Crealy NO Campaign

Neil And Sue's Concerns

 

We are residents of 14 years in the rural hamlet of Tredinnick, North Cornwall and attended the Parish meeting on Saturday  12/12/15 regarding the proposed development at Camel creek.

 

We view this development with great consternation and concern.

 

236 proposed units is too many by far it overwhelms the adjacent rural hamlets of Tredinnick , Trenance , St Jidgey and Canalidgey.

 

This development has even more units than the village of St Issey.

 

The proposed development will have a massive impact on noise, light and traffic on what is still a very rural farming community. Nothing that was said at the meeting by the developers assuaged our very real concerns.

 

We both felt the proposed development was ill conceived and made no effort to blend in with this quiet ancient rural environment.

 

We are very concerned about the environmental impact. Dark lane is not suitable for any large flow of traffic and it is inconceivable that residents and renters in the new Camel Creek development who have almost certainly driven to the site would not get in their cars and take the shortest route to the adventure park, especially in wet weather.

 

Dark lane is prone to flooding and is at the base of a short flood valley. Last winter the floodwaters were over the bridge . This development will increase run off and drastically affect the ecology of this pretty camel creek.

 

Pollution and flooding downstream to Little Petherick is a major concern. The developers say they have taken this into account however even the plans presented at the meeting were wrong.  The so called lakes are to be only six inches deep and linked up in an “S” shape with water flowing down the hill with no facility to pump water back up.

 

This deveopment will increase run off

 

Similar developments have failed to live up to the hype often ending in bankruptcy and loss of control of the site by the local Parish council. One only has to look at the failings of the similar development at St Winnard’s Perch .

 

Insufficient space has been allocated for staff car parking. 950 full time jobs will create a massive car parking problem. Areas 18,19 and 20 on their plans, supposedly set aside for parking would be vastly insufficient and exacerbated if the convention centre is in use or outsiders/guests of residents use the facilities, such as restaurants and covered pool. The proposed car parking will be highly visible perched as it is high up on the slope.

We are very concerned that the area of land above the proposed development and below the main road, that has also been bought by the developers will eventually become an overflow car parking area; leading to further expansion of this inappropriate development. The 150 spaces allocated for users of the facilities and staff is woefully inadequate and the developers suggestion that half of this might be allocated for staff does not stack up.

 

950 full time jobs appears to be highly exaggerated and is a political head line grabber. The idea that workers will be “bussed in“ , as suggested by the developer is ludicrous and very badly thought out. The parking issue has been ignored in the attempt to cram as many units into this rural green field site.

 

The single road access to this site appears to be insufficient for the volume of traffic. We believe the developers will eventually wish to enlarge the site , increase road access and car parking once full occupancy has been achieved further ruining a rural community in an area of outstanding natural beauty.

 

It appears that the development is being pushed through quickly as the developers take advantage of changes in planning to create more housing in North Cornwall. The application just before xmas seems to us a blatant attempt by the developers to avoid as much local opposition as possible, as many people are otherwise occupied. The fob of allowing free use to locals within 1 km of the site has been set to cover only the minimum number of houses, taken from the centre of the new proposed development it doesn’t even reach Tredinnick  the nearest hamlet.

 

The so called "six star resort" has absolutely nothing to do with affordable housing.

 

There is a big concern in the community that those residents who rely on an income from holiday lets will be massively affected. No reassurances were forthcoming at the meeting nor had the planners taken any steps to assess this effect.

 

Help us stop this development by filling in our message form.

 

Neil and Sue Chapman

 

SOME OTHER LETTERS SENT TO THE PLANNERS :

 

Peter & Sally Ann George The Farmhouse Trevibban Barton
St Issey

Wadebrige PL27 7SE

 

Dear Sirs
OBJECTION - Planning Application PA15/08900

22nd December 2015

 

We are the owners of The Farmhouse, Trevibban Barton, with land adjacent to the proposed application. I wish to object to the planning application PA15/08900 on the following grounds:

Local Consultation

I met with the developers, Will and John Broome on the morning of 26th August 2014 prior to the public consultation meeting; I discussed issues of concern regarding the proposal. At the time I felt it was a positive and constructive meeting, John Broome agreed to make changes to the proposed planning application.

Soon afterward, I was sent a revised site plan by John Broome to distribute locally, it embraced some of our key concerns, (I attach a copy of the site plan, Appendix A) the plan shows changes made following our meeting and was agreed that these changes would be reflected in the actual planning application.

As we agreed at the meeting, the revised site plan Appendix A, clearly showed the removal of the car parks close to the Trevibban settlement. However, in the planning application site plan AA5538_REVL_1005 you will note they have been reinstated.

Another key concern was the outdoor extension of the tropical spa, which by its very nature would create unacceptable noise in close proximity to the Trevibban settlement. John Broome agreed that the tropical pool would be indoor only and reflected this in the revised site plan.

If you refer to plan AA 5538 1300, a raised platform appears clearly showing visitor access and in DWG AA5538 1250RevE it again, clearly shows an outdoor extension of the Tropical Spa water feature.

You will note the site plan submitted within the planning application differs from the site plan (Appendix A) agreed by John Broome to be distributed to locals during the local consultations.

It’s now my clear concern that the developer has not embraced any of the issues raised by the local residents. It is frustrating to see that local consultation process has had absolutely no effect, not even minor changes to the planning application submission.

1

Flood Risk Assessment

The flood risk assessment is based on the existing undisturbed landform.

The application is devoid of a detailed Sustainable Urban Drainage (SUDS) scheme to prove that the proposed development will not create flooding on site, or just as importantly, further downstream.

From the document 01-04 001 I can see that there is 43,370m2 of residential floor space alone, that’s an incredible 10.85 acres of living area, add to that 15,754m2 of central facilities space (3.95 acres), add that to the lakes, car parks, roadways, hard standing areas, the non-permeable area is simply vast. Where are the flow rate calculations in extremis?

Can it in fact, be safely built?

What happens when any of the balancing lakes are at capacity? I can assure you they will be, the applicant must factor for extreme weather conditions we now experience.

Because of the sheer scale, an unnatural, built environment located on poorly draining pasture and marshland, surely it has to be a material planning consideration and must not to be left to ‘deferred matters’.

Will the Environment Agency sign off on this proposal, can they be 100% sure it will not flood? If the scheme is approved will Cornwall Council be prepared to underwrite any future liability?

Visual Assessment

From the documentation it is not possible to determine true visual impact.

The visual assessment document is selective in nature and in no way addresses the visual impact from Trevibban or longer distant views from Tredinnick. Why are there no visuals or massing views from the Trevibban settlement, in particular, the residences most effected and indeed as identified as ‘Sensitive Views’ in the site constraints plan AA5538 1001? Why are there no specific mitigation measures proposed?

No medium or short term, view montages are shown to help determine visual impact, with an application of this scale, how can you possibly determine visual impact from this document alone?

The developers freely admit there will be ‘night glow’ from the site (8.43 Affect on Visual Amenity) Surely this level of light pollution cannot be acceptable in this beautiful, rural location?

2

Ecological Assessment

This is a site rich in ecology, it has to be, for centuries it has been pasture land, we know that orchids exist within the adjacent property, Trevibban Mill, I find it hard to believe that the ecological report is a comprehensive and accurate reflection of the ecology of the site, there are just over 9 pages covering this in the Ecological Assessment, surely this document is completely inadequate for a scheme of such great scale?

By the nature of the extent of earthmoving, infrastructure, lakes created etc. etc. there will be complete and absolute destruction of the existing landscape. If allowed to go ahead, without doubt, will wipe out all the existing flora, fauna and wildlife habitat currently on the site.

There is minimal provision for protecting or stewardship any of the wildlife, flora and fauna of the site in this application (The hand feeding of wild rabbits as observed in drawing AA5538_1208 is duly noted).

There is no provision for wildlife corridors, historic badger runs etc. etc.

The fact that the assessment is merely based on general observations taken from a snapshot of less than a month (March 2015) is surely, woefully inadequate.

How can a large planning application located on sensitive greenland pasture be successfully determined using such scant documentation?

I strongly appose this lightweight approach to the ecology of the site.

Landscape Plan

The application is devoid of a landscape plan.

In all the visuals and plans many mature trees are shown, however the application is silent on detailed landscape proposals, or indeed, any form of planting commitment. There must be a full and detailed landscape plan submission at the planning stage, showing species, maturity of trees proposed and how they will be resourced sustainably.

As a major application within such a sensitive landscape, this must not be left post decision under ‘deferred matters’

3

Employment

The contextual analysis talks of 730 jobs, by looking at the breakdown of employment, it is clear they will be low and semi skilled positions, more than likely on minimal wage, quite probably zero-hour and seasonal contracts.

Is this the type of employment that is actually beneficial to the area?

I understand that the area of Padstow, St Merryn, and Wadebridge there are good employment opportunities with job vacancies currently unfilled. I know locally, jobs such as laundry posts are currently filled mainly by migrant labour, not locals.

Let’s assume 50% of these jobs are indeed filled by locals, that means 365 employees will arrive from out of area - migrant workers. Where would so many workers be housed?

North Cornwall has an affordable housing crisis, this development would only add to these extreme pressures. How can this proposal possibly benefit an area where locals already have great difficulty finding affordable housing?

How does low wage, seasonal work, low/semi skilled employment help local families and communities to truly prosper?

Need

Subjective interpretation of national policy in itself does not constitute ‘Need’.

Retallack Resort is the nearest in concept and location to this proposal, they have also invested in Spa Pools, wave machines, restaurants, activities etc. etc. but for many years have unsold properties on their books and having previously been in administration, clearly demonstrates the difficulties in the sector and the lack of demand for more in the area.

With an application of this nature and especially on Greenfield land, commercial need for such a major development should be clearly demonstrated.

It would be great if the applicant could invite interested parties to view a similar scheme, current or even previous to demonstrate need...

Infrastructure

The Internet connection to the immediate area is woeful; the connection is intermittent and is on average less than 2Mpbs at Trevibban.

There is no capacity to successfully supply broadband into the proposed development.

4

As I understand it, there are no proposals to upgrade the Rumford exchange and as the government announces the right to high speed broadband by 2020, the application is silent on how this may be achieved.

Scale

It is very hard to determine sheer scale from the planning documents, so I thought this might be helpful. I’ve used a Tesco superstore* for comparison, as we’re all generally familiar with scale of these structures.

Let’s just take the tropical pool, located merely 140 metres away from the nearest property at Trevibban

Tesco Superstore 2,761m2 Tropical Pool 5,255m2

It is give or take, the combined size of two superstores, a simply vast, six storey high structure with an additional roof café added on top for good measure

*Source: https://en.wikipedia.org/wiki/Tesco / DWG PA5538 1250

Noise

The application is devoid of a noise impact assessment and any mitigation measures that are likely to be required.

The restaurants, spa, tropical pool and service area are vast amenities and are in very close proximity to the Trevibban settlement. There has been no consideration given to location in respect of the transmission of noise.

Centre parks, the closest scheme I can find in planning terms to this proposal, do not build near residential settlements because of noise generated. Ask anyone who has been; they can be very noisy indeed.

This application is not residential by nature, it’s a tourist park, people having a good time, being outdoors, you’re going to get noise, we experience noise on a daily basis from Creely, but this proposal is literally on our doorstep, it is not a suitable location for this type of development.

The central facilities layout DWG AA 5538/1250 is devoid of any plant room locations to service tropical pool, spa, restaurants etc. does not show where plant to supply heat, air conditioning etc. etc. is to be located. Such vast, energy intensive structures require major plant and machinery running 24/7. Where is this located? What sound levels in db will be generated? How will this noise be mitigated?

Pre-application PR talked of bio-mass heating, where will the stack be located? How high will it be?

5

No detail regarding traffic flow for service lorries are given, we know that refrigerated trucks often arrive in the early hours keeping their engines running to maintain temperature, where will they park to be unloaded?

Staff changeovers, will occur on a 24 hour basis, where is the staff car park? How is traffic managed during anti-social hours?

Changeover day, How will traffic be managed? These issues do not seem to be considered in the application documentation.

Accuracy of Application

The application has inaccuracies and surely, should not be determined as it stands.

On all the site plan (which should be accurate and scaleable) if we take a look at the six storey Tropical Spa, plans show a continuous green roof, where in fact, this is clearly not the case, taking a look at drawing number AA5538-1301, you can clearly see balustrading and stair access to the roof from the café. Clearly it’s an extended operational area that is hidden in the site plan. This outdoor café area has further sound implications for the Trevibban settlement.

Additionally, in AA5538 1250 RevE, a new building appears (not shown on the site plan or mentioned at the public consultation) it’s.... – 18. Service area, to include laundry, food delivery, kitchen prep/maintenance. It’s close to the Trevibban settlement, has noise and nuisance implications, again it’s missed out on the site plan.

AA5538 1200 shows similar inconsistencies.

Plan AA5538 1008c Site Levels (conveniently) does not show the proximity of the proposed development to the Trevibban properties (on this plan they simply don’t exist), so locational relationships in terms of FFL and ridge heights etc. means the massing effect between the two environments cannot be determined. Surely this document is inadequate.

Generally, there is a general lack of detailed scale drawings, plans, massing information, building heights, cross sections etc. etc needed to help determine the schemes impact locally.

The newly added rooftop amenity, service area right on the site boundary, service areas, reinstatement of outdoor tropical spa amenity were not disclosed during the public consultation and today, still remain hidden on the site plan.

6

In summary

In my opinion,

• The supporting documentation for this planning application is lightweight, inconsistent and misleading.

• There has been absolute failure to address any of the communities concerns during the public consultation process.

• There is no proven need.

• It is a vast tourist park; it is incorrectly located adjacent to a residential

  settlement.

• There are no planning grounds for this to be approved.

  I am strongly opposed to this development. I urge Planning Officers and Councilors to have this application “called in” and not be determined at planning level, as it is my opinion, the applicants believe the validity of such an application is solely based on their own interpretation of newly adopted / emerging planning policy.

  Peter George 

 

 

30 December 2015

North Cornwall Planning Committee Cornwall Council
For attention of Paul Banks

Objections to Proposed Camel Creek Resort Development application - Case PA15/08900

 

Dear Sirs,

We are objecting to the proposed scheme for the reasons set out below. We are also making a number of requests for the Council to consider.

1. Commitments made by John Broome to us and other residents in adjoining Trevibban Barton

Area north of activities centre/ tropical pool to be undeveloped woodland

The overall (and presumably most up to date) Site Plan 1005 M shows the area to the north of the activities building would remain undeveloped woodland with a smaller overflow parking area on the north  east.    However  the  plan  on  page  25  of  the  Design  and  Access  Statement  (“DAS”)  shows  a  large   overflow carpark in the area and section 5.4 of the DAS says that overflow parking is provided to the east of the central buildings. Similarly the plans on which the Environmental Statement (“ES”)  are based (eg Environmental Statement Appendix 8.2 Part 2) indicate land to the north east of the activities building would be for overflow parking. The plans in both the DAS and the ES also show a Service area on the north west of the Activities building which is not in Site Plan 1005.

John Broome visited us at our property in August 2015 and assured us that this area would remain undeveloped woodland, since it is high up and very visible and also adjacent to the properties at Trevibban Barton. John Broome showed the attached plan to us to demonstrate his commitment that there would be no overflow parking and no Service area in this area.

Steel Appendix - Document-15 provided to residents by John Broome.pdf

It is not clear what the applicant’s  actual  plans  are as the plans in the application are inconsistent with each other and with the attached plan he showed us.

We believe the application should be refused but we request that if the planning committee is minded to allow any development that this be subject to a planning condition that this area north of the activities centre and tropical pool and adjacent to the Trevibban Barton community remains

Mr and Mrs T Steel Oakie Barn Trevibban Barton St Issey

Cornwall PL27 7SE

undeveloped woodland, as John Broome had committed to local residents and as shown in the attached plan given to local residents in response to concerns raised.

Road layout to not be a complete loop

We were also told by John Broome that the road would stop at the northern end of the Tropical Pool building and there would be no access for vehicles to pass through to exit the site on the north side, in order to restrict the traffic volume and noise in the north part of the site adjacent to Trevibban Barton. The attached plan shown to us and provided to other residents of Trevibban Barton demonstrates this. However in the submitted plans the road in the northwest corner above activities centre still exists but appears to narrow in some drawings (eg 1008, 1005) whereas it remains a full road in others (eg 1250 and the DAS page 25). We also note that the DAS section 5.7.3 refers to a continuous loop which is contrary to what John Broome told us.

Again, if the scheme is allowed to proceed we request this is conditional on keeping the commitment made by John Broome to the residents of Trevibban Barton that the road would not be continuous around the northern part of the site.

Use of Private access lane to Trevibban Barton

There is single track privately owned access lane to the Trevibban Barton complex which the previous owner of the site was entitled to use to access his deer farmland on which the proposed scheme would sit.

John Broome also assured us in person that this lane would not be used to access the site either during the construction phase or thereafter as it would be unsuitable for this purpose. He offered to provide a padlocked gate where the lane meets his land, which we would hold the keys to. We also request that if any permission is given it is conditional on not using the Trevibban access lane to access the site.

2. No need or demand for the development

Substantial new holiday accommodation already approved nearby

The nearby Retallack planning applications demonstrate there is no need for this proposed development either in terms of need for more luxury holiday accommodation in the area or to satisfy existing or create new demand. Retallack is less than 4 miles from Crealy and was granted permission in January 2014 to build another 334 holiday lodges (which they refer to as providing luxury tourism) and 32 staff accommodation units in addition to their existing lodges, as well as swimming pools and other leisure facilities. [We note the Camel Creek application appears to make no allowance for staff accommodation]. Surely having already granted permission for 334 new holiday homes nearby, there is no need to permit the complete destruction of tranquil and attractive agricultural land (which the applicant notes in para 7.55 in the Planning Statement may include Grade 3a quality land and would therefore contravene Local Plan Policy 22), and all the wildlife it must support, in a National Landscape Character Area for further new holiday homes?

Ability to create quality jobs

The first listed benefit claimed by the applicant in 3.2 of the Design and Access Statement (“DAS”)  is the  creation  of  705  full  time  employees  and  a  further  250  from  “enhancements to Crealy Adventure Park”.      In  section  3.3  it  says  it  will  create  1400  new  jobs  of  which  50%  will  be  full  time.    If  this  is  a   deciding factor for granting consent then the viability of the scheme and its ability to provide quality jobs should be proven (see below).

Even if the scheme were to be viable the majority of any new jobs created would in fact likely be flexible hours or part time and around minimum wage. Most positions would be unlikely to be filled by local residents and therefore create further transport and affordable accommodation needs. We note  the  Planning  Statement  refers  in  paragraph  6.28  to  Policy  2  in  Cornwall’s  emerging  plan   containing  an  objective  to  support  an  increase  in  “better  paid  full  time  employment  opportunities” which these will predominantly not be.

Viability of scheme given market failure for new holiday accommodation

Retallack recently applied in July 2015 to have the holiday use restriction removed from their planning  consent  because  of  the  “market  failure  in  holiday  occupancy  restricted  developments”   (extract from their July 2015 Planning Statement section 1.3). In section 1.4 of the Statement they say  “the position regarding market failure in the new holiday accommodation sector is fully recognised by Cornwall Council”. In  their  Planning  Statement  conclusion  8.1  they  state  “with the holiday use condition, the proposed development is neither fundable nor viable both for the developer and potential investors/owners”.      We note that the applicant is proposing holiday use restrictions at Camel Creek and acknowledge that otherwise it would not comply with the Development Plan and national policy (see paragraph 3.4 and 7.11 of their Planning Statement).

The applicant is promising so-called  “6  star”  accommodation.  But there is no evidence provided in the application documents to support the feasibility of the scheme. We are extremely sceptical that the location of the site, being 5 miles from the coast with no coastal views, with indirect road access to the coast, being adjacent to Crealy, being a highly seasonal destination and being at least 5 hours from London, will attract sufficient investor or tourist demand for 236  “high  quality  six star holiday dwellings”. John Broome told us that the double villas would sell for around £2m each whereas local estate agents we have spoken are very sceptical that holiday homes this far from the coast could sell for anywhere near this amount, particularly given the holiday use restriction makes it difficult to obtain mortgages and the recent stamp duty increase on holiday homes.

We noted that Will Broome told the Cornish Guardian that the applicant has carried out extensive due diligence but we also note that the applicant has a track record of similar grandiose projects which have failed. We believe the planning authorities should not consider allowing this scheme without a thorough independent and objective feasibility study by a reputable expert to consider whether a six star holiday use restricted scheme is viable, whether it will really support 705 full time equivalent jobs, and whether the applicant will likely be able to obtain sufficient funding to ensure that the project can be completed as envisaged. If not there is a risk of an incomplete or abandoned project or the planning authorities being forced to consent to a modified plan, perhaps of lower quality or higher density and/or removing the holiday use restrictions in contravention of planning policy as is being requested at Retallack.

3. Scale of proposed development and impact on views and character of the site

Vast scale of proposed buildings

We note the scheme proposes siting the tallest and largest proposed buildings on the highest part of the site. Section 4.5 of the Design and Access statement says the eastern elevation of the Tropical Pool, which is on the upper part of the site and around 100 metres from the existing neighbouring properties, will have a height of 21.5 metres (per table 4.1 in Environmental Statement chapter 4). We estimate from drawing 1250 the building would be around 160 metres long and the north eastern end wall would be around 80 metres long (note the scale on plan 1251 indicate this north eastern elevation would be 160 metres long but we hope this is an error in the drawing). This is an absolutely vast building which, as another objection notes, is six stories high and approximately twice the size of a typical Tesco superstore. The proposed accommodation covers an area of 43,400 square metres (dwelling schedule 001) and the proposed facilities have an area of 19,500 square metres (facilities schedule 003). This would completely adversely change, and is totally out of keeping with, the current tranquil agricultural landscape.

Impact on character of a National Landscape Character Area

The applicant’s  Landscape  Appraisal  acknowledges that the proposed development sits within National Landscape Character Area NCA 152 - Cornish Killas (para 7.1) and Cornwall Landscape Character Area 34 - Camel Estuary (para 7.2) and is situated  “in  an  isolated  rural  location,   consequently  tranquillity  levels  are  generally  considered  to  be  high”  (7.28).    This  massive   development would significantly damage the quality of the local area.

The site is highly visible from the B 3274 which is a primary access route for tourist visitors and currently provides the first view of the Camel Estuary for visitors in a scenic, rural landscape. We expect this would be significantly impacted by this vast development, including a 20m high, 160m long and 80m wide predominantly glass-walled pool building only 500m away.

Lack of drawings or visuals provided to show impact on views

There is a Landscape Appraisal document (B.0387 06B LVIALR Landscape Appraisal) which discusses the impact on the views from 11 viewpoints but surprisingly only one of these is a short range view (which notes major impact) and none of these cover the views from adjacent communities such as Trevibban Barton (despite these being identified as sensitive in the contextual analysis in page 17 of the DAS) or the nearby B 3274.

There are no drawings provided which show a cross section through the site and its surroundings to illustrate the heights of the buildings and how prominent the buildings such as the activities centre and tropical pool will be from the surrounding areas.

Document AA5538 01.07 001 DAS (“DAS”)  section 2.3.10 p17 says it is important to protect the rural character of the surrounding area and the visual impact should be limited to respect views from existing properties to the north of the development. But there are no drawings showing what the visual impact will be on the existing houses at Trevibban Barton adjacent to the site or from the

nearby roads. It is not possible for affected parties or the planning authorities to assess the impact of the proposed scheme without drawings showing the intended impact on the landscape and on the views from the existing properties and from the B3274.

Planting

The applicants state, in section 4.4 of the DAS, that nearby properties will be screened from the development  and  that  “this  approach  will  effectively  eliminate  the  visual  impact  on  any  potential   surrounding  areas”  but  how  can  this  statement  be  demonstrated  without  drawings  illustrating  the   impact?

Furthermore, it says  “the  properties  that  do  adjoin  the  site  will  be  screened  from  any  development   by  extensive  planting”.   Do the trees illustrated in the plan 1005 represent the committed planting plan - there appear to be no details provided of the planned planting in terms of the number, type, size, maturity of trees that will be provided. Will the trees really be tall and mature enough to screen a 21.5 metre tall and 80 metre wide glass building 100 metres away from the Trevibban Barton community?

We request that any permission given is conditional on evidence of a committed detailed planting plan  that  will  genuinely  “eliminate  the  visual  impact  on  any  potential  surrounding  areas”.

4. The scheme does not in our opinion meet Planning requirements

This scheme would have a significant adverse impact on the surrounding countryside and settlements

Planning  Statement  (“PS”)  para  6.10 refers to planning Policy ECN 12: Purpose built holiday accommodation which states that new purpose built self-catering accommodation will only be permitted where they are suitable in scale and character for the location and meet one of 3 conditions. The first 2 (conversion of existing schemes or farm diversification) are clearly not met and condition (c) requires that they are located outside the designated landscape areas, will not have a significant adverse impact on the surrounding countryside and that it provides accommodation unlikely to be met by the adaption and improvement of available existing sites in the locality.

PS para 6.34 refers to  Planning  Statement  22a:  Protection  of  the  Countryside  in  Cornwall’s  emerging   plan  which  “seeks to prevent the loss of undeveloped countryside and states that permission will only be granted where they:

•   Can show existing urban capacity and unallocated land cannot meet the local need, and/or:

•   Have no significant adverse impact upon biodiversity, its beauty, diversity of landscape, the

  character and setting of settlements, the wealth of natural resources, agricultural, historic and recreational value.

  In para 7.38 and 39 the PS concludes that the development would respect the existing landscape character and would not have a significant adverse effect on the character areas and surrounding areas and therefore complies with ECN 12 and Local Plan Policy 23. This must be an area where the planning authorities need to apply judgement but we find it difficult to accept that 43,400 square metres of accommodation and 19,500 square metres of facilities, including a 21.5 meter glass

• building twice the size of a Tesco superstore, can be suitable in scale and character for this rural location and would not have a significant adverse impact on the site which is currently a scenic and tranquil deer farm, on the adjacent Trevibban Barton settlement or on the views from the nearby roads. Furthermore the conditions in ECN12 are not met as there is accommodation available at existing sites in the locality at Retallack.

  Claimed holistic link with Crealy

  PS  para  5  refers  to  ECN  3:  Business  expansion  which  states  that  “proposals  for  expansion  of  an   established business on land adjoining an existing site will be permitted where the development cannot  be  satisfactorily  accommodated  on  existing  or  allocated  employment  land...”    In  para  7.7  the   applicant argues that the proposed scheme is located next to Crealy Adventure park which is an established tourism business and accordingly complies with ECN 3.

  We disagree with this claim. The proposed scheme would not be expanding an established business. John Broome told us there will be limited access between the proposed resort and Crealy and the plans confirm this. The target market for six star accommodation is completely different to the established customer base of Crealy. If the applicant genuinely regards them as the same business either he does not really intend  for  Camel  Creek  to  be  “six  star”  or  Crealy  will  need  to  significantly   change away from the established business. We do not believe this meets the objectives of ECN 3.

  5. Likely adverse impact on local businesses

  As the Retallack applications demonstrate, the market for quality holiday accommodation is already over-supplied and the proposed development would further adversely impact existing holiday accommodation businesses and particularly local people letting accommodation in the local area.

  Planning statement 7.16 and 7.17 says that the retail and leisure facilities would not compete with town centre facilities and are primarily to serve the holidaymakers staying in the complex. The plan shows buildings 2, 7, 11, 12, 13 and 14 are respectively a Tree House restaurant, a Restaurant/Café, a Fine dining restaurant, a Mid-market restaurant, another Café and (another ?) Tree House restaurant. Other documents refer to a planned pub. We question whether guests staying in 236 units, most of whom would not choose to eat in the resort facilities each day, could provide enough demand. For this many outlets to be financially successful they would surely need to attract visitors away from Padstow and elsewhere.

  6. Noise and light pollution

  No noise study provided

  Planning statement para 7.52 states that the development would not result in a material increase in noise which would result in disturbance, noting that the area is not particularly tranquil because of the Crealy Adventure Park. There does not appear to be any study performed to evidence this assertion and it seems likely to us that there will inevitably be a material increase in noise from such a vast tourist park.

  Trevibban Barton does suffer from noise from Crealy during opening hours if the wind is coming from that direction, however the proposed development is much closer and there is currently complete silence (other than natural sounds) after Crealy closes at 5pm or 6pm. Also the fact that Crealy can already create some disturbance for local properties is a reason to ensure no further noise pollution is allowed, not an excuse to allow it to get worse!

  Tropical Pool noise

  Some drawings (eg 1005 site plan) indicate that the Tropical Pool buildings will be totally enclosed whether the pool plans (1251 to 1252) indicate that part of the pool will extend outside the building. Local residents were told by John Broome that the buildings would be enclosed and there would be no noise created. No external pool areas should be permitted so close to existing properties.

  Furthermore it is not clear where the heating and cooling plant, which will need to be very large to service the pools and the vast central buildings, will be situated and what the noise impact will be. We believe there must be an assessment of what will the noise impact be on the nearly properties.

  Traffic Noise

  The transport assessment (Environmental Statement Appendix 8.1) predicts 524 vehicle journeys per day and a peak rate of 73 per hour. This appears to ignore staff and non-resident visitor (eg convention centre) traffic and is based on data from a Butlins site - we question whether this is really comparable or relevant given visitors to the Camel Estuary area are more likely to want to leave the site to visit the local beaches or towns. Even based on the applicant’s assessment there will be almost continuous traffic noise from the site.

  Night light pollution

  The area is currently completely dark and tranquil at night time. There is no night glow and one of the features of the area is the view of the stars on a clear night. The Landscape Appraisal (prepared by Pegasus who also prepared the planning application) section 8.37 states that the properties to the north may experience minimal night glow and paragraph 8.43 concludes there would be an overall minor adverse effect. No evidence is provided to support this view. We believe the light pollution from the scheme will create a very significant adverse change to the environment given its size; in particular the vast tropical pool building appears to have primarily glass walls – the north east side elevation alone which faces the Trevibban Barton community appears to have a surface area of around 1,700 square metres (80m long and 21.5m high). Surely this would be highly visible from these properties and the B 3274 and other roads after dark, even if screened with planting? We believe a proper independent study should be required and if permission is granted conditions should be applied to mitigate light pollution such as requiring all glass walls to have shutters that close whenever artificial lights are switched on.

  7. Parking

  One of the inconsistencies in the different plans in the application relates to overflow parking as noted above. Section 5.4 in the DAS addresses parking space but there appears to be little analysis of the parking spaces required. It  states  there  is  parking  for  100  “service”  cars  but  will  this  be   adequate for the claimed 955 full time equivalent employees? It is not clear from the plans where

  guests would park on arrival whilst checking in at reception, where delivery lorries would deliver goods and turn around or where taxis or shuttle buses for the convention centre would drop visitors off.

  8. Drainage and flood risk

  The DAS section 2.3.7 notes that the site falls within low Flood Risk Area 1 and some parts of the site are within Flood Risk Areas 2 and 3. We know from experience at Trevibban Barton this area is susceptible to flooding and the flood risk assessment does not adequately address the worst case impact from the removal of land which currently absorbs surface water and the additional output from this enormous proposed development.

  9. Summary

  In summary we strongly oppose the proposed scheme because:

•   Commitments made by John Broome to residents of Trevibban Barton have not been seen through in the final plan submitted

•   Retallack already has permission for 334 new luxury holiday lodges less than 4 miles away and has reported that their proposed development is neither fundable or viable without removing the holiday use restrictions that are required under planning policy

•   We  do  not  believe  a  so  called  “six  star  resort”  is  viable  in  this  location or adjacent to Crealy and there is no indication of any objective feasibility study to evidence viability

•   The promised jobs, if provided, would mostly be low level part time positions unlikely to be filled by local people so creating further pressure on affordable housing

•   The scale of the development (64,000 square metres of buildings) is totally out of context with this rural tranquil location in a National and Cornwall Character Area and will destroy farmland and the local ecology

•   There are no drawings or visuals to show the impact on local views and no detail or commitment on the proposed planting or screening to be created

•   The scheme does not meet planning policy as it will have a significant adverse impact on the countryside, there are already available existing sites and it would be a new business not an extension of an established business

•   There is no noise study or light pollution study to assess the impact on the Trevibban Barton communities

•   This will likely create additional flood risks.

• We sincerely hope you will reject this application. Yours faithfully,

•  

• Tim and Jo Steel