropriate in this instance to condition these matters. The appeal scheme therefore conflicts with Local Plan Policies SP1.1, SP2.1 and SP2.5.

Combehead Farm, Bridford, Exeter, Devon, EX6 7LQ — Dartmoor — Appeal Decision Together the policies, amongst other matters, seek to protect the National Park’s special qualities, including its water environment, whilst also seeking to reduce flood risk and promote the use of sustainable drainage systems. 79. The proposal would also conflict with the relevant provisions of Section 14 of the Framework and also the Circular in terms of protecting soils and waterways. Biodiversity 80. The Authority’s Ecology Officer has previously identified the need for ecological enhancements to be provided on site that arise in association with the proposed temporary dwelling and agricultural building. 81. During the appeal proceedings both main parties agreed that the relevant provision of biodiversity enhancements could be provided at the site and that this could be appropriately secured via a suitably worded planning condition on the grant of a permission for the proposed new works. From the evidence before me, I have no reason to reach an alternative view. 82. In respect of this main issue, subject to a relevant condition being imposed on a grant of planning permission for the temporary dwelling and agricultural building, I am satisfied that the appeal scheme would accord with Policies SP1.1, SP1.2 and SP2.3.

Combehead Farm, Bridford, Exeter, Devon, EX6 7LQ — Dartmoor — Appeal Decision Together amongst other matters these policies seek to conserve and enhance the natural environment. Other Matters 83. The proposed development would provide socio-economic benefits associated with the delivery of the proposed new development, albeit these are likely to be modest in nature and do not overcome my above concerns. I am also not convinced that benefits of a similar scale could not be delivered through a more appropriately designed scheme. Conditions 84. The permission relates to the existing pond only. As the pond permitted has already been installed at the site, it is not necessary for me to attach conditions https://www.gov.uk/planning-inspectorate 12

Combehead Farm, Bridford, Exeter, Devon, EX6 7LQ — Dartmoor — Appeal Decision Together amongst other matters these policies seek to conserve and enhance the natural environment. Other Matters 83. The proposed development would provide socio-economic benefits associated with the delivery of the proposed new development, albeit these are likely to be modest in nature and do not overcome my above concerns. I am also not convinced that benefits of a similar scale could not be delivered through a more appropriately designed scheme. Conditions 84. The permission relates to the existing pond only. As the pond permitted has already been installed at the site, it is not necessary for me to attach conditions https://www.gov.uk/planning-inspectorate 12

Combehead Farm, Bridford, Exeter, Devon, EX6 7LQ — Dartmoor — Appeal Decision Appeal Decision APP/J9497/W/23/3333517 requiring that development is commenced within a specified timescale or that it be constructed in accordance with approved plans/drawings. However, for the avoidance of doubt, I have attached a condition that clarifies the pond to which the permission relates. Conclusion 85. For the reasons given above, and having regard to all other matters raised, I conclude that the appeal should be allowed insofar as it relates to the existing pond installed at the site, but dismissed insofar as it relates to the remaining elements of the appeal scheme.

Combehead Farm, Bridford, Exeter, Devon, EX6 7LQ — Dartmoor — Lewis Condé INSPECTOR https://www.gov.uk/planning-inspectorate 13 Appeal Decision APP/J9497/W/23/3333517 APPEARANCES FOR THE APPELLANT: Mr B. Denison (Appellant) Mr M. Willis (Willis & Co Chartered Town Planners, Planning Agent) Mr C. Popkin (Willis & Co Chartered Town Planners, Planning Agent) Mr P. Williams (Reading Agricultural Consultants) FOR THE LOCAL PLANNING AUTHORITY: Ms J. Rumble (Dartmoor National Park Authority) Mr D. Meek (South West Norse Limited) PLANS 1. Coombehead Farm Constraints (created 28/2/2024) DOCUMENTS 1. A Landscape Character Assessment for Dartmoor National Park (April 2017) https://www.gov.uk/planning-inspectorate 14