Local Development Framework Consultation

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.

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