Local Development Framework Consultation

I have read the guidance notes

LA1.3 Housing Allocations - R81 ARNSIDE REDHILLS ROAD

Yes

No

The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.

The DPD is not consistent with national policy.

Site R81'Arnside. Policy LA1.3 (and paras. 3.77 to 3.92 and 3.95)

Detailed comments from National Trust

National Trust has consistently raised concerns regarding this particular site and its suitability for development given that it is a green field site situated on the edge of the built up area of Arnside, and the noticeable adverse effect that development would
have upon views from higher, open access, land to the south that are enjoyed by many residents and visitors.

It is noted that previous consultations have resulted in an overwhelmingly negative response to the proposed allocation (29 submissions) including from the Arnside and Silverdale AONB Manager, Arnside Village Society and the AONB Landscape
Trust. Generally these objections have expressed particular concern about the adverse impact of development upon the landscape character of the AONB- as confirmed by the final NPPF: "Great weight should be given to conserving landscape and scenic beauty in National Parks, the Broads and Areas of Outstanding Natural Beauty, which have the highest status of protection in relation to landscape and scenic beauty"- para 115. Relevant advice on major planning applications (para 116) in these special landscapes notes the requirement to consider three criteria, not simply need but also the potential to
meet need outside the designated area and an assessment of the detrimental impacts and how these could be moderated. It is suggested that it is appropriate for a similar approach to be taken to land allocations.

In terms of need it is noted that other, small, sites are available within Arnside, below the 0.3 hectare threshold used by the Council, which are suitable for development and are likely to make a contribution to meeting need. Furthermore the Trust does not object to the other allocations proposed within the AONB. As demonstrated by the work across the District on land allocations there are a wide variety and number of alternative sites, outside designated landscapes, that have been suggested for allocation but that are not proposed to be taken forward. In terms of need attention is drawn to para 2.12 of the Land
Allocations DPD- it is not apparent that the provision of market housing in Arnside would "meet needs related to the AONB". Overall therefore the Trust would continue to question the necessity to allocate Site R81.

Responses by the Council to objections to this site, in particular in the context of the impacts upon the AONB have largely relied upon relevant landscape character assessment documents. The principal one of these is the Cumbria Landscape Assessment Toolkit which was finalised in 2011; the site is covered by Landscape Sub-Type 3B: Wooded Hills and Pavements. This landscape type is only found in the AONB; Arnside Knott is a key feature of the area and the overall Vision is that the landscape
will be "conserved and enhanced" with development to be subject to strict controls. It is noted that historically residential (and other) development has led to some 'suburbanisation' of rural character. It is specifically noted that planned and incremental expansion of settlements such as Arnside could result in a loss of historic boundaries and a weakening of vernacular or traditional characteristics. The Guidelines for development state:
• any further expansion of villages should be managed to respect their natural and historic boundaries and features and to avoid sprawl and encroachment into surrounding countryside and important village settings;
• protect village fringes from unsympathetic peripheral development... ensure any new developments are visually contained and respect the scale, traditional form and character of the settlement and building materials;
• resist infill development of important open or historic spaces within villages.

Having regard to these criteria it is considered that site R81 is not appropriate for allocation for housing development and should not be taken forward.

If, notwithstanding this objection in principle, the site is to be allocated then it is considered that its sensitivity is such that specific requirements for its development should be set out in Policy. Some of the relevant matters are covered in paragraph 3.95; however, this only has the status of advisory/supporting text. It is considered that a Policy, similarly to Policy LA2.12, should be prepared, in particular requiring the preparation by the Council (with appropriate consultation) of a Development Brief for the site.

Headline topics for the Development Brief would include:
• Development restricted to those areas less open to long range views, especially from key viewpoints on Arnside Knott.
• Establish a landscape framework for the site to both reflect and reinforce the importance of woodland - including substantial new planting along the southern edge of the site.
• Retention of existing trees.
• Additional planting and landscaping.
• Incorporation of public footpath links, including to connect to existing paths on Arnside Knott.
• Guidance on the scale, especially height, but also overall massing of new buildings to minimise impacts upon views from the surrounding area and in particular from Arnside Knott.

NO, I do not wish to participate at the oral examination

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I have read the guidance notes

2.67

Yes

No

The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.

The DPD is not consistent with national policy.

It is considered that site R81 is not appropriate for allocation for housing development and should not be taken forward.

If, notwithstanding this objection in principle, the site is to be allocated then it is considered that its sensitivity is such that specific requirements for its development should be set out in Policy. Some of the relevant matters are covered in paragraph 3.95; however, this only has the status of advisory/supporting text. It is considered that a Policy, similarly to Policy LA2.12, should be prepared, in particular requiring the preparation by the Council (with appropriate consultation) of a Development Brief for the site.

Headline topics for the Development Brief would include:
• Development restricted to those areas less open to long range views, especially from key viewpoints on Arnside Knott.
• Establish a landscape framework for the site to both reflect and reinforce the importance of woodland - including substantial new planting along the southern edge of the site.
• Retention of existing trees.
• Additional planting and landscaping.
• Incorporation of public footpath links, including to connect to existing paths on Arnside Knott.
• Guidance on the scale, especially height, but also overall massing of new buildings to minimise impacts upon views from the surrounding area and in particular from Arnside Knott.

NO, I do not wish to participate at the oral examination

Please notify me

I have read the guidance notes

0.3 Section 3

Yes

No

The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.

The DPD is not consistent with national policy.

it is considered that site R81 is not appropriate for allocation for housing development and should not be taken forward.

If, notwithstanding this objection in principle, the site is to be allocated then it is considered that its sensitivity is such that specific requirements for its development should be set out in Policy. Some of the relevant matters are covered in paragraph 3.95; however, this only has the status of advisory/supporting text. It is considered that a Policy, similarly to Policy LA2.12, should be prepared, in particular requiring the preparation by the Council (with appropriate consultation) of a Development Brief for the site.

Headline topics for the Development Brief would include:
• Development restricted to those areas less open to long range views, especially from key viewpoints on Arnside Knott.
• Establish a landscape framework for the site to both reflect and reinforce the importance of woodland - including substantial new planting along the southern edge of the site.
• Retention of existing trees.
• Additional planting and landscaping.
• Incorporation of public footpath links, including to connect to existing paths on Arnside Knott.
• Guidance on the scale, especially height, but also overall massing of new buildings to minimise impacts upon views from the surrounding area and in particular from Arnside Knott.

I have read the guidance notes

2.12

Yes

Yes

Given the very special nature of AONB landscapes and the particular presures facedin and around Arnside this is a necessary and welcome approach in principle. It accords with national policy as set out in the NPPF and also conforms with the Core Strategy policies relating to the AONB

NO, I do not wish to participate at the oral examination

Please notify me