ALL SAINTS GOLF CLUB IP28 6JQ

DESIGN & ACCESS STATEMENT

for

FULL PLANNING APPLICATION

to

Change use of part of golf course to 15 caravan/lodge holiday homes with new access from A1101; construction of new access road, parking spaces & associated infrastructure

1. INTRODUCTION

1.1: This statement has been prepared to accompany an application for full planning permission for the use of land for siting 15 timber holiday lodges at All Saints Hotel & Golf Club, Fornham Saint Genevieve.

The lodges are all mobile wheeled units fabricated off-site & brought to site in two parts & placed on grass reinforcement mesh bases. They are caravans for the purposes of the Caravan Sites & Control Development Act 1960 & will be required to be licensed accordingly by the Council prior to occupation.

1.2: The lodges would essentially be of “generic” form & style. There are many available variations on a similar theme but as a guide details of typical legislation compliant lodges have been submitted as part of the application.

1.3: The remainder of the introduction sets out the background to this application & describes the application proposals. Section 2 describes the application site & its location. Section 3 sets out the relevant Planning Policy context & Section 4 examines the proposals within such context. Section 5 provides a brief summary & conclusion of this statement.

1.4: The application as submitted provides a Location Plan illustrating the broader site of All Saints Golf Club including the Hotel, Health Club & Spa, 18 hole Golf Course & associated infrastructure.

A larger scale block plan indicates the access point & the zone within the south western corner of the existing golf course within which the proposed holiday lodges are to be sited.

Detail drawings & associated information for the access point are included with this application.

1.5: M & D Developments acquired the All Saints Hotel & Golf Club in 2015. The premises were at that time in need of major investment & improvement both in terms of the hotel facility & associated spa, gym, swimming pool & golf course. Many such improvements to the hotel & associated facilities have since been carried out.

Notwithstanding this it has not been possible to make the golf course itself financially viable. This is almost certainly in part due to competition from the nearby Bury St Edmunds & Golf Clubs but is also related to the expansive layout of the All Saints course.

1.6: All Saints golf course extends to some 125 acres. An 18 hole golf course can be accommodated within 80 acres. A feasibility study of the golf course & greens have revealed that the arrangement of the course is inefficient & could be improved to create a more easily managed & popular leisure facility. A great deal of time & expenditure is currently being wasted maintaining peripheral areas that are not required.

The study has revealed an area of the course in the far south west corner that can be utilized for compatible alternative leisure activities. This is the area within which the site of the application proposal is located.

2. SITE LOCATION & DESCRIPTION

2.1: All Saints Hotel & Golf Club is located to the north of Bury St Edmunds within the administrative area of Bury St Edmunds District Council. The golf course abuts the northernmost suburban developments of the town & is in practical terms a part the developed envelope of Bury St Edmunds itself.

The principal existing access to the Hotel & Golf Club complex is from the B1106 in the north eastern corner within the of Fornham St Genevieve. It is the B1106 which also forms the northern boundary to the site.

The east flank of the site is bounded partly by the settlement of Fornham St Genevieve itself & partly by the running north-south which forms part of this boundary.

The southern boundary adjoins the Lark Valley Business Park whilst the western flank adjoins Pigeon Lane which is a small dead end lane becoming a track at its southern end before it adjoins the A1101 Mildenhall Road opposite the Northern Way Industrial Estate.

The northern half of Pigeon Lane is lined with a ribbon of some 25 semi-detached houses on the eastern side which back onto the golf course.

2.2: A major feature of the golf course & site is the River Lark which enters the site almost centrally on the northern boundary & weaves diagonally across the site to exit in the south east corner.

There are many linked ponds & water features across the golf course with a central bridge feature which currently dictates the means of access from one part of the course to another. The river creates a central floodplain the extent of which (Zone 2 & 3) is indicated on the Flood Risk Assessment documents. The site proposed for lodges is outside this floodplain & remains unaffected.

2.3: Whilst essentially “flat” in nature the golf course is gently undulating & such topography is principally the result of man-made features related to golf course layout.

There are a significant number of trees of varying quality across the western sector principally poplar & willow. The northern, western & southern boundaries are all heavily tree lined. The residential properties along Pigeon Lane are screened by a continuous line of mature conifer.

2.4: The major significant inward views of the golf course are from the B1106 along the northern boundary. This boundary is flanked by a continuous line of Lombardy Poplars & the golf course is glimpsed through these trees. The lodge site is distant (850m+) & not visible from this point.

The area of the site proposed for lodges is tucked in the very south western corner of the golf course along the boundary with the Lark Valley Trading Park & the A1101 Mildenhall Road.

Access is via a previously approved junction off the A1101. The lodges themselves will be heavily screened with existing & enhanced tree planting on the southern side of this access & not visible from the highway. The northern side boundary adjacent to the access junction is to be left with the existing mature trees to maintain the available distant views into the open landscape of the golf course.

The lodges are screened within the open landscape by siting them behind the long arc of existing dense conifer trees which serve to curtail open views from the A1101. The lodges do not interrupt the available open views across the golf course.

3. PLANNING POLICY CONTEXT

3.1: In seeking permission it is noted that the proposed structures would meet the legal definition of a caravan & therefore do not require specific planning permission in their own right. Therefore the application seeks a change of use for part of the existing site from one recreation/leisure use to another in the form of a holiday park.

It is also relevant that the proposal does not replace an existing leisure activity but supplements it by utilizing redundant parts of an existing golf course with a compatible use. Whilst the development proposals must be considered in policy terms it is necessary to consider relevant issues in this light.

3.2: The National Planning Policy Framework sets out the Government’s planning policies for & how these are expected to be applied. It is a requirement that planning permission must be determined in accordance with the development plan unless material considerations indicate otherwise. The NPPF (although recently revised) retains a presumption in favour of sustainable development.

In terms of this application the most relevant parts of the Development Plan are the St Edmundsbury Core Strategy & the Joint Development Management Policies Document.

3.3: Interpretation of policies in terms of this application requires a clear understanding of the term “rural”. Policies aimed at promoting “rural economy” and mindful of rural issues envisage factors affecting remote or isolated communities. It has been noted that All Saints Hotel & Golf Club physically adjoins & is part of Bury St Edmunds. It is not a remote or isolated site in the countryside.

With these observations in mind the Policy of primary relevance would still need to be considered as the Joint Development Management Policy DM34: Tourism Development.

This is illustrated below:

Policy DM34: Tourism Development

Planning applications for new tourism facilities, including overnight visitor accommodation (hotels, bed & breakfast, self-catering, holiday lodges, static and touring caravans and tenting fields), or improvements and extension to existing facilities, will be permitted provided that: a. the proposals are connected to and associated with existing facilities or located at a site that relates well to the main urban areas and defined settlements in the area and can be made readily accessible to adequate public transport, cycling and walking links for the benefit of non-car users; b. it would not adversely affect the character, appearance or amenities of the area and the design of a standard acceptable to the local authority; c. vehicle access and on-site vehicle parking would be provided to an appropriate standard.

The larger urban areas (Market Towns and Key Service Centres), will be the focus for larger scale tourism activities and overnight accommodation in accordance with the requirement to concentrate development at the most sustainable locations.

In rural areas any tourism activity/proposal must, in addition to criteria a., b., and c. above, seek to support the existing local community services and facilities, and: d. have no significant adverse impact on nature conservation, biodiversity or geodiversity interests, or upon the character or appearance of the landscape and countryside; e. be of an appropriate scale for their context and/or comprise the conversion of suitable existing rural buildings or limited extension to existing visitor accommodation. The occupation of any new tourist accommodation will be restricted via condition or legal agreement to ensure a tourist use solely and not permanent residential occupation. 3.3: A number of other policies may be considered as secondary criteria to the above over-arching policy & these may include:

DM1 Sustainable Development

DM2 Development Principles & Local Distinctiveness

DM10 Impact of Development on Sites of Biodiversity & Geodiversity Importance

DM45 Transport Assessments & Travel Plans

DM46 Parking Standards

4. ASSESSMENT

4.1: The proposed lodges would create additional tourist accommodation to that already available on the site by All Saints Hotel. The hotel has 41 rooms & an application for 42 further rooms has recently been approved by the Council. There remains a strong demand for additional tourist accommodation.

4.2: Bury St Edmunds & Beyond has recently produced (February 2018) a study of local tourism & this has indicated Bury St Edmunds as having a high appeal levels to visitors. 64% of respondents to their survey were likely to require accommodation within the area with family groups seeking weekend & longer accommodation of particular note.

With tourism contributing over £1.6 billion to the Suffolk economy (2016 Impact of Tourism Report) & providing some 12% of all employment in the County it is clearly an important industry. It is considered that development of this industry is in accordance with the core principle of the NPPF.

The proposed development will generate additional jobs & once operating will lead to increased visitor spend within the local economy. A separate Economic Statement is included in the application.

4.3: Policy DM34 relates to the development of tourism & states that improvements & extensions to existing facilities will be approved subject to several criteria being met.

The proposed development being leisure/recreation would be directly connected to the existing leisure/recreation facilities on the site & as previously noted is directly connected to other centres of tourism in the area.

Accessibility to central Bury St Edmunds is excellent for both pedestrians & cyclists with a regular bus service. Access to the A14 is readily available for exploring further the surrounding area.

The proposals therefore meet the criteria a) as set out in this policy.

Criteria b) seeks to avoid harm to the character, appearance or amenities of the area. As noted the proposed lodge park would not be visible from the A1101 or surrounding public areas. The open character of the golf course around the River Lark would be retained with the development contained in the south western corner of the site largely concealed behind existing landscape features.

Vehicle access & on-site parking will be provided to an appropriate standard in compliance with criterion c). Criteria d) concerns biodiversity & conservation. The areas of golf course involved are heavily maintained & mown amenity grassland of low ecological value. It is considered that the lodge park will offer more scope for creation of diverse habitats by an increased variety of landscaping & tree planting which may be conditional on any approvals granted.

Whilst criteria e) makes reference to “rural” development it notes that the scale of development should be appropriate to context. It must be noted that the proposal involves a comparatively very small portion of a very expansive site immediately adjoining a large industrial estate.

The site would allow the single storey lodges to be well spaced within a landscaped environment without need for a rigid geometrical suburban arrangement. This is appropriate in both scale & context of the golf course.

5. SUMMARY & CONCLUSIONS

5.1: This application seeks permission for 15 holiday lodges at All Saints Hotel & Golf Club, Fornham St Genevieve. The proposals aim to create additional tourist holiday accommodation in a fully sustainable location on the edge of one of the principal Suffolk towns. The use for such accommodation is entirely compatible with the existing recreational/leisure use of the site.

5.2: The proposals do not replace an existing use but supplement a current use which is in danger of becoming financially unviable. Rationalisation of the golf course will enable the retention of this leisure facility & attract more visitors on site to participate in this activity.

5.3: Examination of the relevant Planning Policies has indicated that the provision of holiday lodges in this location complies with the objectives & criteria of these policies. The provision of additional leisure & tourism facilities will contribute significantly to both the local & broader rural economy. No significant material harm would result to the local character of the recreational site & surroundings.

5.4: The new access provisions can provide safe vehicular conditions for additional visitors & improve accessibility for cyclists & pedestrians to Bury St Edmunds centre. The lodges can be placed outside the floodplain of the River Lark on mesh bases & a positive reduction in flood risk can be achieved through a suitable surface water management strategy.

5.5: Proposals for diversification of tourism & hospitality must now be considered in light of the current & potentially permanent effects of pandemics. Traditional accommodation facilities are not likely to remain attractive in such circumstances. Detached, individual & independent accommodation such as that provided by holiday lodges can provide a sustainable solution.

5.6 In view of these conclusions the development proposals must be considered reasonable & are as such commended to the Local Planning Authority.

Andrew Kellock Architects

October 2020