Temporary holiday sites, including caravan and camping sites

Advice note that covers nutrient neutrality, recreational impacts and the new GIRAMS subscription model

Who does it apply to?

This advice note applies to all new temporary holiday sites and caravan and camping sites, including:

• certified sites for caravan and camping
• exempted sites
• temporary holiday sites, including rallies and pop-up campsites operating under the 28/60 day permitted development rules
• any other temporary holiday sites which result in overnight accommodation 

What has changed?

Two significant changes have been introduced since 2022 that now impact the operation of caravan and camping sites, including temporary holiday sites, one at national level and one at a county-wide level.

Before the issues below arose, temporary uses of land, such as for holding caravan rallies or temporary holiday sites, were not considered likely to significantly affect a European-designated site for nature or ecological reasons. That assessment has now changed, and mitigation for those effects is needed.

The following matters now need to be considered:

Nutrient Neutrality

Natural England’s advice letter dated 16 March 2022 about nutrient pollution in the protected habitats of the River Wensum Special Area of Conservation and the Broads Special Area of Conservation and Ramsar site. 

• Nutrient Neutrality (north-norfolk.gov.uk)

Recreational impacts

Joint work by the Norfolk planning authorities and Natural England has identified that residential and tourist-related development, including caravan and camping sites, contribute to increased recreational use on internationally designated Habitat Sites, particularly European sites. 

• Habitat Mitigation: Recreational impacts (north-norfolk.gov.uk)

Both nutrient pollution and recreational impacts from caravan and camping sites have the potential for adverse impacts on European designated sites, which require assessment under the Conservation of Species and Habitats Regulations 2017 (Habitats Regs), and this will, in most cases, require those adverse impacts to be mitigated.

What does mitigation look like?

The Norfolk-wide Green Infrastructure and Recreational Impact Avoidance and Mitigation Strategy (GIRAMS) agreed between the Norfolk planning authorities and Natural England is a way to manage adverse impacts on European sites. In most cases, through payment of a mitigation tariff. The tariffs collected are used towards programmes to help manage those adverse impacts. The GIRAMS mitigation tariff to be paid depends on the development type and size. The mitigation tariff is designed to provide mitigation in perpetuity (circa 80 years).

Recreation impacts: seeking to find solutions  

North Norfolk District Council recognised that payment of a single GIRAMS payment designed for 80 years worth of mitigation was adding a significant financial burden for temporary holiday sites and caravan and camping sites, especially those that may only operate for less than five years. 

GIRAMS subscription model

North Norfolk District Council have listened to those concerns and put together a subscription model for GIRAMS mitigation, which significantly reduces the financial outlay for smaller tourism businesses while allowing necessary mitigation to be secured.

Example:

Using the 2023/24 standard tariff unit rate of £210.84 and a temporary campsite with ten standard-sized pitches. They would have been required to pay a full upfront cost of £1,405.60. 

Alternatively, using the subscription model, a 1 year subscription would cost £21.08,  approximately £2.11 per pitch . This subscription model significantly reduces the upfront GIRAMS mitigation costs.

North Norfolk District Council have shared the subscription model with all the Norfolk authorities and will be using this model from 2024 onwards. Discussions with the Caravan and Camping Club have identified a preference for subscriptions to start per calendar year, from 1 January to 31 December, rather than aligning with tax years. The Council will adopt the calendar year approach from 2024 .

The rate for GIRAMS is reviewed annually as of 1 April each year. 

Nutrient Neutrality

Natural England's advice applies to caravan and camping sites as they include overnight accommodation. Finding a solution for nutrient neutrality has been difficult, but the Council has been working with Natural England on this. We have identified a solution suitable for temporary camping and caravan sites where wastewater is stored in tanks and disposed of outside the nutrient neutrality catchment.

Waste disposal, mitigation and nutrient neutrality

Understanding how waste from caravan and camping sites, including temporary holiday sites, is to be disposed of is key to resolving nutrient neutrality.

Many organisations require sites to have a sealed container (cess tank) underground that is emptied by tanker or has direct access to main drains. If mains drainage is used, it may be acceptable if the wastewater treatment works serving the site discharge their treated water outside the nutrient neutrality catchment. If the treated wastewater is discharged within the nutrient neutrality catchment, mitigation may be required, such as purchasing credits. However, currently, there are no credits readily available in North Norfolk. This means that some temporary holiday sites on mains drainage discharging within the catchment may not be able to proceed.

Waste water disposal by sealed containers or cess tanks

The Council has been working hard to deliver a solution to help temporary holiday sites continue operating. Natural England has now confirmed their agreement to the principle of temporary holiday sites collecting wastewater in a sealed container such as a cess tank and disposing of it out of catchment. For example, disposing of wastewater at a wastewater treatment works that does not discharge into the sensitive catchment.

To address the nutrient neutrality matters required as part of any Regulation 77 application, applicants proposing ways to collect wastewaters and dispose of it out of catchment would need to secure a legal agreement such as a Unilateral Undertaking made under S106 of the Town and Country Planning Act.

The Council has developed a legal document template that applicants can use. Applicants will need to fill in the specific parts of the legal document relevant to their site. Once completed and submitted to the Council, and after it is agreed, this is registered as a local land charge. This legal document secures the appropriate collection and disposal of wastewater so that it does not end up in sensitive catchments or add to the nutrient enrichment concerns raised by Natural England.

With a legal agreement, the Council has complete its Habitats Regulations Assessment and Appropriate Assessment to confirm that the scheme is acceptable under the Habitats Regulations to allow a positive Regulation 77 decision to be issued.

Cess tank approach documents

These documents may be useful for site owners wishing to use the cess tank approach for their temporary holiday site in the nutrient neutrality area.

• Draft Unilateral Undertaking (Microsoft Word) to be completed
• Guidance notes (PDF) to help complete the Unilateral Obligation

A fee of £95 is payable to North Norfolk District Council to carry out title checks for the land, to confirm the applicant has a legal interest in the land subject of the legal agreement and to insert the completed legal agreement on the land registry as a local land charge.

How long would a Unilateral Undertaking last? 

Once a Unilateral Obligation has been completed and signed to secure collecting wastewater in a sealed container and disposing of it out of catchment, the agreement can be used for multiple years on the same site for the specified activities.

Applicants are advised to make sure they also have the correct GIRAMS tariff payments in place if they use the legal agreement for subsequent years on the same site.

What if I can't use a cess tank or the main drainage discharges into the nutrient catchment?

At this stage, until the establishment of mitigation solutions either through credits or on or off-site mitigation solutions (unless a temporary holiday site is found to be nutrient neutral), the local planning authority, as competent authority under the Habitats Regulations, would not be able to conclude it is satisfied that there is no reasonable doubt as to the absence of adverse effects on the integrity of European site. Unfortunately, this means that some temporary holiday sites located within the nutrient neutrality catchments of the River Wensum Special Area of Conservation and the Broads Special Area of Conservation and Ramsar site may not be able to operate until mitigation solutions are progressed.

How do I know if Nutrient Neutrality requirements affect my site?

Catchment maps for Norfolk, Wensum, Bure and Yare and focussed catchment maps for the Wensum, Bure and Yare are available on the Council’s Nutrient Neutrality web page.

Mapping tool

The Council also has a mapping tool within which you can select Map Features, followed by Area Regulation, Restriction and Mgmt. You can select layers on nutrient neutrality, including foul water drainage and surface water catchments.