Agenda item


Public submissions in respect of planning committee agenda items 28 July 2020.





It is recorded that written public representation was received from members of the public in lieu of attendance at the planning committee meeting and taken into consideration by all members of the committee in respect of Planning Application B 19 0520 a summary of which is below:


Additional letters of objection:

Robert Doughty Consultancy had tabled 3 additional letters of objections on behalf of objectors. The letters are very similar in main content, but also raised issues specific to each objector. The letters raised issues in relation to:


·         Traffic and Highway matters

·         Flood Risk

·         Permanent Residential use

·         Sustainability

·         Residential Amenity

·         Impact on neighbouring uses – boundary treatments & impact on farming operations

·         Land drainage


Officer comments in relation to the additional objections:

Traffic/Highway matters -

The LCC Highway Officer who commented on the application was asked to respond to the highway/traffic comments contained in the further objection(s) received. In summary, they have advised:

  • The TA uses the most relevant information available in TRICS for estimating trip rates to a caravan park. The TRICS data is the best available data.
  • Whilst Mr Doughty's letter says that the chosen sites are not comparable, he does not say what he considers the appropriate trip rates should be nor does he provide any evidence to support his assertions regarding the traffic movements.
  • The trip rate report had been re-run in TRICS using data from the last 20 years and the results show lower trip rates than those used in the TA.
  • The trip rate associated with permanent occupancy would be likely to be much higher than holiday accommodation.  However, this use was not being applied for under this application and planning enforcement will presumably be able to ensure the site is only occupied as holiday accommodation.


It was considered that the response supported the conclusions of the report, and Officers had no further comments to make.

Flood Risk –

It was accepted that the language in the report was incorrect. The sentence to be corrected as follows:

“FRA includes reference to the need for a Sequential and Exceptions Test, these are covered by other documents provided with the application.”

It was accepted that only a limited exercise has been undertaken in relation to both the Sequential and Exceptions Tests within the documents submitted with the application.


Officers have considered the proposals in light of the requirements of policy 4, including the principles pertaining to Sequential and Exceptions tests. The proposals are to support an existing leisure site, and this matter was covered under paragraphs 7.8 and 7.65 of the published report. Officers raised no objections to the approach taken within the application submission. Officers remained of the view that the proposals were acceptable in that regard and the conclusions of the section on Flood Risk remained unchanged.


Permanent Residential Development

This was addressed in detail within the report. The proposals were for holiday accommodation as described and would be conditioned as such. Any breaches of the conditions identified would be investigated by Planning Enforcement should they occur.


It must also be remembered that there were currently facilities on site, including a bar/restaurant, and driving range, all of which could be accessed by people using the caravans, hence the ‘hub’ would supplement these facilities.  It should also be remembered that there was currently a hotel on site, and also there were other examples of holiday accommodation within the immediate locality, therefore the broad principle of holiday accommodation in this area had been previously accepted.


Sustainability and economic benefit

It was considered that it had been sufficiently dealt with in the main report. The Councils’ Economic Development Manager has reviewed the application and supported the proposals. It was considered that the report was informed by a sound methodology and no independent testing was required. In the event the figures quoted were not achieved in full, there would still be a significant positive economic effect.   It was considered that both points were matters of planning judgement for the decision-maker.


Residential Amenity

It was considered that this was sufficiently dealt with in the main report, and no further comments were required.


Impact on neighbouring uses – boundary treatments & impact on farming operations

Officers were of the view that the details presented were acceptable, the reference to ‘rabbit proof fencing’ and ‘stock fencing’ were common terms, and it would be possible to erect a boundary up to 2m in height without the need for planning permission, therefore further details were not necessary.  Further, this must be considered in the context of the existing boundaries, which were established and comprised of significant vegetation that already presented a clear visual and physical barrier. The proposals were to supplement the existing arrangements.


Officers consider it is unlikely that users of the site would be encouraged to transgress on to neighbouring land.  In any event, any level of transgression would be unlikely to be so significant that it could not be managed by the site operator and neighbouring landowner in order to ensure that it ddi not become problem to the adjacent operations.


Land Drainage

It was considered that this matter has been sufficiently dealt with, the approach to drainage was considered appropriate to the statutory consultees, and would also be dealt with by way of conditions proposed.  It was considered that there was existing drainage arrangements serving the golf course, and there was ample space within the site to ensure that drainage and surface water in particular were dealt with in a sustainable way. Equally, the use of SUDs features for other activities and benefits is a recognised approach


Additional letter of comment:

An email has been received from a Mr M Nundy that identified he was a member of the management committee at Hubberts Bridge Community Centre. It provided comments in relation to the main foul drainage arrangements across the land belonging to the community centre. They advised that the arrangements had not been agreed, and they had a number of concerns and questions which would needed to be addressed, before they could consider agreeing to their intention. They understood the intentions of the applicants and that a request may be made, but they were not aware of any reason whereby they would not require our permission to proceed as they intend.





Officer response

The revised drainage proposals showed foul drainage being connected to the mains sewer system, this had been discussed with Anglian Water.

In this case, the Council had been informed by Anglian Water that subject to a feasible drainage strategy being developed and agreed by them, along with details of connection points, locations, and agreements being in place for any necessary infrastructure, they had no objections.

The development would need the agreement of Anglian Water to connect to the public network and this would be managed under the Water Industry Act 1991. Any private agreements regarding the ability to connect to the drainage system would be outside of the planning decision, and would fall to the statutory undertaker (Anglian Water) and could involve civil agreements between parties.

Officers had no further comments to add, and the conclusions and recommended conditions remained unchanged.


Additional correspondence on behalf of the Applicant:

The applicant’s agent tabled two letters on the applicant’s behalf.  The first addressed the content of the Report to the Planning Committee, and the second sought to respond to the comments provided by objections received post publication of the report.

Officer response

The letter in response to the content of the Report sought to reinforce the findings of that report, and in particular the lack of objection from technical consultees. Officers noted that:


  • The letter referenced the economic effects of Covid-19, and how the proposals could support economic recovery and job creation.
  • The letter reinforced the policy compliant nature of the scheme, and that the proposals accorded with the aims of the NPPF, and that proposals which accorded with an up-to-date development plan should be approved without delay.


Officers have no further comment to make on this letter.


The second letter sought to respond directly to the additional letters of objection received post publication of the report. The letter highlighted the following points:


  • Further detail was given in respect of the Sequential and Exceptions Tests approach for this development, with due regard to the nature of the proposals and the characteristics of flooding in Boston. It concluded that a sequentially preferable location for the development was unlikely.
  • The Agent disagreed with the assertions made in respect of the economic case, indicating that owner-occupied caravans could have higher levels of occupancy, and therefore it did not follow that average spend from the units would be lower. They also indicated domestic tourism growth was likely to occur as a result of Covid-19 and the scheme would enable Boston to capture some of this growth.
  • The owners remained committed to delivering the site as a holiday destination, with proposals for the hub likely to come forward for Reserved Matters within a period of 3months from any grant of approval for the outline.
  • The site would be a managed environment and holidaymakers would be encouraged to follow the site rules, and thus any matters relating to trespass could be appropriately managed, as could any issues of noise or disturbance.


Officers have no further comment to make on this letter.




The Chairman closed the meeting thanking all attendees for their time and noting the success of the Zoom system used to facilitate the first virtual planning committee meeting.


Supporting documents: