Retrospective planning application EDDC 18/1517
UK National Commission for UNESCO already alerted by members of the general public
“Jurassic Coast Trust (Objects)
Comment submitted date: Tue 04 Sep 2018
Firstly, we would like to point out that the Jurassic Coast Trust, as the organisation responsible for the protection of the Jurassic Coast World Heritage Site, should have been formally consulted on this application.
You should also be aware that this application has been raised by the general public with the UK National Commission for UNESCO, with whom we are now liaising.
The core issue for us is the extension of the viewing deck or ‘ice cream deck’ into the World Heritage Site (WHS). The boundary for the WHS is described for this part of the coast in appendix 2 of the Site management plan. Both the full plan and its appendices are available to download freely from http://www.jurassiccoast.org. At Ladram Bay the WHS sits between the break in slope at the top of the cliff and the mean low water mark. The extension of the decking therefore has a direct impact within the Site’s boundaries.
These potential impacts should be considered under the following policies from the WHS management plan:
1.1 Protect the OUV (Outstanding Universal Value) of the site through prevention of developments that might impede natural processes, or obscure the exposed geology, as set out in the GCR / SSSI details, now and in the future.
1.2 Where developments affecting the Site or setting do take place, avoid or at least mitigate negative impact on the natural processes and exposed geology.
1.3 Oppose developments in the Site’s setting that may warrant a future need for coastal defences, particularly in light of potential sea-level rise and extreme weather events.
1.4 Protect the landscape character, natural beauty and cultural heritage of the Site and setting from inappropriate development.
Retrospective planning permission is wholly inadequate to deliver these policies for three key reasons:
1 There is not enough information provided about the nature of the structure and how it is anchored and supported. A proper assessment of its impacts on the WHS is impossible based on this application.
2 Retrospective permission does not allow for the mitigation of impacts within the design process.
3 There is no evidence that alternative approaches that provide similar benefits to the holiday park’s users whilst protecting the natural environment have been considered.
National Planning Policy provides World Heritage Sites with the highest level of protection (see NPPF paragraphs 184 and 194). The long operation and high rating of the holiday park does not excuse the applicant from following proper planning procedures.
If the applicant had followed normal planning procedure, we would have had the chance to comment early on the design, suggest alternatives if necessary or, if deemed to be appropriate development, recommended suitable consent conditions.
Protection of the World Heritage Site relies on the planning system to deliver these opportunities.
We strongly recommend that East Devon District Council refuse this application.”