Seasonal worker accommodation on a fruit farm

Seasonal worker accommodation planning on a fruit farm usually starts in the wrong place, with a search for a housing policy that will allow twenty caravans in a field. The better starting point is the caravan legislation, because agricultural land used during a particular season to accommodate workers employed in farming operations on land in the same occupation is exempt from site licensing, and the General Permitted Development Order grants planning permission for caravan sites in circumstances where a licence is not required.

That route is narrow and heavily conditioned. Where the scheme falls outside it, you are applying for a temporary permission with seasonal occupancy conditions, and the application stands on the labour evidence rather than on housing need.

Why seasonal accommodation is not ordinary housing

A permanent dwelling in the countryside has to clear a policy hurdle about isolated homes and, where it is for a rural worker, an essential functional need for somebody to live at or near the place of work. Seasonal accommodation is a different proposition. It is occupied for part of the year by people employed on the holding, it is tied to a cropping programme, and it is usually removed or mothballed for the winter.

Councils assess it as accommodation ancillary to the agricultural business. That means the decisive questions are whether the labour requirement is real, whether the site is the right place for it, and whether the occupation can be controlled so that the accommodation does not become general housing in the open countryside.

Get that framing right in the Planning Statement and the rest follows. Get it wrong by presenting the scheme as a housing proposal, and the officer starts from a policy of restraint.

The caravan route and where it comes from

Two pieces of legislation work together.

Schedule 1 to the Caravan Sites and Control of Development Act 1960 lists cases where a site licence is not required. One of them covers the use of agricultural land for the accommodation, during a particular season, of a person or persons employed in farming operations on land in the same occupation. Part 5 of Schedule 2 to the General Permitted Development Order 2015 then grants planning permission for the use of land as a caravan site in circumstances where a site licence is not required.

Four conditions have to hold for that to work:

• the land is agricultural land, and it is in the same occupation as the land where the farming operations take place
• the occupants are employed in those farming operations, not in a packhouse operated as a separate business, and not on somebody else's holding
• the use is seasonal rather than year round
• the units are caravans within the statutory definition, which sets maximum dimensions for a twin unit and requires that the structure is capable of being moved

Modular buildings on strip footings, timber cabins and anything craned into place in sections that cannot then be moved are not caravans. That is the point where most schemes leave the permitted development route without realising it.

Where the route applies, get a written record: a plan of the site, the dates of occupation each season, the employment position of the occupants, and the specification of the units. A council investigating a complaint will ask for exactly that, and a lawful development certificate under section 191 is the formal way to put the position beyond doubt.

Temporary permissions and seasonal conditions

Outside the exemption, the normal route is a planning application for a temporary use, often for three to five years initially, with conditions that do the work:

1. Occupation restricted to persons employed in agriculture or horticulture on the holding, and their dependants.
2. A seasonal occupancy window, for example between 1 March and 30 November in any year, with the units unoccupied outside it.
3. A limit on the number of units and their siting, by reference to a plan.
4. Landscaping and screening, with a planting season specified and a replacement obligation.
5. Removal of the units and restoration of the land at the end of the permission, or on cessation of the agricultural use.
6. A management plan covering site rules, waste, quiet hours and the responsible person.

A temporary permission suits both sides. The farm gets consent aligned to a business that changes, and the council keeps the ability to review. Where the operation proves durable, a further application with better evidence usually gets a longer term.

The 28 day and 60 day temporary use rights are not a route to this, and the reasons are set out in the discussion of camping and caravan use under the 60 day right. Seasonal worker accommodation runs for months, not days.

Site licensing as a separate consent

Where the licensing exemption does not apply, the site needs a licence from the council under the 1960 Act, and planning permission has to be in place first. Licence conditions follow the model standards for caravan sites, which deal with spacing between units, boundary distances, fire points and fire fighting equipment, roads and gateways, water supply, sanitation, waste storage, lighting and electrical installations.

Licensing sits with a different team from planning, and the two have different concerns. Speak to both before finalising the layout, because a spacing standard can reduce the number of units a field will take by a quarter and there is no point discovering that after permission.

Where the accommodation is in a building rather than caravans, the questions change again: housing standards, means of escape, and whether the occupation amounts to a house in multiple occupation requiring licensing.

Foul drainage and water supply on a field site

This is where field sites become expensive, and where applications are refused when the answer is left vague.

Foul drainage for a site of any size will normally need a package treatment plant. Small sewage discharges are governed by the general binding rules where the discharge is within the stated volume limits and other conditions are met, and a permit from the Environment Agency is needed above those limits or where the rules cannot be satisfied, for example close to a protected site or a source protection zone. Size the plant for peak season occupancy rather than an annual average, and say who maintains it. A Foul Sewage Assessment setting out the calculation, the discharge point and the consent position answers the question before it is asked.

Water supply needs the same treatment. A mains connection with a metered supply and adequate pressure, or a private supply that has been risk assessed and sampled under the private water supply regulations, with the council's environmental health team involved. Tankered water for twenty people through a summer is not a plan.

Flood risk deserves a line too. A field that floods in February is not necessarily unsuitable for accommodation occupied from March to November, and the vulnerability classification for seasonally occupied caravan sites is more forgiving than for permanent homes, provided there is a flood warning and evacuation plan that somebody will actually operate.

Access, parking and minibus movements

Highway officers look at the junction, not the field. Visibility splays at the access, the width of the lane, passing places, and whether large vehicles can pass a minibus.

Movements cluster. Workers leave together at first light and return together. And there is usually a mid-shift run to a packhouse as well. Set out the daily profile: number of minibus trips, timing, where vehicles turn, and parking provision on site for staff cars and bicycles. Where the lane is single track with hedges on both sides, expect to be asked for passing places, and check whether they affect a hedgerow, since removal may require notice under the hedgerow regulations.

Landscape effect is the other recurring objection. Caravans read as white or cream blocks across a field, and on a site in or near a National Landscape a Landscape and Visual Impact Assessment is worth commissioning rather than arguing about. Siting against an existing hedge or woodland edge, with the units in muted colours and no floodlighting, deals with much of it.

Evidencing the labour requirement

The strongest applications contain a labour profile rather than a paragraph of assertion. Cropping schedule by variety and week, hectares in production, pickers required per week across the season, historical worker numbers for the past three seasons, and the current accommodation arrangements including anything rented off site.

Illustrative example. A 46 hectare soft fruit holding with a labour peak of 85 workers across nine weeks, currently housing 40 in an existing exempt caravan site and 45 in rented houses 18 km away. The application proposes 24 additional caravans on the same holding, occupied 1 April to 31 October, with a package treatment plant sized for 90 people, a mains water connection, and a minibus profile of four movements a day. The labour table, not the design, is what persuades the committee.

Keep the file current each season. Occupancy records, employment records and maintenance logs for the treatment plant are what defend the permission when a neighbour complains.

To see which reports a farm accommodation scheme is likely to need, enter the holding's postcode on PlanScope.

This is general guidance rather than legal advice. A lawful development certificate is the only formal way to confirm that works are lawful. Check the position with your local planning authority or a qualified professional before relying on it. PlanScope provides AI-assisted draft reports for planning applications. Reports should be reviewed before submission. We do not guarantee planning approval.