Local Development Framework Consultation

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.