Please read and sign before 5th December, as the responses will be collated and must reach the Planning Inspectorate before 11.59pm on 6th December.

Objection in the matter of the appeal against refusal of a certificate of lawful development for change of use of the agricultural field to the north east side of the Ruda Holiday Park, Moor Lane, Croyde EX33 1NY for the siting of static and touring caravans.

Application Reference: 64385 Appellant’s Name: Parkdean Holiday Parks Ltd Appeal Reference: APP/X1118/X/18/3217206

1. This field has always been an agricultural field and an important green area in the AONB revealing: mediaeval field boundary; a green undeveloped area between the Holiday Park and the developed residential part of Moor Lane and tracking a line of undeveloped green landscape from Moor Lane up to the green natural landscape of the northern ridges beyond. It features prominently in many of the established walks in the AONB. It can be seen from the footpaths: on Saunton Ridge; through Croyde Beach Dunes and those accessed from Broadway Lane and Middleborough Lane which lead to walking routes in the Northern ridge area.
   
   
2. Application 64385 and its appeal relies solely on the interpretation of planning permission 56528 granted in January 2014. That application was for a change in the opening times of the Holiday Park. Its clear purpose was to extend the time over which the existing lodges and static caravans and tourer caravan areas and related communal service areas for holiday makers such as the club house and swimming pool, launderette, etc could be used for holiday purposes. No mention was made in that application for the siting of new areas for static caravans etc.
   
   
3. After application 56528 was granted, the applicant made two applications (61826 and 61846) for change of use of certain areas of land owned by them. Application 61826 was in respect of the field in question, for the siting of 50 static caravans. During public consultation this was reduced to 13 static caravans/9 lodges and finally to 12 lodges only with green roofs. The application received many and various objections including flood risk issues and harm to the AONB. If the applicant had applied for and obtained the change of use now claimed, as a result of application 56528, presumably there would have been no need for these subsequent planning applications. The applicant withdrew application 61846.
   
   
4. This application for a certificate of lawful development was made shortly after the withdrawal of application 61846 and correctly refused by the LPA. A certificate of lawfulness for the claimed change of use would permit siting for an unspecified number of static and touring caravans etc on the field.
   
   
5. The Inspector is strongly urged to do the same – there is no convincing reason in fact or law for allowing this appeal.