Development
of
Lyme Regis Golf Club
Member's
Practice Area

"AONBs were designated to conserve and enhance their landscapes"
"Beyond the picturesque", The Countryside Agency


Points of Objection

Planning Application No. 1/W/06/000161
Lyme Regis Golf Club, Timber Hill, Lyme Regis, DT7 3HQ

'Erect single storey timber clad golf driving range, small office, and store, and extend car park' (Full)

Now that an Appeal has been lodged against the Refusal of 25th May 2006 you may wish to browse the suggestions given below for ideas for adding to your representation to the Planning Inspectorate. Both the Council's decision notice and the officer's report for this application can be accessed by going to the planning website enter the application number 1/W/06/000161, click search and then click on the Decision or Report tab.

I suggest that you only write to the inspectorate if you have something new and significant to add to your original representation, perhaps a comment on the club's reasons for apealling, let's not bombard the inspector with unnecessary letters.


Please make allowances in what follows for it was written before the application went to committee

We are now dealing with the third driving range application for the site. Previous applications were 1/W/2004/893 made in 2004 and 1/W/05/000854 made in July 2005. The 2005 application saw a reduction in size of the proposed driving range building and an attempt at tree screening the car park.The current application now sees an almost identical application to that of last year but the building has been lowered into the ground by 900 mm. This has necessitated some ground work in making a splayed gently sloping area to the front of the building.

Recreational facilities are already being provided on this field, which the latest application calls a driving range (without buildings), in accordance with the above policies. The construction of a virtually unscreened stark building approximating the size of two London double-decker buses would tip the balance and go against all the above policies.

I include immediately below details of the wording of WDDC's refusal notices to both of the previous applications.



Planning Application 1/W/2004/893 and 1/W/05/000854

The Reasons For Refusal

The proposal comprises development in the open countryside, within the Area of Outstanding Natural Beauty (AONB) where the primary objective of planning policy is the conservation of the natural beauty of the landscape. Having regard to its location, size and prominence the development would be contrary to this objective and detrimental to the rural character and appearance of the area. The proposal is therefore contrary to Environment Policy G (Re:AONB) of the Bournemouth, Dorset and Poole Structure Plan (adopted July 2000), Policy L1 (Re: the ANOB) of the West Dorset District Local Plan (adopted November 1998), and Policy SA1 (Re:the AONB) of the West Dorset District Local Plan Revised Deposit (published March 2004), as well as to the objectives of the landscape character designation of "West Dorset Farmland" in West Dorset 2000 (adopted as Supplementary Planning Guidance in February 2002).

All the above policies are also relevant to the present application and just quoting the policies should be sufficient to stop this proposal. But if you feel like adding a little more I include some suggestions below.

As with the Strawberry Field sports complex development proposal on the adjacent field there are two incontrovertible reasons that this application should be refused: (click on the links for more details) Additional supporting reasons that the application should be refused: Although not a planning matter you may feel, as many people do, that you would like to comment on how the interests of town councillors Owen Lovell and Ken Meech may influence their views on this application. They are also the chairman and vice-chairman of the Development Control West Committee, the committee that will determine the application's outcome.

Contravention of Planning Policies

Area of Outstanding Natural Beauty (AONB)

" IN AREAS OF OUTSTANDING NATURAL BEAUTY LOCAL PLANNING AUTHORITIES SHOULD LOOK TO MEET THE DEMANDS FOR SPORTING AND RECREATIONAL ACTIVITIES WHERE THE PROPOSALS ARE CONSISTENT WITH THE PRIMARY OBJECTIVE OF CONSERVATION OF THE NATURAL BEAUTY OF THE LANDSCAPE, AND THE NEEDS OF AGRICULTURE, FORESTRY AND OTHER USES"

The field is presently providing sporting activities which are consistent with the conservation of the natural beauty of the landscape. The construction of the building and landscaping to form the splayed area though will seriously detract from the natural beauty of the area.

Defined Development Boundary of Lyme Regis (adopted and draft)

Outside of which development is not normally allowed.

The following policies of the Local Plan (adopted) apply:

  • POLICY SP3 (Development Outside Defined Development Boundaries)

    DEVELOPMENT WILL NOT BE PERMITTED OUTSIDE THE DEFINED DEVELOPMENT BOUNDARIES SHOWN ON THE PROPOSALS MAP, EXCEPT AS FOLLOWS:-

    vii)
    TOURIST, RECREATION OR COMMUNITY FACILITIES APPROPRIATE TO A RURAL AREA IN ACCORDANCE WITH LOCAL PLAN POLICIES T4,T10,R6 AND R10.


  • POLICY R10 (Countryside Recreation Proposals)

    PROPOSALS FOR THE PROVISION OF RECREATIONAL AND SPORTING FACILITIES IN THE COUNTRYSIDE WILL BE PERMITTED PROVIDED THAT:

    i)
    THEY ARE COMPATIBLE IN CHARACTER, DESIGN AND SCALE WITH THE SITE AND ITS SURROUNDINGS;
    ii)
    THE AMENITIES OF LOCAL RESIDENTS AND VISITORS ARE SAFEGUARDED;
    v)
    THEY DO NOT CONFLICT WITH LANDSCAPE POLICIES IN CHAPTER 7 OF THE LOCAL PLAN.


  • POLICY L1 Chapter 7 - Areas of Outstanding Natural Beauty)
  • WITHIN THE DESIGNATED AREA OF OUTSTANDING NATURAL BEAUTY, PRIORITY WILL BE GIVEN TO THE CONSERVATION OF THE NATURAL BEAUTY OF THE LANDSCAPE. EXCEPT FOR SPECIFIC ALLOCATIONS IN THE LOCAL PLAN, DEVELOPMENT IN THE AREA OF OUTSTANDING NATURAL BEAUTY WILL ONLY BE PERMITTED WHERE IT WILL NOT RESULT IN HARM TO THE NATURAL BEAUTY OF THE AREA. PARTICULAR ATTENTION WILL BE PAID TO THE DESIGN, EXTERNAL APPEARANCE AND LOCATION OF ALL PROPOSED DEVELOPMENT IN THIS AREA.

Whilst the following policies of the Revised Deposit (published March 2004), of the Local Plan must be considered:
  • POLICY SA1 (Area Of Outstanding Natural Beauty)

    DEVELOPMENT WHICH WOULD HARM THE NATURAL BEAUTY OF THE AONB WILL NOT BE PERMITTED. DEVELOPMENT WILL ONLY BE PERMITTED IF ITS SCALE, SITING AND DESIGN CONSERVES AND, WHERE THERE ARE OPPORTUNITIES, ENHANCES THE QUALITY OF THE LANDSCAPE".

  • POLICY C8 (Countryside Recreation Proposals).

    PROPOSALS FOR THE PROVISION OF RECREATIONAL FACILITIES IN THE COUNTRYSIDE WILL BE PERMITTED PROVIDING THAT:

    i)
    THEIR SCALE IS IN KEEPING WITH THE SURROUNDING ENVIRONMENT AND THEY WOULD NOT BE VISUALLY INTRUSIVE IN THE LANDSCAPE.

Government Inspectors's Report

Objections to the Revised and as yet unadopted Local Plan have recently been considered by a Government appointed independent inspector. Inspector Jill Kingaby said that the golf club's neighbouring Strawberry Field is not a suitable site for built recreational facilities.(See LRNews 3rd Feb 2006) This must also apply to the driving range field which is just over the hedge from Strawberry Field. Could the inspectors ruling on this be responsible for the appearance of two articles in the Lyme Regis News (3rd March 2006) both concerned with development along the Charmouth Road. To put it bluntly do the town council and the golf club feel that if planning permission is not obtained very soon then the Local Plan once adopted will put an end to all such pipe dreams?
See government inspector Jill Kingaby's report

It is probably already too late for even the unadopted Local Plan is required to be taken into account when considering planning applications. West Dorset District Council Director of Planning and Environment David Evans said: "This is not a binding report [Jill Kingaby's] but we have to follow the inspector's recommendations unless there are very clear and sound planning reasons to do otherwise, which have not been fully considered during the inquiry process". The question is by what degree will it be taken into account, on this the future of these fields probably rests.

Additional reasons for refusal of planning consent

Precedents have been set both by a government inspector and by the WDDC's Development Control West Committee to protect the Lym Valley from further development. This alone should protect the practice area field from this development. Listed below are examples of decisions of refusal made by the government inspector and the DCWC.

  • Government Planning Inspector Mr. Christopher Gethins said "The Lym Valley extending northwards from Lyme Regis is clearly an asset which should not be further eroded by non-essential development" (LRNews 28 Feb.2003). And that the natural beauty of the Lym Valley deserves the strongest protection from unnecessary development. He said the national policy for protecting such sites made the strongest possible case for resisting unnecessary development to which he attached considerable weight.

    The appeal hearing at which he was presiding over was the result of the WDDC's DCWC's refusal of application 1/W/2002/0547 to build a garage with living accommodation over at Manor Fields Farm in Lyme Regis on the ground that it was outside the Lyme Regis development boundary (DDB) and within an AONB, and respectively contravened policies SP3 and L1.The site is within the same valley and AONB and less than a kilometre away from the practice area. He considered the building would 'cause significant harm to the natural beauty of the Lym Valley ' and it would be clearly visible from the other side of the valley'.

  • An application (no.1/W/2002/0345) for a tennis court at Fernhill Hotel, 600 metres distant from the proposed driving range site, was refused (LRNews 10 May 2002). The Development Control West Committee claimed it was "inappropriate so close to the new world heritage site". Both Fernhill and the practice area are approximately 600 metres from the cliff tops of the world heritage site. Principal area planning officer Gerald Hughes told the committee that the proposed site was in an area of very attractive, unspoilt countryside. The hard surfaced tennis court would "erode the quiet beauty and rural character of the area". The Golf Club application would have much greater impact on unspoilt countryside than the Fernhill application, already blighted by the busy A35, otherwise what was said concerning that site also applies to the practice area.
  • One of the strongest possible precedents against developing along this escarpment must now be the planning officers robust case against the Strawberry Field proposals. Many of his points also apply to the present application. Great concern was given to the ineffectiveness of the screening proposed on that site. Although some tree planting between the road and the range building and also at the sides is planned for the present application the openness to the Harcombe valley will remain. It is in the nature of such a beast to be open to the environment in the very direction that screening would be most required.

    Unfortunately the officer's Strawberry Field report no longer seems to be available on the WDDC website, but if you would like to see it I would willingly email you a copy. You will need Acrobat Reader and the file size is 500 kb.

  • The refusal of the 2004 and 2005 driving range applications have now themselves become precedents. The outcome of the present application will be eagerly awaited by those interested in development in this area. The rejection of this latest application will further add strongly to the weight against future development, including the inevitable one for Strawberry Field, on this hillside. You can help to make it so by objecting to this application.

The Harcombe Valley, of which the recently adopted Parish Plan had some cautionary warnings (see extract) will be detrimentally affected by this incongruous building. Sited along the escarpment it will be very obvious all along the Harcombe Valley north from Rhode Hill. The nature of the building excludes any possibility of screening it from view from the valley. Viewed from certain angles across the valley it will not be the actual building that will be seen but the 20 metre (appx) wide gaping rectangular black hole formed by the opening.

Although the building in this latest application will be sunk into the ground by 900mm it will not result in a lessening of the impact it has on being viewed from the opposite side of the valley. From this direction the full height of the building will still be visible. In fact it could be argued that its impact will be worse. The landscaping to form the splay to the front of the building will in fact concentrate and funnel the eye towards it. The actual splay will also introduce an aspect to the landscape completely out of keeping with the present land use .

Although it is planned to increase the planting on the Devon banks around the building it is not clear if the corrugated steel roof sloping down to the Charmouth Road will be effectively screened. The result could produce a stark contrast between the magnificent views obtain across the hedge of Strawberry Field and an industrial like scene.

Piecemeal development. This application should not be viewed as an isolated unimportant development. It comes after a long and bitterly fought battle over the development on the next field to the practice field - Strawberry Field. The golf club was probably holding off with their first application hoping that if the Strawberry Field application was successful it would ride along on its back, for once a foothold of development has been made further applications are much easier. This application is now the crucial first step in development along this escarpment and must be repelled.

It must also be borne in mind that the golf club offered MMO2 a site on the field for their TETRA mast. This offer was taken up and resulted in the installation of the mast without planning permission. An indication that the club is not at all concerned about the environmental issues or the preservation of the AONB. Their first driving range application was devoid of any feeling for the fields place in the landscape. It was merely an afterthought once their applications were refused that they turned first to attempting screening with trees and hedges and now with the latest version cutting the building into the ground. With such cavalier attitude to the environment how long would it be before their, "The plans do not include any provision to install any artificial lighting" was reversed once the building was installed?

The approval of this particular application would signal the way ahead for more development in this area. The town council have already suggested to WDDC that the Defined Development Boundary (DDB) be extended to include the town council owned Strawberry Field but fortunately the WDDC show more concern for the conservation of the landscape of this area than the local council and refused to include it. A driving range breaching the DDB would be a precursor to development on Strawberry Field and beyond.

Present sporting use of the field is as a practice area for the golf club. Whilst there is planning permission for a pitch and put course on Strawberry Field. Neither of these activities requires a building. For this is the crux of the matter here. It is not that there may be more people using the field, for the doubling or trebling at any one time - with the exception of parking - could easily be accommodated.

The crucial thing here is the building. Once one building is erected on either of these sites then as certain as night follows day others will follow. The first building to the west of the main road must be resisted at all costs. It is not what the building will be used for, its size, colour, materials or even how well screened but just that it is a building that will stand on fields where none has stood before. Construct one building here and you can say goodbye to the valley as we know it for ever.

On the Plans of the 2004 application there were many obvious mistakes in the dimensions of the building. The architect overcame this problem with the 2005 application and now this one by not putting in any dimensions at all. How can these plans for a building in such a prominent and sensitive position be taken seriously if measurements are not included?

  • I did check the actual dimensions for the 2005 application with the club's agent. The building's max.depth was 9.5 metres (31ft) , with a length of 19 metres (62ft 4in.). The roof heights above the floor level were 3 metres (9ft 10in) at the back of the building and 4.7 metres (15ft 6in.) at the front.

    Because of the sloping ground, the floor level at the front of the building was above ground level. This resulted in the roof having a height of 5.3 metres (17ft 4½in.) above ground level at the lowest corner.

    Although the building in the present application, and we assume it has the same dimensions, is sunk into the ground by 900mm (3ft) the ground to the front of the building is cut away by a similar amount thus presenting the full height of the building to viewpoints across the valley.

    As a visual aid to its size picture two of the old London Route Master buses end to end . This building would be slightly shorter and somewhat higher.

  • Referring to the size of the parking area on the Location Plan, it is stated, the minimum of 12 places in the 2005 application has now changed to maximum in the current application. This wording change we welcome but are concerned that it may be an insufficient number of places for I have seen well over this number of cars on the site. Once the public are allowed on the site demand will increase.
On these points alone, lack of information, the application should be thrown out for what would WDDC be agreeing to?

What's not on the plans. There are several things that one would expect to be included in such a development that is open to the public but details of which are lacking on the plans.

  • In his supporting letter that accompanied the application club secretary Mr Wright says,

    "2.The plans do not include any provision to install any artificial lighting."

    He is probably referring here to flood lighting. A building open to the public normally requires outside lighting. There is no indication, on the plans, of general lighting on or around the building. It must be remembered that this is a dark valley with no street lighting being visible from most of its length and any outside lighting high on this hill would be a serious pollution problem. Lighting may not be included in the first instant but circumstances may make the later introduction desirable.

  • Internal lighting would also be a serious problem. The Bridport driving range has fluorescent lighting in the open fronted driving bays making the illuminated interior visible from afar especially on dark winter afternoons. This would again be much worse on the Lyme site it being in an elevated position.

  • There is no provision for toilet facilities. With the public use of the range I would have thought that toilets would be essential. There is then the problem of how the foul sewage will be dealt with. The application states that surface water will be dealt with by "Soakaways". It must be remembered that a spring line exist below this field and consideration must be taken of this.

Long term planning intentions, whatever they may be, are of course not a planning matter, but speculation may help you in deciding whether or not to object to this application. Some possibilities that come to mind are:

  • The positioning of the driving range in the south east corner of the field leaves plenty of space for expansion once a foothold of development has been made and the range proves the success that we are told it will be.
  • The golf club has made aborted planning applications in the past for a new and relocated clubhouse. Wouldn't this field make a wonderful site for it?
  • Flood lighting is not included in the application but it should be borne in mind that of the 28 driving ranges that I was able to locate (summer 2004) in Devon and Dorset 68% had floodlighting, whilst only three of the Dorset ranges were without it. Planning permission should be easier to obtain without floodlighting but could be added at a later date.

What use is a covered driving range?
The letter of support accompanying this application lists far fewer benefits of a covered driving range than that associated with the previous application. Gone are its advantages for all weather golf and improvement in safety whilst use by the disabled seems to have been abandoned. Here are what we are left with:

  • It will be an added attraction for many tourist visitors to the area.
  • There will be additional local employment opportunities
  • It will improve the teaching facilities .
  • It will encourage more children to try golf.

The construction of this building would not allow anything that cannot be done under the present arrangements, for remember that in this application the practice area is now considered to be a 'Driving Range - without buildings'and indeed that is what it is used for. In attracting 60 members to its new junior section over the last 18 months the club has shown that a building is not necessary to increase golfs attractiveness to youngsters. Blighting this valley for all time for dubious advantages cannot be justified.

Noise. The production of noise from a driving range was given an airing at the August,2004 Uplyme Parish Council meeting when the first application was considered and again for the second application at the July 2005 meeting.. I think that the subject of noise should not be raised unless you have personal experience of the level of noise that can be created by a driving range. Of course any noise created within the building will be amplified by its shape and the roof material - steel - acting like an enormous megaphone.

Having visited the Bridport driving range and although there was only one person using it I think I can say that although the noise will not be deafening it will be discernible across the Harcombe Valley resulting in annoyance rather than a nuisance especially on calm days. But it must be remembered that a footpath touches the corner of the field 300 metres away diagonally opposite the building, where due to the megaphone effect the noise will be at maximum. This will definitely detract from one's enjoyment of the AONB (please read A good walk spoilt)

All the same I do think that we have so strong a case that over emphasis on this unknown factor should be moderated. Although concern that a possible noise problem may be created could be included in your objection. Your personal experience may suggest otherwise.

A good walk spoilt. Whilst I have never been in agreement with Mark Twain's views on the game of golf, the installation of this driving range will have the effect of spoiling the walks and much besides of many people.

The Interests of District Councillors Owen Lovell and Ken Meech

After objectors to the Strawberry Field sports project had pointed out that town councillors Owen Lovell and Ken Meech had been involved in the Strawberry Field project since its inception both councillors decided, after seeking advice, not to vote nor sit as chairman and vice-chairman on the Development Control West Committee when the sports complex application was to go before that committee.

Their announcement of this decision came a matter of days before the relevant Committee meeting.

Following their action in standing down from an official role in deciding the Strawberry Field application, few people can have any doubt as to their involvement in that project, and their personal interest, as Town Councillors, in its implementation. Cllr. Lovell has subsequently further shown and expressed his interest in the development of the field by becoming the chairman of the town council's Strawberry Field Committee.

A successful outcome for the golf club over the driving range application would give the green light for further development in this area. It is therefore in the councillors' interests to see the driving range built over the hedge from Strawberry Field. So, for them now to sit on this hearing would be just as inappropriate as it would have been on the Strawberry Field hearing.

When the Lyme Regis News carried the decisions of the two councillors to withdraw from the planning committee for the Strawberry Field hearing, it reported that the two councillors "thought it was unfair that Uplyme Parish Council should be allowed to take part in the planning application hearing". Uplyme Parish Council, exercising its perfectly proper legal rights, will also be objecting to the Golf Club's third application. Can the views of the Parish Council be given a fair hearing if the Chairman and Vice-Chairman of the committee concerned have expressed such undemocratic sentiments?

If you agree that the two district councillors have a "personal prejudicial interest"* in this application you can express your concern by writing to the following address requesting that the two councillors have no input to the hearing.

  • Alan Muir
    Legal Services Manager & Monitoring Officer
    West Dorset District Council
    Stratton House
    55/60 High West Street
    Dorchester, DT1 1UZ

    A.Muir@westdorset-dc.gov.uk
    Phone (direct) 01305 252205
*A personal prejudicial interest is described as,

" one which the public, with knowledge of the relevant facts, would consider to be so significant that it is likely to prejudice the Councillor's judgement of the public interest"
Contained in a letter from Mr Muir to the chairman of the Uplyme Parish Council, 7 July 2003


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Thanks you very much for any support that you can give.

Email:   johnrhodehill.co.uk  if you have any comments.

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