Head of Operations - Holiday and Park Homes Direct: [01252 ... · Head of Operations - Holiday and Park Homes Direct: [01252] 796079 . The NCC is the UK trade body for the caravan,

file:///C|/Documents%20and%20Settings/1393196/Desktop/PPS%2016/FW%20NCC%20Response%20to%20PPS16 htm[16/06/2011 11:04:23]

From: Jeremy Morton [mailto:[email protected]] Sent: 25 March 2011 14:30To: Planning, PolicyCc: Alicia DunneSubject: NCC Response to PPS16

Dear Michael Please find attached the NCC response + Annex 4 which needs to be added to the end of the document I would be grateful if you could confirm receipt please Kind Regards

Jeremy MortonHead of Operations - Holiday and Park HomesDirect: [01252] 796079www.thencc.org.uk

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The NCC is the UK trade body for the caravan, motorhome, and caravan holiday and park home industries.

Public Consultation: Draft Planning Policy Statement 16 To: Michael Francey

PPS16 – Tourism – Public Consultation, DOE, Millennium House, 17-25 Great Victoria Street, Belfast BT2 7BNC

From: Alicia Dunne

Deputy Director General Organisation: The NCC, Catherine House, Victoria Road, Aldershot GU11 1SS. Tel: 01252 796079 Email: [email protected] Date: 25th March 2011 The NCC is the trade association representing the collective interests of caravans, motor homes and the holiday and residential park industry. The industry has a turnover approaching £3 billion, employs in excess of 100,000 people and serves over 1 million caravanners and over 250,000 holiday and park home residents. Our members include over 90% of the UK manufacturers of caravans, motor homes and caravan holiday and park homes along with the leading park owners, dealers, and supply and service companies. ___________________________________________________________________________

The NCC welcomes the opportunity to contribute to the Public Consultation on the Draft Planning

Policy Statement 16. In making this response we have consulted with our members in Northern

Ireland drawing on extensive knowledge and experience; from experience in contributing to

other similar consultations in England, Wales and Scotland and from having been involved in the

most recent working group process in Northern Ireland since 2004.

EXECUTIVE SUMMARY The NCC views PPS16 as ‘dictating limiting behaviour from the outset’ (i.e. what a business

or consumer can’t/shouldn’t do). It should be enabling not controlling within structured

guidelines

o PPS16 has no structured guidelines that apply the basic principles of planning policy

and encourage all parties to work to facilitate (re)developments in a sustainable way

The basis for PPS16 – development plans and restrictive guidelines - is undermined by the

draft PPS24 which clearly echoes our request for flexible, responsible and sustainable

planning guidance:

N. Ireland PPS16 Public Consultation 03.2011

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mailto:[email protected]


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o Imposing restrictions from the outset suggests that caravan holiday parks and touring

caravan sites, when compared against other accommodation options, are not capable

or are being denied the opportunity of being developed within the original stated

primary and key objectives of PPS16

The emphasis has moved to considering physical limits and sustainable development issues

only and does not provide clear and enabling guidance on delivering the environmental

and local economic aspects as well – PPS24 see (9).

o The PPS16 requirements for TSM6 and 7 neither meet the future needs of this sector of

the tourism industry nor do they provide opportunities for continued growth and

development

The NCC endorses ‘responsible sustainability’. We are not encouraging development at all

costs, but in a sustainable manner that works for everyone

o To achieve its potential the caravan sector should be able to secure planning permission

without undue delays and difficulties but with appropriate limitations/restrictions and

guidance in place.

It is time to be imaginative not restrictive, not the time to reduce the revenue of those that

want to invest in new sites and (re)develop their existing site and their future.

o The Development plan process is unworkable and is not fit for purpose. PPS24 clearly

suggests that a more enlightened planning process is adopted. Stating that sites must be

identified in Development plans is unrealistic and impractical. No business person will

wait 10 years for a decision.

The NCC would like to see an overarching and more general national policy framework

with less prescriptive guidelines that allows for regional and local flexibility. A framework

that focuses on minimising undue delays and difficulties and guidance that treats each plan

on its own merits, rather than imposing limitations and restrictions at the outset. Planning

needs ‘wiggle room’ rather than concrete rules. There was certainly broad agreement of

this ‘theme’ at the meeting held by the NITB in February 2011

RECOGNISING THE ECONOMIC BENEFITS OF TOURISM 1) NITB has successfully developed the tourism industry in NI and has ambitious plans for the

future (see Annex 1). In their publication ‘Campaigning for tourism – One Voice. One Team’

NITB recognised the need to unblock those issues which impede the growth and the

competitive position of the industry to achieve their ambitious plans (see Annex 2)


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2) In 2004, The NCC welcomed the proposals set out in the draft PPS16 and the note it struck

that planning would be exercised ‘positively in favour of tourism’ and the encouragement that

would give to urban and local economies who depend on tourism for their livelihood. The

NCC has been fully involved in the PPS16 working group since then and made a full and

comprehensive submission to the draft PPS16 in 02/2009 which outlined the areas that

needed to be addressed and why (see Annex 4).

3) Seven years on, the proposals in the Public Consultation document (PPS16) in relation to Static

Holiday Parks and Touring Caravan Sites in the Countryside (TSM7), do not reflect the

overall stance of the original draft, or the revised RDS Strategy for 2025, reviewed in 2008

(Annex 3). This confirmed the need to support tourism growth and place the emphasis on

sustainable (re)developments that bring economic and social benefits.

4) Caravanning is currently a growing industry making a significant contribution to GDP. Modern

caravanning has also made giant strides towards responsible sustainability.

a) NI Tourism statistics show caravanning and ‘staycations’ are still popular and provide an

affordable alternative in the current climate. NITB Tourism Barometer (12/2010)

indicates that whilst the camping and caravan volume was static, nearly 2/3rds stated

that domestic demand had increased over 2009.

b) NI Tourism currently contributes 4.9% of NI GDP which is on a par with agriculture

c) It is estimated that caravanning contributes 20% (c£96M) of NI’s tourism income of

£480M

d) Whilst the news is positive now, sites need to be able to upgrade facilities and amenities

to respond now before an upturn in the economy. That is likely to lead to more overseas

holidays, so we must keep the holidaymakers who are staying at home when that upturn

comes by providing them with a positive holiday experience.

PPS16 PROPOSALS THREATEN CARAVANNING’S FUTURE

5) NCC submissions made in 2004, 2006 and 2009 supported the (re)development of new

provision and the expansion of holiday parks/static and touring caravan sites in a

sustainable way, that balance local economic and social benefits and the needs of residents.

In the revised PPS16 document the emphasis has moved away from maintaining this balance

to considering physical limits and sustainable development issues only and does not provide

clear and enabling guidance on delivering both the environmental and local economic

aspects – PPS24 see (9).


4

a) Sites are being treated as pariahs, to be hidden away (out of sight and out of mind),

enclosed and in a woodland location. Not allowing site (re)developments close to the

coast or water or to have a decent countryside view - all desirable tourist needs as the

visitor wants to be in a scenic area – ignores tourism’s eco friendly credentials.

b) Imposing restrictions from the outset suggests that holiday parks/static and touring

caravan sites, when compared against other accommodation options, are not capable or

are being denied the opportunity of being developed within the original stated primary

and key objectives of PPS16 which were:

i) To encourage and facilitate the provision of good quality tourism development

ii) To contribute to the growth of the regional and local economy

iii) To promote sustainable tourism

iv) To provide sufficient protection of tourism assets

6) The PPS16 requirements for TSM6 and 7 neither meet the future needs of this sector of the

tourism industry nor do they provide opportunities for continued growth and development. It

is also receiving less favourable treatment than hotels despite the level of innovation in this

sector which offers less impact options and increased sustainability and an increasingly

smaller carbon footprint. Current PPS16 proposals:

a) Do not encourage the (re)development of static and touring holiday parks,

b) Do not treat these (re)developments in a fair and equitable manner when compared with

other options such as hotels (TSM5)

c) Do not meet future needs with regard to sustainable tourism investment

d) Do not account for the changes within our industry that embrace responsible sustainability

and low impact options.

e) Do not set an appropriate, enabling tone. They are too rigid and limiting

f) Do not recognise or appear to understand the value and potential of Tourism to Northern

Ireland given its economic contribution and the growing demand

g) Do not invite entrepreneurship, innovation and discussion. Conversely they stifle new and

existing business owners who should be supported and encouraged.

7) PPS16 has no structured guidelines that apply the basic principles of planning policy and

encourage all parties to work to facilitate (re)developments in a sustainable way.

a) For example, prescriptive guidance limiting size (2 hectares is the minimum for economic

viability) and location is economic suicide and are not normally part of national

guidelines:


5

b) 21st century caravanning requires modern facilities and developments in the industry

backed by consumer demand have led to increases in the size of the home and the

facilities. But this is a forward thinking industry that recognises it has a responsibility to

minimise this impact. There is considerable investment taking place in the UK to redevelop

and upgrade parks but in a sustainable manner and in harmony with the local

environment. Nowadays a site might well have a smaller carbon footprint than a hotel.

8) The NCC views PPS16 as ‘dictating limiting behaviour from the outset’ (i.e. what a business or

consumer can’t/shouldn’t do). It should be enabling not controlling within structured guidelines.

To achieve its potential the caravan sector should be able to secure planning permission

without undue delays and difficulties but with appropriate limitations/restrictions and

guidance in place. Stating that sites must be identified in Development plans is unrealistic and

impractical for the following reasons:

a) Development plans have been a totally unsatisfactory method of identifying locations for

new sites. Some plans took 10/15 years to be developed. Some are not even finalised,

yet in some cases a new round of planning is imminent. No business would be prepared to

wait another 10+ years for a decision to be reached. In short, the process has been

unworkable and is not fit for purpose so the possibility of a plan for a new caravan

holiday home (static) or touring caravan park having been included originally is

extremely remote.

i) In TSM5 it states planning permission will be granted to new hotels, whereas in TSM7

permission for new static holiday parks and touring caravan sites will only be granted

if they had already been identified in the original development plan. In addition

there are restrictions on size as well as location which make investment both

uneconomic and unrealistic. (2 hectares is the minimum)

ii) NITB confirm that “new developments that have been given planning approval in the last

few years have been branded hotels as the major chains were keen to establish a

presence”. The NCC does not consider this to be a positive message to tell struggling

rural economies.

b) Not being able to develop sufficient on-site, self catering accommodation (TSM6) for a

caravan home owner’s non caravanning visitors, also limits viability. More important, is

the need to choose between developing either a site’s amenities and facilities (TSM7) or

self catering accommodation (TSM6) as PPS16 restrictions make it doubtful both would be

approved.


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c) Normal practice suggests that under the circumstances an application can be put forward,

whether or not a site has been identified, and then assessed on its own merits against

established planning principles.

LACK OF JOINED UP THINKING - PPS 24 AND PPS16

9) The whole basis for PPS16 – development plans and restrictive guidelines - is undermined by

the draft Policy Statement PPS24 which clearly echoes our request for flexible, responsible

and sustainable planning guidance. The introduction states:

a) The Executive’s Programme for Government makes economic growth and wealth creation

a top priority, to be taken forward in a fair and sustainable manner. This strategic

priority is echoed as a key theme that underlies the planning system, which seeks to

deliver economic development while protecting and enhancing the environment.

b) In the current economic climate it is important that the planning system adapts flexibly

and quickly to the many challenges facing the local economy. It is vital that proposals that

may bring investment are processed as quickly as possible.

c) The Department’s guiding principle to development management is set out in Paragraph

59 of Planning Policy Statement 1 ‘General Principles’:

i) “in determining planning applications…development should be permitted, having regard

to the development plan and all other material considerations, unless the proposed

development will cause demonstrable harm to interests of acknowledged importance.”

AN INDUSTRY PREPARING FOR THE FUTURE - RESPONSIBLE AND SUSTAINABLE

10) The NCC endorses ‘responsible sustainability’. In other words:

a) Site (re)developments are planned, designed and executed to a high standard

b) They are built in a sensitive and sustainable manner to preserve the visual appearance

and character of the local infrastructure and heritage

c) The requirements are balanced against potential local economic and social benefits and

the needs of local residents

d) Each application is treated on its own merits and is economically viable and sensitive local

planning ensures that the right balance is achieved.

We also endorse the recent Visit Britain Action Plans which promote the concept of ‘Wise

Growth’, which underpins all their plans, and where all these factors work together with each

other to the benefit of tourism rather than ‘dictating a limiting behaviour at the outset’.


7

11) Caravan Holiday parks and touring caravan sites are being targeted unfairly without

recognising the immense steps taken by the industry in other parts of the UK. New low impact

(re)developments are sustainable, provide enhanced community amenities, blend in with the

landscape, embrace bio-diversity and at the same time benefit the local economy. Our green

credentials embrace environmentally friendly low impact solutions ranging from Mechanical

Ventilation and Heat Recovery (MHVR), solar panels, wind turbines and grey water recycling

to achieve responsible sustainability. This is being recognised through national industry

awards such as those run by David Bellamy and PPS16 is not acknowledging these

innovations. For example:

a) The NCC has adopted a proactive stance, reviewing BS standards and encouraging

members to supply and use environmentally friendly and sustainable materials and

products to manufacture homes, responding to Government initiatives and consumer

demand

b) To date, more than 600 holiday parks have received a David Bellamy Conservation

Award for the work they’ve done to protect and enhance Britain’s natural environment.

i) creation of new wildlife meadows and woodlands

ii) construction of solar-powered shower blocks

iii) energy efficient lodges made out of recycled plastic

iv) Only using local produce, materials and craftsmen.

c) The Caravan Club has 43 sites that are committed to enhancing the natural environment

around the site

d) The Camping and Caravan Club also have sites which offer eco pods and Forest holidays

e) Scotland’s Green Tourism Business Scheme has over 700 members

f) Local job creation and economic growth from the development of new and existing sites is

significant. For example:

i) In 2010, Gwynedd Council approved a £15m redevelopment of a caravan park in

north Wales. It will create 12 permanent jobs and 30 seasonal positions, on top of an

existing 350 jobs. The plans involve demolishing 450 chalets dating back to the

1970s. The 10-year plan will include a nine-hole golf course and extending the

coastal path on the site.

ii) In 2009 a £3m project in Norfolk successfully transformed a 1960’s chalet park into

a 21st century tourist attraction in a 28 acre woodland area. It included a local farm

shop and also created 40 additional jobs


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PLANNING FOR THE FUTURE

12) An increase in short breaks as opposed to longer holidays and the need for affordability

means that a positive stance towards caravan holiday parks and touring caravans makes

economic sense. Broader accommodation options are essential as is a more flexible and

innovative approach.

a) The Derry Tourism Strategy recognises that given the long term financial climate there is a

need to cater for all budgets alongside hotels. It states: ’opportunities exist to develop

hostel, camping, caravan and motor home provision for tourists’ to meet changing visitor

lifestyles and requirements.

13) Sites should be able to put forward plans under TSM7 to expand and/or (re)develop their

amenities to an appropriate size to meet demand, where there is a clear need and there is

no adverse environmental impact and taking PPS24 into account.

a) Each application should be assessed on its own merits rather than by placing arbitrary

restrictions on them all at the outset - these restrictions are not being applied in the same

way to other tourism developments - as this will only limit the potential of the caravan

industry and its contribution to NI Tourism long term.

14) Owners often have non caravanning friends who visit and need to be put up on site. Limiting

self catering accommodation options (TSM6) will not encourage this. More important, having

to choose between developing/expanding either a site’s amenities and facilities or

accommodation due to site size limitations, as PPS16 is implying is a deterrent.

15) Allowing more sustainable Caravan Holiday Homes has the potential to free up existing

bricks and mortar homes for local housing use and first time buyers rather than as second

home/holiday home owners.

New and existing sites: size and mix of homes + location = economic viability

16) Modern caravans and motor homes are larger so any (re)development will lead to fewer

pitches which in turn decrease revenue. To encourage entrepreneurs and existing business

owners to invest in (re)development or new build parks need to be viable as well as having a

location that holidaymakers want to go to which gives enjoyment and relaxing.

a) This means having a site with a mix of caravan holiday homes, touring caravans, motor

caravans and touring and tent pitches to ensure a steady fixed income base that

balances out weather extremes. (Mixed sites are successful in other parts of the UK, often

in areas of outstanding natural beauty such as the Lake District and the New Forest).


9

b) Whilst two hectares is the absolute minimum size a site needs to be viable and to provide

the infrastructure, amenities and a positive holiday experience, each application should

be treated on its own merits. Size should not be a determining factor.

i) On a site of one hectare, by law you can only fit a maximum of 75 pitches for

caravan holiday homes, tourers and tents. When one adds in the infrastructure needs,

services and basic amenities, the return on investment (ROI) as against the total costs

will not make financial sense.

a) NB: on a site with up to 75 pitches 140/280 people could be staying overnight.

The size, visual appearance and amenities a hotel would require to provide for

that number would be more detrimental to the local environment than the site itself,

and far less affordable.

c) Raising pitch fees to replace any lost revenue is not a solution and any increases above

RPI must be explained and justified in writing

d) By their very nature sites encourage expenditure in the local economy and this can easily

be managed at the planning stage. Hotels on the other hand are more likely to have

facilities that limit expenditure outside of it.

Upgrading the site

17) Many site owners who would like to upgrade, extend or enhance their amenities will not do

so due to the ‘small scale’ rounding off or ‘infilling’ restrictions. Unused land is often not

suitable for additional development. In addition the payback of enhancing amenities cannot

be offset by increased income from more pitches which comes from being able to increase

site size to compensate. As above, raising pitch fees to replace any lost revenue is not a

solution.

a) Existing site owners and the site will suffer with developments limited to infill – closer

neighbours - privacy issues, limited views and loss of personal and general enjoyment

through lack of open space will make the holiday experience less enjoyable. This is

neither sustainable tourism nor desirable tourism.

i) Existing sites in NI are old and outdated and need to be upgraded, to ensure the

amenities and facilities meet the everyday standards UK and foreign tourists expect,

and to cater for modern caravans and motor homes and compete with other tourism

options.

a) With limited/no site expansion allowed, this will result in fewer pitches which in

turn will make the park less viable.


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WHAT SHOULD THE PLANNING SERVICE DO NEXT?

18) At a time when land and property values are falling in NI, now is the time to encourage and

facilitate private sector entrepreneurs and business owners to invest in sustainable

(re)development in order to revive regional and local economies and meet tourism demand.

Business entrepreneurs do not invest money in something that takes time to be approved and

might fail due to size and location. It is time to be imaginative not restrictive; not the time to

reduce the revenue of those that want to invest in and develop their existing site and their

future. That is not to say there should be no restrictions but every case should be looked at on

its own merits. For example:

a) How can an owner upgrade and expand the existing site to increase the number of

pitches and ensure income does not decrease, as otherwise the incentive to do so is lost.?

i) Could lower impact options such as eco homes be subject to less limiting planning

regulations in terms of site size if brought onto an existing site to increase pitch

numbers to pay for upgrading the site and enhancing amenities?

b) How can the local community become involved so the site becomes a benefit not a burden

and visitors are encouraged to take a more responsible approach?

19) It is unrealistic to assume that an increase in hotels and self catering accommodation alone

will satisfy tourism demand and help to drive the economy forward at a time when

demographics, lifestyle circumstances and the financial situation are making fundamental

changes to the way in which we live our lives. Caravanning is here to stay; it is a growing

business which is being prevented from responding to demand. The NCC strongly

recommends a more positive message: ‘lets work together for our mutual long term benefit and

so that we can achieve each others goals’. A more flexible policy would encourage investment

and further build the tourism industry:

a) Tourism developments in the countryside should not be feared. Visitors want to be out in

‘open space’ and do not want to damage it -holiday parks need not open all year round

- and developers support responsible sustainability.

b) The NCC is not encouraging development at all costs, but in a sustainable manner that

works for everyone without decreasing existing revenue.

i) Larger mixed sites should be encouraged to ensure viability and a steady income and

to ensure we can cater for modern caravanning needs and vehicle sizes.

ii) Relax the location restrictions and allow sensible planning guidance to perform its role


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iii) Expansion should be encouraged especially as the infrastructure is already there – on

older parks it will be essential to cater for the size of modern caravans and motor

homes.

iv) Applications should be allowed, whether or not a site has been pre -identified, and

then assessed against established planning principles.

v) Treat each plan on its own merits whether it’s a new site, (re)development or an

expansion.

c) The Development plan process is unworkable and is not fit for purpose and PPS24 clearly

suggests that a more enlightened planning process is adopted. Consider producing an

overarching and more general national policy framework with less prescriptive guidelines

that allows for regional and local flexibility and training support to iron out any possible

misunderstandings. Planning needs ‘wiggle room’ rather than concrete rules.

d) Think ahead; 20 years ahead. Tourism is or should be a national priority and given the

slowness with regard to putting together local/regional plans, the planning service should

be putting forward a policy that minimises this and allows tourism to achieve its potential.

20) We are ready to facilitate an opportunity for officers to visit caravan developments, both

locally and elsewhere in the UK, to enable a more positive and responsive PPS16 to be

achieved.

21) We would also welcome the opportunity to sit down with the planning service and discuss our

points in more detail.

The NCC

March 2011


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Annex 1

The future for tourism in N.Ireland

NITB has set out bold, ambitious plans for the future as tourism can be an engine of economic

growth and can create jobs and widen the base of the economy. N. Ireland now needs to

maintain the momentum it has built up.

NITB targets

Increase visitors from 3.2million to 4.5million by 2020

Increase earnings from tourism by £520million to £1billion by 2020

o tourism earnings would account for 2.6% of the economy

Create c10,000 more rooms will be needed

In turn this would create 13,000 jobs

How is this going to be achieved?

Bringing new accommodation on stream by investing in entrepreneurs and growing indigenous

businesses.

Creating a new relationship with planners and developers.

Supporting the development of larger units with facilities to meet the needs of large family

groups.


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Annex 2

What are the challenges?

From NITB discussion groups/surveys in 2009, three points emerge:

Need to embrace entrepreneurialism

Need to show that this is country that wants to do business and facilitates it - the ‘system’ did

not encourage innovation and change. Ministers would need to remove ‘road blocks’ to

development. High profile support from government for the sector

Planning v economically viable/economic reality

Planning currently does not support and facilitate tourism development. Whilst clear and

consistent criteria for responsible tourism development are essential an understanding of the

link between this and the economics of an investment opportunity is important too.

Lack of the right type of accommodation

The range of new developments that have been given planning approval in the last few years

have been in branded hotels as the major chains were keen to establish a presence. To date

there is little evidence of the new styles of product mentioned below being introduced to the

market.

Product development trends in Europe includes:-

o ‘Glamping’ i.e. luxury camping in tepees, yurts and the redevelopment of static

caravan parks to holiday lodges.

o Future trends indicate that larger units of self catering accommodation with facilities

such as games rooms, swimming pools, spas etc will be required.


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Annex 3

History

PPS 16 recognised the importance of tourism to Ireland. In 2002 it contributed £395m to the

economy and supported 20,000 FTE by 2005 it had risen to £889m and 41,000 respectively.

Ambitious plans for growth were set as many businesses depended on tourism in whole /part; so

land use planning system had a key part to play in ensuring tourism related development

maximised the economic and employment benefits of tourism to NI

SP 10 clearly indicated that planning policy would be exercised positively in favour of tourism

subject to environmental impact.

TOU1 said it would give favourable consideration to tourist development proposal and seek to

facilitate and protect the tourism industry and where appropriate area plans will contain a

tourism strategy – Fermanagh 2007

NI draft prog for Govt 2002 aimed to ensure the huge potential for tourism was fully exploited

The RDS for NI in 2025 pub in 09/2001 said that a spatial framework should be provided to

accommodate changing tourism and leisure habits whilst conserving key assets and emphasising

sustainable tourism, caring for the environment and protecting unspoilt areas, landscapes and

assets, capitalise on the areas tourism magnets and exploit their potential; create tourism

gateways

All in all the overall aim was to manage and create a positive environment for tourism from which

it could continue to develop and benefit local economies and employment and foster a longer

term love of the culture and significance of Irish heritage to preserve and enhance it for future

generations. To create policies that met key tourism development issues ensuring that the

development was sustainable appropriately located and sensitively designed and able tom

make a full contribution to urban and local economies

Annex 4 Separate emailed document

National Caravan Council LimitedCatherine House, Victoria Road, Aldershot, Hampshire, GU11 1SS

Telephone: 01252 318251 Facsimile: 01252 322596 Reg. No. 519228


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Draft Planning Policy Statement 16 Tourism - Northern Ireland National Caravan Council’s submission to the issues for Stakeholders’ consideration relevant to the preparation of PPS 16 (February 2009) Name: Alic ia Dunne, Deputy Director General Organisation: National Caravan Council, C atherine House, Victoria Road, Aldershot,

Hampshire GU11 1SS Email: [email protected] The National Caravan Council (NCC) represents the collective interests of the UK caravan, motorhome and park home industry. The industry has a turn over of £3 billion and employs nearly 100,000 people. It serves over 1 million caravanners and 250,000 park home residents. We have over 550 companies in membership, including over 90% of UK production of touring caravans, caravan holiday homes and park homes, and the leading parks, dealers, suppliers and service companies. The NCC through it’s specialist division, the National Park Homes Council, also represents the residential park home industry (mobile homes) in the UK. General comments

1.0 The National Caravan Council (NCC) welcomes the opportunity to contribute comments as a stakeholder for consideration in the preparation of a new PPS 16 Tourism in Northern Ireland.

1.2 The caravan industry enjoys steady growth, and makes a major contribution to tourism in the UK1. In Northern Ireland we believe this is grossly undervalued, and is not assisted in fulfilling its considerable further potential.

1.3 The NCC welcomes and supports the three key objectives of PPS16 identified to:

1.3.1 facilitate tourism development in contributing to the growth of the regional and local economy

1.3.2 promote sustainable tourism development in appropriate locations in an environmentally sensitive manner and

1.3.3 provide sufficient protection for tourism assets from inappropriate development

1 NCC UK Caravan Statistics – 2008 – see page 7 for details

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mailto:[email protected]

1.4 We are, however, extremely disappointed with the proposed policy direction in relation to caravan and camping sites in Northern Ireland and the apparent lack of forward thinking in respect of the contributions the caravan industry in Northern Ireland currently makes, and can continue to make to domestic tourism.

1.5 Holiday caravan parks – touring caravan, motorhome and caravan holiday homes – are important to the local economy and the viability of regional tourism in Northern Ireland. According to the Armagh and Down Regional Tourism Area, caravans, motorhomes and tenting accounted for 40% of all tourism accommodation.

1.6 The area’s 2005 figures indicate that touring caravans alone contribute £3.86m per annum into the local economy and caravan holiday homes £81.26m. Allowing for inflation and current projected estimates for all caravan holiday park bookings in 2009 it is possible that this contribution may exceed £100m.

1.7 In 2007 the Camping and Caravanning Club, representing 450,000 caravanning members across the UK, reported that the regional spend in Northern Ireland amongst members was £203,215. Overall the average length of stay is 6.3 nights, with an average spend of £29.55 per pitch/unit (excluding park site fees) and a total of £32m contributed to local communities2.

1.8 The caravan industry is also a significant local employer. In February 2009 Pontins announced that it is to create 2,000 new jobs, spending £50 million refurbishing its six holiday camps across England and Wales. Over 250 jobs are also to be created in Exmouth (Devon) by Haven Holidays operated by NCC member Bourne Leisure.

1.9 We are also concerned that the overall objectives of Planning Policy Statements – to set national guidance to inform local planning decisions – appear to be lost in the draft PPS 16 Tourism. The statement as drafted contains issues and specific detail such as precise expansion limitations for caravan parks which would not ordinarily be included in national guidance.

1.10 Of particular note is the absence of any reference to the Good Practice Guide on Planning for Tourism issued by the Department for Communities and Local Government (CLG) in England in 20063, which followed a review of similar planning guidance on Tourism (PPG21) and a subsequent consultation in 2003.

1.11 We would urge the Planning Service in Northern Ireland to study the document and its purpose which is threefold:

1.11.1 To ensure that planners understand the importance of tourism and take this fully into account when preparing development plans and taking planning decisions’

2 Spend in the Local Community - summary report – The Camping and Caravanning Club 2007 3 Good Practice Guide on Planning for Tourism, DCLG - May 2006

2

1.11.2 To ensure that those involved in the tourism industry understand the principles of national planning policy as they apply to tourism and how these can be applied when preparing individual planning applications and

1.11.3 To ensure that planners and the tourism industry work together effectively to facilitate, promote and deliver new tourism developments in a sustainable way.

1.12 Of particular relevance to the caravan industry is the inclusion in the Guide of specific planning policy guidance specific to the caravan sector. The three annexes covering Tourist Accommodation, Seasonal and Holiday Occupancy Conditions and Data Sources and Techniques cover holiday, touring caravan and chalet parks in specific detail, with recognition of the opportunities the caravan sector brings to rural tourism, the industry’s commitments to environmental protection and the importance of effective occupancy conditions designed to ensure that the holiday accommodation is used for its intended purpose.

1.13 We believe that the new PPS in Northern Ireland should give

appropriate emphasis to the need for planning policies to encourage expansion of tourist accommodation and take account of the importance tourism custom can bring to sustaining small businesses in rural communities.

1.14 The PPS must also recognise the importance of rural diversification – use of agricultural land (farms) for tourism activities including provision for small touring parks, bed &breakfasts establishments etc.

1.15 In this regard we believe that the Planning Service should, in addition to the comments made in 1.10- 1.12 above, also have regard to developments and planning policies elsewhere in the UK that actively encourage, support and promote the caravan industry’s contribution to tourism. Please see footnotes as references.

1.16 The PPS must acknowledge the shift towards more traditional domestic holidays and the increase, in particular, in short breaks/weekends.

2.0 Response to issues for stakeholders on policies for self catering - Caravan/Camping Sites

Please see table below containing our comments in response to the questions numbered 53-62 inclusive relating to proposals affecting the caravan industry:

Self Catering Accommodation – Caravan/Camping Parks

Q.53- Is there a need for new static caravan/chalet parks in the countryside?

Yes, caravanning must develop to meet the growing needs of both the domestic and inbound markets - many local people want to spend their holidays at home at affordable rates and to enjoy the freedom that caravan holidays offer without the extra expense of traditional bricks and mortar second home/holiday home ownership. Caravan parks for caravan holiday homes (‘statics’), touring caravans and motorhomes provide an important economic advantage to the local community with increased use of the local shops, cafes, restaurants and

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tourist amenities. Whilst many are residents of Northern Ireland, returning money to the local economy rather than taking foreign holidays and spending abroad, the caravan holiday lifestyle also attracts many from Southern Ireland, the UK mainland and the immediate European continent. The planning policy towards caravan park development as drafted appears to resist any new applications particularly on coastal land and within urban areas which is contrary to the aims and objectives of the previous draft PPS 16 dated 2004 which appeared more favourable and inclusive towards caravan park development. With this in mind, the only locations for new parks are in a countryside location, preferably in a tourist area close to tourist amenities. It is worth noting that many caravan parks located in urban areas have been lost in recent years due to redevelopment for housing. Furthermore, in the context of land values within urban areas it is not economic to develop new or extend existing caravan parks within such areas.

Q.54- If so – Is the local Development Plan the most appropriate means of identifying suitable locations for this form of development?

The objective of Planning Policy Guidance- or Statements - is to inform local planning authorities and decision makers on what should be considered in relation to tourism in local development plans. At present the local plan is an unsatisfactory mechanism for identifying locations for new caravan parks. Firstly, the process of progressing development plans has become increasingly protracted and frustrating. For example the Northern Area Plan, eight years after commencement has not significantly advanced in recent years and there is no likelihood of achieving adoption in the next three years. Secondly, there is a need for flexibility to respond to the evolving and projected market demand. Thirdly, shifting responsibility for identifying suitable locations for such development to a local level could compromise the autonomy and integrity of local government in relation to assessing and increasing local land values.

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Q.55- If not (Q.54) How could regional policy serve in the identification of suitable sites?

Appropriate regional policies could define the criteria (economic, social and environmental) against which proposals for caravan holiday homes (static), touring or caravan holiday home /touring caravan parks could be evaluated. These criteria could include landscaping policy, visual integration, transport links and availability of mains services (water, sewage & electricity). Consideration should be given to locating parks in areas where tourists actually want to holiday and demand is high. Many ‘old-style’ caravan parks in urban area have been redeveloped for housing in recent years (as have many older hotels). Often this is seen by local residents as a planning gain particularly with regard to old style caravan parks that do not sit well in an urban environment. The countryside close to towns and villages that have experienced a substantial reduction in caravan parks/hotels could be considered suitable for a more appropriately located modern caravan parks to address the balance/shortfall. This approach would be more flexible and enable the Planning Service to respond more effectively to changes in the holiday market as they evolve, rather than the rigidity of the slow moving, inflexible development plan system.

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Q.56- In what circumstances (if any) should a touring caravan site be

Touring caravan sites of an appropriate scale should be allowed in the countryside, where there is a demonstrable need and with no adverse environmental impact. Many visitors enjoy the opportunity to experience the ‘get- away-from-it-all’

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allowed in the countryside?

feeling. Caravan parks have the potential to contribute significantly to the local economy including creating employment, and when carefully planned and implemented these can enhance both the local landscape and biodiversity through planting woodlands of native species and the creation of ancillary, species rich wetlands rather than the featureless and relatively sterile farmland that preceded their implementation. In many instances the replacement of huge unsightly agricultural steel sheds in the country with a properly laid out and landscaped caravan park would present planning gain rather than planning blight. Touring parks are a huge draw, for not just domestic holidaymakers but also the growing overseas tourists who bring money into the NI economy.

Q.57- What specific criteria might be applied to ensure satisfactory integration of such sites into the landscape?

Sustainable development with ‘softer’ layouts and enhanced landscaping using lower density and greater landscaping is outlined in the industry document co-authored by the NCC ‘Caring for the environment; a guide to good practice’4 Any planning application could be referenced to this and supported by a visual assessment indicating from the critical views into the site, the degree of visual integration that could be achieved. This would give the Planning Service the information it needs to properly assess any application and to determine what, if any, additional landscaping may be appropriate. Modern caravans are, by virtue of their low-profile and environmentally friendly colours (governed by a British Standard), much easier to integrate into the landscape and in some instances less intrusive than farm buildings. In addition it is beneficial for park businesses to provide screening from, for example, prevailing winds and to enhance the visual amenity of the park for visitors. Furthermore caravans tick another ‘sustainability’ box by virtue of their unique tenure and dedicated regulatory and legislative framework.

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Q.58- What should be the maximum size of a touring caravan site permitted under the policy?

This should be determined by need, projected demand and local economics rather than any arbitrary limit, and assessed on individual merits. Where a touring caravan park is part of a farm diversification scheme it may be quite small, but where it is intended to provide a reasonable range of modern facilities and support full time local employment it needs to be of a size to make it economically viable for all concerned. Modern touring caravans/motor homes require more ‘on-park’ facilities than caravan holiday homes (statics) by their very nature, (e.g. water connections, grey water waste disposal, electric connections, public toilets/showers, laundry and a dedicated disposal point for chemical toilet waste). Caravanning in the 21st century is environmentally friendly and its green credentials are of note5. Now facilities can also include solar heating panels, to pre-heat water used in the showers and washbasins, photo-voltaic cells on the roofs of the reception office and toilet block to generate electricity, geothermal heat recovery systems, grey water recycling used for toilet flushing, low-energy lightbulbs fitted as standard – and some even have wind turbines to boost energy generation. The investment required to bring modern caravanning holidays – akin to many other holiday requirements - to the discerning caravanner are such that the size of the development needs to

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4 Caring for the environment; a guide to good practice’ – 1994 NCC, BHHPA in association with the English Tourist Board and the Countryside Commission of England and Wales 5Poolsbrook Country Park Caravan Club Site http://www.caravanclub.co.uk/About+us/News+Articles/2008/November/Poolsbrook+MP+Visit.htm

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be viable. It is understood that even local councils that have attempted to develop very small touring parks on the whole fail to make a profit even with the benefit of grants and resources not available to private sector.

Q.59- Are there specific areas in the countryside where touring caravan sites are not appropriate?

Touring caravan, motorhome and caravan holiday home (static) park developments should be assessed on the current and projected demand, and with appropriate consideration to the individual merits such development may bring to the surrounding area.

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Q.60- Is specific policy necessary in regard to proposals for the expansion of existing caravan & camping sites (static and touring)?

Specific planning policy to support such development is essential and could reflect similar specific policy guidance in existence in England – see footnote 1. We would encourage the Planning Service to follow the model set out in the Good Practice Guide on Planning for Tourism, DCLG - May 2006 . If PPS16 Tourism in NI could adopt a similar approach it would serve the demand and aspirations of the caravan industry and its growing customer base. It would also inform and support Northern Ireland PPS21 and its cross reference to the Planning Strategy for Rural Northern Ireland TOU4 Caravan and Camping Sites, CO6 Caravans and Chalets together with PPS4 covering the importance of the economic benefits of tourism to the local economy.

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Q.61- Should such expansion proposals be subject to a defined size threshold?

There should be no arbitrary limit imposed on acceptable and agreed expansion as this will frustrate the potential of this tourism sector to make its full contribution to tourism and the local economy. It would be deemed wholly unacceptable to isolate caravan parks by limiting the scope for growth and improvement (for example placing a 10% limit on park expansion) when similar criteria is not available in limiting other tourism expansion proposals – e.g. hotels, self catering developments and marinas. In order for parks to adapt and improve to cater for the new generation of caravannners they must to allowed to redevelop sensitively and appropriately (landscaping, road layouts, larger pitches with improved spacing) in order to present themselves better with environmental inclusion. We would encourage the Planning Service to follow the model set out in the Good Practice Guide on Planning for Tourism, DCLG - May 2006

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Q.62- What specific criteria might be applied to ensure satisfactory integration of such enlarged sites into the landscape?

We would encourage the Planning Service to follow the model set out in the Good Practice Guide on Planning for Tourism, DCLG - May 2006.

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In conclusion, we are anxious that the Planning Service recognises the contribution the caravan industry makes to tourism and the importance that specific, structured guidance can offer local planners in better understanding the importance of tourism, and to enable them to work more effectively with the tourism industry promoting and delivering new tourism developments in a sustainable way. We would welcome the opportunity to address the Planning Service further on all the points raised and to assist all relevant agencies engaged in the development of tourism in Northern Ireland. We would be very happy to facilitate an opportunity for officers to visit caravan park developments both locally and on the mainland to assist with the formulation of an effective, positive policy statement. National Caravan Council

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UK caravan industry statistics

Statistical information on the importance of the touring caravan, motor-home and caravan holiday home industry in the UK is shown below:

• The industry contributes over £5 billion to the UK economy (new/used retail sales plus holiday spend)

• It employs in excess of 90,000 people, including part time and seasonal

staff

• More than £1.75 billion was spent on UK caravan holidays in 2007 • It is a growing industry – caravan parks across the UK are experiencing

increases in bookings • Caravan holidays accounted for nearly 11.5 million trips in 2007, while the

number of camping holidays approached 5 million • More than 53 million nights are spent in caravans each year

• In Britain currently there are

- 500,000 touring caravans

- approximately 300,000 caravan holiday homes and

- 138,000 motorhomes

meaning there are nearly one million leisure accommodation vehicles in use • There are approximately 120 licensed caravan parks in Northern Ireland

• There are more than 2,000 licensed holiday/touring parks in UK, many in

rural areas where tourism is vital to the economy

Sources: Vital Statistics - National Caravan Council, 2008 VisitBritain’s United Kingdom Tourism Survey 2007

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