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West Wight Alpacas land accessed off Main Road Wellow Yarmouth Isle Of Wight PO41 Continued siting of caravan for use as agricultural workers dwelling TCP/30601/L, P/00608/14 I object to this application for reasons including but not limited to: a) Validity This Planning Application is invalid because there is no material difference between it and Mr Payne's previous application TCP/30601/J, P/01784/12 which was refused in Nov 2013 by the Planning Inspector. This application is actually only an appeal against the appeal which should, by law, according to the Planning Inspectorate, have been made through the court, not the LPA. b) Need There is no need for an agricultural worker to reside on-site. This was the finding of the Planning Inspector, and the view of the LPA, and nothing has changed since then. c) Sustainability The sustainability of the business is highly uncertain. The owners have continued to put money into the business and now they have started to sell land (£40,000) to put back into the business, suggesting a worsening of the business. They are still not paying sustainable living wages to any workers, according to the application. Further large expenses and operational cost are likely to fall on the business later this year as a result of d) below. d) Change in legal and regulatory environment DEFRA and HSE requirements are likely to require considerable expenditure simply to comply with regulations. By the Autumn, DEFRA expect to introduce new testing for bovine tuberculosis (bTB) and other procedures which have not been budgeted for. bTB in alpacas and llamas is becoming an increasingly worrying issue, both for human and animal health. Controls are expected to be introduced by the Autumn 2014, according to DEFRA. If animal-movement restrictions are brought-in the entire business model may become obsolete and it is hard to see how the business could continue in its dual agricultural and tourism niche. When I spoke to DEFRA on 26 th June 2014 they told me that the consultation period had ended and that while the British Alpaca Society (BAS) are still lobbying DEFRA the outcome is not certain to go in BAS's favour. This might also reduce the worth of alpacas in the UK market generally, reducing the capital base of West Wight Alpacas. The Government has a long-term commitment to make the whole of England an Officially Bovine Tuberculosis Free Status zone and a Strategy document was issued in April 2014 In parallel, there has been a “Consultation on tuberculosis (TB) animal disease controls for deer and camelids” which closed on 6 th May. The H&S requirements as laid down in various government documents suggest that considerable works will be required to make the alpaca farm H&S compliant particularly but not exclusively to reduce the risk of E.coli 0157 and a repeat of the 'Godstone' incident. I have worked on a fuller report however I have received correspondence from Mr and Mrs Payne's solicitors and I need to seek some advice before presenting a full case against the application. I have discussed this with the Case Officer and it has been agreed that my full submission will be made at a later time after further discussions with the LPA. For this reason, my submission at this

David-brief Comments Submission Stage 1

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West Wight Alpacas land accessed off Main Road Wellow Yarmouth Isle Of Wight PO41

Continued siting of caravan for use as agricultural workers dwelling

TCP/30601/L, P/00608/14

I object to this application for reasons including but not limited to:

a) Validity This Planning Application is invalid because there is no material difference between it and Mr Payne's previous application TCP/30601/J, P/01784/12 which was refused in Nov 2013 by the Planning Inspector. This application is actually only an appeal against the appeal which should, by law, according to the Planning Inspectorate, have been made through the court, not the LPA.

b) Need There is no need for an agricultural worker to reside on-site. This was the finding of the Planning Inspector, and the view of the LPA, and nothing has changed since then.

c) Sustainability The sustainability of the business is highly uncertain. The owners have continued to put money into the business and now they have started to sell land (£40,000) to put back into the business, suggesting a worsening of the business. They are still not paying sustainable living wages to any workers, according to the application. Further large expenses and operational cost are likely to fall on the business later this year as a result of d) below.

d) Change in legal and regulatory environment DEFRA and HSE requirements are likely to require considerable expenditure simply to comply with regulations.

By the Autumn, DEFRA expect to introduce new testing for bovine tuberculosis (bTB) and other procedures which have not been budgeted for. bTB in alpacas and llamas is becoming an increasingly worrying issue, both for human and animal health. Controls are expected to be introduced by the Autumn 2014, according to DEFRA.

If animal-movement restrictions are brought-in the entire business model may become obsolete and it is hard to see how the business could continue in its dual agricultural and tourism niche. When I spoke to DEFRA on 26th June 2014 they told me that the consultation period had ended and that while the British Alpaca Society (BAS) are still lobbying DEFRA the outcome is not certain to go in BAS's favour. This might also reduce the worth of alpacas in the UK market generally, reducing the capital base of West Wight Alpacas.

The Government has a long-term commitment to make the whole of England an Officially Bovine Tuberculosis Free Status zone and a Strategy document was issued in April 2014

In parallel, there has been a “Consultation on tuberculosis (TB) animal disease controls for deer andcamelids” which closed on 6th May.

The H&S requirements as laid down in various government documents suggest that considerable works will be required to make the alpaca farm H&S compliant particularly but not exclusively to reduce the risk of E.coli 0157 and a repeat of the 'Godstone' incident.

I have worked on a fuller report however I have received correspondence from Mr and Mrs Payne's solicitors and I need to seek some advice before presenting a full case against the application. I have discussed this with the Case Officer and it has been agreed that my full submission will be made at a later time after further discussions with the LPA. For this reason, my submission at this

Page 2: David-brief Comments Submission Stage 1

time before the cut-off date of 27th June is not complete or supported with the documentation that will follow.