Land South of Tudor Lodge, Fen Road, HOLBEACH, PE12 8QD

Land South of Tudor Lodge, Fen Road, HOLBEACH, PE12 8QD — South Holland District Council — Appeal Decision Site visit made on 1 July 2025 by F P Tinsley MA (Hons) MBA MRTPI an Inspector appointed by the Secretary of State Decision date: 17 September 2025 Appeal Ref: APP/A2525/W/25/3364588 Land South of Tudor Lodge, Fen Road, HOLBEACH, PE12 8QD • The appeal is made under section 78 of the Town and Country Planning Act 1990 against a refusal to grant outline planning permission. • The appeal is made by Mr L Russell of Seagate Homes against the decision of South Holland District Council. • The application reference is Ref: H09-0813-24 • The development proposed is described as ‘Residential Development’ Decision 1. The appeal is dismissed. Preliminary Matters 2. The applicant has provided a very limited description of the proposed development, as set out in the application form for the proposed development and repeated in the banner heading above. The Local Planning Authority has not expanded on the description of the development in its description of development set out on its decision notice. For clarity, it is clear that the appeal before me seeks outline planning permission for residential development, with all matters reserved except for means of access. I have considered this appeal on that basis. Main Issues 3.

Land South of Tudor Lodge, Fen Road, HOLBEACH, PE12 8QD — South Holland District Council — Appeal Decision The main issues are: • Whether the site is a suitable location for the proposed development with regard to the spatial strategy for the area. • The susceptibility of the proposed development site to flooding and the need to provide a sequential assessment of the proposed development site to establish whether the principle of development is acceptable in terms of flood risk. Reasons Location of the development 4. The appeal site lies outside the defined settlement boundary and is therefore considered to be within open countryside, where development is strictly controlled and only permitted under specific exceptions. While the site plays a limited role in enhancing the setting of the residential development to the north, providing an open paddock area that contributes to the character and appearance of the area as an edge-of-settlement location, I do not consider it to constitute residential https://www.gov.uk/planning-inspectorate

Land South of Tudor Lodge, Fen Road, HOLBEACH, PE12 8QD — South Holland District Council — Appeal Decision Appeal Decision APP/A2525/W/25/3364588 curtilage. It is distinct in character from the residential development to the north and is physically separated by the access road. 5. Policy 1 of the Local Plan sets out a spatial strategy based on a hierarchy of settlements. Within this framework, Holbeach is identified as a ‘Main Service Centre’ a second-tier settlement where development is to be directed, provided it supports the settlement’s role as a service centre, sustains existing facilities, or meets the needs of surrounding communities. In this case, any support offered by the proposal to Holbeach’s role as a service centre is considered negligible, given the small number of units proposed relative to the scale of the wider settlement. 6. Development in the countryside beyond settlement boundaries is constrained, as such locations are generally less sustainable in terms of access to local services. However, the appeal site would be no less accessible to services than many other dwellings in the immediate vicinity, although most of these are located within the settlement boundary.

Land South of Tudor Lodge, Fen Road, HOLBEACH, PE12 8QD — South Holland District Council — Appeal Decision The single dwelling located outside the boundary, approved under reference H09-0950-22, primarily permitted eight dwellings immediately to the north of the appeal site within the boundary. This isolated approval does not, in itself, justify further development in the open countryside. 7. The appeal site’s southern boundary, marked by a mature and substantial hedgerow, forms a physical edge to the more open countryside to the south. The appellant considers this feature to represents an effective settlement boundary. However, the Local Plan clearly defined the settlement boundary, which excludes the appeal site and its hedgerow. In addition, I am conscious that hedging and similar boundary features may change with the passage of time and cannot be relied upon to remain a defining landscape feature in perpetuity. I therefore attach only limited weight to this consideration. 8. The proposed development is in clear conflict with Policy 1 of the Local Plan, as it lies outside the defined settlement boundary.

Land South of Tudor Lodge, Fen Road, HOLBEACH, PE12 8QD — South Holland District Council — Appeal Decision Although its proximity to the settlement edge, the enclosing effect of existing vegetation and surrounding development, and the designation of Holbeach as a location suitable for directed growth may offer some justification, along with limited short-term economic benefits, these factors do not outweigh the fundamental policy conflict. The site is not a suitable location for the proposed development when considered against the spatial strategy of the Local Plan. The proposed development does not fall into any of the Policy 1 exemptions allowing development in the countryside and other material considerations considered above do not indicate that an exemption is justified in this instance. Flood Risk 9. The application site is located within Flood Zone 3 according to Environment Agency mapping; however, it is considered to be in a low-risk area in accordance with the South East Lincolnshire Strategic Flood Risk Assessment (SFRA), both under present-day conditions and future modelled scenarios. 10. Policy 4 of the South East Lincolnshire Local Plan 2019 (the Local Plan) requires that development proposals within Flood Zones 2 and 3 demonstrate that there are no reasonably available sites at a lower risk of flooding.

Land South of Tudor Lodge, Fen Road, HOLBEACH, PE12 8QD — South Holland District Council — Appeal Decision This policy also sets out to pass the Sequential Test, a district-wide search of alternative sites within defined settlement boundaries should be undertaken. There is potential in the policy to justify a smaller search area restricted to a settlement-specific area, reflecting the https://www.gov.uk/planning-inspectorate 2

Land South of Tudor Lodge, Fen Road, HOLBEACH, PE12 8QD — South Holland District Council — Appeal Decision This policy also sets out to pass the Sequential Test, a district-wide search of alternative sites within defined settlement boundaries should be undertaken. There is potential in the policy to justify a smaller search area restricted to a settlement-specific area, reflecting the https://www.gov.uk/planning-inspectorate 2

Land South of Tudor Lodge, Fen Road, HOLBEACH, PE12 8QD — South Holland District Council — Appeal Decision Appeal Decision APP/A2525/W/25/3364588 characteristics of South Holland district, which is predominantly low-lying and particularly prone to flooding. 11. Paragraph 173 of the National Planning Policy Framework (the Framework) states that a sequential, risk-based approach should be applied to individual applications in areas known to be at risk now or in the future from any form of flooding. An exception applies only where a site-specific Flood Risk Assessment (FRA) demonstrates that no built development within the site boundary, including access or escape routes, land raising, or other potentially vulnerable elements would be located in an area at risk of flooding from any source, now and in the future. This scenario and therefore the exception does not apply to the proposal before me. Paragraph 23 of the Planning Practice Guidance (PPG, ID: 7-023-20220825) further clarifies that even where a FRA shows the development can be made safe throughout its lifetime without increasing risk elsewhere, as is the case here, the Sequential Test must still be satisfied. 12.

Land South of Tudor Lodge, Fen Road, HOLBEACH, PE12 8QD — South Holland District Council — Appeal Decision The FRA submitted with the application addresses the requirement to undertake a Sequential Test and concludes that the site is not at risk during the 1% fluvial and 0.5% tidal event. The FRA considers the site to have a low probability of flooding and therefore passes the Sequential Test. However, from the evidence before me no consideration has been given to whether there are other sites within the district or settlement that have a lower flood risk. For this reason, I do not consider that an adequate Sequential Test has been undertaken, regardless of the FRA’s conclusion. In this regard, I note the Council’s statements that there are sites within Flood Zones 1 and 2, including within principal settlements, that it considers could or should have been explored first. 13. In accordance with paragraph 35 of the PPG (ID: 7-035-20220825), as an adequate Sequential Test has not been undertaken an Exception Test should not be undertaken. Therefore, justification of the proposed development on the basis of the Exception Test is not relevant. 14. SFRA Breach Hazard Maps for the Holbeach area have been submitted as part of the appeal documentation.

Land South of Tudor Lodge, Fen Road, HOLBEACH, PE12 8QD — South Holland District Council — Appeal Decision While I accept that areas to the north of Holbeach are at the greatest risk of breach flooding, and that this risk progressively reduces moving south toward the appeal site, it is also noted that there is allocated land to the north of the appeal site which is at a higher risk of breach flooding. The appeal site may represent one of the few locations in the town that is not susceptible to breach flooding. However, this evaluation does not constitute compliance with the Sequential Test, which requires that alternative reasonably available sites be identified and assessed to ensure that development is steered to areas of lowest flood risk. No other individual sites have been considered. 15. In summary, I am not satisfied that the appellant has adequately addressed the requirement to provide a Sequential Test that evaluates potential alternative sites for development, either at a district-wide or settlement-specific level. The proposal therefore fails to comply with the requirements of the Framework, the PPG, and Policy 4 of the Local Plan, all of which require that such a test be undertaken.

Land South of Tudor Lodge, Fen Road, HOLBEACH, PE12 8QD — South Holland District Council — Appeal Decision As such, I am unable to determine whether there are other alternative reasonably available sites at lower flood risk that are sequentially preferable compared to the appeal site. I attach substantial weight to this matter in my determination of the appeal. https://www.gov.uk/planning-inspectorate 3

Land South of Tudor Lodge, Fen Road, HOLBEACH, PE12 8QD — South Holland District Council — Appeal Decision As such, I am unable to determine whether there are other alternative reasonably available sites at lower flood risk that are sequentially preferable compared to the appeal site. I attach substantial weight to this matter in my determination of the appeal. https://www.gov.uk/planning-inspectorate 3

Land South of Tudor Lodge, Fen Road, HOLBEACH, PE12 8QD — South Holland District Council — Appeal Decision Appeal Decision APP/A2525/W/25/3364588 Other Matters 16. I have noted the appellant’s arguments in the submitted appeal statement, including the points made concerning scale and appearance of the proposed development given the site’s context, setting, and surrounding characteristics. However, such matters would be dependent on the detailed design, which falls outside the scope of this outline planning application, where all matters other than access are reserved. Therefore, I give limited weight to these matters, especially as they do not overcome the harm identified in relation to the main issues. Conclusion 17. I have found that the proposal fails to provide a sequential assessment of the development site to determine whether the principle of development is acceptable in terms of flood risk. Additionally, the site is not a suitable location for the proposed development when considered against the spatial strategy for the area. As the proposal conflicts with the development plan as a whole, and the material considerations including those set out in the National Planning Policy Framework do not justify a departure from it, the appeal is dismissed.

Land South of Tudor Lodge, Fen Road, HOLBEACH, PE12 8QD — South Holland District Council — F P Tinsley INSPECTOR https://www.gov.uk/planning-inspectorate 4