Dear Lucy Smith

Planning number 26/00563/CU (or 26/00563/F

I am writing to you in your capacity as Case Officer reviewing the application by the White Horse Caravan Site at Holme-next-the-sea to extend the period of time when the caravans can be occupied from 8 months per year to 11 months per year.

We request that the Borough Council of Kings Lynn and West Norfolk refuse the application to extend the period of time over which caravans at the White Horse Caravan Site can be occupied.

We also request that the developers be directed to restore the area to a standard consistent with the surrounding natural landscape, which will facilitate the recovery of the Natterjack Toad population to levels approaching Natural England’s FCS objectives.

The UK ranks in the bottom 10% globally for nature protection, making it one of the most nature-depleted countries in the world.  We cannot afford to lose more of our native species by constantly eroding what little is left of their habitat.

Unauthorised development on the site of the White Horse Caravan Site

In November 2025, work began on the development of the 0.91 hectare White Horse Caravan Site.  No planning application had been submitted and the developers – Holkham Estate and McDonnell Caravans – claimed the work to be permitted development.  The only forewarning of commencement of the development was the arrival of diggers, which excavated the grass sward and surrounding ponds and ditches, and laid down tonnes of concrete and hard-standing on which large caravans were erected.

Evidence of Natterjack Toads

Residents of properties adjacent to the White Horse Caravan Site have reported the presence of Natterjack Toads in their gardens, providing strong evidence that this endangered, protected species were also present at the Caravan site, prior to commencement of the development.

Audio recordings made of Natterjack Toad calls, verified using georeferenced photo evidence, indicate a substantial population of these amphibians present within 100m of the Caravan Site.

Following objections to the development a Shadow Habitat Regulations Assessment was carried out.  This found no evidence of Natterjack Toads, probably because they and their habitat had been removed.

Conservation value of the site

The caravan site lies within the Adaptation and Resilience Zone defined in the Holme-next-the-sea Neighbourhood Plan as the only remaining, coherent area of landscape in the Parish suitable for making compensatory adjustments for the loss of Parish amenity by tidal inundation.

The Amphibian and Reptile Conservation Trust point out that a fundamental requirement for the recovery of the Natterjack Toad to Favourable Conservation Status (FCS) is the protection and expansion of suitable habitat beyond the boundaries of designated sites.  Without this wider landscape recovery the species is unlikely to recover to levels approaching Natural England’s FCS objectives.

Rather than eroding the availability of suitable habitat for the Natterjack Toad, conditions within the Adaptation and Resilience Zone should be enhanced to enable their population to recover.

Legal and policy grounds for objections to the application:

1.           The development of the site should not have been carried out due to

a.       its protected status as part of the North Norfolk Coast Ramsar Site,

b.      its very close proximity to the North Norfolk Coast Site of Special Scientific Interest (SSSI), Special Area of Conservation (SACs) and Specially Protected Area (SPA).

Natterjack Toads are listed as a feature of both the SSSI and the Ramsar designations.

Permitted Developments within a Ramsar Site must be assessed by the relevant nature organisation and demonstrate that the development is unlikely to have a significant effect on the habitats or species of international importance, or would adversely affect the ecological integrity of the designated site.

The developer has not demonstrated that the development will not adversely affect the population of the Natterjack Toads nor the ecological integrity of the site.

2.      Norfolk Wildlife Trust point out that, given the failure of the developers to provide sufficient information to allow the Council to carry out a Habitat Regulations Assessment (HRA), the proposal fails to comply with the local planning policies

3.      The Holme-next-the-sea Neighbourhood Plan, Policy HNTS 9, specifies that:

·         Proposals for new holiday accommodation units or sites, or intensification or extension of existing uses incorporating static /semi-permanent/permanent structures, including associated facilities, will not be permitted.

The proposal to extend the period of time during which the caravans may be occupied is an intensification and extension of existing use and therefore should not be permitted.

·         Where accommodation, pitches or facilities are removed or relocated on the site, the area affected must be fully restored to a standard consistent with the surrounding natural landscape.

The caravan pitches have been relocated within the site, so the area must be fully restored to a standard consistent with the surrounding natural landscape.

 Further negative impacts on the Natterjack Toad population and the adjacent designated protected areas include

        i.                 increased footfall in the protected site of Park Piece because occupants of caravans at the White Horse site are to be directed away from the Nature Reserve and towards Park Piece, which is part of the habitat of the Natterjack Toads.

       ii.                 an increase in the amount of vehicular traffic to the caravan site.

     iii.                 increased pressure on the already inefficient sewage system.  Heavy rainfall frequently triggers local storm overflows causing raw sewage to be discharged into the River Hun and the Wash.

We support the Parish Council’s objection to the extended operating period of the Caravan Site on the basis of:

·         incomplete consideration of the impact of the development on adjacent designated sites

·         omission of any reference to the Natterjack Toad population

·         inappropriate interpretation of WeBS data

·         lack of clarity regarding the number of caravans (64 or 37)

·         extensive alterations to the original site plan and access routes, which negate the validity of the flood risk assessment.

We request that the Borough Council of Kings Lynn and West Norfolk refuse the application to extend the period of time over which caravans at the White Horse Caravan Site can be occupied.

We also request that the developers be directed to restore the area to a standard consistent with the surrounding natural landscape, which will facilitate the recovery of the Natterjack Toad population to levels approaching Natural England’s FCS objectives.

Agreed by the undersigned petition