Response from Mr John Hammond (Individual)
1. Mr John Hammond (Individual) : 16 Dec 2015 22:54:00
Discussion Paper section
1. Introduction
Please make your comments below on the section you have selected. Where appropriate, make reference to the paragraph number you are referring to, your preferred option, the question number asked in the Discussion Paper and the reference number of the site you are commenting on.
Q1. The weight of recent legal advice, and common sense, appears to favour a less than rigid definition of what might constitute a 'major development' in an AONB. However, such a definition should take into account, on a case by case basis, the potential of any development to have a serious adverse impact on the natural beauty of the site as well as traffic and health considerations.
Any definition therefore would need to consider that 'In determining what constitutes major development the Councils will consider whether the development, by reason of its scale, character or nature, has the potential to have an unacceptable adverse impact on the landscape, scenic beauty, wildlife, cultural heritage or special qualities of the AONB. The potential for adverse impact on the AONB will be dependent of the individual characteristics of each proposal and its context.' (James Maurici QC responding to South Downs National Park Authority).
Q. 2 Councils should identify housing requirements for the AONB but these need not be exclusively met within the boundaries of the AONB. Nearby conurbations - say Milnthorpe and Carnforth - could better meet the needs (with respect to employment, commerce and travel) without the need to compromise the natural setting of the AONB.
Q. 3 Evidence on the problematic nature of groundwater and sewerage disposal in Silverdale which is likely to be exacerbated further by the introduction of major developments.
Q.4 A valid and comprehensive vision statement.
Q.5. Appropriate objectives set out.
Q.6. Yes, taking account of the need to preserve the special characteristics of the AONB and making sure that the need for affordable housing is not used as a bridgehead to build unneeded market housing which would encourage in-migration rather than meet real needs of the local community.
Q. 7 Wherever possible.
Q. 8 Implementation of the Lancaster DPD (Policy DM 41) would encourage the appropriate mix of housing types.
Q.10 Yes, though in this particular area there is unlikely to be much.
Q. 11 Yes, on a case by case basis, respecting the character of the AONB.
Q. 12 Yes, where these are an expression of local need.
Q.13 Encouragement towards the provision of HS Broadband and adequate mobile phone coverage.
Q.14 Large scale projects seem inappropriate though small scale, like solar panels, should be encouraged.
Q. 16. Parking at both railway stations is inadequate, and needs improving. The issue likely to be exacerbated further if the Silverdale Shuttle bus service is discontinued. There is also a growing need for parking in the centre of Silverdale.
Q. 17 Present numbers of mobile and static caravans at various sites provide access for substantial numbers of visitors, contribute to the economy of the area and make access roads sometimes difficult to negotiate. However, substantial further development will impact adversely on and begin to destroy the natural beauty and peace of the AONB (which is what attracts the visitors) and produce gridlock on the narrow lanes. Further applications for expansion of sites and numbers therefore require the closest scrutiny.
Q. 18 Yes.
Q. 20 Yes. S56 and S 58. This quiet valley, close to and parallel with the sea to the east of Know Hill, with hedges and residual woodland is a typical feature of the local topography which gives this particular AONB its distinctive charm. The valley provides, in that corner of the village, visual access and a feel for the natural land forms which characterise the area.
Q. 21 The assessment of development proposals are inextricably linked with the need to preserve AONBs and the considerations for determining whether a particular project can be termed a major development. Alongside this the Statutory Management Plan's emphasis on conserving and enhancing landscape quality, local distinctiveness, geodiversity and the need to retain green space within settlements, should also have a crucial role.
Q. 22 By limiting wherever possible any development that would threaten the existing bio and geodiversity.
Q.23 Given the nature of the limestone terrain and the lack of mains sewerage in Silverdale further development should be severely limited.
Q.24 Existing policies are adequate.
Q. 25 The DPD should deter design features which are alien to or at odds with a built environment which sits in harmony with the defining features of the AONB.
Q. 26 Option (v) is preferable, provided the impact of any development on the landscape is held to a minimum and that neighbouring conurbations like Milnthorpe and Carnforth are used to reduce the need for development in the AONB.
Q. 27 I do not feel competent to comment on all the sites listed but wish to make comments on sites I know best: sites 56, Land South of Whinney Fold, and 58, Land West of Lindeth Road.
Both sites should be excluded from further assessment under criteria listed in paragraph 6.17 of the DPD:
'development of the site would represent a clear breach of National planning principles relating to AONBs: i.e. development in that location would have a materially adverse impact but could not be demonstrated to satisfy an overriding national need.'
'development of the site would constitute a major development and could not be demonstrated to be in the overriding public interest.'
'development would cause harm to the landscape or settlement character of the AONB, or the visual amenity of the AONB in a way that could not be mitigated.'
These exclusion clauses apply to both sites. Development here, particularly a major development, would destroy for ever some of the distinctive 'landscape quality, character and tranquillity' which still exists in this part of the AONB (Statutory Management Plan, para 1.6 in DPD Discussion Paper). There is no overriding national need or overriding public interest served by development on these sites as any demonstrated regional housing need could be satisfied by development on a less sensitive local site, or at a conurbation outside the AONB.
Further, there are drainage problems on the sites evident following the recent heavy rainfall that left deep pools of water on both sites. Development of these sites would further exacerbate these problems.
There are also access difficulties, particularly with the Whinney Fold Site. The only entrance to the site would be through Whinney Fold, a lane too narrow for two cars to pass comfortably. This road already serves 10 dwellings and has poor visibility at its junction with Shore Road.
Q. 30 Yes, phasing, perhaps through 3 five year periods, would appear appropriate as this would give time for other sites to become available and avoid over provision which would encourage in-migration rather than meet existing needs.
Are there any topics or issues that you think we have missed or that you wish to raise?
I have commented on most of the questions which I have numbered throughout.
I hope the response is intelligible.
