Linton Parish Council Objection to Planning Ref C/50/46L. Hotel complex, self‐catering accommodation, and associated leisure facilities at Linton Camp.

Linton Parish Council wishes to object to Planning Ref: C/50/46L. The scale of the application proposal is wholly excessive and inappropriate for this rural location within the Dales National Park (YDNP). Re‐development of the site is supported in principle, but an objection is made due to the excessive scale of the development (which brings with it several other negative planning impacts). The full details of the objection are set out below.

The Amount / Scale of Development The Parish Council, having consulted with our parishioners, consider that the amount / scale of proposed development on the site is wholly excessive and inappropriate for this rural location within the Yorkshire Dales National Park (YDNP). Government planning policy advises that such major development should be refused in National Parks unless there are exceptional circumstances. No such circumstances exist.

The development proposal is a major development within the YDNP. Planning legislation defines major developments as providing more than 1000 m2 of floorspace. The application forms indicate that the proposal provides almost 7000 m2 of floorspace. Therefore the development is of a very significant scale.

The National Planning Policy Framework (NPPF) advises at paragraph 172 that within statutorily protected landscapes such as National Parks ‘the scale and extent of development within these designated areas should be limited. Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest. Consideration of such applications should include an assessment of: a) the need for the development, including in terms of any national considerations, and the impact of permitting it, or refusing it, upon the local economy; b) the cost of, and scope for, developing outside the designated area, or meeting the need for it in some other way; and c) any detrimental effect on the environment, the landscape and recreational opportunities, and the extent to which that could be moderated.’

It is recognised that Policy BE1 from the Adopted Yorkshire Dales National Park Local Plan 2015 – 2030 identifies the site of Linton Camp as suitable in principle for redevelopment, but this does not mean that the scale of what is proposed by this current application is by default acceptable. The development will result in a large hotel complex, with further self‐ catering lodge accommodation, and ancillary leisure uses including indoor and outdoor swimming pools, a cinema, restaurant, gym, and spa facility.

NPPF planning policy, which is more up‐to‐date than the current Adopted Local Plan, provides firm advice that a development of this scale, within a statutorily protected landscape such as a National Park, should be refused planning permission other than in exceptional circumstances. There are no such circumstances.

Local Plan Policy BE1, when read in conjunction with Appendix 3 of the Plan that sets out the development constraints for the Linton Camp site, does not specifically outline the scale of development that will be acceptable. However, criterion 3 and 4 of the policy set out for Linton Camp in Appendix 3 do provide some useful pointers.

Criterion 3 explains that ‘the focus of development opportunity is upon the part of the site that already contains buildings. Any development of the remaining parts of the site not currently occupied by buildings will only be permitted where it can be shown to enhance or better reveal the significance of the Scheduled Monument and where it will conserve or enhance the particular landscape, wildlife and archaeological qualities of the area.’ The current development proposals cover an area of land that is far greater than which is currently developed. Additional land is to be developed to the south and east, which is further extended if the footprint of areas such as the outdoor swimming pool is included. Private water treatment works are also proposed, although no details are provided on this proposed installation. Such development will further extend the area of the site that is to be developed.

The amount of development is significantly more than that which was previously constructed. The existing buildings are much smaller with spaces between them, whereas the large hotel suite blocks, and the hub building significantly increase the built footprint over and above that which previously existed, a footprint increase (m2) of approximately 85%.

Criterion 4 specifies that that new structures on the site are likely to be predominantly single storey. This is not the case with the development proposal. The hotel buildings are all 2 or more storeys in height, and the resulting amount of development proposed is very extensive.

In conclusion, the scale of development on the site that is supported by the Local Plan is clearly meant to be far less development than that which is currently proposed.

Landscape Impact The Parish Council consider that due to its scale and design the proposed hotel complex, self‐catering holiday accommodation, and other associated leisure development, will have an unacceptable impact on the special qualities of the YDNP landscape.

There is extensive planning policy, both locally and nationally that outlines the importance of protecting the special qualities of the National Park landscape. Policy SP1 requires development to conserve or enhance the landscape character of the National Park through use of high quality design, appropriate landscaping, and removal of unsightly development. Policy SP2 explains that development will not be permitted that prejudices the National Park purpose of conserving and enhancing natural beauty. Policy SP4 indicates that development must not give rise to any unacceptable, adverse impacts in terms of important public views.

The sensitivity of this site is recognised by Appendix 3 of the Local Plan that identifies the development constraints for any proposals on this site. It specifies that this is an extremely prominent open countryside location and that visual and landscape character impacts are a key consideration. Appendix 3 goes on to outline that new structures on the site are likely to be predominantly single storey, in line with the existing structures, have an emphasis on high quality design and landscaping that sits harmoniously in the landscape. Finally, the NPPF advises at paragraph 172 that ‘Great weight should be given to conserving and enhancing landscape and scenic beauty in National Parks’.

The site is located within a valley bottom and there are views of the application site from the surrounding area including the local footpath network. Views of the site are available from higher ground to the south and south east, and east and north east. The development will be prominent in the local landscape and will be detrimental to its appearance. In particular: ‐  Whilst it is acknowledged there are attempts to partially submerge the hotel building, the rounded shape and scale of the hotel blocks will be prominent in the landscape. The resulting design will appear alien to the surroundings. The ‘Special Qualities’ of the YDNP are outlined in Appendix 2 of the Local Plan. The ‘Special Qualities’ include ‘Numerous small, attractive villages and hamlets most of which have been there for over a thousand years as well as scattered farmsteads’. When viewed from higher ground villages such as Linton and Burnsall can be seen and together with scattered farmsteads contribute to making the YDNP landscape special. The current proposal will be detrimental to that special quality resulting in overly large geometric shapes that will be prominent in the landscape and not seen elsewhere throughout the National Park.  The application seeks to compare the impact of the existing buildings to those that are currently proposed. The existing buildings are totally beyond repair and could not be restored and returned to use. Many of the buildings are now artificially propped up with scaffolding so that they continue to have an impact on the local landscape. Without propping they would collapse. The new buildings should therefore not be justified in terms of their impacts in comparison to the existing buildings as many of the existing buildings should no longer be standing. To address this the YDNP could use the powers that it has under Section 215 of the Town and Country Planning Act 1990 (as amended). Under these powers the YDNP can serve a notice and compel the landowner to remove these derelict structures as they are now beyond repair and their resulting appearance has an unacceptable impact on the local landscape.  The cross‐sections attempt to demonstrate that the visual impact of what is proposed from the existing buildings is little different. However, the cross‐sections through the site are inaccurate and misleading. For example, on existing elevation C‐ C it is claimed the gable height of the building adjacent to the B6160 is 6 m high when it is more likely 4.5 m.  The overall height of the proposed buildings is very significant. The proposed hub building is partly 3 storeys’ in height. Floor to ceiling heights are in places 4 metres high, which is well in excess of typical heights. Development of this scale is far in excess of what Appendix 3 of the Adopted Local Plan explains should be acceptable, which refers to new structures on the site being predominantly single storey.  The application indicates that a new private water treatment plant is to be constructed. The development proposal is of a significant scale and extensive works may be needed to treat the effluent from the proposed complex (including water from the swimming pool). The full impacts of any proposed installation need to be considered as part of the napplicatio and it is not appropriate to require further details by planning condition as the impacts are not known and could be significant.  The design of the two storey hub building is oriented towards to the north so that its highest section has maximum impact on both the road and the wider landscape views. This was rightly highlighted by the YDNP during pre‐planning advice, section 4.6, where YDNP stated ‘A key issue of the design is the potential impact from the large expanses of glazing particularly those facing towards the valley (north‐western, northern and north‐eastern elevations). Large expanses of glazing are likely to result in a significant level of light emission and reflection which, in such an isolated position in the landscape, would have a negative visual impact. It is therefore recommended that the northern elevations of the lodges and the Hub are kept as plain as possible with few openings. It is noted from ‘Elevation F‐F’ that the western and north‐western elevation of the hotel accommodation suites will be fully glazed, albeit with a slightly overhanging roof. The extent of glazing could result in a wide strip of illumination being seen from a considerable distance.’ In submitting the application in this way the developer has both ignored the pre‐planning advice and, in effect, submitted a proposal that will maximise the negative impact the currently uninterrupted world‐class vistas of the dales both in daylight and importantly at night‐time. Uninterrupted view of Linton Camp site from B6160 between Burnsall and

Linton Camp development site.

Linton Camp is also clearly visible from tourist view point highlighting the beauty of the Dales National Park in Grassington. Development will detract from this view.

Linton Camp development site.

Linton Camp occupies a central position in the visita taken from Snake Path. A regular postcard view taken to draw tourists into the unspolit national parks area.

Linton Camp development site.

In summary, due to its scale and design the development will be harmful to the special qualities of the YDNP.

Light pollution Due to the scale of the development, necessary external lighting to facilitate the proposed use, and the design of the buildings that include extensive areas of glazing, the Parish Council considers that Light pollution from the development will have an unacceptable impact on the precious dark skies of the YDNP.

Policy SP4 ‘Development quality’ from the Adopted Local Plan states that development must not give rise to any unacceptable, adverse impacts in terms of the darkness of the night sky. Paragraph 2.31 of the policy justification states that ‘One of the Special Qualities of the National Park is the extensive areas that benefit from tranquillity and access to a dark night sky. This is an increasingly scarce resource in and is protected by national planning policy. Where these qualities are present, proposals for development should avoid harmful levels of noise or light emissions.’

The importance of protecting dark skies is similarly reflected by the NPPF (as amended in 2018). It states that ‘decisions should also ensure that new development is appropriate for its location taking into account the likely effects (including cumulative effects) of pollution on health, living conditions and the natural environment, as well as the potential sensitivity of the site or the wider area to impacts that could arise from the development’. In particular the policy states that development should ‘limit the impact of light pollution from artificial light on local amenity, intrinsically dark landscapes and nature conservation’.

The application is accompanied by an external lighting assessment prepared by PSA. That assessment is extremely selective in the identification of ‘sensitive receptors’ that may be impacted upon by the development. The footpath to the south of the site and B6160 to the north are recognised as receptors that may be affected, but no detailed consideration is given to other public footpaths or roads in the local area. For example, clear views of the site are available from the B6265 between Grassington and Hebden, which due to its elevated level looks directly across to the application site.

Uninterrupted view of the site from B6265 between Grassington and Hebden

Linton Camp development site.

The design of the hotel is such that bedroom accommodation includes extensive areas of glazing. Much of that glazing is orientated towards the B6160 and the higher land to the east and north east, as previously referenced. In hours of darkness light emitted from bedroom accommodation would be prominent and have an unacceptable impact on the characteristics of the YDNP when viewed from the higher land to the east and north east.

Similarly, no consideration is given in the light assessment to higher land to the south, which includes Thorpe Lane and other footpaths. The proposed hub building and suite accommodation would be orientated to face towards the south and south west. Extensive areas of glazing are proposed in this elevation and extensive light would be omitted from the proposed buildings.

The lighting assessment comments that from the nearest residential properties within the village of Linton it is not possible to view the site. This is not the case.

The PSA External Lighting Assessment states that ‘the site is generally located within open fields approximately 1km away from the village of Linton to the west of the site’. This is factually incorrect and highly misleading. The distance between the proposed development and houses within Linton village is a mere 300m (as measured by google maps).

The PSA lighting assessment also states that ‘Due to the topography of the area it has been noted that you cannot see the site or any of the existing structures from the village of Linton’. This is, once again, factually incorrect and misleading. The northernmost existing camp properties are directly visible from properties in Linton. The proposed structures in the development plan are larger than those which presently exist and their design includes large areas of glazing. The development will therefore impose a significant and unacceptable light pollution impact on properties within Linton village, which requires adequate consideration.

Linton Camp buildings clearly visible from properties on eastern edge of Linton Village

Current buildings at the camp are clearly visible from properties in Linton village.

Linton Village is clearly visible from Linton Camp. Note lack of lighting in Linton Village.

Linton Village – clearly visible from Linton Camp

The external lighting assessment is also based on out of date planning policy advice. It refers to Planning Policy within the NPPF that is now superseded and out of date. In summary, the external lighting assessment cannot be relied upon as a thorough consideration of the impacts of the development.

External lighting of all paths, parking, and servicing areas will be required. As explained below, the proposal that all deliveries will take place below ground is unrealistic. Inevitably there will be a requirement for more above ground servicing space, which in turn will impact on the amount of light pollution.

For the reasons explained above this large‐scale development has an unacceptable impact on the dark skies of the YDNP generally, and light emissions will have an unacceptable impact on the special qualities of the YDNP landscape from certain viewpoints as well as a direct and negative impact on the residents of Linton.

Highway / Traffic / Sustainability Due to the scale of the development proposed, and the nature of the proposed use, the development will unacceptably increase traffic on the local highway network because of vehicle trips made by visitors to the development, employees from out of the immediate local area, and vehicles servicing the site. The local road network is unsuitable to accommodate the additional vehicle movements, and the site is an unsustainable location for this development as realistically it is not accessible by means other than private motor vehicles. The Parish Council therefore request that the application is refused for reasons relating to Highways / Traffic / and Sustainability.

Local Plan Policy SP1 ‘Sustainable Development’ outlines that ‘The Yorkshire Dales National Park Authority will presume in favour of development that is sustainable.’ It outlines that proposals that reduce the need to travel will be supported. Policy SP4 requires that development should not prejudice highway safety or cause unacceptable levels of traffic that would harm the environment or capacity of the local road network. It also requires developments to contain adequate provisions for connection to public transport. Similarly, Policy C12 ‘Infrastructure needed to support development’ explains that development will only be permitted where adequate infrastructure exists or will be provided to serve the proposal. Finally, Appendix 3 of the Local Plan, that sets out specific considerations for Linton Camp, explains that careful consideration is needed of how to manage traffic impacts and incorporate sustainable transport choices, including linkages with and enhancements to the rights of way and public transport networks.

Access to the site is very poor and, given inadequate public transport services, we anticipate that all of the visitors and the majority of staff will arrive by private vehicles. To reach the site visitors will be restricted to the following routes:

Most visitors to the site are likely to arrive from either the A59 or A65 to the south. The vast majority of these visitors to the proposed hotel complex, including the numerous service vehicles required for a development of this scale, will then use the B6265 Grassington Road. However, they will then be directed to pass through the village of Linton via Lauradale Lane. After crossing the bridge in the heart of this conservation village they will fork right on a narrow single track road with no passing places. This is the direct route to the site and is indicated on most, if not all, satnav systems (Waze, Google maps and RAC routefinder all show this route), pictures below. Right turn in centre of Linton village to the unmarked single track road leading to Linton Camp

Narrow single track, tree lined road with no passing places leads to Linton Camp

Linton Camp Buildings.

This directly conflicts the developers statement that ‘The major traffic routes bypass the village [of Linton] and there is only one through road, the B6265, leaving the settlement itself peaceful.’ In actual fact we believe that the impact of the increased traffic through the peaceful settlement, which is without speed restrictions, referred to in the conservation area statement will have an unacceptable negative impact on the amenity of existing residents and highway safety. The village will be peaceful no more.

In addition to the unacceptable burden on the inadequate local highway network the proposal will also exacerbate the extreme traffic congestion that the Village of Linton already suffers, as demonstrated by the following photographs. On road parking (both sides of the road) often reduces the road to a single lane, not easily passable by larger vehicles. Increased traffic intensity will not only worsen this situation but will materially increase the chances of road traffic accidents.

Congestion in Linton village – winter 2018. Congestion is materially worse in summer.

Capacity of Lauradale Lane is often reduced to single vehicles although an unrestricted speed limit remains in place.

The village is so congested that vehicles are parked all the way down the Lauradale Lane.

Access to the bus stop and heart defibrillator are also often blocked by parked cars

From Harrogate most vehicles accessing the site will travel along the B6265 through Grassington then via the narrow single carriageway Church Lane which passes directly by Threshfield Primary School. This route is already heavily congested at school drop off and pick up times. Increased traffic will exacerbate this situation.

In addition to increased congestion, more traffic will heighten the threat of road traffic accidents involving children walking to and from school. Many children walk or cycle from Linton Village, crossing the B6160, as well as children from Linton Falls and Threshfield all of which have to walk along the single car width Church Lane.

Severe congestion at Threshfield school results in multiple cars parked along Church Lane.

Parents push prams to school with children walking along the single track Chruch Lane

In addition to visitors arriving and leaving the hotel via Church Lane this will also be the main route by which they will access the centre of Grassington. It is likely that this trip could be taken multiple times per day by visitors staying at the site. From Ilkley visitors may also drive to the site via the B6160 passing through Bolton Abbey. The B6160 is narrow and unsuitable to accommodate the amount of vehicular traffic that a proposal of this scale will generate. Visitors will add to the bottleneck at Bolton Abbey (caused by existing visitors and the existing stone arch that has height restrictions and reduces the carriageway width to a single lane). Service vehicles are unlikely to be able to access the site from the B6160 due to the restrictions imposed by the stone arch. As a result of the scale of development that is proposed, the increased vehicle movements are unacceptable.

Due to the nature of the development a large number of employees will be required to service the hotel development. Sufficient employees will not be available in the immediate local area and will inevitably will be employed from out of the area adding to vehicle trips to the site. A smaller scale development, possibly one that just proposed self‐catering holiday accommodation without a hotel and associated leisure development, would not generate the same number of vehicle movements by either visitors or prospective employees. Such a development would not require the same number of employees to service hotel bedrooms, and staff the associated leisure uses.

Similarly, due to the nature of the development that is proposed, the number of deliveries to the site is likely to be extensive. The application proposes that all service deliveries will take place in the below ground parking area. This is completely unrealistic. Delivery vehicles will arrive that do not comply with the height restrictions for entering the underground parking area. The space below ground is limited and therefore is likely to lead to vehicles above ground either making deliveries or waiting to access the below ground service area. In addition to highway safety issues, the impact will be a requirement for above ground servicing of the development and more landscape / light pollution impacts.

The target demographic for the hotel, social status A & B, are likely, given their disposable income, to be car owners and therefore are unlikely to utilise public transport, especially if services are infrequent. Bus services to the site are very poor and will not be a viable alternative for either visitors or employees. The limited number of buses that are available, significantly decrease during the winter months. Operation of the facility will therefore depend heavily on movements via the local road network. The site is not a suitable location for development of the scale proposed and the use would be best directed to an alternative more sustainable and accessible location.

The application proposes improving connectivity to the local footpath network and reference is made to the footpath that runs to the south of the site. However, to achieve this improved connectivity a permissive right of way across private 3rd party land would be required to reach the footpath. It is not believed any permission has been given by the landowner to provide this improved connectivity.

Finally, as highlighted above all visitors to the development will realistically arrive by car and will use the car for shopping at supermarkets as well as locally in Grassington. Although it is very worthy to encourage walking and cycling, it is unrealistic to expect this to have more than a marginal effect on car usage. The previous applicant’s own Market Survey showed that the most popular holiday activity in the Dales is sightseeing by car (mentioned by 85% of respondents).

In summary, the Parish Council considers the location is unsustainable for a development of this scale as there is an inability to access the site effectively by public transport. Furthermore, the resulting development will have an unacceptable impact on the local road network, significantly increasing the congestion within the already congested village of Linton as well at Threshfield School. In addition to this we are concerned by the materially increased risk of accidents involving children during their walk to school which requires them to walk along and cross the major access routes to the hotel complex.

Flood Risk / Drainage Objections to the application with respect to Flood Risk and Drainage have been made by both the Lead Local Flood Authority ( County Council) and the Environment Agency. The Parish Council consider that inadequate information has been provided to demonstrate the proposed foul and surface water drainage solutions are appropriate, and given the absence of information the impacts of this development can not be assessed. The on the basis of the concerns raised by these statutory consultees the application should therefore be refused planning permission as the proposal does not comply with Local Plan policy, and planning guidance and policy contained within the NPPF and Planning Practice Guidance.

Local Plan Policy CC2 identifies detailed considerations for ensuring that both flood risk and drainage for new development proposals are appropriately addressed. Similarly, Appendix 3 of the Local Plan identifies that there are high surface water flood risks on parts of the site that need to be considered.

With respect to foul drainage the application indicates that effluent is to discharge to a new private water treatment plant. Treated effluent is to soakaway in a similar fashion to the surface water run‐off. The application indicates that an alternative is to provide a new connection to the existing sewerage system. Surface water is expected to be discharged to soakaways subject to percolation testing. It is apparent from both the application and the Consultation responses provided from both by the Lead Local Flood Authority and the Environment Agency that such considerations have not been properly considered addressed by the applicants. Planning Practice Guidance relating to the use of non‐mains drainage sets out a presumption that foul drainage will discharge to a public sewer unless it can be shown that such a solution is not practicable. No information has been provided to demonstrate that this preferable option has been properly investigated before proposing a private water treatment plant and therefore the application is unacceptable in this respect. Similarly, it appears from the application submission that no percolation testing or other investigations have been undertaken to establish the suitability of the use of soakaways for both surface water drainage and treated effluent from the proposed private treatment plant. Appendix 3 of the Local Plan recognises that there are high surface water flood risks on the site. Significantly more investigations and information is needed for this issue to be properly addressed prior to the determination of the application. Finally, if a new private treatment plant is required no information is provided on its location or design. There may be landscape impacts and this concern is set out above in more detail in the ‘Landscape Impact’ section of this objection. In summary, drainage has not been properly considered by the applicant and the true impacts of the development are not known.

Proximity to a Major Hazardous Installation The application should be refused due the sites proximity to an Ethylene Pipeline that is a major hazardous installation. The development would result in a highly sensitive end use in the event of an emergency situation and therefore development of the scale proposed should be resisted.

The application site is located within close proximity to an Ethylene Pipeline, which is understood to be a Major Accident Hazard Pipeline as defined by the Health and Safety Executive. Safety zones are designated around such installations. More sensitive development and land uses are not permitted in those zones that are adjacent to such installations. According to information held by the pipeline operator (Sabic) the application site includes land within the inner, middle, and outer safety zones. The development would be a highly sensitive use in the event of an emergency situation. The proposal is for a large‐ scale hotel complex, which will result in a high concentration of people in a small area. Visitors to the site would be temporary and unfamiliar with the site and its surroundings which is of concern in an emergency. The development in such close proximity to the pipeline should not be accepted.

It is recognised that the site had a previous use that included visiting members of public, but that previous use was far less intensive than that which is proposed. Furthermore, as the buildings are now beyond repair that previous use could not be re‐established without a further planning application and consideration must be given to the appropriateness of this development proposal given the presence of the pipeline.

In summary, the completion of this large‐scale development in such close proximity to a major hazard should not be permitted.

Local Consultation The Yorkshire Dales National Park Management Plan 2019‐24 states that ‘local people will be at the heart of the delivery of most of the objectives set out in this Management Plan.’ As such it is with disappointment that neither the Parish Council nor the residents located adjacent to the proposed development have been directly made aware or consulted with respect to the proposed development.

This lack of engagement and consultation with local people has clearly been a conscious decision on behalf of the Linton Redevelopment Company as it references ’No consultation exercise has been undertaken but previous consultation exercises held within the Fountaine Inn resulted in positive responses with no negative responses for any development of the site for tourism activities.’ Given the objections that have been raised by the Parish Council and residents relating to prior proposed, and subsequently rejected, plans. We find it hard to believe that the alleged feedback was indeed ‘all positive and no negative comments’.

We hope that it is clear from this response that Linton Village Parish Council and its parishioners are strongly opposed to the proposed development of Linton Camp.

The scale of the proposed development and its impact on the Yorkshire Dales National Park as well as more locally on Linton village will in our view be irretrievably adverse. The fact that we have at no point been engaged through this extensive planning exercise also highlights a complete disregard for opinion of the local community and a total lack of concern that such a development would have for the existing residents of this, currently tranquil, conservation area village.

This said, we remain open to working together with the YDNP authorities and the developers to find positive solution for the Linton Camp site that would be appropriate and beneficial to the National Park and the village of Linton.

I trust the YDNP Planning Authority will take the concerns of Linton Parish Council into account when considering the planning application.