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A - 23-0193-PP - Use of land as caravan site with associated installation of 33 serviced caravan pitches

Renfrewshire Council · 27 August 2024
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Report by Chief Planning Officer
Planning and Climate Change Policy Board: 27 August 2024 
Reference No 23/0193/PP
Application Type Planning Permission
Proposal Use of land as caravan site with associated installation of 33
serviced caravan pitches.
Location 1 Newton of Barr, Lochwinnoch, PA12 4JB
Ward 9 - Johnstone North, Kilbarchan, Howwood and Lochwinnoch
Community
Council
Lochwinnoch Community Council
Applicant Mr Tom Milligan
Recommendation Refuse
All plans, reports, documents and representations relating to this application can be
viewed in full online at https://pl-bs.renfrewshire.gov.uk/online-
applications/applicationDetails.do?activeTab=documents&keyVal=RT8ZHOMWGMY00 
This report fulfils the requirements of regulation 16, Schedule 2, paragraphs 3(c) and 4 of
The Town and Country Planning (Development Management Procedure) (Scotland)
Regulations 2013.   
The report is presented to the Planning and Climate Change Policy Board in line with the
Council's Scheme of Delegation.   
Proposal
This application seeks planning permission for the use of land at 1 Newton of Barr as a
caravan site with the associated installation of 33 serviced caravan pitches. Newton of Barr
extends to approx. 4.67 hectares in area. The proposed development is located within the
centre of this area, and extends to approx. 1.3 hectares in area. 
The serviced caravan pitches are arranged in an E shape. There is also an associated
waste, recycling and sanitary disposal point proposed. The site is accessed via the A760 to
the north east. 
Site Description
Newton of Barr is located to the south west of Lochwinnoch. It is triangular in shape, and
bound by the A760 to the north east, a woodland strip to the west with a residential property
beyond, and a woodland strip to the south west with the national cycle network beyond. 
There is a mix of existing uses on the site. These include a leisure centre with artificial
pitches, three grass pitches (in the north west corner, north east corner and adjacent to the
south east boundary), and approx. 12 informal caravan pitches located in the centre of the
site. There is a dwellinghouse adjacent to the site access however this is outwith the
ownership of the applicant. 
The proposed 33 serviced pitches would be located on the combined area of the 12 existing
caravan pitches and the grass pitch adjacent to the south east boundary which is currently
designated as an area of open space. 
Pre-Application Consultation with Officers
The Scottish Government strongly encourages constructive pre-application discussions
between prospective applicants and the planning authority.  Pre-application discussions seek
to identify key planning considerations at an early stage and help inform what supporting
information is required to support a subsequent application.

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Pre-application discussions have taken place, focusing on the following matters:
▪ The requirement for planning permission for the caravan pitches. 
Negotiated Improvements
Following submission, the following changes have been negotiated between officers and the
applicant: 
No changes have been negotiated. 
Site History  
The planning history for the site is as follows;
Application No: 14/0787/PP
Description: Refurbishment of existing indoor football facility and erection of dwellinghouse
and garage (Section 42 application for the deletion of Condition 7 of planning approval
11/0036/PP relating to a restriction on occupation of the dwellinghouse).
Status; Granted subject to conditions. 
Application No: 11/0036/PP
Description: Refurbishment of existing indoor football facility and erection of dwellinghouse
and garage.
Status; Granted subject to conditions. 
Application No: 10/0843/PP
Description: Siting of mobile snack bar
Status; Granted subject to conditions. 
Consultations   
SportScotland – No objections. 
S.E.P.A – advise that the information supplied with the planning application is insufficient to
allow an assessment to determine the potential impacts in relation to flood risk. As this
information has not been provided, SEPA  therefore, has a holding objection to the proposed
development. 
Environment, Housing & Infrastructure (Env. Protection) - No objections. Advise that the
development will require a Caravan Site License before the site is operational. 
Chief Executive's Service (Roads Development) – No objection subject to conditions. 
Scottish Water – No objection. 
Lochwinnoch Community Council – Advise that they would object to the application if it is
for static residential caravans or long term storage on the grounds that this would be
contrary to the local development plan and an unsuitable development in the conservation
village and Clyde Muirshiel Regional Park. There would not be sufficient infrastructure to
support a development of this nature, and the area is at risk of flooding. 
However if the development is for short term towed caravans, camper vans and tents the
community council would support the application on the basis that such a development
would be an extension of the existing facilities at the site, the site is suitably screened, the
facilities at the site can manage such a development, use of the site for short term tourism is
encouraged by Renfrewshire  Council policies, and additional short stay serviced caravan
pitches would support local community and viability of village shops and services.

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Representations
The application has been publicised in line with the requirements of the relevant legislation. 
The following representations were received: 
Object - 2
Support - 0
Neutral – 0 
The matters raised in the letters of representation can be summarised as follows. 
1. There is insufficient detail within the submission.
2. Organisation and maintenance of the site is poor. Development could have detrimental
impact on conservation village.
3. There is no requirement for the car parking adjacent to the “small” football pitch.
4. Object to any caravan storage at the site.
5. The caravan pitches are isolated with no obvious landscape proposals that could
provide a practical and visual structure for the site and its possible future development.
Careful consideration is required over the future development of this important site.
6. No indication as to how long caravans would stay at the site. Length of stays should be
limited.
7. No indication as to the surfacing of the caravan area or the access road.
8. The area is at flood risk, and the submission requires a flood risk assessment.
Policy Context   
In making any determination under the Planning Acts, regard is to be had to the
development plan unless material considerations indicate otherwise. In this instance the
Development Plan consists of National Planning Framework 4 (NPF4) and the Renfrewshire
Local Development Plan (2021) (LDP). 
The following provisions of the Development Plan are considered relevant to the
determination of this application: 
National Planning Framework 4 
Policy 1 - Tackling the climate and nature crises
Policy 2 - Climate mitigation and adaptation
Policy 3 – Biodiversity
Policy 6 – Forestry, woodland and trees
Policy 8 – Green belts
Policy 13 – Sustainable transport
Policy 14 – Design, quality, and place
Policy 20 – Blue and green infrastructure
Policy 21 – Play, recreation and sport
Policy 22 – Flood risk and water management
Policy 29 – Rural development
Policy 30 - Tourism 
Full details relating to the policies of the NPF4 can be found online. 
Renfrewshire Local Development Plan
Policy ENV1 – Green Belt
Policy ENV2 – Natural Heritage
Policy E4 – Tourism
Policy P6 – Open Space

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Policy I1 – Connecting Places
Policy I3 – Flooding and Drainage 
New Development Supplementary Guidance
Delivering the Environment Strategy – Green Belt and Regional Parks
Delivering the Economic Strategy - Tourism 
Full details relating to the policies of the LDP can be found online. 
Other relevant policies and guidance 
Renfrewshire’s Tourism Plan 2024-2027 
Submitted Reports and Assessments
In assessing and reporting on a planning application the Council is required to provide
details of any report or assessment submitted as set out in Regulation 16, Schedule 2, para
4(c) (i) to (iv) of the Development Management Regulations. 
The following reports and assessments were submitted in support of the application: 
None. 
Scottish Ministers Direction
In determining a planning application, the Council is required to provide details of any
Direction made by Scottish Ministers under Regulation 30 (Directions requiring consultation),
Regulation 31 (Directions requiring information), Regulation 32 (Directions restricting the
grant of planning permission) and Regulation 33 (Directions requiring consideration of
condition) of The Town and Country Planning (Development Management Procedure)
(Scotland) Regulations 2013, or under Regulation 50 (that development is EIA development)
of The Town and Country Planning (Environmental Impact Assessment) (Scotland)
Regulations 2017. 
None. 
Planning Assessment
Section 25 of the Town and Country Planning (Scotland) Act requires decisions on planning
applications to be made in accordance with the Development Plan unless material
considerations indicate otherwise. Key matters in assessment of this application are flood
risk, loss of open space and green belt location. 
SEPA have advised that the application site is shown to be fully at risk of flooding from the
River Calder based on the SEPA Future Flood Maps. 
Policy 22 of NPF4 states that development proposals at risk of flooding or in a flood risk area
will only be supported if they are for essential infrastructure where the location is required for
operational reasons, water compatible uses, redevelopment of an existing building or site for
an equal or less vulnerable use, or redevelopment of previously used sites in built up areas
where the LDP has identified a need to bring these into positive use. 
SEPA advise that they do not consider the proposal to meet any of the exceptions listed
above. In addition, they consider the application to fall within the most vulnerable land use
classification. Introducing formal overnight accommodation pitches would increase the
overall risk by increasing the number of people and receptors on the site. SEPA further
advise that touring caravans are classed as ‘most vulnerable’ and as they do not have
foundations, and flooding underneath or around the supports could cause damage or

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movement in the event of a flood. SEPA also raise concerns over the provision of safe
access and egress from the site in the event of a flood. It has also not been demonstrated
whether there will be a reduction in functional floodplain capacity due to the development. 
In view of the above, SEPA have submitted a holding objection to the proposed development
as it has not been demonstrated that the proposals will not result in an overall increase in
flood risk. 
To overcome the holding objection, SEPA have advised that a detailed Flood Risk
Assessment (FRA) should be undertaken by a suitably qualified professional to further
assess and define the flood risk at the site. 
The detailed FRA was first requested by the Council on the 20th July 2023. In response the
applicant advised that in their view the development does fall within the exceptions detailed
in Policy 22, namely redevelopment of an existing site for an equal or less vulnerable use.
The applicant further advised that the proposed use is equal to the current use of part of the
site, the site can be closed and clients asked to vacate if a flood alert is in place, and there
will be no reduction in floodplain capacity. Touring caravans can be removed from the site
with little notice if neccesary. 
The above response has not been accepted by SEPA, and the holding objection has been
maintained. No further detailed flood risk information or a FRA has been submitted by the
applicant despite several further requests by the Council. SEPA have advised that if the
applicant does not provide the detailed flood risk information as requested then the
representation from SEPA should be considered as an objection. 
The provisions of NPF4 policy 22 with respect to flood risk are noted above. It is not
considered that any of the exceptions listed in policy 22 would apply to the development.
The development is not for essential infrastructure, it is not a water compatible use, it is not
redevelopment of an existing site and rather is intensification of an existing most vulnerable
use, and it does not constitute redevelopment of a previously used site in a built up area
where the LDP has identified a need to bring the site into positive use.   
Policy I3 of the LDP states that a precautionary approach will be adopted to the reduction of
flood risk from all sources. Avoidance is the first principle of sustainable flood risk
management, and new development requires to avoid areas susceptible to flooding. 
The applicant has not submitted the information neccesary to demonstrate compliance with
policies 22 of NPF4 or I3 of the LDP, or address the points raised in the holding objection
from SEPA. The development does not therefore comply with polices 22 of NPF4 or I3 of the
LDP. It is considered that the applicant has been provided with sufficient time to submit the
information requested by SEPA. 
The application site is located within the green belt. 
Policy 8 of NPF4 states that tourism uses will be supported within a green belt designation
as defined by the LDP. This is on the basis that a number of additional requirements are met. 
In this instance, the green belt location is essential as the development seeks to formalise
and expand upon the existing uses already operating at the site which includes caravan
pitches. The purpose of the green belt at this location would not be undermined. 
The proposal is compatible with the established character of the area. The site already
operates a mix of uses. The pitches would be set back from the A760 and behind the leisure
centre and detached dwellinghouse. The site is also screened from the south and west by

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woodland and would not be overly visible from external locations. The visual impact on the
green belt would therefore be minimal. It is not considered that there would be significant
long-term impact on the environmental quality of the green belt. 
Given the characteristics of the site as noted above it is also not considered that the
development would have a detrimental impact on the character and appearance of the
adjacent Lochwinnoch Conservation Area. 
Policy ENV1 of the LDP also states that tourism related development will be supported in the
green belt in principle provided it is acceptable under Policy E4 of the LDP. 
Policy E4 of the LDP states that proposals for sustainable tourism development will be
supported where it can be demonstrated that the assessment criteria are met. 
In this instance the proposed development is capable of strengthening the appeal and
attraction of Renfrewshire to a range of visitors by expanding the infrastructure and facilities
available to accommodate touring caravans. 
It is noted that the Council’s Tourism Plan aims to grow opportunities around outdoor
activities, the natural environment, and historic villages. An outcome of this is to increase the
capacity to attract and accommodate visitors. It is also noted that Lochwinnoch Community
Council have offered support for the application on the basis that it would be for short stay
serviced caravan pitches. 
The applicant has confirmed that the development would be for short-term stay or touring
caravans, with no static caravans proposed. The applicant states that such a development
would support the local economy as it could bring about an increase in local spending at
pubs, restaurants, and shops. They also state that the location is  well suited for visitors
wanting to make use of outdoor pursuits such as Castle Semple Loch and the national cycle
network, and surrounding villages could also benefit from local tourism travel. 
The scale of the development is considered to be proportionate to the landscape character
and setting of the area. It will complement existing tourist facilities in the area. 
Roads Development have offered no objections to the capacity of the local road network to
accommodate additional visitors to the area. Recommendations are made with regard to
works required at the site to accommodate the development. These could be secured
through appropriate planning conditions. 
It is considered that a site specific locational need has been demonstrated given the existing
facilities which exist at the site, and its location within Clyde Muirshiel Regional Park and in
proximity to other tourist attractions. 
The New Development Supplementary Guidance sets out further considerations which apply
to tourist developments. 
The proposed development will add to the appeal and attraction of Renfrewshire as a visitor
destination, and contribute to the local economy. It will complement existing tourist facilities
in the area. 
There are no significant detrimental impacts on visual amenity, built heritage, natural
heritage interests, biodiversity, and landscape character.

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The design of the development is appropriate for the location, and is compatible with
neighbouring land uses. The position of the pitches within the site, and the existing mature
screening to the south and west, reduces the visual impact of the development. 
There have been no objections from consultees with regard to infrastructure capacity to
serve the development. 
While the site would be accessed by touring caravans, its location in proximity to
Lochwinnoch Village, the national cycle network and Lochwinnoch train station mean that
some journeys within the area by persons staying at the site could be undertaken by
walking, cycling and public transport. 
The site-specific locational need for the development has been demonstrated above. 
The opportunities to incorporate low carbon generating technologies are limited given the
nature of the proposed development. 
On balance it is considered that the development complies with Policy E4 and the
associated New Development Supplementary Guidance on tourism development. 
The development is also therefore considered to be acceptable in principle under policy
ENV1 of the LDP. 
All development proposals must thereafter be assessed against the green belt development
criteria set out within the New Development Supplementary Guidance. 
There will be no loss of prime quality agricultural land or agricultural land of lesser quality
that is locally important. 
There will be no adverse impacts on the qualities of wild land. 
Traffic and access infrastructure can be sensitivity accommodated. The access to the site
from the A760 already exists, and Roads Development have sought the formalisation of this
access in addition to requirements relating to surfacing, sight lines and external links. These
matters could be addressed via condition. 
It is not considered that the development would have a significant effect on public water
supply or the water environment from pollution risk. 
Roads Development have recommended additional links to enhance connectivity between
the site and surrounding active travel routes, namely the national cycle network to the south.
Again, these matters could be managed via condition. 
With regard to open space, it is noted that the caravan pitches would be located on an area
of land within the application site which is designated as open space under Policy P6 of the
LDP. The land has previously been used as a football pitch, and Sportscotland have been
consulted as the football pitch would be lost to accommodate the development. 
Sportscotland have advised they have undertaken consultation with OneRen, local clubs and
the sports governing body to better understand pitch activity in the local area. It is stated that
the pitch has not contributed to playing capacity locally for a number of years, and that
existing alternative grass pitch capacity is generally meeting the demand of users in
Lochwinnoch.  The information received by Sportscotland indicates that the change of use
would not impact on users and the overall pitch capacity locally. Sportscotland therefore has
no objection to the proposed development.

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Policy P6 and the associated new development supplementary guidance states that areas of
valuable and functional open space, recreation provision and amenity space will be
protected from development. The proposed development was therefore advertised as
development potentially contrary to the development plan. 
However, the consultation with Sportscotland demonstrates that the open space is now no
longer valued as a recreational asset, and that alternative grass pitch capacity is generally
meeting demand in the area. The open space is located at the rear of the site and is not
generally accessible or visible from public vantage points. There will not be a significant net
loss of open space, and Sportscotland advise there is no requirement to provide alternative
provision at another site. The amenity of the surrounding area will not be significantly
affected by the loss of the open space and by the nature of the proposed development, and
the benefit of the development to tourism outweighs the present limited open space value of
the site. In this instance therefore it is considered that the loss of this designated area of
open space is acceptable. 
Sportscotland have also advised that the proposed development therefore also meets the
requirements of NPF4 Policy 21. 
Roads Development have recommended additional connections to enhance access from the
site to areas of open space. This could be managed via condition. 
The development will not have a significant detrimental impact on the local landscape
character given the enclosed nature of the site. 
There have been no objections from consultees with regard to provision of services, and
there will be no significant detrimental effect on identified nature conservation interests
including species and habitats. 
A soft and hard landscaping scheme for the site and proposed boundary treatments can be
managed via condition. 
In view of the above, it is considered that the development complies with Policy ENV1 of the
LDP. 
Policy 30 of NPF4 also provides support for new or extended tourist facilities including
caravan and camping sites in locations identified in the LDP. 
While the LDP does not specifically designate areas for tourist facilities or accommodation, it
is noted above that the development complies with LDP policies ENV1 and E4. 
Policy 30 states that proposals for tourism related development will take into account the
following factors. 
The development will contribute to the local economy by providing accommodation for
tourists. The accommodation is accessible from Lochwinnoch by walking and cycling, and
tourists staying at the site could spend money at the local shops and services available
within the village. 
The nature and scale of the activity is compatible with the area. The comments from
Lochwinnoch Community Council are noted again with resect to the community council
offering support for short term caravans, motorhome and camping but not for long term static
caravans or storage of caravans.

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The development would not hinder provision of homes or services for local people, and
would not have a detrimental impact on the local community. 
There are opportunities for sustainable travel given the proximity of the site to Lochwinnoch,
the national cycle network, Lochwinnoch train station, and tourist facilities at Castle Semple. 
The applicant has advised that touring caravans can be an accessible accommodation
option for disabled people as they can travel with their equipment and/or medication. 
Measures to reduce carbon emissions are limited given the nature of the development. 
Access to the natural environment could be enhanced as per the recommendations from
Roads Development. 
In view of the above, it is considered that the development would comply with Policy 30 of
NPF4. 
The development would also comply with Policy 29 of NPF4 as it could contribute positively
to the viability and diversity of the local rural economy. The development is suitably scaled,
sited, and designed. 
The development is located within the Clyde Muirshiel Regional Park. 
Policy 20 of NPF4 states that development proposals in regional and country parks will only
be supported where they are compatible with the uses, natural habitats, and character of the
park. Given the above assessment it is considered that the development is compatible with
the regional park. 
The New Development Supplementary Guidance also sets out several assessment criteria
with regard to development proposals within the Clyde Muirshiel Regional Park. 
In this instance the development will bring economic benefits to the area. 
There will be no significant impact on nature conservation, landscape character or heritage
resources. 
The development will not cause significant conflict with neighbouring land uses. 
There are opportunities for active travel, and Roads Development have recommended
additional linkages to improve accessibility at the site. 
The proposed development is appropriate in design and scale to its surroundings, and will
have no significant impact on the visual amenity of the area given the enclosed nature of the
site. 
The development will not prevent or significantly impact upon recreational access to the
surrounding area. 
The proposed site plan indicates that all existing trees within the application site boundary
will be retained. A condition could be applied to ensure that measures are put in place to
protect these trees, and the trees along the boundaries of the site, during the construction
phase. 
The site is currently considered to be of low ecological and biodiversity value as it primarily
comprises of existing areas of hardcore and mown grassland. While most of the grassland

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would be removed to accommodate the caravan pitches, there is ample opportunity
elsewhere within the site and within the overall land owned by the applicant to deliver
biodiversity gain. It is considered that this could be managed as part of the landscaping
condition. 
There are no local or national designated sites of nature conservation within the application
site boundary. The nearest designated sites are the Garthland Lodge Wood to the east of
the site on the opposite side of the national cycle network, and Castle Semple and Barr Site
of Special Scientific Interest approx. 500m to the south east. It is not considered likely that
the development would have a significant effect on these designations given the nature of
the proposed development, the separation distance, and the intervening land use,
topography, and vegetation. 
In view of the above, it is considered that the development complies with policies 3 and 6 of
NPF4 and ENV2 of the LDP. 
Roads Development have offered no objections to the development with regard to traffic
generation, road safety or the capacity of the local road network. While the nature of the
development would necessitate access via car, journeys thereafter to local amenities could
be undertaken by walking or cycling. 
Roads Development have sought the formalisation of the existing access in addition to
requirements relating to surfacing, sight lines and external links. These matters could be
addressed via condition. 
It is considered that the development complies with policies 13 of NPF4 and I1 of the LDP. 
Policy 14 of NPF4 seeks to ensure that proposals are designed to improve the quality of an
area whether in urban or rural locations and regardless of scale. The enclosed nature of the
site ensures that the development will not have a significant impact on the character and
appearance of the place, and I am satisfied the development aligns with policy 14. 
Finally with regard to policies 1 and 2 of NPF4, the development is not considered to have a
significant impact with respect to greenhouse gas emissions or nature. However, the
applicant has not demonstrated that the development is acceptable with respect to flood risk.
The development is therefore considered to be contrary to policy 2 with regard to the
requirement for the development to be sited and designed to adapt to current and future
risks from climate change which would include flood risk.   
In response to the points raised in the letter of representation:
1. A flood risk assessment has not been submitted as noted in the foregoing assessment.
The information in relation to this matter is insufficient to assess flood risk. In relation to
other matters it is considered that there is sufficient detail within the submission to
assess these and for these to be controlled via condition as noted in the foregoing
assessment. 
2. It is not considered that the development would have a detrimental impact on
Lochwinnoch Conservation Area.
3. This area already exists, and does not fall within the scope of the current application.
4. A condition could be used to prohibit caravan storage at the site.
5. A landscaping scheme for the site can be requested via condition. 
6. The applicant has indicated that the use of the site would be for short stay. 
7. Confirmation of hard surfaces can be sought via condition.
8. A flood risk assessment has not been submitted as noted in the foregoing assessment. 
Section 75 Obligations

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The Council is required to provide a summary of the terms of any planning obligation which
is required to be entered into under Section 75 of the Town and Country Planning (Scotland)
Act in relation to the grant of permission for the proposed development: 
None. 
Conclusion
The proposed development is considered to be acceptable with regard to the applicable
policies on green belt and open space. It also complies with the policies on tourism
development, and could contribute positively to the viability and diversity of the local rural
economy. 
However the applicant has failed to demonstrate that the development is acceptable with
regard to flood risk at the site, and it is noted that SEPA as a statutory consultee have
objected to the development. On balance the matters relating to flood risk are considered to
take precedent, and the application is therefore recommended for refusal on the basis it is
contrary to policy 22 of NPF4 and I3 of the LDP. 
Recommendation
Refuse 
Reason(s) for Recommendation 
1. The proposed development is unacceptable as it is located within a flood risk area. It
does not align with the precautionary and avoidance principles advocated by Policy I3
of the Adopted Local Development Plan and the associated New Development
Supplementary Guidance on flooding and drainage, and does not meet the criteria for
any of the exceptions listed in Policy 22 of National Planning Framework 4.     
Schedule of Plans Determined 
Drawing Number Revision Drawing/Document Title
771 A2-01 A Proposed Site Plan
771 L-02 A Location Plan
771 L-03 A Existing Site Plan 
For further information please contact James Weir, Development Standards Team, Email:
james.weir@renfrewshire.gov.uk