Mr P Turner South Lakeland District Council Clerk to Lower Allithwaite Parish Council South Lakeland House Sunnyside Lowther Street Holme Lane Kendal Allithwaite Cumbria LA9 4DL GRANGE over SANDS LA11 7QD Tel: 01539 733333 www.southlakeland.gov.uk

Our Ref: SL/2017/0883 Your Ref: Date: 29 September 2017

Dear Sir/Madam

LOCATION: Lakeland Leisure Park, Moor Lane, Flookburgh, GRANGE OVER SANDS GEOCODE: Easting: 337780 Northing: 473990 DEVELOPMENT: Installation of 85 hardstanding bases (for 85 static caravans) with associated infrastructure (above and below ground), new internal access road, pedestrian footpaths and landscaping REFERENCE NUMBER: SL/2017/0883 (Please use this whenever you contact us) PLANNING OFFICER: Kate Lawson

We have received the above application that you may wish to comment upon. The following link will take you directly to the application: http://kdc- pam.southlakeland.gov.uk/AniteIM.websearch/ExternalEntryPoint.aspx?SEARCH_TYPE=1&DOC _CLASS_CODE=DC&folder1_ref=SL/2017/0883 Or go to our website: http://applications.southlakeland.gov.uk/planningapplications/welcome.asp to view the documents. Please send your comments by email: [email protected] before 28 days (27 October 2017). If you do not reply within that period I will assume you have no comments.

Yours faithfully

Kate Lawson Development Management

South Lakeland District Council South Lakeland House Lowther Street Kendal Cumbria LA9 4UF

Date: 26 September 2017 Our ref: 23030/NT/KR/14839998v1 Your ref:

Dear Sir/Madam

Application for Full Planning Permission - Lakeland Holiday Park, Moor Lane, Flookburgh, Cumbria On behalf of our client, Bourne Leisure Ltd, we are pleased to submit via the Planning Portal (ref. PP- 06402142) an application for Full Planning Permission for the installation of 85 hardstanding bases (for 85 static caravans) with associated infrastructure (above and below ground), new internal access road, pedestrian footpaths and landscaping at Lakeland Holiday Park, Moor Lane, Flookburgh, Cumbria.

Application Submission

In addition to the completed application forms and declarations, the application comprises the following supporting documents, which have been submitted via the Planning Portal:

 Application Forms and Certificates

 Planning, Design, Access & Heritage Statement– Lichfields, September 2017

 Location Plan – Drawing Ref: 875/44-3

 Existing Site Plan – Drawing Ref: 875/44-4

 Proposed Site Plan – Drawing Ref: 875/44-1

 Site Masterplan – Drawing Ref: 875/44-2. Rev B (updated and submitted for illustrative purposes)

 Ecological Assessment – Tyler Grange, August 2017

 Transport Assessment (accompanied by Appendix) - Integrated Transport Planning Ltd, September 2017

 Travel Plan - Integrated Transport Planning Ltd, September 2017

 Construction Traffic Management Plan- Integrated Transport Planning Ltd, September 2017

 Flood Risk Assessment (accompanied by Appendices A – G) – Bratherton Park Design Consultants, August 2017

Registered in England No. 2778116

Regulated by the RICS

 Landscape Plan – Andrew Davis Partnership – Drawing Ref: W1238 CPo1. Rev C

 Landscape Plan – Andrew Davis Partnership – Drawing Ref: W1238 1001. Rev A

 Landscape Plan – Andrew Davis Partnership – Drawing Ref: W1238 1002. Rev A

 Landscape Plan – Andrew Davis Partnership – Drawing Ref: W1238 1003. Rev A

 Landscape Plan – Andrew Davis Partnership – Drawing Ref: W1238 1004. Rev A A payment for the sum of £1,690.00, to cover the requisite planning application fee, has been paid via the planning portal.

Summary We trust that we have provided all the necessary information and that you will be able to validate the application at the earliest opportunity. We will contact you shortly to discuss timescales for the determination of the application.

Should you have any queries in the meantime, please do not hesitate to contact myself or my colleague Rachel Davies

Yours sincerely,

Katy Rodger Planner

Pg 2/2 14839998v1

Lakeland Leisure Park, Proposed Extension Planning, Design, Access & Heritage Statement Bourne Leisure Ltd. September 2017

© 2017 Nathaniel Lichfield & Partners Ltd, trading as Lichfields. All Rights Reserved. Registered in England, no. 2778116. 14 Regent’s Wharf, All Saints Street, London N1 9RL Formatted for double sided printing. Plans based upon Ordnance Survey mapping with the permission of Her Majesty’s Stationery Office. © Crown Copyright reserved. Licence number AL50684A 23030/NT/KR 14729130v4

Lakeland Leisure Park, Proposed Extension : Planning, Design, Access & Heritage Statement

Contents

1.0 Introduction 1 Application Documents 1 Scope of Planning Statement 1 EIA Screening Opinion 2

2.0 Background 3

3.0 The Application Site and Surrounding Area 4 The Surrounding Area 4 The Holiday Park 4 The Application Site 4

4.0 Planning History 7

5.0 Development Proposals 8 Use and Amount 8 Scale and Layout 8 Landscape 8 Access and Parking 9 Services 9

6.0 Planning Policy Context 10 National Planning Framework 10 South Lakeland Development Plan 10 South Lakeland Core Strategy 11 Saved Policies of the South Lakeland Local Plan 13 Key Planning Considerations 13

7.0 Planning Principles and Policy Assessment 14 Principle of Development 14 Flood Risk and Drainage 14 Landscape and Visual Impact 15 Ecology 21 Transport and Access 21 Sustainability 22

8.0 Heritage Statement 24

Lakeland Leisure Park, Proposed Extension : Planning, Design, Access & Heritage Statement

Statement of Significance 24 Assessment of Proposed Development 25

9.0 Summary and Conclusions 27

Appendices

Appendix 1: List Entry Plan Appendix 2: List Entry Description

Lakeland Leisure Park, Proposed Extension : Planning, Design, Access & Heritage Statement

1.0 Introduction

1.1 This Planning, Design, Access & Heritage Statement has been prepared by Lichfields on behalf of Bourne Leisure Ltd. (“the applicant”), to accompany a full planning application for development at Lakeland Leisure Park, Moor Lane, Flookburgh, Cumbria, LA11 7LT. This application seeks permission for:

“Installation of 85 hardstanding bases (for 85 static caravans) with associated infrastructure (above and below ground), new internal access road, pedestrian footpaths and landscaping.”

1.2 The proposed development forms part of Bourne Leisure’s continuing investment and enhancement of Lakeland Leisure Park. There are a number of on-going projects to improve the quality and standard of accommodation across the Park in order to meet the expectations of guests and remain an attractive option for tourists in the area.

1.3 This application for planning permission follows an application for pre-application advice (ref. IE/2017/0107). As part of the pre-application process a meeting was attended between Lichfields and Chris Harrison, of South Lakeland District Council, on Monday 17th July 2017. Discussions took place with regards to the scope of the application and the following points were raised;

 the Highways Department required a Transport Assessment, Travel Plan & Construction Management Plan to be submitted;

 a Heritage Statement would be required;

 a Visual Impact Assessment should be included as part of the Planning Statement; and

 a Flood Risk Assessment and Drainage Strategy would be required.

1.4 As a result of the above advice, all of these elements have been incorporated as part of the planning application.

1.5 Discussions also took place with regards to ecology and landscaping and it was confirmed the Council approved of the strategy being undertaken. Overall it was concluded that the South Lakeland District Council were supportive of the scale and principle of development in the context of the existing park. Application Documents

1.6 The application package comprises the following documents which should be read in conjunction with this Statement: 1 Flood Risk Assessment, prepared by Bratherton Park Design Consultants ; 2 Ecological Assessment, prepared by Tyler Grange; 3 Transport Assessment, prepared by ITP Ltd; 4 Travel Plan, prepared by ITP Ltd; 5 Construction Traffic Management Plan, prepared by ITP Ltd; 6 Landscape plans, prepared by Andrew Davis Partnership LLP; and 7 Application drawings prepared by Bratherton Park Design Consultants. Scope of Planning Statement

1.7 The Planning Statement provides an assessment of the key planning considerations and is divided into the following sections:

Pg 1 Lakeland Leisure Park, Proposed Extension : Planning, Design, Access & Heritage Statement

 Section 2.0 provides background information on Bourne Leisure Ltd, including the company’s Mission Statement;

 Section 3.0 provides a brief description of the site and surroundings;

 Section 4.0 addresses the site’s planning history;

 Section 5.0 describes the proposed development;

 Section 6.0 summarises the relevant statutory considerations, planning policy and guidance to be addressed;

 Section 7.0 contains our assessment of the proposed scheme against planning policy and guidance;

 Section 8.0 comprises the Heritage Statement in relation to the scheduled monument that is within the application site; and,

 Section 9.0 provides a summary of the assessment and outlines our conclusions. EIA Screening Opinion

1.8 We have given consideration to the relevance of this application to the Town and Country Planning (EIA) Regulations 2017. The scheme is one to which the EIA regulations may apply because it falls within Part 12 of Schedule 2 of the updated EIA Regulations as a permanent camp and caravan site exceeding 1 hectare.

1.9 For Schedule 2 developments, EIA is required only in situations where the development could give rise to significant environmental effects due to the characteristics of the potential impacts. The documents enclosed with this application demonstrate that the scheme does not give rise to significant environmental effects. The enclosed Ecological Assessment and Flood Risk Assessment analyse the likely impact of the proposed development on the existing environmental receptors and it is concluded that there will be no significant effects.

1.10 As the site falls within the threshold of Schedule 2 of the Regulations, we note that South Lakeland District Council is required to formally screen the application on submission under the requirements of Part 6 of the Town and Country Planning (EIA) Regulations 2017. We would appreciate it if South Lakeland District Council could confirm in writing that it agrees with our view that the scheme is not an EIA development.

Pg 2 Lakeland Leisure Park, Proposed Extension : Planning, Design, Access & Heritage Statement

2.0 Background

2.1 Bourne Leisure, established in 1964, is a significant contributor to Great Britain’s tourism economy, operating more than 50 holiday sites. These sites comprise hotels and holiday resorts; family entertainment resorts; holiday villages; and holiday parks. They are managed by a number of subsidiary companies; Butlins, Warner, and Haven.

2.2 Bourne Leisure is the leading operator of holiday parks in the UK and employs some 16,000 staff of which 2,100 are permanent staff and 7,300 seasonal staff for Haven. The business now generates some £1 billion turnover, and has a leisure asset base in excess of £2.5 billion. Nationally, Bourne Leisure’s parks attract over four million visitors per year. Bourne Leisure has over 50 years’ experience of the holiday industry and how to cater for the needs and expectations of holiday makers. The Company’s hotels, resorts, villages and parks are all under continual review, to ensure that the facilities provided are adapted to respond to changes in the tourism market.

2.3 For Bourne Leisure to continue to attract customers and respond to changing market conditions, the Company has to invest regularly to maintain a product, so as to meet increasing customer expectations. To this end, investment to provide new and improved existing facilities and accommodation on Haven sites in 2016 amounted to circa £60 million.

2.4 In particular, the Company seeks to ensure that the facilities at all of its sites are good quality and well maintained, necessitating a programme of replacing older facilities. In addition, Bourne Leisure needs to ensure that accommodation is of high quality, necessitating the upgrading and replacement of older caravan communities and the introduction of new caravan pitches. Significant investment is required to maintain and enhance the viability and attractiveness of all of the Company’s operations as “destinations” in their own right. A lack of investment would result in stagnating facilities attracting fewer visitors, and therefore, falling income. This harmful outcome for the Company would, in turn, have wider detrimental effects on the local economy (e.g. reduced employment and local spending).

2.5 Bourne Leisure, therefore, has active development programmes for the maintenance and enhancement of all of their sites and the Company’s sites are under continual review to ensure that the facilities provided are adapted to respond to changes in the tourism market.

2.6 The increased demand for higher grade accommodation and the price premium holiday guests are prepared to pay for higher grades of accommodation/ facilities has been recognised, and experienced by Bourne Leisure in recent years. The Company aims to meet the new levels of demand, with improved levels of accommodation, park standards, services, entertainment, eating establishments and other facilities.

2.7 There is clear evidence of increasing demand from visitors for good quality caravans in attractive settings at the Haven sites. In part, this is also driven by the ‘staycation’ effect, where the demand from UK residents to holiday ‘at home’ is growing. Bourne Leisure consider that the Lakeland Park can attract more visitors, that will result in a number of beneficial impacts.

Pg 3 Lakeland Leisure Park, Proposed Extension : Planning, Design, Access & Heritage Statement

3.0 The Application Site and Surrounding Area The Surrounding Area

3.1 Lakeland Leisure Park is located approximately 2 kilometres to the south of Flookburgh town centre. It is located to the north of Morecombe Bay, to the south of the Lake District National Park in Cumbria. The nearest train and bus station to Lakeland Holiday Park is in Cark-in- Cartmel which is 3 kilometres away from the Park. The Holiday Park

3.2 The Holiday Park comprises static caravans, touring caravan and camping pitches. An entertainment and service complex situated to the western edge of the Park provides sport and leisure facilities, including an indoor and outdoor swimming pool, as well as shops and restaurant/ bar. Throughout the Park there are a number of open spaces, including a golf course and the Otter Lake which provides opportunities for water-based activities and sports.

3.3 The Holiday Park is open from 21 March to 6 November annually. The Application Site

3.4 The application site extends to 4.7ha. It is located to the south-east of the Holiday Park and forms part of the existing 9-hole golf course. An existing twin unit caravan is located on the western part of the site.

3.5 The site is bound to the north by the historic Cark Airfield and to the east by the existing golf course. Directly to the south of the site is Morecombe Bay, with the Holiday Park’s feature Otter Lake, which is subject to a recent permission for extension, and existing caravan development to the west. The existing Owner’s Club building adjoins the western boundary of the application site.

Pg 4 Lakeland Leisure Park, Proposed Extension : Planning, Design, Access & Heritage Statement

Figure 3.3.1 View from the eastern edge of the site looking south west towards the existing developed part of the Park – the new Owners Club is visible

Figure 3.3.2 View from the eastern edge of the site looking north west to the established tree belt which encloses the existing developed part of the Park

Pg 5 Lakeland Leisure Park, Proposed Extension : Planning, Design, Access & Heritage Statement

Figure 3.3.3 View from the eastern edge of the site looking north across the existing golf course area that will remain

Pg 6 Lakeland Leisure Park, Proposed Extension : Planning, Design, Access & Heritage Statement

4.0 Planning History

4.1 The Holiday Park has seen growth and improvements over the years. A search of the planning history for the Park identifies a long history of planning permissions ranging from extensions to the Holiday Park, to smaller signage applications, as well as applications for the provision of leisure and retail facilities.

4.2 The most relevant planning permissions (related to expansion and improvement of the Holiday Park) listed on South Lakeland Council’s Planning Portal include:

 SL/2016/0940 - Installation of 39 static caravan pitches and extension of the existing Otter Lake with associated landscaping and infrastructure above and below ground. Application determined 8 February 2017.

 SL/2013/0795 – Leisure Reception/ Owners Lounge and Lakeside Facilities (Revised Scheme SL/2012/0859). Application determined 8 October 2013.

 SL/2012/0859 – Reduction in Number of Caravans, Formation of a Lake, Erection of Owners Building, Leisure Facilities and Associated Works. Application determined 31 December 2012.

 SL/2008/0756 – New Swimming Pool and Changing Facilities. Application determined 24 September 2008.

 SL/2006/1110 – Erection of Replacement Single Storey Amenity Building and Construction of Service Road and Parking and Creation of a New Caravan Sales Area. Application determined 19 December 2006.

 SL/2003/2015 – 9 Hole Golf Course, Extension to and Re-development of Caravan Site, Caravan Sales Area and office, Reception and Office and Associated Works and Landscaping. Application determined on 4 February 2004.

4.3 It is clear from the above that South Lakeland District Council has adopted a positive approach to past development proposals at Lakeland Leisure Park. The planning history demonstrates that the applicant is committed to an ongoing programme of improvements across the Park and that the Council has been supportive of these works.

4.4 The applicant is continuing to build out permission ref. SL/2012/0859 and a further ‘phase’ of static caravan pitches is being developed this winter around ‘Otter Lake’. The applicant will also be implementing permission ref. SL/2016/0940 this winter by digging out the ‘Otter Lake’ extension (an application to discharge the pre-commencement conditions has been submitted to the Council). Therefore, it is continually investing in the Park to improve the site layout and quality of accommodation.

Pg 7 Lakeland Leisure Park, Proposed Extension : Planning, Design, Access & Heritage Statement

5.0 Development Proposals

5.1 This application seeks full planning permission for;

“Installation of 85 hardstanding bases (for 85 static caravans) with associated infrastructure (above and below ground), new internal access road, pedestrian footpaths and landscaping”. Use and Amount

5.2 The proposed development seeks to provide 85 hardstanding bases for the provision of 85 static caravans. The bases will be installed within an area to the south-east of the Holiday Park, which currently forms part of the existing 9-hole golf course, and will provide additional self-contained holiday accommodation units. An existing twin unit caravan is to be removed in order to accommodate the development.

5.3 The hours of opening and annual operating period for the proposed development will be the same as those which apply to the operation of the existing Park. Scale and Layout

5.4 The static caravans will be laid out in small communities, positioned around landscape features including planting and water bodies. The internal access roads will structure and provide access the new ‘communities’ on the site. The proposed layout is shown on drawing W2138 CP01 which accompanies the application.

5.5 The new pitches will comprise;

 Seventy three 4m x 12m (13 x 40ft) static caravan bases;

 Six 13.7m x 6.7m (45 x 22ft) lodge bases;

 Six 12.8m x 6.7m (42 x 22ft) lodge bases.

5.6 Each new static caravan pitch will be accompanied by a parking space and will be fully serviced (see further details below). Landscape

5.7 Detailed Landscaping Plans have been prepared by the Andrew Davis Partnership, to integrate the proposals with the rest of the Holiday Park and the surrounding areas. A range of landscaping is proposed to enhance the proposed new static caravan communities and their amenities. This, in turn, will also provide new habitat areas. Along the northern boundary of the site a landscaped bund is proposed to establish a strong boundary to the site, continuing that which already encloses the existing developed part of the Park. It is anticipated that in 10 years or so the tree planting on the bund will be a strong feature. This boundary planting would be implemented as ‘advanced planting’ so that it can begin to establish before the new pitches are developed on the site.

5.8 The proposed landscape also includes five water bodies that will act as attractive features but will also offer a sustainable solution to surface water drainage and/or provide suitable habitats for great crested newts as part of the mitigation strategy.

5.9 An area of open space is proposed in the north eastern portion of the site to separate the new development from the listed structure located on the eastern boundary. This area will also provide amenity space for Park guests.

Pg 8 Lakeland Leisure Park, Proposed Extension : Planning, Design, Access & Heritage Statement

5.10 The golf course may be reconfigured in due course to account for the loss of the area where this new development is proposed. A further planning application will be submitted in due course, if this is necessary for the proposed works to alter the golf course.

5.11 The existing golf course area is very generously laid out and the reconfiguration is considered by the applicant to be a straight forward matter. The new layout will be able to retain the 9 hole golf course and will not have a greater impact on the environment than the existing. Access and Parking

5.12 The development will be serviced by new internal roads, extending from the existing access to the south-west of the site.

5.13 Each new caravan pitch will be provided one car parking space which will be constructed adjacent to the individual pitches.

5.14 Footpaths will be laid out providing accessible pedestrian links between the existing Park and the new development. Services

5.15 The proposed hardstandings will be fully serviced.

5.16 The new development will connect to the nearest existing part of the foul drainage network on the existing Park and given that the proposal represents a relatively small proportion of the total number of caravans at the Park, the additional foul flows generated from the development will be minimum and it is assumed readily accommodated in the public system.

Pg 9 Lakeland Leisure Park, Proposed Extension : Planning, Design, Access & Heritage Statement

6.0 Planning Policy Context

6.1 This section outlines relevant planning policy and guidance, identifying the key considerations which should be taken into account when determining the planning application. National Planning Framework

6.2 The National Planning Policy Framework (NPPF) sets the national planning policies for England. It introduces a presumption in favour of sustainable development as the basis for every decision. Sustainable development in relation to economic, environmental and social progress is emphasised (para. 7), as well as support for the provision and expansion of tourist and visitor facilities and creating a prosperous rural economy (para. 28).

6.3 The NPPF provides a strong pro-growth agenda for planning decisions, with particular emphasis on economic considerations. . It encourages biodiversity to be enhanced as part of development projects as well as taking the visual impact of development into account (paras. 61 and 109).

6.4 In determining applications in relation to heritage assets the NPPF states:

“…local planning authorities should require an applicant to describe the significance of the heritage assets affected, including any contribution made by their setting. The level of detail should be proportionate to the assets’ importance and no more than is sufficient to understand the potential impact of the proposal on their significance. As a minimum the relevant historic environment record should have been consulted and the heritage assets assessed using appropriate expertise where necessary...” (Paragraph 128)

6.5 It continues, “…when considering the impact of a proposed development on the significance of a designated heritage asset, great weight should be given to the asset’s conservation. The more important the asset, the greater the weight should be. Significance can be harmed or lost through alteration or destruction of the heritage asset or development within its setting. As heritage assets are irreplaceable, any harm or loss should require clear and convincing justification. Substantial harm to or loss of a grade II listed building, park or garden should be exceptional. Substantial harm to or loss of designated heritage assets of the highest significance, notably scheduled monuments, protected wreck sites, battlefields, grade I and II* listed buildings, grade I and II* registered parks and gardens, and World Heritage Sites, should be wholly exceptional”. (Paragraph 132).

6.6 Conversely, proposals which will lead to less than substantial harm to the significance of a heritage asset should be weighed against the public benefits of the proposal, including securing its optimum viable use (Paragraph 134).

6.7 Development should be directed away from areas at highest risk of flooding. A sequential test, risk based approach to the location of development to avoid where possible flood risk to people and property should be applied (Paragraph 100). South Lakeland Development Plan

6.8 The South Lakeland development plan comprises the Local Plan Core Strategy (October 2010) and the Saved Policies of the South Lakeland Local Plan (adopted in 1997 and amended in 2006).

Pg 10 Lakeland Leisure Park, Proposed Extension : Planning, Design, Access & Heritage Statement

South Lakeland Core Strategy

6.9 The Core Strategy (adopted October 2010) provides the strategic planning framework for the district, outside the boundary of the National Park. It seeks to maintain and enhance the strength of tourism across the area. High quality goods and services are required in the tourism market due to increased competition. Development at caravan sites is supported where there is no impact on conservation of the landscape, capacity of surrounding road system and parking or protection of wildlife, archaeological and geological features.

6.10 The following policies set by the Core Strategy are relevant to the Lakeland Holiday Park and the development proposals:

Policy CS1.1 – Sustainable Development Principles

6.11 Development proposals will be expected to contribute towards the sustainable development principles set out by this policy. The most relevant of these are set out below:

 “It is vital to protect the countryside for its intrinsic beauty, diversity and natural resources and also for its ecological, geological, cultural and historical, economic, agricultural, recreational and social value;

 There is a need to take account of and enhance landscape character and features particularly the AONB and coastal areas. The area’s role as a setting for and gateway to the Lake District and Yorkshire Dales National Parks should be developed;

 Support for tourism, which is a key driver of the local economy, needs to be balanced with protecting and enhancing the attractiveness of the area”.

Policy CS4 – Cartmel Peninsula Strategy

6.12 Lakeland Holiday Park is located within the Cartmel Peninsula and Policy CS4 of the Core Strategy therefore applies. Paragraph 5.7 of the Core Strategy highlights that “tourism is a fundamental part of the local economy”. However, local markets are becoming increasingly competitive and as a result, “tourist facilities need to become more specialised, offering higher quality goods and services, with a focus on added value”.

6.13 With regards to tourism, Policy CS4 states that the Council will seek to “maintain and enhance the strength of tourism across the area”.

Policy CS7.4 - Rural Economy

6.14 The Council will give favourable consideration to employment generating uses in rural areas where the proposal is of a scale in keeping with its surroundings, is not detrimental to the character or appearance of the landscape and does not give rise to unacceptable levels of traffic.

Policy CS7.6 - Tourism Development

6.15 This policy states that development should be of an appropriate scale and be located where the environment and infrastructure can accommodate additional visitors. Particular emphasis is placed on improving the quality of existing tourist accommodation and the need to broaden the range of accommodation available.

Policy CS8.2 - Protection and Enhancement of Landscape and Settlement Character

6.16 This policy requires proposals to demonstrate that their location, scale, design and materials will protect, conserve and, where possible, enhance the special qualities of the environment

Pg 11 Lakeland Leisure Park, Proposed Extension : Planning, Design, Access & Heritage Statement

associated with the nationally designated areas of the National Parks and Arnside and Silverdale AONB. This includes “the pattern of distinctive features such as hedges, walls, traditional buildings woodlands, hay meadows, wetlands, valleys, fells and rivers, and their function as ecological corridors for wildlife”.

Policy CS8.4 - Biodiversity and Geodiversity

6.17 This policy calls for development proposals to protect, enhance and restore the biodiversity and geodiversity value of land and buildings, as well as maximise opportunities for restoration, enhancement and connection of natural habitats. In addition to this, development proposals are expected to incorporate beneficial biodiversity and geodiversity conservation features. Development proposals that would have a direct or indirect adverse impact on nationally, sub- regional, regional and local designated sites will not be permitted, unless the benefits of the development clearly outweigh the impacts on the site and the wider network of natural habitats, or can be easily mitigated.

Policy CS8.6 - Historic Environment

6.18 This policy requires the safeguarding and, where possible, enhancing of historic environment assets, including their characteristic settings and any attributes that contribute to a sense of local distinctiveness.

Policy CS8.8 - Development and Flood risk

6.19 The Council states that development within the Environment Agency’s flood risk zones will only be acceptable when it is compatible with national policy and when the sequential test and the exception test, where applicable, have been satisfied.

6.20 New development will only therefore be permitted where it can be demonstrated that it would not have a significant impact on the capacity of an area to store floodwater; measures required to manage any flood risk can be implemented; surface water is managed in a sustainable way; provision is made for the long term maintenance and management of any flood protection and/or mitigation measures; and, the benefits of the proposal to the community outweigh the flood risk.

Policy CS8.10 - Design

6.21 This Policy requires the siting, design, scale and materials of all new development to be of a character which maintains or enhances the quality of the landscape or townscape. New development should protect and enhance key local views and features / characteristics of local importance.

Policy CS10.2 - Transport Impact of New Development

6.22 Development proposals are required to reduce the need to travel and should maximise the use of sustainable forms of transport appropriate to its particular location, with the level of traffic to be generated by the proposals accommodated by the existing road network, without detriment to the amenity or character of the surrounding area.

6.23 In addition, this policy requires development proposals to incorporate parking standards that are in accordance with any adopted and emerging sub-regional and/or local policy and guidance.

Pg 12 Lakeland Leisure Park, Proposed Extension : Planning, Design, Access & Heritage Statement

Saved Policies of the South Lakeland Local Plan

6.24 The Saved Policies of the South Lakeland Local Plan that are of relevance to this application are as follows:

Policy T6 – Caravan Site Development (Outside the Arnside-silverdale AONB)

6.25 This policy states that “Proposals for new caravan development, or small-scale extensions to existing sites, will only be permitted where there is no adverse impact on: (a) the conservation of the landscape and built environment; (b) the capacity of the surrounding road system and the adequacy of parking and access; or (c) the protection of wildlife, archaeological and geological features.”

Policy S2 – South Lakeland Design Code

6.26 All new development is expected to take account of the South Lakeland Design Code. This includes standards relating to the character, setting, context, proportion and detail and decoration of new buildings.

Policy S3 – Landscaping

6.27 This policy requires that a high standard of landscaping is provided within all new development, both for the initial scheme and its long-term maintenance. Where possible, existing landscape features shall be integrated into landscape schemes.

Policy S10 – Parking Provision in New Development

6.28 Off-street parking will be required for new development. The requirement for this will be based on Cumbria County Council’s published guidelines. Key Planning Considerations

6.29 The key policy requirements and tests set by the above planning policy documents are summarised below by topic heading with policy references in brackets.

 Principle of development;

 Flood Risk and Drainage;

 Landscape and Visual Amenity;

 Ecology;

 Heritage;

 Transport and Access; and

 Sustainability

Pg 13 Lakeland Leisure Park, Proposed Extension : Planning, Design, Access & Heritage Statement

7.0 Planning Principles and Policy Assessment Principle of Development

7.1 The NPPF expects the planning system to “proactively drive and support sustainable economic development to deliver…business…and thriving local plans that the country needs…” (para. 17). As part of this, the Government is committed to supporting sustainable rural tourism and in particular “the provision and expansion of tourist and visitor locations in appropriate locations where identified needs are not met by existing facilities…” (para. 28).

7.2 Within the South Lakeland Core Strategy, Lakeland is located within the Cartmel Peninsular and Policy CS4 of the Core Strategy therefore applies. The policy supports the principle of new tourism development in this location and highlights that the tourism industry is a fundamental part of the local economy and therefore the Council will seek to maintain and enhance the strength of tourism in the area.

7.3 Saved Policy T6 of the South Lakeland Local Plan supports proposals for small scale extensions to existing caravan site, subject to site specific matters, and Policy CS7.6 of the Core Strategy also supports the enhancement and expansion of tourism infrastructure in accordance with the Development Strategy. It states that development should be of an appropriate scale and be located where the environment and infrastructure can accommodate additional visitor levels. Emphasis is also placed on improving the quality and range of visitor accommodation provided.

7.4 Lakeland is an established Holiday Park located approximately 1.3 miles to the south of Flookburgh in Cumbria. The Holiday Park comprises a range of static caravan pitches, touring pitches and temporary camping pitches. There are also several large ancillary buildings located towards the west of the Park which provide services and facilities for holidaymakers.

7.5 The proposal seeks to improve and expand the accommodation on offer at the Park, ensuring the Park continues to be an attractive option for tourists/ visitors holidaying in Cumbria. The proposed development will, visually and environmentally, respects the existing layout and scope of the park and form a ‘natural’ extension. Therefore, it is considered to be in accordance with adopted and emerging planning policy.

7.6 Overall, the principle of this development is supported by local policies and national guidance. Flood Risk and Drainage

7.7 The NPPF encourages “opportunities offered by new development to reduce the causes and impact of flooding” (para 100). The proposed development is located within Flood Zone 3 and a Flood Risk Assessment therefore forms part of this application and should be read in conjunction with this Statement.

7.8 The Flood Risk Assessment concludes that the application site and the existing Holiday Park are defended by the existing coastal embankment which is maintained by the applicant. Existing embankment heights of 8.00 and 8.30 metres AOD afford adequate protection against the 200 year tidal forecast for this area and also extend to the 1000 year prediction area.

7.9 The FRA confirms that, in accordance with Policy CS8.8 of the Core Strategy, the proposals satisfy the Sequential and Exception Test and the proposed development may be completed without conflicting with the requirements of the NPPF.

7.10 The drainage from the application site will be in the forms of a SUDs solution draining naturally into the proposed waterbodies and, by control, into the surrounding watercourses for discharge into Morecambe Bay estuary as the existing regime for the Park.

Pg 14 Lakeland Leisure Park, Proposed Extension : Planning, Design, Access & Heritage Statement

7.11 Overall, the proposals are in accordance with the NPPF and Local Plan policy in relation to flood risk and drainage. Landscape and Visual Impact

7.12 The NPPF states that the planning system should contribute to and enhance the natural and local environment by protecting and enhancing valued landscapes (para. 101).

7.13 Policy CS8.2 of the South Lakeland Core Strategy requires proposals to demonstrate that their location, scale, design and materials will protect, conserve and, where possible, enhance the special qualities of the environment associated with the nationally designated areas.

7.14 The application site is identified within an area of ‘Sub type 2d - Coastal Urban Fringe’, as defined by Cumbria County Council’s Landscape Character Guidance and Toolkit (CLCG). The key characteristics of these areas include:

 “low lying flat land

 urban influences linked to tourism development;

 derelict buildings and major transport routes;

 strong man-made landforms on coastal edges;

 mixed land cover of mown grass, pasture, scrub and semi natural grassland; and,

 weak field patterns” (page 46).

7.15 The guidance for development in these areas seeks to “minimise the impact of new development by careful siting, design and high standards of landscape treatment, particularly where public views are affected” (page 49).

7.16 The location of the proposed development, which will appear as a ‘natural’ extension to the existing Holiday Park, is considered to be an appropriate form of development within this location and one which will have limited impact on the wider landscape character as it is well related to the existing built extent of the Park, particularly as a result of the integral landscaping scheme.

(i) Landscape Impact

7.17 Landscape design, by the Andrew Davis Partnership include proposals for an extensive landscaping strategy to provide both amenity planting and infrastructure planting to create buffers to the adjoining Airfield and enhance the screening of the site from external viewpoints. The proposed boundary planting along the northern edge of the site is identified on drawing W2138 CP01 as ‘advanced planting’ that would be installed prior to the static caravan pitches being developed. This planting would be read in the landscape as a continuation of the boundary tree screen that already encloses the existing developed area of the Park. Therefore, the tree planting along this bund will have some time to establish and develop as a screen to the development site before the pitches are created. The drawing, and Figures 7.1 and 7.2, show photographic examples of successful planting elsewhere on the Park which has established very well within a short period of 4 years.

Pg 15 Lakeland Leisure Park, Proposed Extension : Planning, Design, Access & Heritage Statement

Figure 7.1 Example of boundary planting on top of a bund which has established very well to screen the Park

Figure 7.2 Another example of boundary planting at the Park which is well established and has been successful

7.18 The landscaping strategy detailed on the accompanying drawings demonstrates that the character of the existing landscape will be protected and enhanced.

7.19 Additionally, the proposals comprise a low density development and the siting of the proposed pitches has been carefully considered to respond to the character of the existing landscape. The detailed static layouts are designed to create high quality ‘communities’ within a landscaped setting. The detailed design, therefore, ensures that the character of the landscape is protected. Figure 7.3 shows the high quality design of existing caravan development at Lakeland. A standard caravan design is proposed for all the units within the application site, to be in accordance with the existing appearance of the park.

Pg 16 Lakeland Leisure Park, Proposed Extension : Planning, Design, Access & Heritage Statement

Figure 7.3 An example of the high quality amenity planting implemented at Lakeland Leisure Park across one of the new caravan communities

7.20 Overall the proposed development is of a modest scale and its design, location and layout and is compatible with the surroundings as a result of the proposed extensive landscaping strategy.

(ii) Visual Amenity

7.21 The application site and proposed development was designed following a visual assessment from external viewpoints. The site was selected as appropriate for the proposed extension as it comprises an area of land which is well related to the existing Park, including the recently constructed ‘Otter Lake’ Lounge/Owners Club. The site is also enclosed on two sides by existing planting. The ‘triangle’ of land has been designed as an infill development which can ‘close off’ this corner of the Park.

7.22 The visual assessment was undertaken in July 2017 to examine the potential visual impact of the proposed development from the most prominent and publically accessible key viewpoints. The weather was overcast/wet, and pictures were taken on a digital camera with a lens set to a focal length equivalent to 50mm (on a 35mm frame), to provide a good representation of the normal ‘eye’ view.

Pg 17 Lakeland Leisure Park, Proposed Extension : Planning, Design, Access & Heritage Statement

1 Views from Redding Lane

7.23 As shown in Figures 7.4 and 7.5 the Park lies on lower land, to the South of Redding Lane (to the west of Boarbank Hall). The view is broad, including the airfield and also looks across the Park’s golf course to the northern boundary of the built up part of the Holiday Park. There are glimpsed views of caravans, but these are limited given the distance of the viewpoint. Due to the topography of the land and planting in the foreground of Figure 7.4, the application site is partly screened.

7.24 The woodland belt on the edge of the Holiday Park will be extended, as described above, to enclose and screen the expansion site.

Figure 7.4 View South from Redding Lane to the west of Boarbank Hall

Figure 7.5 View South from Redding Lane to the west of Boarbank Hall

7.25 In Figure 7.5 the application site is more visible but the planting belt will screen this area (as evidenced by the success of planting at and around the existing Holiday Park).

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2 View from Allithwaite Road

7.26 Figure 7.6 shows that the Park lies to the south of Allithwaite Road. From this viewpoint the developed part of the Park is not visible, as the existing substantial tree belt encloses and screens the Park. The view looks across the golf course, but the part that is the subject of this application is in a narrow part of the course and will be behind the new tree belt. This will screen the site, meaning it will not be visible from this viewpoint after a couple of years, so there will not be an impact.

Figure 7.6 View South from Allthwaite Road (near cluster of houses)

3 Views from Humphrey Head

7.27 Figures 7.7 and 7.8 show that the Park lies to the west of Humphrey Head. As these viewpoints are an elevated position and the topography of the lower land is generally flat, there are views across the south-eastern elements of the Park.

7.28 From the more southerly end of Humphrey Head (near the trig point, Figure 7.7), the new development is to be located in the ‘north-eastern triangle’ and from this viewpoint is visible, albeit the view if filtered by the existing landscaping and the distance of the site from the viewpoint. The proposed extensive planting to the northern boundary of the site will screen and enclose the site as per the remainder of the Park. Therefore, the development will not have an adverse impact from this viewpoint.

7.29 In Figure 7.8, the viewpoint also from Humphrey Head but the foopath along the western edge, views are still largely limited by the tree screening and it is only in the gap in this screen where caravan development can be distinguished. The application site is located in front of the caravan communities that are visible as it comprises the area where there is a gap in the boundary planting. Therefore, the site forms part of the existing ‘visual envelope’ of the Park. Notwithstanding this, the extensive boundary planting that is proposed along the northern boundary of the site, will ensure that the application site and newly developed area is screened and enclosed, as per the rest of the Park. On this basis, the development will not have a detrimental impact on the long distance views from this viewpoint on Humphrey Head.

Pg 19 Lakeland Leisure Park, Proposed Extension : Planning, Design, Access & Heritage Statement

Figure 7.7 View west from Humphrey Head (near trig point)

Figure 7.8 View west from footpath on the western edge of Humphrey Head

7.30 As shown by the above photographs, the development will integrate within the existing Park appearing as a ‘natural’ extension to the Holiday Park when viewed from the few external vantage points.

7.31 The scale and layout of the development will reflect the natural topography of the land and will integrate with the landscape due to the additional planting. This will comprise native, structural planting.

7.32 The landscape of the application site will also be enhanced through the introduction of the proposed ponds, which will create attractive landscaped features.

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7.33 Taking the above into consideration, the proposals are deemed to be in accordance with the requirements of the NPPF, Policy CS8.2 of the South Lakeland Core Strategy and Saved Policies S3 and T6 of the South Lakeland Local Plan. Ecology

7.34 Policy CS8.4 of the Core Strategy calls for development proposals to protect and enhance the biodiversity and geodiversity value of land and buildings, as well as maximise opportunities for restoration, enhancement and connection of natural habitats.

7.35 As the Holiday Park is located in close proximity to the Morecombe Bay Special Area of Conservation (SAC), Special Protection Area (SPA), Ramsar site and an Area of Special Scientific Interest (SSSI), an Ecological Assessment has been prepared by Tyler Grange (August 2017) and forms part of this planning application.

7.36 This concludes that the development would not be likely to trigger any planning policies which relate to the protection of either statutory or non-statutory nature conservation designations.

7.37 In addition, the Ecological Assessment highlights that whilst some loss of habitat of ecological importance in connection with the proposed development is inevitable, these losses would be more than compensated through the incorporation of habitats for wildlife incorporated within the green infrastructure within the proposed development and habitat creation and management on the adjacent golf course.

7.38 Furthermore, the development’s landscape proposals and the habitat creation and management on the adjacent golf course will also accommodate the recommended mitigation/compensation in respect of protected species.

7.39 Overall the Ecology Report concluded that on the basis of the implementation of the proposed mitigation and enchantment strategy, the proposed development is acceptable and in accordance with both national and local planning policy.

7.40 The proposals seek to protect and enhance ecological resources and therefore accord with Policy CS8.4 of South Lakeland Core Strategy and Saved Policy T6 of the South Lakeland local Plan. Transport and Access

7.41 The NPPF states that planning applications should explain how safe and suitable access to the site can be achieved (para. 32). Policy CS10.2 of the Core Strategy and Saved Policy S10 of the Local Plan highlight that the proposed development should be considered in context of the local transport network and must incorporate appropriate levels of car parking and cycle provision.

7.42 The construction of the 85 proposed pitches will take place in two phases with no more than 50 under construction at any one time. Each construction phase is likely to commence in September, and be complete by March the following year. This is timed to coincide with the existing holiday park’s off-peak and closed seasons. A Construction Traffic Management Plan is enclosed with this planning application, which puts forward measures to ensure the construction vehicles can safely access and leave the site, causing minimal disruption to the surrounding highway network and local communities

7.43 The application site is within walking distance to the existing Holiday Park’s facilities and services that are located in the western section of the Park, including the Wildlife Trail, Trail Explorer Route and Coastal Walk which can be easily accessed from the application site.

Pg 21 Lakeland Leisure Park, Proposed Extension : Planning, Design, Access & Heritage Statement

7.44 As shown on the Proposed Site Plan, the application proposes the introduction of 106 no. new parking spaces, with the provision of 2 per lodge. 1 per caravan and 9 visitor spaces. Parking is also provided within the communal car parking areas of the existing Park.

7.45 The new pitches will be accessible via new internal access roads and pedestrian footways, with the access arrangements into the Park itself remaining unchanged.

7.46 In the context of the existing Park, the proposed net increase of 85 pitches at the Park is considered to be modest. A Transport Assessment has been prepared which confirms the proposed works will generate an additional 23 trips in AM development peak hour (1000-1100) and 21 additional trips in the PM development peak (1500-1600). The assessments undertaken demonstrate that the resulting highway impact attribution to the additional traffic generated would be negligible on the operation of the local highway network.

7.47 In addition, the Transport Assessment concludes there are no overwhelming safety issues on the local highway network that may be exacerbated as a result of the proposed development and increased pedestrian/vehicular activity in the area.

7.48 A Travel Plan is also enclosed with this planning application which sets out a package of measures which promote safe and sustainable travel to/from Lakeland Leisure Park and aim to meet the following targets;

 5% increase of the number of staff travelling to work by sustainable forms of transport by 2022;

 increase the number of visitors using sustainable forms of transport whist staying at the holiday park by 2022.

7.49 Furthermore, the Travel Plan sets out a monitoring strategy which provides a breakdown of the monitoring activities and responsibilities in order to ensure the objectives are being met and the targets delivered.

7.50 Overall it is concluded that neither the construction phase nor the proposed development itself will have a severe impact on the local highway network in accordance with NPPF and in line with Policy CS10.2 of the Core Strategy, and Saved Policy S10 of the Local Plan. Sustainability

7.51 The NPPF states that a presumption in favour of sustainable development “should be seen as a golden thread running through both plan-making and decision-taking” (para. 14).

7.52 As already demonstrated, the proposed development will help to ensure that the Park can continue to contribute to sustainability objectives in terms of social, economic and environmental benefits. For example, the Holiday Park employs 200 people (on average) every year on a full time, part time and seasonal basis. The Park also utilises local contractors and suppliers where possible, including – Crowe Construction, Brooks Supplies, Miniheat, Bushels electrical, Lakeland verandas, Ulverston Glass, Lakeland dairies, Cartmel sticky toffee pudding, Kendal mint cake, Higginsons and clock tower supplies.

7.53 In addition, the Holiday Park and Bourne Leisure (Haven Holidays) brand also contributes to positively promoting the area as a tourist destination, which results in additional visitors (circa. 80,000 per annum to the Holiday Park) and spending in the locality, thereby benefiting the local economy.

7.54 This statement has assessed the impact of the proposals on the environment in terms of any adverse visual, amenity, traffic, ecological and landscape impacts. The assessment confirms that there is no adverse impact on any of these environmental factors and, indeed, the proposed

Pg 22 Lakeland Leisure Park, Proposed Extension : Planning, Design, Access & Heritage Statement

landscaping will enrich the biodiversity value of the site. This statement also demonstrates that subject to a range of recommendations being adopted, the proposal would not give rise to any issues with regard to flood risk and drainage.

7.55 The above assessment identifies that the proposals would represent sustainable development in accordance with the sustainable development principles in the NPPF.

Pg 23 Lakeland Leisure Park, Proposed Extension : Planning, Design, Access & Heritage Statement

8.0 Heritage Statement

8.1 The NPPF requires an assessment of the significance of any heritage assets likely to be affected by the proposed development including any contribution made by their setting (para. 128). Through Policy CS8.6 of the Core Strategy the Council seek to protect the significance of historic environment assets. This Heritage Statement has been prepared to address with national and local planning policy. Statement of Significance

8.2 ‘World War II fighter pens and other airfield remains and defences of the former airfield of RAF Cark’ are a scheduled monument (list entry number 1020988) comprising ten separate areas of protection and includes parts of the former World War II airfield known a RAF Cark (see Appendix 1). The list entry details are enclosed at Appendix 2 of this Statement.

8.3 Within the application site is what appears to be a brick-built roofless structure interpreted as a transformer plinth for housing electrical transformers (national grid reference: SD3782 7392) (see Figure 8.1) which is designated as part of the scheduled monument. The grid reference for the structure within the application site aligns to that referred to in the listing description as a transformer plinth.

Figure 8.1 Photograph of the heritage asset within the application site

8.4 The monument is designated as it comprises a good example of defending airfields against attack, the importance of which was realised before the outbreak of World War II. In relation the former airfield of RAF Cark, the reasons for designation by Historic England state:

Pg 24 Lakeland Leisure Park, Proposed Extension : Planning, Design, Access & Heritage Statement

“The remains of the south eastern part of the former airfield of RAF Cark survives exceptionally well with all six original dispersal pens remaining in virtually a complete state along with the upstanding remains of many of their support buildings including sleep shelters and transformer plinths, and the concrete footprints of other support buildings such as flight offices and blister hangars. Also located in the south east part of the airfield is a rare and well preserved example of a machine gun range. Dispersal pens are now rare survivals in England, and with their associated structures they illustrate well some of the measures taken to protect aircraft during World War II by means of dispersed and well-defended pens. Additionally the battle headquarters is another rare survival and together with the four surviving pillboxes and the anti-aircraft gun platform these features remain a good example of defence against the threat of capture. RAF Cark's first watch office, a single-storey structure superceded by a larger watch office during the progress of the war, survives well and is a rare example in north west England of this early World War II type of watch office.”

8.5 The application site currently comprises the golf course, forming part of the Holiday Park. Therefore, the setting of the heritage asset has already been altered and there is an existing visual relationship between the asset and the development of static caravans at the Park. However, the structure remains and is preserved on the site. The asset has historic significance as part of the designated monument group comprising the former airfield of RAF Cark. Assessment of Proposed Development

8.6 The initial proposals for the site excluded the transformer plinth and included a planted ‘buffer’ between the development boundary and the asset. At the pre-application meeting, following completion of the visual assessment work, a revised scheme was presented which included extensive planting to the northern boundary of the application site. To ensure the development is adequately screened from long distance views, the boundary planting was extended to the embankment. This scheme, therefore, included the heritage asset within the development boundary. The pre-application advice from the Council’s Conservation Officer indicated that in principle the proposed development could be acceptable subject to suitable mitigation; comprising a buffer between the development boundary and the asset, as initially proposed, or, the inclusion of the asset within the development boundary with suitable mitigation, for example, a surrounding amenity area with interpretation information. The latter approach forms part of the scheme which is the subject of this application.

8.7 To avoid harm to the setting of the asset, the development includes an area of amenity space around the transformer plinth. This open space includes a grass area along with two ponds, which are required as part of the ecological mitigation strategy. The amenity space around the asset is considered to comprise sufficient mitigation. The space will enhance the monument asset as an historic feature, enabling it to be viewed by Park guests and the historic importance of the transformer plinth and the surrounding site of the former airfield of RAF Cark to be understood.

8.8 The Holiday Park has been developed on part of the former airfield and is a substantial visitor accommodation facility in the area. As shown on the plan identifying the various assets comprising the scheduled monument (see Appendix 1), there are already a number of outlying structures around the built extent of the Park. These have been retained and preserved with the Park having been built up to the east and south of the assets. This proposal would develop the application site in a similar manner in relation to the transformer plinth. Therefore, it is considered that the setting and historic significance of the heritage asset, as part of the scheduled monument, would be preserved. The ‘buffer’ around the asset, discussed above, will further ensure this.

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8.9 The historic importance of the asset itself would be preserved by the proposed development and the setting clearly defined. Therefore, its significance is retained.

8.10 The listing description identifies the largest protected area of the monument which comprises a group of dispersed fighter pens with supporting structures and discusses this in detail. The proposed development will not impact the setting or significance of this largest protected area.

8.11 Overall, having regard to the assessment of the design proposals and the setting of the application site, it is considered that the proposals comply with NPPF and Policy CS8.6 of the Core Strategy.

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9.0 Summary and Conclusions

9.1 This Planning, Design, Access and Heritage Statement accompanies a planning application for installation of 85 additional static caravans at Lakeland Leisure Park. The proposed hardstanding bases will be accompanied by new internal access roads, car parking, pedestrian access and associated landscaping.

9.2 The proposed development is considered appropriate and will form a ‘natural’ extension to an established Holiday Park. The inclusion of an extensive landscaping scheme as part of the application will ensure that there are no adverse impacts on long distance views towards the Park. The landscaping will also ensure that the development integrates with the existing developed part of the Holiday Park and create high quality caravan communities as well as providing ecological benefits to ensure there are no adverse impacts on habitats/species on the site.

9.3 The proposals are in accordance with national and local planning policy and will deliver positive economic and social benefits.

9.4 The proposals form part of the continued enhancement and upgrading of Lakeland Holiday Park, as part of Bourne Leisure’s ongoing development plans. The proposed caravan bases will facilitate the provision of an improved standard of accommodation that will meet customer expectations.

9.5 In summary, the proposal will result in a sustainable development, helping maintain Lakeland as successful business, thereby continuing to grow the tourist accommodation available in the areas. In light of this, it is considered that planning permission is warranted.

Pg 27

Appendix 1: List Entry Plan

Heritage Category: Scheduling List Entry No : 1020988

County: Cumbria

District: South Lakeland

Parish: Lower Allithwaite, Lower Holker

Each official record of a scheduled monument contains a map. New entries on the schedule from 1988 onwards include a digitally created map which forms part of the official record. For entries created in the years up to and including 1987 a hand-drawn map forms part of the official record. The map here has been translated from the official map and that process may have introduced inaccuracies. Copies of maps that form part of the official record can be obtained from Historic England.

This map was delivered electronically and when printed may not be to scale and may be subject to distortions. All maps and grid references are for identification purposes only and must be read in conjunction with other information in the record.

List Entry NGR: SD 37939 74121 Map Scale: 1:10000 Modern Ordnance Survey mapping: © Crown Copyright and database right 2017. All rights reserved. Ordnance Survey Licence number 100024900. Marine mapping: © British Crown and SeaZone Solutions Ltd 2017. All rights reserved. Product licence number 102006.006. Print Date: 25 September 2017 This is an A4 sized map and should be printed full size at A4 with no page scaling set. Name: World War II fighter pens and other airfield remains and defences of the former airfield of RAF Cark

HistoricEngland.org.uk

Appendix 2: List Entry Description

Lakeland Leisure Park, Proposed Extension : Appendix 2: List Entry Description

World War II fighter pens and other airfield remains and defences of the former airfield of

RAF Cark List Entry Summary

This monument is scheduled under the Ancient Monuments and Archaeological Areas Act 1979 as amended as it appears to the Secretary of State to be of national importance. This entry is a copy, the original is held by the Department for Culture, Media and Sport.

Name: World War II fighter pens and other airfield remains and defences of the former airfield of RAF Cark

List entry Number: 1020988 Location

The monument may lie within the boundary of more than one authority.

County: Cumbria

District: South Lakeland

District Type: District Authority

Parish: Lower Allithwaite

County: Cumbria

District: South Lakeland

District Type: District Authority

Parish: Lower Holker

National Park: Not applicable to this List entry.

Grade: Not applicable to this List entry.

Date first scheduled: 23-Apr-2003

Date of most recent amendment: Not applicable to this List entry.

Lakeland Leisure Park, Proposed Extension : Appendix 2: List Entry Description

Legacy System Information

The contents of this record have been generated from a legacy data system.

Legacy System: RSM

UID: 34998 Asset Groupings

This list entry does not comprise part of an Asset Grouping. Asset Groupings are not part of the official record but are added later for information. List entry Description

Summary of Monument

Legacy Record - This information may be included in the List Entry Details.

Reasons for Designation

The importance of defending airfields against attack was realised before the outbreak of World War II and a strategy evolved as the war went on. Initially based on the principle of defence against air attack, anti-aircraft guns, air raid shelters and dispersed layouts, with fighter or `blast' pens to protect dispersed aircraft, are characteristics of this early phase. With time, however, the capture of the airfield became a more significant threat, and it was in this phase that the majority of surviving defence structures were constructed, mostly in the form of pillboxes and other types of machine gun post. The scale of airfield defence depended on the likelihood of attack, with those airfields in south or east England, and those close to navigable rivers, ports and dockyards being more heavily defended. But the types of structure used were fairly standard. For defence against air attack there were anti -aircraft gun positions, either small machine gun posts or more substantial towers for Bofors guns; air raid shelters were common, with many examples on each airfield; and for aircraft, widely dispersed to reduce the potential effects of attack, fighter pens were provided. These were groups together, usually in threes, and took the form of `E' shaped earthworks with shelter for ground crew. Night fighter stations also had sleep shelters where the crew could rest. For defence against capture, pillboxes were provided. These fortified gun positions took many forms, from standard ministry designs used throughout Britain and in all contexts, to designs specifically for airfield defence. Three Pickett-Hamilton forts were issued to many airfields and located on the flying field itself. Normally level with the ground, these forts were occupied by two persons who entered through the roof before raising the structure by a pneumatic mechanism to bring fire on the invading force. Other types of gun position include the Seagull trench, a complex linear defensive position, and rounded `Mushroom' pillboxes, while fighter pens were often protected by defended walls. Finally, airfield defence was co-ordinated from a Battle Headquarters, a heavily built structure of which under and above ground examples are known. Defences survive on a

Lakeland Leisure Park, Proposed Extension : Appendix 2: List Entry Description

number of airfields, though few in anything like the original form or configuration, or with their Battle Headquarters. Examples are considered to be of particular importance where the defence provision is near complete, or where a portion of the airfield represents the nature of airfield defence that existed more widely across the site. Surviving structures will often be given coherence and context by surviving lengths of perimeter track and the concrete dispersal pads. In addition, some types of defence structure are rare survivals nationally, and all examples of Pickett- Hamilton forts, fighter pens and their associated sleep shelters, gun positions and Battle Headquarters closely associated with defence structures, are of national importance.

There are some 18 types of watch office, some reflecting evolving techniques and technology associated with reporting and observation, and some a combination of roles, for example, with the incorporation of a meteorological (`Met') office within the building. There are also differences between the types of watch office found on fighter and bomber stations, while some individual structures display evidence for their adoption as the station's role evolved or changed. During the war years the watch office had one or two storeys; in the two storey examples, the bottom level housed the Met office, while air traffic control was confined to the upper level. At the start of World War II there were no air traffic control or operations (`Ops') staff working in the watch office, and only operational aircraft had radio. At this stage the duty pilot would log aircraft movements manually. It was only as the skies became busier that air traffic control and operations personnel were employed, and that radio became more widely used. Of the 500 or so examples originally built, some 220 watch offices survive, all of which constitute significant and symbolic structures. However, examples are considered to be of particular importance where they have an obvious and visual relationship with the flying field and other contemporary structures and buildings; where they survive as good examples of their type, perhaps with original fixtures; or where the station has operational significance, such as an association with the Battle of Britain.

The remains of the south eastern part of the former airfield of RAF Cark survives exceptionally well with all six original dispersal pens remaining in virtually a complete state along with the upstanding remains of many of their support buildings including sleep shelters and transformer plinths, and the concrete footprints of other support buildings such as flight offices and blister hangars. Also located in the south east part of the airfield is a rare and well preserved example of a machine gun range. Dispersal pens are now rare survivals in England, and with their associated structures they illustrate well some of the measures taken to protect aircraft during World War II by means of dispersed and well - defended pens. Additionally the battle headquarters is another rare survival and together with the four surviving pillboxes and the anti-aircraft gun platform these features remain a good example of defence against the threat of capture. RAF Cark's first watch office, a single-storey structure superceded by a larger watch office during the progress of the war, survives well and is a rare example in north west England of this early World War II type of watch office.

History

Legacy Record - This information may be included in the List Entry Details.

Lakeland Leisure Park, Proposed Extension : Appendix 2: List Entry Description

Details

The monument, which falls into ten separate areas of protection, includes parts of the former World War II airfield known as RAF Cark. The largest protected area lies on the south east part of the airfield and consists of a group of dispersed fighter pens each intended to house two aircraft, together with upstanding structures that include crew sleeping shelters and transformer plinths for electrical supply, and the concrete bases of flight offices and blister hangars. Elsewhere, largely scattered around the perimeter of the airfield, are the upstanding remains of a number of pillboxes, an anti-aircraft gun platform, a battle headquarters building from where defence of the airfield could be coordinated, an air raid shelter, and an early watch office.

Cark airfield lies on a flat tongue of land immediately north of Morecambe Bay and is flanked by marshes on its south west and south east sides. It was constructed early in 1941 and the site was laid out to support fighter operations in the north west by No.9 Group, Fighter Command, based at Barton Hall, Preston. However, on completion Cark was occupied initially by `F' Flight of No.1 Anti-aircraft Cooperation Unit who used Hawker Henleys and Westland Lysanders for target towing around Morecambe Bay to help train RAF and army gunners. In March 1942 the airfield passed to No.25 Group, Flying Training Command, and became No.1 Staff Pilot Training Unit, in order to train operational aircrews as instructors, with the Avro Anson being used for this task. By mid-1942 `R' flight of No.1 Anti-aircraft Cooperation Unit 1614 Flight was also operating from Cark using Henleys and Bolton Paul Defiants. In December 1942 `F' and `R' Flights were disbanded and immediately reformed as 650 Squadron, re-equipped with Miles Martinets as target tugs and Hawker Hurricane MK IV's. In November 1944 650 Squadron finally left Cark after which the airfield primarily became associated with test flying and the development of remote control target drones. During 1945 the recently formed Mountain Rescue Team moved to Cark. RAF Cark closed on December 31st 1945.

During World War II aircraft were considered to be vulnerable when on the ground, either from air attack or from possible ground attack. Elaborate precautions were thus taken to prevent any loss of aircraft when not in action. As a result aircraft were often held in dispersed pens located around the perimeter of the airfield but with easy access to the main runways. At Cark all six original dispersal pens survive in the south east part of the airfield. These are identified as `Hurricane Type' pens on the original airfield site plan and their layout consists of substantial earthwork banks arranged in an approximate `E' shape which partly enclosed two aircraft, one in each bay, in order to offer some protection from bomb blasts. At the rear of each pen, built into the earth bank, is a precast reinforced concrete air raid shelter with a brick-built entrance from each bay of the pen and a brick-built exit to the rear.

A number of support buildings servicing the needs of the dispersal pens are included within the scheduling. These buildings provided the means by which the aircraft housed within the pens could be made ready for duty under `scramble' conditions and include two surviving brick and concrete sleeping shelters, three surviving transformer plinths, the concrete bases of five flight offices and the concrete bases of three blister hangars. The sleeping shelters provided night accommodation for up to 22 airmen each. Internally there were cubicles separated by brick partitions either side of a central passageway with two bunks provided

Lakeland Leisure Park, Proposed Extension : Appendix 2: List Entry Description

per cubicle. Two brick-built roofless structures interpreted as transformer plinths for housing electrical transformers for providing power to the nearby structures are located close to the dispersal pens whilst a third stands to the south at SD37827392. The flight offices provided accommodation for flight officers and clerks while the blister hangars were mainly used for aircraft storage and maintenance. Also included within the scheduling at the south east side of the airfield is a machine gun range consisting of a partly open-fronted brick and concrete building which functioned as the firing position, and a buttressed, brick- walled, earth-banked target setting.

On the northern side of the airfield runways, at SD37067471, stands the airfield's first watch office, a single-storey building from where a good view over much of the airfield could be obtained. It housed a duty pilot who would log aircraft arrivals and departures. As the airfield became busier this watch office was superceded by a larger structure housing air traffic or operations staff.

Nearby, at SD37197479, stands the battle headquarters. It is the standard Air Ministry design 11008/41 which became operational after mid-August 1941. It was sited to give a good view over the whole airfield and acted as the command post for the airfield defence commander, whose office was central to the structure. Telephone connections and runners to defence posts such as pillboxes enabled the commander to monitor the development of an attack on the airfield, and to excercise control over the whole defence force, as well as receiving incoming information on the movement of enemy troops and aircraft. The battle headquarters is surrounded by an earth bank and is constructed of concrete and brick. Internally there is an office, messenger's room, sleeping accommodation, PBX (or telephone) room and chemical closet, while at the western end there is an observation post with a narrow viewing slit all the way around.

Four pillboxes forming part of the airfield defences still survive. Upon the airfield itself, at SD37007430, there is a cantilever mushroom-type pillbox about 6m in diameter with 360 degree vision. It contains an internal ricochet wall and an entrance on its west side. Three other pillboxes are located immediately outside the airfield with two being on the south west side and the other on the south east side. That at SD36907419 is a five-sided brick and concrete structure of local design with gun loops on its south west and north sides and an entrance on the south; that at SD36937404 is a type-22 hexagonal concrete pillbox with gun loops on each face and an entrance on the east; and that at SD37947412 is another cantilever mushroom-type with an entrance on its north. Another defensive feature on the airfield's south west side is a 40mm Bofors anti-aircraft gun platform located at SD36997367. At SD36977424, close to the mushroom-type pillbox on the airfield, there is a Stanton air raid shelter of concrete construction with a brick entrance at its western end. Much of its protective earth banking has eroded away.

A number of features are excluded from the scheduling. These include all fences and fence posts, the sea defence embankment upon which those pillboxes and the anti-aircraft gun platform situated around the perimeter of the airfield are located, a kerb adjacent to the five- sided pillbox, a concrete retaining wall and short fence adjacent to the type-22 pillbox, and all paving, steps, gravel paths and a tarmaced road on and adjacent to the battle headquarters. The ground beneath all these features is included.

Lakeland Leisure Park, Proposed Extension : Appendix 2: List Entry Description

MAP EXTRACT The site of the monument is shown on the attached map extract.

Selected Sources

Books and journals RAF Cark Other SMR No. 6342, Cumbria SMR, Lower Allithwaite WWII pillbox, (1989)

National Grid Reference: SD 36897 74190, SD 36928 74043, SD 36970 74272, SD 36990 73666, SD 36997 74303, SD 37058 74703, SD 37214 74788, SD 37818 73928, SD 37926 74367, SD 37939 74121

875/44

FLOOD RISK ASSESSMENT

TO ACCOMPANY

PLANNING APPLICATION FOR EASTERLY PARK EXTENSION

AT

LAKELAND LEISURE PARK MOOR LANE FLOOKBURGH GRANGEGRANGE----OVEROVEROVER----SANDSSANDS CUMBRIA

AUGUST 2017 Lakeland Leisure Park 875/44 Flood Risk Assessment

CONTENTS

1.0 INTRODUCTION

2.0 EXISTING SITE DESCRIPTION

3.0 THE PROPOSAL

4.0 EXISTING FLOOD CONDITIONS

5.0 FLOOD RISK ASSESSMENT

6.0 THE SEQUENTIAL TEST

7.0 THE EXCEPTION TEST

8.0 CONCLUSIONS AND RECOMMENDATIONS

APPENDICES

APPENDIX A --- LOCATION PLAN (REVISION A)

APPENDIX B --- MASTERPLAN SHOWING PROPOPROPOSEDSED EXTENSION (REVISION A)

APPENDIX C ––– PROPOSED LAYOUT (1:500 @ A1)

APPENDIX D ––– APPROVED ZONAL PLAN CONSENTED IN 2005

APPENDIX E ––– LETTER DATED 31 STSTST AUGUST 2012 FROM THE ENVIORONMENT AGENCY

APPENDIX F --- ENVIRONMENT AGENCY FLOOD MAP

APPENDIX GG---- ENVIRONMENT AGENCY PREDICTED FLOOD DEPTHS (UNDEFENDED)

Lakeland Leisure Park 875/44 Flood Risk Assessment

1.01.01.0 INTRODUCTION

1.1 This Flood Risk Assessment (FRA) has been produced to accompany a Planning Application for an easterly extension to Lakeland Leisure Park, Moor Lane, Flookburgh, Nr Grange-Over-Sands.

1.2 The Planning Application is being submitted on behalf of Bourne Leisure /Haven Ltd who are the owners and operators of Lichfields Lakeland Leisure Park.

1.3 The FRA has been compiled in accordance with the previous requirements of PPS25 Development and Flood Risk (December 2006) and which has now been incorporated within the National Planning Policy Framework (NPPF).

1.4 The Application Site fits in an area which has the benefit of Planning Consent for a Golf Course under an Extant Consent SL/2003/2015 dated February 2004. A copy of the approved plan is attached at Appendix D and this is dated 2005 as an agreed amendment to the 2004 consent.

1.5 Planning Consent was granted in 2012 for the construction of the existing lake and the reduction in the permitted number of caravans on that site from 205 to approximately 150 (number not specific). The actual number of caravans will be 146 on completion of this area in 2018 and this is in the zone consented for 205 on Appendix D.

1.6 A more recent consent was granted for an extension to the existing lake which would result in an eventual number of caravans on that zone of 83 compared with the 95 consented on Appendix D.

1.7 These revised thoughts over the original Planning Consent demonstrate the desire for less intensive development at Lakeland Leisure Park and within the zone of extension, the heads of population will not increase beyond those which were envisaged in the 2004 Planning Consent.

Lakeland Leisure Park 875/44 Flood Risk Assessment

2.02.02.0 EXISTING SITE DESDESCRIPTIONCRIPTION

2.1 The Application Site is shown edged red on Appendix A and comprises 4.7 Ha. The site is wholly contained within the existing Golf Course consented in 2004 and this will be reconfigured to accommodate the development. To the south east of the site is the EA maintained water course East Plain Delph Cut (Main River) located behind the substantial coastal defence embankment which defends the entire caravan park and some adjacent properties. The remainder of the site under the control of the Applicant is edged in blue and amounts to approximately 76.1 Ha in total.

2.2 To the West of the Application Site is an unnamed watercourse which runs due north/ south and connects into East Plain Delph Cut. We do not believe that the Environment Agency manage and maintain this particular water course and as such this is undertaken by the caravan park. However, this water course is labelled on the EA website as Mains River.

2.3 The site forms part of the historic Cark Airfield and the coastal defence was put in place to protect the airfield, subsequently offering protection to the campsite which became the holiday park.

2.4 The site is extremely flat and the general level approximates to 5.0 m AOD. The topographic survey is mostly shown on Appendix C.

2.5 The general watercourses offer drainage to the developed sections of the holiday park and form part of the original airfield regime of drainage. These drain into the East Plain Delph Cut to the South which flows to the South – West corner of the holiday park and discharges into Morecambe Bay estuary through tidal flaps which are backed up by an over-pumping arrangement which was installed in 2008 to assist the park drainage during tidal lock conditions where gravitational outflow is not possible. This has proved to be effective and with a robust maintenance regime on all the drainage and watercourses throughout the park, it is now well drained apart from older areas which still require redevelopment and which are not the subject of this FRA.

Lakeland Leisure Park 875/44 Flood Risk Assessment

3.03.03.0 THE PROPOSAL

3.1 The proposal is shown at Appendix B in the context of the existing holiday park. It comprises 85 static caravans with some retained open space, feature landscaped areas and 3 small water bodies.

3.2 The water bodies will act as attractive features but also will offer attenuation of surface water from the immediately surrounding caravan impermeable areas and offer a sustainable solution to surface water drainage.

3.3 Similar sustainable solutions have been introduced on the main lake development to the west of this application site and are also agreed in principle within the proposed lake extension. Apart from offering a sustainable solution which is a recognised requirement of such development, it also ensures that there is not an overwhelming of the existing water courses and the exit pump arrangement.

3.4 The caravan bases will be insitu concrete and the road and parking bay surfaces plus the access paths to the caravans will be a mixture of porous tarmac and small amounts of porous block paved areas.

3.5 In addition to the porous nature of the tarmac and block paved areas, to aid further attenuation, storage crates will be installed in groups below each decking area which are gravelled serviced to enable the rainwater pipes from the roofs of the caravans to be directed by a perforated land drain down each side of the base into the storage crates and taking advantage of the free draining soils which prevail on this site. This will ensure that the maximum amount of surface water is directed to ground even though the water table is relatively high and fluctuates. This will offer more sustainability and not overwhelm the proposed water bodies.

3.6 Additionally, it is proposed that perforated metro drain, which is a recognised form of land drain, will be installed alongside each road such that in periods of heavy rainfall, any run off from the porous tarmac which cannot seep within the timeframe will be collected in the land drains and directed to ground in similar form to the storage crates. These are recognised methods of soakaway and sustainable drainage.

Lakeland Leisure Park 875/44 Flood Risk Assessment

4.04.04.0 EXISTING FLOOD CONDITIONS

4.1 Lakeland Leisure Park, the remainder of Cark Airfield and land to the North heading up to Flookburgh rely heavily upon the coastal defences which are in place and shown on Appendix A.

4.2 Without the costal defence, the area would flood tidally and the undefended flood depths are shown at Appendix G which indicate across the development site that in the event of 1000 year tidal inundation, the Application Site would flood to a depth of approximately 2.7 metres were it not for the coastal defence embankment.

4.3 The Environment Agency flood mapping is appended at Appendix F and shows that the whole of the site including the surrounding areas apart from higher ground at Raven Winder and Cannon Winder are also susceptible to flooding within Flood Zone 3. The Application Site is deemed to be within Flood Zone 3 (a) as it is defended by the coastal embankment. Without this defence the area would reside in Flood Zone 3 (b).

4.4 Appendix F shows the extract from the Environment Agency website for flood zones and clearly shows that the line of the flood defence offered by the embankment and the blue and white hatching which denotes an area benefiting from flood defences as flood zone 3 (a).

4.5 Further potential flooding results from rainfall and fluvial effects in the watercourses which, without adequate outfall, would overtop due to the entrapment created by the coastal defence and high tide conditions.

4.6 Therefore, the existing flood potential on the Application Site and the surrounding area is a combination of tidal and fluvial inundation. The fluvial potential is dealt with by the over pumping arrangement and natural gravitation during low tide to maintain the watercourses at a controlled level to permit drainage from the land.

Lakeland Leisure Park 875/44 Flood Risk Assessment

5.05.05.0 FLOOD RISK ASSESSMENT

5.1 The Application Site and the remainder of the holiday park and surrounding area reside within the high probability Zone 3 (a) and depend upon the robust defence of the coastal embankment. Dependence is also placed upon the maintenance of the watercourses throughout the site and the over-pumping arrangement installed in 2008.

5.2 Table 2 of the NPPF lists the various vulnerability classifications. Sites used for holiday or short let caravans and camping are classified as “more vulnerable” with regard to flood risk. All the caravans on Lakeland Leisure Park, including the Application Site are for holiday or short let and none are residential.

5.3 Table 3 of the NPPF tabulates the comparison between each of the flood risk zones and the vulnerability classification. In Zone 3 (a), more vulnerable development of the nature proposed would be permissible as long as it passes the Exception Test which is required for this classification.

5.4 In the absence of the existing coastal defence embankment, there would be significant danger to life and it is quite clear that the holiday park would not exist were it not for the protection afforded by the embankment.

5.5 In 2008 and onwards, the Applicant invested over £3 million in repair and strengthening of the embankment with the approval of the Environment Agency who at that time had the responsibility for “holding the line” but this required considerable investment which fortunately was available from the Applicant to protect their asset.

5.6 The Shoreline Management Plan (SMP) for this section of Morecambe Bay contains a paragraph confirming that the maintenance of the embankment is the responsibility of Bourne Leisure/Haven (the Applicant) and this maintenance is ongoing on a regular basis through their Consultants in conjunction with the Environment Agency. Not only does this maintenance protect the holiday park but also assists in protecting other properties to the North which otherwise would be affected in the event of a breach.

5.7 The crest level of the southern embankment is 8.00 m AOD and the crest on the western section is 8.30 m AOD. Ignoring wave action which could overtop the embankment at high tide during storm conditions, these levels clearly offer protection against the 200 year tidal level of approximately 7.37 m AOD and also the 1000 year tidal prediction of approximately 7.64 m AOD with a minimum of 500mm factor of safety in the worst event.

5.8 Therefore, with continuing maintenance of the embankment, the watercourses and the over-pumping arrangement, the risk of flooding of the Application Site and the holiday park are kept to a minimum and it is therefore safe to apply the criteria related to Flood Zone 3 (a) with regard to the Sequential Test and the Exception Test laid down in the NPPF.

Lakeland Leisure Park 875/44 Flood Risk Assessment

5.9 Recent discussions have taken place with the Consultants who act for Bourne Leisure/ Haven and they have confirmed that their monitoring procedure is twice yearly by agreement with the Environment Agency for whom they effectively act as Agents. One of these monitoring visits is to take place very shortly and the intention is to bolster up a toe of the embankment where it abuts the marsh land to the north west of Lakeland Leisure Park. This is a form of ongoing enhancement and regular repair to the embankment to ensure that it is a continually robust form against any deterioration which can take a hold if weaknesses appear.

5.10 Stockpiles of rip rap stone are kept at all times on the park premises and in the vicinity of the embankment so that if a monitoring visit identifies work which is required, this will be cleared by the Consultants with the Environment Agency for work to be undertaken which constantly keeps on top of the condition of the embankment.

5.11 The Consultants advise that currently the estuary sands have returned and are now approximately 2m higher against the outside of the embankment than they were when the worst problems occurred in 2008 and this is typical of the fluctuating nature and mobility of this tidal area. Also, the outlet channels have all but disappeared which means that when the tide comes in, there is not a concentrated flow of water heading towards the holiday park. That is a current condition and could change.

5.12 The caravans are placed on bases which vary from 5.40 m to 6.00 m AOD, with the floor levels a further 600mm minimum above those levels, thereby ensuring the same protection against maximum possible water levels.

5.13 This constant monitoring and repairs as necessary to the substantial embankment ensure the continued protection of Lakeland Leisure Park and justify its designation as flood zone 3 (a).

Lakeland Leisure Park 875/44 Flood Risk Assessment

6.06.06.0 THE SEQUENTIAL TEST

6.1 To satisfy the requirements of the NPPF it is necessary that this proposal is considered under the requirement for a Sequential Test.

6.2 The NPPF outlines the sequential preference for new development to be located in Flood Zone 1 where possible. If this is not possible or reasonable then the preference should be shifted to Flood Zone 2 as long as consideration is given to the flood vulnerability of the proposed development using Table 2 of the NPPF. Where this is not possible or reasonable then Flood Zone 3 may be considered but at all times the process ensures that the proposed development is located within an area with the least flood risk where possible or reasonable.

6.3 This FRA identifies the Application Site to be in Flood Zone 3 (a). The 85 proposed static caravans are effectively relocated from other areas which are consented for higher numbers but which will not be developed to that extent. Reference is made to Appendix D where it can be seen that 205 caravans were consented in the largest area of extension and this will now contain 146 when completed. Therefore there would be 59 caravans unfulfilled in this area. Similarly on the area consented for 95 caravans there will only be 83 when the lake extension area is completed which leaves 12 caravans undeveloped within this area.

6.4 On the 2 other blue zones to the north of the extended consent there is a total of 143 caravans permitted and there will only be 106 when the final 19 have been completed. This leads to 37 caravans which are permitted but not developed.

6.5 The total of these undeveloped residual quantities is 108 and therefore the 85 caravans which are now proposed will still fall under that originally consented number.

6.6 The logical area for the extension to accommodate these caravans to be constructed is to the east of the existing park within the ownership boundary. Elsewhere, it would be in an isolated position closer to the listed structures of the historic air field which would be deemed to be unacceptable. It would also lead to servicing difficulties and the reconfiguring of the Golf Course would be less possible.

6.7 Therefore, it is considered that the Sequential Test is satisfied in concluding that there is no suitable or sensible alternative available for the development outside Flood Zone 3 (a) or less vulnerable within the ownership of the Applicant.

Lakeland Leisure Park 875/44 Flood Risk Assessment

7.07.07.0 THE EXCEPTION TEST

7.1 The proposed development is classified as “more vulnerable” because it comprises caravans for holiday or short let use and Table 3 of the NPPF requires that for such development, the Exception Test needs to be satisfied.

7.2 The Exception Test requires that benefits stemming from the proposal are weighed against the flood risk associated with the classification to ensure that the proposal is exceptional through those benefits.

7.3 There are benefits which stem from the scheme and the relaxed nature of the recent and proposed layouts. The water bodies offer ecological enhancement, the environment within which the caravans are sited is more spacious and pleasing for the holiday makers, and the water bodies which have been created and which are to be created together with the attenuation measures balance up the increase in impermeable area resulting from the development.

7.4 The proposal within this Application continues a high capital investment by the Applicant and this drives the need to continue to maintain the embankment which not only benefits the holiday park but others.

7.5 For these factors, it is concluded that the Exception Test is satisfied and that this development in Flood Zone 3 (a) should be permitted with regard to flood risk.

7.6 The development should be supported by suitable flood warnings and an evacuation plan which can be agreed with the Environment Agency and can also be placed as a Condition on the Planning Consent.

Lakeland Leisure Park 875/44 Flood Risk Assessment

8.08.08.0 CONCLUSIONS AND RECOMMENDATIONS

8.1 The Application Site and the remainder of the holiday park are defended by the existing coastal embankment which is maintained by the Applicant by agreement with the Environment Agency and confirmed within the SMP.

8.2 The embankment heights of 8.00 and 8.30 m AOD afford adequate protection against the 200 year tidal forecast for this area and extend to the 1000 year prediction also.

8.3 Dependence will continue upon the maintenance of the existing drainage watercourses throughout the site and the over-pumping provision during tidal lock conditions to cope with potential fluvial flooding.

8.4 The 3 water bodies will offer additional storage for rainwater.

8.5 The drainage from the Application Site will be in the form of a SUDS solution draining naturally into the lake and, by control, into the surrounding watercourses for discharge into Morecambe Bay estuary as the existing regime.

8.6 The benefits resulting from this Application in the form of more relaxed layouts and attenuation ensure that the proposals satisfy the Exception Test for more vulnerable development in Flood Zone 3 (a) which is the designation for this site.

8.7 The Sequential Test is satisfied by determining that there are no other suitable alternative sites within the control of the Applicant than the one which is proposed.

Lakeland Leisure Park 875/44 Flood Risk Assessment

APPENDIX A

Lakeland Leisure Park 875/44 Flood Risk Assessment APPENDIX B

Lakeland Leisure Park 875/44 Flood Risk Assessment

APPENDIX C

Lakeland Leisure Park 875/44 Flood Risk Assessment APPENDIX D

Lakeland Leisure Park 875/44 Flood Risk Assessment APPENDIX E

Lakeland Leisure Park 875/44 Flood Risk Assessment APPENDIX F

Lakeland Leisure Park 875/44 Flood Risk Assessment APPENDIX G