The Byre, Woodend Lane Cromhall, Wotton-under-Edge GL12 8AA

Tel: 01454 269 237 www.enzygo.com

Dover District Council, Council Offices, White Cliffs Business Park, Whitfield, , CT16 3PJ Our Ref: CRM.256.002.PL.L.001 11th May 2021

Dear Sir/Madam, Application for a Lawful Development Certificate (LDC) for Land opposite the Dog and Duck Inn, Dog and Duck Caravan Park, Plucks Gutter Please find enclosed details relating to an application for a LDC for the existing use as a caravan park of Land opposite the Dog and Duck Inn, Dog and Duck Caravan Park, Plucks Gutter, , CT3 1JB. The original planning application for the use of this piece of land as a caravan park was applied for on October 6th, 1961 (Planning Ref: 61/0438). The temporary consent issued by Council required the use of land as a caravan park to cease by 30/11/1976, however, the site has been in continuous use since this date and there is no evidence that we have seen to suggest that this application has ever been renewed. On this basis, we are writing to seek a LDC in order to extend the consent for the use of the site as a caravan park. This letter describes the application site, the existing licenses on the site, and the precise description of what is being applied for. We request confirmation from Dover District Council that the information/evidence supplied in this letter is sufficient to allow Dover District Council to decide the application and confirm that the existing use of the land is lawful for planning purposes, under Section 191 of the Town and Country Planning Act 1990. Application Site The application site is located on Land opposite the Dog and Duck Inn, as illustrated by the red boundary on the Location Plan referenced CRM.256.002.PL.D.002 appended to this letter. The site is bounded by the wider caravan park to the west and south which are also in the applicant’s ownership, denoted by the blue line. Little Stour River is located approx. 60m north of the site with Plucks Gutter road to the west. Mature hedgerow surrounds the site to the east, south and west. Dog and Duck cottage is approx. 44m north east of the site and the Dog and Duck Inn is approx. 65m west of the site. There is an existing road access into the northern side of the application site via Plucks Gutter Road. The application site is approx. 0.37ha in size. The application site is currently formally used as a caravan park and has been in continuous use for this purpose since 1962.

Evidence to support the confirmation of lawful development based on relevant planning law The Planning and Compensation Act 1991 allows for development (including use as a caravan site) with proof that it has been in continuous in use for a period of over 10 years to become lawful in terms of planning. The application site has been in use for well over 10 years with aerial imagery showing the site

Registered in No. 06525159 at Gresham House, 5-7 St. Pauls Street, Leeds, England, LS1 2JG

in its current use as an active caravan site as far back as 1990 (see below). No enforcement action has been taken, or enforcement notice is in enforce, in relation to the application site. Therefore, it is considered that the owner of the site is lawfully entitled to a LDC. Historic Aerial Imagery 1 displaying the continued use of the application site as a caravan park for > 10 years Imagery date (1/1/1960) - The site has been starting to take the shape of its current layout since 1960, with caravans shown on Land to the south of Dog and Duck Inn. However, the application site (Land opposite the Dog and Duck Inn) is still shown as vacant.

Imagery date (1/1/1990) - The application site is now clearly in use as a caravan park. Land to the west of the Dog and Duck Inn is also now in use as a caravan park and land to the south is fully developed.

1 Sourced from Google Earth Pro, 2021

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Imagery date (1/1/2003) - The application site is in continued use as a caravan park. Holiday units are now shown on land to the south of the application site, which are also in the applicant’s ownership.

Imagery date (07/09/2013) - The application site is in continued use as a caravan park.

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Imagery date (9/24/2020) - The most recent aerial imagery from 2020 shows that the application site is still in continued use as a caravan park.

Conclusion The application site has been operated successfully as a caravan park since it was granted temporary planning consent in 1962 under planning application 61/0438. No enforcement action has been taken, or enforcement notice is in enforce, in relation to the application site. Whilst the only readily available imagery shows the application site in use since 1990 (which is greater than ten years), the site has been in operation since 1962 since planning consent was originally issued.

On this basis, we request confirmation from Dover District Council that the existing use of the land is lawful for planning purposes under section 191 of the Town and Country Planning Act 1990.

Yours Sincerely,

Robert Jake Chamberlain Msc PIEMA AssocCIWM

Senior Planning Consultant, Enzygo Ltd

Tel: +44 (0) 1454 269 237

Mob: +44 (0) 7948 929 418

Email: [email protected]

P a g e | 4 Samuel House, 5 Fox Valley Way, Stocksbridge, Sheffield, S36 2AA

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