Kiln House Kilnhouse Lane, Tunstall, HULL, HU12 0JH

Kiln House Kilnhouse Lane, Tunstall, HULL, HU12 0JH — East Riding of Yorkshire Council — Appeal Decision Hearing held on 23 April 2025 Site visit made on 23 April 2025 by A J Sutton BA (Hons) DipTP MRTPI an Inspector appointed by the Secretary of State Decision date: 9 June 2025 Appeal Ref: APP/E2001/W/24/3358128 Kiln House, Kilnhouse Lane, Tunstall, East Riding of Yorkshire HU12 0JH • 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 IAPS Ltd against the decision of East Riding of Yorkshire Council. • The application Ref is 23/00864/PLF. • The development proposed is change of use of land for the siting of 60 lodge style caravans for holiday use with ancillary works. Decision 1. The appeal is dismissed. Procedural Matter 2. The East Riding Local Plan Update 2025 – 2039 Strategy Document (Local Plan 2025 – 2039) was adopted during the appeal process. Policies of this recently adopted plan replace those stated on the Council’s original decision notice. The main parties had an opportunity to make written submissions on this matter and to discuss this at the hearing. The submissions and comments are addressed below. Main Issue 3.

Kiln House Kilnhouse Lane, Tunstall, HULL, HU12 0JH — East Riding of Yorkshire Council — Appeal Decision The main issue is the effect of the proposal on the character and appearance of the landscape and the setting of Tunstall. Reasons 4. The appeal site is a parcel of agricultural land comprising predominately semi improved grass land which is bounded by mature hedges. The site is in National Landscape Area (NCA) 40, and the qualities of this character area are defined as low lying, broad undulating plains, which includes long stretches of rapidly eroding soft cliffs. I saw this pattern of erosion close to the site at the end of Seaside Lane. 5. As highlighted in the appellant’s Landscape and Visual Assessment prepared by H2 (LVA) the NCA provides a broad assessment, and the East Riding of Yorkshire Landscape Character Assessment 2018 (ERY LCA) builds on this to identify more refined local character types. The ERY LCA shows the appeal site in Coastal Farmland LCT20, and the subsect of this landscape type, LCA20B. The identified characteristics of this landscape character area that appear evident in this location include flat to gently undulating land, clay cliffs eroding into the sea, limited tree cover due to exposed windswept coastal landscape, small villages and https://www.gov.uk/planning-inspectorate

Kiln House Kilnhouse Lane, Tunstall, HULL, HU12 0JH — East Riding of Yorkshire Council — Appeal Decision Appeal Decision APP/E2001/W/24/3358128 farmsteads, minor roads threatened by erosion and fragments of historic field pattern around villages and hamlets. 6. The ERY LCA indicates that hedgerows in this character area tend to be fragmented. However, the northern hedge boundary of the appeal site, along Seaside Lane, is a considerable length with no significant gaps. This existing hedge is described in the appellant’s LVA as species poor. While the hedge is made up of a limited number of species, those present appear native. Moreover, I saw that one of the most notable features of this boundary treatment is its shape, resulting from the environment in which it situated. Indeed, although its unbroken length may be unusual in this character area, this distinctly weathered green feature appears particularly appropriate in this coastal setting and for this reason it contributes positively to the coastal farming landscape east of the small settlement of Tunstall. 7. There are old farm buildings with hardstanding on the appeal site, but these are grouped at the existing site access on Kilnhouse Lane.

Kiln House Kilnhouse Lane, Tunstall, HULL, HU12 0JH — East Riding of Yorkshire Council — Appeal Decision These structures are largely screened by hedges such that only glimpses of roofs can be seen when approaching the site from the wider area and when viewed from the village. I observed that their traditional agricultural forms, even in a poor state of repair appeared generally in keeping with the prevailing rural aesthetic and do not seem particularly detracting feature when seen as part of this wider landscape. 8. The ERY LCA states that other prominent features and land uses in this landscape character area include tourism development and large scale turbine development. However, while there are turbines off this part of the coastline, these features are generally observed in distant views as a wider backdrop to this coastal location. The onshore examples are located some distance to the south and west and therefore are not a harmfully dominating feature near the appeal site and its immediate surrounds. The matter of existing tourist development is addressed below. 9. In keeping with the landscape characteristics described above, the appeal site is a short distance from the edge of Tunstall.

Kiln House Kilnhouse Lane, Tunstall, HULL, HU12 0JH — East Riding of Yorkshire Council — Appeal Decision As relatively undeveloped farmland I saw that the site forms part of the field pattern that sweeps from the east edge of Tunstall to the coast. Development immediately beyond this settlement is largely limited to a scattering of dwellings, a couple of individual park homes and farm buildings on Kilnhouse Lane and Seaside Lane. 10. The appellant asserts that there is already a range of detracting features in this area in addition to wind turbines. This includes large modern agricultural buildings. However, these are generally visible on the western side of Tunstall, so those features do not harmfully interfere with the setting of the village or significantly influence the character of the landscape to the east of the settlement, near the appeal site. Also, although there is some farm equipment, containers and other clutter at surrounding properties, these items are largely evident towards the end of Seaside Lane beyond the appeal site, such that they are not particularly intrusive features, visually, in the relatively undeveloped belt of arable and pastureland east of Tunstall. 11.

Kiln House Kilnhouse Lane, Tunstall, HULL, HU12 0JH — East Riding of Yorkshire Council — Appeal Decision Turning to the settlement, Tunstall is a collection of dwellings and agricultural buildings, generally arranged in a linear pattern, along Main Street. This settlement has been developed on a ridge. With a slightly perched position, the village is a https://www.gov.uk/planning-inspectorate 2

Kiln House Kilnhouse Lane, Tunstall, HULL, HU12 0JH — East Riding of Yorkshire Council — Appeal Decision Turning to the settlement, Tunstall is a collection of dwellings and agricultural buildings, generally arranged in a linear pattern, along Main Street. This settlement has been developed on a ridge. With a slightly perched position, the village is a https://www.gov.uk/planning-inspectorate 2

Kiln House Kilnhouse Lane, Tunstall, HULL, HU12 0JH — East Riding of Yorkshire Council — Appeal Decision Appeal Decision APP/E2001/W/24/3358128 distinct feature that, as evidenced in the appellant’s LVA, can be readily observed from footpaths that cross surrounding agricultural land and from nearby rural roads. 12. Most of this settlement is designated a conservation area (CA), and the core of this well preserved historic settlement, is the Grade I listed Church of All Saints, originating from the 13th Century. This cobble faced and dressed stone form is a distinct historic focal point of the village, and the church yard serves as a good place to appreciate the informal layout of the village and its edge of coast setting. Other historic buildings contributing to the significance of this designated heritage asset include similarly traditional cobble clad properties, including farm buildings. 13. There are five Grade II listed buildings in the CA, again focused on Main Street. These include close to the church, Manor Farmhouse, an 18th Century cobble dwelling and a Barn to the south of this also demonstrating this local vernacular. Hall Farmhouse, an 18th Century Flemish bond brick property and the cobbled Town Farmhouse are located opposite these designated assets.

Kiln House Kilnhouse Lane, Tunstall, HULL, HU12 0JH — East Riding of Yorkshire Council — Appeal Decision Also, near to these buildings is a 1930s K4 kiosk which has been relocated in the village as a result of coastal erosion effecting its original location. 14. Regarding the setting of the CA, the appellant draws attention to Tunstall Conservation Area Appraisal 2007, which states that the boundaries of the CA have been designed to include the whole village’s historic core and its setting. While not seeking to challenge this, I am mindful that the National Planning Policy Framework (the Framework) defines settings as surroundings in which the heritage asset is experienced…its extent is not fixed and may change as the asset and its surroundings evolve. 15. In respect of the setting, I observed that the relatively undeveloped parcels of land on the east side of Tunstall allows the appreciation of this historic rural settlement on the ridge. Also, when in the settlement, the landscape to the east of the village, which includes the appeal site, positively contributes to how the significance and historic interest of the CA is experienced, particularly when standing in or near the church yard and looking out over the wider rural coastal setting. 16.

Kiln House Kilnhouse Lane, Tunstall, HULL, HU12 0JH — East Riding of Yorkshire Council — Appeal Decision Addressing the presence of tourist development in this area, the sizable Sand-le- Mere holiday park and the smaller Holderness Country Park are south of the village. However surrounding fields close to the village, including the appeal site, provide a good degree of visual separation such that that existing tourist development does not harmfully encroach on the predominately agricultural and sparsely developed wider setting east of this historic settlement. 17. S72(1) of the Planning (Listed Buildings and Conservation Areas) Act 1990 requires when determining proposals in conservation areas that special attention shall be paid to the desirability of preserving or enhancing the character or appearance of that area. The Framework requires when considering the impact of proposed development on the significance of a designated heritage asset, great weight should be given to the asset’s conservation. 18. The appellant’s Landscape and Visual Statement of Case (LVSC) describes the development as small However, it was agreed by the main parties at the hearing that the scheme would be a medium scale development. The site is over 5 ha, and the development would comprise 60 two bedroom lodges, each with separate living space.

Kiln House Kilnhouse Lane, Tunstall, HULL, HU12 0JH — East Riding of Yorkshire Council — Appeal Decision The site would also include internal roads and wastewater treatment https://www.gov.uk/planning-inspectorate 3

Kiln House Kilnhouse Lane, Tunstall, HULL, HU12 0JH — East Riding of Yorkshire Council — Appeal Decision The site would also include internal roads and wastewater treatment https://www.gov.uk/planning-inspectorate 3 Appeal Decision APP/E2001/W/24/3358128 infrastructure. While appreciating that this number of units would be less than existing holiday parks to the south, it seems to me that such a scale of development is sizeable and could not be considered small. 19. The proposed site layout shows space around the lodges and a relatively undeveloped amenity area on the corner nearest to Tunstall. There would also be two ponds within the site. However, even with this retained space, much of the existing fields in the appeal site would be covered by structures under this scheme. The height of the lodges would not exceed that advised for new buildings in the CA Appraisal. Be this as it may, with this concentration of lodges, along with internal roads and other built features, the existing pastureland at the appeal site would be substantially lost, and its current contribution to the qualities of this landscape, in particular being seen as part of a continuum of relatively undeveloped land, would be considerably diminished. 20.

Kiln House Kilnhouse Lane, Tunstall, HULL, HU12 0JH — East Riding of Yorkshire Council — Appeal Decision Also, as a sizeable holiday park, the activities that would likely arise on the site, such as the toing and froing of cars and visitor recreational activities in the site, would be distinctly different from agricultural activities such that the nature of use and appearance of the site would be considerably changed by this proposal. Affecting a 5 hectare parcel of land, this harmful visual change would amount to a significant erosion of the swathe of existing agricultural land east of Tunstall. 21. A new access to the holiday accommodation would be created roughly midway along the site boundary on Seaside Lane. There is conflicting evidence as to whether the existing hedge line on Seaside Lane would have to be removed and replaced further back in the site for highway safety, with the appellant’s LVSC suggesting that approximately 140m of hedgerow would need to be removed for visibility splays. This conflict aside, the submitted information indicates that at least a 6m gap would have to be made in this existing positive landscape feature in order to create the new site access. 22.

Kiln House Kilnhouse Lane, Tunstall, HULL, HU12 0JH — East Riding of Yorkshire Council — Appeal Decision While fragmented hedges may be a feature in the wider area, such a large gap would significantly diminish the visual quality of this existing strong native hedge line. The proposed Landscape Strategy recommendations suggests that existing boundary hedgerows would be enhanced and the submitted Landscape Masterplan shows a hedge boundary either side of the new access. Be this as it may, a new significant gap would be created, and not only would this be visually harmful to the appearance of the existing hedge in this landscape, but this would allow views of the development, and, in turn of the harmful changes in the character of the site. 23. The Landscape Strategy also recommends a 10m width of landscaping from the boundaries, creation of some woodland and the planting of native species and areas of wildflowers. Choice of materials and colours are offered for the external finish of the lodges and lighting controls are suggested. These are all matters which could be secured by condition. The Council is concerned that the proposed landscaping scheme, including the potential removal and reinstatement of the hedge on the northern boundary would be difficult to establish in this harsh, exposed coastal environment.

Kiln House Kilnhouse Lane, Tunstall, HULL, HU12 0JH — East Riding of Yorkshire Council — Appeal Decision This aside, the evidence suggest that the proposed soft landscaping would take around 8 – 9 years to mature and there may be a need for some assessment of residual effects after that timeframe. Again, this could be secured by condition. https://www.gov.uk/planning-inspectorate 4

Kiln House Kilnhouse Lane, Tunstall, HULL, HU12 0JH — East Riding of Yorkshire Council — Appeal Decision This aside, the evidence suggest that the proposed soft landscaping would take around 8 – 9 years to mature and there may be a need for some assessment of residual effects after that timeframe. Again, this could be secured by condition. https://www.gov.uk/planning-inspectorate 4

Kiln House Kilnhouse Lane, Tunstall, HULL, HU12 0JH — East Riding of Yorkshire Council — Appeal Decision Appeal Decision APP/E2001/W/24/3358128 24. However, under this proposal, this visually detracting form of tourist development would be brought considerably closer to the edge of the village than is currently the case. Planting in the region of 325 m hedge at the eastern boundary would not address the harm arising at the north and west of the site. Moreover, even with the proposed measures outlined above, with a 6 m high hedge on the north and west of the site, and supplementing hedges with more varied species, as evidenced in images of viewpoints 22 and 23 in the appellant’s LVA, the development would still significantly encroach into the landscape when looking from the Church yard and the seat on the grass verge in the centre of Tunstall. 25. The appellant’s LVSC suggests that trees would form part of the Landscape Strategy. Even if these could establish in these challenging coastal conditions, in a character area largely devoid of trees, these new green features would mark the site as distinctly different in this part of the landscape, drawing attention to the concentration of development at this locale. This would significantly temper any benefit in respect of this proposed mitigation.

Kiln House Kilnhouse Lane, Tunstall, HULL, HU12 0JH — East Riding of Yorkshire Council — Appeal Decision Moreover, I am not convinced that trees could screen the mass of lodges that would be clearly apparent from the elevated sensitive viewpoints at the centre of the CA, near the Church. 26. With reference to public paths, while it is stated that they are limited in the area, the submitted evidence shows a significant network of local paths which include ROOSF09 and 10, close to the east and north edges of Tunstall with access from Seaside Lane. These paths allow walkers to reach the coast over relatively open agricultural land with views of the village. The northern boundary of the appeal site, on Seaside Lane, is seen as a continuation of agricultural land in this expansive landscape from these paths. Moreover, as the ground rises at these footpaths, the fields comprising the appeal site are also clearly apparent. Indeed, this observation is reflected in the appellant’s LVA Zone of Theoretical Visibility Plan. 27. The loss of agricultural land and extensive changes in the appeal site would be apparent from the new access on Seaside Lane when approaching along these nearby footpaths.

Kiln House Kilnhouse Lane, Tunstall, HULL, HU12 0JH — East Riding of Yorkshire Council — Appeal Decision Even if the proposed landscaping was to mature in the timeframe anticipated the development would not be ‘self-contained’ when viewed from these important public vantage points. The substantial coverage of development at the appeal site would considerably alter current views from these locations around Tunstall, and the lodges would appear as a harmful dominating feature. 28. Also, the proposed extent of development would adversely alter the current fine balanced between tourist development and farmland in this area. The existing predominately agricultural landscape that provides the wider setting east of Tunstall would be significantly infilled and in turn this would detrimentally alter how the significance and interest in the CA is experienced and appreciated. The proposal would fail to preserve the character or appearance of the CA’s setting in this regard. 29. Despite the appellant’s contentions that the proposal would have a neutral visual effect on the village and some moderate beneficial visual effects close to the site and its surroundings, for these reasons it is my view that the resultant extensive changes to the character of the landscape would be significant and harmful.

Kiln House Kilnhouse Lane, Tunstall, HULL, HU12 0JH — East Riding of Yorkshire Council — Appeal Decision https://www.gov.uk/planning-inspectorate 5

Kiln House Kilnhouse Lane, Tunstall, HULL, HU12 0JH — East Riding of Yorkshire Council — Appeal Decision https://www.gov.uk/planning-inspectorate 5

Kiln House Kilnhouse Lane, Tunstall, HULL, HU12 0JH — East Riding of Yorkshire Council — Appeal Decision Appeal Decision APP/E2001/W/24/3358128 30. The supporting text of Policy EC2 of the Local Plan acknowledges that some tourism developments, including static caravans and holiday lodges may be appropriate in a Countryside location, but in all instances, it will be important that the character of the Countryside is protected and the relationship with nearby settlements is fully considered. The proposal would conflict with this Policy requirement for the reasons stated. 31. The proposal includes the dismantling of farm buildings in the wider appeal site. However, as already indicated even in a poor state of repair these existing structures have a fairly neutral visual impact in this landscape. Even if this was not the case, their removal from the southeast corner of the site would not compensate for the visual harm on the site’s northern boundary. 32. I find nothing before me that would currently prevent the removal of existing hedges at the site, and I note that this proposal provides an opportunity for a management plan to enhance 690m of existing hedgerows. However, while this could be secured by condition, this would not address the harm to the character of this area indicated above.

Kiln House Kilnhouse Lane, Tunstall, HULL, HU12 0JH — East Riding of Yorkshire Council — Appeal Decision Moreover, even if hedges were removed from around the site separate of this proposal, the views would simply change to that of grassland, and the undeveloped qualities of the landscape would largely remain intact. 33. It is suggested that the development would be screened similar to the Sand-le- Mere holiday park, and I am directed to planning permissions for that tourist development and others in the wider area, with regards applying landscaping conditions. However, this proposal would bring this land-use considerably closer to Tunstall than the existing holiday parks highlighted. The visual harm on Tunstall and this local landscape would be greater than is the case with those existing developments, and conditions could not resolve this significant harm. 34. A condition for a restoration scheme has been suggested. However, this is intended to address the part of the site which may be at risk from coastal erosion in the long term. In any event, there is no suggestion that this development is a short term temporary use of the land.

Kiln House Kilnhouse Lane, Tunstall, HULL, HU12 0JH — East Riding of Yorkshire Council — Appeal Decision As such, a condition addressing another matter, that may occur in the long term on part of the site, would not suitably mitigate the harm to the landscape that forms part of the wider setting of the historic settlement of Tunstall. 35. At the hearing the appellant highlighted that the site could host up to 50 pitches for camping and caravans for a duration of up to 60 days. Limited details were provided regarding this matter. This aside, even if I accept this as a fallback position, the use of the site for a limited part of the year is distinctly different, in terms of appearance, than a scheme that would see the long term citing of 60 lodges on the site, with all the associated infrastructure that would support the development. This matter attracts very limited weight accordingly. 36. Reference is made to permission for static caravans on open countryside sites at Cowden and Low Skirlington. However, those sites are close to Hornsea, a considerable distance to the north of this appeal site. The circumstances are therefore not directly comparable to this proposal. 37. I am also directed to an appeal decision for a proposal at Allerthorpe Golf Course.

Kiln House Kilnhouse Lane, Tunstall, HULL, HU12 0JH — East Riding of Yorkshire Council — Appeal Decision However, that site is some distance in land from the appeal, and in a different landscape character area. With regards the appeal decisions at Roos, this was for https://www.gov.uk/planning-inspectorate 6

Kiln House Kilnhouse Lane, Tunstall, HULL, HU12 0JH — East Riding of Yorkshire Council — Appeal Decision However, that site is some distance in land from the appeal, and in a different landscape character area. With regards the appeal decisions at Roos, this was for https://www.gov.uk/planning-inspectorate 6

Kiln House Kilnhouse Lane, Tunstall, HULL, HU12 0JH — East Riding of Yorkshire Council — Appeal Decision Appeal Decision APP/E2001/W/24/3358128 18 residential units, so a considerably smaller magnitude of development than proposed in this case. Also, that plot of land, although agricultural and close to a settlement which is designated as a conservation area, is immediately adjacent to the settlement edge as opposed to forming an important and sensitive part of the wider landscape. Those cases are distinctly different in those regards and not directly comparable to this proposal. Those appeal decisions attract limited weight and have not altered my findings for these reasons. 38. In summary on this matter, the proposal would substantially alter the character of the appeal site, and this would significantly erode positive landscape features that form the wider setting of the Tunstall CA. These visually harmful changes would significantly diminish how the significance of this designated heritage asset is appreciated and experienced; the character or appearance of the CA’s wider setting would not be preserved under this proposal. 39.

Kiln House Kilnhouse Lane, Tunstall, HULL, HU12 0JH — East Riding of Yorkshire Council — Appeal Decision The Framework clarifies where the development proposed will lead to less than substantial harm to the significance of the designated heritage asset, this harm should be weighed against the public benefits of the proposal. 40. The Local Plan Update 2025- 2039 acknowledges the importance of tourist development to the local economy, highlighting that a priority of the Economic Development Strategy is to support growth in the tourism sector. The written evidence suggests that up to 16 direct and indirect jobs would be supported by this development. It was confirmed at the hearing that there would be around 6 direct full time jobs created. This would be a moderate, albeit significant public benefit. 41. With regard other economic benefits, I am directed to UK Caravan and Camping Alliance 2019 Economic Benefits Report and its updated report 2024. The figures (and benefits) in these reports cover England as a whole. However, it is reasonable to conclude that as a moderate holiday home development there would be some wider economic benefit to this national business sector, most notably static caravan industry. 42.

Kiln House Kilnhouse Lane, Tunstall, HULL, HU12 0JH — East Riding of Yorkshire Council — Appeal Decision The appellant provides an assessment of potential on-site and off-site visitor expenditure, referencing Pitching the Value 2024. It is estimated with the pitches proposed, this development could generate economic benefits in the region of £1.3m per annum. Also, although it is likely that future holiday makers may bring their own food, it seems to me at least some future users of the site would venture out and support local services. There cumulative economic benefits could be considerable. 43. However, I find no compelling evidence that this harmful development would be the only means of securing this level of economic benefit in this wider east coast location. Also, while tourism is an important contributor to the local economy, tourists are drawn by attractions which can include historic settlements and valued landscapes such as that evident at and around Tunstall. As outlined this development would harmfully alter valued features and assets in and close to the appeal site, and in turn this would diminish their appeal as tourist attractions. These factors counter against the benefits that the proposal may bring to the tourist economy in this area. This public benefit therefore attracts modest weight at best. 44.

Kiln House Kilnhouse Lane, Tunstall, HULL, HU12 0JH — East Riding of Yorkshire Council — Appeal Decision The appeal site is described as poor quality, improved grassland. The proposed landscaping strategy recommends more varied planting schemes and the creation https://www.gov.uk/planning-inspectorate 7

Kiln House Kilnhouse Lane, Tunstall, HULL, HU12 0JH — East Riding of Yorkshire Council — Appeal Decision The appeal site is described as poor quality, improved grassland. The proposed landscaping strategy recommends more varied planting schemes and the creation https://www.gov.uk/planning-inspectorate 7

Kiln House Kilnhouse Lane, Tunstall, HULL, HU12 0JH — East Riding of Yorkshire Council — Appeal Decision Appeal Decision APP/E2001/W/24/3358128 of different habitats. It is suggested that this would amount to an uplift of over 44% habitat units on the site and this is a matter which could be conditioned. This would be at least a moderate public benefit give the size of the site. 45. There may be visual benefits from the long term management of the wider hedgerow around the site. But this benefit would be considerably countered by the harmful impact of the gap in the existing hedge on Seaside Lane and the significant visual harm that would arise in this landscape and to the wider setting of the CA by the substantial change in character in the site. This matter attracts very limited weight accordingly. 46. It was stated at the hearing that the resultant tourist accommodation would be ‘low key’ such that it would provide a quiet restorative environment on this coastal location. Such social and health benefits would be mainly restricted to those using the site and in turn this would limit this public benefit. 47. There would be some public benefits, but even when considered cumulatively, these benefits would be moderate, and this is not sufficient to outweigh the great weight given to the asset’s conservation.

Kiln House Kilnhouse Lane, Tunstall, HULL, HU12 0JH — East Riding of Yorkshire Council — Appeal Decision The clear and convincing justification for the harm to the significance of the designated heritage asset (from development within its setting) has not been demonstrated in this case. 48. In light of the above I find that the proposal would have a significant harmful effect on the character and appearance of the landscape. Also, for the reasons stated, the proposal would fail to preserve the character or appearance of the wider setting of Tunstall Conservation Area. In this regard the proposal would conflict with Policy S4, EC2, ENV1 and ENV2 of the Local Plan 2025 - 2039. These Policies collectively state that in the Countryside, proposals for tourism development will be supported where their scale, design and cumulative impact is appropriate for the location having particular regard for, amongst other matters, landscape character. 49. The proposal would also fail to accord with provisions of the Framework which seek to conserve the historic environment. Other Matters 50. Regarding policy support for this type of development I am directed to the findings of the East Riding Tourist Accommodation Study (2016).

Kiln House Kilnhouse Lane, Tunstall, HULL, HU12 0JH — East Riding of Yorkshire Council — Appeal Decision Although highlighting that traditional coastal resorts are still an important part of the tourism offer in East Riding, the study found that the overall offering in the area is not sufficiently diversified to attract new types of visitors and therefore the potential benefits of this sector to the economy and community are not being maximised. 51. Taken this finding forward, Policy EC2 of the Local Plan 2025 – 2039 seeks to develop and diversify the visitor economy. While this Policy provides some support for tourist development in the countryside, this is qualified, and is subject to the scale, design and cumulative impact being appropriate for the location. This aim is also reflected in Policy S4 of the Local Plan 2025 – 2039, which requires proposals respect the intrinsic character of their surroundings. This development would fail to respect the local character for the reasons already stated. 52. Also, while Policy A5 of the Local Plan 2025 -2039 provides further support for appropriate expansion and diversification of the key economic sectors in the https://www.gov.uk/planning-inspectorate 8

Kiln House Kilnhouse Lane, Tunstall, HULL, HU12 0JH — East Riding of Yorkshire Council — Appeal Decision Appeal Decision APP/E2001/W/24/3358128 Holderness and Southern Coastal sub area, including tourism, this Policy encourages small-scale serviced, self-catering and hostel accommodation in this area. This is in keeping with the findings of East Riding Tourist Accommodation Study, which summarised in Table 12 of the Local Plan, indicates that the key tourism accommodation for North and South Holderness is new small-scale accommodation enterprises focused on serviced (B & B, Farm and Inns) and self- catering units in the form of farm building conversions, additional camping and touring caravan pitch provision. 53. As already indicated, with 60 units, the proposal would not be a small scale accommodation enterprise. Turning to the type of accommodation proposed, this scheme would not include on-site cafés, bars or shops, and this would differ from some other existing holiday parks in the wider area. Nonetheless, this development would result in a holiday park of static caravan lodges. In this regard it would be very similar to the type of tourist accommodation already on offer at Sand-le-Mere and other holiday parks along this part of the coast.

Kiln House Kilnhouse Lane, Tunstall, HULL, HU12 0JH — East Riding of Yorkshire Council — Appeal Decision Consequently, the development would not particularly diversify tourist accommodation in this locale. The principle of this type of development at the scale proposed in this location would not accord with the aims of these Local Plan Policies. 54. Policy EC4 of the Local Plan 2025 – 2039 seeks, amongst other matters, to increase overall accessibility, stating that new development will be supported where it is accessible, or can be made accessible, by sustainable modes of transport. Addressing this aim and relevant to the development proposed in this case, supporting text of Policy EC2 clarifies that the rural nature of the East Riding means that access to tourism facilities will often be by car. This supporting text goes on to state that [while acknowledging this factor] it will be important that consideration is given to Policy EC4 of the Local Plan 2025-2039 so that visitor destinations are accessible by sustainable modes of transport wherever this is possible. 55. Pertinent to these Local Policy aims and requirements, it was confirmed at the hearing that there is a bus service available at Tunstall, but this is infrequent.

Kiln House Kilnhouse Lane, Tunstall, HULL, HU12 0JH — East Riding of Yorkshire Council — Appeal Decision There are also some limited bus services in the wider area and the network of footpaths provide connections to local villages and the services within them. 56. The appellant asserts that future users would likely stay at the holiday park once they arrive by car. However, I find no certainty that this would be the case. Moreover, while there are some alternatives to using the car once future visitors arrive at the proposed holiday accommodation, this is a distinctly rural location and there are very few facilities at Tunstall and limited services at Roos, the nearest village beyond Tunstall. If future visitors wish to enjoy attractions in the wider area and access a wider range of services, they would be largely dependent on the car given the circumstances described above. 57. Be this as it may, as reflected in the Local Plan text, it seems to me that this is likely to be an issue with many tourist developments along this rural coastline and at least in this case there are some alternatives to using the car. Moreover, a condition requiring a travel plan could encourage those visiting the site in future to use such sustainable transport options. Accordingly, I find no conflict with Policy EC4 in this case.

Kiln House Kilnhouse Lane, Tunstall, HULL, HU12 0JH — East Riding of Yorkshire Council — Appeal Decision However, this factor is not sufficient to outweigh the harm identified to the landscape and wider setting of the heritage asset. https://www.gov.uk/planning-inspectorate 9

Kiln House Kilnhouse Lane, Tunstall, HULL, HU12 0JH — East Riding of Yorkshire Council — Appeal Decision However, this factor is not sufficient to outweigh the harm identified to the landscape and wider setting of the heritage asset. https://www.gov.uk/planning-inspectorate 9

Kiln House Kilnhouse Lane, Tunstall, HULL, HU12 0JH — East Riding of Yorkshire Council — Appeal Decision Appeal Decision APP/E2001/W/24/3358128 58. The Environment Agency (EA) released updated National Coastal Erosion Risk Maps (NCERM2) following the submission of this appeal. The Council confirmed that this up to date information prompts a rapid review of recently adopted Policy ENV6 of the Local Plan Update 2025 – 2039 which designates a Coastal Change Management Area. The timeframe for the process of review is yet to be confirmed. 59. The EA guidance on this matter encourages decisions makers to use the new NCERM2 to inform planning decisions, advising, where an increase in erosion risk has been identified, this may affect the outcome of a planning decision pending approval. This may mean granting permission with extra conditions as to the type, location or lifespan of the development, or refusing permission in areas considered to be at higher risk. 60. The appellant’s evidence concludes that under the revised coastal erosion projections the appeal site is unlikely to be affected by coastal erosion for at least 30 years, yet it will be subject to some degree of impact between 2055 and 2105. A condition is suggested to address this matter.

Kiln House Kilnhouse Lane, Tunstall, HULL, HU12 0JH — East Riding of Yorkshire Council — Appeal Decision While the Council has not raised this issue as a reason for refusing planning permission, nonetheless, given the potential increased risk to the appeal site this matter needs to be addressed. However, as I have found other grounds to dismiss this scheme, it is not necessary to deal with this new issue in this decision. Conclusion 61. For the reasons stated above and having regard to the development plan, and material considerations, including the Framework, the appeal should be dismissed.

Kiln House Kilnhouse Lane, Tunstall, HULL, HU12 0JH — East Riding of Yorkshire Council — A J Sutton INSPECTOR https://www.gov.uk/planning-inspectorate 10 Appeal Decision APP/E2001/W/24/3358128

Kiln House Kilnhouse Lane, Tunstall, HULL, HU12 0JH — East Riding of Yorkshire Council — Participants at Hearing Appellant Miss W Sockett – Planning Consultant Council Mr T Booth-Robinson - Planning Officer Mr B Blackledge - Landscape Consultant Other Interested Parties Cllr McMaster Mrs Midgley - Tunstall Village Hall Group Mr Smales – Local Resident https://www.gov.uk/planning-inspectorate 11 Appeal Decision APP/E2001/W/24/3358128

Kiln House Kilnhouse Lane, Tunstall, HULL, HU12 0JH — East Riding of Yorkshire Council — Additional Submissions Prior to the Hearing Appellant: APP 1 – Comments on the Environment Agency’s National Coastal Erosion Risk Map (NCERM2) released January 2025, and NeFRA2 and NCFRM Q&A - Questions and Answers for Flood Risk Management Authorities Staff on NFRA2 and NCERM, dated March 2011. APP 2 – Additional Commentary on the recently adopted East Riding Local Plan Update 2025 - 2039 Council LPA 1 – Copy of the East Riding Local Plan Update 2025 – 2039 and copy of Tunstall Conservation Area Appraisal. LPA 2 - Comments on the recently adopted East Riding Local Plan Updated 2025 – 2039. During the Hearing Appellant: App 3 – Printed set of A 3 drawings as submitted with original application. App 4 – Printed images from the Landscape and Visual Assessment (H2) submitted with the original application. Following the Hearing Council LPA 3 - Conditions relating to Restoration, Materials, Colours and Travel Plan. LPA 4 - Listed Building Documents Interested Parties IP 1 - Statement from Mrs Midgley - Tunstall Village Hall Group. https://www.gov.uk/planning-inspectorate 12