Commissioners' Meeting
2/3 October 2013
Forest Holidays and the closure of Camping in the Forest campsites
Introduction
1Forest Holidays was the first Public/Private Partnership entered into by the Forestry Commission in 2006.
2In July 2013 Forest Holidays put in a planning application to close down the Camping in the Forest campsite at Thorpe Woodlands, Thetford Forest and replace it with a luxury lodge site. The planning decision is due on 4 November 2013.
3As the site users believe the majority of the Commissioners are unaware that Forest Holidays have been closing down campsites in order to create lodge sites, they have written to the Commissioners to make them aware and to raise their concerns about the Thorpe planning application.
4The concerns are due to be discussed at the October meeting of the Commissioners and these notes provide background information, obtained by the Thorpe site users, to the agenda item.
5In the last few weeks it has come to light that:
(a)Forest Holidays have been pursuing a programme of campsite closures in preference to creating new lodge sites.
(b)The programme of campsite closures has gone unreported and undetected due to:
*planning applications not being submitted for scrutiny to the National Committees;
*progress reports for the Commissioners omitting to mention campsite closures.
(c)For the current planning application, an Environmental Impact Assessment has been deemed unnecessary by the local council due to figures used in the planning application which the site users believe are questionable.
Forest Holidays
6In 2006 the Forestry Commission entered into a joint venture with the Camping and Caravanning Club, known as Forest Holidays, to run its 21 campsites and 3 cabin sites. In 2012 this joint venture was replaced by 2 new ones. Camping in the Forest (CITF), also a joint venture between the Forestry Commission and the Camping and Caravanning Club, continues to run the campsites.
7Forest Holidays, which runs the lodge sites, is now a joint venture between Lloyds Development Capital (65%), the former Forest Holidays management team (15%) and the Forestry Commission (20%). Lloyds Development Capital describe this on their website as a management buyout.
Programme of closures
8In July 2013 Forest Holidays put in a planning application to close down the campsite at Thorpe Woodlands and replace it with a luxury lodge site.
9Thorpe Woodlands is an undeveloped, affordable campsite that has been used by 3 generations of families for over 40 years. Currently a family of four could use a caravan at Thorpe for a week in high season for £152. A lodge for a week in high season will, according to the planning application, cost up to £2,948.
10It initially appeared that the Thorpe Woodlands campsite had been an unlucky one off. However this no longer appears to have been the case.
11Although both incarnations of Forest Holidays have had the exclusive right to create new sites on Forestry Commission land, they have only chosen to do this on 2 occasions. The 3 other lodge only sites added to their portfolio have all been affordable campsites that they have closed down. Thorpe will be the 4th campsite to be closed.
12The 3 sites already lost are:
*Woodlands (Forest of Dean) - now Forest of Dean lodge site
*Ardgartan (Scotland) - now Argyll lodge site
*Spiers House (North Yorkshire Moors) – now Cropton lodge site
13For each campsite lost the pattern has been the same. Typically:
*The Commissioners are told of plans to erect lodges at the campsite.
*Forest Holidays omit to submit the plans to the National Committee for scrutiny.
*Forest Holidays apply for planning permission.
*The Commissioners are told that planning permission has been granted.
*The site users find out that the campsite is going to be closed.
*The Commissioners are told that the lodges have been built at the new lodge site.
*According to the publicly available documents, at no time are the Commissioners or National Committee members told that the campsite facilities are being closed.
Unreported and undetected
14The minutes of the Executive Board for 3 May 2007 state:
“The Forestry Commission had to give formal approval to any plans to redevelop sites to ensure any planned redevelopments were conducive with Forestry Commission policies. There was a need to clarify the level at which decisions would be taken and ensure they were properly recorded. It was agreed that these decisions would be taken at National Committee level. The internal guidance on the FC aspects of the governance of Forest Holidays would be revisited to ensure this was clear.”
15The minutes for the Executive Board for 27 June 2007 state:
“Commissioners had decided that decisions on new Forest Holidays sites would be made at National Committee level.”
16In practice the only planning applications that have been presented for scrutiny to the National Committees have been for the Sherwood Pines and Blackwood sites, ie. the two new sites.
17No planning applications have been submitted to the National Committees for Ardgartan, Woodland Forest of Dean, Spiers House or Thorpe Woodlands.
18On 4 September, under a Freedom of Information request, we requested a copy of the “internal guidance on the FC aspects of the governance of Forest Holidays” referred to in the minutes above for 3 May 2007.
19On 23 September we received the following response from the Forestry Commission “You requested an electronic copy of the internal FC guidance on the governance of Forest Holidays. We do not hold this information and are thus unable to provide you with the information requested.” We have written back seeking clarification on this.
20It is possible that not bringing the planning applications before the National Committees was just a dreadful misunderstanding. However that does not explain the language used in the publicly available minutes etc, which has meant that even an interested reader of the documents, let alone a casual one, could not have known that the campsites were being closed.
21This is illustrated as follows.
Ardgartan campsite: closed and replaced by Argyll lodge site
22This campsite had 200 pitches. In July 2008 a planning application was made for 28 lodges. The number of pitches then reduced to 100. On 30 October 2012 a planning application was made for 13 additional lodges and the removal of the need for any pitches. The campsite is now closed.
As reported to the Commissioners:
17 September 2008erection of 40 cabins
4 December 2008latest developments
13 June 2013site at Argyll [lodge site] had additional cabins added
Woodlands Forest of Dean campsite: closed and replaced by Forest of Dean lodge site
23This campsite had 90 pitches. In May 2009 a planning application was made for 76 lodges. The campsite closed in 2009. Two neighbouring CITF campsites are nearby.
As reported to the Commissioners:
14 June 2007locating 75 lodges on one of the current campsites
3 December 2009construct 76 cabins
28 September 2010new cabin site recently completed
Spiers House campsite: in the process of being closed and replaced by Cropton lodge site
24 This campsite had 200 pitches. In August 2007 a planning application was made for 40 lodges. The number of pitches reduced to 160. In February 2013 a further application was made to add 8 lodges and reduce the camping area by a quarter. In September 2013, the complete closure of the camping area was announced on the CITF website, even though there had been no further planning application.
As reported to the Commissioners:
14 June 2007locating lodges
17 September 2008erection of cabins
13 June 2013site at Cropton [lodge site] had additional cabins added
Thorpe Woodlands campsite: being closed and replaced by a lodge site
25This campsite has 130 pitches. In March 2013 a scoping/screening application was made for 70 lodges. In July this was replaced by a full application. Planning decision due 4 November 2013.
As reported to Commissioners:
17 September 2008locating cabins
Spiers House revisited
26This site is particularly interesting because, after planning permission was granted in 2007 for 40 lodges, a visit was made to the site by the Commissioners in 2009 when the first batch of lodges had been built. The Commissioners were, therefore, shown a site with both lodges and camping pitches.
27In the last couple of weeks the following announcement has appeared on the Camping in the Forest website:
“Please be advised that Spiers House will close for business on 1st November 2013. The Camping and Caravanning Club do not directly manage or operate the Spiers House campsite, the lease is held by Forest Holidays and while planning permission was being sought for cabins, the camp site has remained open under the Camping in the Forest badge. This has always been the longer term plan for Spiers House by Forest Holidays while the planning permission was being secured.”
28If it has, indeed, been the longer term plan for Spiers House, there is nothing anywhere to suggest that this was explained to the Commissioners in 2009 when they were shown, what was then, a dual use site. Also, although the minutes of the Commissioners' meeting of 13 June 2013 said that the Cropton lodge site had additional cabins added, the minutes did not say that the camping facilities at Spiers House were being closed.
29Interestingly, the February 2013 planning application only referred to removing ¼ of the remaining pitches rather than all of them. Forest Holidays are, presumably, within their rights to close down the rest of the site, but it seems strange that it was not stated explicitly in the planning application.
30Something else that was discussed at the Commissioners' meeting on 13 June 2013 was Memo 13/13 which referred to the two new Joint Ventures. This said that Camping in the Forest would concentrate on the camping and caravanning sites and that Forest Holidays would concentrate on the cabin business.
31What Memo 13/13 did not mention, but we found out through a Freedom of Information request, is that the leases for 5 of the campsites passed to Forest Holidays rather than to CITF with the following condition “FH lessee, although let by licence to CITF 21 Sept 2012 for a period of 5 years when title will then be assigned to CITF if FH do not issue intent to build on the land.”
32The 5 sites in question are Spiers House, Thorpe Woodlands, Beddgelert, Christchurch (Forest of Dean) and Glenmore. In the case of Glenmore, planning permission for the lodges was only granted on condition that they retained 206 camping pitches. No such stipulation is likely elsewhere, and so the future of Beddgelert and Christchurch campsites would also appear to be in doubt.
Year round use
33Lodge sites are used all year round. Archive material on the internet shows that Ardgartan, Woodlands Forest of Dean, Spiers House, Thorpe Woodlands and Christchurch Forest of Dean all started being advertised as year round sites in the early part of 2009. (Glenmore and Beddgelert had been advertised as being year round sites before then.)
34 It is interesting to note that Christchuch Forest of Dean should be on this list as well as being one of the sites for which Forest Holidays retained the lease. In the case of Thorpe Woodlands, this advertisement was not, in fact, accurate as the site was only available for 3 weeks over the 2009/10 winter season. Year round use at Thorpe actually commenced in 2010/11.
Environmental Impact Assessment
35The planning application for Thorpe Woodlands uses a figure of 460 pitches to argue that the construction of 70 lodges and associated facilities will reduce the intensity of use of the site. However the figure of 460 pitches was not used for the Thorpe website/brochure until after the Commissioners had been told of plans for “locating cabins” at Thorpe. Previously the figure had been 130.
36The Commissioners were told of the plans on 17 September 2008. Archive material on the Internet shows that the number of advertised pitches for Thorpe was increased from 130 to 460 between 20 December 2008 and 6 March 2009.
37The planning application itself refers to there being a reduced emphasis on the promotion of the Thorpe site in expectation of the proposed cabin development.
38Having decided to reduce promotion of the site, it makes no sense to increase the number of advertised pitches and then choose to use this increased figure of 460 in the planning application rather than historical site usage figures which, on average, fall below 70 pitches per night.
39Of all the campsites that Forest Holidays have so far sought to convert to lodge sites, Thorpe is the only site with a Special Area of Protection (SPA). A decision was therefore required by the local authority on whether or not an Environmental Impact Assessment was required.
40Although several campsites had their website pages changed in early 2009 to year round use, Thorpe was the only site for which the number of advertised pitches was, simultaneously, dramatically increased (from 130 to 460).
41In arriving at their decision for Thorpe that no Environmental Impact Assessment (EIA) is required, the council have made the following comments “given the intensity of the existing recreational use of this site”, “the proposal would result in less accommodation on site”, “the proposal is likely to result in an overall reduction in traffic given the reduced number of units”.
42The comments, and the conclusion drawn, would be justified if the figure of 460 was valid. If the figure of 460 is not valid, then the implications are very serious. I have therefore looked into this issue in more detail and have concluded that the figure of 460 is not valid. My findings are attached in Appendix A.
Actual site figures
43We have been trying since 16 August to get hold of actual site figures so that we can try and form a balanced view on the (somewhat contradictory) claim by Forest Holidays that the conversion of the campsite to a lodge site will mean that the site will be both less intensively used whilst also generating more visitor nights to the area.
44We have asked the council planning officer to raise the issue with Forest Holidays.
45We have asked CITF, Forest Holidays and the Forestry Commission for the actual site figures. On 16 September I was advised that the Forestry Commission held no information after the joint venture was set up in 2006.
46As the Forestry Commission had a 49% share in Forest Holidays until September 2012, now have a 20% share and have had board representation all of that time, it seems strange that the Forestry Commission have no information. We don't understand why, had they wanted to, the Forestry Commission couldn't obtain the figures, especially if their own joint venture could be circumventing the EIA regulations by using figures that the site users believe, with good reason, to be inappropriate.
Redevelop versus new
47Four of the 6 lodge only sites added/being added to the Forest Holidays' portfolio have been converted campsites. When the previous Forest Holidays applied for planning permission for their new site at Blackwood it took 3 ½ years to get approval and then permission was only granted for 60 lodges instead of the 80/150 originally applied for. In contrast Forest Holidays expect it to take just 13 weeks to get approval to convert the Thorpe site.
48Part of the reason that approval can be obtained in just 13 weeks is because the council planning officer will only write to the neighbours of the site which, as the campsites are located within forested areas, may only number 2 or 3. Because the Forestry Commission (as landowner) and Forest Holidays (as applicant) could write to the site users but do not do so, the site users do not find out about the plans until planning permission has been granted.
49Thorpe has been the first site where the site users have been able to lodge objections. This is because a couple of the site users found out about the planning application by accident. CITF had to write to the other seasonal pitch holders in July after angry posts were made on the CITF Facebook page.
50We have had no further letters from CITF, which is another reason why the site users have written directly to the Commissioners. Unlike Spiers House, there have been no updates on the CITF website.
51It is understandable that Forest Holidays prefers to convert campsites. However they have the exclusive right to create new sites, and £60million with which to do it, and so the site users think it is wrong for them to take away affordable facilities from those on lower incomes.
52Nobody is asking for subsidies. The site has been a profitable one. If Forest Holidays want to set up a lodge site in Thetford Forest there are no shortage of places where they could do it. They don't need to close down the Thorpe site.
Appendix A
Environmental Impact Assessment concerns
Forest Holidays Planning Application for Thorpe Woodlands campsite
1Under the Town and Country Planning (Environmental Impact Assessment) Regulations 2011, Breckland Council was asked to decide if an Environmental Impact Assessment (EIA) was needed for the planning application by Forest Holidays for the Thorpe Woodlands campsite.
2The council decided that an EIA was not required. A review of the decision letter written by the local council suggests that the decision was reached on the basis of figures used by Forest Holidays which the site users believe are inappropriate.