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The Sub-Committee received report ES-2476 which related to a new premises licence for Pakefield Caravan Park, Arbour Lane, Pakefield, Suffolk, NR33 7BQ. The Senior Licensing Officer introduced the report and stated that a hearing was being held as fifteen representations had been received against the licence from other persons, and one representation objecting to the licence had been received from a Responsible Authority (Environmental Protection). Since the report was published the applicant had amended times for licensable activity and opening hours. Regulated entertainment was to finish at 2230, sales would finish at midnight and the New Years extension was removed. As a result four objections have been withdrawn, including from the Environmental Protection team. The Senior Licensing Officer confirmed there was already a premises licence on this site for the current clubhouse building, this new licence would related to a new clubhouse being built in a new area of the site. The Senior Licensing Officer noted the application form stated times for the shop would be from 1000 to 2200 the following day, however the public notices displayed around the site stated the shop and sale times would be 0800 to 2200 and this is what the objectors had responded to. The licensing team were satisfied that these were the intended times and that the public had been adequately informed. Responsible authorities had been contacted regarding the correct times and there had been no response to indicate these were an issue.
The Applicant's Solicitor stated that the public opening hours referred to the opening hours of the shop from 0800 to 2200. The original application hours reflected the hours for the current licence which had been in place since Park Holidays had obtained the park in 2021. This application had therefore been to retain the existing license in the new clubhouse location, however following objections and recognising the concerns raised by locals and the fact that the clubhouse would be closer to residential properties this had been amended to an earlier finishing time and to remove the New Year extension. The planning conditions for the site also required activity to stop at an earlier time.
The Applicant's Solicitor stated the application was the result of the redevelopment of the holiday park which included the relocation of the clubhouse, provision of an additional 86 caravans and improved entrance access from the A12 rather than through residential areas. The current clubhouse was quite dated and would be in need of serious refurbishment in the next few years. The decision had therefore been made to move this to the new area of the site. The new clubhouse would be more modern and built to proper acoustic standards. The external patio areas of the clubhouse would face away from the nearest residential area, further helping to reduce noise. The aim was for the new building to open in April, and the license for the existing clubhouse would be surrendered a week after the new clubhouse opened for use.
The Applicant's Solicitor highlighted the operating schedule included in the agenda and noted no representations had been received asking for amendments or additional conditions on this operating schedule. The current clubhouse had been operated by Park Holidays for four years and there had been no issues raised by residents or by responsible authorities over this period. Objectors to this application had raised questions about the need for an off-license, this would be part of the general shop offer on site and a Challenge 25 policy was in place across the site.
The Applicant's Solicitor stated there was reference in the objections to nuisance from previous events and noted these events were outdoor events held under a temporary event notice and this application was for indoor events inside a clubhouse. Approximately 80% of the caravans on the site were owned by residents and Park Holidays would not want to upset either their own residents or neighbours by causing a noise disturbance.
The Chair invited questions.
The Applicant's Solicitor confirmed the new building would be fully air conditioned. The capacity of the building was approximately 300 people.
Councillor Reeves asked if the building would be open to the public and whether any areas would be age restricted. The Applicant's Solicitor confirmed the clubhouse would not be open to the general public, people had to display a pass to enter the premises. A Challenge 25 policy was in place across the site, and the passes used to enter the clubhouse were different for adults and children to allow for staff to easily distinguish them.
The Senior Licensing Officer asked when the old premises licence would be surrendered. The Applicant's Solicitor confirmed there would be an overlap of one or two weeks to allow for a trial ‘soft opening’ to train staff after which the licence would be surrendered.
The Legal Advisor asked what was the basis for amending the shop opening times from 1000 to the earlier time of 0800. The Applicant's Solicitor stated this had been a misunderstanding on the application form. The total opening hours were shorter overall, the opening time had just moved forward by two hours. The notices put up on site made it clear that opening times would be from 0800 to 2200
The Chair noted that there was a Lead Objector who would be speaking on residents behalf and but anyone who wished to add anything to the objection may do so.
The Lead Objector stated she was speaking on behalf of her neighbours. They lived in a quiet residential area with a number of retired residents. Caravans were already occupied and positioned right on this boundary, close to the properties and overlooking residents gardens. The new clubhouse was a much larger complex than the current one which operated on a much smaller basis with limited provision. People would be leaving the clubhouse for up to half an hour after the finishing time, causing a nuisance, noise and disturbance to residents particularly if visitors had been drinking and were not as away of the noise they would cause. No effort had been made to adhere to the planning conditions for an acoustic buffer despite assurance to the planning committee. The applicant had also assured the planning committee that live entertainment would only be for one event per quarter but this license application allowed entertainment every night of the week all year round. The Lead Objector highlighted the impact of noise and disturbance to neighbours, impacting their sleep, mental and physical health and quality of life. All proposed hours were for Monday to Sunday starting at 10.00 and allowed for entertainment for a long period of time every day. The objector also stated a amusement arcade was in place on the site, and fireworks were also used on site and asked if these were also not a licensable activity.
The Chair invited questions.
Councillor Reeves asked if there had been any issues from the current clubhouse. The Lead Objector stated that it was further away from properties but that outdoor entertainment activities had been very loud and could be heard across the neighbourhood.
Councillor Reeves asked if they supported the amended shorter hours. The Lead Objector stated they were pleased the hours had been reduced, but the application was still for every night a week which seemed excessive.
Councillor Craig asked if there had been any disturbance from the caravans on the boundary at present. The Lead Objector stated that these were mostly used by workers at the moment who did not make much noise but they did overlook residents gardens and invade their privacy.
Councillor Reeves asked the Applicant's Solicitor if there would be a fence built in accordance with planning conditions. The Applicant's Solicitor confirmed a fence was a planning condition, the current caravans on site were older ones occupied by site workers and these would be moved once construction was completed and a fence installed. A second objector stated that she lived opposite the clubhouse and stated that the acoustic screen should be in place before the clubhouse opened and before caravans were moved into place. The Legal Advisor stated this was not a matter for this meeting, but this would be raised with the Council's Planning Enforcement team.
The Legal Advisor asked if the objectors were comforted by the removal of the objection by environmental protection. The objectors statedthey were not, there was still noise disturbance from the site.
The Chair invited each party to sum up.
The Senior Licensing Officer stated that planning has already been considered by the planning committee and should not be reconsidered by the licensing committee. The Senior Licensing Officer noted that the reduction in hours would mean that the planning conditions would be met. The Senior Licensing Officer also noted that fireworks were not a licensable activity.
The Applicant's Solicitor summarised responses to the issues raised by the objectors. The clubhouse had to be closed and vacated by midnight. The caravans in place on the site boundary were occupied by site workers and would be moved. The Applicant's Solicitor noted that the building would be airconditioned and so windows and doors would not need to be opened, helping to reduce noise. The Applicant's Solicitor accepted that seven day live music was concerning to residents and they would be content with this being restricted to Friday and Saturday for live music. The other activities applied to relatively small things such as showing childrens films and TV shows in a side area which is why it was for seven days a week and for long hours. The amusement arcade was covered by a bingo license which was applied for separately. The Applicant's Solicitor noted that this application would help increase tourism in the area and the replace the sites lost due to coastal erosion, although this had to be balanced with the needs of local residents. The Applicant's Solicitor highlighted points 9.12 and 9.15of the Section 182 statutory guidance which stated that if there were crime and disorder issues the police were expected to object, and similarly Environmental Protection were expected to object for noise disturbance. Concerns raised by the Responsible Authorities had been dealt with and changes made. The applicant noted that residents could bring a review of the license and if there was noise nuisance or antisocial behaviour the park could be issued with a notice or forced to close. However Park Holidays did also need to protect their investment and consider the impact of activities on their own and local residents.
DECISION NOTICE
Park Holidays UK Ltd has applied for a new premises licence for Pakefield Caravan Park, Arbour Lane, Pakefield, Suffolk, NR33 7BQ. The proposed hours are for:
Plays (Indoors) Monday to Sunday 10:00 to 01:00
Films (Indoors) Monday to Sunday 10:00 to 01:00
Indoor sporting events Monday to Sunday 10:00 to 01:00
Live music (Indoors) Monday to Sunday 10:00 to 01:00
Recorded music (Indoors) Monday to Sunday 10:00 to 01:00
Performances of dance (Indoors) Monday to Sunday 10:00 to 01:00
Anything of a similar description (Indoors) Monday to Sunday 10:00 to 01:00
Late night refreshment Monday to Sunday 23:00 to 01:00
Supply of Alcohol – On and Off the premises Monday to Sunday 10:00 to 01:00
In the shop: New Year’s Day 08:00 to 22:00
PROPOSED OPENING HOURS Monday to Sunday 08:00 to 01:30
The Sub-Committee heard from the Senior Licensing Officer, who summarised the report and confirmed that the hearing had been held as 15 representations against the application had been received from other persons and one representation had been received from a Responsible Authority (Environmental Protection) The Senior Licensing Officer stated that since the report was submitted times for licensing activity and opening hours had been amended. Regulated entertainment would now finish at 10.30pm, sales would finish at midnight and the New Years extension had been removed. As a result, four objections have been withdrawn, including the objection from the environmental protection team. The Senior Licensing Officer stated that the application form stated times for the shop would be from 1000 to 2200 the following day, however the public notice stated the shop and sale times would be for 0800 to 2200 and this is what the objectors had responded to. The licensing team were satisfied that these were the intended times and this is what the public had been informed of and responded to.
The Sub-Committee then heard from the Applicant’s Solicitor who stated that they had applied for hours until 1am as this was the same as the premises license the park currently had which had been in place since park holidays had obtained the park in 2021. This application had therefore been to retain the existing license in the new clubhouse location, however following objections and recognising the concerns raised by locals and the fact that the clubhouse would be closer to residential properties this had been amended to a finishing time of 10.30pm for regulated entertainment and a closing and finishing time of midnight for sale of alcohol and refreshments. This was also the same finishing time as required by planning conditions. Any reference to New Year had also been removed as this was also not allowed by the planning conditions.
The Applicant’s Solicitor stated that the current clubhouse had been operated by Park Holidays for four years and there had been no issues raised by residents or by responsible authorities such as the police over this period. The Applicant’s Solicitor highlighted the operating schedule and confirmed that they operated a Challenge 25 policy. The applicant’s solicitor stated that 80% of caravans were owner occupied, and they would not wish to cause a nuisance to their own or local residents.
The Sub-Committee then heard from the objectors who stated that the new clubhouse was a much larger complex than the current one which operated on a much smaller basis with limited provision. People would be leaving the clubhouse for up to half an hour after the finishing time, causing noise and disturbance in the local area and impacting residents sleep, health and quality of life. The objectors also highlighted that no effort had been made to adhere to planning conditions regarding an acoustic buffer, further adding to the disturbance.
The decision of the Sub-Committee
The Sub-Committee, having considered the application, the Licensing Officer’s report and the representations received from the applicant and other objectors has decided to grant the licence subject to the revised opening and operating times:
- All regulated entertainment, including plays, films, indoor sporting events, recorded music, performance of dance, anything similar to recorded music to finish at 2230 Monday to Sunday.
- Amplified live music and anything similar to live music to finish at 2230 Friday to Saturday and not to take place Sunday to Thursday.
- Sale of alcohol, late night refreshments and opening hours to finish at midnight Monday to Sunday.
- Alcohol off sales and opening times in the shop 0800 to 2200 Monday to Sunday
This is also subject to the additional conditions as specified below.
Prevention of Public Nuisance
- Windows and doors must be kept closed from 2130, except for access and egress.
Reasons for decision
In arriving at this decision, the Sub-Committee has taken into consideration the representations of the applicant, objectors as well as the Licensing Officer’s report. The Sub-Committee also considered the Council’s own licensing guidance and statement of licensing policy, as well as the Statutory Section 182 guidance, and Human Rights Act 1998.
The Sub-Committee notes that paragraph 9.12 and 9.15 of the Section 182 statutory guidance states that the responsible authorities are experts in their respective fields and great weight should be placed on their representations or lack of. In this case the Sub-Committee places great weight on the fact that Responsible Authorities, in particular the Police and Environmental Protection, have not raised any objections. The Sub-Committee notes that Environmental Protection had previously raised objections but the applicant has reached agreement with them regarding the proposed opening hours. This shows that applicant is prepared to take a pragmatic approach when dealing with responsible authorities.
The Sub-Committee was mindful of the representation from the objectors, and notes concerns regarding noise in the evening and therefore considers it necessary to impose a condition regarding the closing of doors and windows from 2130 to reduce noise nuisance.
The Sub-Committee notes that the application appeared to contain some discrepancies regarding the opening time of the shop which was reflected in the notice on the Council’s website. However the public notice which the residents responded to contained the correct hours and therefore the sub-committee is satisfied that the local residents have not been impacted by this discrepancy. The sub-committee also notes that the responsible authorities had been informed and had raised no objections.
In relation to some of the concerns raised relating to planning matters, this is not a matter for the Licensing Sub-Committee however the Sub-Committee notes that if there are any concerns these can be raised with the planning authority.
The Sub-Committee would also like to reassure the objectors that this matter could be brought back for review if there was evidence that the premises when operating was in breach of its conditions or if the conditions prove insufficient to promote the licensing objectives.
The Sub-Committee is therefore satisfied that that licence can be granted as applied for subject to the conditions imposed.
Anyone affected by this decision has the right to appeal to the Magistrates’ Court within 21 days of receiving notice of the decision.
Date: 20 August 2025