Reports for seasonal agricultural worker caravans

Seasonal worker accommodation on a farm needs two separate consents, and the one people forget is the site licence. Planning permission under the Town and Country Planning Act 1990 decides whether the use of the land is acceptable at all. A caravan site licence under the Caravan Sites and Control of Development Act 1960 decides how the site is laid out, spaced and run. Most seasonal worker accommodation planning applications that stall do so because the farming need has been evidenced carefully and nothing else has, which leaves environmental health and the lead local flood authority with nothing to comment on except the gaps.

Some farms need neither. Schedule 1 to the 1960 Act exempts the use of agricultural land as a caravan site for the accommodation, during a particular season, of people employed in farming operations on land in the same occupation. Where that exemption bites, Part 5 Class A of the Town and Country Planning (General Permitted Development) (England) Order 2015 permits the use too. Two things have to hold together: the occupiers must be employed in farming on land in the same occupation as the site, and the use must be seasonal rather than all year.

Two regimes that ask different questions

The planning question is about the principle and the impacts. Is a residential use of this field acceptable in a countryside location, is it tied to a genuine agricultural operation, and what happens to the highway, the watercourse and the neighbours.

The licensing question is about the running of the site. Spacing between units, surfacing, fire points, refuse, water points and the number of caravans all sit in licence conditions drawn from the model standards the Ministry of Housing, Communities and Local Government publishes for caravan sites in England. Those standards include a minimum separation between caravans of 6 metres, which has a direct effect on how many units fit in the area you have applied for.

Get the two in the wrong order and you lose time. Apply for 24 pitches, get permission, then discover the spacing standards allow 16 on that footprint, and you are back for a variation.

Evidence of agricultural need

This is the part that carries the application. A planning officer in a rural authority is being asked to accept residential occupation outside a settlement boundary, which national policy resists unless there is an essential need for a rural worker to live at or near their place of work. The evidence has to be specific to the holding.

Set out the cropping or livestock calendar month by month, the labour requirement in worker days against each operation, the existing permanent labour on the holding and the shortfall the caravans are meant to cover. Add the travel-to-work argument: where the nearest settlements are, what the public transport is, and why workers cannot reasonably live off site. A Planning Statement is the document that holds this together and ties it to the adopted local plan policy on rural workers and farm diversification.

Two numbers matter more than the rest. The peak-season headcount, and the number of weeks the accommodation is occupied. Councils condition both.

Water supply and foul drainage

Foul drainage is the single most common reason a seasonal accommodation scheme is refused or held. Twenty caravans with shower blocks produce a load that a domestic septic tank cannot take, and the discharge is seasonal, which makes a package treatment plant harder to run well.

Work out the population equivalent first, then test the options in the order national guidance sets: mains sewer connection, then package treatment plant with a permitted discharge, then septic tank with a drainage field only where ground conditions allow. A Foul Sewage Assessment should record the calculation, the percolation test results and whether the sewerage undertaker has confirmed capacity. Where the site is on a private borehole or a spring, a Water Supply Assessment needs to show yield, storage and the sampling regime, because a seasonal site with intermittent demand is exactly where supply quality problems appear.

If the site sits in Flood Zone 2 or 3, the position hardens. Caravans are treated as highly vulnerable in flood risk terms, and a seasonal use does not change that classification.

Access, parking and movement

Transport evidence for this kind of site is modest but it has to exist. Councils want the access geometry, visibility splays measured on site rather than scaled off a drawing, the surfacing of the first few metres, and a parking count that reflects how the workers actually arrive. Minibus arrivals and departures at shift change behave differently from private cars.

A short Transport Statement covering trip generation at peak season, the access arrangement and pedestrian movement between the caravans and the packhouse will usually satisfy a highway authority on a site of this scale. Where the access is onto a rural road with a 60mph limit and no footway, expect a request for speed survey data rather than assumed speeds.

Internal movement is worth a drawing of its own. Separating worker pedestrian routes from tractor and lorry movements is a safety point that an officer can see immediately.

Siting, landscape and fire separation

A block of white caravans in an open field reads badly in a landscape assessment, and in a National Landscape or on the edge of a National Park it will be the deciding issue. Site the units against existing buildings, hedgerows or woodland edges where you can. Show the existing and proposed site sections as well as the plan.

The layout drawing should carry:

• the 6 metre separation between caravans, dimensioned
• fire point locations and the distance from the furthest caravan
• the amenity block, drying space and refuse storage
• hardstanding extent and its drainage
• any lighting columns, with their height and direction

Where the proposal is visible from a public vantage point or sits in a designated landscape, a Landscape and Visual Impact Assessment gives the officer something to weigh. On a smaller or well-screened site, photographs from agreed viewpoints and a planting plan will do the same job for less money.

External lighting is the quiet refusal risk. Seasonal sites are occupied at 5am in the picking season, and a bank of floodlights on an unlit rural lane draws objections about both amenity and bats.

Hardstanding, services and the works that are not permitted

Part 5 Class A permits a use, not a building site. Laying hardstanding, forming a new access, putting in a treatment plant or erecting an amenity block are separate operations that need their own permission unless another class covers them. Part 5 Class B does permit works on land already used as a caravan site where a licence condition requires them, which is a narrower power than it first appears.

Part 6 of Schedule 2 covers agricultural development on units of 5 hectares or more, with prior approval for the siting, design and external appearance of larger buildings. It does not extend to residential accommodation. Plenty of farms have assumed otherwise and ended up with an enforcement notice on a converted barn used for workers.

Temporary permission and what it commits you to

Councils frequently grant three or five years for seasonal worker accommodation, with conditions limiting occupation to people employed in agriculture on the holding, restricting the occupation period to named months, capping the number of caravans and requiring removal and restoration at the end of the period.

That is usually a sensible outcome. It lets the authority test whether the need is real and whether the site behaves, and it gives you a track record to argue from at renewal. Keep the records the conditions imply: an occupancy log, the employment link for each occupier, the treatment plant service certificates and the water sampling results. Renewal applications are won on evidence of compliance.

One honest uncertainty: how hard an authority looks at the functional need varies a great deal between rural districts, and the same evidence pack does not get the same reception everywhere. Ask for pre-application advice before you commission surveys, and ask specifically what the council expects on drainage.

Illustrative example

A 40 hectare soft fruit holding applies for 18 caravans for a May to October picking season. The labour schedule shows a peak requirement of 22 workers in July against two permanent staff. Foul drainage goes to a package treatment plant sized for a population equivalent of 36, discharging to a ditch under an environmental permit. The layout places the caravans behind an existing packhouse with 6 metre spacing, two fire points and a 2 metre hedgerow infill along the lane. Permission is granted for five years, occupation limited to 1 May to 31 October, with a condition requiring the site to be cleared by 30 November each year. This example is illustrative and is not based on a decided application.

Entering the site postcode on PlanScope will show which of the 66 report types the constraints at that location are likely to trigger, including the drainage and landscape documents a seasonal accommodation scheme usually needs. Start with the postcode entry on the home page.

This is general guidance, not legal advice. Check the position with your local planning authority or a qualified professional before relying on it, and remember that a Lawful Development Certificate is the only formal way to confirm that an existing or proposed use is lawful. PlanScope provides AI-assisted draft reports for planning applications. Reports should be reviewed before submission. We do not guarantee planning approval.