Local Development Framework Consultation

I have read the guidance notes

LA1.1 Development Boundaries

Yes

No

The DPD is not consistent with national policy.

We welcome the decision to remove small villages from the hierarchy of specified settlements. However, we would question the need to impose settlement limits and/or development boundaries on settlements of any size.

National guidance set out in the National Planning Policy Framework (NPPF) clearly supports a presumption in favour of development, except where this would go against principles of sustainability. Such an approach should already be inherent within all parts of the Council’s Core Strategy.

As such, it is these policies which should form the basis for the consideration of the viability of any site for development. There is no need to impose specific development boundaries as well.

The opening to proposed policy LA1.1 implies that sustainable development can normally only be achieved within the identified settlements and therefore development outside these settlements will not be supported. In light of the NPPF, this is an arbitrary statement. All developments and sites should be assessed individually as to whether the development proposed achieves sustainability.

Too often, development boundaries can be arbitrary or outdated and impose unnecessary restrictions upon where development can or cannot be directed. Such boundaries should not be the division between whether a site is suitable for development or not, especially in light of the NPPF.

In most cases, there is little or no difference between the suitability of a site lying adjacent to a settlement boundary, either inside or outside of its bounds. But with the way policy LA1.1 is currently written, one site would be looked upon much more favourably than the other if it were inside a development boundary, and vice versa.

Any proposal that conforms to appropriate DPD policies and supports sustainable development should be considered as likely to be acceptable, whether or not it is situated within a defined settlement.

In this context, allowing the local proposition of development sites ensures that development can react to local demand or need. Effectively, the planning system should impose its own checks and balances upon development without the need to designate arbitrary development boundaries.

LA1.1 needs to be reformulated to change its tone from that of limiting development to certain settlements to instead become more aspirational in terms of the form of development that is envisaged for each type of settlement.

All targets or limits that will restrict certain forms of development to specific locations should be removed. Therefore, all references to settlement boundaries should also be removed from the supporting text to the policy.

It is also imperative to alter the opening paragraph of LA1.1 to remove the implication that sustainable development is not achievable outside of the identified settlements. The opening to the policy should instead read as follows;

‘Although sustainable development could be possible at any location in South Lakeland, the settlements set out below are considered to represent where such development is more likely to be achievable. Outside of these settlements, individual developments will be assessed against Core Strategy policies in light of their achieving sustainable development, as set out within the Core Strategy and national planning guidance.’

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I have read the guidance notes

2.33

Yes

No

The DPD is not consistent with national policy.

We welcome the decision set out in paragraph 2.33 not to propose specific residential allocations to small villages and hamlets and to also make provisions for neighbourhood planning powers as a route to the proposal of sites for housing development.

Having said this, we would note that it is also essential to ensure that communities are not able to arbitrarily block housing developments that meet the criteria of sustainable development. This position must be enshrined in policy otherwise it is much less likely that residential developments would be brought forward, especially if there is a risk that suitable proposals will be derailed for non-planning reasons.

A re-wording of paragraph 2.33 to this effect would support both the concepts of neighbourhood planning and the potential for local developments to meet specific needs.

In light of the introduction of the National Planning Policy Framework (NPPF) as the basis for national planning guidance, it is also necessary to make much stronger reference to this within the supporting text to Policy LA1.4. Given the presumption in favour of sustainable development that now underpins development planning in England, such an approach must be inherent to local development policies and clearly stated as such.

Given these points, supporting paragraph 2.33 to Policy LA1.4 should be re-written as follows;

‘Residential allocations are not proposed in small villages and hamlets. Here development is primarily to meet local needs and is likely to be predominantly on small sites. Housing development proposals outside main settlements will be determined against adopted Core Strategy policies which set criteria for development in the countryside as well as provision for the exceptional approval of affordable housing proposals.

Core Strategy policies reflect the presumption in sustainable development that underpins the National Planning Policy Framework. In this light, any proposed development that is considered to meet the aspiration of sustainable development within the local context of South Lakeland will be viewed positively.

Neighbourhood planning powers offer considerable scope for small rural communities to bring forward proposals themselves. As can be seen from Table 1 above, delivery in small settlements has been strong. However, to ensure that the needs identified in the Core Strategy are met, the Council will monitor completions in small rural communities and may review the need for allocations in the event of delivery falling short.

While such local proposals of development will be encouraged and supported, it must also be made clear that these powers are not an opportunity for communities to arbitrarily block development proposals. Any proposal that accords with the expectation of sustainable development will be supported as set out in local and national policies and led by the National Planning Policy Framework.’

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