South Somerset Local Plan Review 2016-2036 Preferred Options Consultation (Regulation 18)

Comment ID 1456
Document Section South Somerset Local Plan Review 2016-2036 Preferred Options Consultation (Regulation 18) Economic Prosperity Tourism Text Block [View all comments on this section]
Respondent Nathaniel Lichfield & Partners… [View all comments by this respondent]
Response Date 18 Sep 2019
Attachments
Comment

Policy EP8- New and Enhanced Tourism Facilities


The emerging Plan recognises the important contribution of the tourism industry to the local economy. This is reflected by the supporting paragraphs to draft Policy EP8 (New and Enhanced Tourism Facilities). In particular, paragraph 10.60 acknowledges that:

“The tourism sector contributes significantly to South Somerset’s economy. The range of unique, nationally and internationally recognised attractions and tourist accommodation, coupled with the attractive rural environment and built heritage combine to offer real potential for further growth and value in the visitor economy.”

Paragraph 10.63 in the emerging Plan also states that “To improve South Somerset's tourism offer and to extend the tourism season, support will be given to sustainable tourism developments that benefit businesses, communities and visitors, subject to their scale and location.” This paragraph also sets out a variety of sustainable development objectives that major new tourism proposals should be assessed against.

Bourne Leisure endorses the supporting paragraphs to draft Policy EP8 particularly as they recognise the value of tourism to the local economy and are supportive of tourism-related development. However, we are concerned that emerging Policy EP8 does not adequately correspond with the objectives in paragraph 10.63.


Policy EP8 in the Draft Strategy states:


Policy EP8 - New and Enhanced Tourism Facilities

“New and enhanced tourism facilities will be supported within or adjacent to existing built settlements where they are of an appropriate scale to the size and role of that settlement.

Outside settlements, new and enhanced tourism facilities must be in keeping with the character and scale of the location and landscape setting.

In all cases, development proposals will need to demonstrate that there are no significant adverse impacts on biodiversity interests (including Natura 2000 and other internationally and nationally designated sites), and that they do not harm the District’s environmental or cultural heritage, ensuring the continued protection of designated conservation features.


Locations that are accessible and have good transport links, including road and public transport, will be supported.


New holiday accommodation in the countryside will be supported where existing buildings are reused.”


Policy EP8 is the only direct tourism policy within the draft local plan and therefore it is critical that it clearly covers all aspects of tourism development and is an effective policy that supports suitable tourism opportunities in the authority area. We consider that there are some fundamental issues with the policy as it is currently drafted that need to be addressed, namely:


1 Provide clarity that both new and enhanced tourism accommodation and facilities will be supported;
2 Take a more positive approach in supporting the growth of existing tourism related businesses;
3 Allow for appropriate mitigation of any adverse impacts on the District’s environmental assets or culture heritage;

4 Provide greater support for a range of tourist accommodation and facilities in the countryside.


We discuss each of these matters in further detail below before providing suggested changes to the draft policy wording to address these concerns.


1. Support for tourist accommodation and facilities
Emerging Policy EP8 refers to supporting new and enhanced tourism “facilities”. It should be clear that this includes the provision of tourist accommodation. Supporting the maintenance and enhancement of tourism accommodation, as well as associated facilities are both important elements of a successful tourism economy. The policy needs to clearly support both.


A policy that supports new and enhanced tourist accommodation will also better align with the supporting paragraphs and development objectives for emerging Policy EP8 and contribute positively towards their delivery, thereby ensuring the plan is effective, in line with the tests of soundness.


2. Growth of existing tourism related businesses
Emerging Policy EP8 should take a more positive approach to supporting the growth of existing tourism businesses and ancillary development.

Due to changing market trends, increasing visitor expectations and the competitive nature of the tourism industry particularly between authority areas, it is important that the new Local Plan fully and explicitly supports the improvement of existing tourism-related businesses alongside the development of new facilities.

Experience shows that for properties such as the Cricket St Thomas Hotel, allowing operators to take forward small but significant projects and also more comprehensive schemes, often involving the enhancement, extension and expansion of the hotel, park or resort, is essential to their long-term success. Whilst, the development of new tourist infrastructure is vital, the existing facilities in the area, which already bring many positives to the local economy, should also be supported by development planning policies. Policies should therefore also give in-principle support to their maintenance and enhancement, including the provision of ancillary proposals.


3. Mitigation of adverse impacts
The importance of protecting the District’s statutory designated natural or cultural heritage assets (supporting paragraph 10.65) is acknowledged. As many of Bourne Leisure’s sites are located in rural and/or coastal areas, incorporating or adjacent to environmentally and ecological sensitive sites, the Company has significant experience of operating in such locations and takes the need for conservation and enhancement fully into account – both in day to day operations and when preparing development proposals.

There are circumstances where development can be appropriate when it has the potential to have an adverse impact on the environment and/or designated and non-designated sites, if appropriate mitigation measures are provided.

Accordingly, emerging Policy EP8 should include a clear provision whereby development proposals can be considered on a case-by case basis, taking into account any mitigation measures proposed to be provided.

4 Provide greater support for tourist accommodation in the countryside.
Currently, Policy EP8 only provides support for new holiday accommodation in the countryside where existing buildings are reused. This is contrary to national guidance that takes a more supportive stance to tourist development in rural areas.

This policy blanket approach does not consider the context of individual developments and the potential benefits that they can provide or indeed the lack of harm that may be caused. For example, Bourne Leisure’s Cricket St Thomas Hotel is in a countryside location, the hotel is a Grade II* listed park and garden. The existing tourism use not only supports the site’s on-going maintenance as an important heritage asset but also supports a significant number of jobs in the local area. Maintaining and enhancing the appeal of tourism accommodation remains vital to securing their long-term viability and to positively contribute to the visitor economy in South Somerset. In future the need to increase the level of accommodation at a site such as Cricket St Thomas Hotel, may be essential to its long-term success, however the re-use of existing buildings on-site may not be feasible or appropriate. Given the potential benefits that such a development may bring (e.g. benefits to local economy and maintaining the historic environment) a more nuanced policy approach is required, whereby tourist accommodation in the countryside is considered based on the individual context of the site and merits of the proposals.

Such an approach would provide greater consistency with the NPPF, which explicitly refers to supporting the provision and expansion of tourist and visitor facilities in order to promote a strong rural economy. The NPPF states at paragraph 83:

“Planning policies and decisions should enable: …

c) sustainable rural tourism and leisure developments which respect the character of the countryside…”

It is important that emerging Policy EP8 does not restrict new tourism accommodation in the countryside through only the re-use of existing buildings.

Suggested changes

Based on the above four highlighted issues, we consider that draft Policy EP8 should be amended as follows:

Policy EP8- Tourism Development New and Enhanced Tourism Facilities

“New and enhanced tourism accommodation and facilities (including ancillary development) will be supported within or adjacent to existing built settlements where they are of an appropriate scale to the size and role of that settlement.

Outside settlements, new and enhanced tourism accommodation and facilities (including ancillary development) will be supported where they enhance the overall quality of the tourism offer in the district and have no significant adverse impacts upon must be in keeping with the character and scale of the location and landscape setting.

In all cases, development proposals will need to demonstrate that there are no significant adverse impacts on biodiversity interests (including Natura 2000 and other internationally and nationally designated sites), and that they do not harm the District’s environmental or cultural heritage, ensuring the continued protection of designated conservation features. Where adverse impacts arise from the proposed development, consideration will be given to whether suitable mitigation measures can be secured to ensure overcome any adverse impact.


Locations that are accessible and have good transport links, including road and public transport, will be particularly supported.


New holiday accommodation in the countryside will be supported where existing buildings are reused.”


(proposed amendments underlined and with strikethrough).

 

It is important to consider the implications should emerging policy EP8 not be amended. Currently, the draft policy is unclear whether support exists for a range of tourism related developments (e.g. accommodation and ancillary development). Crucially, when considering where to invest in new or existing tourism accommodation and facilities, the policy support (or lack of it) will be a key factor influencing the investment decisions for businesses. In the absence of appropriate policy support, future investment may be diverted to alternative assets in locations where there is greater certainty that projects will be supported by the relevant local authority. This would lead to negative economic impacts (e.g. less job creation/retention, less direct and indirect spending in the local area). It will therefore be vital that policy EP8 is fully supportive of a range of tourism related developments if the Plan is to be effective in delivering its various aims at draft paragraph 10.63.


For consistency with both national policy and the proposed revised Policy EP8, it will also be necessary to update the draft supporting text at Paragraph 10.65 to the following:


“Statutorily designated natural or cultural heritage assets are recognised as having scope for tourism proposals subject to appropriate control and mitigation measures that ensures the features for which they are designated are not compromised (see Policy EQ5: Biodiversity) and address any adverse impacts of the proposed development.”
(proposed amendments underlined).