Development Management Submission Document

We do not object to this policy. However, Table 2 of the Technical Guidance to the National Planning Policy Framework (NPPF) classifies 'Caravans, mobile homes and park homes intended for permanent residential use' as 'Highly Vulnerable' development, which is considered inappropriate in Flood Zone 3. Policy DM19 does not currently take flood risk into account and we consider it may benefit from the additional text, included in the policy below:
"Applications for the stationing of mobile homes for agricultural workers in the Green Belt and wider countryside will be permitted provided it can be demonstrated that:
i) it is essential for the proper functioning of the enterprise for at least one person to be present on the holding at most times of the day and night;
ii) the functional need relates to a full-time agricultural/horticultural worker;
iii) there is clear evidence of a firm intention and ability to develop the enterprise concerned;
iv) there is clear evidence that the proposed enterprise has been planned on a sound financial basis;
v) no dwelling or other existing building suitable for conversion to a dwelling has recently (generally considered to be within the past two years) has been sold or let by the applicant that would have otherwise met the functional need;
vi) the functional need could not be fulfilled by another dwelling on the unit, or any other accommodation in the area as a whole that is suitable for, and available to, the worker(s) concerned; and
vii) any mobile home will be located outside Flood Zone 3, and will only be located in Flood Zone 2 where it is shown to pass the Sequential and Exception Tests and is supported by a site-specific Flood Risk Assessment.

Any development which is permitted should be of a scale, design and siting such that the character of the countryside is not harmed and nature conservation interests are protected.
Permissions for mobile homes will be subject to conditions, in particular to restrict their occupation to persons solely or mainly employed, or last employed, in agriculture in the locality and require their removal from the holding after a maximum period of three years."

We support this policy. However, due to their nature, houseboats are likely to be located in areas at high risk of flooding. In accordance with the NPPF, development in Flood Zone 3 is required to pass the Sequential Test and to be supported by a site-specific Flood Risk Assessment, of which the safety of occupants must be an important consideration. We therefore suggest that the following text is added to the 3rd paragraph of this policy, to ensure that due consideration is given to the wider setting of the moorings and how this might affect the safety of the occupants during a flood event, such as if there is safe access/egress to higher ground:
"Permanent moorings and associated infrastructure, where permitted, should not cause disturbance or pollution to the surrounding environment, and should not adversely impact on the appearance of the local area, the objectives of the Green Belt, or the commercial or leisure use of the rivers and surroundings. They should only be permitted where the Local Planning Authority is satisfied that the development has a tolerable level of safety for occupants in a flood event."

We are very supportive of this policy, but suggest the additional text set out below is added to the 3rd paragraph, in order to ensure that development contributes towards achieving the objectives of the Water Framework Directive (WFD). These include the prevention of further deterioration as well as the protection and enhancement of aquatic ecosystems, which have not been addressed in your Core Strategy. We therefore consider it important that the following amendment is made:
"Where a particular landscape feature is of ecological or landscape importance and should be retained, planning permission will be conditioned to ensure the retention and continued maintenance/management, where appropriate, of this landscape feature. On-site environmental enhancements including opportunities to create/enhance/restore habitats and to contribute to Water Framework Directive objectives, will also be sought."