Local Development Framework Consultation

1. Introduction

Recent government policies and actions in planning are counter productive and damaging to both the landscape and society. Planning has been massively undermined by changes in legislation, priorities and cuts to local authority budgets. It needs a complete rethink to deal with the greatly changed situation since the original enlightened Post-War legislation. There has been some recognition of the long term problems of globalization and climate change but the political will to deal with these problems is lacking. More austerity is the last thing we need.

In the Arnside Silverdale area where I live South Lakeland District Council/Lancaster City are in the process of a pointless exercise on a search for sites, that will make it even more difficult for the AONB to be protected from unsuitable development.

A design guide has been promised in every AONB management plan and I have yet to see one! This would be of more use than all of this policy that is of little practical value and will continue to be changed/overridden by events and national government!

Similarly, the Localism Bill suggested that there is a better way of doing things and suggested reforms to ensure that decisions about housing are taken locally. Proposals include preparing list of assets of community value - where is our list? Communities to draw up a "neighbourhood development plan". Silverdale started to prepare a plan but this has been overtaken by (put aside for?) this ill judged search for sites! Would the skills of the professional planners be more usefully employed in helping the local communities preparing their own plans, making use of the wide variety of talent in the local community? Not just encouraging the greedy people who have a vested interest in development.

I am not convinced by any of this and I very much doubt that many people will be able to find the time or make the effort to 'wade' through the plethora of documents. It is almost as if they are designed to obfuscate and confuse the public!

As I have said before, the main people who are likely to be interested in replying are those with professional knowledge, plenty of time and/or a vested interest in development.

At the heart of the National Planning Policy Framework is “a presumption in favour of sustainable development, which should be seen as a golden thread running through both plan-making and decision-taking. For plan-making this means that:
• Local Planning Authorities should positively seek opportunities to meet the development needs of their area;
• Local Plans should meet objectively assessed needs, with sufficient flexibility to adapt to rapid change, unless: …..
- Any adverse impacts of doing so would significantly and demonstratively outweigh the benefits, when assessed against the policies in this Framework taken as a whole; or
- specific policies in this Framework indicate development should be restricted.”

This "presumption in favour of sustainable development" provides wide opportunity for developers to question the fundamental basis of the policies and their interpretation.

2. Background

2.8 Agree with AONB management plan aims

2.9 Sounds okay but how do the District Councils intend to deliver objective 10 unless they are prepared to buy the necessary land and carry out preliminary work providing services and infrastructure. Experience has shown that the private sector will not do this - even when bribed by allowing a proportion of larger expensive development that everybody agrees is not needed in this area.

2.10 What do you mean by the most sustainable site?

2.18 The definition of a major development should be considered in relation to the scale of the area under consideration.
c (1) 3-4 houses would be too many on most places in the AONB
b (2) 0.1ha would be more appropriate size area

2.19 I agree that what constitutes major development will be a matter of judgement and this should be for qualified and experienced planning officers, architects and landscape architects to provide the necessary independent advice..

Beside being limited to essential need for affordable housing - account needs to be taken of:
the physical suitability of sites for development, this is a limestone area and most natural drainage is underground and although there are not many obvious floodplains, many places are subject to serious seasonal flooding from underground springs and the unpredictable development of new swallow holes.
Many areas depend on septic tank drainage that works really well and is a good example of true sustainability for low the density dispersed development that used to be typical of areas such as Silverdale. Many short sighted planning decisions for large new houses and extensions have undermined and damaged this landscape friendly form of delopment! Similarly, the size of village schools need to be considered

See above

3. Evidence Base

Q 1 In the previous section I indicated that no major development should be considered within the AONB - except where this would be in the national or exceptionally strong public interest. There should not be a precise definition although it would normally be much lower than you have suggested.

Q2 Councils should not try to identify housing requirements over the plan period, other that ensuring that : Objective 10 of the Management Plan to implement a development planning approach that delivers services, infrastructure and affordable housing to meet local community need while conserving and enhancing landscape character and the special qualities of the AONB. - should be rigorously applied. It is clear that there is no compelling need for new housing to meet the speculative market for expensive homes for commuters, second or retirement homes. These requirements should be met within easy travelling distance of existing urban areas that can provide the full range of necessary services.

YES - development elsewhere in Lancaster District and larger cities can help to protect the AONB landscape by providing desirable alternative well designed settlements at suitable locations, some of which are already being considered in the wider District plans. In other words prioritize this sort of speculative development outside the AONB!

Similarly, revive the development of new Country Parks (similar to Beacon Fell) in the urban fringes to provide for informal leisure in the countryside near to where people live.

The above local developments would be more sustainable.

4. Vision and Objectives

Both the vision and objectives seem excellent

Q5 All the objectives seem fine. particularly 3, 4 and 5 but elsewhere in the discussion paper I can find no convincing proposals to ensure that they are implemented, in fact quite the reverse! What about the necessary resources?

The government is cutting funding for Local Authorities - implementation of this vision and objectives will require expert staff with sufficient resources to carry out the necessary work, otherwise this will all be a wasteful paper exercise.

How will you ensure that any development is of a high standard?

Have you considered how devolution of more powers to the regions might affect this and what would be the best arrangement to make use of scarce resources?

5. Policy Issues

Q6 Affordable housing and houses for essential local needs should be the only housing development allowed if the aims and objectives of the AONB are to be achieved.

There should be no market homes allowed even "where essential to enable the delivery of affordable units without grant funding" - experience demonstrates that developers will exploit this and then (by various devious means) not deliver the affordable homes!

[SEE ATTACHED DOCUMENT]

I did have the time to comment on the wider Local Plans for either District but I did attend a meeting in Carnforth and looked at the public consultation on the Lancaster District. I was not convinced of the case for such large numbers required. I have not studied the areas in detail although I do agree that some well planned and designed development might be necessary/desirable in the areas: UE1 and GB1. I also thought expansion of Dolphinholme might be worth considering in more detail. I could see landscape problems with the other areas (particularly most in South Lakeland) and loss of good agricultural land and viable farmholdings did not appear to have been considered? I am in general agreement with the following comments on Green Belt land that are relevant and would complement the much stronger protection needed for AONB's and National Parks. Merrick Denton-Thompson, President Elect of the Landscape Institute and currently Chair of the Policy and Communications Committee said:

"The protection of the Green Belt has become a symbol of the green credentials of politicians across the political divide despite the fact it is being quietly eroded every day. The Green Belt has always been a relatively crude planning device to prevent the merging of villages and towns, as such it has only one value.

"In my view the Government needs the skills and innovation of landscape planners, landscape architects and landscape managers to renew and transform the Green Belt, by giving it new values relevant to the demands of the 21st century. Green Belts should become highly valued multi-functional places, distinctive in character, resilient to change, teeming with wildlife, and contributing to local health and well being. Landscape professionals’ analytical skills and imagination are needed by us all if the nation is to sustain the Green Belt for the next century."

No

6. Options for Meeting the Objectives and Delivering the Vision

I did not answer questions Q 7 - 25 in the previous section as all of these require more detailed assessment and value judgements for each individual proposal and site - I do not agree with a tick box system of planning that provides rigid guidance for every situation and undermines the need for proper planning consideration of design and development.

Q 18 - 20 Identifies some of the main elements for assessing private open spaces but clearly all the important open spaces have not been identified and this could be done better for individual neighbourhood development plans, or as part of the planning appraisal for a specific proposal.

Q 26 Of the options listed at 6.7 I consider (1) Development sites (carefully and restricted) allocated in primary settlements only plus highly restrictive policies everywhere else the most appropriate for the AONB.

Q27 and 28 I consider that many of the sites identified are too large for the AONB, and have serious landscape and environmental problems - I will try and identify some of these and send with copies of maps in the post if I can find time.

Q29 The whole of the AONB is special and has a boundary. Further development boundaries should not be necessary and are likely to encourage further infilling of remaining open spaces and large gardens that are an essential part of the landscape character - one of the main reasons for the AONB designation (in 1972) was to resist pressure (such as that clearly identified and encouraged in this discussion paper) for non essential housing and caravan sites. That pressure has been successfully resisted over the majority of the area and there have been significant improvements in the wider land management and conservation during the last 45 years. It is essential that a strong development control system continues and if possible should be strengthened so that enlightened protection continues in the difficult time ahead.
[SEE ATTACHED DOCUMENT]

Q31 Small family farms have continued to disappear since the AONB was designated. As farmers retired, farms have been split into lots and the farm steading sold separately to the land thus ending any possibility of a new young farmer purchasing a potentially viable farm holding.
Three large supermarkets have been allowed/encouraged to develop in Carnforth and there have been similar developments in nearby market towns resulting in loss of small shops and businesses.
These and other wider issues over which the local planning authority has little control should be identified as problems that undermine their ability to effectively plan for landscape conservation and maintenance of a vibrant society and small scale local economy. In other words real long term sustainability.

No