Local Development Framework Consultation

2. Background

The planning process needs to overtly recognise the austerity driven reductions and changes to public services and the way that they are being redesigned and delivered. Planned or actual cuts to bus services, local doctors surgeries, for example, will affect access to facilities within and outside the AONB for residents as well as visitors. There will inevitably be other reductions to services in the pipeline which are less obvious but cumulatively affect the sustainability of AONB communities and the visitor economy.Funding and budget reductions will also affect the ability of local Councils and RSLs to meet or influence others to meet identified housing needs. Organisations with responsibility for promoting and protecting the AONB have reduced capacity to deliver their responsibilities at a time when there are unprecedented development and other pressures.

See above

As Above

3. Evidence Base

The AONB Housing Needs Survey identifies a need for 72 affordable homes (Para 3.3) over the period 2014 to 2019. Para 3.4 raises the possibility of this being delivered by open market housing cross subsidy. This could be a gift to profit driven private sector housing developers of highly unaffordable housing enabling them to justify development in the AONB which otherwise would be rejected out of hand. Link this to para 5.9 which points to very unambitious requirements for affordable housing as a % of open market developments of 35% in South Lakeland and only 30% in Lancaster. Using these figure potentially justifies 168 open market and unaffordable houses to deliver 72 affordable over 5 years or 504 open market houses over the 15 year Plan period.
The Planning Authorities need to be confident that the Housing needs assessment is robust given its importance and reliance on self assessment by survey respondents. Also in looking to meet identified housing needs full account should be taken of these needs being met to some extent outside the AONB and the housing need and the District wide housing needs and housing land supply assessments
In response to Q 2 I would suggest limiting housing assessments to a five year period and review periodically bearing in mind the potential for shifts in national housing policy and the reality that people's needs will change from that identified in September 20I4
Q 3 Can infrastructure providers really plan with confidence over the Plan period given they often work to shorter timescales and with uncertainty over their funding arrangements. We are already seeing reductions to key services in public transport which underpin sustainability. Given recent flooding events full regard needs to be had to the Environment Agency's views at this key stage leading to site allocations.

4. Vision and Objectives

Q 5 The objectives are very general and can be a basis for justifying anything particularly in the light of national policy with its presumption in favour of sustainable development. Couple this with the Lancaster District Development Management Policies identifying Silverdale as appropriate for development and the case for development appears to be strengthened. Clearer and more specific objectives need to be set out emphasising the special character of the AONB and that development is an exception not a given.

None identified

5. Policy Issues

It is not clear from the Discussion document what planning consents are in place but not yet implemented which could contribute to the housing target. On a District wide basis new housing should be focused around the existing urban settlements leaving the AONB, and other rural areas, to meet demonstrable local needs rather than the wishes of housing developers and others whose actions are driven by profit or personal preference which, unless strongly controlled by a tight policy framework , will ultimately destroy the essence of the AONB.
There are a large number of sites put forward for assessment for housing development and, in Silverdale these have the potential to destroy the character of this part of the AONB. A number of them would fall into the category of major developments. Robust application of the site assessment criteria will hopefully see many rejected. Site S 48 appears to be particularly unsuited to development given its heavily wooded nature, proximity to other existing and valued woodland, and with a well used public path running through it which is an important part of the local footpath network.
The AONB Housing Needs Survey identifies a need for 72 affordable homes (Para 3.3) over the period 2014 to 2019. Para 3.4 raises the possibility of this being delivered by open market housing cross subsidy. This could be a gift to profit driven private sector housing developers of highly unaffordable housing enabling them to justify development in the AONB which otherwise would be rejected out of hand. Link this to para 5.9 which points to very unambitious requirements for affordable housing as a % of open market developments of 35% in South Lakeland and only 30% in Lancaster. Using these figure potentially justifies 168 open market and unaffordable houses to deliver 72 affordable over 5 years or 504 open market houses over the 15 year Plan period. Adding in the affordable homes quota, at 72 X 3, produces a figure closer to two years District wide housing supply for either Lancaster or South Lakeland being built in the AONB - a disastrous outcome. The Planning Policy framework has be very clearly make this unattainable in the AONB.
Q 6 Yes an affordable housing proportion should be specified and the starting point should be nearer 80% having regard to the housing needs assessment. This may seem extreme but a clear marker has to be put down and argued for strongly pending further national guidance.
Q7 Yes
Q8 Strong Planning Framework, high % for affordable housing and good design standards
Q10 Yes prioritise development of Brownfield sites
Q16 Anticipating the end of the Silverdale Shuttle car parking required at Silverdale Station possibly by agreement with the Golf Club or owner of the RSPB car park
Q17 Existing policies on caravan sites should be retained with a clear presumption against new developments, extensions or increases in seasonal occupation periods