Local Development Framework Consultation

As a resident of Yealand Redmayne I would like to bring to your attention a few observations about the uniqueness of the Village:

a. The Yealands consists of three separate villages Conyers, Redmayne and Storrs, the layout of the villages in centred on fields separating the villages and around the road, where originally - farms were built on the west side of the road and barns on the east side.

b. The villages have grown since the 17c with a distinct Quaker involvement and values, which is clearly apparent in the mix of social housing, semi detached housing whose price is below the national average and local character stone built housing.

c. the road is more a rural county lane - which assists the rural setting as an asset for walker and cyclists.

d. the Development plan already show this mix of housing 40% plus of housing is more than fairly priced - and I think the village is proud of its overall inclusiveness.

e. the potential of more building: raises my concerns as >

1. the erosion of the current village boundaries, character and curtilage
2. knowing the cost to build in local stone –how could any new affordable homes be build to a affordable purchase price?
3. given point 2. Is the proposal Property Developer led or needs led

f. the village of Redmayne has grown from approximately 120 dwelling in 1999 to 150 homes in 2016 which is a 25% increase ...... how many other villagers or towns have grown some 25% in 16 years!


Thank you for carrying out this consultation

6. Options for Meeting the Objectives and Delivering the Vision

Any houses built on W87 would devalue our property, as we would lose our view of the Warton crag. Their elevated position would mean they are looking straight into our bedroom window. In the resent wet weather, the field entrance to the side of our house number 13, was like a river. If W87 was to be built on, this would add to regular flooding suffered by number 2, 4, 6, and 8 Main St, As would W88, W89, W92, W93 and W95 as the surface water goes down Sand Lane. And the drains cannot cope with the current run off. The Traffic in the Village is terrible all day, and more so at school times, and early evening it is only a mater, of time before a serious accident occurs.

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1. Introduction

AONB DPD
1.2 The AONB has been identified by the government as being of national importance.

1.4 The two District Councils have a statutory duty under Section 85 of the CRoW Act 2000 to have regard to the statutory purpose of AONB's in carrying out their functions. Within the AONB, Government policy requires that councils give great weight to conserving landscape and scenic beauty.

5.32 Both Councils have adopted policies to ensure inappropriate development is directed away from areas of highest risk from flooding.

5.33 The AONB contains a wide range of significant historic landscapes, features and distinctive settlement patterns.

6.12 sites put forward have to meet basic criteria:
avoid harm or adverse impacts on wildlife, landscape or heritage significances;

Councils have been asked to put forward sites for building BUT if there aren't any suitable sites proposed that aren't going to have an adverse affect on the landscape or a detrimental effect on property already in the area then they don't have to propose sites just for the sake of it.
People do not have a right to live in the village they were brought up in. My son, born and brought up in Warton has
bought a house in Carnforth, if at a later date he wishes to and can afford to move back into Warton then so be it. He will then be freeing up affordable/ starter housing in Carnforth.
We do not need more housing in Warton as there are plenty of market value houses for sale which aren't selling or are taking a long time to sell.
Not only would building on any of the proposed following sites have a massive visual impact upon the village, the infrastructure cannot cope with an increased population. There are already issues with flooding, drainage and volume of traffic. Each time there is heavy rain the road surface on Sand Lane and Mill Lane crumbles leaving huge potholes.
The Council has a duty of care to its residents and future residents. If any building is allowed on the following sites, the Council will not only be reneging on this duty of care but may also be causing safeguarding issues with regard to properties being flooded.

Site reference;

W83.Greenfield site. Virtually on the Crag. Would increase flood water running down Crag Road and affecting houses on Main Street opposite Crag Road.
W84. Greenfield site. Part of this land is Parish Council land, although I believe the boundary is incorrect on this proposal, however the land was totally flooded on 5th/6th December 2015.
W85. Brownfield site. On flood plain. Disregarded local knowledge when built houses in original entrance to farmyard when developing Farelton Close which meant that floodwater had nowhere to go (it used to flow through the farmyard onto the floodplain until it was able to drain into the river Keer), hence the flooding now experienced at Town End on Main Street.
W86. Greenfield site. Again on flood plain and has been under water and flood water from Main Street is channelled into this field during floods.
W87. Greenfield site. Any building here would increase flood risk to houses on Main Street which were flooded on 1st September 2015, 18th November 2015 and 5th/6th December 2015.
W88. Greenfield site. Increase flooding risk to houses on opposite side of road from where Sand Lane meets Main Street.
W89. Greenfield site. Comment as W88.
W90. Greenfield site. Westover already has issues with regard to drainage. It will ruin the outlook from the school and could also have an impact on safeguarding issues with regard to the school pupils.
W92 and W93. Greenfield site. Building on this land would increase the flooding of the river Keer due to less land available to absorb rainfall which in turn would have significant effect on flooding to houses on Gardener Road. These houses were badly damaged in floods on the weekend of 5th and 6th December 2015, with many people having to move out of their homes. There is also concern with regard to the large retaining wall of Hutton Gardens were this land to be developed.
W94. Greenfield site. Virtually on the Crag.
W95. Again increase flooding risk to river Keer as the shack that is present on the land won't have much of an impact.

As flooding risks are predicted to increase over the next few years this rules out all of these sites.

3. Evidence Base

The traffic through Carnforth is a disgrace. The new Heysham by pass will have a negligible affect on the traffic through our town. Traffic lights in front of Tesco are VERY badly programmed and are one of the worst causes of traffic. If there was a roundabout instead of traffic light the traffic would improved greatly. Building new houses across the area is going to bring our area to a complete standstill.

There is a lot of industrial areas, brownfield sites, where housing should be proritised for example near the train station in Carnforth. Also the old quarry area is perfect for housing and should be explored long before housing applications are approved to build on our greenbelt.

Looking specifically at Warton... The area is AONB. It cannot be allowed to allow housing to be built within this area.

The traffic through Carnforth is a disgrace. The new Heysham by pass will have a negligible affect on the traffic through our town. Traffic lights in front of Tesco are VERY badly programmed and are one of the worst causes of traffic. If there was a roundabout instead of traffic light the traffic would improved greatly. Building new houses across the area is going to bring our area to a complete standstill.

There is a lot of industrial areas, brownfield sites, where housing should be proritised for example near the train station in Carnforth. Also the old quarry area is perfect for housing and should be explored long before housing applications are approved to build on our greenbelt.

Looking specifically at Warton... The area is AONB. It cannot be allowed to allow housing to be built within this area.

The traffic through Carnforth is a disgrace. The new Heysham by pass will have a negligible affect on the traffic through our town. Traffic lights in front of Tesco are VERY badly programmed and are one of the worst causes of traffic. If there was a roundabout instead of traffic light the traffic would improved greatly. Building new houses across the area is going to bring our area to a complete standstill.

There is a lot of industrial areas, brownfield sites, where housing should be proritised for example near the train station in Carnforth. Also the old quarry area is perfect for housing and should be explored long before housing applications are approved to build on our greenbelt.

Looking specifically at Warton... The area is AONB. It cannot be allowed to allow housing to be built within this area.

To who it may concern,
I am writing to raise objections to the potential for house building on a number of named sites in and around the village of Warton.
In my opinion it is of local and national importance to preserve as many of the fields at the foot of Warton crag as possible. The named sites falling into that category are:

W87 Land North of Mill Lane and Town End Fold, Warton

W88 Land North West of Sand Lane 1, Warton

W89 Land North West of Sand Lane 2, Warton

In order for the population to enjoy and appreciate the beauty and significance of Warton Crag, it is necessary to maintain the farming land rising up to meet the crag. This should be designated " important open space " and should not be an area of land being proposed to build houses on.

Graham Baldwin

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Re Development Proposals for Warton
Land off Sand Lane
Site W92 and Site W93


Development on this site, in both versions, is completely inappropriate. Additional traffic on this already very busy road to Silverdale and ingress and egress to the site would be horrendous. For pedestrians walking on Sand Lane it would be even more hazardous than at present. In additional to the local people there are a number of visitors to the area who will walk down Sand Lane and out to the shore to see the birds there. If you look at the RSPB website you will realise that this is an area of international significance where up to half a million birds over-winter.

This site, together with other the sites selected for development, would mean thousands more vehicles using Sand Lane and access to Carnforth would become even more congested. The services and infrastructure needed to support a larger community are not available (schools, doctors surgery, we don’t even have a local shop, etc.). Warton would resemble a town not a small village in an Area of Outstanding Natural Beauty.

We came to live here 11 years ago. Our home was carefully chosen and we even paid far more than we could truly afford to have the privilege of living here. Our home is elevated from the field it overlooks. The wall down to field level is approximately 4.5 to 5.00 metres high and is made of stone and it is over one hundred years old (it formed the part of the wall around the old Warton Grange site and was preserved when the redevelopment took place to build Hutton Gardens and is appropriate to the character of Hutton Gardens). The development plan comes right up to this wall and it fills us with fear to think of the damage and potential to undermine the structure and foundations of this high wall and also even our property if building work were to take place in such close proximity. Because of the elevated position of house, and similarly so for the properties on either side of us, we would probably be looking directly into rooms at bedroom level from our garden. There would be no privacy whatsoever for anyone. The joy of coming to live in an AREA OF
OUTSTANDING NATURAL BEAUTY has the potential of developing into a nightmare.

Phil and Josie Barnes

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3. Evidence Base

Discussion Section: I have read the Arnside Parish Council and Arnside Parish Plan Trust response to the AONB DPD Issues and Options Consultation Discussions Paper and agree broadly with the points which they have raised, in particular with the requirement for small-scale development units in the AONB (5ha and 10 units) and strict guidelines in place to prevent piecemeal development of large sites, and also in the use of brownfield sites as an absolute priority to deliver the small amount of affordable local housing identified.

Specific sites proposed in the AONB. I support the use of small, brownfield sites and oppose the development of large sites which would go against the principle of ‘highest protection’ afforded in the AONB – would ‘cause harm to the landscape or settlement character of the AONB, or the visual amenity in a way that could not be mitigated’ (6.17).

A1 Allotments, Silverdale Road Open Space Agree
A2 Arnside Edge, Far Arnside Development No - Open Space
A3 Ashmeadow House Grounds Open Space Agree
A4 Ashmeadow Woodland Open Space Agree
A5 Crossfield House, Redhills Rd Development No
A6 Garage off Queens Drive Development Agree
A7 High Close, Knott Lane Development No
A8 Hollins Lane 1 Dev/Open Space Low density
A10 Land E of Beechwood Lane Open Space Agree
A11 Land N of Briery Bank 1 Development No – Open Space
A12 Land N of Briery Bank 2 Development No – Open Space
A13 Land adjoining Cemetery 1 Open Space Agree
A14 Land NW of Briery Bank 1 Development Agree
A15 The Common, Redhills Rd Dev/Open Space Open Space
A17 Land adjoining Cemetery 2 Development No - Open Space
A18 Land W of Saltcotes Hall 1 Development No - Open Space
A19 Land W of Saltcotes Hall 2 Development No – Open Space
A20 Memorial Playing Field Open Space Agree
A21 Arnside Knott & Heathwaite Open Space Agree
A22 Station Fields, Station Road Development Car park only
A23 Station Fields, Station Road 1 Open Space Agree
A24 Station Fields, Station Road 2 Development No
A25 Station House, Sandside Road Development Agree
A26 Station Yard, Sandside Road 1 Development No
A27 Station Yard, Sandside Road 2 Development Agree partial
A28 Telephone Exchange Development Agree
A29 Trafalgar Garage Development Agree
A30 Woodland S of Redhills Rd Open Space Agree
A97 Middlebarrow Quarry Development No
A105 Land adjacent Royd Development Agree
A106 Land W of Black Dyke Rd Development No
A107 Land NW Briery Bank 2 Development No

3. Evidence Base

Q1 Major development limits. The NPPF limit of .5ha and 10 units seems OK and should be adopted. If it’s done case by case then there is a risk that it could be challenged for a large development. It also fits with the principle of distributing the small number of affordable, local occupancy only, housing requirement around small sites to ensure minimal impact on the special character of the area. Large sites would have a significant adverse impact. The NPPF would normally take precedence over the guidance in NPPG, and in any case the NPPG seems to be suggesting that major development sites in AONB could be less than the 0.5 ha or 10 units
Exceptions might be that there should be an assumption that brownfield sites will be remediated/developed regardless of size? The old Travis Perkins site for example. There may be a very few sites larger than 0.5ha or 10 units which are genuinely brownfield or currently detract from the AONB that could be brought forward for development.

Q2 Housing requirements over the Plan Period. Yes they should be indentified. This should be done in stages only after the initial demand is fully taken up. Allowance should be made for the likelihood that the initial figure includes a significant backlog so this backlog should be factored out of future projections. A new housing survey should be done every 5 years.
The document points out in para 3.3 there is only a proven need for affordable local housing and that in a protected area it is this that should be used as the target - wider housing needs can be met in the wider areas of both authorities. However, where there are opportunities within the AONB to provide general housing on genuine brown field sites then these should be developed as a priority.

7. Delivery of Development

Q 27 Site A15 (the Common) is currently designated as Important Open Space. It is way over the site maximum size proposed and was regarded by the Inspector as having amenity value in helping preserve the open character of the village and the AONB. It has been the subject of many community attempts to protect this site from development. It should not be developed in any part and should continue to be designated as "Open Space.

5. Policy Issues

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5. Policy Issues

Q23
Infrastructure ie effluent drainage currently in Silverdale is solely by septic tanks, is this environmentally sustainable in an area of such fragile natural beauty that the AONB is supposedly to look after. Surely any major developments is likely to impact on this.
Q15
Road Access into SIlverdale is only by narrow roads all of which have pinch points and the need for passing places exacerbated in summer with increased volumes of traffic.North Lancashire rural roads are already known to have higher than average numbers of rta`s. Therefore any further development of houses, caravan sites and leisure facilities will make these matters even more of a concern.
There is no room for parking in Silverdale village centre at the moment further numbers of vehicles from development will pose further problems in this area.
As one of the main aims of AONB "is to meet the needs of the quiet enjoyment of the countryside" all these proposed developments will surely impinge on this for nature lovers, ramblers, cyclists and all those who are encouraged to come to this area to enjoy and experience the quality of the area. Again development is at odds with these policy aims which are promoted by local authoristes for the health and wellbeing of their public.

Q17 Further development of caravan sites again is at odds with the ethos of the AONB as it will further encroach into areas of natural woodland and grassland at the detriment of wildlife.

Q27
tS43 and S50. These appear to be more than 10 dwelling houses ie a major development as referred to in paras 2.17 and 2.18. These would not be appropriate in the AONB as according to national guidelines AONBs are considered to have such natural beauty it is desirable that they are conserved and enhanced, and that LA`s must take into account the purpose of conserving and enhancing the natural beauty of AONBs. Such development would surely be in breach of these principles. this also applies to site A2.

Q31
One of the criteria of AONB is that it is "area of outstanding landscape and whose distinct character and natural beauty are so precious it is in the nations interest to protect them" and they were created "because of their fragile natural beauty and the primary aim is to conserve and enhance the natural beauty of the landscape". we fail to understand how all this proposed development in this area meets this criteria, without impacting detrimentally on what it is supposed to be protecting. Even small adhoc development s can interrupt and fragment vital natural corridors/environs for all sorts of wildlife.
The AONB is currently undertaking projects to encourage endangered species (red squirrels, various butterfly species) into the area, further encroachment into the woodland and grassland will be at odds to these aims.

I wold like to comment that as lay persons my wife and I have found it very difficult to have to read all the documentation and try to respond coherently. A lot of the language used is hardly encouraging for the general public to respond and engag.e in this consultation process

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1. Introduction

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2. Background

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3. Evidence Base

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4. Vision and Objectives

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5. Policy Issues

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6. Options for Meeting the Objectives and Delivering the Vision

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6. Options for Meeting the Objectives and Delivering the Vision

Comments relate to Question 27, sites B73, B74, B75 & B76,

Any development on these sites would severly impinge on the AONB's special qualities, especially on the flora & fauna.

The sites are not appropriate for development for the following reasons:-

The surrounding access roads are single track, already challenging & have significant additional traffic in the summer months from the local caravan parks.
There are no street lighting or pavements.
There are no mains sewage or drainage systems.
There is no public transport.
There are no local services in Slackhead other than a post box.

6. Options for Meeting the Objectives and Delivering the Vision

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6. Options for Meeting the Objectives and Delivering the Vision

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Site ref. S56 - Land south of Whinney Fold, Silverdale.
We would like to express our strong opposition to any development at the above greenfield site on the basis of:-
1. Serious sewerage and drainage problems.
The recent heavy rainfall has again highlighted the drainage problem on this site (and indeed on adjacent site S58) there being knee-high standing water in places. There is no main drainage system in Silverdale and properties rely on
septic tanks, trusting that these work satisfactorily and efficiently - sadly not always the case! Indeed, we understand that recently a quantity of sewage from a septic tank in the Shore Road area (Whinney Fold is off Shore Road) found its way into the main floodwater drains and flowed onto the shore. To build houses on this site (which lies in a hollow below the 20 metres contour) plus proposed adjacent development sites to the south (site S58 etc.) with the major problem of having to deal with significant amounts of grey water and rainwater could create a "perfect storm" and be liable to result in a corridor of mayhem along the western side of Lindeth Road.
2.Major access and traffic issues
The access road to the existing Whinney Fold development is very narrow with residents and visitors cars frequently parked. Any further housing development on the site on the scale being being proposed would make traffic conditions very problematic. Exiting Whinney Fold is difficult with site lines to the left very poor onto Shore Road which can be very busy with traffic leaving the shore.
3.Greenfield Site
There are brownfield sites in Silverdale and these should be built on before any greenfield sites are considered. Greenfield sites should only be used as a last resort. To build on this beautiful green haven would be an environmental disaster of the highest order. Once it's gone it's gone forever! The AONB needs to be protected not scared.

Roy and Sylvia Davies

3. Evidence Base

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6. Options for Meeting the Objectives and Delivering the Vision

SITE B31
this proposal would double the size of the caravan site - Slackhead a short distance to the north is already massively busy when the 4 large caravan caravan sites to the south are fully utilised - the area cannot withstand yet more strain on its infrastructure
SITE B73
this area is a nationally designated toxic waste dump with steel upstands dotted around the site that vent toxic gases - a more ridiculous place for housing development is hard to credit - regardless a development on this scale will do nothing for the local ambience that visitors seek in the wooded area around the site - the road system is inadequate to serve more housing development
SITE B74
the road past the site is inadequate to serve more housing development - there are no sewer services to the site - the junction at Slackhead and the and the bridge over the Leighton Beck are pinch points that are getting increasingly busy
SITE B75
this area is common land and should not be presented for housing development by presumably the local estate who have 'manorial rights' to it I believe - there are no sewer systems and it is located at a busy intersection of small roads - if anything it should be developed as car park (free) for vacationers / walkers wishing to access the 'Fairy Steps' - there is presently nowhere for people to park other than on the verge of Leighton Beck Rd., which due to the volume of traffic on this narrow country road is an unsafe option
SITE B76
this area is massive in relation to the existing housing developed in the 60's - it has no safe road access, no mains sewerage, is partly on designated limestone pavement and has been thoroughly objected to by signed petition by local residents which was placed on the SLDC website less than 2 years ago - it is totally unsuited for housing development on a number of grounds
SITE 109
this is a large development relative to what presently exists in a village that has no services - the road system is already challenged and has had traffic calming measures applied not with total success

the various large caravan sites and the impact they have on the local infrastructure should not be ignored - the no.s of people they bring to the area already stresses the roads (pollution / noise / danger to walkers / cyclists) heavily to varying levels trough the year - more houses won't improve the situation

the AONB is somewhere for people to relax and unwind in and needs to be carefully protected and watched over otherwise it will cease to serve the purpose it has been designated for - as the UK gets ever more crowded and busy we should be very mindful of the danger of development that will degrade the area - the AONB should resist any opportunist attempts to develop it in inappropriate directions
one only has to look at what an unpleasant mess has been made of the area around the motorway jnc36 to see what can happen to unspoilt ground when development is not very carefully contained in this very special part of the world

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Dear Sir,
As the owners of the plot referenced S43, Elmslack Field, Cove Road, Silverdale we have recently become aware of its inclusion in your development plan. We had seen the 2014 document and no mention of our land was made.
We request that you withdraw our land from your list of potential development sites as we have no wish to either sell it for development or develop it ourselves at the present time.
Please could you let us know when you have received this e-mail and if our request is possible?

Kind regards,
Neil & Michelle Entwistle

5. Policy Issues

5.31 Biodiversity and Geodiversity
Q22: How should the AONB DPD protect or enhance the biodiversity and
geodiversity of the AONB?

Protection can only come from an in depth comprehensive knowledge base. Beyond the statuary sites there are a number of species rich areas that are rapidly diminishing in number. The ones that remain have no protection but are currently vital links between SSSI's or have the potential to be,they should all be mapped and their protection will enhance the AONB's resilience to habitat and species loss and potential change from global warming. There are at least 14 proposed development sites which if carried forward will destroy biodiversity and/or break important linking wildlife corridors.From an initial appraisal of the maps A2;A7;A97;B31;B33;B40;B73;B74;B76;;B114;B116;S44;S52 and S98 fall into that category
and there may be more.

I write concerning the Development Plan document with regard to B.32. I assume that access to this area would be via Mill Lane. Some 20 plus years ago when the Parsonage Fold development was Carried out access to this was via Mill Lane and under the Third Schedule of our deeds the residents are required to pay on demand one twelfth of liability to pay for the maintenance and repair of Mill Lane. At that time use was limited to the twelve residents and very occasional use by Farmers and access to filter beds at the end of the lane. Use was massively increased when the Heron Corn Mill was developed by a large Heritage Lottery Grant though in a letter of 9-6-14 theHeritage Lottery fund confirm that access via Mill Lane was not known to be a Public Bridelway and maintenance arrangements were also not known. The level of this increase was such that up to 300 cars a day have been recorded together with coaches and delivery wagons. At present a proposed car park would give further wear and tear and access to development of B32 would be a totally unacceptable liability to us. These additional uses have also given very real and frequent concerns regarding the safety of pedestrians children and animals who use this Public Bridelway,matters raised with our M.P. And Beetham Parish Council and continue to this day. A further concern,should B32 be developed is that the pastoral scene from our home would be severely compromised.For the above reasons I would not support change of use of this area of land. Dr.Peter Fielden.

6. Options for Meeting the Objectives and Delivering the Vision

Affordable Homes - I note that there is an estimate of the number of homes required in the five years to 2019. I think that there should be some attempt to gauge when these homes would be required, I am concerned that once given the "green light" sites will be developed as per the "Whinney Fold" development in Silverdale. When this site was finished there were too few local people in a position to proceed with occupancy at the time of completion and the homes were offered in the Manchester area in order to fill some of the properties. Any building should be phased so that they actually benefit local people.

Employment and small scale industrial sites - again where is the evidence of companies wishing to locate to or expand within the AONB - I am very concerned that this document has been produced using some ration or percentage figures produced by central government, rather than local evidence.

The sites put forward for inclusion in the draft plan do not reflect the sensitivity of the local area - many will include large tracts of tree felling, many are in open countryside. With regard to more homes - the existing infrastructure is very limited. we have a CO-OP and butchers but these do not cater for one's entire weekly needs, so trips to Carnforth and further afield have to be made on a weekly basis. All the roads in and out of Silverdale are difficult making the area unsuitable for more employment sites - even small scale businesses rely on deliveries by large trucks, the village is often congested now with deliveries to local businesses.

Car transport is the main mode of transport as the buses are infrequent and the railway station is too far from the village - we do currently have the subsidised shuttle bus - but this is still expensive for those not eligible for a bus pass also if funding is withdrawn the station will become totally in accessible for many people.

6. Options for Meeting the Objectives and Delivering the Vision

S48 - East of Lindeth Close - this would be visually intrusive and require significant tree felling.

S50 - East of St Johns - This site should not be included as more houses on this site will erode an important open space and be intrusive and insensitive to the surrounding area.

S51 - This site would lend itself to no more than a couple of dwellings - any more would be too intrusive and require encroachment into the woods at the back.

S54 - This land should not be considered as the area is prone to flooding at the lower end and the access onto Cove Rd is very dangerous to both motorists and pedestrians. The narrow road is also the main route to Holgate's caravan site used by regular convoys of cars and caravans as well as delivery wagons and tractors and trailers going to and from the caravan site. This suggested allocation is between the two fields owned by the National Trust and any development here would destroy the uninterrupted flow of the landscape and adversely affect the setting of the ancient Farmstead at Bank House farm.

S52 - Hawes Villa - This area is unsuitable for any development due to the terrible access over the railway and at the junction at the top of the road.

S55, S57, S98 are all unsuitable for either homes or employment use - visually any developments would be detrimental and there are access issues.

I am concerned that the evidence included in this local plan has been largely based on overall national forecasts and trends and does not reflect the actual need at local level.

Silverdale has been a place of beauty and relaxation for many years, a place where people can escape from busy lives in towns and cities. ( caravan sites, RSPB, Leeds Children's holiday camp + day visitors throughout the year who enjoy the walks and trails in the area). We need to build on this and avoid the danger of becoming yet another mini town trying to be "all things to all men".

We need more up to date consultation with local people to determine who needs what and when.

Unfortunately affordable starter homes are not suitable for expanding young families - young couples are often forced to move on after the birth of their second child and consequently are back to square one being priced out of the market.

Similarly it is important for older residents to be able to move to a smaller property with in the area in order to be able to maintain existing social networks which are so important as people age.

We need to:

Be creative in how needs are met such as shared ownership of larger properties, conversion of single dwellings to flats or semis.

Look at learn from and explore successful projects in other areas such as shared ownership, self build eco homes etc.

Silverdale is a very special place so let's take the opportunity to make sure all needs are met in innovative ways that are not detrimental to the natural beauty of this area.

I have tried to make sense of the various documents and the questions posed but without many hours to cross reference them all I will make the following comments.
Where there is a need for small scale housing development it should be limited to brown field sites. Large detached houses are plentiful in this area. Instead there is a need for houses under £300k that younger people and families can afford.
I would like to see some of the large houses divided into more sustainable and affordable properties.
Most new housing should be provided in urban centres where jobs and facilities are more readily accessible.
Lancashire County Council are proposing to cut all subsidised bus routes.
This will mean that Silverdale, the Yealands, Warton and Millhead residents who can afford private cars and are able to drive making far more car journeys than at present. It will leave everyone else stranded.
The car park at Silverdale station is too small to cope with demand so many train users will choose to drive to Carnforth.
Many tourists come into the area by public transport. They will either go elsewhere, to the detriment of local jobs, or drive in causing more problems on the roads and making cycling and walking even more dangerous than at present.
This goes against all the policies promoted by the AONB, Lancaster City Council and Lancashire County Council.
The recent flooding issues have highlighted the need for planners to resist planning permissions in areas where water levels and flooding are constant problems.
Many of the proposed sites come into this category. Most of the green field sites would have a serious and detrimental visual impact on the AONB.
Best wishes
Sarah

5. Policy Issues

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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

6. Options for Meeting the Objectives and Delivering the Vision

Development on the site A12 would take away a spectacular view from the many users of Briery Bank, both local and visiting. The Summary Sheet refers the harm to a visual ammenity, this is surely one. Whatever the conversation or thoughts folk are having as they walk or drive along this road the impact of this window across to the estuary and the fells miles away draws their attention. The AONB needs people to think about landscape and dramatic viewpoints help achieve this.

"The AONB is characterised by … spectacular views; …" It would be a shame to permanently lose the views in both directions across A12.
As you come from Milnthorpe the view of Arnside alongside the estuary is of the hill and fields mixed with housing and is really lovely.
The view from Briery Bank across the estuary is beautiful. In fine weather I often see people pause to enjoy it as they pass.
To fill in the fields along the northern edge of Arnside with housing would change the character of Arnside and several of the proposals - including A12 - would be major developments.
I object to the proposal to build on A12.

6. Options for Meeting the Objectives and Delivering the Vision

Question 27: Anyone who considers that sites W84 (Land Between 14 and 48 Main Street, Warton) and W86 (Land East of Mill Lane, Warton) are appropriate in terms of flood risk and drainage should visit them in their present condition (20th November) after the rains on Wednesday (18th November). Several houses in the 1 Farleton Close to 8 Main Street block have suffered flooding twice already this year. I would also suggest that as rainfall is likely to increase in the future as a result of climate change the appropriateness of site W85 must also be called into question for the same reason.

5. Policy Issues

I am a local resident who is concerned about the development of the area as a whole. I understand that you wish to consult but am afraid that I have insufficient knowledge of national planning policies etc to attach my comments to specific areas1-7 but hope that you will take the issues I wish to raise into account and put them under the appropriate headings.
I am very pleased that the 2 district councils have worked together on this but the lack of involvement of the county councils means that a number of the issues raised particularly under issue 5 - policy issues are not included
-transport -
1.there will be NO bus after the 31st March which affects both housing and employment
2.Have the railways been consulted? There are recent issues about pedestrian track crossing which will cause problems at Silverdale station
Excess water 5.32
The removal of many trees and concreting of areas means a considerable amount of surface water. The County Council have had to renew some drainage but with limited effect. There is low lying water particularly near the Silverdale graveyard. Some of the suggestions as to small housing developments will remove yet more trees and further affect the water table. I would like to see this issue addressed in every planning application.

Septic Tanks
Building over soak-aways effects the ability of septic tanks to function and can lead to problems of fully disposing of effluent

Roads
The roads are narrow and currently we have problems in vehicles passing each other - particularly caravans and drivers who are not used to country roads. Increasing traffic will cause problems in some areas

Housing
Recent developments have been for 4 bedroom houses. We need smaller and cheaper housing which will enable local young people to stay here and encourage others to come. WE need developments a group of affordable homes rather than just a small percentage of larger developments.- the suggestion of small exception sites seems a good one as long as it doesn't conflict with the water issues- 5.10/11

[SEE ATTACHED DOCUMENT]

We have attended the AONB DPD Consultation Event and considered the Issues and Options Discussions Paper, site suggestion maps and draft Sustainability Appraisal Scoping Report. Please acknowledge receipt of this email.

We wish to make the following comments on Meeting Housing Needs in the Warton Village Area concerning 'Sites being assessed for development'.

1 Flooding concerns: Sites being assessed for development: W84, W85, W86 and W90 are currently underwater and cannot be considered suitable for development. Other sites beneath Warton Crag, W87, W88, W89 & W95, are steeply sloping sites which carry much water from the upland. If covered with concrete and tarmac this would result in more flooding within the village. Currently (9 Dec 2015) a large lake has crept over adjacent low-lying properties in the village.

2 Visual impact on the AONB: Elevated sites above the general level of the village will visually affect the AONB. There will be a visual impact on the Scheduled Ancient Monument of Warton Crag.

3 Infrastructure: Traffic increase in the Sand Lane/Main Street junction will be problematic in an area which is already congested. This junction is full of large holes where an underground spring adds to surface degradation in wet weather. The footpaths between school and Sand Lane, and Sand Lane and Carnforth are inadequate for families with children and pushchairs.

4 Government Policy: George Osborne stated in Parliament that there would be no building in AONBs. Why is this being considered? Green Belt building is to be considered for affordable housing. We understand that there is considerable reluctance on the part of developers in the area to build affordable housing on Green belt as they cannot make any profit. Nor do they want to pay for the infrastructure required.

5 A Local Plan for Lancaster District (Oct 2015): This states that there will be no alteration to Green belt boundaries 'unless there are exceptional circumstances' and no exceptional case has been put forward.

6 Housing Need: Warton Parish Council suggested, at a recent meeting, that the housing needs of Warton are already being met by planning applications which are currently in hand. So is there a real need for additional houses, and where would the occupants work?

Carol Allen and John Glaister

7. Delivery of Development

[SEE ATTACHED DOCUMENT]

[SEE ATTACHED DOCUMENT]

7. Delivery of Development

[SEE ATTACHED DOCUMENT]

[SEE ATTACHED DOCUMENT]

6. Options for Meeting the Objectives and Delivering the Vision

[SEE ATTACHED DOCUMENT]

Having attended the recent AONB DPD Consultation Event and given it some consideration we would like too make the following points:

We are opposed to significant development in and around Silverdale and in our view any new housing development in Silverdale should take into account the following:
Silverdale is an AONB:
Areas of Outstanding Natural Beauty are particularly special landscapes whose distinctive character and natural beauty are so outstanding that it is in the nation's interest to safeguard them.
Building development in an AONB seems a contradiction.
We need to retain our greenbelt not build on it.
Lack of infrastructure. Traffic congestion is already problematic because of too many campsites and would only increase: there are few pavements making it dangerous for walkers and cyclists. ?
Issues about water and drainage need to be taken into account, especially in low lying areas re water table and septic tanks: The whole of the village is on septic tanks
Only affordable housing needs to be considered instead of more luxury homes. Sites near Lancaster/Morecambe and Kendal could be developed, nearer to major employers in the area.
There is currently a range of properties of all types and values on the market. ?Property is slow to sell anyway and it would make it even more difficult, especially in areas affected by development .
Too much development and one would feel one was no longer in a rural village. ? Loss of green space to development would change the character of Silverdale and surrounding areas. The land adjacent to Silverdale village is of a very high conservation value for rare wildlife and needs protection. ?
Please keep in mind that Silverdale is an AONB and we would like it to remain so.

[SEE ATTACHED DOCUMENT]

1. Introduction

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.

I have commented on most of the questions which I have numbered throughout.
I hope the response is intelligible.

6. Options for Meeting the Objectives and Delivering the Vision

[SEE ATTACHED DOCUMENT]

1. Introduction

A7 High Close, Knott Lane, Arnside

We would be concerned over the density of any proposed development on this site. Knott Lane itself is narrow and has no pavement. This currently makes it difficult for both motorists and pedestrians and any significant increase to the local population would only worsen this situation. Knott Lane is the only vehicular route from the village to the National Trust car park on Arnside Knott and is used throughout the day and throughout the year. It is also a heavily used walking route by both locals and visitors. Any significant increase in traffic on this lane could lead to potential accidents.

To whom it may concern

We are very worried about the proposed housing developments in Warton. Already the traffic is a dreadful problem and the building of new homes would make it so much worse. Cars speed down the village with no regard to other vehicles coming the other way and with so many children using the main street to get to school, clubs, church, etc. it is an accident waiting to happen.

To build more houses would make the problem so much worse and would increase the size of our village massively. It would take away our rural life as a small village and eventually be just part of Carnforth.

We have lived in this village for 45 years and have seen many changes, so please don't make any more and change our lovely rural village and rural life for ever.

[SEE ATTACHED DOCUMENT]

I am writing to express my dismay at the proposed plans to build a substantial number of new homes on green field sites in Warton. I, along, with the vast majority in the village, are against such plans. Not only will it destroy the environment, it will also change irrevocably rural life in the village. I am told 'consultations' are underway for a massive increase in the number of new properties. Usually such consultations are nothing more than a sop to local people, whose views are rarely taken into consideration. Any new builds will change for the worst the look and feel of the area.

Joel Hockey

[SEE ATTACHED DOCUMENT]

2. Background

Question 1. Major development as defined in the blue box on page 12 of the Discussion Paper should not be exceeded in any new definition of major development within the ANOB should this be defined on a cases by case basis.

3. Evidence Base

Action needs to be taken so affordable housing built as affordable housing remains affordable and is restricted to people having lived in the ANOB for at least 5 years in the last 15 years who have grown up in the area or with family associations here. Affordability needs to be defined as at least a minimum percentage below the market value for the property and action taken to prevent such housing being sold on at prices above this level and to people without the above minimum connections to the area. Otherwise any affordable housing will not remain affordable and thus any need for affordable housing within the ANOB will never be met.

Question 2. There is a strong need to link proposed development to local needs to prevent a land grab by developers, based only on their own financial interest. I do not dispute a need for affordable housing, but there does not appear to be a need for more expensive properties. A search on rightmove.co.uk alone on the 29/11/15 identified 258 properties for sale within a 3 mile radius of Arnside.

It is unclear how the need for 72 affordable homes with the ANOB by 2020 was identified. Surveying local residents on this and infrastructure needs would be a good starting point in identifying local needs.

4. Vision and Objectives

Question 4. I think the ANOB vision is about right, although development need to be kept to the minimum necessary to protect the ANOB.

Question 5. I think the objectives are about right.

5. Policy Issues

Question 6. The use of non-affordable houses to subsidise affordable houses at a rate of 35 to 40% of new homes on a site being affordable ones allows too much construction in the ANOB. The percentage of affordable homes needs to be increased to at least 50% and if necessary some district council funds be put to the cost of these homes.
Council taxes on second homes in the ANOB could be increased and the funds generated put towards construction of affordable homes in the area, thus lifting the percentage of affordable homes in new developments.

Question 7 – Yes where possible.

Question 8 – Yes within reason. Building some affordable house with facilities for the elderly or infirm is clearly needed, but will increase development costs. Therefore it would be sensible to put these measures into an appropriate percentage of affordable homes, but perhaps not all, to enable the percentage of affordable homes in developments to be increased.

Question 9 – Yes, but this needs to be controlled to prevent spoiling the scenery within the ANOB.

Question 10 (brownfield land). Yes use of brownfield land should be prioritised. I understand some of the proposed sites are contaminated land ie Trafalgar Garage Arnside, Station Yard Arnside and possibly the Travis Perkins site in Sandside which is old railway sidings. There would be benefit id developing these sites to ensure any contamination issues are addressed. Other brown field sites are not particularly attractive eg Arnside telephone exchange or quarry lane depot Sandside. Development of the old boat-yard site in Arnside would also be beneficial either to restore or replace the old boatyard building which is progressively decaying.

Question 12. Arnside needs a car park near station. Using the station yard appears sensible with on-road parking by the station restricted to drop-off / pick-ups and disabled parking. There is a need for development that would create more local job opportunities in the area.

Question 13 (locations for employment) Sandside Travis Perkins site and Quarry Depot, Quarry at Silverdale, Wilacy’s at Sandside.

Question 14 (energy). Solar on roofs is an obvious win. Large-scale wind would not be appropriate, but smaller scale systems that can put on buildings without causing structural damage could be a way forward. Many woodland areas within the ANOB could be coppiced to provide wood pellets for biomass boilers providing some jobs and better managing some of our woodlands. Clearly larger sites using the woodchip boilers such as schools or care homes would be helpful to enable more efficient boilers to be used thus protecting air quality. A scheme allowing landowners to long-term rent pieces of grazing land to adjacent houses for installation of borehole based ground-source heat pumps may be worth investigation.
Question 16. I agree parking near Arnside station is needed. Station yard is an obvious location for this, with on-road parking by the station restricted to drop-offs/ pickups and disabled parking.
Introducing a small parking charge for non-residents parking on Arnside Prommenade (50p for 2 hours and £1 for up to 12 hour or £2 for 24 hours) could generate significant income for Arnside Parish Council each year.

Question 17. I agree new and extended caravan sites need to be controlled, but they also generate income and jobs. I think new areas can within limits be allowed, but should be screened by surrounding trees and with the areas planted with trees to minimise visual impact.

Question 18. I would add:
• Is the space important for soaking up rainfall and runoff water in the local area or helping to avoid flooding issues.
• Would development of the space significantly negatively impact parking issues in the local area.

Question 20 (new open spaces)
• The common on Redhills Road Arnside. This is the only green space along most of Redhills Road or adjoining the Inglemere estate. It also runs alongside a flat right of way that is used my many people, particularly elderly people who can no longer make it up the knott. Therefore it is an important green space in this part of the village. Development of this site would most likely cause problems with a row of parked cars along this part of Redhills which would be difficult to pass and potentially hinder traffic from and to the Inglemere estate.

• Station field similarly provides an important green space as people enter Arnside without which this part of Arnside would feel very built up. It also contains historic salt plans which could be better presented and which United Utilities had to take great care not to damage when undertaking significant work in Arnside. Judging by how often this land floods it probably also protects the road to the station from flooding during heavy rain.

• Yet again the fields adjoining Briery Bank in Arnide provide important private green space in this part of Arnside. It is also important this hill be kept clear of parked vehicles due to the bends on it and particularly to avoid accidents in icy weather. Development at the top of Briery Bank is already causing problems with parked vehicles even on a bend which is not policed. Development of the land adjoining Briery Bank is highly likey to cause problems on the hill itself.


Question 22 (biodiversity) – Yes.

Question 23. There are lots of implications. However, in new developments we need to move beyond simply discharging all surface runoff into sewers. If operated correctly non-mains sewage could be seen as an opportunity to generate renewable power via anaerobic digestion in areas where mains sewage and treatment is not possible. This could also provide opportunities for local farms to produce crops for co-digestion with the sewage. We need to look at sewage as a resource for generating renewable energy through community projects rather that a waste problem. Similarly could you look at development based run-off water collection with the aim of toilets only using this water.

Question 24 – Yes.

Question 25 Yes.

6. Options for Meeting the Objectives and Delivering the Vision

Question 26. I prefer option 6, but avoiding allocation in open countryside unless absolutely necessary. Focusing development in primary settlements only results in turning these into progressively more urban environments losing their character as villages and prioritising the interests of smaller settlements over the majority who live in larger settlements. Instead smaller settlements could be helped to keep their services such as schools, shops, pubs and public transport by offering them appropriate supporting developments. This would enable new more sustainable villages to be grown while keeping larger villages as villages within the ABOB rather than converting them into towns.

Question 27. I have already made these comments in answer to other questions. However, the number of sites identified for development is completely disproportionate to local development needs and just looks like as many people as possible trying to make large profits by selling agricultural land for development with little or no thought about if this will benefit local communities.

Question 28. The list of criteria for sites needs information that only the owner will have access to. Therefore there needs to be a facility for people to suggest sites which the ANOB then contact site owners about to determine their interest and complete your form.

Question 29. Yes. Arnside, Silverdale, Beetham, Warton.

7. Delivery of Development

Question 30. Phase in 5 year periods.

Question 31 (other issues).
• The consultation has been undertaken very poorly and has failed to consult many people in Arnside:
o Only 1 every few houses in Arnside received postcards notifying them of the consultation. I know many people near me who did not receive these notifications.
o The consultation event at 2-7pm on a weekday was held at a time when the majority of working people in Arnside will be unable to attend.
o The consultation documents were only available in the village at the ANOB office apart from on 1 afternoon. The ANOB office is closed on weekends and only open 9-4pm on weekdays. Therefore once again making it virtually impossible for those working outside the village to see the documents.

• The plans designate virtually all green space in Arnside for building, which is unnecessary and will destroy the character of the village in addition to failing to meet the objectives of the ANOB.

• There are limited numbers of jobs in the local area. There is no point building large numbers of houses without appropriate job creation.

[SEE ATTACHED DOCUMENT]

6. Options for Meeting the Objectives and Delivering the Vision

Section 6 question 27 asks “have you any comments on any of the sites put forward?” In response to this I would like to OBJECT to development on site A15 – the common and support this site, A15, to be designated as Important Open Space. This site was designated as Important Open Space and is mentioned as part of the significant character of the AONB in the Landscape Character Assessment Document for the Area. There is no good reason to further erode the character of the AONB by building on this site. Arnside cannot meet the entire housing need of SLDC (often described as “local need”) however much people want to live here and however much the developers stand to make. At some point the endless expansion within the AONB, justified on the back of previous waves of expansion must be stopped and this site, A15, being one of the last flat meadowlands left must not be lost to development or the whole concept of the ANOB designation starts to become meaningless. Access along Redhills Rd to this site is poor with a single narrow pavement and the junction of Silverdale Road (a bus route) and Redhills Road is already subject to serious congestion at certain times of day, particularly when deliveries are being made to Avery’s convenience store. The doctor’s surgery and dentists are located close to this junction and it is a route regularly used by children to school. Congestion at this point is a serious safety concern and additional vehicles from any development of site A15 would exacerbate the existing congestion problem and increase the risks of accidents. A15 should be designated as Important Open Space as I was in a previous local plan.
As for sites A11, A12, A14, A22, A23, A24 et al., what a mess! The Map Book is incredibly poorly organised with regard to these sites, which whilst being contiguous and/or overlapping on the ground, they are not even on consecutive pages in the document. It makes one wonder if you could have done any more to confuse and put people off responding. This whole hill side which is again a characteristic open space for the AONB is visible on entry to the village and from a wide of locations in and around the village. I OBJECT to development in this area and support these sites as being designated as Important Open Spaces. These meadows are characteristic of the AONB and must be protected to prevent Arnside just becoming a single housing estate and losing the important character for which it was designated as an area of outstanding natural beauty. Both of the two main routes into the village pass by this area and more development in this area would lead to further congestion. Arnside is geographically out on a limb and has only limited access and limited local services (doctor, dentist, school, buses, etc) which are already stretched. Any expansion of more than a very small scale is unsustainable and these areas (A11, A12, A14, A22, A23, A24 et al.), collectively or individually represent a significant expansion that must not be allowed. Given their prominent position, particularly noticeable on entry to the village and their significant contribution to the character of the area these sites should be designated as Important Open Space.

The whole process is difficult for a lay-person to comprehend and access and seems designed to be as obtuse as possible

2. Background

Background –
Q1. I think that this should be reviewed on a case by case basis as definition set out in section 2.18 could have a dramatic effect on a small village. If a guideline is to be considered I would suggest that this is proportionate to whether the location is a primary or secondary settlement. (Options could include 10 and 5)
Evidence Base
Q2/3. Yes the council should identify housing requirements over the plan period. Consideration should be given to a number of factors:
• Response rates to survey if this is high or low it should give an indication to the materiality of the issue in each location
• A review of sales of houses in various price brackets to understand whether additional housing would solve the need or whether market forces can address the situation
• A review of time taken to sell houses for the above reason
• A calculation should be made whether a development will address a need or whether the primary intent is to profit from open market housing

3. Evidence Base

Evidence Base
Q2/3. Yes the council should identify housing requirements over the plan period. Consideration should be given to a number of factors:
• Response rates to survey if this is high or low it should give an indication to the materiality of the issue in each location
• A review of sales of houses in various price brackets to understand whether additional housing would solve the need or whether market forces can address the situation
• A review of time taken to sell houses for the above reason
• A calculation should be made whether a development will address a need or whether the primary intent is to profit from open market housing

4. Vision and Objectives

Vision and Objectives
Q4. I agree with the vision would consider adding:
• Preserves residents connectedness with the landscape character around them enhancing their well-being

5. Policy Issues

Policy Issues
Q6. The AONB is defined as one of the highest level of greenfield sites and should be protected. Additional building should therefore be considered when there is a specific need. On this basis a higher threshold should be set for the proportion of affordable housing which should include a local connection restriction. On the premise that developments should be small it may be worth exploring options that include locals part building their homes or to consider how access can be gained to the new tools that are being launched to encourage self-build nationally. This option can be done on small scale.
Q8. Given the established need for rental accommodation the council ought to either consider building council houses that do not have a right to buy or to set a maximum rental that can be charged linked to CPI.
• Consideration should be given to building of bungalows which would have a lesser impact on the landscape and protect the setting of and views out from and into the AONB
Q9. Options could include allowing temporary building status for workers that have employment on the land which could follow high eco credentials. There are examples such as where there are semi-permanent traditional forestry roles such as charcoal burning etc
Q10. Yes brownfield sites should be prioritised, work should be undertaken within communities to establish sufficiency. E.g. the pub at Yealand Conyers could be converted into flats with an allocation for local residents at a capped rate.
Q11. Yes in the main new developments should be limited to settlement areas unless there is a significant local need identifies elsewhere. From a density perspective consideration should be given to fewer houses per hectare to ensure that any larger developments are not out of kilter with the current housing landscape.
Q13. Barns, outhouses and public houses should all be considered for development. Incorporation of live work options should be considered. Similarly allocated space for communities to develop co-operative community led ventures should be encourage e.g. stores
Q14. Care needs to be considered in striking the balance between environmentally sustainable technology vrs the visual impact of using these. Where B4rns high speed broadband is in a village all new builds should be obliged to ensure that a connection is fitted
Q17. There is a significant number of caravan sites in the AONB further developments should not be permitted. The traffic created by visitors driving to sites and caravans being moved to sites is already causing significant issues in the surrounding villages.
Q18. The key elements for assessment of private open space have been identified. There should be great identification of open space looking from all the Yealands down towards the A6 as this is a key vista both into and out of the villages. In the area surrounding Yealand Storrs and Yealand Redmayne it is also a significant flight path for birds that move between White Moss and Cringlebarrow wood.
Q23. Consideration needs to be given to siting developments where there is easy access to drainage and sewerage systems and to whether additional pressure on these can be supported.
Q25. The design and materials should be used in a way that allows housing to blend into the environment. Consideration should also be given to the lighting impact of building extends beyond the boundaries of existing street lighting. In addition strict height restrictions should be put in place to minimise the impact on the environment. Use of renewable energy should be mandated.

6. Options for Meeting the Objectives and Delivering the Vision

Options for Meeting the objectives
Q26. I would recommend option 3 as there should be sufficient opportunity to satisfy local housing requirements within this criteria. The location of these sites are spread well across the AONB allowing people to live close to their preferred areas without causing any significant transport issues. It could be worth considering allowing a small amount of conversion / building on brownfield sites only in secondary settlements.
Q27. All the sites identified in Yealand Redmayne are based on converting fields / gardens into additional housing. I fundamentally disagree with this approach to building in a secondary site. All options will have a detrimental impact on the landscape by changing the fringing of the village at the Yealand Redmayne / Storrs end of the village and probably adding further light pollution. In addition there is no access to sewerage systems. I believe the policy should be to look at options on any brownfield sites to address what appears to be a very small housing need requirement.
Q28. The 1st premises should be that no additional building is required however conversion of the pub in Yealand could be done on a basis of mixed use encoraging live/work options for local people.
Q29. Yes boundaries should be set. This will ensure that people have greater clarity of the future impact of building in line with the duration of the development plan. This should protect the landscape and the historical context of villages. This should be applied for all primary and secondary settlements in the AONB

[SEE ATTACHED DOCUMENT]

[SEE ATTACHED DOCUMENT]

This is an addendum to our earlier response.

With regard to sites A13 and A17.

These sites surround the Arnside Cemetery. It has long been hoped that when the cemetery is full it could extend slightly into either the northern half of A17 or into part of A13. Both sites are woodland at the moment, part of the Hagg Wood Forestry Commission plantation, leased from Dallam, which is a mixture of ancient woodland and old conifer plantation. The conifers were cleared around 15 years ago. Ideally it most of it would be left as prime wildlife habitat but it would be good if its final designation could make sure that a small part of it could be joined to the present cemetery at some time in the future.

The woodland in A17 to the south of the cemetery is very rocky and could not be used for burials. It also adjoins the open fields and should not be built on. That to the north, between the cemetery and the houses has a much deeper soil level and is suitable for burials as is A13.

Best wishes

Ann and Ken Kitchen

[SEE ATTACHED DOCUMENT]

5. Policy Issues

Q6. The only houses which should be built within the AONB are those identified as Affordable houses. These should be subsidised by allowing development on brownfield sites on the edge of the AONB boundary. In an AONB greenfield sites should not be used.
Planners should look at converting large houses into flats/apartments - as there have been a few big properties on the market - for long periods of time
Planners should not allow Market Value Housing to be built on plots of land in a Village, where a need for Affordable has already been identified.
Q7. Yes Affordable Housing should be offered to locals.
Q14. There should be some restrictions on putting solar panel on residential houses in AONBs. Guidelines are needed. Aesthetically they can spoil buildings. Would it not make more sense for those who want to invest in solar, to buy into panels on industrial units elsewhere. They could then get a reduction on their electric bill, in much the same way as they do now.
Q15.The AONB should encourage Highways to get rid of excess signage. All Villages should be 20mph from entering to exiting the Village boundary- so we can get rid of all other mph signage.
Q17. Extending Caravan Sites in the area would not be wise as this impacts enormously on local roads - already at full capacity in the summer season.
Q23.Building more houses in Villages without mains sewerage is asking for trouble. There is already spillage of sewerage in certain places eg. Silverdale Shore.
Houses are built too close together so that the soak- aways do not work properly. All adds to sewerage problems.

In an AONB all decisions made should protect the designation. Otherwise it makes a nonsense of designating.
Consequently building on greenfield sites should be a No No.
We can not make more land. Once it is gone - it is gone forever!
We also need to accept that Village life is different to Town life. We should not try and make one like the other - that's what makes both special.


Thank you for the opportunity to comment.

6. Options for Meeting the Objectives and Delivering the Vision

Q27. Do Planner check all new sites - physically - before putting these sites onto consultation maps?
I ask this, because there are sites on the Silverdale plan which are totally inappropriate for building - one I believe carries SSSI status!
Putting sites like this on initial maps, just alienates people.
Q28. Why does the Council not put pressure on the Government to find different types of Affordable Housing - ie. converting large houses into flats/apartments. Especially as these properties are sometimes difficult to sell.
Again builders could be given incentives to do these conversions ie.Market Value buildings on brownfield sites outside the AONB.

Thank you for the opportunity to comment.

Regards future planning in Warton.
Once again plans are been asked to be considered for Warton for green field sites which would spoil Warton as a quite tranquil village. The main roads are getting congested, the wild life (herons, hedgehogs, peregrines, owls etc) will all be affected. Their is enough brown field sites in and around Warton suitable enough for building on and if you look on Rightmove their seems to be an abundance of suitable housing on offer! Property developers and land owners are just out to make money and are not bothered who and what is affected, they will not bother as long as they make money. We therefore object to anymore plans for building on green field sites in Warton! Mr M.P.&S.C. Lawson

Planned Development within Area of Outstanding Natural Beauty of Silverdale

Dear Sirs and Madams,

Comments were invited, regarding the above, at Council and other venues in this neighbourhood and I am convinced, that I should respond:

(I) Britain has less tree cover and quality farmland than elsewhere in Europe and what remains, I feel, should not be despoiled by making (needlessly) “Greenfield sites” into “Brownfield sites”.

(II) Wildlife which includes a host of orchids scarcely exists outside the Silverdale Area. Let us consider this Bounty - how and where it grows, before sentencing natures “glories” to an inglorious “death” under concrete and macadam!
And so many rare species of bird exist hereabouts particularly at “Leighton Moss”!
But they will leave as abruptly as they came if petrol/oil fumes build up without strict control. Yes, the recently arrived egrets will quit the area and say “Goodbye”. They will “go” the same way as the Larch and the Ash – and the whole country will be so much the poorer!
The above (I) and (II) only begin to indicate the fast developing tragedy! There is (everywhere) so much more of our heritage that is being despoiled.

Now let’s think of practicability:

(III) Are the occupants of the “new build housing” to work locally? If so where?
What transport is to be provided? Do people wish to live outside “the town”, when income is constrained? Do they wish to travel daily, perhaps twenty miles, to earn a living; this could be counterproductive.
What is the extent of the “carbon footprint” to sustain these houses? Please consider the chronic parking problems and increasing traffic on these local roads!

The development of new housing in Silverdale, I submit, makes NO Sense at all!
I hope the politicians will see sense and reject this development in its entirety.

Yours faithfully,


Ray Lee,

[SEE ATTACHED DOCUMENT]

4. Vision and Objectives

[SEE ATTACHED DOCUMENT]

[SEE ATTACHED DOCUMENT]

[SEE ATTACHED DOCUMENT]

[SEE ATTACHED DOCUMENT]

6. Options for Meeting the Objectives and Delivering the Vision

This consultation has been made far too complex. In Silverdale the plans were set out in an upstairs room - outside slippery staircase with no clear disabled access, and the staff who attended lacked knowledge of local area.

This web form is too hard to navigate.

As I write this the roads in the lower end of the village of Silverdale are flooded. This happens most rainy days, although it has been a very wet November, but we must anticipate this sort of weather in future. Despite this your plan to put yet more concrete in areas adjacent to Cove road - the effect on the water table do not appear to be addressed.

More housing means less green space and fewer trees - again the water table rises. An independent report by Parkins and Partners commissioned by Lancashire CC concluded that the bedrock was losing porosity and fissures wewre silting up. Yet the staff at the consultation were unaware of this, nor could they reassure us that the fragile nature of the geology was being taken into account

While welcoming a joint district council approach to the ANOB, it is disappointing that it does not include county council. In particular it is bizarre that Silverdale is considered an area for development predicated on local transport availability. Don't you know that LCC are removing the local bus service in April 2016 ?

I regret I am unaware of any detailed geological studies of this area , although they are sorely needed in view of the regular flooding . Two things maybe of interest however –
I am aware that the county council conducted a survey around the Cove Road area before digging new drains last year . There may be more studies, of course that I am unaware of .
I am also aware that the county council commissioned a study into soakaways around Bleasdale School , which suggested some worrying changes in the porosity of the rocks . This was a local study conducted to resolve the particular issues around drainage from Springbank . I mentioned it in my original email . It is unlikely that these changes in the geology are restricted to that small area .

The person dealing with this is Steve Williamson from the county council , who may have more information

6. Options for Meeting the Objectives and Delivering the Vision

Discussion Paper section

6. Options for Meeting the Objectives and Delivering the Vision

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.

Q9 How should the AONB plan for development on rural estates. 5.16 - Strict guidelines should be put in place to prevent piecemeal development. I support the use of small, brownfield sites and oppose the development of large sites which would go against the principle of ‘highest protection’ afforded in the AONB

Q26 Which options represent the most approach to development in the AONB - 6.17 and 6.18

Q27. Specific sites proposed in the AONB.

A1 Allotments, Silverdale Road Open Space Agree
A2 Arnside Edge, Far Arnside Development No - Unsustainable location poorly related to any settlement
A4 Ashmeadow Woodland Open Space Agree
A7 High Close, Knott Lane Development No - Prominent site with potential landscape impact, poorly related to any settlement
A8 Hollins Lane 1 Dev/Open Space - Open Space Agree
A11 Land N of Briery Bank 1 Development No – Open Space - prominent in landscape terms
A12 Land N of Briery Bank 2 Development No – Open Space - prominent in landscape terms
A15 The Common, Redhills Rd Dev/Open Space Open Space - prominent in landscape terms
A17 Land adjoining Cemetery 2 Development No - Open Space - poor access
A18 Land W of Saltcotes Hall 1 Development No - Open Space - prominent in landscape terms
A22 Station Fields, Station Road Development widen into lay-by for Car parking for railway station only
A24 Station Fields, Station Road 2 Development No - drainage issues, site prominent in the local landscape
A25,26,27 Station Yard, Sandside Road 1 Development No - flood risk problems
A29 Trafalgar Garage Development Agree
A97 Middlebarrow Quarry Development No - unsustainable location
A106 Land W of Black Dyke Rd Development No - liable to flooding
A107 Land NW Briery Bank 2 Development No - Open Space- site prominent in the local landscape

Q29 Should the AONB identify development boundaries? for which boundaries.
Yes - Arnside, Sandside/Storth, Silverdale and Warton

No

No

Apologies for the late sending of our comments on the proposed development in the AONB in particular the site Y103.

1. This particular site would not fit in with the "principles of development" in that it is not a sustainable site and development would detract from the natural beauty of the area. It would also appear that there is little evidence for affordable housing to be built in this site.

2. The sustainability of any new buildings could be compromised along with that of existing residential dwellings. This is mainly due to access which is poor. The road is narrow and already difficult for traffic with no pavements on the roads along Footeran Lane and Silverdale Road for pedestrians. It is already a challenge for children going to school and for older residents attending the village hall.

Services are sparse with a small school, village hall and church. There are no shops, post office, GP service or pub. In addition it is likely that the existing bus service will be reduced or even cut. The mobile library service which only visits every 3 weeks at present is also under review. It is difficult to envisage how so few services would support many more people.

Community infrastructure is identified as a key requirement of a functioning community and as stated above infrastructure is poor and would be insufficient to sustain new development.

There is no employment in the site apart from that at the school and any new residents would have to travel to neighbouring towns e.g. Lancaster, Carnforth or Milnthorpe having a negative impact on road usage. It would seem more sensible to develop and provide affordable housing on the edge of the AONB in larger towns.

There is one small open space - the village green - which is insufficient for a large increase in the number of children in the site. It would be detrimental to the area if this open space was in any way reduced or compromised.

3. There would be a negative impact on the already fragile sewage systems in place. This has been made far worse with the recent heavy rain fall. All properties discharge waste into septic tanks. Should additional properties be built a new sewage system would need to be installed.

4. Storrs Grange, our property is a Grade 2 listed building as are neighbouring properties. It is hard to see how new developments would meet strict planning regulations with relation to the access and heritage criteria imposed with any changes. Our application for a flu to be installed was difficult to get through. This will have no impact on the local environment. New developments would have a massive impact.

Overall we feel that developments in Yealand Redmayne or neighbouring Storrs or Conyers are not viable. The roads, services, sewage systems are insufficient and would require investment. It would seem more appropriate to concentrate development on other areas such as Warton, Carnforth or Milnthorpe which have more community infrastructure already in place.

Regards
Geraldine Moore (Chairperson Village Hall Committee) & Michael Wilson

Planned Development within Area of Outstanding Natural Beauty of Silverdale

Dear Madames and Sirs,

herewith I wish to comment, as encouraged by you, in writing regarding the Development Plan for the AONB regarding Silverdale.
I am against any ‘new built’ houses (apart of sensibly built council houses for local people) as they will have a huge impact on the whole character of the village.
They would ruin the charming unique rural character of the Silverdale village. Everybody says, ‘how beautiful Silverdale is’ – because it is still largely unspoilt (apart of the four surrounding Caravan Sites).
Another point is with regard to the traffic – New houses would mean more cars will be on the road, going daily in and out of the village – when the roads are already congested, largely because of the extra people from the caravan sites. Soon it will be unbearable! It will also be more dangerous, because of the narrow roads and the increased parking on the roadsides.
My opinion is that ‘our’ village has contributed towards developments with the hundreds of caravans in close proximity to Silverdale enough already.
Why should we sacrifice precious green field land (used as farmland) to new buildings, when it is needed to keep the traditional farming alive? In the leaflet ‘Explore Silverdale Village’ Martin Fishwick wrote, “There has been a historic loss of viable grazeable limestone grassland … this has led to a reduction from the high teens of farms in the 1950s to just four today.” Farming’s ‘custodianship’ is vital to the maintenance of the landscape.
There are currently about 40 houses empty and for sale. We should rather convert and renovate the existing empty buildings for ‘affordable housing’ to prevent ‘new build’ on green sites.
Why build on important green field land to the detriment of wildlife, when there is enough ‘brown field’ land available - for instance in Lancaster, where abandoned former factory buildings (on St. George’s Quay) are about to be demolished. New houses there would have ‘river view’ and the entire infrastructure on the door step.
If one would allow building of new houses in Silverdale this would mean, that the people would nevertheless have to commute to Lancaster (for work or school).
This seems to be so ridiculous!

I hope you will consider my opinion and agree to save Silverdale’s special character as an “Area of Outstanding Natural Beauty” by not building new houses.
To finish with a quotation from Roger Scruton in the ‘Sunday Telegraph’:
“The green fields are a ‘symbol of everything permanent, cherished, and consoling.’ We must protect what’s left of them because they are ‘an immovable part of what we are.’”
In that sense: Please keep Silverdale green and beautiful!


Yours sincerely,

Kerstin Nagel,

4. Vision and Objectives

Firstly, I would like to make a general comment that the title: Area of Outstanding NATURAL Beauty (AONB) uses the word natural. Additional housing, let alone so called "affordable housing" is man-made and therefore contrasts with the natural geography of the area.

Additional housing should be dictated by genuine needs and not by policy from central government.

The document speaks of additional employment. Where is this additional employment? In the 15 years I have lived in Silverdale I have not seen any significant local increase in job opportunities.

Any housing to support additional employment should be as close as possible to where these jobs are. An additional 72 houses could mean an excess of hundred additional motor vehicles travelling daily to the larger towns of Lancaster, Morecambe and Kendal on roads with very limited capacity for additional traffic.
Transport links by road to both Silverdale and Arnside are both limited to a single road with one carriageway in each direction, (ie Stankelt Rd and Sandside Rd, respectively). All other roads are singletrack with passing places. During the summer, particularly due to tourism, the roads can be congested and occasionally blocked altogether through recreational vehicles, caravans etc.
Both villages have rail links and thought needs to be given to developing housing within walking distance of the stations allowing access to employment opportunities in a much larger area, but only if it is not possible to build affordable housing close to the new jobs.

The AONB area relies on tourism any new jobs are likely to be in this industry. This has increased recently, particularly in Silverdale through resulting from programmes such as 'Autumnwatch'. Care therefore needs to be given not to disturb the ambience of the area so tourism can be sustained for even expanded.

In the Silverdale area, with which I am most familiar, many of the proposed development sites are inpractical. I would not wish to spend time going through these individually but the two nearest my house on Elmslack Lane i.e. 43 and 51 are cases in point.
Site 51 is on a steep slope has no access, and forms a boundary of Eaves Wood. The landowner was recently forbidden to cut down trees, yet this is now being proposed for development!

Site 43 has multiple landowners, very little access and any potential access would be onto singletrack road with passing places this site is also larger than 1 ha and therefore constitutes a "major development" (as are several other proposed sites). The site is also visible from Eaves Wood, particularly the pepperpot and therefore would become something of an eyesore.

The third site (45) along Cove Road is actually a private house.

There are several other proposed sites which are now prime farmland e.g. site 50. These should not be disturbed as they form part of the local economy, and would become an eyesore as being overlooked by prime areas e.g. site 50 is overlooked by Eaves Wood. These areas with hedgerows form natural habitats for wildlife which would be destroyed through development.

Various areas of "important open space" are afforded protection but there is nothing in a document to say how these may be developed or access granted where this is not already available.

The document repeatedly comments on how the AONB should be protected but says little about how facilities could be enhanced. To give a couple of examples, there are several disused quarries within the AONB how could these be developed, or are they to remain a scar on the landscape? Arnside viaduct has had the enabling works for a footpath/cycle track laid, this offers the opportunity to develop a path for pedestrians and cyclists across to the other side of the bay and would significantly enhance the tourist appeal of the area. There must be many other examples of how the area can be enhanced and with this employment opportunities and a real need for affordable housing.

1. Introduction

[SEE ATTACHED DOCUMENT]

2. Background

[SEE ATTACHED DOCUMENT]

3. Evidence Base

[SEE ATTACHED DOCUMENT]

4. Vision and Objectives

[SEE ATTACHED DOCUMENT]

5. Policy Issues

[SEE ATTACHED DOCUMENT]

6. Options for Meeting the Objectives and Delivering the Vision

[SEE ATTACHED DOCUMENT]

[SEE ATTACHED DOCUMENT]

[SEE ATTACHED DOCUMENT]

My concern is a lack of homes for rural workers, employed in agriculture and forestry in the AONB, who have made and continue to make this area special.
I am in favour of a select and small number of suitable dwellings, with agricultural restrictions within the AONB to support genuine rural workers, and farmers who make an invaluable contribution to the beauty and character of the AONB.
The plan should make provision to accommodate this specific need, and be less focused on larger developments which will spoil the nature and character of the area.

2. Background

Q1: Should the AONB DPD define what would constitute ‘major development’ (a threshold above which planning consent would not normally be granted) in the AONB or should this be considered on a case by case basis? If there should be a definition, what should it be?

The definition given in Statutory Instrument 2010 No.2184 is a suitable definition of a 'major development' in the AONB.

Q6: Should the AONB DPD identify the proportion of affordable housing to be developed in the AONB? If so, what proportion and how would it be delivered?

Yes. A majority of new housing should be affordable. Multi-dwelling developments should be mainly or totally affordable housing.

5. Policy Issues

Q7: Should the AONB DPD restrict new housing development to local people and/or those who are going to use the property for their sole or main occupancy?

All affordable housing should be restricted to local people, which I would define as those that already live or work in the AONB.

Q8: How should the AONB DPD promote the development of certain housing types within the AONB to meet particular housing needs?

Yes. In addition to affordable housing I believe there is a need for housing for older people to move into when their existing homes is no longer suitable for their needs.

Q12: Should the AONB DPD identify allocations of land for community infrastructure? What community infrastructure is required and where?

Yes. There is an unmet demand in Silverdale for additional sports facilities such as tennis courts, a multi-use games area and a skate park.

Q14: What types of energy technology should policies in the AONB DPD cover? How should policies deal with energy-related developments?

The AONB in not a suitable place for any energy related developments except on a very small scale, such as roof mounted solar panels.

Q16: Do you consider that there is a need for any additional parking facilities in the AONB’s settlements and, if so, where should it be located?

For different reasons parking is a problem on The Promenade at Arnside, on Emesgate Lane in Silverdale and on Main Street in Warton. If any development land is identified close to these areas it should be considered for parking. At both Arnside and Silverdale stations the station yards should, if possible, be developed as car parks.

Q17: What policy stance should the AONB DPD take towards proposals for new or expanded caravan sites within the AONB?

I agree with the existing policies of Lancaster and South Lakeland.

Q20: Aside from those spaces marked on the accompanying maps, are there any other parcels of land that you feel should be given Important Open Space designation? Why?

Given that the area is an AONB I would expect all or almost all farm land, wood and moss to be designated, except for areas adjacent to any existing development. If that is not accepted, then places that have significant public access should be designated. The obvious examples of places not included on the maps are Warton Crag, Leighton Hall park, Leighton Moss, and Gait Barrows nature reserve.

Inside existing settlements, the Institute Field in Silverdale should be designated as an open space as it is one of the few green spaces close to the centre of the village.

6. Options for Meeting the Objectives and Delivering the Vision

Q26: Which option(s) represent the most appropriate approach to development in the AONB? Are there any other options we should consider?

Option 5 - Allocate predominantly in Primary Settlements and in smaller amounts in Secondary settlements and Beetham + exceptions criteria for everywhere else – would be the most appropriate approach.

Q27: Have you any comments on any of the sites put forward?

Site A2: Arnside Edge. Not an appropriate location. Development here would destroy the view from the road and from the shore.

Site A7: High Close. This would be a major development in a largely undeveloped area and therefore not acceptable.

Site A12: Land North of Briery Bank 2. This would be a major development and therefore not acceptable.

Site A17: Land Adjoining Cemetery 2. This would be a major development in a largely undeveloped area and therefore not acceptable.

Site A18: Land West of Saltcotes Hall. This would be a major development and therefore not acceptable.

Site A26: Station Yard, Sandside Road. Some development of this area would be acceptable provided it includes significant station car parking.

Site A97: Middlebarrow Quarry. It is difficult to imagine a suitable development for this site. Given its location the best option would allow it to become a nature reserve like Trowbarrow Quarry.

Site S42: Blue Hills Cottage, Spring Bank, Silverdale. This site is already developed more than the plan would suggest, leaving little room for further development. Problems exist with access via Spring Bank – see planning applications 09/00903/FUL and 15/00739/FUL.

Site S44: Hawes Villa, Moss Lane, Silverdale. This site is away from other habitation and on the edge of Hawes Water, one of the most attractive parts of Silverdale. Access is via Moss Lane which is a single track road not suitable for increased traffic.

Site S46: Kayes Garden Centre, Lindeth Road, Silverdale. This would be a major development and therefore not acceptable.

Site S48: Land East of Lindeth Close, Silverdale. This would be a major development and therefore not acceptable.

Site S50: Land East Of St Johns Avenue, Silverdale. This would be a major development and therefore not acceptable. When viewed from the 'Pepper Pot' on King William's Hill any development would be highly visible.

Site S52: Land East of Hawes Villa, Moss Lane, Silverdale. This is an undeveloped field, apart from an old railway wagon. The site is away from other habitation and on the edge of Hawes Water, one of the most attractive parts of Silverdale. Aces is via Moss Lane which is a single track road not suitable for increased traffic.

Site S54: Land South Of Cove Drive, Silverdale. This may be a major development and therefore not acceptable. When viewed from the 'Pepper Pot' on King William's Hill any development would be highly visible.

Site S56: Land South Of Whinney Fold, Silverdale. This may be a major development and therefore not acceptable. If a larger development is required in Silverdale this would be more suitable than many other locations as it would less intrusive.

Site S58: Land West of Lindeth Road, Silverdale. This may be a major development and therefore not acceptable. If a larger development is required in Silverdale this would be more suitable than many other locations as it would less intrusive.

Site S67: Townsfield, Silverdale. Part of this land either adjacent to Emsgate Lane or Cove road could be sites for sports facilities such as tennis courts or a multi-use games area.

Site S70: Railway Goods Yard, Red Bridge Lane 1, Silverdale. The station car park is adjacent to this and was part of the old goods yard. Due to its shape the car park can only take unto about five cars and is often full. A larger car park is required, especially if Silverdale looses its bus services. This land should be developed as a car park.

Site S98: Sixteen Buoys, Ford Lane, Waterslack. This site is undeveloped other than a large agricultural/industrial building. It is separated from other buildings at Waterslack by the railway line. It is therefore not part of an existing development, other than the large building.

7. Delivery of Development

Q31: Are there any other issues that the AONB DPD should address? Have you any other comments?

I think the AOND PDP should attempt to define what 'sustainable development' means in the context of an AONB or National Park. I would expect this to be different from the meaning sustainable development in other areas.

2. Background

question 1 No. Major development plans should be considered on a case by case basis.

3. Evidence Base

Question 2 Yes. The respective Councils should identify housing needs in the AONB area in line with national criteria.

4. Vision and Objectives

question 5. Broadly agree with objectives, but consideration must be given to the different 'settlements' within Silverdale itself, each hub with its own character and sustainable in its own location eg the character of Silverdale Green is quite different to that of the areas nearer the quarries or in more agricultural settings.

5. Policy Issues

Question 6 No. National Guidelines re housing needs and development should be applied. There is surely a question of accountability as the body (AONB) is not part of the electoral process. Is the AONB now to be a satellite county with its own governance?

Question 25. The local vernacular architecture in Silverdale is varied and piecemeal, and with few exceptions of little architectural merit and poorly constructed. Standards of design need to embrace the use of modern materials and technologies to ensure that Silverdale village is sustainable and a place to live and work for families now and in the future.

5. Policy Issues

Question 6 No. National Guidelines re housing needs and development should be applied. There is surely a question of accountability as the body (AONB) is not part of the electoral process. Is the AONB now to be a satellite county with its own governance?

6. Options for Meeting the Objectives and Delivering the Vision

Question 31 Option (v) in Table 4

6. Options for Meeting the Objectives and Delivering the Vision

Question 29 No development boundaries should be identified for any type of settlement, but should be assessed on a case by case basis.

Silverdale Village does have a strong community, but it covers a wide and diverse area in terms of property and landscape setting that makes definition difficult. Development boundaries would not allow flexibility to make sound judgements based on circumstances at the time.

5. Policy Issues

Q23. In Silverdale we have no piped sewage system, and rely largely on septic tanks. In 1995 our groundwater was declared to be vulnerable by the Environment Agency, and pollution was present on the foreshore. As a result the E.A. insisted that new discharges in the Silverdale area had to conform to three stage treatment, i.e. a modern biological treatment plant, U-V sterilisation, and tertiary polishing/filtration. Since 1995 many more houses have been built in Silverdale, but apparently not always conforming to the EA's rules. Caravan sites have more than doubled their capacity. We need an assurance that any building project conforms to the EA's rules in respect of their discharges. The daily load of grey water is 150litres/day/person in the UK (2014 figures), which passes into the ground water. We need to have analyses of the ground water to determine whether our vulnerable water is being further contaminated. The Environment Agency would perform these.

Q27. Commenting on S56, land south of Whinney Fold. This greenfield site is being considered at present for a major development (as defined in Town and Country Planning Order 2010) of 19 houses, which cannot be demonstrated to satisfy an overriding national need, or to be in the overriding public interest. It lies in a hollow below the 20metre contour, which would require the grey water and excess rainwater runoff to be pumped out. The southern third of the site has just been flooded to a depth of 2 to 3 feet in the recent rains. If 40 people, say, are going to live in these 19 houses, that would involve about 6000 litres of grey water/day to be pumped out, together with the effects of 1150mm of rainfall per year. Recurrent flooding seems to be an obvious risk.

6. Options for Meeting the Objectives and Delivering the Vision

S54. I believe have some major concerns with a number of the sites put forward in the proposal document. On a strategic level, Silverdale is a village with little employment and restricted road transport connections to any major employers. Many of the roads that connect Silverdale and indeed through the village go to single lane and with the many tourists and nature lovers we have in the village, these can be very restrictive and indeed dangerous to pedestrians and cyclists. The idea of adding more houses and more road users to this mix does not seem very wise on a safety point of view. Particularly when some proposed sites look like they would add to single lane road sites, such as on Cove Road Site 43 and site 53.
A number of the proposed sites are also presently green field and valuable to both the bio diversity of the area and natural beauty. Site 53 is a wello cared for pasture land that is allowed to grow many wild flowers before the grass cutting is done, very late in the season. This is the home for many insects and birds bats and Roe deer thrive in this field every year.
This area, very importantly is also very sensitive to flooding through the ground water. The Townsfield houses, Cove Drive, Birch drive and schools septic tanks add to this and there is persistent flooding certainly should completely dismiss this area for building development.
I also object to the proposal of building right next to the primary school. One of the main attractions to people having their children in the school is the fact that the playground and sports field are not backed in by houses but instead have that beautiful vista for the children to enjoy. The pollution and noise oif having a building site next to the school would be disastrous for a number of years for the children.
I have focussed specifically on area 54 as I live adjacent to this and know it well, but on a more general view, Silverdale and it's green spaces should be protected from unrequired development, due to both logistical and preservation reasons. The area is a natural haven to many beautiful and fragile flora and fauna and has a balance with all the green spaces, be they woodland, open fields and limestone paving. There are many more sites in the local area which would be more suitable, thean irrecoverably destroying more of our precious open spaces.

[SEE ATTACHED DOCUMENT]

6. Options for Meeting the Objectives and Delivering the Vision

s 6.20

Proposed site 32.
This site is out of sympathy with the historic form and character of the village, which is ribbon development along
roads not blocks of housing. It will damage views out from the church, and views from river into the village. The
effect of massing of houses will be magnified by the slope. Access to the site is poor, along narrow Mill Lane, and
the route from the A6 is complicated. The site was rejected in the recent LDF exercise, why has it surfaced again ?









access poor along Mill Lane, route from A6 problematic

6. Options for Meeting the Objectives and Delivering the Vision

s. 6.20
proposed site 109. This block of housing is out of character with the ribbon development of the village. Access
will be poor and traffic on the narrow approach road will be increased. There are already times of day when traffic
is too heavy.

6. Options for Meeting the Objectives and Delivering the Vision

s 6.20
site 13

This is the abandoned Slackhead Tip. It was used for domestic and toxic waste disposal, records of what was
dumped are poor or non-existent. It was cited in a Friends of the Earth report about 25 years ago as a possible
source of radio-active pollution. It has been generating methane, shown by vent tubes. Has methane generation
finished ? A letter from the NRA to Beetham Parish Council dated 27 June 1991 stated "The landfill was not
engineered to containment principles...". Presumably this means insufficient compaction and no surface seal.
Disturbance of the surface will affect water ingress and movement, with new routes for drainage within and from the
base of the tip. Altered flow patterns and amounts, together with changed water chemistry, could remobilise
pollutants.

If the tip is insufficiently compacted it will not be stable enough for building. Alterations in water flow could increase
instability in an already poorly compacted mass. Any tendency to settle may be accentuated by the tip lying in a
doline, a natural subsidence hollow in the limestone caused by solution of the underlying limestone. Rock solution
could be increased by changes in water flow in the tip mass, with changes in water chemistry, leading to further
settlement.

Public Health England's interactive radon maps indicate that radon is endemic in the area. Disturbance of the tip
may cause radon to be channelled preferentially via the tip to any buildings above..

Road access to Slackhead is already poor, there is too much traffic on the road up the hill from Beetham.
Additional traffic will make the situation much worse.

2. Background

Q1 Do need definition of major development. Para 116 of the NPPF seems to ignore exceptions that go to meet local need. Thus the definition needs to be more nuanced than just size and number so to allow moderate sized development (e.g. for housing) that demonstrably and solely is there to meet a local need (where local is truly local - probably one parish only, certainly AONB only).

Q2 We need to establish a rolling needs - housing and employment sites needed in the next five years, then a less certain subsequent five years , then the next five. This to be reassessed as appropriate. Land supply should match this - a five year preferred allocation then a hierarchy of sites not to come on line until the need has been shown in subsequent periods. This hierarchy should be based on availability as well as landscape impact as there may well be sites that are not yet ready for development but could come up in the future.

Q3 We need to look at the wider Lancaster & S.Lakeland plans to look at impacts they may have on the function and setting of the AONB. For landscape there will be things like wind turbines and solar farms. For infrastructure there will be the tourist developments along the A6 corridor and how access from these can be guided to be more sustainable and less environmentally damaging e.g. pro-actively creating bridle paths into the AONB and support for public transport systems. These may need development conditions on sites outside that help fund these links into the AONB.

Q4 Vision - OK Q5 - Objectives - OK

Q6 Very important issue to goes to the heart of community character and sustainability. We do need a high proportion of affordable housing and also a good stock of local needs rentable property. Affordable can mean higher density on AONB sites as the surrounding environment and village amenities compensate for smaller plot sizes. However that would also mean that village amenity - shops, pubs, play areas and fields, allotments etc need encouragement and should not be crowded or priced out by housing demand. I would go for a very high affordable element (even totally) - not necessarily subsidised directly but allowed at a higher density with no possibility of "market value" housing being allowed so that the present inflated land values are lowered (basically treat all sites as "Exception" sites)

Q7 Therefore yes: local need with lasting restrictions. The ageing population and number of homes already occupied by those who have retired here mean that there is already a good stock of available properties that come on the market regularly. Is there evidence of frequency of sale for the various house types in the AONB? If more rentable new property were built then the many properties now kept by those inheriting them for the high rents that can be charged would drop, freeing more properties for sale.

Q8 Definitely. A lot of local need is for downsizing so this would help deliver the higher densities and lower cost housing mentioned above.

Q9 Very rarely. The AONB is tiny. Nowhere is far from an established settlement. Very, very few people would actually need to live "on site". Rural estates provide the bulk of these sorts of jobs but also the bulk of land that will be suitable for development. Their requirements should thus always be factored into any development proposals for their land.

Q10 Prioritise certainly. But need to be clear what "brown field" actually is. Needs to be only already developed land, not undeveloped land within the same curtilage. For instance a quarry might be brown field but the unquarried and unbuilt land should not be considered so.

Q11 Yes - see 6 above

Q12 if possible - see 6 above

Q13 A high proportion of people work from home. Need for locations close by where, e.g. vans and equipment can be stored so they don't need to be parked on public highways. Also need for small workshops where craft workers can operate so they don't disturb neighbours. There should be a blanket ban on changing shops and amenity facilities to housing unless a suitable alternative is provided.

Q14. Very small scale for local use. Ought to be a relaxation on things like solar panels on buildings within conservation areas provided they do not irretrievably alter appearances. There is a need for woodland management in much of the AONB and hence opportunities for wood fuel so there is a need for things like storage and drying facilities. These could be located alongside other agricultural buildings.

Q15 See answer to Q3. New open countryside tourist accommodation areas inside the AONB need to be prohibited and the existing sites encouraged to be less car dependent. We need to establish a proper network of quiet lanes and a better bridleway system. As the AONB is only about 6 miles long at the most, traffic has no need to speed. 20mph limits need to extend to all pedestrian routes between communities to protect walkers, horse riders and cyclists. A blanket 40 limit should be the maximum anywhere.

Q16 There is a problem with parking but managing speeds and encouraging alternatives would be better than encouraging more cars. However there could be more use made of Carnforth as hub into the AONB with bus and rail links. Both Silverdale and Arnside stations need to be improved. and a connection from the former into the RSPB should be facilitated. In addition the road network around Leighton Moss should be quietened and connections between the Morecambe Bay, Barrow Scout and Silverdale Moss sites strengthened so that those who do arrive by car can leave their vehicles at the visitor centre and make a full day of it without further use.

Q17 Touring caravans are a real problem on our narrow lanes and in the villages. No more touring pitches should be allowed. Permanent caravans and chalets could be added inside existing sites if their design, colour and impact on the landscape is strictly controlled. Can we make sure that the existing stock is better used and not taken up by, effectively, second homes that are used sparingly?


Q18 Criteria given look comprehensive

Q19 & 20 No map for Warton given. Comments here are thus about whether sites put forward for development should actually be important open space:
W84 Part of this land is already public amenity land - the NE corner is the Small Weir, a historic parish watering place owned by the Parish Council. The rest of the site does make an important contribution to the open aspect of that part of the village. It is also impractical for development as it is regularly flooded, the water being, this month, right up to the roadside.
W87, 88, 89 and 95 are all on the lower slopes of Warton Crag. The Crag is the first piece of high ground coming up the coast since Cheshire. It marks the beginning of the Lake District massif, being the southernmost point of the limestone ring that encircles this. Its importance is not only to the landscape of the AONB but also as the geological entry to the National Park. It is thus vital open space.
W90 is the field next to the school field. Its open aspect towards the East looking over the Forest of Bowland and into the Yorkshire Dales links the village into the wider countryside as well as giving the school a rural, as opposed to suburban setting. Events like the village sports are held on the School field and get their rural feeling from this setting. It also gives particularly good views of the historic Old Rectory from the footpath that runs along its eastern side, the only open views of the scheduled monument.

Q21 Site assessment pro-forma looks to be comprehensive.

Q22 Of course. That's the whole purpose of a DPD for the AONB

Q23 Because of the AONB terrain the historic villages are built on hillsides above the mosses. If development is allowed on the mosses it will flood unless the site is raised but if the site is raised the rest of the moss will flood more readily. The hillsides do experience a lot of run-off in times of heavy rain. Hard development risks directing this into the existing settlement. Any such developments must therefore allow for effective soak away or be capable of directing run-off around existing buildings and onto the flood plains. The heavy rains this week led to flooding of houses in Gardner Rd, Warton, the lowest-lying developed area and also to houses on Sand Lane and at Town End from run-off exacerbated by development uphill.

Q24 & 25 There needs to be an effective design guide for the AONB which also recognises the considerable range of styles in each community. Abiding by this guide should be a requisite for any development that might interfere with the setting of elements of the historic environment. In addition the DPD should make it possible to assess development not only on its visual appearance but also on impact it might have on hidden features. Very little archaeological work has ever been done in the historic areas of the AONB so this needs to be born in mind, either by requiring surveys or prohibiting work that could damage unsurveyed areas.

Q27 Most sites were covered in response to Q 19 & 20 as they are on areas important to keep as open space.
W86, 92 & 93 have less implications as open space but their development would lead to a major change in the character of that end of the village and eat into the separation between Warton Village and Millhead. Being far from the village centre it would be likely not to contribute much to maintaining the facilities in Warton as Carnforth would be just as accessible.

Q28 Two possible areas that might be appropriate in Warton are:
the Roods play area which has a run of old persons' bungalows on one side. This could be developed into a site for sheltered and old persons' housing. It is owned by the City Council but access would really need removal of the first existing bungalow.
At the end of Well Lane and Borwick Close there could be room for perhaps 10 to 15 houses spreading along no further than those on the other side of Borwick Lane

Q29 In many cases yes. The coherent settlements must be stopped from ribbon development so boundaries should be set for e.g. Warton, Yealand Conyers, Redmayne and Storrs, Beetham, Slackhead, Arnside. Probably not appropriate for disseminated settlements like Silverdale.

Q30 see response to Q2

No

6. Options for Meeting the Objectives and Delivering the Vision

COMMENTS RELATE ONLY TO SITES IN YEALAND
Sites Y101 and Y102 are at the top of the village where there is a 180 degree vista from the minor road known as the triangle. This road forms a natural edge to the village and should be considered a Development Boundary. Housing on these two adjacent sites, which are beyond the minor road, would destroy the natural edge of the village at this point. Development here would obliterate for ever one of the few places in the AONB accessible by road where the sweep of the the beautiful limestone ridges can be seen. Houses here would have an adverse impact on the sense of tranquillity, space, and place which is so much part of the area. Of many beautiful views in the the Yealand villages, this is the most grand.
The Yealands lack a centre, so a potentially good place for future smypathetic housing developments would be in the area around and between Well Lane and the church in Kylbarrow Lane. Housing here and near Footeran Lane could increase the visual amenity, and sense of community cohesion in both parishes, if combined with appropriate infrastructure. Individual buildings of 1-3 houses, or small terraces, each designed by a different architect or builder, could harmonize well with the existing community and housing stock.
Site Y103 off Footeran Lane makes up part of this area. Footeran Lane can be dangerous for pedestrians; developments to the West of the lane would need careful planning across both parishes, so that building of individual houses in this area would not preclude the possibility of a much needed footpath to the school and village hall, from both directions. Any plans for footpath and road improvements in this area should be considered prior to any building approval, and be subject to careful planning scrutiny. There may also be scope for designation of some areas East of Footeran Lane as "Open Space", given the existing pond by the school, which was greatly enlarged Southwards during the recent floods.

1. Introduction

[SEE ATTACHED DOCUMENT]

I am writing to express my concern over the proposed potential development sites in Warton, reference numbers W87/88/89/92/93/95. The concerns that i have are that the infrastructure that we have is currently at capacity and feel that expanding the population will only exacerbate the current problems. The quality of the roads is very poor and this will only get worse as the flow of traffic increases. The amount of traffic travelling through Warton already causes problems particularly on Main street where there are multiple cars parked on the road side making it increasingly difficult to pass on coming traffic, this is especially problematic with buses. There is also the problem of congestion in Carnforth, this will be exacerbated by any development plans. Currently Carnforth struggles to cope with the through flow of traffic and is frequently congested. I also have concerns as to have the schools are meant to cope with the extra population, as i am concerned regarding the healthcare provisions for the proposed increase in the local population. I work at Royal Lancaster Infirmary and there are constant significant pressures placed on the site due to a lack of bed capacity and fear this will be exacerbated and to get appointments with GP’s in the local area is also problematic and will also be exacerbated as they have an increased number of patients. There are issues with flooding within the village, with the proposed development sites this will only get worse, as the surface water will not be soaked up in the fields, it will run straight off the development sites. Finally, living in an area of outstanding natural beauty is what attracts many visitors to the area and i fear that with the proposed developments there will be a profound impact upon the environment and local wildlife. Our green space should be protected, not taken away.

Yours Sincerely

Charlotte Pinder

I have looked at the DPD relating to Silverdale. For its size, this village must be one of the very few in the country that for some reason still has no mains drainage. Most of the residents have to rely on septic tanks. Surely this problem must be addressed before any new housing is even considered. This is the 21st. century not the 19th. and this situation should never have been allowed to continue.

David Player

Q19 Of the existing designated open spaces shown on the accompanying maps, are there any you feel need not be designated as Important Open Space or any that could be suitable for other uses? What uses?

Site A8: Hollins Lane, Arnside. The site is enclosed by residential development on all sides with the backs of residential properties on the western and eastern sides. A LVIA has previously been submitted indicating the site is visually prominent. The site is suitable to accommodate a modest housing scheme.

I question the above statement the site is visually prominent from Hollins Lane. The site was originally the cricket field for Earnseat School, the old cricket pavilion remains on the site albeit in a rather dilapidated state. This should be of some historical value to the village. I often Hollins Lane looking across the field to the wonderful view beyond.see people standing near the gate on

The site was viewed by Holme Housing several years ago with view to creating a small development of affordable housing. They carried out extensive surveys and found that the sewers on Hollins Lane were running at full capacity. On discovering this they analysed the site for natural drainage also the viability of excavating the site to connect with existing sewers, they found that this was not a viable option as the land is limestone and the cost of excavation would be prohibitive. At present the field soaks up some of the water during heavy rain. The grids and drains on Hollins Lane are already inadequate with heavy rain because of this there is often a stream running down Hollins Lane. Further development will lead to increased flooding potential and surface water.

The steep gradient of the lane from the corner at Swinate to the top of Silverdale Road will mean the properties from 1 to 12 will be overlooked. The proposed development will be at least 1.5 to 2 metres above existing properties (damp course to damp course). New owners will be able to look directly into the bedrooms of existing properties. Any properties that are built on this side of the field would also prevent the access and use of light.

Hollins Lane is a single track road with no pavement for much of it. The lane is already used as a rat run for people wishing to avoid Silverdale Road and the Promenade, the traffic increases substantially during the summer and whenever Holgates is busy. This is a great concern as the road is not suitable for the increase in traffic that further development will create. People who live at the top of Swinate and on Plantation also use Hollins Lane to access their properties because of the steep incline of Swinate. There have been several occasions when Hollins Lane has been covered either in ice or snow when we and others have had to park at the bottom of Briery Bank because Hollins Lane has been impossible to navigate.

DEVELOPMENT PLAN DOCUMENT AONB/SLDC
RELATING TO BEETHAM
Having attended the event on December 1st 2015 held at The Heron Theatre, Beetham and having inspected the map of the area of Beetham in relation to sites under consideration for future development, I submit the following comments in relation to the site identified as B32,responding as a property owner in Parsonage Fold, Beetham.
The proposed site is not only in the ANOB but is also within the special Beetham Conservation Area.
Access to the site is from Mill Lane Bridleway which is narrow up its whole length to a degree that currently traffic using the lane is already a danger to pedestrians and horses. Any increase in traffic would add to existing hazards. I do not consider that any acceptable access exists for vehicles in relation to any possible development.
The run off of water from the existing field already adds to the level of water in the flood plain of the River Bela which floods when the river level is high enough to spill into that area. Any development that would replace any of the field with hard surface areas could add to the possibility of the flood plain water over-spilling into Mill Lane itself, which could have serious consequences for existing properties.
Parsonage Fold properties lie adjacent to the identified site. These were not a new build as they were conversion of existing barns and as such remain part of the character of the whole village of Beetham. According to section 6.0.12 of the SLDC Character Appraisal of Beetham Conservation Document- I quote ‘such buildings can be said to add to the general architectural richness of the area….and it will be important that careful attention is given in any development proposals that are likely to affect such buildings.’
All the properties in Parsonage Fold referred to are subject to certain restrictions, stated in the property deeds, which are designed to preserve the essential character of the whole environment. Therefore when considering the identified site with regard to its suitability for modern development any such agreement would be in direct opposition to this. Indeed, the whole village of Beetham would essentially be threatened with losing its overall character.
In addition to restrictions in the deeds, each property owner in Parsonage Fold is liable for a share of the maintenance of the section of Mill Lane that would be driven across to provide access to any such development. Therefore I have a financial interest in objecting to the same.
The rear of the properties of Parsonage Fold form a natural boundary to the open fields/agricultural land. This land is greenfield and an integral part of the village setting.
In conclusion I express the wish that all the considerations in this document be taken into account in any future decision making.
2nd December 2015

3. Evidence Base

3.3 and Question 2 - I do not feel that a balance has been struck between the suggested demand for housing and the sustainability of the pressures on the wildlife within the villages, the amenity provided by the existing open space and the number of jobs available within the area to support an increasing population.

3.5 and Question 3 - Many parts of the villages within the AONB have very narrow streets and there seems to me to be a lack of information as to how the requirements for public safety along roadways, the need for car parking for visitors and residence can be squared with the provision of further housing. The road into Milnthorpe from Arnside is, in my opinion dangerous and the problems have been exacerbated by a lack of safe access to the recent housing in the area. Warton is congested along te main street, Silverdale at certain times of day has few parking spaces close to the amenities. At Silverdale Road Arnside there are no footpaths in part and this has become a more serious problem in recent years. More houses in these areas will increases the danger and the pressure for parking. Site A105 for instance has no access from the public highway and no frontage on a road or track where parking would be practical. The building of houses on the filed/allotments has excerbated parking andtraffic problems with no obvious solution.

4. Vision and Objectives

Vision and objectives

Question 4 - There does not appear to be sufficient mechanisms which will allow a rational balance between development and protection of the character of the AONB. How does 4.4(3) work in practice?

In Silverdale there is no public foul drainage system. How will you measure the effects of new development on the ground water quality and are you aware of the subsurface drainage of the area and how it impacts the natural environment?

5. Policy Issues

The number of houses it is suggested for the SLDC area are 400, there should be a clear view on the suggested requirement for the AONB as a whole and within each community.

Tthere is no suggestion how the need for 72 houses in Arnside equates to the plan. Will this mean 216 houses in 15 years. This is not attainable or rational.

Q6 The proportion of affordable housing needs to be high at 40%, but this reduces the opportunities for developers and thus pressure on the development of largersites which will seriously impact on the character of the area.

Q7. I believe that new housing for local people will provide a sustainable control on the pressure for inappropriate larger developments.

Q7. I see no reason why local builders cannot achieve a reasonable provision of new affordable sustainable houses.

Q9. There is in adequate provision for the redevelopment of brownfield land. Each year there should be a balance between the development of new sites and brownfield to ensure remediation over the period of the DPD.

Q15. There are, along some streets inadequate parking for visitors and inadequate access for vehicles. These areas should be identified and new development halted until the access traffic problems have been addressed. The pressure for more car parking should be addressed, but not at the cost of losing valuable amenity land such as that along Station Road Arnside.

Site A2 should be open space.

Site A7 should be retained a s Open space as it is adjacent to the Red Hills Fields. The current use of the land should be retained.

Site A8 should be retained as an open space

Site A11 supports valuable wildlife and should be returned to open space. The adjacent recently constructed houses along the road are fine, but additional pressures along this road would damage the character of the village.

A12 retain as open space as above.

A14 retain as open space

A15 this land has been under pressure for many years and it is a valuable opens space and level amenity for the nearby older people.

A17 Poor access and damage to the local amenity make this land adjacent to the cemetery and farm land of good quality retainable as a woodland.

A18 land with poor access and to develop this wuld damage the character of Arnside.

A19 Another opens spac ethat doesn seem to me to be suitable development land.

A20 Permantly maintained a s open space.

A22 The land to which I refer above. A car park here woud be seriously damaging to the character of the village.

A24 as above.

A97 Retain as open space.

A105 The wildlife that this garden has supported includes hedgehogs, frogs toads newts and many bird species. Infilling such sites damages the character of the village, puts pressure on access and parking and threats wildlife that rely on larger gardens to supplement their natural environment.

A106 This lands is a valuable amenity, it floods and to raise the site levels would seriously damage this aspect of the village along one of the access roads.

A107 A valuable open space which is part of the character of the village.

7. Delivery of Development

Question 27 Please see above comments on sites.

Q27 Any development plan should have an implementation plan that is phased through time. As the housing needs have been assessed on a 5 year demand, this should be reviewed and phased every 5 years to ensure suitability and protection of the area from inappropriate development.

2. Background

Q1
There should not be a rigid definition of major development, but the Local Plan should make it clear how each case will be assessed. The South Downs National Park Authority has received a legal opinion on this matter, derived from the caselaw, guidance and appeal decisions, from James Maurici QC. This is summarised as follows:
1. The determination is a matter of planning judgment to be decided by the decision maker in light of all the circumstances and the context of the site.
2. The phrase “major development” is to be given its ordinary meaning. Accordingly, it would be wrong in law to:
a. Apply the definition of major development contained in the Town and Country Planning (Development Management Procedure) (England) Order 2010.
b. Apply any set or rigid criteria.
c. Restrict the definition to proposals that raise issues of national significance.
3. The decision maker may consider whether the development has the potential to have a serious adverse impact on the natural beauty and recreational opportunities provided by a National Park or AONB by reason of its scale, character or nature. However, that does not require (and ought not to include) an in-depth consideration of whether the development will in fact have such an impact. Instead, a prima facie assessment of the potential for such impact, in light of the scale, character or nature of the proposed development is sufficient.
4. As a matter of planning judgement, the decision maker must consider the application in its local context. The same development may amount to “major development” in one National Park, but not in another; or in one part of a National Park, but not in another part of the same National Park.
5. The application of criteria such as whether the development is EIA development, whether it meets the 2010 Order definition, or whether it requires an appraisal of the likely traffic, health, or retail implications of the proposal will all be relevant considerations, but will not determine the matter and may not even raise a presumption either way.
6. Having considered all the circumstances, including the local context, the decision maker must take a common sense view on whether the proposed development can appropriately be described – in ordinary language - as “major development”. This will normally be much larger than 6 housing units.
The Preferred Options Local Plan for the SDNPA contains a policy (SP3) on major development which states:
‘ In determining what constitutes major development the SDNPA will consider whether the development, by reason of its scale, character or nature, has the potential to have an unacceptable adverse impact on the natural beauty, wildlife or cultural heritage of, or opportunities for quiet recreation provided by, the National Park. The potential for adverse impact on the National Park will be dependent on the individual characteristics of each proposal and its context.’
It is suggested that this could be adapted for the AONB context as follows:
‘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 on the individual characteristics of each proposal and its context.’

3. Evidence Base

Q2
The Councils should identify housing requirements (as distinct from housing need) for the AONB. This should be based on the objectively assessed housing need for the Housing Market Area (or Areas) in which the AONB sits, but should also take other factors into account. There should not be an over-reliance on the local housing needs survey, which represents a snapshot in time, only looks 5 years ahead, and is a separate and distinct approach from the Strategic Housing Market Assessment (SHMA). The requirement should also not be a simple pro rata sub-division of the SHMA need(s) because:
a) This would not take into account the great weight to be given to conserving the landscape and scenic beauty of AONBs (para 115 of the NPPF), which should be the key consideration in arriving at a housing requirement (as opposed to housing need)
b) It would not give due consideration, in relation to major development, to the scope for meeting need elsewhere outside the designated area (para 116 of the NPPF), and
c) It would not be sufficiently sensitive to the local demographic characteristics of the AONB, in particular the preponderance of elderly population which will not generate births to the same extent as in the wider HMA and whose deaths will release existing housing stock at a greater than average rate over the plan period.
Additional information required will therefore include the local population and household characteristics and the capacity for any housing need to be accommodated nearby outside the AONB, such as in Carnforth and Milnthorpe.

Q3
In addition to the evidence referred to in response to Q2, further evidence will be required on:
• the feasibility and environmental capacity of Silverdale to accommodate development based on private sewage treatment systems and/or the cost and impact of introducing mains drainage;
• the likelihood of the existing bus services, in particular the Silverdale Shuttle, surviving local government cuts and/or the feasibility of funding these services through CIL or Section 106 agreements;
• the scope for improving cycle access to Milnthorpe and Carnforth from Arnside/ Storth/ Beetham and Silverdale/ The Yealands/ Warton respectively.
• the extent to which existing community facilities (e.g. primary schools, doctors’ surgeries, library, parks and play facilities, community halls, public houses, post offices, shops etc.) can remain viable with and without further housing development and the acceptability in terms of landscape impact of the level of development likely to be required to ensure such facilities remain;
• the likely date for the introduction of high speed broadband where not currently available in the AONB and for the redevelopment of the Silverdale telephone exchange to enable affordable housing in a sustainable location during the plan period.

4. Vision and Objectives

Q4
The vision for the AONB DPD is supported.

Q5
The objectives for the AONB DPD are supported.

5. Policy Issues

Q6
The DPD should identify a proportion of affordable housing to be developed, taking into account the government’s recent proposals to include discounted market housing within this term and ensuring that such housing does not take the place of genuinely affordable social housing to rent or other intermediate housing types such as shared ownership.
There is a danger that the provision of affordable housing will be used to justify unacceptable market housing, of a type which attracts in-migration rather than catering for local need and on a scale which would have an adverse impact on the special qualities of the AONB. In order to avoid this, a very high proportion of affordable housing (in excess of 50%) should be required at any housing site and certain housing sites should be identified for exclusively affordable and local housing needs.

Q7
While it may not be possible to do this for all sites, it should be done for selected sites, especially those in the most sustainable locations.

Q8
Site-specific policies should be prepared to ensure that an appropriate mix of housing type and size is provided taking account of the latest information on housing need (which may change over the plan period) but also the specific characteristics of the site and its surroundings, in order to ensure that the house types proposed for the site will respect its setting.
Unless required for consistency within the South Lakeland part of the plan area, there is no need to duplicate Policy DM 41 of the Lancaster Development Management DPD, which states that new residential development should provide an appropriate dwelling mix in accordance with robust evidence of local housing need, and Policy SC4 of the Lancaster Core Strategy which states that the Council will aim to maximise the opportunities offered by the development of new dwellings to:
• Redress imbalances in the local housing market;
• Achieve housing that genuinely addresses identified local housing need; and
• Secure units of “in-perpetuity” affordable housing.
Indeed, the latter will form the strategic justification for site specific policies in the Arnside and Silverdale DPD.

Q9
No comment.

Q10
The DPD should prioritise brownfield land but a locally appropriate target is not realistic in view of the relatively small amount of brownfield land available. Even where brownfield land is not currently available (i.e. the site is developable but not deliverable), it should be taken into account by allocating it for a later phase of the plan period. This is likely to be the case for the Silverdale telephone exchange site, which is understood to be possibly available after 10 years.
The plan should also prioritise sites which are not strictly brownfield in terms of the NPPF definition but which have been subject to other uses such as a private garden (e.g. land at 12 Emesgate Lane in Silverdale village centre) or nursery (e.g. the part of Kay’s Nursery which does not protrude into open countryside).

Q11
The density of development should emerge from an appropriate assessment of the constraints and context of the site concerned, rather than being a rigid pre-determinant. If guidance is to be given on density of development it should be on a site-specific basis after taking account of all available information, most importantly a visual impact/ landscape assessment.

Q12
Yes, the DPD should identify land for community infrastructure. The requirements for community infrastructure should be taken from Village Plans and any subsequent expressions of interest from the local community. It is important to stress that such infrastructure should meet local needs and not those of a wider area outside the AONB. For instance proposals for a skate park and MUGA on the Institute Field in Silverdale should not be supported unless there is evidence of sufficient demand to justify such a facility from within the village’s population.

Q13
Support should be given to measures which assist working from home, such as high speed broadband. The railway goods yard site at Red Bridge Lane (S70) site, if not considered appropriate for housing, should be investigated for employment use, subject to an assessment of viability in such a location. It would be well located to serve commuters by train from Arnside as well as being accessible by shuttle from Silverdale.

Q14
Large scale renewable energy projects are not appropriate in the AONB and would be unlikely to pass the tests in paragraph 116 of the NPPF. Policies should make this clear while setting policies for small scale domestic renewable energy such as solar panels.

Q15
Policies should support existing bus services especially those serving the railway stations, such as the Silverdale Shuttle. This should be a high priority for CIL/ section 106 agreements.
Site allocations should take into account possible safety and congestion issues at peak visitor times when on-street parking may restrict visibility, such as Shore Road, Silverdale when parking on the shore itself is inaccessible or full.


Q16
In addition to further parking at Arnside station, extra parking at Silverdale station should be considered possibly in conjunction with either a housing or an employment development at site S70.
Further, well-designed parking (including disabled spaces and cycle parking) should be provided as a part of a landscaped square in Silverdale village centre, incorporating the Royal car-park and land opposite if this comes forward for housing development at a later phase of the DPD. Such a scheme was promoted through the Silverdale Village Plan and should be given strength as a material consideration through allocation in the DPD and through the Infrastructure Plan/ CIL Infrastructure Schedule and/or relevant Section 106 agreements.
There is also scope for car-parking to serve Silverdale village centre on land to the rear of 17-21 Emesgate Lane, with access off Bank House Lane, adjoining the public toilets.

Q17
The existing policies in the Lancaster DM DPD and the South Lakeland Local Plan give the right approach. They may be helped by specific policies in the AONB DPD, especially to clarify the limited permitted extent of caravan parking at Gibraltar Farm and restrictions on events and noise at this sensitive location.
Static caravan sites already have an adverse impact on the scenic beauty of the AONB, although they also bring welcome expenditure to support village facilities. Measures to restrict their impact, such as agreements to control the colour of replacement caravans and schemes for landscaping more exposed locations, should be investigated. A policy to support and encourage this should be included in the plan and such measures could form part of section 106 agreements when proposals for redevelopment / extension of caravan site facilities (as recently constructed at Holgates) come forward for approval.

Q18
The elements suggested are sensible. One additional element, however, should be the extent to which the site is potentially under threat from development pressure. This might apply to some of the unacceptable sites put forward as part of the call for sites.
There should also be reference within the criteria to the extent to which the site contributes to the special qualities of the AONB as set out in the Statutory Management Plan 2015.

Q19
I am not convinced that all of the land shown adequately meets the criteria set in paragraph 5.29. While I would support the protection of most of these sites from development, they could equally be protected by general countryside policies and the blanket approach to some areas, apparently based on ownership by the National Trust, creates a danger that the concept of Important Open Space is devalued and that sites not so allocated have a ‘second class’ level of protection.
In order to avoid this, there should be either a much wider spread of land included in this category, or a more selective approach to the sites put forward. For instance, while part of Site S61 (The Lots) is extremely important and meets the criteria, the north–eastern part of Bank House Farm is arguably less so, while Site S68 (Lodge Meadow) is an isolated field on Hollins Lane with no relationship with the existing settlement of Silverdale. Where such areas are protected through ownership by the National Trust or others, giving them spurious additional protection could undermine the conservation of other land in private ownership.

Q20
If the extensive areas of designation as Important Open Space shown in Silverdale remain in the DPD then other land under threat from development and with as much or more contribution to the landscape should be included, such as sites S43, S50, S54, S55, S56, S58, and S98.
In particular the small valley west of Lindeth Road (Sites S56 and S S58, together with part of Site S46/S41) forms an important part of the setting of the village and is an excellent example of the landscape described by the Statutory Management Plan for the AONB as part of the first special quality (Outstanding Landscape and Spectacular Views) as follows:
“The small-scale yet complex nature of the landforms gives an intimate feeling within valleys and woodlands which contrasts with the open nature and expansive views from higher ground and along the coast.”
Other areas of land to be considered for designation as Important Open Space are:
• The Institute Field, Spring Bank
• The playground, Cove Road
• The bowling green, Cove Road.

Q21
All views from existing public rights of way, including glimpsed views between frontage development, should be protected; but such protection should not be confined to public viewpoints and should apply to green corridors adjoining existing settlements regardless of public access to them. The landscape and countryside of the AONB must be protected for its own sake and development on greenfield sites, especially that which comes within the definition of major development, should be refused except in exceptional circumstances and in the public interest. AONBs have the highest status of protection in relation to landscape and scenic beauty and such national designation will normally outweigh local development needs.

Q22
Existing policies are probably adequate, but if a greenfield site is allocated for development the opportunity should be taken to protect and enhance biodiversity on some of the land within or adjoin the site.

Q23
Development in Silverdale should be restricted to a level which will not harm groundwater quality and which would not result in harm to the internationally recognised SSSI/ SPA of Morecambe Bay. Since there are no watercourses in Silverdale as a result of the heavily fissured limestone bedrock, any packaged treatment plants or individual sceptic tanks need to discharge into a drainage field which must meet the requirements of the Building Regulations and be at least 15metres away from any building. A specific policy relating to the requirements for foul and surface water drainage in Silverdale should be included in the plan and any site allocations should only be made once it is established that these requirements can be met either within the site or on adjoining land in the same ownership. This is especially critical for sites close to the shore where effluent may drain quickly into Morecambe Bay, contaminating bird feeding grounds, possibly even after treatment and certainly in the event of poor maintenance of plant or power cuts (which are not infrequent).

Q24
Existing policies may be adequate.

Q25
Development should avoid the ‘suburbanisation’ which has occurred in several settlements in the AONB to date. The DPD should seek to define the crucial elements of design which contribute to the built character of the AONB, as opposed to those which detract from it. These should form the basis of design guidance for allocated sites and for windfall development.

6. Options for Meeting the Objectives and Delivering the Vision

Q 26
Given the need to ensure that the landscape impact of any development is minimised, I consider that any sites in secondary settlements should not be ruled out if their environmental impact is acceptable and they meet a local community need. I do not consider that reliance on exceptions sites and /or an assumption of some development elsewhere will achieve this. Although such sites may be less sustainable than sites in the Primary Settlements, it must be accepted that travel by private car will remain the main mode and that this can only be mitigated to some extent by support for bus services and cycling.
I therefore consider that option (v) is the most appropriate approach to development in the AONB. I do not consider that this approach need necessarily rule out the possibility of additional housing on windfall sites and that an assumption can be made about a small amount of development on such sites, typically large gardens, coming forward in the future as they have done in the past. Indeed some of the sites identified under the call for sites come into this category and should be treated as such rather than being specifically identified in the DPD.

Q27
I attach a table commenting on the sites put forward for development in Silverdale. All sites must be capable of meeting Building Regulations in relation to the treatment and percolation of foul and surface water drainage. In summary, I consider that they can be grouped as follows:
Sites Suitable for Development
S47 Land between 10B and 12 Lindeth Road (subject to retention of the views through the site to the valley beyond)
S49 Land east of 12 Emesgate Lane (subject to availability; best developed towards the end of the plan period as part of a comprehensive scheme for the whole site in accordance with a planning brief to ensure it contributes to the improvement of the village centre).
S53 Land south east of Woodlands Hotel
S54 Land south of Cove Drive
S70 Railway Goods Yard, Red Bridge Lane (employment use)
Sites Suitable for Development in Part
S46 Kayes Garden Centre, Lindeth Road (south-eastern half of site only)
S48 Land east of Lindeth Close (northern part of site only)
Sites not Suitable for Development
S41 36 Lindeth Road
S42 Blue Hills Cottage, Spring Bank (already developed)
S43 Elmslack Field, Cove Road (but the frontage onto Cove Road, apart from a narrow field access, may be suitable if justified to meet local needs and if developed in such a way as to ensure no future extension onto this site)
S44 Hawes Villa, Moss Lane
S 45 Hawthorn Bank, Cove Road (but possible space for one dwelling in the grounds)
S50 Land east of St John’s Avenue (but the frontage onto St John’s Avenue, apart from a narrow field access, and a small corner to the east of St John’s Grove may be suitable if justified to meet local needs and if developed in such a way as to ensure no future extension onto this site)
S51 Land north of Woodlands Cottage, Woodlands Drive
S52 Land east of Hawes Villa, Moss Lane
S55 Land south of Park Road and east of the Row
S56 Land south of Whinney Fold (but a small area at the northern extremity of the site may be suitable if justified to meet local needs and if developed in such a way as to ensure no future extension on this site or into site S58)
S57 Land south of Windy Ridge, Wallings Lane (but possible site for one carefully designed house)
S58 Land west of Lindeth Road
S98 Sixteen Buoys, Ford lane, Waterslack

Q28
Sites which might be suitable for development in sustainable locations near the village centre are set out below. There are several sites which form parts of large private gardens the availability of which are dependent on owners’ intentions. They may not be allocated but instead form part of the evidence to support a windfall allowance. The possible exception to this is the curtilage of 12-14 Emesgate Lane. This central site is understood to be not currently available but it which offers an opportunity to enhance the village centre. It could therefore be allocated for development towards the end of the plan period, subject to a development brief.
• Telephone exchange, Gaskell Close (after 10 years)
• Curtilage of 12-14 Emesgate Lane, including site S49 (after 10 years)
• Land south and south-east of Clarence House, Silverdale Green
• Land north of Hillcrest, Spring Bank
• Land west of Bradshawgate (possible access via S45 and/ or through gardens on Bradshawgate)
• Land west of 29 Emesgate Lane/ Green Arbour/ Bleasdale School (subject to access and existing uses)
• Site of / west of 31 Emesgate Lane
These sites will need further investigation in order to establish their deliverability and (in some cases) developability.

Q29
Yes, I believe that the DPD should identify development boundaries in order to provide more certainty about the protection of greenfield land in the future and in order to provide a clear indication to potential developers. This does not, of course, rule out the possibility of exceptions sites outside the development boundaries where appropriate. It should at least apply to Arnside, Silverdale, Storth/ Sandside, and Beetham. I am not clear on the practicality of defining meaningful boundaries for the other four settlements.

7. Delivery of Development

Q30
Yes, the DPD should phase development in three 5 year bands to correspond with those in the NPPF (para 47). This will allow at least some of the sites above to come forward at later stages and ensure that local housing needs are met throughout the plan period and not just at the beginning when an over-supply could encourage in-migration. Phasing based purely on infrastructure coming forward would not achieve this.

Q31
No comment.

6. Options for Meeting the Objectives and Delivering the Vision

Appendix to Consultation Response from Keith Reed: Site Assessment Table

This constitutes a table which cannot be copied into this space. I will therefore send it separately by e-mail.

2. Background

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5. Policy Issues

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6. Options for Meeting the Objectives and Delivering the Vision

Once again I feel I must put my views in opposion regarding proposed building sites in warton (the sites in question are w87/88/89/92/93/95 ) there is no reason whatsoever to build on green field sites when there are grey sites available for example at millhead (the old gravesons site) I would also like to point out the extra congestion and insufcient infrastructure in place, there is also a serious problem of extra flooding if building goes ahead. In our area there are new houses standing empty so I cannot see the reason to build any more example at halton. Surely common sense will prevail and leave our nice village and comunity alone.i would also remind you that warton is in a anob.

6. Options for Meeting the Objectives and Delivering the Vision

Comments on proposed site W84. (Land between 14 and 48 Main Street)
1. This site is currently under water; as it is every winter and during any period of heavy rainfall. Any building work would require the ground level to be raised by at least 1 metre, with the risk of raising the water level in the field and increasing the flood risk to other properties. Foul water drainage would inevitably be below the high water level, with the risk of polluting the environment if any leaks occurred.
2. The pavement on Main Street adjacent the proposed site is the closest/best position for the public, and birdwatchers in particular, to watch the wildfowl, (swans, ducks, geese, gulls), on the flooded fields in the winter, and lapwings nesting in the spring time. This viewing position also provides superb views across the fields to Millhead and beyond all year round. Building houses on this site would deprive the Warton residents and the public in general of one of the finest views in Warton, and harm the visual amenity of the AONB

Continued comments on proposed site W84. (Land between 14 and 48 Main Street)
3. Any building work on the proposed site would deprive my house of some light, and totally deprive me and my neighbours of the views described in (2.) above which have been enjoyed by residents for over 100 years since the first houses were built.
4. Building on the proposed site would of necessity mean traffic problems, access problems, noise, mess and general inconvenience for the inhabitants of Warton in general, and the home owners opposite the proposed site on Main Street in particular.
5. Prior to any new developments on any site in Warton a decent pavement complete with street lighting must be constructed between Warton and Millhead. The current pavement is too narrow and pedestrians are at risk every time they use it, especially in wintertime when cars have difficulty seeing pedestrians due to oncoming headlights and the risk of collision is greatly increased.

By the criteria laid down in the scoping report, development of site W84 should be excluded on the grounds of:
1. The proposed site is in a flood zone
2. It would harm the landscape character of the AONB
3. It would harm the visual amenity of the AONB
4. Result in the loss of an identified area of open green space

6. Options for Meeting the Objectives and Delivering the Vision

I would like to express my objection to the development of green field sites in Yealand Redmayne. Firstly, Yealand is within an area of outstanding natural beauty, it is also a popular area for walkers and tourists. New builds would spoil the village and surrounding countryside. There are brown field sites available for development locally e.g Milnthorpe and Sandside - locations of previous industry. There are also buildings which are empty and dilapidated, why can't these be developed? Have we not lost enough of our green field sites already?
Secondly, the access to the village and surrounding area is by narrow country roads. Each new build is likely to have at least 2 cars. Eight acre running into nineteen acre lane is already a busy road with traffic accessing the Yealands as well as Silverdale and Arnside. Increasing the population in this area is likely to make the roads more dangerous to road users, including horse riders, cyclists, pedestrians as well as car drivers. Traffic also increases during the tourist season.

3. Evidence Base

Q27, Warton is AONB and therefore it is simply not possible to build on any greenbelt land within this area. Warton itself has other areas where houses could be built. Warton grange farm is going to be developed into housing, therefor no other areas in warton need considering.
Q28, In millhead before the bridge coming from warton there is a large redundant brownfield site which is waiting to be developed also warton grange farm is going to be developed so there willl be housing available there.

Dear Sir,
I would like to add a few comments regarding the proposals for building houses at Warton, Carnforth.
I am concerned about the adequacy of the infrastructure.
1. Any new building would need considerable improvement to the sewers and sewerage system of the village; already this is inadequate and has no capacity for more use. Is this included in the proposed development?
2 The roads through the village are few, narrow and dangerous with no footpath at all in some places and inadequate footpaths when they do exist. It is difficult to see how this problem could be solved. Are there proposals to include widening of the road to Carnforth, and provision of footpaths and lighting on that road? The 20 mph limit has been an improvement in the village in so far as it is observed; a widened road might perhaps become a race track ! The bridges would also have to be updated.
3 There are now no shops in the village so more houses would necessitate more cars and more traffic.
Is there any provision for shops to be included in the plans, and if so, where would they be and how would they affect the nearby residents?
4 There is not much requirement for employment in the area. This would mean people would have to travel, so again this would cause increased traffic. Carnforth main street is already a bottle neck; this would be exacerbated !
5 There is a considerable risk of flooding in the village. This has already been increased by the building of houses off Sand Lane. and on the site of the old stables there. It is quite noticeable when the rain pours down the road like a river, and floods into the front doors of the houses on Main Street.. They seem, these days, to be permanently protected by sand bags and some have installed a permanent flood defence.
It is already noticeable that the number of springs pushing up the road surface and forming potholes has increased.
In short the village needs grassy areas to soak away the excess water. (If global warming is proved a reality, this would be even more so. )
Is there a demand for more houses in the village ? There always seem to be several for sale.
I have no doubt other people will be contacting you about these concerns. I hope they will be given serious consideration.
Yours truly

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Dear sirs

Objection to sites for devlopment at - W87 (north of Mill Lane and Town End Fold), W89 (north west of Sand Lane 2), W88 (north west of Sand Lane 1), and W92/93/95 (south east of Sand Lane 1).

I believe that the above document is being discussed. As a resident of XXXXXX I would just like to share my views with you.
Myself, my wife and 2 kids moved to XXXXXXX around 3 months ago. We'd made the move from renting to owning and what we loved so much about the property (XXXXXXXX) was the fantastic views of the crag which could be seen from outside the house and from numerous windows inside. We also have 2 cats and the location was absolutely ideal for them to run free in the fields directly surrounding us. In our opinion a perfect place to start our home owners journey.
I can't express how much this upsets us to think that all that could be taken away from us with the proposed development. These were some key features that bought us to Warton and ultimately sold the house to us.
It's not just the amazing views that would be lost. I believe it would have a big effect on the wildlife surrounding and would make Warton busier with traffic in a town that is not designed for bigger development. The proposed development would look out of place and would ruin the outstanding natural beauty of where we live.

Thankyou for taking the time to read my message and I hope you will support my families objections and help in keeping where we live the way it is.

Kindest regards
Chris Saxon

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6. Options for Meeting the Objectives and Delivering the Vision

Q27.Have you any comments on any of the sites put forward?

As I write, site A22 is under water. Any proposal to build on this would seem foolhardy in the extreme.
For the AONB, appearance is everything. Whether arriving in Arnside by car, along the road from Milnthorpe, or by train, the first views of the AONB are of the pasture along the hillside, comprising areas A12, A14, A18, A22, A23, A24, A26. Building development on these areas would completely change the character of the AONB. Far more suitable would be development of areas where there has already been building, such as A28 and A29

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5. Policy Issues

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6. Options for Meeting the Objectives and Delivering the Vision

Question 27.
Site Y103 Land west of Footeran Lane.
The development of this site would not only constitute a clear instance of ribbon development into the strip of open countryside separating the villages of Redmayne and Conyers, but would also cause irreparable harm to the setting of an important cluster of historic Grade 2 listed buildings on the southern edge of the village (Storrs Farm, Storrs Holme and Storrs Grange). The location of these buildings at the perimeter of the village makes them an especially important part of the village aesthetic, and this area of the AONB, since they are the most visible feature of the village as one approaches from the south along the road, or from the footpath descending from Cringlebarrow.
The development would result in a loss of productive agricultural land, and of a green space currently separating the two villages. The proposed site borders a very narrow lane, and any widening of that lane would damage the rural character of the village still further.

The beautiful historic buildings of the AONB are a most important feature of its landscape, and must be respected in themselves, but also in their setting. Their construction from local limestone makes them one of the most distinctive and attractive features of the area. There is little point in imposing severe restrictions upon the owners of these properties if inappropriate developments are to be allowed in very close proximity to them.

1. Introduction

Introduction 121. - The most important part of the Introduction is the commitment to conserve and enhance this Area of Outstanding Beauty, and allocate land for development which shows a preference for land of lesser environmental value.

These tenets should form the basis of any development proposals, and should specifically exclude consideration of productive and sustainable agricultural land for any such development. It is far too easy an option to sacrifice 'greenfield' sites for development and this should be resisted at all costs.

In preserving the unique characteristics of the AONB, the discrete villages of Beetham, Storth, & Arnside must maintain their existing boundaries, if they are not to merge and be subsumed into linear sprawl from Milnthorpe to the coast at Arnside.

3. Evidence Base

I object to proposed building on site W90. Building houses directly looking into school grounds is extremely risky and would unsettle the school and residents. Would all the proposed residents be vetted and crb checked as they would be looking out at young school children. The road network at that side of the village is horrendous and has regular congestion due to buses and wagons. There are no facilities in warton except a pub and post office so to increase the inhabitants by a significant number seems badly thought out. I believe it would significantly effect the school with many children leaving with my concerns and years of building work making use of the school fields unusable.

5. Policy Issues

Question 17 In my view there is more than adequate provision of caravan sites in the AONB and no need for the extension of existing ones.
Question 27 (Comments on proposed development sites):
S44 Hawes Villa This site is adjacent to a nature reserve and is already heavily developed with static caravans, trailer caravans and motorcaravans on the site. There is probably considerable "agricultural" run-off from the keeping of pigs and horses into Hawes Water. There is minimal access to the area.
S52 Hawes Villa This is relatively unspoilt as yet and would be better designated as open space as it adjoins the nature reserve area. There is minimal access.
S98 16 Buoys This small site is one of the finest botanical sites in the AONB, the idea of its being "developed" is horrifying! Apart from anything else it is home to Spring Sandwort which is nationally scarce. I'm surprised it isn't designated an SSSI.
S50 St Johns Ave The houses of St Johns Ave/Hazelwood are already just visible on the skyline from afar (You can see them from the Howgills) - extending the housing down the hillside from St Johns Ave would affect the aspect of the whole area. It would be better designated as open space. There is also limited access, so more road building would be required if it were developed.
A2 Far Arnside This is a rock and shingle shoreline, unsuitable for any sort of development.
A97 Middlebarrow Quarry This is just starting to recover from its industrial past. The ponds have been colonised by newts, there is a developing cover of birch trees and peregrine falcons may often be seen. Together with the adjacent Middlebarrow Wood it would make a good open area, or indeed nature reserve. There is very poor access and a railway crossing is necessary.
A7 High Close This is surrounded on all sides by green areas, development would completely spoil its aspect.
B31Slack Head road. The existing caravan site is aleady something of an eyesore, developing the adjacent area would destroy extensive wooodlad and ruin the aspect from the other side of the valley.
B73 Marble Quarry - This appears to be the Deepdale landfill area which is hardly suitable for any sort of development - you can still smell the gases of decomposition coming up from below! Besides which it is now well colonised with vegetation and starting to recover from past ill treatment.

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5. Policy Issues

Question 7. Houses should be restricted to people who will be using them as a main residence in order to maintain the vibrancy of the community, no holiday homes should be allowed at all. They shouldn't be solely limited to locals although priority should be given to young people who have grown up in the area, followed by people from SLDC and Lancaster Council areas. Young people from the Lake District are already priced out of the market within their own areas so have to look further afield, with the AONB being a good compromise-it would be disappointing if this choice was also taken from them.

Question 9. Limited housing development in rural areas should not be completed discounted if it can be managed to avoid spoiling the nature of the area. In this instance the local community could be enhanced without causing inconvenience, distress or discomfort to the existing residents, who have chosen to live in a rural location with immediate access to open spaces. For example sites 100 & 102 should be discounted due to the levels of disruption and distress caused to a number of existing residents.

Question 11. Yes where possible brownfield sites should be used, as well as areas next to brownfield sites in order to reduce the impact on the natural environment.
Density should also be highly limited (with specific reference to the more rural areas of Beetham and the Yealands). New affordable housing tends to be very dense and this would not suit the setting or indeed the people who would choose to live in such an area. People who would like to live here wish to do so because of the open spaces and views, not because they wish to live in large housing estates. This is not normally a considerations for new or affordable homes and given the unique location should be treated with high priority.

Question 13. Live work spaces would be a good idea to promote small scale local business opportunities. The re-use of old or derelict buildings should be prioritised before new building works. It is important to remember that many employment opportunities already exist in the local area with excellent transport links to these with the A6 and railway line.

Question 15. Services and in particular access and highways is a key issue in deciding which developments and which sites should be allowed to progress. Only sites with direct access from a main route should be considered in order to protect rural roads from overuse and damage. For example 99, 101 & 103 should be considered more favourable than 100 (which should be immediately discounted) due to poor access from very narrow roads which could not cope with the increase in residential traffic, let alone construction traffic.

Question 20. The land to the North and East of The Meadows should be designated as open space because the housing density of that particular area is already fairly high for the area. In order to protect the nature and feel of the local area additional housing should not be added within this vicinity.

Question 21. Very limited development, if any should be allowed in the most rural areas of Beetham and the Yealands in order to limit damage to the settlement identities and the local landscapes. Instead priority should be given to suitable developments in larger settlements where the effect will be felt less and where there are more services and amenities already in existence.

Road safety for site 100. Access to the Meadows is very narrow and extra traffic could cause incidents to occur. Most importantly the main access route to this site is directly past the village play area, putting local children in danger from general traffic and especially construction traffic. If children were prohibited from using this area due to safety concerns it would be very damaging to the local community. Site 100 should be immediately removed from the plans as it is not suitable for many reasons.

Dear Sir,
I make the following points with reference to the planning policy for possible housing development in Yealand Redmayne. There are three areas proposed; two of them, those postulated on the northeast side of Silverdale Road at the northern exit to the village, give me great concern.
My major worry is the traffic flow coming off the A6 road up Nineteen Acre and Eight Acre lanes on to Silverdale Road in the middle of our village. The components of this traffic are threefold:-
1) Domestic - cars travelling to and from work from the Silverdale and Arnside areas. This traffic is numerous and generally exceeds local speed limits.
2) A high number of commercial vehicles - large trailers carrying caravans to and from the various sites, delivery vehicles such as the daily CO-OP lorry and now many vans delivering groceries ordered on line (e.g. Tesco).
3) Agricultural vehicles, cattle trucks, tractors, etc.
This results in a very high density of traffic using Silverdale Road.
The postulted development on the land behind number 40 Silverdale Road means more traffic coming out on to the already crowded main road. Additionally vehicles from the proposed new dwellings will join vehicles from the current five dwellings using what is already a single track lane. This traffic coming out at either end of the lane has very poor visibility and also for passing traffic.
All of the above is even more relevant to the larger development on the north east side of Silverdale Road as the road exits the village. It would appear that these homes would require their own access road (parallel to Silverdale Road) joining the single track lane behind number 40?
My second point refers to the aesthetic view of our village. Both of the above developments will have a detrimental effect on how the village looks. Indeed, the larger option can only be described as ribbon development which surely is to be decried in an AONB.
I do understand that housing is needed in rural areas and as such the proposal to enlarge the centre of our village in the ‘Meadows’ area is probably the best option. There is already reasonable safe road access and the traffic using Footeran Lane is far less than that using Silverdale Road.

J. W. Stokes.

6. Options for Meeting the Objectives and Delivering the Vision

Identifying sites
The main requirements for the Village of Warton in respect of any prospective Development are in my opinion.
1. Avoid making the traffic and parking problems any worse than they already are, especially between Borwick Lane and the Malt Shovel which are currently choking the village and potentially an accident waiting to happen, any development discharging traffic onto Main Street within these limitations would exacerbate the current situation.
2. Ensure that there is no encroachment of any unsuitable development within the recommended limits of the Warton Crag SSSI ‘buffer zone’ that would be of detriment to the environment and habitat of the Crag and detract from the rural aspect of the approach slopes.
3. Maintain the character and environs of the Conservation Area of the central village.
4. The provision of low cost affordable housing for first time buyers or older downsizers, 1, 2 bed houses and flats and somehow create a preference for people with the minimum of personal transport or even none, this however would have to be backed up with a much improved public transport system.

The potential sites for building dwellings as above are very limited, in that the centre of the village should be eliminated for the reasons in 1 and 3 above and the residential corridor of Main Street from the Malt Shovel to the junction of Sand Lane is restricted in that to the South is a flood plain and to the North, behind the existing houses, development would encroach on the SSSI buffer zone.
Therefore it would appear that the obvious sites for development would be beyond the junction of Sand Lane and Main Street, going south and south west i.e. towards Millhead (but not within areas that would be affected by flooding), and along Sand Lane.

Developers apparently have a major say in the type of housing they build notwithstanding the Local Authority recommendations and the requirement for Sustainable Development to suit the village needs, profit obviously being the major factor. Surely Developers can make the same % profit on cost regardless of the type of housing that cost is spent on, or do they make excessive profit on larger houses?

I would suggest that the more large detached houses that are built, that number could be multiplied by 2 or 3 and, if built in the wrong location i.e. in the confines of the village, that would be the number of cars adding to the village congestion.

Also we must ask is there a need for large houses in the village, there are currently a number of large houses under occupied so I would think not, albeit that should large houses be built, they would sell due to the desirability of living in the village.

1. Introduction

I haven't been able to find the individual site assessment which the website says would be published summer 2015. Without that it has been difficult to understand why some sites have been proposed for designation as 'open space' whilst other sites which appear to me to have more of the characteristics of coastal pasture have been proposed for development.

The online paperwork has been difficult to access due to very slow internet speeds in SIlverdale. I had to download the documents at work in Lancaster. This online form has also been difficult to complete and it has taken me signficantly longer to do than if I had been living somewhere with faster and more stable internet connection.

3. Evidence Base

Q2 - The housing availability and opportunity for development should be considered in the context of the entire area rather than just for a specific parish. Carnforth is really the centre of the local rural area and it would be wrong,in my view, to ignore its proximity and service provision for the entire area in terms of excellent transport links, secondary school, supermarkets etc. Why not also include it when considering the accommodation mix?
Analysis of the turn over rate of those living in existing low cost rental accommodation and over 55s provision in Silverdale. It is rare for there to be availability - but there seems to be a reason that people don't want to move in, especially to Whinney Fold.

Q3 - County Council savings are requiring the closure of the Silverdale library, and it has been looking to get rid of the Silverdale Shuttle Bus for years, as it is the most subsidised public transport in Lancashire.

Public transport in Silverdale is so poor (and likely to get worse as council savings bite) that development of the village must follow what it can sustain. Officials should also be aware that although there is a railway station in Silverdale, there are no walking routes to and from the station to the main residential part of the village. For those replying on the trains as a means of getting to and from work, the bus is essential - but not always reliable! Many choose to drive (or get a lift) which is not viable for all. The village is, therefore, an isolating place which suffers from the rural premium in terms of Indices of Multiple Deprivation more than Arnside, for example.

Off road walking and cycling routes are desparately needed around Silverdale, including to the railway station and onwards to Carnforth. Not only would it make the station accessible (safely) on foot, but it would enable those wanting to get to Carnforth on foot or by cycle (or those visiting Leighton Moss to get from the station to the visitor centre without having to walk on the main road) to do so without dodging traffic (often in the dark on these winding country roads). My teenage daughter has on several occasions been stuck at the station after school unable to get home as the shuttle bus has failed to arrive (or the train has been delayed and missed the shuttle bus link). With such a time between buses, it is a long cold wait in the dark after school on winter evenings - especially when it is raining. It is not safe to walk.

The road from Silverdale to Carnforth is also part of the national coastal cycle route. This narrow winding road which floods regularly is an accident waiting to happen. On off road track along the course of the railway line (for example) would make sense and be a fabulous addition to the area.

5. Policy Issues

Q6 - The DPD should not identify the proportion of affordable housing in the parish (or AONB) but rather for the wider rural area - I would suggest Carnforth and its rural hinterland would be more appropriate.
Q7 - No BUT this is an area with a high rural premium. People need to understand what they are getting into living here if they work outside of the village.
Q8 - No - don't micromanage it - let it be led by market forces. However, the council does need to set high standards for the type of housing built. It should be in keeping and beautiful.
Q10 - YES - why such a low target level? Surely in an AONB the aspiration should be for there to be development only on brownfield sites (such as S46 and S70). Rather than a targtet of 28%, I would like to see it as 100% (or pragmatically and with allowance for additional backfill between existing areas of development then maybe 75%). But 28% is too low - and very specific - maybe explaining the rationale for this figure would have aided clarity about the proposal. Whilst I agree with Lancaster City Council's focus on urban developent, there should surely include a target for brownfield development at least when it comes to places outside of the urban core.
Q11 - The AONB should seek to guide the density of new development across the whole local area, not just within the AONB - density should be based on providing the required housing on available brownfield sites rather than defining how much space each property requires. Cutting cloth based on what's available is more important than ripping up green fields in an AONB. Future generations will not thank us for urbanising protected landscapes to increase developer profit margins.
Q12 - Community infrastructure - Inclusion of the Silverdale Insitute as protected land would seem to be at least as valuable to the community as the Lotts and Cricket Club which have been proposed for protection as open space. Also off road walking and cycling routes to Carnforth would improve things for local people and visitors to the area, including those using the national cycle route which is targetted at families cycling from Barrow to Glasson Dock - and which is incredibly dangerous on the narrow winding roads without pavements in this area.
Q13 - empty shop spaces in the centre of the village should be targetted for new development. To encourage more modern businesses in Silverdale, improvements are required to internet connectivity for all. It has taken me a ridiculous amount of time to complete this consultation response due to the instability and slow speed of the connection.
Q14 - solar panels on the roofs of old properties make a significant change to the look and feel of the AONB and I am surprised that they have been allowed. However, all new build properties should be required to include solar panels and encouraged to incorporate the latest energy technologies (who know what they might be in the future). Furthermore, I would not no energy farms please - wind turbines or fields covered i solar panels would not be in keeping with the character of this AONB.
Q15 - as identified previously - off road walking and cycling routes would significantly improve road safety.
Q16 - I would like to see areas in the centre of Silverdale allocated for carparking. Saturday morning is a particular problem but actually most times between 8am and 10pm there are problems.
Q17 - coastal views from all parts of the Bay should be respected and, as such, the visual impact of recreational developments such as caravan sites should be minimised
Q18- No - I would like to see more of the elements identified in the Landscape and Seascape Characteristic Assessment - the elements included in 5.29 are generic - those in the document above are what make Arnside & Silverdale AONB what it is!
Q19 -I do not understand why the northerly part of S67 (the half north of the hedge which divides this site) and S69 have been identifies as Important Open Space. They certainly do not seem to me to fit the criteria as well as sites S56 and 58.
Q20 - I do not understand why S58 and S56 have NOT been identified as Important Open Space. They are rolling coastal pasture which contribute to the rural character of the area, opening up views and adding to the variety of sights, sounds and smells. It is bounded by a public right of way which is well used by visitors and villagers alike and the stream running through it, the ancient hedgerows, trees and limestone walls bounding them, offer significant benefits to wildlife for food, rest and shelter, including for birds from Leighton Moss which often come here during poor weather. These fields also act as the soak away for all of the septic tanks from surrounding properties..... Sitting on top of limestone, the pond and stream which floods when it rains both identify that development in this area would cause problems for properties built in these low lying fields.
Q21 - by comparison with the report on Landscape and Seascape characteristics
Q22 - limit developent to brownfield sites only - and avoid developing in areas which flood (and close to them as this will exacerbate the flooding)
Q23 - As identified above, the pasutres comprising sites S56 and S58 are the soak away for all of the septic tanks from surrounding properties..... This is a thin layer of soil sitting on top of limestone, the pond and stream which floods when it rains both identify that development in this area would cause problems for properties built in these low lying fields.
Q24 - The councils should maintain high expectations and aspirations for all new developments in the AONB - developers should be pushed to provide excellent (rather than cheap) developments which respect out local traditions. Our community is more important than their profit margins. They should also be encouraged to be cognaissant for building materials in this coastal setting - for example wooden clad buildings may look pretty for a start but without significant maintenance they quickly deteriorate. Local building materials are more appropriate.

4. Vision and Objectives

Q5 - I would like to see brownfield sites mentioned in this Vision - highlighting the importance than new developments will, wherever possible, be focus on brownfield sites so that greenfield sites in this area of beauty are not ripped up when there are derelict and low grade sites stand empty because it is cheaper for developers to develop a new site rather than dehabilitate an old one.

6. Options for Meeting the Objectives and Delivering the Vision

Table 2 - Silverdale library is proposed for closure by the County Council - with the degree of cuts requred, saving it is inconceivable
Q26 - S46 and S70 are brownfield sites with good public transport links - in fact S70 would have the best transport links if an off road walking route were included to the railway station (which obviously includes the bus stop). The scrub land which is currently proposed for designation as open space (S69) could also be included as it fails to meet the criteria set out in this document for designation as open space. Without access to your site assessment document, it is not possible to know. Similarly, the northern apart of site S67 should be considered for development rather than designation of open space.
Q27 - My comments on many of these sites are included throughout my response, however, for completeness I will go through site by sit with my comments:
- S46 - this brownfield site would make an excellent development opportunity. The site is currently a mess and development would be a benefit to the local area. Furthermore it has excellent local transport connections and beautiful views across open countryside - which should afford the developerplenty of opportunity to make enough profit on the open market properties to enable them to include significantly more affordable homes than would be the case in an area for which the profit margin is lower.
- S47 - the steep aspect of this site makes it difficult to understand how it could be used for residential development.
- S49 - this backfill site would be in keeping with the surrounding developments and, if linked to the site next to the GP surgery, would bring another undevelopable (due to poor access currently) scrubland in the centre of the village into use.
- S56 - this coastal pasture has all the attributes of a landscape which should be preserved rather than developed. Furthermore, the proposed site extends into an area outside of the current ilne of development.
S58 - this is a curious site to include for possible development. It has all the attributes of a protected landscape, floods regularly and is the soak away for all of the surrounding septic tanks - many of which date back over 100 years....It should be automatically excluded as it regularly floods - I have recent photos of two extensive areas of flooding on this site should you find them useful. Furthermore, together with development of the adjacent sites which have been proposed, this site would consistute a major developent which is not in the public interest and would be the largest single development in SIlverdale ever.
- S67 - the northerly half of this site would make more sense to develop (as it has excellent access and is located between two existing residential areas) rather than keep as unaccessible open space. If designated as open space, I would like to see it make accessible for local people rather than grazed occasionally by animals.
- S69 - I can see no value in designating this low grade scrubland as open space
- S70 - this would be an excellent development site for residential or employmet use
Q28 - the plot of land which is for sale adjacent to the doctor's surgery but has very poor vehicular access
Q29 - development should be restricted in accordance with the Landscape and Seascape character assessment to protect important aspects of our landscape. I would like to see more of the themes from that document included in this DPD - or to see it appended to this DPD so that its findings are not lost in the future when new developments are proposed. Setting specific development boundaries does not seem to me like the right way to go about doing this as what should and shouldn't be protected over time may change. One thing I am particularly passionate about is protecting views from the Bay as I think the caravan development at Far Arnside, whilst beautiful for those lucky enough to stay in them, has made a mess of the view for the rest of us looking at them from other parts of the coastline.
Q30 - this should be a rolling plan which is reviewed every 5 years. Only the forthcoming phase should ever be considered in detail for specific developments as things change so much. What is currently a thriving site may find itself derelict and a potential brownfield site (and vice versa)

7. Delivery of Development

Q30 - this should be a rolling plan which is reviewed every 5 years. Only the forthcoming phase should ever be considered in detail for specific developments as things change so much. What is currently a thriving site may find itself derelict and a potential brownfield site (and vice versa)

5. Policy Issues

Paragraph 2.18
Q.1. Yes the AONB DPD should define what constitutes a major development
to protect the distinctive settlement character of Silverdale and area.
No more than 4 houses

Paragraph 3.5
Q.3 The DPD needs to take into account the planned cuts in public transport. It is likely
that Silverdale will have no bus service and several trains do not stop at Silverdale station.
It also needs to take into account Silverdale's septic tank system which needs adequate area for drainage.
There are problems with septic tanks draining into surface water drainage and onto the shore

Paragraph 5
Q7 To preserve character of AONB new development should be restricted to local people and for sole/main occupancy
Q8 Planning permission should not be given for house with more than 3 bedrooms, there are plenty of large properties already.
Q10 Brownfield sites should be prioritised, and no greenfield sites used.
Q11 The density of new housing needs to be guided to preserve the AONB's character.
Q18 Would be appropriate to add for designation of open space assessment that it should lessen the density of
buildings to preserve tranquillity and dark skies.
Q20 S58 west of Lindeth Road Silverdale should be re-designated as open space to conserve tranquillity and dark skies
in a densely populated area. It is worth noting that the pond has become a large lake in recent storm.
Q23 Silverdale with no mains drainage needs to preserve land to provide drainage. We already have a problem with septic
tanks draining onto the shore.
Low lying fields with run off from surrounding higher land are also at risk of flooding
Q25 Any new builds in AONB should have some limestone facing to fit in with area.

Paragraph 6
Q26 Option vi provides the most advantage for all localities. Availability of public transport is not going to be an option it seems.
Q27 Site S56 land south of Whinney Fold Silverdale would constitute a major development and therefore be unsuitable for AONB
It is already densely populated round it, and surface water drainage is a problem here.

to whom it may concern ,I wish to express my concerns over proposed developments
in warton carnforth I live at xxxxxx and at the moment I am having three feet of water
pumped out of my cellar due to the recent heavy rain with a loss of contents to the cost of
£3.200, the fields at the bottom of the village flood every year as the drains can not cope
with the extra rain fall and building more houses would only add to the problem
in addition to this the access roads in and out of the village are already inadequate
for instance in the summer you will see young mums walking from millhead
to the school in warton pushing a buggy on the road ass the pavements are not wide
and in some places there are no pavements in addition to this the school is not big
enough to take more children and recently it took me a month to get an appointment
with my doctor there are plenty of brown field sites in and around Lancaster and carnforth etc
but if you must build on green field sites build on fields just off the a6 where access is
easy or down past the longlands hotel towards burton in Kendal etc
yours j.r.tyson

MAPS
A2. Arnside Edge, Far Arnside - I am opposed to development for the reason that this site is directly on the coast; it should remain free from development in the interests of coastal amenity, wildlife and rising sea levels (climate change) - not a sensible place to build.
A3. Ashmeadow House, Promenade, Arnside - I support its continuation as an open space.
A4. Ashmeadow Woodland - I support its continuation as a public open space.
A10.East of Beechwood Lane, Arnside - I support its continuation as a public open space.
A20. Memorial Playing Field, Arnside - I support its continuation as an important community amenity area and as a public open space.
A21. Arnside Knott and Heathwaite - I support its continuation as inalienable National Trust land supporting grassland and woodland communities of European importance and as a public open space.
A22. Land Fronting Station Road, Arnside - I oppose development of this land; its open aspect gives a pleasing aspect as viewed from the railway. To build on it would be over-development. Houses here would also generate too much car movement in an already over-crowded road in vehicular terms.

MAPS continuation 1
A23. Station Fields, Arnside. I support their continuity as an open space for reasons of public amenity and landscape and to avoid over-development in an inappropriate place.
A24. Station Fields, Arnside. I oppose development of this land. Rest of Answer as per Map A22 above.
A25. Station House, Arnside. I oppose development of this land which currently serves as an access to Arnside station (trains for Carnforth & Lancaster), to the Arnside-Silverdale AoNB Office and to the coastal walk to Sandside. Parts of this land would be appropriate for the much-needed off-road parking for train users, and as such would be an encouragement to commute by train and to walkers and cyclists visiting Arnside as tourists.
A26. Station Yard, Sandside Road, Arnside. I oppose development of this land. Rest of answer as per Map A25 above.

MAPS continuation 2
A27. Station Yard, Arnside - I support development of this site.
A29. Trafalgar Garage, Ashleigh Road, Arnside. I support development of this site.
A30. Woodlands S of Redhills Road, Arnside. I support retaining this woodland as open space

5. Policy Issues

5.21.PARKING IN ARNSIDE - I agree that parking provision in Arnside is insufficient. This is particularly so for train users. No parking is provided for train users travelling in the direction of Barrow; car users wishing to transfer to the train currently park along the B5282 between the station and the promenade, reducing this to a single-track road with passing places which, in especially in summer, is hazardous. There would appear to be adequate space to develop parking for train users on the far-side of the station. To provide parking here would be a boost to rail travel for commuters and tourists alike. Network Rail should be encouraged to negotiate for the acquisition of land to provide much-needed parking.

5.31 Biodiversity - the Development Plan does not mention / take account of NON-STATUTORY WILDLIFE SITES LISTED by the CUMBRIAN & LANCASHIRE WILDLIFE TRUSTS. These sites lack statutory protection but yet are regarded as of such importance to the local community that they have been listed over the years in the expectation that informed decision-making will ensure their continued survival.
Another category of wildlife interest omitted from the Development Plan is that of ANCIENT TREES. There is an Ancient Tree Forum (see their website) which would be happy to advise; it recently held a meeting in Cumbria, at which it was resolved to form a Cumbrian Branch of the Ancient Tree Forum. In particular, the ATF will be able to advise whether it has listed / been notified of specific ancient trees in the Arnside-Silverdale area.

6. Options for Meeting the Objectives and Delivering the Vision

6.18 SUSTAINABILITY I strongly support the proposal that, once a site has been approved in principle for development, the detailed plans should include the provision of PEDESTRIAN+CYCLIST ONLY ROUTES entering / exiting the housing area. Arnside has many examples of such routes, probably surviving from the pre-existing footpath network. It is often the case with new housing estates that there is only one route in/out, which is - by definition - vehicular. The provision of pedestrian+cyclist only routes gives parents escorting children, children themselves, shoppers, the option of accessing the village on foot.
6.24 BIODIVERSITY The line of development is normally guided by excluding protected areas such as SSSIs - to this exclusion should be added Wildlife Sites listed by the Cumbrian & Lancashire Wildlife Trusts.

Mention of non-statutory Wildlife Sites listed by the Cumbrian and Lancashire Wildlife Trusts.

6. Options for Meeting the Objectives and Delivering the Vision

Paragraphs 6/14 to 6/20
Question No 27
Site Number A 15 The Common
Building on this site will increase congestion on the Silverdale Road junction with Orchard Road. There will be even more cars blocking this area than at present. It may be more difficult to park near the surgery in Orchard Road. There is also the Spar shop and the dentist near this junction.

Site Number A7 Knott Lane. I understand it is proposed to build six houses. Above this site is The Knott, our local hill, owned by the National Trust. It is a site of special environmental interest. There is no footpath by Knott Lane and it is even now difficult walking up the road because of frequent cars passing. Also it will make the walk less attractive if the present open space is lost.

Site Number A 11 Briery Bank. This is where the orchard is located. Every other year the South Lakeland Orchard Group holds a special one day event with children's activities, apple naming, etc. a very enjoyable day for the community. If this site is built upon it will be a loss to the community.

Site Number A25 Station - Crossing the line problem for the disabled. The bridge over the line to get to and from the south bound track is very difficult for disabled people especially when it is windy. At Silverdale arrangements have been made for people to cross the line.

[SEE ATTACHED DOCUMENT]

Dear Sir or Madam,
After attending the AONB DPD Consultation Event at the Gaskell Hall, Silverdale on 25/11/15 I would like to make the following comments.

S41,S46,S47,S56 & S58 : - The big concern here is that all this being allowed for development as it would then become one large building area and substantially add to the size of the village changing its characteristics.

S42 : - Where would the access be is this site was allowed for development. At the moment access is via a single track private road. At the point where this private road widens cars are parked on both sides and can be dangerous with current traffic levels.

S44 : - Access via a single track road not suitable for larger volumes of traffic. Part of this road is by a bridge over the railway on a sharp bend. This site is pretty much right on the water table.

S48 : - Building on woodland, surely there are better brownfield sites than this. Where would the access be for this site, the single track bumpy private road? There is also a footpath through this site, would that be retained?

S50 : - Greenfield site that shouldn't be built on plus the owner hasn't given permission for this site to be included in this consultation.

S52 : - Same access issues as S44

S54 This area floods at worst, very wet at best. It is below the sewerage systems at the school fields. Below this site is Cove Drive and Birch Drive which can flood as things stand.

S70 : - If the shuttle is lost then where are people supposed to park to catch the trains? There is a shortage of space for parking at the railway station as it currently is.

How many properties are being considered for Silverdale? If over development is allowed then the village would change beyond recognition and just be another run if the mill place rather than an AONB.
Another issue is the roads to and from the village, these can be very busy in the summer when all the holidaymakers are staying with their caravans. The impact on these roads from more people in these new potential properties needs to be considered. There can be dangerous enough, especially for cyclists.

Adding to these traffic concerns is the potential for increase from the Warton sites. Carnforth can be a problem for traffic as it is, adding all these sites at Silverdale and Warton would only make matters worse.

There are sites included in Warton that can flood (as of now) just from heavy rains or consistant rain.

Our climate is only getting wetter and this has to be taken into account not only for the Warton sites but also the Silverdale sites as Silverdale sewerage is by septic tanks, not mains sewers.

I appreciate that properties have to be built, I only hope that the AONB isn't ruined by overdevelopment.

The type of properties that are lacking are one or two bed properties, for young starting out or older wanting to downsize. There are plenty 3,4 or 5 bed properties and due to there location aren't cheap and are hence beyond a lot of peoples budgets if they want to stay in the area.

One concern I have over new developments is them being bought for second homes or investments of buy to holiday let. This for me is a countrywide problem, homes that could be used for living in are used for holidays and not always in use.
Planning within the village is a concern on past performance. Hazelwood should have been developed with local concerns for suitable housing in mind. It wasn't and now two bed apartments go at silly prices. There are properties on this site always for sale. That was a huge missed opportunity to provide suitable one or two bed properties for those with smaller budgets.

Thank you for taking the time to read this email.

[SEE ATTACHED DOCUMENT]

6. Options for Meeting the Objectives and Delivering the Vision

[SEE ATTACHED DOCUMENT]

6. Options for Meeting the Objectives and Delivering the Vision

[SEE ATTACHED DOCUMENT]

3. Evidence Base

[SEE ATTACHED DOCUMENT]

6. Options for Meeting the Objectives and Delivering the Vision

[SEE ATTACHED DOCUMENT]

5. Policy Issues

[SEE ATTACHED DOCUMENT]

6. Options for Meeting the Objectives and Delivering the Vision

[SEE ATTACHED DOCUMENT]

2. Background

Q1) No they should not set an arbitrary threshold as that can be easilly manipulated. Also 5 houses would potentially have major ramifications on water movement with less infiltration and thus more overland flow. Water movement is a particular issue in certain places within Warton and thus though it is only 5 houses its implications could be major.

Q2)The survey was a good methodology but it does not take account of the number of young people that have already been priced out of the market and had to move into other settlements – and thus their opinions were not obtained . I personally know of 4 people that this is the case for and they are not accounted for due to the questions being aimed into the future rather than incorporating those that have grown up in the village but had to move away. It is difficult to legitimately calculate the extent to which the need for affordable housing is underestimated but it certainly is. I would possit more than twice as much but as I said it is virtually impossible to calculate.

Q3) Historical maps could be good to identify historical brown field sites - for instance where old railway cuttings are over grown and thus overlooked as a woodland in a drive-by survey. It may be useful to contact the Mourholme Historical Society for maps etc. Traffic is also an issue that could be remedied through the use of disused railway lines which previously joined the Leeds and Barrow line, they cross both the river and the main road and thus could be readily used with minimal disruption. There has also been an ongoing issue with sewerage from Warton and Millhead in the summer. Though I know work has recently been done, I am unaware if the capacity has been increased and thus if the infrastructure will be able to handle increased usage and need?

Q4) Yes I would say that the vision is correct with emphasis on social and environmental sustainability.

Q5) Yes I would say the objectives are correct with the emphasis on travel due to the high proportion of commuters in the AONB

Q6) Yes the proportion of affordable housing should be defined and should be higher than the Lancaster District due to the high house prices in the village coupled with the importance of low wage jobs in the local economy (service sector). Thus those in affordable housing are less likely to commute and in turn are less likely compound those traffic issues in and out of Warton, particularly in peak times. Also the definition of affordable housing as espoused by the LCC is not in accord with the real time wages of the local people. With an average house price of £180,000 the 'affordable' price would be around £130,000 and in turn would require a household income of over £30,000 to obtain a mortgage at 95%, which is far and above the real time finances of most people that work in the local community.

Q7) Yes all housing in new developments should be primary residences - ideally for local people with as high a proportion of affordable housing as possible.

Q8) Yes the DPD should put emphasis on local people and truly-affordable houses and make it a requirement of getting planning/allowing a development.

Q9) Where it is for workers with agricultural ties to the housing - and there are no objections, it should be allowed but it should not be used as a mechanism for wealth accumulation etc.

Q10) Yes 'brownfield first' is a good policy but, as suggested earlier, a more thorough investigation into historical brownfield sites and or orphan sites could be done through historical societies etc. For instance in Warton, there is an old POW camp and old railway lines that have been over looked.

Q11) Yes the DPD should guide density - in order to ensure a diversity of buildings and ensure that the majority have a garden. Though this may seem like a misallocation of space, in reality gardens generally increase species diversity and richness whereas small areas get hard-surfaced and thus have no ecological value. Also space is so important in its contribution to the 'rural way of life' i.e. having friends over for a BBQ. So for environmental and cultural reasons the majority should have a big enough garden for a vegetable patch. Also, though it seems strange, gardens can be a valuable resource in regard to food security - as both those in rural areas and urban learned in WW2.

Q12) Warton is in desperate need of a shop and soon we will not have a bus service. Both of these need reinstating in order to add to the vibrancy of the community. Also parking is a huge issue particularly in the centre of the village though there is a lack of space for a car park. It would also be vital for the footpath between Warton and Millhead to be widened – and/or another added to the northerly side on the Warton Hall Farm edges.

Q13) It has been posited many times at the bar that it would be a good idea to revert the fields between Millhead and Warton to a native wetland - and in essence extend Leighton Moss around the crag helping to generate more tourism and thus more jobs.

Q14) Energy security is a pertinent issue that is gaining momentum. Though it is not widely touted there is great scope for the use of biogas in order to increase local energy security and also reduce the pressure on the waste water infrastructure going into the future. There is great scope for wind power in Warton due to its location though the amount of migrating birds could cause conflict. For this reason would suggest that small scale wind with helicoidal blades would be advisable.
Q15) With house prices being as high as they are in Warton, there is no reason that all of the new houses could not be passive houses and epitomise green construction. Yes this would impact profits made but there is no economic risk in building a house in this area and this surely with reduced risk there should be reduced profit?

Q16) Yes there is need for more parking certainly within Warton but I am unsure as to what space there is that would reduce the parking issues in the village centre.

Q17) No more tourist caravan sites - seasonal tourism is helpful to the local economy but we need something more substantial and year round.

Q18) Yes the correct elements have been identified for open space.

Q19) I, as well as many others, feel strongly that reverting the flooded fields back to nature would have significant ecological, economic and cultural benefits.

Q20) As above.

Q21) All assessment not predicated on subject-specific knowledge should be done through widespread, stakeholder public consultation.

Q22) Biodiversity and geodiversity should be enhanced through educating land owners and managers about land management at scale. For instance, a lot of the flooding on Sand Lane in Warton and at the bottom of the hill is a direct consequence of poor land management (I am an environmental scientist and thus have the subject specific knowledge to make this comment). Removal of grass and planting crops in bare earth allows water to flow over not being slowed and soaking through grass.

Q23) With the envisaged increase in environmental variability associated with Global Warming there is an increased risk of flooding both on site (changes in the water table) and beyond the site due to impacting the way the water moves at a landscape scale.

Q24) We should aim to build on the extensive history of the area and aim to conserve, preserve and enhance our historic environment.

Q25) As suggested before, all new developments should be built to passive/the highest standards and that is very achievable - given house prices. We should be aiming to increase resilience and sustainability through energy security both in production and use. Also the building should take into consideration local building materials i.e. no more fake sandstone monoliths to developers’ greed.

Q26) Option 5 seems the best all round approach through spreading the development pressure but also steering development toward existing infrastructure.
Q27) Of the proposed sites, they all have the potential to detract from the scenic and natural beauty of the village. To the north of Sand Lane would spoil the views to the Crag of all those living there. Those to the south (behind the houses) would spoil the rear views of those houses and also create a traffic issue in that you will have two roads then branching off Sand Lane. Also there is a significant issue of flooding due to dismal land management on Sand Lane’s fields and Warton generally. As I walked to work today I walked past 5 houses with sand bags covering their drives - so flooding on these sites is evidently an ongoing problem and the areas highlighted for roadways are where the flood water is diverted. Also I feel it would be pertinent to add that within the AONB it has been established in court that views have a value (Marilyn Barnes in Arnside), and thus disrupting the views could incur unexpected costs as views are normally not regarded as having a tangible value but this case over turns this precedent. Mrs Barnes was fined commensurate with the value added to her property due to increased views. The houses on Sand Lane look back toward Ingleborough which is an iconic view and a significant contributor to the outstanding natural beauty of the area. On the whole I agree that there should be no building on uphill side of Warton for both scenic and flooding reasons and those at the back of Sand Lane are essentially in the ‘soak away’ for said flooding. There is a serious land and water management issue in Warton and until it is resolved virtually all proposed development will exacerbate this issue. I hope the individual reading this does not think I am a NIMBY protestor because I am also compiling a suggested site that is literally in my back garden and building on land that I have been working for years. I will not see any financial return from this but it is in the best interests of the village and I want to raise my children here!
Q28) I have submitted a proposal for the development toward the end of Sand Lane on flat ground and no flooding risk. It will only spoil the views of myself and one neighbour rather than a whole street who may seek financial reimbursement for loss of property value, I know that some are thinking of getting valuations before development for this very reason.

Q29) Yes development boundaries should be put in place for the primary settlement in accordance with aesthetic (I.e. not up the hill from the village) and safety i.e. not on low crag road beyond the straight out of the village as the road is thin and windy and thus unsafe.
Q30) Yes development should be phased in 3 lots of 5 years and done in accordance with the highest proportion of affordable housing/whichever will deliver the best returns to the community first. This is the best way because no added pressure can be put on the AONB in the next 15 years and a lot can change in 15 years. For instance, if house prices were to re-establish their link with wages then there may not be as much of a need for affordable housing - or if the financialisation of housing continues we may need more affordable housing and future governments can insist on a larger social housing contingent (based on higher prices and thus greater capacity to cross subsidise). Though it is understood that we need more housing, that does not necessitate more monoliths to developers’ greed. The development should serve the community - not as has been the case, where the detriment to the community has served the pockets of developers.

Q31) Though I understand why the AONB DPD is being done separately, the cause of the two main issues in the village lay beyond the AONB, namely flooding and traffic. Flooding is particularly bad in Warton due to the bridge over the Keer in Millhead causing a bottleneck, behind which water build up and the heightened water table has ramifications back up the catchment i.e. Warton (and Scotland Road and Truckhaven further back). You may be able to see on maps that there is a disused railway bridge over the River Keer that also goes over the main road and could come down either side on disused land. Through redirecting traffic this way traffic pressure could be alleviated on the bridge and it potentially removed (leaving the secondary foot bridge) which would also help alleviate flooding in Warton. Just a suggestion but I think it would be a good line of enquiry and could be coupled with development of the TDG site in Carnforth.

As a graduate in Environmental Science and Politics I am familiar with and capable of analysing a large array of documents. Even with my experience I found it time consuming and at times difficult to decipher what was being said and I could understand how some would find this process difficult and fealt incapable of contributing. Might I suggest that future documents come with a less wordy break down of what is being said in lay mans terms. Other than that I found the process transparent. As a caveat might I also add that I think it would have been beneficial for those facilitating the face to face consultation were a little more informed as to what was going on. Had the community of known that the plan was to find a site for 20 houses then the process may have been better received.

Possibly but due to time constraints I did not have time to critically analyse this document.

I have been a resident of Warton Village for the past 50 years. I am appalled by the proposed development of greenfield sites in this village. Further building in Warton could only have an extremely detrimental effect on what is a lovely village in an area of outstanding natural beauty. The village has a narrow winding main street which already struggles to cope with existing traffic. Also, any further building on the Crag side of the village would increase the danger of flooding on the lower side of the village. There is already a serious risk of flooding! The road through the village has been flooded in the past week and the fields have become an extensive lake. The fact that it is an AONB area should be enough in itself to preclude any further building! Yours sincerely Patricia Wilkinson

Dear Planners
AONB DPD Planning Consultation – Comments
I am a resident of Silverdale and a Chartered Civil Engineer with extensive experience in sewerage and sewage treatment. With my professional background I have a keen interest in the safe disposal of sewage and having lived here for 11 years I am aware of many problems with the existing “sewage disposal” arrangements. These include smell, discharge of crude sewage/sludge to groundwater and resulting pollution of the shore, all due to lack of understanding and poor maintenance. I am therefore extremely concerned about any proposal to build new houses in Silverdale. I am not against new development but these MUST have provision for safe treatment and disposal of sewage.
Of major concern is the cumulative damage to the environment - groundwater systems and the coastal margin. I also have concerns about possible non-compliance with Building Regulations.
Because the limestone bedrock is heavily fissured effluent from existing septic tanks is not retained for long enough in the immediate sub-surface zone for appreciable secondary treatment to occur. Virtually crude sewage quickly flows through fissures and merges with ground water to discharge in springs along the shore. This probably results in areas with high bacterial content posing a health risk to people and contamination of sea water.
Where new properties are too far away from the “public sewer system” then the only realistic options, acceptable under Building Regulations, for sewage disposal are packaged treatment plants or septic tank plus secondary treatment eg a drainage field.
Effluent from packaged treatment plants can be discharged to a watercourse (with EA consent) but as there are none to speak of in this area the only suitable discharge would be the same as for a septic tank ie a drainage field.
In general parlance people refer to septic tanks discharging to “soakaways” but a drainage field consisting of sub-surface perforated pipes is required by Approved Document H.
The siting requirements are that a septic tank should be at least 7m from the house and no more than 30m from heavy vehicle access. The drainage field should be at least 15m away from any building.
The size of a drainage field or its “floor area” is calculated from this formula:-
Area = population X percolation rate X 0.25 square metres
The minimum acceptable value of percolation rate is 12 so for a 4 person house the minimum floor area for the drainage field is 12 square metres. This assumes excellent percolation and in reality this value could be several times higher.
Considering these Building Regulation requirements any new property would need a back garden reaching at least 18m from the house and 5m wide. This is a considerable size of garden which is not achieved in most cases of new development.
In an unsewered area it would not therefore be possible to develop most sites at the density required for financial viability whilst complying with Building Regulations and not adversely affecting the environment. This does not consider proximity to other houses - which would make the situation even more difficult, the ground conditions or the topography.
In summary I do not believe any new houses can be built while Silverdale remains unsewered due to:
• Continuing contamination of ground water and coastal pollution
• Non-compliance with Building Regulations for new houses
• Potential proliferation of small, inefficient sewage treatment plants with no control on maintenance or performance
Yours sincerely

[SEE ATTACHED DOCUMENT]

[SEE ATTACHED DOCUMENT]

B75---- THIS SITE/LAND AT DEEPDALE ,SLACKHEAD, HAS SINCE 1821 ,RE PARLIAMENTARY ENCLOSURE AWARD AND CONFIRMED BY THE ORDNANCE SURVEY RECORD BOOK IN THE 1860`S, AND BY THE INLAND REVENUE IN 1912, AS BELONGING TO WESTMORLAND COUNCIL, BUT RECENTLY ANNEXED BY DALLHAM ESTATE BEEN OF OPEN ACCESS TO THE PARISHIONERS OF BEETHAM PARISH FOR THAT 150 YEARS, AND I ASK FOR IT TO BE DESIGNATED AS PUBLIC OPEN SPACE, FOR THAT CONTINUED PURPOSE.
B80---THIS SITE /LAND WEST OF KEASDALE RD, CARR BANK, STORTH,HAS SINCE 1821 [AS IN THE SAME CRITERIA OF B75] BEEN OF OPEN ACCESS TO THE PARIS HONERS OF BEETHAM PARISH AND I ASK FOR IT TO BE DESIGNATED AS PUBLIC OPEN SPACE, FOR THAT CONTINUED PURPOSE.

Dallham Estate who have very recently annexed the sites are proposing development on them in the current development plan, which is being opposed by Beetham Parish Council.
The historical documentation referred to is currently held at Kendal Record Office, and I have in my possession copies of them.
They both have customary footpaths crossing them which are well used by parishioners, and to this point in time this has not been attempted to be curtailed by the Estate.
Regards

Bob Pickup

[SEE ATTACHED DOCUMENT]

[SEE ATTACHED DOCUMENT]

6. Options for Meeting the Objectives and Delivering the Vision

Our comments are in regard to section 6, question 27.

Areas A18 and A19

We appreciate the importance that the Local Planning Authority has placed on this land insofar as its visual impact when approaching Arnside from the B5282 (Sandside Road). With this in mind, the land has been let only for agricultural purposes over many years. In order to preserve the attractive nature of the land, the lettings have been undertaken carefully, often with tight restrictions on the number of livestock being grazed. This has had a negative impact on the level of income and whilst there is no public access to the land, essentially the owner is “subsidising” a public good due to the current designation of the land.

We feel that developing part of the land represents a sensible, balanced approach to the problem.

The land is currently let to a neighbouring farmer who accesses the property from his own holding. However the access track to the property off Black Dyke Road (along which the bridleway passes) is under the same ownership. We appreciate that this access would need to be upgraded and widened if it was to be for residential purposes. However my client has other options for access (details of which can be supplied on request).

Sustainability of this development is achieved by combing whole of the extent within the existing settlement area. The development in A19 is designed to be located on land with a reduced visual impact (from the east) and would reduce the need to expand the “footprint” of Arnside in future. The scale of the development is modest in comparison to the wider area.

The site is located within the development limits of Arnside and therefore is within the built up area of the village for planning purposes. Arnside is identified as a “Local Service Centre” in the adopted Core Strategy and is such identified as a suitable location for further housing growth and we note that there are approximately 112 new homes in Arnside planned for over the next 15 years.

We note that whilst land to the south east of the property is now utilised for orchards and gardens, this has broken up the ‘open’ aspect of the wider designated area.

Much of the remainder of the property is already surrounded by residential properties.

In addition, my client personally comments “…this is the prime site for development in the entire district and enjoys magnificent views across the estuary to the Lake District mountains. It is the last available site in the area so endowed and will require very careful planning to do justice to its position and to enhance the 'Entrance to Arnside'. It is entirely surrounded by houses with a line of mixed quality 80 year old housing running right along the skyline to its rear.”

We trust the above is in order and that you’ll contact the writer with any further comments or queries.

Oliver Bateman

[Additional information]:
Site A18

Please accept my apologies for a late entry.

I am the owner of the site. I would like to develop it. I have owned the land for nearly 40 years and for at least the first 30 of those years have been content to let it for grazing. However it is becoming increasingly difficult to let and increasingly uneconomical because it is entirely surrounded by houses and not attractive to local farmers.

It is a prime site for development with glorious Arnside views and within easy walking distance of the amenities of the village and the railway station. However its position as a vantage point makes it visible to the approach to Arnside from the Sandside road and its development will need to be carefully planned. Its total area exceeds 10 acres and could accommodate many years of housing construction for the district.

I have always considered that it should be treated as a whole not developed piecemeal like the land to the southeast across the bridle path, much of which has been sold off as garden extensions for the houses on Blackdyke Road. If the same approach was engaged for the houses on Church Hill the site and the view from Sandside Road would be ruined.

I appreciate that development is a long term issue but I would like encouragement that is seriously contemplated in order that I will not be obliged to sell it off piecemeal .

Please be assured that I am very willing to work with you to make the very best of the opportunities.

Yours faithfully,

Christopher J. Smith

2. Background

Q1 Should the AONB DPD define what would constitute ‘major development’ (a threshold above which planning consent would not normally be granted) in the AONB or should this be considered on a case by case basis? If there should be a definition, what should it be?

The AONB should not seek to provide a definition of major development. The Local Plan will identify the sites that are to accommodate new development and provide settlement boundaries to the main settlements. This will be sufficient guide as to where new development is likely to be acceptable.

It is unnecessary to seek to provide a definition for a term used in the National Planning Policy Framework and providing unnecessary inflexibility in the consideration of any future development proposals.

As indicated the Development Management Procedure Order does provide a definition by reference to 10 dwellings and the NPPF deliberately did not apply such a definition. One could end up with a circular argument based upon Section 38(6) of Planning and Compensation Act 2004, whereby you apply a definition to major development in a statutory document and other material considerations i.e. the NPPF, indicate that such a definition should not apply.

3. Evidence Base

Q2 Should the Councils identify housing requirements for the AONB area over the plan period? What additional information is required, and what calculations should be made to guide housing requirements?

Yes and for South Lakeland this should be based upon South Lakeland District Council’s identified gross housing requirement of 216 new dwellings, as set out in Table 1A: Overall Housing Requirement and Balance between Settlements, plus any identified housing need in the Lancaster City District.

The gross figure will need to be adjusted to take into account of completions and the proposed start date of the Local Plan.

It is not understood how a gross requirement of 216 dwellings has become an indicative requirement of 123 dwellings on the South Lakeland side (paragraph 2.6) or where this is referenced in the Land Allocations document.

The South Lakeland Land Allocations Table 1A does provide an apportionment of the district housing requirement that is to be provided in its part of the AONB area i.e. 216 dwellings, so the comment to the contrary at paragraph 5.6 is not agreed.

4. Vision and Objectives

Q4 Have we set out the right vision for the AONB DPD? If not, how should it be changed?

Amendments
• fourth bullet point should be “and heritage assets”

5. Policy Issues

Q6 Should the AONB DPD identify the proportion of affordable housing to be developed in the AONB? If so, what proportion and how would it be delivered?

SLDC do in fact operate a lower threshold of 3 or more dwellings for all schemes outside of the Principal and Key Service Centres. So in all the AONB settlements in South Lakeland the lower threshold applies.

Analysis of SLDC’s Housing Land Position Report 31st March 2015 has been undertaken by Garner Planning to seek to identify those mixed tenure sites (granted permission since the Core Strategy was adopted) that have delivered affordable housing, where the CS6.3 threshold is 3 dwellings i.e. Local Service Centres and Rural areas. Only two sites have produced affordable housing:-
• Holmes of Natland 12 dwellings including 4 affordables; and
• Greengate House 8 dwellings including 2 affordables.
Applying a threshold of 3 dwellings is not producing affordable housing in South Lakeland and perhaps the same picture emerges in Lancaster City. So the plan should consider a threshold of more than 10 dwellings before affordable housing is required otherwise housing may not be viable and actually deliver completions.

Both South Lakeland and Lancaster City are producing housing completions at above half the level indicated in their Core Strategy. Applying the business mantra – keep doing the same things and you will get the same result – you need to do something different. It is suggested that an affordable housing requirement of 25% is applied to schemes of over 10 dwellings, subject to a viability clause.

Q7 Should the AONB DPD restrict new housing development to local people and/or those who are going to use the property for their sole or main occupancy?

SLDC did have a local occupancy requirement in the context of its Interim Planning Approach to Housing Development (July 2008). There was an intention to include a local occupancy requirement in the context of the South Lakeland Core Strategy. Garner Planning submitted written and verbal evidence in relation to this matter at the Core Strategy Hearing in 2010. The Core Strategy Inspector concluded in his report:-

“The available evidence on the success of the IPATH policy to date is limited, but it is far from conclusive that the policy is achieving its desired effect. If anything the modest number of completions over 3 years tends to support the points made on behalf of local house-builders.”

A local occupancy condition did not form part of the adopted Core Strategy.

SLDC have tried a local occupancy policy and it has not worked and delivered the required housing completions. Indeed South Lakeland continues to suffer the effect of the limited completions during the IPATH period. The lesson should be learnt and the AONB local plan should not include a local occupancy policy.

Q8 How should the AONB DPD promote the development of certain housing types within the AONB to meet particular housing needs?

Planning authorities are required to deliver “a wide choice of high quality homes”(NPPF paragraph 55) and to plan for a mix based on current and future demographic trends.
So you need a robust evidence base to identify the mix of housing that will meet anticipated future requirements.

Different sites have different qualities and can appeal to different markets and it should be for the applicant to determine the size of property on any site, but within the context of the wide choice that the Local Plan might refer to.


Q9 How should the AONB DPD plan for housing development on rural estates, in isolated locations or specifically for agricultural and forestry workers?

It should not.

Q10 Should the AONB DPD prioritise and/or set a locally appropriate target for the use of brownfield land? Is there enough brownfield land in the AONB to do this?

It should not prioritise brownfield land over greenfield land or set a target. The local plan should however encourage the effective use of previously developed land.

SLDC’s Core Strategy pre-dates the NPPF which focusses on a presumption in favour of sustainable development. It is the location of development in terms of accessibility to services that is key rather than brownfield in preference to greenfield.

Few of the sites identified as being considered for development are previously developed. This is perhaps not surprising given a lack of limited industrial legacy in the AONB area.

Q11 Should the AONB DPD seek to guide the density of new development? If so, what approach should the plan adopt?

Individual sites may be more sensitive in landscape terms in the AONB, this might encourage lower density than might be acceptable outside of the AONB area. No density restrictions should be set out in the Local Plan.

Q12 Should the AONB DPD identify allocations of land for community infrastructure? What community infrastructure is required and where?

Yes it should identify allocations of land for community infrastructure but they will need to ensure those allocations are on land where it has been confirmed the landowner is willing to release the land to provide that infrastructure.


Q15 What policies should the AONB DPD contain to manage the impact of new development on highways and other services?

The distribution of new housing should reflect the fact that only Arnside has a railway station within the settlement. This would suggest Arnside is most suited for a larger proportion of housing growth, which would provide new residents the opportunity to access larger settlements by rail.

Q16 Do you consider that there is a need for any additional parking facilities in the AONB’s settlements and, if so, where should it be located?

Consideration should be given to providing increased car parking close to Arnside Railway Station.

Q18: Have the right elements for assessing the designation of private open spaces as Important Open Space been identified

The second bullet point should delete the words “Is the open space prominent in the street scene?” and simply read “Is the open space visible from publicly accessible points in the wider surrounding area?”

The two parts are similar but visibility from outside the site encompasses the street scene part.

Q19 Of the existing designated open spaces shown on the accompanying maps, are there any you feel need not be designated as Important Open Space or any that could be suitable for other uses? What uses?

Site A8: Hollins Lane, Arnside. The site is enclosed by residential development on all sides with the backs of residential properties on the western and eastern sides. A LVIA has previously been submitted indicating the site is visually prominent. The site is suitable to accommodate a modest housing scheme.


Q21 How should the AONB DPD provide for the assessment of development proposals that may impact on landscape, seascape, coastal features or settlement identity and separation?

Determination of any detrimental landscape impact in the context of determining sites to be allocated for built development and in the context of planning applications on windfall sites.

Q22 How should the AONB DPD protect or enhance the biodiversity and geodiversity of the AONB?

Not allocating sites for built development which are particularly sensitive in this regard unless appropriate mitigation is achievable.




Q25 How should the AONB DPD manage the significance and protection of design features, and the standards of design required for new development in the area?

Make an appropriate assessment of any scheme submitted as part of a planning application. One can include fine words as a policy but good and bad design is highly subjective.

6. Options for Meeting the Objectives and Delivering the Vision

Q26 Which option(s) represent the most appropriate approach to development in the AONB? Are there any other options we should consider?

(ii) Allocate in Primary Settlements only + assumption of some development elsewhere judged by policies.

Placing Arnside in a category of its own as a focus for growth as it is the only settlement with a railway station within the settlement in the AONB.

Q27 Have you any comments on any of the sites put forward?

Comments made on the Arnside sites only.

A2 – unsustainable location poorly related to any settlement;
A7 – prominent site with potential landscape impact and detached from the settlement;
A8 – suitable for residential development for the reasons set out in the Call for Sites exercise. A landscape and visual assessment has been undertaken confirming there would be no significant harm to the AONB by developing this site for residential. The site is close to local services and public transport. There is a willing landowner and the site is available for residential development;
A11 – prominent in landscape terms;
A12 – incorporates A11 – prominent in landscape terms;
A17 – poor and tortuous access to site that is poorly related to the settlement with no pedestrian access linking north to the settlement;
A18 – access to be reviewed, potentially dependent on A22 and A24;
A19 – entirely dependent upon A18 coming forward to provide access and possibly A22 and A24;
A22 – potential car parking area for the Station;
A24 - drainage issues and steep site that is prominent in the local landscape;
A25 – flood risk problems – car park potential only;
A26 – includes A25, as above.
A27 – forms part of A26 – flood risk problems; and
A97 – unsustainable location poorly related to services.
A106 - liable to flooding;

Q29 Should the AONB DPD identify development boundaries? For which settlements?

Yes for Arnside, Sandside/Storth, Silverdale and Warton only.

7. Delivery of Development

Q30 Should the AONB DPD phase development during the 15 year time horizon of the plan? What phasing approach is appropriate?

No. All that a phasing policy can do is prevent development that could come forward from coming forward. A phasing policy cannot make sites come forward. One is unable to predict the timing of housing land release and the authority should allow individual landowners to bring sites forward at the earliest opportunity.

Neither SLDC nor Lancaster City Council can currently demonstrate a five year land supply. Neither authority have had a problem with too much housing coming forward. The Local Plan should encourage landowners to bring forward housing sites for development, in appropriate locations.

Q31 Are there any other issues that the AONB DPD should address? Have you any other comments?

Comment on Appendix 1: Site Assessment Summary Sheet

The Suitability/Sustainability – there needs to be separate consideration of the distance of a site from a railway station. The walking distance to a railway station should be 1km rather than 400 metres.

There should not be the suggestion that brownfield land in unsustainable locations is more suitable than greenfield sites in sustainable locations. This is contrary to the focus of the NPPF.

It is not clear what an “identified area of open green space” is. Identified by who and in which planning document?

Comments have been made by Garner Planning on the previous draft. There is no point repeating those comments here but it clear the previous comments are not resulting in revisions to text even where the Scoping Report Consultation Responses says there will be changes to the text.

Comments regarding the settlement hierarchy need to be taken into account by the planning authorities in determining housing allocations rather than Hyder in reviewing such allocations.

Appendix A still does not refer to South Lakeland's Core Strategy and Land Allocations documents although it was agreed to amend this reference.
Table 5.1 Soils and Land Quality - the Scoping Report Consultations Responses Tracker says you will include reference to "sustainable locations" but this has not been done.

Table 5.1 and Appendix B. The response to the previous comment that the affordability gap is a function of many retired people in owner occupied housing with no mortgage and a lower income than when employed is confirmed by the Consultation response - it is the ratio of average incomes to average house prices. That does not mean there is an affordability problem. Retired people now have an income below the level that could secure a mortgage on the house they live in, but they of course are not in housing need because they are owner occupiers with no mortgage. Affordability is therefore skewed in areas with high numbers of retirees.

Table 5.1 Housing - housing allocations are not just to meet affordable housing needs, they are to meet general needs. Housing supply affects affordability as well as second homes.

Table 6.1 Housing - there has been no clarification of housing requirements in the Issues and Options Discussion Paper, maybe this will come at a later stage.

Table 6.1 - 12. Natural Resources - the Scoping Report Consultation Responses Tracker says it is agreed that the table should state "To encourage development of brownfield land in sustainable locations". The text has not been amended to say this.

Appendix B 1.16 Housing allocations are not just to meet affordable housing needs they are to meet general needs.

2. Background

[SEE ATTACHED DOCUMENT]

3. Evidence Base

[SEE ATTACHED DOCUMENT]

4. Vision and Objectives

[SEE ATTACHED DOCUMENT]

4. Vision and Objectives

[SEE ATTACHED DOCUMENT]

5. Policy Issues

[SEE ATTACHED DOCUMENT]

5. Policy Issues

[SEE ATTACHED DOCUMENT]

5. Policy Issues

[SEE ATTACHED DOCUMENT]

5. Policy Issues

[SEE ATTACHED DOCUMENT]

6. Options for Meeting the Objectives and Delivering the Vision

[SEE ATTACHED DOCUMENT]

6. Options for Meeting the Objectives and Delivering the Vision

[SEE ATTACHED DOCUMENT]

6. Options for Meeting the Objectives and Delivering the Vision

[SEE ATTACHED DOCUMENT]

7. Delivery of Development

[SEE ATTACHED DOCUMENT]

[SEE ATTACHED DOCUMENT]

[SEE ATTACHED DOCUMENT]

[SEE ATTACHED DOCUMENT]

[SEE ATTACHED DOCUMENT]

[SEE ATTACHED DOCUMENT]

7. Delivery of Development

The Constabulary welcomes the opportunity to comment on this consultation.
Whilst I am not qualified to comment on most of the aspects of this consultation, I merely wish to raise the issue of new development being resistant to crime and anti-social activity, thereby contributing to the sustainability and well-being of small communities within the AONB (Special characteristics Item 1.3 'Strong community and culture' 'A sense of tranquility, space and place').
Accordingly, I seek the Council's support in encouraging developers to achieve Secured by Design accreditation, particularly in new housing and business/employment development.

[SEE ATTACHED DOCUMENT]

Dear Mr McNeill,
Arnside & Silverdale AONB Development Plan Document (DPD): Issues and Options Consultation
Cumbria GeoConservation is pleased to note that the discussion paper covers the ‘unique limestone geology’ (1.3), and the management plan includes geodiversity (1.6). It concurs that the area is loved for ‘its unique geology’ (4.2). It is useful that bio- and geodiversity are considered of ‘key environmental significance’, and that a key question is ‘how should the AONB DPD protect and enhance geodiversity?’
One way to achieve this would be to make more mention of the Local Geological Sites (LGS) in the AONB and to ensure that these are included in tourist information and on the AONB web site.
As noted in our previous reply of 29 April 2015, Cumbria GeoConservation agrees that sites with ‘geological designations’, to include LGS and Limestone Pavement Orders (LPO), should be included in ‘exclusion criteria’ for development.
Yours sincerely

2. Background

Question 1. Yes, the AONB DPD should define what would constitute a ‘major development’. Whilst this definition would not necessarily be ‘set in stone’ it would be a starting point for discussions. The definition given in the Statutory Instrument 2010 No.2184 – The Town and Country Planning (Development Management Procedure) (England) Order 2010 (paragraph 2) should form the basis for any definition.

3. Evidence Base

Question 3: The DPD should ensure that it has the County Wildlife Sites GIS layer for both Cumbria and Lancashire. The Cumbria layer can be sourced from the Cumbria Biodiversity Data Centre based with Tullie House Museum in Carlisle.

4. Vision and Objectives

Question 4: We agree with the vision.

Question 5: We agree with the chosen objectives.

5. Policy Issues

Question 10: It is worth noting that in wildlife terms, brownfield sites are often richer in wildlife than many greenfield sites. It should not be assumed that development of brownfield sites is preferable in wildlife terms to the development of improved pasture.

Question 19: we feel that Local Wildlife Sites should be considered for designation as Important Open Space where there is open access available.

Question 22: There should be a presumption against development where the development will impact negatively upon Local Wildlife Sites. There should be a “no net loss” of habitat within the AONB due to development and developments should seek to enhance and improve biodiversity wherever possible. The AONB should seek to ensure that all Local Wildlife Sites receive up-to date surveys with the data handed to the appropriate Local Records Centre.

6. Options for Meeting the Objectives and Delivering the Vision

Question 27

All of the following sites should be automatically excluded from further assessment due as the “development would harm a protected species, a site designated for its
biodiversity importance or an area of priority habitat or would compromise
habitat connectivity” (page 32, paragraph 6.17)

The comments should be read with the following caveats:

By “intersects” we mean that the area shown for the proposed site overlaps with the site boundary for a biodiversity designated area/priority habitat. As such development of this site will destroy some or all of the designated area. The overlap may be a small section or the entire site.

By “adjoin” we mean that the area shown by the proposed site sits very close to a designated site/priority habitat and development upon this site may potentially have negative impacts upon the designated site/priority habitat.

Sites not included in the list below are excluded simply on the basis that there is no recorded biodiversity at the site. This does NOT means that the site has no biodiversity value and all sites that go forward from this stage should undergo further biodiversity assessment through site visits by qualified ecologists. Development appraisal should not only be sensitive to current loss but also sensitive to loss of restoration potential.


Deciduous woodland Priority Habitat– Deciduous woodland is one of the most biodiverse habitats within the AONB and the Trust feels that permission should not be given to developments that require widespread removal of trees.

Site Reference – A2, Arnside edge. This site intersects Hollins Farm Verges County Wildlife Site (CWS) SD47-13. This site intersects Morecambe Bay Special Protection Area (SPA), Special Area of Conservation (SAC) and Morecambe Bay Site of Special Scientific Interest (SSSI)

Site reference –A4, Ashmeadow Woodland, Silverdale Road, This site intersects an area of deciduous woodland.

Site reference – A7, High Close, Knott Lane. Site closely adjoins Dobshall Woods CWS (SD47-11), Red Hills Wood (SD47-36) and Red Hills Pasture CWS (SD47-37). Development could have significant impact on these sites. The site also intersects an area of deciduous woodland.

Site reference – A13, Land adjoining cemetery 1. Site intersects Hagg Wood CWS (SD47-16).

Site reference – A17, Land adjoining cemetery 2. Site intersects Hagg Wood CWS (SD47-16).

Site reference – A21, Arnside Knott and Heathwaite. Site intersects Red Hills Pasture CWS (SD47-37). Site intersects Arnside Knott Site of Invertebrate Significance.

Site reference – A30, Woodland south of Redhills Road. Site intersects Red Hills Wood CWS (SD47-36)

Site reference – A97, Middlebarrow Quarry. Site intersects Middlebarrow Wood CWS (SD47-15). Site adjoins Middlebarrow Wood SSSI. It is thought that this quarry and the nature conservation interest was considered mitigation for a previous development and should not therefore be considered.

Site reference B31, Land North of Beetham Holiday Homes, Slack Head Road. Site intersects Major Woods CWS (SD47-26).

Site reference B33, Hall More Caravan Park. Site intersects Hale Moss Site of Invertebrate Significance.

Site reference B36, The Bottom Yard, Dallam Tower. Site intersects Crow Wood CWS (SD48-07)

Site reference B37, Timber Yard, Dallam Tower. Site intersects Crow Wood CWS (SD48-07)

Site reference B38, Land South of Quarry Lane. Site intersects a ‘Special verge’ (roadside verge of importance)

Site reference B39, Quarry Lane Depot. Site intersects ‘Special Verge’ (roadside verge of importance). Site intersects deciduous woodland.

Site reference B40, Willacys Wood. Site intersects deciduous woodland.

Site reference B73, Marble Quarry. Site intersects Marble Quarry and Hale Fell SSSI, Site intersects Morecambe bay Pavements SAC. Site intersects marble Quarry Limestone Pavement Order. It is thought that the biodiversity interest at this site may form part of compensation for a previous development.

Site reference B74, Land West of Slack Head. Site intersects Major Woods Limestone Pavement Order. Site intersects Major Woods Site of Invertebrate Significance.

Site reference B75, Land at Deepdale. Site intersects deciduous woodland.

Site reference B76, Land North of High Croft Lane. Site intersects Underlaid Wood Limestone Pavement Order.

Site reference B77, Land North East of Yans Lane. Site intersects Haverback Bank Limestone Pavement Order. Site intersects deciduous woodland.

Site reference B104, Leighton House, Brackenthwaite Road. Site intersects Underlaid Wood Limestone Pavement Order. Site intersects Underlaid Wood Site of Invertebrate Significance. Site intersects ‘special verge’ (roadside verge of importance). Site intersects deciduous woodland.

Site reference S44, Hawes Villa, Moss Lane. Intersects Haweswater SSSI. Intersects Morecambe Bay Pavements SAC.

Site reference S52, Land East of Hawes Villa, Moss Lane. Site adjoins Haweswater SSSI. Site adjoins Morecambe Bay Pavement SAC.

Site reference S59, Eaves Wood and Park Field. Intersects Eaves Wood SSSI.

Site reference S60, Heald Brow. Intersects broadleaved woodland.
Site reference S62, Levens Field and Woodwell. Intersects deciduous woodland.

Site reference S63, Pointer Wood. Intersects deciduous woodland.

Site reference S64, Jack Scout. Intersects Jack Scout SSSI. Adjoins Morecambe Bay SAC and SPA

Site reference S65, Burton Wells Wood and Lambert's Meadow. Intersects deciduous woodland.

7. Delivery of Development

Question 31:

The Trust would like to support calls for the DPD to require home owners / landlords to make provision for nesting birds and roosting/hibernating bats when undertaking any renovations or repairs to their property. In addition all new development should be required to make provision for species such as swifts, bats, swallows, barn owls, house sparrows or other species that might live locally.

Conservation of habitats and species is something that needs to be considered throughout the landscape and not just within designated sites. The AONB needs to get a better understanding of how species move through the landscape between designated sites and increasing this landscape permeability wherever possible. This is becoming increasingly important with the changing climate forcing species to move in order to stay within their climatic niche.

Housing & employment development in Arnside & Silverdale AONB

We have considered the potential development sites within our Network Distribution Area and conclude that they could have an impact on our infrastructure. With the information supplied, it is not possible to determine the exact impact on our assets.
As each development takes place, they will be reviewed during the usual planning application process.

The applicant should be advised that great care should be taken at all times to protect both the electrical apparatus and any personnel working in its vicinity.

The applicant/s should also be referred to two relevant documents produced by the Health and Safety Executive, which are available from The Stationery Office Publications Centre and The Stationery Office Bookshops, and advised to follow the guidance given.

The documents are as follows:-
HS(G)47 – Avoiding danger from underground services.
GS6 – Avoidance of danger from overhead electric lines.

The applicant should also be advised that, should there be a requirement to divert the apparatus because of the proposed works, the cost of such a diversion would usually be borne by the applicant. The applicant should be aware of our requirements for access to inspect, maintain, adjust, repair, or alter any of our distribution equipment. This includes carrying out works incidental to any of these purposes and this could require works at any time of day or night. Our Electricity Services Desk (Tel No. 0800 195 4141) will advise on any issues regarding diversions or modifications.

Electricity North West offers a fully supported mapping service at a modest cost for our electricity assets. This is a service, which is constantly updated by our Data Management Team (Tel No. 0800 195 4749) and I recommend that the applicant give early consideration in project design as it is better value than traditional methods of data gathering. It is, however, the applicant’s responsibility to demonstrate the exact relationship on site between any assets that may cross the site and any proposed development.

Yours sincerely,


Eric Roberts

Dear Sir/Madam

Arnside & Silverdale Area of Outstanding Natural Beauty (AONB) Development Plan Document (DPD) - Issues and Options Consultation

Thank you for consulting the Environment Agency on the above document which forms part of the Lancaster City Council and South Lakeland District Council Local Plans.

Overall we support the content, structure and approach of the AONB consultation document.

We are pleased that flood risk and drainage are included as policy issues in the draft document. Please see our comments below in response to Q23: what are the implications for development in places without mains drainage or mains sewerage systems?

Private sewage treatment infrastructure (septic tanks and more likely sewage treatment plants) are likely to be adequate for the scale of housing development envisioned for the AONB. However, for Silverdale the current requirement for higher than average standard of sewage treatment (as outlined in the attached Environment Agency’s Local Planning Guidance issued to Lancaster City Council’s Development Management Team) will need to be continued to mitigate against impacts on its vulnerable groundwater.

We’d recommend that the requirement for the higher standard of sewage treatment for Silverdale be incorporated as policy into the DPD to reflect the importance of this need and we would be happy to discuss this with you further.


Yours faithfully

Jeremy Pickup
Planning Advisor - Sustainable Places
[SEE ATTACHED DOCUMENT]

Dear Alastair McNeill

Thank you for your email. The Commission does not have the resources to respond to all consultations, and it is not our practice to respond to consultations on local plans or infrastructure projects unless they raise a clear or significant equality or human rights concern.
Local, Parish and Town Councils and other public authorities have obligations under the Public Sector Equality Duty (PSED) in the Equality Act 2010 to consider the effect of their policies and decisions on people sharing particular protected characteristics. We provide advice for public authorities on how to apply the PSED, which is an on-going legal obligation and must be complied with as part of the planning process. Thus, the PSED is the mechanism through which public authorities involved in the planning process should consider the potential for planning proposals to have an impact on equality for different groups of people. To assist, you will find our technical guidance here.
Yours sincerely
Philippa Bullen
Corporate Communications Officer

Dear Alastair McNeill

Thank you for your email. The Commission does not have the resources to respond to all consultations, and it is not our practice to respond to consultations on local plans or infrastructure projects unless they raise a clear or significant equality or human rights concern.
Local, Parish and Town Councils and other public authorities have obligations under the Public Sector Equality Duty (PSED) in the Equality Act 2010 to consider the effect of their policies and decisions on people sharing particular protected characteristics. We provide advice for public authorities on how to apply the PSED, which is an on-going legal obligation and must be complied with as part of the planning process. Thus, the PSED is the mechanism through which public authorities involved in the planning process should consider the potential for planning proposals to have an impact on equality for different groups of people. To assist, you will find our technical guidance here.
Yours sincerely
Philippa Bullen
Corporate Communications Officer

[SEE ATTACHED DOCUMENT]

6. Options for Meeting the Objectives and Delivering the Vision

Re Site Reference Number: A24

We as Landlord would strongly oppose to any development on Station Field, Arnside. Our objections are as follows:-

Our building comprises of 32 privately owned residential retirement flats immediately next to the proposed site for development. Any buildings would have a huge impact on the residents particularly if houses were to be built close to our boundary wall which runs along the entire side of the field. Residents on this side of the building would have their privacy invaded and noise levels would certainly be an issue, with the ground floor flats loosing considerable light.

Restricted access due to the entry from the main road only (Ashleigh Road is privately owned and could not be considered for public use). This would mean less parking on an already busy road and spaces would be reduced due to access into a new development.

Flooding: Station Field has a high level of flooding all year round therefore to consider any type of housing would be quite out of the question.

Station Field is in an area of Outstanding Natural Beauty and any dramatic changes such as the suggestions been made would have a devastating effect on the landscape. The Salt Pans which were at the top of the field have already been severely damaged due to previous temporary works that were carried out in the field.

Re site Reference Number: A22

We oppose the development of parking along the front of the field as it is constantly under water and again, too close to our boundary wall. Noise levels would be a huge issue to anyone living on this side of Ashleigh Court.

Kind Regards,

Angela Simpson
Estate Manager
Hanover Housing

[SEE ATTACHED DOCUMENT]

[SEE ATTACHED DOCUMENT]

[SEE ATTACHED DOCUMENT]

[SEE ATTACHED DOCUMENT]

Hi
Please find attached initial comments from the School Planning Team – I look forward to providing additional information throughout the process:

Response to Arnside and Silverdale AONB Issues and Options November 2015

In response to Arnside and Silverdale AONB Issues and Options, I would like to thank you for the opportunity to be involved in this process.
Overall Summary

Section 14 of the education act 1996 dictates that Lancashire County Council's statutory obligation is to ensure that every child living in Lancashire is able to access a mainstream school place in Lancashire. Some children have Special Educational Needs for which they access school provision outside of Lancashire. The Strategy for the provision of school places and school's capital investment 2015/16 to 2017/18 provides the context and policy for school place provision and schools' capital strategy in Lancashire. Over the next three years, Lancashire County Council and its partners will need to address a range of issues around school organisation in order to maintain a coherent system that is fit for purpose, stable, and delivering the best possible outcomes for children and young people.

The main issues to be addressed are:
• The urgent need to provide additional primary and secondary places in some
parts of the county;
• The sufficiency of suitable education provision for children with special
education needs and children who require alternative provision within County;
• The need to keep under review, and take appropriate action where necessary,
the fall in secondary school numbers; and
• Continuing to support the educational viability of the high proportion of small
schools in the county, where appropriate.

Where new housing development creates a demand for school places in excess of
those available, Lancashire County Council will expect district councils to work with
Lancashire County Council in seeking a financial contribution from the developers
that is proportionate to impact in order to mitigate against the effect of any new
development on local infrastructure. It is critical that developers make a financial
contribution to school places as, without one, Lancashire County Council will be
unable to deliver the required provision and this will impact on the children and
families that come to settle in new developments.

The team produces an Education Methodology document which outlines the Lancashire County Council methodology for assessing the likely impact of new developments and, where necessary to mitigate this impact.
The impact of any housing development is assessed, with Primary school aged pupil accessing a school within 2 miles and a secondary school aged pupil within 3 miles. This is reflected within Lancashire County Councils Home to School Transport Policy.
Pressure for additional school places can be created by an increase in the birth rate, new housing developments, greater inward migration and parental choice of one school over another. If local schools are unable to meet this demand, a new development can have an adverse impact on the infrastructure of its local community.
Planning Obligations will be sought for education places where Lancashire primary schools within 2 miles and/or Lancashire secondary schools within 3 miles of the development are:
• Already over-subscribed,
• Projected to become over-subscribed within 5 years, or
• One of the major challenges in providing new places is the lack of current school sites capable of supporting expansion.

If a large new housing development is proposed (more than 150 houses), it may not be feasible to expand existing schools. In such cases, Lancashire County Council will undertake an initial assessment on whether a site may be required, taking into account the existing provision in the area. If the development is large enough to justify the possibility of a new school, the developer may be asked to contribute a suitable school site as part of the development. Where a number of small developments are expected to come forward in an area with an aggregated requirement for a new school, Lancashire County Council would expect the local planning authority to assist in the negotiations to secure a school site.
In the case of the provision of a school site Lancashire County Council would expect to be consulted on the location of the school site to ensure its suitability. The size of this site would be determined in accordance with DfE guidance.

[SEE ATTACHED DOCUMENT]

Waste management (with particular reference to Q23 - but more fundamental)

The lack of rural sewerage provision in a significant part of the AONB is a major issue and one whose resolution needs to be seen a priority through the DPD process. This includes enforcement and better monitoring but also better design standards. If rural sewerage is not possible, a bespoke solution may need identifying. Currently diffuse pollution is compromising the condition of a number of water bodies in the AONB, and domestic discharges are a recognised as a significant component of the issue.

Open Spaces

Q18 - include orchards and relict orchards in elements list.

Biodiversity (with particular reference to Q22)

We note that a number of the offered sites would have direct or indirect impacts on designated (SSSI/SAC etc) and on Local Wildlife Sites (known as “Biological Heritage Sites” in Lancashire). We assume and expect that these will be rapidly screened out of the DPD process.

Development appraisal should not only be sensitive to current loss but also sensitive to loss of restoration potential and maintenance, enhancement and restoration of local sites and ecological networks and those of the wider Morecambe Bay Nature Improvement Area. There is a need to better understand the role that the fabric of the Arnside & Silverdale AONB plays in connecting sites and enabling movement between them. Some areas that are not designated may be key linkages. We note that the AONB features strongly in many larger scale assessment of are of key ecological linkage; for example Buglife’s ‘B-lines’ project, the work of Morecambe Bay NIA, and the evolving Lancashire ecological networks.

There should be a pro-active aim to support key species that form a part of the settlement character.

There is a need to recognise that the biodiversity identity of the AONB is not framed around the presence of one or two ‘iconic’ species but rather the diversity of species and species assemblages - some widespread, some very specialised, and many not labelled as ‘S41 species’ - that are found here and which, in combination, lead to it being a ‘biodiversity hotspot’.

We hope that you find these comments useful. They are made on behalf of our Area Conservation Officer for Northern Lancashire, Ms Kim Wisdom, to whom correspondence should first be sent.

Response to your consultation

The Marine Management Organisation (MMO) is a non-departmental public body responsible for the management of England’s marine area on behalf of the UK government. The MMO’s delivery functions are; marine planning, marine licensing, wildlife licensing and enforcement, marine protected area management, marine emergencies, fisheries management and issuing European grants.
Marine Licensing
Activities taking place below the mean high water mark may require a marine licence in accordance with the Marine and Coastal Access Act (MCAA) 2009. Such activities include the construction, alteration or improvement of any works, dredging, or a deposit or removal of a substance or object below the mean high water springs mark or in any tidal river to the extent of the tidal influence. You can also apply to the MMO for consent under the Electricity Act 1989 (as amended) for offshore generating stations between 1 and 100 megawatts in England and parts of Wales. The MMO is also the authority responsible for processing and determining harbour orders in England, and for some ports in Wales, and for granting consent under various local Acts and orders regarding harbours. A wildlife licence is also required for activities that that would affect a UK or European protected marine species.
Marine Planning

As the marine planning authority for England the MMO is responsible for preparing marine plans for English inshore and offshore waters. At its landward extent, a marine plan will apply up to the mean high water springs mark, which includes the tidal extent of any rivers. As marine plan boundaries extend up to the level of the mean high water spring tides mark, there will be an overlap with terrestrial plans which generally extend to the mean low water springs mark. Marine plans will inform and guide decision makers on development in marine and coastal areas. On 2 April 2014 the East Inshore and Offshore marine plans were published, becoming a material consideration for public authorities with decision making functions. The East Inshore and East Offshore Marine Plans cover the coast and seas from Flamborough Head to Felixstowe. For further information on how to apply the East Inshore and Offshore Plans please visit our Marine Information System. The MMO is currently in the process of developing marine plans for the South Inshore and Offshore Plan Areas and has a requirement to develop plans for the remaining 7 marine plan areas by 2021.
Planning documents for areas with a coastal influence may wish to make reference to the MMO’s licensing requirements and any relevant marine plans to ensure that necessary regulations are adhered to. For marine and coastal areas where a marine plan is not currently in place, we advise local authorities to refer to the Marine Policy Statement for guidance on any planning activity that includes a section of coastline or tidal river. All public authorities taking authorisation or enforcement decisions that affect or might affect the UK marine area must do so in accordance with the Marine and Coastal Access Act and the UK Marine Policy Statement unless relevant considerations indicate otherwise. Local authorities may also wish to refer to our online guidance and the Planning Advisory Service soundness self-assessment checklist.

[SEE ATTACHED DOCUMENT]

[SEE ATTACHED DOCUMENT]

[SEE ATTACHED DOCUMENT]

3. Evidence Base

Q2
Yes, for affordable housing. Assume that the existing housing stock will satisfy the market housing needs.

Q3 More complete evidence is needed on locally important heritage assets. More evidence is needed on the impact of the few, large, attractions and events.

4. Vision and Objectives

Q4 Add ‘appropriate’ to the design in first bullet .

5. Policy Issues

Q6 The absolute number, rather than the proportion, should be specified. See answer to Q2 above.
Q7 Yes, if possible. This will encourage the local economy. See answers to Q2 and Q6.
Q9 Yes, there should be a policy. There is little need for agriculture and forestry workers in AONB. This could be solved by restrictions to use by ‘agricultural workers’.
Q11 Yes. The density should be high for starter and affordable homes.
Q13 The area is suited to clusters of ‘high tec’ internet based firms which have little impact on the landscape.
Q14 All the quoted types of energy have severe impacts to the AONB and should be discouraged in AONB and its environs.
Q15 There should be a presumption against major new infrastructure.
Q16 More parking is needed near recreational nodes such as Yealnd Storrs, Yealand Conyers village, Jenny Brown’s, Sandside promenade, Beetham village and particularly Heron Theatre. Some of these could be soft engineered for use only at peak times.
Q17 The DPD should uphold the Las positions.
Q19 No
Q21 Uphold the present policies.
Q22 A policy should be developed to map, and protect from development exposed limestone pavement and rock faces.
Q24 There should be a ‘local list’ and the very restricted historic landscape survey should be widened to include older features such as enclosures and historic routes.
Q25 There should be an AONB design guide for new build, extensions and the protection of existing structures.

6. Options for Meeting the Objectives and Delivering the Vision

Q26 Options (i) – (iii) are preferred.


Site Locations Supplement to Q27
We would not wish the following suggested sites to be developed since they are important in the landscape, have good recreational potential or are on isolated rural sites.
A2, A7, A97, A106
B31, B36, B40, B73, B74, B104
S44, S48, S50, S52, S55, S58, S62, S64, S98
W86, W87, W88, W89, W85
Y103

[SEE ATTACHED DOCUMENT]

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

[SEE ATTACHED DOCUMENT]

[SEE ATTACHED DOCUMENT]

Section 5: Policy Issues

Para 5.17
Sport England welcomes the intention to secure contributions for community infrastructure through CIL or s106 agreements. However, I would appreciate the following comments being taken into consideration as CIL progresses.

Experience, training and legal advice suggests to Sport England that the following three guidelines should apply:

1. CIL should specifically exclude any mitigation measures required to make a development proposal satisfactory in planning terms, e.g. if housing is proposed on playing field the mitigation for that loss under NPPF Para 74 should be dealt with OUTSIDE of CIL.
2. CIL 123 lists should only include defined projects and not use generic statements such as ‘Indoor Sports Provision' and 'Outdoor Sports Provision'. Our understanding of the legal position is that where a generic statement is used for a facility type then all provision is caught within CIL and therefore none can be delivered via S106 (to avoid double dipping). Whilst there is some clarity re. what S106 will cover (providing clarity in those instances only) the fact that no projects have been listed under the CIL column for CIL funding will mean all outdoor sports projects not listed in the S106 column will by default be expected to be funded by CIL therefore the LA will be prevented from seeking S106 funding for anything other than clear mitigation on those sites listed. Sport England therefore suggests the CIL column is revised in terms of both Indoor and Outdoor Sports Provision to include ONLY SPECIFIC PROJECTS THAT CAN REASONABLY BE FUNDED THROUGH CIL.
3. CIL 123 lists should be kept to a list of major key priority projects and not seek to deliver all infrastructure. These projects should be the big ticket items where S106 pooling restrictions prevent S106 agreements being a practical tool and where CIL receipts are sufficient to deliver within a reasonable timescale. The project list should exclude smaller projects/improvement schemes that are simpler/quicker/more enforceable for developers/LAs to deliver on or off site via S106 agreements where delivery can become a planning requirement.

Sport England therefore recommends:

1. The CIL list includes specific projects for sport facilities (indoor and/or outdoor) and not generic statements.
2. The statement clarifies that:
a. Mitigation for loss under NPPF Para 74 falls OUTSIDE of CIL
b. Clarification that S106 agreements will be used to secure new sports facilities needed to meet new demand arising from development for sports facilities (indoor and outdoor) where not already sought through the CIL (e.g. CIL may be used to fund a new leisure centre to meet growth in demand for swimming pool BUT S106’s would be used to fund all outdoor sport).the following issues should be taken into consideration as CIL progresses:

Any contribution must be based on evidence and the appropriate evidence for sport and recreation is a Needs Assessment to comply with the requirements of paragraph 73 of NPPF. Sport England has two guidance documents that’s et out an approach to Assessing Needs and Opportunities for:

• Indoor and Outdoor Sport ‘Assessing Needs and Opportunities Guidance’ http://www.sportengland.org/facilities-planning/planning-for-sport/planning-tools-and-guidance/assessing-needs-and-opportunities-guidance/
• Playing Pitch Strategy Guidance ‘An Approach to developing and delivering a playing pitch strategy’ http://www.sportengland.org/facilities-planning/planning-for-sport/planning-tools-and-guidance/playing-pitch-strategy-guidance/

Both guidance documents set out an approach to gather the required evidence and the approach can be tailored to suit the study area. Both guidance documents result in the preparation of site specific action plans that can then be used to direct investment either through developer contributions or funding opportunities.

Question 12

Without evidence from an Indoor and Outdoor Needs Assessment and a Playing Pitch Strategy it is impossible to determine whether allocations for sport and recreation uses are required. Without these assessment of need it is not known what the supply/demand balance is and whether there are deficiencies in the area that could be addressed through new allocations.

Question 18, 19 and 20

No consideration has been given to the function of the open space. Sport England would see playing fields in use as Important Open Space as they provide venues to participate in sport and meet sporting needs in the area. Paragraph 74 of NPPF and Sport England’s Playing Fields Policy make no distinction between privately and publicly owned playing fields and the policy requirements must be adhered to irrespective of ownership. Sport England is a statutory consultee on all planning applications that affect playing fields and our policy should be considered when formulating policy and considering allocations and designations:
http://www.sportengland.org/facilities-planning/planning-for-sport/development-management/planning-applications/playing-field-land/

Without aerial photographs I cannot tell whether any of the sites identified as potential development sites are existing playing fields or last used as a playing field and remains undeveloped. If there are any playing fields used proposed, existing or disused, then a Playing Pitch Strategy will need to be prepared that clearly demonstrates the site is surplus to requirements and is not needed to meet an identified existing or future need. Sport England will object to any subsequent allocations on playing field without the appropriate evidence in place.

I hope you find these comments useful and please do not hesitate to contact the undersigned if you have any queries.
Fiona Pudge BA (Hons) BTP MRTPI

6. Options for Meeting the Objectives and Delivering the Vision

These comments refer to one of the proposed development sites. Response to Q27.

B113 - Nunns Av, Garages. This would require the purchase of all the garages which belong to nearby residents, several of which have been re-developed or had significant amounts of money spent on them. Many are put to extensive use and it is therefore unlikely the owners would want to sell them, particularly as many who own them have nothing equivalent attached to their properties. Access to the back area would be through a narrow entrance, which would be difficult, if not impossible, to widen, and in its present state and dimension would probably preclude the entry of large vehicles such as delivery and refuse collection. There is also an underground spring which leaves the area wet for much of the time.
.

5. Policy Issues

The comments below refer to section 5.31/Q22.

Biodiversity consideration should be extended to include urban biodiversity, specifically to wildlife which is dependent on man and his dwellings. Bats are well protected under current legislation. However certain bird species such as the swift, do not enjoy this level of protection leaving them vulnerable to disturbance and loss of habitat. The AONB is fortunate in having a large contingent of properties which are of an age and construction which make them ideal for nesting swifts and also other predominantly house nesting birds such as house sparrows. This factor should be recognized as an important aspect of the AONB’s towns and villages. Arnside and Silverdale have healthy populations of swifts with smaller numbers occurring in locations such as Warton and Yealand.
The protection of swifts could be addressed in the following ways :
The Swifts in the Community project is currently mapping where all swifts are nesting in the AONB. This information could be available to planners which would allow any planning applications to be checked to establish if the property in question is used by nesting swifts. The information will not only inform planners about the presence of nesting swifts, but their precise location within the property.
However, most work done on properties which hold nesting swifts tends to fall under the planning requirement radar. Maintenance and development work can often be planned at a time when swifts are nesting and disturbance and the erection of scaffolding can have a serious impact on the swift population. This usually causes them to abandon completely any attempt at nesting and often results in them failing to return to the property in future years.
Swifts numbers have declined by nearly 40% in the last 20 years and it is believed to be the loss of their traditional nest sites which are to blame. In addition to protecting their exiting sites, the long term future for swifts, and also for other dwelling dependent birds, would be to increase the stock of properties which enable birds such as these to find suitable nest sites. There are a number of different solutions to this problem. Perhaps the most appropriate are special bricks which have been developed to fit into the outer skin of newly constructed buildings which enable birds such as swifts and house sparrows to find the type of nest site they prefer. The requirement to, or encouragement to, incorporate these into new constructions would go some way to addressing this issue.

The comments below are made in respect of their relationship with the comments made above re. statement of Issues and Options.

Consultation question (a) 4.2 Environment. Should mention the need to also consider the biodiversity of urban areas.

Consultation question (b) 5.3 Key Sustainability Issues and Opportunities. Table section Biodiversity Flora and Fauna. Should Mention the need to also consider urban biodiversity. Question (c) could refer to survey of swift numbers. Question (d) response would include mention of swift conservation within the AONB.

Consultation question (g) Table 6.1 section 10 should also refer to conservation/enhancement of urban biodiversity.

Appendix b Baseline data. Section 1.9 could mention baseline data for nesting swifts provided by Swifts in the Community project. It could also mention the opportunity to conserve and enhance the population of swifts nesting in towns and villages within the AONB.

6. Options for Meeting the Objectives and Delivering the Vision

These comments refer to one of the proposed development sites. Response to Q27.

B80 Keasedale Rd Storth. An area of valuable woodland set on a steep slope with a public path going through, makes this an inappropriate piece of land to develop. The woodland provides a link for wild life moving between the Landscape Trust land at Teddy Heights and the gardens in the properties in Keasdale Rd/Av.

[SEE ATTACHED DOCUMENT]

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Thank you for your consultation and seeking the views of United Utilities Water Limited in this process.

We have reviewed your Arnside & Silverdale AONB Development Plan Document and supporting consultation documents and have no specific comments to make at this stage, but wish to be included in further consultations and where necessary, the development of your future growth plans and supporting policies, to ensure we can facilitate the delivery of the necessary sustainable infrastructure in line with your delivery targets, whilst safeguarding our service to customers.

[SEE ATTACHED DOCUMENT]

[SEE ATTACHED DOCUMENT]