Local Development Framework Consultation

[SEE ATTACHED DOCUMENT]

We have looked at the web site of responses you refer to and are extremely concerned at the negative conservation and heritage suggestions referred to in the response from Mr. and Mrs Kitchen (ref 28 November 2016 Plot A11). We therefore wish to reinforce our own response are follows:

We strongly object to 2 of their recommendations

1. Trees on the eastern boundary. We see the retention of this vegetation as a tremendous asset forming an existing screen to any development viewed from the east. Although this vegetation may well have grown up since the 1950’s it is now reasonably mature and also provides an important wildlife habitat. Bat roosts in particular need survey work. The over grown trees / hedge line is now regularly used each evening by bats. We are trying to extend this line of vegetation and habitat along our own adjoining property and would object strongly to its removal merely to enhance the views from new/adjacent properties.

2. Site access. The access to the proposed development (if allowed at all) should definitely not be off the access track to Nos. 30, 31 & 32 Briery Bank which is on the blind bend. As stated in our first response the existing limestone wall is an historical and important part of the original fabric of Arnside dating back to the 1750’s and shown on the tithe map long before the construction of Briery Bank or its housing. To destroy this wall for the sake of a new housing development would be sacrilegious. Access must be off Briery Bank preferably to the southern end of the plot on the straight section of the road where sight lines are improved.

Regards,

Peter Goulder and Sheila Porter

[SEE ATTACHED DOCUMENT]

[SEE ATTACHED DOCUMENT]

I have read the submission made by Arnside Parish Plan Trust on 30th December 2016 and fully support their comments and conclusions as they relate to Arnside.

I wish to comment on the submission made by Arnside Parish Council on 3 January relating to two sites which are currently designated as Key Settlement Landscapes - A15 The Common and A18 Station Field. The Parish Council suggest extra development in one (A15) and redesignation of the other (A18) to allow a carpark to be built.
I do not agree with either of these suggestions and am opposed to the development proposals. I consider that these important landscapes should be preserved as key landscapes as the DPD proposes, and that another solution should be found for extra parking on the edge of the village.

No

[SEE ATTACHED DOCUMENT]

I Refer to land rear of Whinney Fold Silverdale. I oppose any development
I am surprised this piece of land has even been suggested for development. There is limited infrastructure in silverdale. Roads accessing and around the village are poorly maintained. Railway station over a mile away with at least half that distance on unlit country lanes. No bus service to speak of and our local shuttle service under threat. There are no mains sewers in the village so all water, surface and sewage is left to soak away in to the porous limestone that the village is built on. This has been the case sine the village came into being. How much more foul watert can we pour into the rock before we start contaminating the shore and Morecambe bay and destroying the habitat and wildlife, if we aren't already. The proposed land floods. The surrounding area is basin shaped so all water accumulates at the lowest point. Which will include liquid from any sewage plants. A development will increase the speed of run of due to the introduction of Tarmac and Concrete covering the porous field. I feel this will increase the flood risk.

Site A25 Station House

As outlined in our letter prior to the Draft Plan Consultation, when we were first made aware by South Lakeland Council that the site of our new home had been proposed for development, we can confirm that we wish to withdraw site A25 as a development plot.

Ian and Rona Carr

Following to my discussions with The Development Team at the recent Storth public consultation I would like to make the following points.

In regarding site B35 which I am the owner.

As residential developments boarder the site absolutely (Kingfisher House) this is the obvious place for the extension development. Not industrial, I cannot foresee it being used for any other commercial activity apart from what is currently occupying the site.

I must also disagree with the flood rating of 3a which you said comes from the Environment Agency Model, I disagree with this with seven generations experience of the site and photographic evidence.

The site currently is at a high that does not flood, large amounts of fill raising its level over the past three decades, and it would be very easy to mitigate any once in 100 year tide (this would be an 11m plus tide with a west by south west gale driving the tide in and the Rivers Bela and Kent being in Spate) by putting floor levels 18/24 inches above the present concrete/ hardcore. This would give any development a ground floor, floor height the same as The Flats at Herons Quay and would be easy to landscape in the front elevation 10m development line.

Prior to raising the level when it was owned by British Railways only the back side flooded as the tide comes up through a 12” cast iron pipe under (it is really the top water drain whose storm flap on the embankment has been removed or was never fitted but would be a simple remedy) Travis Perkins part of the yard (approx ten yards from my west boundary) flooding the Quarry Lane then spilled into what is now my yard, the modelling shows that this was unaffected!!! And it came from the front in through the gate which was wrong, that is why I disagree with the findings.

Also it shows all along the front, not taking into account that there is a four to five foot difference in levels between the Ship Corner and The Dixes Corner (I have photos that bare this out). None of the properties already there to the best of my knowledge have ever flooded or been close to flooding.

I would garner the relevant factual evidences to make these comments evidential at such time as the site was put forward for any residential development.

I do agree that the lower 40% of Travis Perkins yard floods and would be difficult to mitigate flooding but the other 60% would be economic to develop with flood mitigation.

[SEE ATTACHED DOCUMENT]

Site 56 - I object to this proposal:

1. This site in the small valley between Lindeth Road and Know Hill is an excellent example of Silverdale’s distinctive landscape that the AONB should be protecting. It’s a tranquil intimate valley with an ancient enclosure pattern and once built on it’s gone forever.

2. The plan suggests ‘approximately 6 dwellings’ but any developer would undoubtedly push for more. It will also set the precedent for further cumulative development. In 1997 when considering the existing Whinney Fold development the City Council’s Planning Committee report stated that: "The proposals have attracted considerable objection, following consideration of these and particularly the concern that the site might be extended in the future, the layout has been amended. The form of the access road has changed; its design has been downgraded to the standard required for a short residential cul-de-sac, so that there is no question of its being seen as a way of opening up the land to the south for further development. At the same time the position of the houses has been amended slightly, so that it would be more difficult to extend this road; access to the field is maintained for agricultural purposes only”.
This blatantly highlights that if the proposed 6 dwellings (or more) are allowed on this site it won’t stop there. I certainly don’t believe assurances that there will be no incremental development in the future.

3. The footpath which overlooks the site is well-used by locals and visitors. The views into the valley would be completely spoilt by any new buildings.

4. The drainage of the site is poor and prone to flooding in wet weather. There is no piped sewage in Silverdale and there are currently concerns about foul smelling effluent on the shore at the foot of Know Hill which will impact wildlife habitats. There will certainly be an increase to the threat of environmental contamination in an area within 200m of the Morecambe Bay SPA.

I attended the consultation event at Heron Hall in Storth on 23rd November, and was grateful for the clear explanations given by staff of the local authorities and AONB Unit.

I just have a few comments which relate principally to the Storth / Sandside area, which is where I live. I feel that the current draft Development Plan adopts the right approach in looking for sites which are appropriate for development and then considering what development would be appropriate on those sites, rather than trying to impose a pre-determined level of development on the area. The former approach is much more consonant with what is required in a nationally recognised (and protected) Area of Outstanding Natural Beauty.

The proposals in relation to Storth and Sandside seemed to me appropriate. Some new housing is needed, especially affordable housing, but this could appropriately be mixed with other types of development, particularly on the sites adjoining Quarry Lane. Hopefully, any development here will respect the beautiful and historic setting, adjacent to the centuries-old Ship Inn, and with the magnificent views across the estuary. The flats to the north of this site (christened by one of your councillors the “East Berlin Council Flats”!) are not a good model to follow.

I liked the idea of designating certain areas of land as of local importance to the community, even if they are not owned publically or by a local organisation or charity etc. The two sites in Storth / Sandside are particularly in need of such designation, since their features are very much part of what makes the village the place it is. The open fields south of Yans Lane, and the belt of trees parallel to Park Road and Storth Road are essential to the character of the settlement. The latter in particular is under threat, in my view, especially since the TPO was not confirmed. I support the management of this site (to part of which my own property is adjacent) by a management plan; but unless this process is put in train, the area will be harmed. Significant felling has taken place recently, seemingly to increase light to adjacent properties; and whilst some of this is small scale and not harmful, some of the work is producing visible gaps in the tree cover.

I hope that these comments are helpful.

Yours faithfully

Richard Daly

Objection to allocation of the Whinney Fold/Know Hill site in the AONB Development Plan

We would like to express our strong opposition to ANY development on this beautiful greenfield site and would question why this issue has raised its ugly head once again!
1. Serious sewerage and drainage problems -
Last winter's heavy rainfall again highlighted the drainage problem on this site, and the adjacent site to the south, 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! Building houses on this site, which lies in a hollow, would create a major problem in dealing with significant amounts of grey water and rainwater. Any effluent from this site could easily drain onto Silverdale shore and lead to a substantial pollution issue.
2.Major access and traffic issues
The access road to the existing Whinney Fold development is very narrow with resident's and visitor's cars frequently parked. Any further development on this site would make traffic conditions very problematic.
3.Greenfield Site
There are brownfield sites in Silverdale and these should be used before any greenfield sites are considered, and this consideration should only ever be as a last resort. To build on this beautiful green haven would be an environmental disaster. Indeed, Arcadis Environmental Consultants, as part of a landscape assessment of the AONB, concluded that development on this site would result in the loss of an important landscape element and would harm the local landscape and settlement character of the AONB. ANY proposed development on this site would be extremely unpopular throughout the village.

No-one should be naïve enough to believe that once the first sod has been turned on this site for an initial six house development that's where it would end - once it's gone it's gone forever! The AONB needs to be protected not scarred and every effort should be given to conserving its landscape and scenic beauty.

Finally, it is questionable whether there is a serious housing need on this site or elsewhere in Silverdale as there has been in recent years, and still is, a difficulty renting/selling low cost properties, e.g. flats.

Roy and Sylvia Davies

No

No

[SEE ATTACHED DOCUMENT]

[SEE ATTACHED DOCUMENT]

The following comments relate to policies and sites within Storth & Sandside described in “Draft Plan v16 171116” and “AS_AONB_Inset_Mapbook_Nov_Consultation_A3L_08Nov2016”.

1 As Treasurer of the Storth Playing Fields and Heron Hall Committee I strongly support the designation of B253 (Storth Primary School & green play areas) and B224 (Storth Playing Field and Heron Hall) as Open Space. The Playing Field Committee of local volunteers maintains and develops the facilities in B224, cooperating with the School to enhance the educational experience of the pupils through, for example, access to large-scale physical education activities, access to the Heron Hall for whole-school assemblies and drama activities. Heron Hall is also used twice each week by a local playgroup, and the field area provides significant play equipment for youngsters in the surrounding villages as well as picnic facilities for the general public.

2 The proposal for the inclusion of residential use in B35 and B81, particularly if a significant portion is “affordable housing” attractive to younger families with children of school age, is to be welcomed, and this would strengthen the existing provision of school and playing field facilities (described in comment 1) in the medium to long term.

3 The designation of B79 and B116 as “Key Settlement Landscape” is also strongly supported as this brings open space into the heart of the village. Were these sites to be developed, the rural character of Storth would be permanently changed.

4 In terms of the proposed “specific development requirements” to apply to sites B35, B38, B81 and B125, the recognition of the need for development to fully manage the known risks of tidal and run-off flooding is welcomed as is the requirement for mitigation measures to safeguard bio-diversity, to respect “materials, scale and character” within sites B35 and B81 in particular - Requirements I to VI, and IX to XI).

5 We strongly agree with the proposed development requirement (VII) to provide a “pedestrian access route” along Park Road from the Ship Inn to the exit of Quarry Lane. In conjunction with the re-think of access to B81 from Park Road to Quarry Lane at the Ship Inn (VIII) it might also be useful to provide a cycle way along Quarry Lane to improve safety for cyclists by avoiding the need to share Park Road with vehicle traffic and pedestrians.

N/A

N/A

[SEE ATTACHED DOCUMENT]

Overall I am impressed by the depth and capacity of this plan and fully support the landscape and biodiversity 'first' approach,
which I hope will become an exemplar to other AONB's and be adopted throughout the country.
The statement in the foreword of both Councils having a 'Commitment to applying polices consistently' is to be applauded and a great asset to the AONB.

AS05 Natural Environment - I fully support the intention and sentiment in this section.
V11 - compensatory measures - in addition to the measures X1 to X1V I feel that any species planted and habitat recreated should only
use locally sourced species, an approach that has already been successfully achieved in the area.

4.2.16 Local sites -Great strides could be made in collating the location and knowledge of these sites by coordinating the immense number of volunteer naturalists that already exist within the AONB

A MAJOR OMISSION - In the plan (as far as I can see) is the lack of recognition of the only natural habitat -
the limestone sea cliff face and immediate top. These are by their location non-intervention zones,
their management is largely directed by natural processes (wind, salt spray) some parts contain species rich grassland that has existed
without management for years and could be small remnants of 'Refugia' grassland i.e naturally occurring grassland that has survived
from the end of the last ice age. They have been and are being damaged by major extension seawards of the footprint around caravans at Far Arnside.

4.8 Camping, Caravan and Visitor Accommodation
AS12
(1) and (1V) I fully support this approach, but suggest that - There should be a clear distinction made as to the permitted
footprint of units and their spacing to prevent an incremental increase in size e.g a 'Lodge' is double the size of a static caravan
and is far greater in landscape impact but often passed off as less impact because of its plastic faux wood. Without restriction of what is allowed within the AONB, the future development and advances in technology and production, will lead to bigger units which would all be permitted because they are called by the name (Lodge/Caravan) that is mentioned in the plan.
(11) There needs to be a clear distinction between temporary movable - tents and more permanent pods yurts and shepherds caravans.
Most of the latter can have permanent bases and sometimes paths.
(111) - surely this clashes with the intended spirit of number (1)

4.8.6 and 7 Recent permissions have been given for pods within the footprint of sites which have countered the aims in the AS05 Natural Environment section of the plan where it states -

"Development proposals will not be permitted that would be likely to compromise the extent, value or integrity of:
(I) any site or habitat protected for its biodiversity or geodiversity value at an international, national or local level;"

Pods have already been built upon and destroyed species rich grassland which is designated a County Wildlife Site despite objections from Cumbria Wildlife Trust. So to allow more just because they are within the footprint does not guarantee that they will not damage irreplaceable habitats.

Well done, in the main it's an excellent plan, everyone involved deserves full praise.

I think the roads around this area will not be able to support much more traffic, so the first need is for a good, free car park on the outskirts of Arnside, preferably near the station. This will give access to both villages by car and rail, which will keep the extra traffic off the narrow, twisting lanes.

Yours sincerely,

Jean Field, Burneside

S56 South of Whinney Fold, Silverdale

I object to any development on this site. It is proposed back land development behind back land development.

The spreadsheet in Arnside and Silverdale AONB Development Plan Document states, “Cannot mitigate landscape impact of developing whole site. Planning application submitted and withdrawn (15/01400/FUL). Smalller area would have moderate landscape impact which could be mitigated, subject to satisfactory drainage/sewerage treatment, and specific biodiversity mitigation”.

If development is allowed on part of this site, because it would only have “moderate landscape impact”, it would be very difficult, and probably impossible, to deny extending the site because the precedent for development would have been set.

The original development, after protracted legal arguments and objections was granted, but designed so that there was no suitable (supposedly) access to the site past and behind the current properties on Whinney Fold.

The road where it joins with Shore Road already causes parking and access issues for residents and visitors to the properties on Shore Road. Any houses built on the site would need at least two parking spaces unless the future residents are expected to be benefit claimants or retirees.

This is because there is very little local employment, the railway station is over a mile from the village down unlit roads without pavements. The bus service, already under threat, only runs around the village and south. There are no buses to Arnside, Sandside or Milnthorpe, the areas where much of the local employment is sited or planned.

Anyone working further away from Silverdale, in any direction, on shift work or with early starting or late finishing needs their own transport and longer distance cycling is not an option for many working age people.

Shore Road is a cul-de-sac which leads down to The Shore across a cattle grid and onto what used to be a large car park. This is very popular and well used by visitors and locals who enjoy the amazing views across the bay.

Over time the car park has been reduced to a fraction of its size by the natural erosion of the coastline caused by the changing tidal flows and sand displacement.

What is left of the car park is prone to regular and sometimes prolonged tidal flooding making it unsafe to park for extended periods.

This means the whole of Shore Road is well used by car drivers, many with older or less active occupants, cyclists and a great many walkers of all ages.

The option of restricting parking, yellow lines or other enforcement measures would destroy the character and ambience of the road and surrounding area and ruin the visitor experience which is so important in the AONB.

The latest housing needs survey asked residents in each village in the AONB what their future housing needs were, which is a reasonable thing to do, but then aggregated the findings into a needs list for the whole AONB.

Family support systems, eg grandchild minding/taking to and from school etc, and older people supporting/caring for older parents, work access and availability make many of the aggregated housing needs unrealistic in this area.

Draft Arnside & Silverdale AONB Development Plan - Document Consultation

At the recent meeting regarding the above plan at Warton Village Hall on 7 December 2016 we were able to consult the documents relating to the proposed developments and would like to comment on these proposals.

Land NW of Sand Lane, Warton, W88 and Land North of 17 Main Street, Warton, W130

We are very concerned about building on green-field land and how this will affect local flood risks. Both these areas lie below Warton Crag and uphill of areas which have recently been flooded. Some occupants of the houses flooded to the south of W130 have only just returned to their homes since the flooding of December 2015.

Water pours down from the Crag when the rainfall is heavy and prolonged. This rainwater has to find a route downhill to the lowest point in the area. A development and farming plan for flood alleviation to improve the land use and the drainage should be considered which, rather than adding to this problem, could help to mitigate these local difficulties.

Carol Allen-Glaister (Dr) and John Glaister (Dr)

Thank you for the updated 'Consultation on Draft Arnside & Silverdale AONB Development Plan Document' which I received by email on the 10th November 2016.

It was good to see that you have now progressed to some more definite sites for final consultation. They seem to be quite small and discreet which is what many of the residents of Silverdale preferred.

I have attached my original letter (SEE ATTACHED DOCUMENT] regarding my thoughts. Unfortunately I was unable to attend any of the recent consultation events.

We have all been happy with the consultation process to date and feel that all of the sites including S50 on the original proposal were subject to a full, fair and open process of consultation.

I hope you can imagine my concern to find that the plot S50 seems to have been discussed with yourself at the recent Gaskell Hall meeting (24/11.2016) with a view to further planning applications.

It was our belief that this farmland had been fully in the mix and due process had eliminated it.

I wondered if you could clarify, to the residents who have boundaries around this land, exactly what is happening?

We are aware that this land is held in the Sarah Burrow Trust and that they have approached you, after a decision seemed to have been made, with what in mind?

Do they wish the land to be considered for low cost homes or are they looking to the planners for some sign that it could be developed by a private firm for an estate of private housing which would surely be outside of the intent of the DPD for our lovely AONB?

There are a lot of elderly and recently bereaved people living adjacent to this land and it would seem unnecessarily cruel to start this all up again when so many thought it had been put to bed.

We have only recently managed to win the planners over regarding the idea of the Skate Park on Spring Bank. Again an extremely stressful time for some of the older residents of Silverdale.

So I guess I am just trying to ascertain what is going on here so that we can start a discussion around what if anything needs to happen next.

Your comments and hopefully reassurance would be greatly appreciated.

Kind Regards

Susan Hadden

W130 - Land behind 17 Main Street Warton.

I have concerns about access, sewerage, flooding and surface water implications of the proposed development but will consider these in light of information from next week's consultation meeting at Warton.

There is, however, a flaw in the proposal that ought to be dealt with at a preliminary stage and this concerns the proposed line of the northern boundary. To minimise visual impact this should properly follow the existing line of the northern boundaries of the dwellings on Church Hill Avenue. I am a former government surveyor with experience in these matters and this morning took a sight line from the wall of Warton churchyard along the existing fence. The boundary ought to meet the hedge on the eastern side of the land to r/o 15 Main Street about 15 metres south of where it is shown on the plan. The proposed boundary line increases considerably the size of the development plot but it greatly increases the visual impact of the development.

W130 - land at rear of 17 Main Street, Warton.
I have previously expressed concern at the proposed line of the northern boundary of this development as shown on plan. As the site is behind existing housing rather than having a direct street frontage there are likely to be potential problems from sewerage, surface water and flooding in an area already susceptible to problems in these respects. I assume that the developer will be required to provide adequate safeguards in respect of these issues.
A particular problem with W130 is that of access. Vehicular access from Crag Road would clearly have a severe impact on the Warton Crag local nature reserve. Access via a continuation of Church Hill Drive appears impossible. This leaves only access from Main Street. In principle I would object to this on traffic grounds but given existing housing along Main Street anyway it is not easy to see where such access might be obtained? On balance then this proposed development raises far too many issues of impact, intrusion and access to be worth serious consideration.

No

No

LCC and SDLC are to be congratulated on providing a strong framework of relevant legislation and current good practice against which the advisability of any future development can be assessed. This is important for the Arnside and Silverdale AONBs but also nationally as the innovative approach is likely to inform the deliberations of authorities across the country.
Given this significance, locally and nationally, I feel it is necessary to point out a serious inconsistency between the spirit of the Draft Document, set out in the Vision and Objectives and Overall Strategy, and the letter of its implementation in a particular proposed development allocation. The proposed development site in question is AS23 - S56 Land at Whinney Fold, Silverdale, for a development of approximately 6 dwellings on a site of 0.30 hectares.
There are a number of problems with this site:
Traffic Access - Whinney Fold is narrow and twisting and barely copes with the 11 dwellings it already serves.
Sewerage disposal and flood risk - The field floods in winter and sewerage outflow from the present 6 house development has contaminated the nearby shore.
Presence of Wildlife - The field is separated from Morecambe bay by a low hill and hosts curlew, oystercatcher, redshank and shellduck. These habitats would be put at risk by further development.

However, the main issue is that of the adverse impact on the "distinctive quality, character and tranquility" which still exists in this part of the AONB. (Statutory Management Plan, pp. 1.6 DPD Discussion Paper.
The allocation of this site would seriously threaten the distinctive landscape character of the Silverdale AONB for the following reasons:
Any development would need to "reflect the settlement character" and "take full account of the cumumlative and incremental impacts". This site is immediately adjacent to the 6 dwelling mini housing estate built by Two Castles Housing Associatioin in 2004. The development of "approximately" 6 more - reflecting the adjacent settlement character - would result in , at the very least, a 12 dwelling housing estate definitely affecting adversely what had been a quiet valley, close to the sea with visual access and a feel for the natural land forms which characterise the area.
Further, it is difficult to believe that "approximately 6 dwellings" means only 6. Already the developer who had unsuccessfully proposed to build18 units on the same but extended site is in conversation for a 10 unit development. It seems that because 6 units is commercially unattractive any future developer will push the "approximately 6" for more, resulting in a larger development with further adverse impact on the remaining landscape.

Consequently, the obvious and best way to safeguard the special qualities of the AONB, set out on p.3 of the DPD - outstanding landscape and spectacular views; unique limestone geology; rare and precious habitats; rich sense of history; sense of tranquility, space and place - is to remove the land at Whinney Fold from the proposed list of Developoment Allocations. This would also bring the letter of the DPD'S specific recomendations in line with the spirit of its impressive Vision and Objectives.

[SEE ATTACHED DOCUMENT]

[SEE ATTACHED DOCUMENT]

[SEE ATTACHED DOCUMENT]

[SEE ATTACHED DOCUMENT]

[SEE ATTACHED DOCUMENT]

[SEE ATTACHED DOCUMENT]

[SEE ATTACHED DOCUMENT]

[SEE ATTACHED DOCUMENT]

Dear Sir /Madam,
Having attended the Draft Plan Consultation Meeting at Arnside E.I in November, I was reasonably heartened by what I heard. A lot of time and effort had gone into deciding the most appropriate sites for development within the AONB. There are still several controversial sites remaining - Whinneyfold at Silverdale being such an example - but overall I felt a lot of progress had been made.
It was therefore with a great deal of concern, that I heard about a possible new site in Silverdale, in the bottom section of the field that runs from Clarence House to the back of St Johns Church.
If this land were to be considered it would contravene everything that we associate with sensible development in an AONB.
It is Greenfield.
It is highly visible.
it would seriously impact on traffic/ safety, in what is already a very busy area....access would be near the school.
It would have significant sewerage issues.
It has limestone bands running across it.
It has a prominent mature tree in the section where the building is proposed.
ETC................!
Furthermore a development of this size is not needed in the Village.
Even before plans are submitted, I urge the Planning Department/Officers, to reject this proposal outright.
Thank you.
Jane Lambert.

Development of land at Whinneyfol, Silverdale.

Once again I find myself commenting on Greenfield Developments in an AONB.
I had hoped that after all the recent consultations, this type of development would no longer 'rear its ugly head'.

I object to this development on the following grounds - in no particular order;

1. It is a 'Greenfield' site and is set in an attractive little valley. Is this not the very thing the AONB wants to protect?
2. Drainage is very poor. The land floods in heavy rain.
3. Sewerage would be a significant issue. It is already a problem in the Village as we have septic tanks.
4. Access is poor, and there would be safety implications.
5.It would cause significant intrusion on existing properties.
6. Development here, could lead to further development at a later date - despite what has been said about a barrier!!!!I

I am not against development on 'brownfield sites', with existing infrastructure. There are places in Silverdale that 'fit this description'. It is up to the Planning Authority to make sure the appropriate housing is built on these Sites - houses that meet the needs of the Village!

Thank you for the opportunity to comment.

Nothing new to raise. thank you.

No thank you.

[SEE ATTACHED DOCUMENT]

[SEE ATTACHED DOCUMENT]

[SEE ATTACHED DOCUMENT]

[SEE ATTACHED DOCUMENT]

Site W88 Land North West of Sand Lane 1, Warton
Site W89 Land North West of Sand Lane 2, Warton

This land is adjacent to my property. Not only would you devalue my property you would seriously encroach on my quality of living with a housing estate built next to my property. I moved back here to live in our family home to enjoy the area of outstanding natural beauty I grew up in, in the house I grew up in. The house is next to our business premises. The views we have need to be seen to be appreciated, when my father built this house nearly 50 years ago he had to go through stringent planning processes to cause the least impact on the environment and area and we were building on land that already had building's in place, not a green field site. The access was made with land my father gave to the highways to make the brow of the hill on Sand Lane wider and the access to our property and garage along side is very wide and set back to enable ease of access and exit. We planted trees, landscaped a huge part of the site for it to remain grass and followed strict rules on how and what could be built. Not 20-30 houses squeezed into a plot regardless of the impact on the area around. The access to the sites in question above W88 & W89 is a single track onto the busy road of Sand Lane and is dangerous to pull out of, the vehicle has to be in the road to enable the driver to see from their window to the road up Sand Lane. This road is already busy with parked cars and traffic to Silverdale.
I am hugely opposed to development on this site, this green field is in full view of Warton Crag, the impact on the area and wildlife habitat would be huge.

The land in question is owned by the same person, who has already had planning granted and has subsequently sold the site and planning at W34. He has also been granted planning at sites W84, W85 and W86. How far are you going to go to allow development of this nature on green field sites for profit. He is also proposing development of sites W88, W89, W92, W93, W95. We live in an area of outstanding natural beauty, people come to our garage and park up to take photo's of Warton Crag and Ingleborough from the top of the hill. This would all go as they would not even be able to see Warton Crag from the roadside only houses. The other issue I have is that they are never happy to put a handful of houses on the land, it is always in the twenties impacting on the highways, the drainage, the whole of the village that already has no shop or facilities other than pubs and a church. We are not a town with all the amenities that houses on this scale require and Mill Lane is already congested and dangerous at peak times due to the width of the road and the amount of traffic going to and from the village. The pavement on Mill Lane is dangerous and there is barely room to walk on it. These plans have already eaten into our area of outstanding natural beauty and are just going towards Warton becoming a town rather than a village.

Eventually all our lovely green fields will have been covered in houses and roads and the view of Warton Crag will be a distant memory with widespread flooding due to no green areas to take the excess water than runs down from the higher fields above and Crag areas. The impact on the environment, wildlife and birds will be enormous, we have squirrels visit most days, birds and wildlife are a normal everyday view from our windows into the site that is W88 and W89. To have all this killed off and moved for housing is unthinkable.

[SEE ATTACHED DOCUMENT]

[SEE ATTACHED DOCUMENT]

[SEE ATTACHED DOCUMENT]

Site reference: S56 - Silverdale. I oppose this proposal.
I would like to comment on three aspects of this site, two general, one specific to our property.
Specific:
1. A building proposal for 18 houses on this site was withdrawn earlier this year. However, this plan included changes to the access road, such that the road passed only 50cms. from our front gate.Since our property (7 Whinney Fold) is surrounded by 6 foot walls, we would have no sight lines on leaving it by car. For the safety of passers-by we need a minimum of 150cms.
General:
1. Drainage problems. The site is at the northern margin of a depression at the 20metre contour. In wet weather (eg December '15) water collects in the southeast corner of the site field, so grey water from the houses and run off from the sewage digesters would also collect there unless it were to be pumped elsewhere. (The present houses in Whinney Fold are at a higher level)
I understand that the Silverdale area, with approximately 850 houses,360 static caravans and perhaps 60 tourers already exceeds the limits permitted under EU legislation for areas without mains drainage. Foul smelling effluent has recently been detected on the shore below Whinney Fold and investigated by the Environment Agency. Further building without investing in proper mains sewerage should not be permitted.
2. Road suitability. The access road has poor pedestrian access, and was not designed for a greater load than the present. The access road is particularly narrow at the entrance.
W G Park, 7 Whinney Fold.

I fully support nearly all the policies in the plan. My only caveat is that as touring caravans cause such disruption on the road system extra pitches should not be allowed and, in well-screened positions, existing pitches could be made for permanent use if the design, materials and colours of the caravan/chalet were appropriate to the location.
My other comments are details in Warton:
site W130 would be acceptable on landscape impact but access is problematic (and it is N. of Main St not Market St). There are three imposing dwellings to the south (15, 17, 19 Main St). These must be protected from demolition or severe loss of setting. In particular 17 should be listed. It is a dressed stone grey granite building dating from the 1890s and was built by the Station Master at Carnforth using stone brought in by the railway. Both the quality of the building and its historic value from the heyday of Carnforth as a railway town make its survival imperative. In addition, on no account should access to the site be allowed from the Crag Rd which is narrow and steep and quite unsuitable for any extra traffic pressure.
Site W88 is the other major site suggested in the village. Again its landscape impact would be minor but run-off from the Crag and fields is a problem to the houses on the east side of Sand Lane. Any development must be such that it lowers the run-off in times of heavy rain.
W215 (The school playing field) I welcome as protected green space. But the neighbouring field which was put forward as a possible development site (W90/91, I think) is just as important as it lies between W215 and a well-used public footpath and gives open vistas from the school across the valley to the Bowland Fells. This gives the school and the playing field, which are both used for community events, their rural setting. If this were developed the school would become a suburban one, not a rural one and the rural setting of the village would be severely damaged.
The other important open space is the area between Warton Village and Millhead. Although the policies give this sort of buffer protection, it would be better to strengthen that by designating this area as important open space.

[SEE ATTACHED DOCUMENT]

AS23-SF6 Whinney Fold Silverdale. I oppose this proposal.
The AONB DPD Draft proposal is a positive and dynamic document covering all aspects of development in our very special, sensitive area. This should therefore be the definitive reference point for any planning applications within the AONB.
The above application goes against the ethos and spirit of the said Draft Plan.
My objections are thus:

The preservation of the distinctive quality and tranquility of the landscape would be absolutely damaged . This is a peaceful,green,rolling valley. Permission for 6 new dwellings is unacceptable. Builders rarely settle for so few dwellings more will follow. It is the opening up of a site which they require.

Access/ visibility to this site is poor for the existing properties. Parking on Shore Rd exacerbates this.

The site proposed is low- lying and prone to flooding. This impacts on current septic drainage tanks which overfolw onto the foreshore.

The site is immediately behind the Silverdale Shore an important wildlife site.

Arnside site A9 Hollins Lane


My husband and I object strongly to the development plan for Arnside; especially to the development of 8 properties on the field on Hollins Lane. We have many concerns regarding this proposal.

The proposed development for 8 houses on Hollins Lane will mean a large increase in traffic on Hollins Lane; this could be as great as an extra 16 vehicles. Hollins Lane is a single-track lane with limited passing places for vehicles, and currently struggles to accommodate the traffic that uses it, particularly in rush hour. There are no passing places near the proposed development and any vehicles parked on the road would make it impossible for other vehicles to pass. The potential increase in traffic could be very hazardous; especially alongside the possible growth in numbers of young children. The positioning of the development is near a blind corner, on a single track road with no pavement. Both my husband and I have experienced near misses when walking along this stretch of road. As adults we were able to have the sense to quickly move to the side of the road when hearing vehicles approaching, small children may not do that. This could have tragic consequences. Hollins Lane is much busier during the holiday season when it is frequently used by tourists as a shortcut from Silverdale Road to Black Dyke Road.

Home Housing recently explored the possibility of building six houses on Hollins Lane. They found that that the land was unsuitable for the planned development. After considerable time surveying the drainage available they decided that the sewers on Hollins Lane did not have the capacity to support the additional waste from six properties and because of the density of limestone in the field there was not enough natural rainwater drainage on the land to sustain the development. This raises questions regarding the feasibility of a development of 8 properties and the ability to create suitable, sustainable drainage for domestic waste and rainwater..

The development on Hollins Lane will have a marked impact on the properties at the south side of the field; especially because of the gradient of the field. As a result of the Prescription Act of 1832, the windows of our property have earned a right of light by having well over the required 20 years of unobstructed daylight. This law also applies to our garden; which must receive adequate daylight on March 29th of every year. Because of the slope of the land on Hollins Lane any development on the field would cast a shadow over our house and garden restricting the amount of light to our property. Therefore the development would need to be built well away from our property and others on the south side of the field. This would ensure the quantity of light to the garden and windows is not adversely affected; causing the amount of light to fall below the accepted level, constituting an obstruction.

The Human Rights Act 1998, Article 8 offers protection for a person’s private and family life. It has previously been used to extend protection to a person’s office space as well as his or her domestic home. My husband and I feel that the protection of private life and the home is relevant to decisions made in the development plan for Hollins Lane as any development on the field on Hollins Lane would adversely affect our enjoyment of our property which may be an interference with our rights under Article 8. Because of the angle of the road and the incline of the proposed plot anyone in the gardens of the proposed development would be able to see directly into our bedroom, part way up the field they can see directly into our kitchen. This is not acceptable as it impinges on our privacy. Both the rear and side garden would have absolutely no privacy unless a high fence were erected, which would contravene the Prescription Act of 1832 as it would take the light from our property.

The case for privacy has recently been highlighted in the Yorkshire Dales when a planning officer dismissed an appeal against refusal of permission for three two-bedroomed property on land at Spedding. This was because the proposed development would severely harm on the privacy of neighbours.


We feel that the field has been chosen for the development solely on the grounds that it may be available as opposed to being suitable. One has to question why other more suitable sites have not been chosen as there are many other more suitable sites in Arnside. Sites that have much easier access to the amenities that Arnside has such as the primary school, the playground, local shops and the doctors surgery.

Policy AS 07 Key Settlement Landscapes. It is considered that the land to the west of Lindeth Road meets the criteria for a key Settlement Landscape and should be designated as such.

Policy AS 16 and AS 23. While supporting in principle the need to find sites to meet as far as possible the need for affordable housing to meet local needs within the AONB, I am concerned that this must be done within the context of paragraphs 115 and 116 of the NPPF. The DPD correctly states that it is not necessary to provide for all housing needs within the AONB and it is noted that there is no definitive quantification of housing needs in the AONB or in its constituent settlements. In the light of this, the very highest level of justification is required for development on site AS23, taking into account evidence about the demand from local people for the current affordable housing units at Whinney Fold.

Any development, if so justified, should be limited to a maximum of 6 dwellings in accordance with the findings of the Landscape and Visual Field Survey. It should be entirely contained within the site indicated, including any requirement for a drainage field given the adverse impact that it would have on the undulating landform of the current meadow. It must also be in keeping with the description of recent development in the AONB Landscape Asssessment as being loose and open in character and should not be a repeat of the existing Whinney Fold development, since both taken together would then constitute major development contrary to the spirit of paragraph 116 and would be a significant urban encroachment into this tranquil and intimate valley.

Given the absolute assurances previously given about no further extensions of the existing Whinney Fold development, it will be necessary to find a water-tight means of securing a defensible boundary as required by criterion i of the mini-brief, including a section 106 agreement and a layout which does not allow any access to the land to the south and east. This should be covered either in the policy or the Reasoned Justification. Further re-assurance on this would be given by allocating the remainder of the land within this valley as either a Key Settlement Landscape or, subject to detailed justification in accordance with the district-wide criteria, as Local green space (a separate submission will be made on this in due course).

Finally, there is concern that this allocation will be seen as an acceptance in principle of development on the Whinney Fold site and that a larger development will be justified on the grounds of viability. The DPD should make it clear that landscape considerations (in their widest sense) over-ride viability issues. Moreover any viability assessment submitted in support of development on this site should not be based on an exessive expectation in terms of threshold land value, given that the whole of the much larger land-holding including the Whinney Fold site changed hands relatively recently for only £60,000 and that there is no over-riding need for the land to be released within the context of an AONB.

With regard to the latter point above, it is considered that the report by HDH Planning and Development fails to take sufficient account of the policy context within an AONB, namely that the NPPF's requirement to boost significantly the supply of housing land does not apply to the same extent by virtue of footnote 9 to paragraph 14. This is of particular importance in supporting the stance taken by HDH that threshold land value should be in accordance with the advice of the Harman report, namely that it should reflect a premium over current use values, and not a deduction from open market land values. This was supported by the Inspector in the London Mayoral CIL Charging Schedule and is even more important in an AONB context where restrictive policies would lead to higher market-led land values.

No

[SEE ATTACHED DOCUMENT]

[SEE ATTACHED DOCUMENT]

I am commenting generally on the state of traffic in and through Warton. The very narrow Main St takes a lot of the traffic from Silverdale and the Yealands. Huge lorries, higher than the cottages frequently come through. New building of houses is going to add yet another 2/3 cars for each house. We will lose what little bus service we have because the buses struggle to get through. The pavements where they e ist are narrow and barely wide enough for 1 oerson. If you walk with a child, pushchair or dog, you struggle not to get wiped out by speeding cars
If there must be development major changes are needed to trafic management

[SEE ATTACHED DOCUMENT]

I have a comment related to the proposal of 16 dwellings on land north of 17 Main St., Warton.

I am concerned about the potential increase in traffic from additional homes particularly coming into Warton just past Sand Lane. There is a corner with limited visibility for both cars and pedestrians, and no pavement, so that pedestrians are forced to walk on the road. Few drivers heed the 20 mph speed limit as it is, and an increase in traffic increases safety risks.

An alternative is to incorporate a pedestrian footpath behind the existing buildings on the farmland that has already received planning permission for housing, although that does not assist access to the houses that already exist in that stretch of road.

Thank you for your consideration.

AS23 – S56 Land at Whinney Fold, Silverdale
I am a Silverdale resident and have very serious concerns about the allocation of land for housing development at this location:
1. This land is important for its scenic beauty in an AONB. It sits in an, as yet, unspoiled intimate valley where there are wonderful hedges, trees, woods a natural pond and historical field boundaries.
2. It is overlooked by a well used public footpath to the east of the site.
3. I do not accept that at this location, in an AONB, 6 houses could be described as a small development. They would not fit with the present building lines. They would protrude out into open fields. I ask that it is not accepted that such development could be adequately mitigated.
4. When considering the planning application for the existing Whinney Fold development in 1997, the City Council’s Planning Committee report stated that: "The proposals have attracted considerable objection, following consideration of these and particularly the concern that the site might be extended in the future, the layout has been amended. The form of the access road has changed; its design has been downgraded to the standard required for a short residential cul-de-sac, so that there is no question of its being seen as a way of opening up the land to the south for further development. At the same time the position of the houses has been amended slightly, so that it would be more difficult to extend this road; access to the field is maintained for agricultural purposes only" – To disregarded this statement would suggest that present assurances, that there will be no further development, are also likely to be disregarded.
5. It is suggested that a defensible boundary could be created to prevent further development. Common sense dictates that such boundaries’ are fine in theory but can always be overcome in practice, if there is sufficient profit in the exercise. Walls and houses can be demolished.
6. Silverdale, it is said, is the largest township in the UK without any mains drainage. In addition to its 1800 or so dwellings, it hosts over 600 static caravans and very many touring caravans. I would submit that a very detailed study of what is happening to sewage now should be undertaken before any consideration is given to any further development. We may be given assurances that any new development will have adequate, modern, sewage disposal systems, but it must be remembered this proposed development is literally only 200 metres from Morecambe Bay, a Special Protection Area (SPA)
7. The field in question is known to flood at times of heavy rain fall.
8. Regarding traffic access, may I refer to 4 above. The present layout was “Downgraded” to deal only with the traffic presently generated.
9. Housing need is questionable. I ask that it be noted, that property in the present Whinney fold has, over the past 8 years, often remained unoccupied over several months, for the lack of interested tenants. It should perhaps also be noted that there is at present no waiting list for these properties.
I ask that in view of all considerations this is not an appropriate site for housing development and that it be removed from the final land allocations.

No thank you.

None

AS23-S56 land at Whinney Fold, Silverdale
I reside in Silverdale very close to the land at Whinney Fold which is proposed as being suitable for development- I am therefore able to speak with the benefit of having a very good knowledge of the area in question.

• AONB –This AONB is the smallest in the country and therefore any proposal for housing development must be considered as having the potential for a major impact, whatever the size of the proposed development. In this instance I am firmly of the opinion that even 6 houses in this location should be viewed as being a major development because of the detriment it would cause to the appearance of this area and the potential it would create for further development into the valley.

• Landscape Impact-The field in question is regularly used to graze cows and sheep and forms a very attractive part of this small valley which displays so many features typical of and very special to this AONB. It is ludicrous to believe that any development of it would leave its character essentially intact and that any impact on it would be small. Nor would it be possible to adequately protect its appearance by tree screening. The view from the public footpath, (East of the site, please see photographs below) across the present rural tranquil scene would be ruined by any development and there would be inevitable noise and light pollution. The suggestion that a defensible boundary could be created in the SE edge to prevent further development into the valley must be treated with caution- a similar assurance was made in relation to the present Whinney Fold development when documents record it was stated that - “ the form of the access road has changed, its design has been downgraded to the standard required for a short residential cul –de- sac, so that there is no question of its being seen as a way of opening up the land to the South for further development. At the same time the position of the houses has been amended slightly so that it would be more difficult to extend this road; access to the field is maintained for agricultural purposes only “. If it is now proposed to flagrantly disregard this assurance, then how can any assurances now being given in relation to this new proposed development be relied upon.

• Design and layout-. At present there are 6 affordable houses in Whinney Fold which have 10 parking spaces with some on road parking. As most of the houses have 2 cars this has proved inadequate and parking disputes have occurred. Even a proposal for 6 houses would generate a lot more traffic which the layout of Whinney Fold was not designed to cope with.
• Flooding and Drainage-I am very concerned about the extra sewerage that any development would generate and as the land is low lying and at different levels then clearly electric pumps would have to be used to move the sewerage to a treatment plant. The shared systems at Stoneleigh Court and Whinney Fold have shown such shared systems are notorious for running problems, and clearly powers cuts, of which we have many in this area must inevitably increase the likelihood of effluent discharging into the bay. I would also highlight the problem of flooding in this field which had water to a depth of 4 foot in the South corner throughout December and January 2015/2016
• Road Access and transport – The Shore at Silverdale is one of the most visited parts of Silverdale-in fact it could best be described as a tourist hot spot in the AONB! This inevitably generates a lot of traffic and Shore Road, from the cattle grid to past its junction with Whinney Fold, is at weekends and Bank Holidays heavily congested and in fact often at saturation point. Surely it would be wrong to open up Whinney Fold to more traffic creating more congestion. There has previously been suggestions that Shore Road only suffers from traffic congestion at times in the holiday season when the beach car park is busy and parking by visitors to the beach occurs in Shore Road. As someone who lives at the bottom of Shore Road and sees it on a daily basis I can say most emphatically that this is not the case. I often note that there are cars parked all the way up Shore Road, and the beach car park was full. (Please see photographs below) When considering the parking facilities for visitors to the shore it is worth being mindful that the term ‘Beach Car Park’ is somewhat misleading-it is an uneven piece of shoreline that is privately owned and which floods on high tides - for these reasons most visitors choose not to park there. As this is an AONB to which we all wish to encourage visitors to come, (who spend money with local businesses) surely we shouldn’t make traffic congestion and parking a bigger problem than it already is. I also question the suitability of the site in relation to how the developers would be able to get their heavy plant machinery in and out - the road is too narrow to allow for heavy plant to access it. (Please see photographs below)

• Need-Before a green field site is destroyed for ever we have to be certain there is a need for such properties in this locality. There are presently over 20 properties for sale in Silverdale, at varying prices. I also know that when affordable housing in Whinney Fold has become vacant it has often stood empty for lengthy periods – one such house was empty for eighteen months and another for about six months.

Sheila Spencer

Photographs
Taken on Sunday 13/03/16

Photograph 1. View of site in question from Footpath. (13/03/16)
[SEE ATTACHED]

Photograph 2. View from Footpath (13/03/16)
[SEE ATTACHED]


Photograph 3. Shore Road parked Cars (13/03/16)
[SEE ATTACHED]

Photograph 4. Shore Road parked Cars (13/03/16)
[SEE ATTACHED]

Photograph 5. The Shore Car Park (13/03/16)
[SEE ATTACHED]

Photograph 6. Whinney Fold parked Cars (13/03/16)
[SEE ATTACHED]

None

None

The planned building land to the NORTH of the Main Road is unsuitable on account of the flooding last winter. Water drains off the Crag in heavy storms as you will know.

The land south of the Road through Warton which floods each winter would make a an excellent nature reserve in the form of wetland and the RSPB, I believe, is interested in doing so. In view of the land in the AONB being proposed for building i believe that great weight should be given to preserving nature for future generations.

Yours faithfully,

John Stelfox.

A14 - The proposed site belongs to me so not sure as to why this is even on here! The road is always very busy and I am concerned about access.

A15/16
This site has been designated as an important open space in the recent past and should continue as such.
The "unkempt appearance" of the western end as described by APC does in fact encourage wildlife, e.g. these are numerous anthills in this area.
This is the AONB after all.
Furthermore, plans have already been approved for the building of 10 flats in a green space very close by, with an affordable percentage as a condition of development. Developments should be spread out around the village and the draft plan is fair in this respect.

Overall the plan is fair and reasonable, with due weight being given to environmental issues as befits a beautiful AONB.

We support the plan in its present form and it should be taken forward without amendment.

[SEE ATTACHED DOCUMENT]

Draft Plan v 16 171116 - AS23 – S56 Land at Whinney Fold, Silverdale

FIRST POINT: I fundamentally disagree with developing a greenfield site for the sake of just 3 'affordable homes'. Since this plan has been in development there have been a number of new properties in Silverdale (including rentals) which have become available but which are standing vacant (and have been for a long time). Just because they aren't in this plan does not mean that there are not properties being developed which meet the need. In response to my comments on the original consultation, your response stated that consideration would be given to meeting any affordable housing requirement from within the wider Carnforth area if no suitable sites are available within the AONB. I contend that no sites are available and that it would be very feasible to accommodate the additional 3 affordable homes proposed in this draft of the plan within plans for Carnforth and the wider area. I have also seen no mention of the impact on the Lancashire Mineral Safeguarding Area in relation to this site (which according to your maps falls within this area); I refer to Para 3.2 Proximal Sterilisation of the Lancashire Waste and Minerals Local Plan Guidance Note on Policy M2.

SECOND POINT: Point I states that 'Mature hedges on SE and NW boundaries to be retained, and development must create a new, robust and defensible boundary to the SE edge.' Two points on this issue: 1) the mature hedges are actually located on the SW and NE boundaries so the wording of plan needs to be amended accordingly; 2) please provide a definition of 'defensible boundary' as this seems to be an important term which is not made explicit in this document. This term is less well known than say Affordable Housing, which is included in the glossary, so including this term in the glossary would be helpful.

THIRD POINT: Point II states that 'Development proposals will require drainage and surface water reports.' Due to the difficulties that are anticipated finding appropriate drainage without impinging on other sites which have been deemed 'not suitable for development', I would like to see the wording of this point read 'Development proposals will require drainage and surface water reports and any ground works on the site may not commence until discharge consents have been granted.' The risk of not including this point is that the developers may destroy the natural green field environment before realising that discharges on the quickly waterlogged shallow soil over solid limestone environment are actually not possible to meet the Environment Agency's standards.

FIRST POINT: It is unclear why it has been deemed necessary to protect a site by designating it 'key settlement landscape' just because the owner proposed it as such - this is what I understand by your reply to my comments on the original I&O consultation to which you responded: 'These sites have been put forward by their owners, the National Trust, who do not wish to see any development on them. Open space policies are designed to protect land within the built up areas from development. Unlikely to be required to protect open countryside.' Rather it must surely be more important to protect those sites which the owner would like to sell for development but which have been deemed during this planning process 'unsuitable for development'. Site 58 falls into this category. Please consider, therefore, including Site 58 as a protected site.

SECOND POINT: The point I make above is presumably the reason that S43 was changed from being a potential development site in the I&O consultation to its protection as 'key settlement landscape' in this consultation. This reinforces my point about Site 58 receiving a similar designation and

THIRD POINT: S46 is listed as not available for development. When S46 comes forward for planning permission, which it inevitably will do, I hope that this will include the requirement for a mix of affordable housing in line with the DPD. At this point, far more than the 3 affordable homes proposed for S56.

S56
I am very concerned about the site S56 in Silverdale being marked for housing and strongly object to this "nibbling away" of green field sites in the AONB. This site demonstrates part of the first special quality of the AONB: “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.” and as such should not be built upon.
The field is low lying with attendant drainage problems, contamination from nearby foul water drainage has already affected the shore 200 m away, part of Morecambe Bay special area of conservation (SAC) and special protection area (SPA).
The field is a habitat for birds utilising Morecambe Bay, particularly for wintering wildfowl and waders. Fieldfare and redwing are seen here in cold weather. The surrounding trees and hedges provide food andnesting habitats for many woodland birds, including hawfinches, while these are to be retained, the noise and activity accompanying a housing development inevitably drives away wildlife. Bats, toads, slow worms, fox, rabbits, voles and deer are present in this area; such a development is bound to have a detrimental impact on them and to our pleasure in observing them. Policy DM28 states that proposals that have a significant adverse effect on landscape character or that would harm landscape quality, biodiversity, geodiversity or heritage will not be permitted.
There are still brownfield sites in Silverdale that would be much more suitable and have less detrimental effect.

[SEE ATTACHED DOCUMENT]

[SEE ATTACHED DOCUMENT]

I am particularly concerned about sewage disposal in Silverdale and how many current planning approvals appear not to comply with Building Regulations or Environment Agency policies. I look forward to being reassured that these policies, which are intended to protect the environment, will be complied with for future devlopments.
Attached, I hope you will find my document which explains some of the detail.
D G Wood

[SEE ATTACHED DOCUMENT]

[SEE ATTACHED DOCUMENT]

[SEE ATTACHED DOCUMENT]

This is a critical comment on this plan by the omission of suggested public open space by Beetham Parish Council and myself at "The Dixes" and "Sandside Orchid Verge", both at Sandside without any justification in the consultation document.

[SEE ATTACHED DOCUMENT]

Arnside Parish Plan Trust is pleased to have been consulted about the Draft DPD Plan for Arnside & Silverdale AONB.

The Trust’s observations are summarised below;

1. General presentation of the DPD document and the proposed policies.

APPT considers that this is a very well-constructed document which is a considerable improvement on the last plan.

This latest version has a clear structure which;

• clarifies the statutory responsibilities of SLDC and LCiC together to manage, protect and enhance the special qualities of this AONB as embodied in the policies laid down in the NPPF and other relevant legislation,

• states clearly that “A key reason for preparing this DPD is to place development more clearly in the context of the primary purpose of the AONB – to conserve and enhance the natural beauty of the area - and to put this purpose at the heart of planning for the AONB”,

• goes on to propose that “A landscape capacity-led approach to development will be taken in the AONB”,

• and then proposes the strategies and development policies which should be applied to achieve those objectives.

2. Impact of these policies on proposed land allocations.

APPT is pleased to see that the document sets out a clear set of criteria for the selection of sites suitable for development or other purposes within the overall objective of “a capacity led approach”. It is very important that these criteria are adhered to despite pressure from commercial developers and other interested parties to compromise for some sites.

APPT notes that the proposed policies have the following principal effects;

• development land will be allocated within the assessed capacity of the AONB landscape to absorb it without undermining the AONB’s special qualities,

• housing needs will be set in that context and any excess of essential need over the AONB landscape capacity can be accommodated elsewhere,

• clear criteria are set out for assessing sites to meet those policies. While there may be differing views on the detail of some sites offered by interested parties, APPT considers that the current proposals are appropriate and should go forward for approval,

• as the document states, “in order to ensure that new development in the AONB meets local needs, proposals for new housing development will be supported where they deliver at least 50% affordable housing.”

It is extremely important that this policy is adhered to despite the dilemmas it poses regarding “viability”.

APPT understands the viability issues that this policy presents to commercial developers but considers that they are not a key concern when set against the core objectives of AONB or against the alternatives available.

The essential local need in this area is for social rented housing because even under the proposed 50% ratio, for many residents, private housing is still unaffordable even at a 20% discount from normal market housing prices.

Relying on commercial developers to fund social rented housing is only likely to succeed if they can produce large numbers of profitable market housing to cover the cost. But that would require large amounts of land in the AONB to be sacrificed to deal with what is, in effect, a case of market failure in the national housing market.

Because “the primary purpose of the AONB – is to conserve and enhance the natural beauty of the area” it is necessary to implement “the highest status of protection” as directed by the NPPF.”

A higher ratio of market housing would use up more land than necessary and would seriously compromise that purpose.

There is therefore no justification to compromise on this policy by increasing the ratio of market housing because market housing is not part of the essential need within the AONB.

APPT therefore recommends that this dilemma should be resolved by giving priority to those sites where partnerships with Housing Associations and other providers of social rented housing can be established.

If that is insufficient, the focus should be on providing the essential social rented housing need in sites outside of, but adjacent to, the AONB, rather than conceding to developers demands for more land for market housing within the AONB.

Such a policy would both protect the landscape and provide the essential local need.

3. Interim planning applications

As it will take some time for this DPD to become approved fully by SLDC and LCiC, APPT urges that in the interim until the process is complete, both authorities should adopt the planning approval principles for the AONB area embodied in this draft DPD.

It may also be helpful to include a section listing the planning permissions already granted within the AONB. There are a significant number of new dwellings (including affordable housing) already provided for, and they should be included to complete the overall picture of land use within the AONB.

4. Conclusion

Subject to the above, APPT is pleased to recommend that the current draft DPD document is put forward for approval.

No thank you

No

[SEE ATTACHED DOCUMENT]

[SEE ATTACHED DOCUMENT]

[SEE ATTACHED DOCUMENT]

[SEE ATTACHED DOCUMENT]

[SEE ATTACHED DOCUMENT]

[SEE ATTACHED DOCUMENT]

[SEE ATTACHED DOCUMENT]

[SEE ATTACHED DOCUMENT]

[SEE ATTACHED DOCUMENT]

[SEE ATTACHED DOCUMENT]

The location and layout Dwg IST/EW001 Rev E is hopefully self explanatory.

As discussed the site owner Mr E. Whittaker & his pension trust are wholly supportive of social housing.

They have confirmed their commitment to "Local housing restrictions" and "low cost units". In addition some 1 bed

over "55s accommodation" is suggested to allow downsizing and freeing up other local housing in the area.

As the site is screened by existing mature woodland, it is less visible within the AONB than the current sites suggested.

The site has utility services as per the attached letters/pro forma etc. Various letters show support for this alternative site, along with persons wishing to self build (as part of a "self build local trust for example) and/also take up local affordable accommodation.

We hope this can still be considered and explored as a viable alternative during the DPD time frame.

Regards
I.Thompson

[SEE ATTACHED DOCUMENT]

Thank you for your consultation on the Arnside and Silverdale AONB DPD. The Lancaster Canal does not pass through the area covered by the DPD and as such the Canal and River Trust has no comment to make on the DPD.

Kind regards

Tim Bettany-Simmons

Policy AS08 – Historic Environment

The proactive tone of policy AS08, which not only seeks to protect but also seeks to enhance the AONB’s historic environment, is fully supported. However, the following amendments to the proposed wording of policy AS08 are suggested:

AS08 currently states: ‘Before works to historic buildings or assets take place, surveys should be undertaken to record their historical interest and build the heritage evidence of the AONB.’
The principle of this statement is supported, but it implies that in all instances where work takes place to assets a survey should be undertaken. This is too onerous, as minor work to assets often does not adversely impact on them and so require such a survey to be implemented. Instead, it is recommended that the principle outlined in section 12 of the NPPF is used, whereby harm to the significance of an asset is the trigger for an appropriate level of mitigation measures to be implemented. Furthermore, it is advised that the reference to ‘historic buildings or assets’ in this sentence is altered to heritage assets, so that it is in line with the term used in NPPF.

It is suggested that the sentence is re-worded along the following lines:
‘Before any work that harms the significance of heritage assets takes place, records should be undertaken to a level that is proportionate to the significance of the asset and the scale of the impact.’

AS08 also currently states: ‘Proposals within the setting of historic assets must be accompanied by an archaeological survey and any finds must be recorded and interpreted.’
This statement implies that in all instances where proposals are located within the setting of an asset an archaeological survey should be undertaken. Again, this is considered too onerous and is unnecessary for many proposals. Heritage assets take many forms within the AONB and it does not follow that the setting of an asset will contain archaeological remains and so require an archaeological survey. It is true that some assets lie in archaeological landscapes and proposals in these sites may require archaeological work. Many sites however, are discrete features and always have been. Undertaking archaeological surveys for these assets is needless because the potential to disturb archaeological remains is negligible.

It is suggested that this sentence is removed.



Proposed Site Allocations

AS18 – A6 Land off Queen’s Drive, Arnside
This proposal does not raise any archaeological issues.

AS19 – A8/A9 Land on Hollins Lane, Arnside
This proposal does not raise any archaeological issues.

AS20 – A11 Land at Briery Bank, Arnside
This proposal does not raise any archaeological issues.

AS21 – B108 Land at Church Street, Beetham
There is some potential for this site to contain currently unknown archaeological assets given the size of the proposed development and the close proximity to the medieval village centre and medieval church. The proposal in the mini-brief to undertake a programme of archaeological investigation of the site in advance of development to record any assets disturbed by the development, is therefore supported.

AS22 – B112 Land at Stanley Street, Beetham
This proposal does not raise any archaeological issues.

AS26 – A25/A26/A27 Station House and Yard, Arnside
The site contains one former late 19th century railway building, which is a local heritage asset. The proposal in the mini-brief to retain the existing buildings is therefore supported.

AS27 – B35/B38/B81/B125 Sandside Road & Quarry Lane, Sandside
These sites contain an impressive set of limekilns and a recently restored 18th century former warehouse, which are local heritage assets. The proposal in the mini-brief to retain these buildings is supported, although they lie in site B38 and not B35 as specified in the mini-brief.

[SEE ATTACHED DOCUMENT]

[SEE ATTACHED DOCUMENT]

[SEE ATTACHED DOCUMENT]

[SEE ATTACHED DOCUMENT]

[SEE ATTACHED DOCUMENT]

[SEE ATTACHED DOCUMENT]

[SEE ATTACHED DOCUMENT]

[SEE ATTACHED DOCUMENT]

[SEE ATTACHED DOCUMENT]

[SEE ATTACHED DOCUMENT]

[SEE ATTACHED DOCUMENT]

[SEE ATTACHED DOCUMENT]

Proposed Policy AS05 - Natural Environment - SUPPORT

Proposed Development Allocations - Housing and Mixed Use - Site Mini-Briefs. With reference to the sites identified within Lancashire (AS23-S56; AS28-S70; AS24-W88 and AS25-W130), we welcome the policy guidance that will apply to each proposed site and especially the requirement for ecological survey and mitigation measures.

[SEE ATTACHED DOCUMENT]

[SEE ATTACHED DOCUMENT]

[SEE ATTACHED DOCUMENT]

[SEE ATTACHED DOCUMENT]

[SEE ATTACHED DOCUMENT]

[SEE ATTACHED DOCUMENT]

I have just had a look at the proposals and note that a number of sites have been removed from the new version. One of these, at Hall More Caravan Site at Hale was originally submitted as a tourism opportunity lodge site on land around the trout fishing lake. However, despite no objections to this site, it does not appear to have survived. The site is particularly suited to such a development, the lodges being situated around a the lake. The intention is to re-market the lake as a trout fishing opportunity following its decline in popularity and the lodges would have become part of the overall project. Indeed, discussions in the past with a planning officer from SLDC did indicate that permission would be likely subject to appropriate landscaping. The development would be part of the overall Hall More Caravan Park which has been in existence for 50+ years and in the same family ownership.

I should be grateful if the inclusion of this site could be re-considered.

Thanks and Regards

Peter Lord

[SEE ATTACHED DOCUMENT] Comments are made on behalf of Mr John Morphet of Hall More Caravan Site.

AS01 In this and related policies 'development' should include extensions to existing developments which together would amount to a significant development.
4.4.4 add wells and springs.
4.5.17 add 'ancient North-South routes'.
4.5.29 ...burgage plot formation and evidence of a ring-garth; compacted building.....
...to the rear. A Back Lane runs through the village to, and beyond Boon Town......
...St Oswalds Church and wells such as Senset Well.
4.5.32 ....of a limestone ridge along a new road to the east of an identifiable ancient way higher on the limestone.
AS12 (1) add 'facilities and parking'.

As you are aware the land off St John's Avenue (formally plot 50) is part of the Sarah Burrow Trust. Please find attached a letter authorised by the Trustees Walter and Frank Burrow, as confirmation that the beneficiaries and trustees are making the land available for allocation and confirm it is suitable for consideration in the Development Plan document for the AONB. The access to the field is the land retained by the Trust off St.Johns Avenue.

Regards
Jane Grime

On behalf of the Silverdale Green Discussion I am attaching a consultation response to the Arnside Silverdale AONB draft Development Plan Document DPD.

The Silverdale Green Discussion Group is a group of about 30 people, consisting of both Green Party members and supporters who meet once a month to discuss green issues. At their last meeting in November they discussed the Draft Development Plan and the attached response is based on this discussion and has been circulated amongst members to obtain a reasonable consensus of view.

[SEE ATTACHED DOCUMENT]

[SEE ATTACHED DOCUMENT]

These comments are submitted by Smith & Love Planning Consultants Ltd on behalf of Applethwaite Ltd and follow comments made previously in response to the AONB DPD Issues and Options Consultation in December 2015.

1. AONB DPD Vision

Applethwaite Ltd previously commented that the DPD Vision should make clear that new development will be “planned and delivered” and not simply “managed” in order to meet objectively assessed market and affordable housing needs in the AONB. The revised Vision partially incorporates this change but adds the unnecessary additional wording; “contribute towards meeting the needs of the communities of the AONB….” This introduces uncertainty and conflicts with the NPPF requirement to ensure that the DPD is positively prepared. The wording of the DPD Vision should therefore be revised simply to; “meet the needs of the communities of the AONB…..”

2. AONB DPD Objectives

Applethwaite Ltd previously commented that the term ‘local needs’ could be misconstrued to relate to solely affordable housing, whereas the objective of the DPD is to ensure that all market, affordable and specialist housing needs within the AONB are met. Applethwaite suggests that draft Objective (IV) is therefore amended as follows and made consistent with its suggested change to the DPD Vision; “To provide a sufficient supply and mix of high quality housing to meet the market and affordable housing needs of the AONB’s communities, without adverse impact on the landscape character and Special Qualities of the AONB.”

3. Draft Policy AS01

The draft policy text; “Development in the AONB will be permitted where it furthers the primary purpose of AONB designation”, could be too restrictive such that the DPD is not positively-planned and cannot be delivered. A preferable form of words is; “Development in the AONB will be permitted where it does not conflict with the primary purpose of AONB designation.”

Applethwaite Ltd agrees with the proposed list of settlements to be defined as AONB Local Service Centres.

Applethwaite Ltd recommends that greater precision and clarity is needed to add certainty to the wording of Policy AS01 to define the meaning of development proposed “within”, “on the edge of” and “outside” settlements, given that the DPD does not propose to delineate settlement boundaries.

Applethwaite Ltd agrees that the question of whether a proposed development constitutes major development will be a matter for the relevant decision taker, but disagrees that a determination should be based on the assessment of whether development has the potential to have a significant adverse impact on the natural beauty of the AONB. The justification for using the wording “has the potential to” is not explained and justified, and Applethwaite considers the alternative word “will” should be used, such that the proposed policy reads; “…….whether development will have a significant adverse impact on the natural beauty of the AONB.”

4. Draft Policy AS02

Applethwaite Ltd suggests that the wording of Criteria (IV) of the draft policy is revised so that new development proposals will be supported where they; “retain and/or restore the scale and pattern of the landscape, with its characteristic highly diverse mosaic of contrasting landscape types.”

5. Draft Policy AS04

Applethwaite Ltd has significant concerns over the wording and requirements of this policy. It is not correct to assert that because the AONB is a protected landscape, allocated housing sites and windfall sites that are suitable for housing, should be developed specifically to help meet local affordable or other locally identified housing needs. The logic that “to do otherwise would fail to address these needs, which could then only be met by releasing more sensitive sites, causing harm and compromising the primary purpose of the AONB designation”, applies equally if the DPD does not ensure that market housing needs arising with the AONB are met. The DPD must ensure that all objectively assessed housing needs (market, affordable and specialist) are met wherever possible, and it should not prioritise local affordable housing delivery in preference to local market needs as both are equally needed and justified within the AONB.

There is also an added viability complication in pursuing a blanket policy of at least 50% affordable housing provision on all housing sites within the AONB, such that the policy is likely to fail and inhibit the delivery of both affordable and market housing. By their nature, housing sites within the AONB will generally be smaller, more constrained and more expensive to develop than sites outside, as a result of higher land acquisition prices and abnormal development and infrastructure costs. Provision of at least 50% affordable housing on all housing sites will not be viable on small sites and can only be achieved if the level of market housing is sufficiently increased to facilitate delivery. As that is unlikely to be possible on many sites within the AONB, flexibility and discretion is required to determine if and when an allocated or proposed housing site can deliver 50% affordable housing.

Paragraph 173 of the NPPF emphasises that ensuring viability is paramount to sustainable plan-making so that DPDs are deliverable. It is clear that; “sites and the scale of development identified in a DPD should not be subject to such a scale of obligations and policy burdens that their ability to be developed viably is threatened. To ensure viability, the costs of any requirements likely to be applied to development, such as requirements for affordable housing, standards, infrastructure contributions or other requirements should, when taking account of the normal cost of development and mitigation, provide competitive returns to a willing land owner and willing developer to enable the development to be deliverable.”

6. Draft Section 4.5 Design

The interpretation of draft Paragraph 4.5.23 is unnecessarily restrictive as presently worded and its relationship with proposed Policy AS07 Key Settlement Landscapes is unclear. Key Settlement Landscapes are proposed to be designated to protect land from development that makes an important contribution to the character of the AONB and its settlements. To ensure greater consistency with draft Policy AS07 it is suggested that draft paragraph 4.5.23 is revised to read; “Much of the (Silverdale) village is fringed by small to medium sized pastures, which are enclosed by a characteristic pattern of limestone walls. Pockets of development are interspersed with woodlands and pastureland that form attractive open spaces and pastures follow a pattern of ancient enclosures in some areas. Some of these open areas form an important part of Silverdale’s character.”

7. Draft Policy AS16

Applethwaite Ltd does not support the proposed allocation of only 0.30ha of Site Ref. S56 at Whinney Fold, Silverdale for the development of approximately 6 no. dwellings. The whole of Site S56 is suitable, achievable and available for development and can yield a higher number of much-needed new homes, and should therefore be allocated for development as it is the only proposed housing allocation included in the draft AONB DPD at Silverdale. The detailed reasons for this are set out in the response to draft site brief Policy AS23 below.

8. Draft Policy AS23

Applethwaite Ltd has an interest in Site Ref. S56 comprising 0.76ha of land to the south of Whinney Fold at Silverdale.

Silverdale is proposed to be defined as a Local Service Centre in the draft DPD and is already defined as a Sustainable Rural Settlement in the Lancaster settlement hierarchy and an identified location for rural housing growth in the Development Management DPD (Policy DM42) of December 2014. It is the principal settlement within the part of the AONB within the Lancaster City Council area.

As a sustainable village and a suitable location for growth, Silverdale is the only settlement in the AONB (together with Arnside in South Lakeland), that provides the full range of essential local community services and facilities including convenience shopping to meet daily needs, St Johns C of E Primary School, bus and rail public transport, health services, public houses / food and drink provision, a village hall / institute, places of worship, a library and sport and recreation facilities. It is a popular village and an attractive residential area for both working families and retired and older people, and there is a very good prospect of new housing development being delivered in the short term as there is strong market interest and take-up.

The AONB DPD evidence base demonstrates that Site S56 is suitable for moderate housing development. It comprises developable land immediately adjoining residential development in the southern part of Silverdale, and within 450m walking and cycling distance of the village centre, that does not contain any important features and aside from the limited loss of agricultural grazing, has no technical, environmental, heritage, infrastructure, access and ownership constraints.

The site scores highly in the Basic Information, Exclusion Criteria, Suitability / Sustainability Criteria and Deliverability Criteria in the DPD Appendix 2: Site Assessment Spreadsheet. For completeness, the missing deliverability criteria are as follows and confirming that the site can be provided with a full range of utility services;

Close proximity - Water services? A mains water supply is available
Close proximity - Sewerage services? The site can be provided with full biological wastewater package treatment facilities and a drainage field meeting the requirements of Part H2 of the Building Regulations 2015.
Close proximity - Electrical services? A mains electricity supply is available
Close proximity - Gas services? A mains gas supply is available
Close proximity - Telecom services? Telephone and fast broadband is available

In respect of the Biodiversity Test, Applethwaite notes the Site Assessment Spreadsheet score the site as ‘orange’ due to the Statutory Management Requirements (SMRs) relating to its use as farmland. The SMR is an agricultural management standard and not an indication of the ecological importance or interest of the site and its suitability for, or constraint from, development. This is confirmed by the AONB Development Plan Site Allocations - Cumbria Wildlife Trust Assessments report, which demonstrates that there are no insurmountable constraints preventing the development of the whole of Site 56. This conclusion was also reached by ecologists appointed by Applethwaite in 2015 to appraise the ecological importance of the site and the limited effect new housing development is likely to have on local biodiversity, qualifying species and/or habitats of European designated sites and European protected species. Overall, there is no ecological constraint to development and the DPD site assessment should record the site as ‘green’.

In respect of the Landscape Test, Applethwaite Ltd disagrees with the conclusions for Site S56 drawn by Hyder Consulting in the Landscape and Visual Field Survey Sheet (AONB SHLAA Sites) Report. This confirms the site occupies a secluded position in the AONB and benefits from limited views in and out. It considers the loss of landscape character would be harmful in combination with the redevelopment of Site 46 (Kayes Garden Centre), however there is no indication that site is deliverable due to access and ownership constraints, and it has consequently not been taken forward in the DPD. In addition, the Hyder Report does not fully consider mitigation or more importantly, the scope for landscape character compensation, which Site S56 can deliver.

The Appendix 2 : Site Assessment Spreadsheet is also silent in respect of the Viability Test. For the reasons explained in the response to draft Policy AS04, the expectation that the allocation of only 0.3ha of the site for the development of 6 no. dwellings, of which at least 3 no. are expected to be affordable units, is unrealistic and is not deliverable. As the only proposed housing site included in the DPD for Silverdale, it is critical that S56 is financially viable and deliverable, and that in the absence of suitable, achievable and available alternative sites, the DPD enables the full development potential of the site to be realised.

Applethwaite Ltd maintains its comment that the whole of Site S56 is therefore a suitable, sustainable and appropriate location for new housing development. The site is available and development is achievable and can be made financially viable, enabling housing to be delivered in the short term so it makes a valuable contribution to the 5 year housing land supply within the AONB DPD. Applethwaite recommends that draft Policies AS16 and AS23 are therefore amended in the next version of the AONB DPD to allocate the whole of Site S56 for an increased number of dwellings.

No

No

The specific inclusion of provision for urban wildlife such as swifts in new development and conversions is a welcome addition to the DPD (AS05 and 4.2.21). However I would like to suggest that an improvement to this would be to mention specifically the unique nature of the area's buildings and their support for wildlife which comes under the category of urban biodiversity. Indeed a specific mention of maintaining and enhancing urban biodiversity, not just bio diversity which is generally referring to the natural rather than man made world, would help to contextualize the reason for the specific mention for swifts etc.

Further to the comments on the DPD re. unique buildings and urban biodiversity, the lack of this being documented is also reflected in the SAR specifically in the table on page 22 of the report. which lists the various aspects of biodiversity.

[SEE ATTACHED DOCUMENT]

Thank you for consulting The Coal Authority on the above.

Having reviewed your document, I confirm that we have no specific comments to
make on it.

Yours sincerely

Rachael A. Bust

Policy AS27: We support the proposed allocation of site B81 for residential development. The site is considered to be acceptable for residential development as it is deliverable in accordance with footnote 11 of the NPPF. This is because the site is available now, offers a suitable location for development (as it is a brownfield site in an accessible location) and is deliverable within 5 years. The residential development of the site would also comply with the 3 dimensions of sustainable development as outlined within paragraph 7 of the NPPF. Development of the site would have a social role as it would provide the supply of housing required to meet the needs of people of present and future generations and would also offer a high quality built development. Development of the site would also have a positive economic impact as it would support growth and potentially provide affordable housing, contributing to building a strong local economy. With regard to the environmental role, as the development would occur on brownfield land, this would protect the AONB and natural environment as development would not take place on more sensitive greenfield sites. As such, the negative impact on the AONB would be insignificant in accordance with Core Strategy policy CS5. Policy AS04: This policy states that proposals for new housing development "will be supported where they deliver at least 50% affordable housing". The justification for this requirement is stated as being "because the AONB is a sensitive landscape protected at national level". It is vital that the affordable housing requirement is however based on an adequate evidence base, as is required by paragraph 158 of the NPPF. This states that the "LPA should ensure that the Local Plan is based on adequate, up to date and relevant evidence about the economic and social characteristics and prospects of the area... and that they take full account of relevant market and economic signals". Paragraph 159 of the NPPF states that a SHMA should be undertaken to assess the housing needs within the area. It is understood that this has not been undertaken for the AONB. Furthermore, paragraph 182 of the NPPF states that the plan is to be based on proportionate evidence. It is therefore considered that the evidence provided is insufficient to support the 50% affordable housing requirement. With regard to the 50% affordable housing requirement, policy AS04 states that "only where this is demonstrably unachievable through available mechanisms will a lower percentage be acceptable". This wording is unclear as to what exactly these 'available mechanisms' are. It is considered necessary for these to be specified to ensure that the policy accords with paragraph 154 of the NPPF which states that "only policies that provide a clear indication of how a decision maker should react to a development proposal should be included in the plan".

[SEE ATTACHED DOCUMENT]

Members of Warton Parish Council wish to object to two areas of the plan as follows;

W88 The proposal to allow consideration of a housing development along the north side of Sand Lane.

The development would encourage gradual infill behind these houses and destruction of the slopes of Warton Crag. The unspoilt view of the Crag from the south, east and west would be damaged beyond repair and the development would not be viable in size to provide affordable housing needed in the village. The additional houses would increase the numbers of vehicles turning into and out off Sand Lane with a corresponding increase in collision risk. Additional housing would increase surface water flooding from the Crag.

Open Space W215

The submission made by the Parish Council to the initial consultation for the plan requested all of the land to the east of the village to Millhead village was designated as open space but only that area designated W215 was agreed. Members would request that further consideration be given to extending that area at least to include the field east of W215 which would improve the rural feel of the school.

J W Ball
Clerk to Warton Parish Council

Members of Warton Parish Council have asked that I object on their behalf to the inclusion of the development site W130 - Land North of 17 Main Street Warton in the Plan because they feel that the site is unsuitable on the grounds of;

i) access to the site can only be made after the demolition of an important house of sufficient architectural and local industrial heritage value to warrant saving.

ii) increased danger of flooding and surface water risks to land owned by the parish council and other properties

iii) the site would border a sensitive boundary with Warton Crag and AONB

iv) in view of the likely cost of the site development the type of housing necessary would not be of the type (low cost housing) required in the village and therefore against the AONB housing needs survey

v) the development would create a detrimental additional strip of housing on sensitive green belt land that if associated with that planned under application 16/00221/OUT would stretch for the majority of Warton Crag border with the village.

J W Ball
Clerk to Warton Parish Council