Local Development Framework Consultation

I have read the guidance notes

General comment / comment on procedure

Yes

Introduction. There is much to support in this plan, which is breaking new ground as the first AONB DPD in England. It builds very positively on the 2014 Management Plan for the AONB and it places the AONB landscapes at the heart of shaping development over the next 15 years. The response of planning officers to the varying stages of the consultation process, from both local planning authorities jointly preparing the plan, has been a positive one and a number of my concerns, amongst others, have been taken on board in reaching the publication plan. The plan may well provide a future template for other AONBs and designated areas, and it also has much to commend it in providing an approach that could also benefit non-designated areas. It has been positively prepared and can be justified as an effective approach that includes joint working across district boundaries, and covers infrastructure necessary to implement policies. It is also consistent with national policies, however much there may be some significant concerns and disagreements with such national policies and a wish to see them improved! As with all plans and DPDs, much will depend on the practical effectiveness of quality implementation and enforcement on the ground, which in turn will depend on the availability of professionally experienced staff and associated resources within the two local authorities concerned.

The following comments are made with a view to further late improvements and additions to the DPD, before submission to the Planning Inspectorate.

- The primary purpose of the AONB designation is strongly supported in para. 3.1.2.
- Although the weakness of not having specific AONB housing need figures is acknowledged (para. 3.1.4), the fact that a housing needs survey for the AONB has identified a 5-year figure of 72 affordable houses, should be strong enough to provide an effective guide to requirements (para. 3.1.5) It may be that if cross-subsidy market housing is necessary to provide such affordable housing, these should be met largely outside the AONB(para.3.1.6) If these 72 affordable houses represent 50% of the housing provision requirements set out in Policy AS03, are we to infer that the DPD could be looking towards 144 houses in total?
- The paragraph on locational strategy is supported (para. 3.1.8)
- The paragraph and definition over major development is supported (para. 3.1.10)
- Given the intended effectiveness of this DPD amongst the development industry and local people, there should be no need to see developers putting forward proposals for larger developments within the AONB? (para. 3.1.11) A strong DPD should send out the message clearly enough and encourage effective policy implementation and enforcement.
- The approach to brownfield land within the AONB is supported (para. 3.1.12).
- Policy AS02 on landscape, is strongly supported, stressing the high levels of sensitivity and limited scope for change (para. 3.1.20)
- The importance of local distinctiveness is also strongly supported (para. 3.1.25), as is the importance of setting, which can be outside the AONB, sometimes considered a location for development unsuitable for the AONB itself (para. 3.1.27)
- Policy AS04, covering the natural environment, is strongly supported as being at the heart of the DPD, and linked to its primary purpose and special qualities.
- There is strong support for policy AS07 covering heritage assets and para. 4.4.4 is particularly important in recognising the influence of a whole integrated raft of smaller but no less important features. The level of detail here is to be applauded.
- Policy AS08 on design, is strongly supported, including the importance of open spaces, notably within the settlement pattern of Silverdale (para. 4.5.4/20-25). The settlement character summaries are helpful in getting across the important elements that must be incorporated within any future development proposals.
- Policy AS11 on caravans, camping and accommodation is supported, with some emphasis on the urbanising effect that they can have(para.4.8.4). Low impact tourism and diversifying away from caravans and into low impact new markets are to be encouraged (para. 4.8.8). The problems of the loophole allowing twice the original footprint without planning permission, is clearly a national issue with caravans and needs to be urgently addressed. Local authorities, especially those covering designated areas, should lobby both Government and local MPs to point out the errors of such a loophole (para. 4.8.9).
- Policy AS12 on water, sewerage and sustainable drainage is supported, alongside para.4.9.2, which specifically draws attention to the problems and constraints of Silverdale in this respect.
- The importance of energy and communications is recognised from policy AS13, and this policy is supported for small-scale renewable, low carbon energy schemes and local broadband improvements. Such schemes must take full account of just how vulnerable the AONB landscape is to them(para.4.10.2) and act accordingly to ‘get it right’. National policy is wrong over fracking and once again strong lobbying of Government and local MPs is necessary to try and change policy to exclude fracking from designated areas such as AONBs (para. 4.10.7).
- Policy AS14 on advertising/ signage standards is supported in order to protect AONBs from potential advertising and signage excesses.
- As far as specific development site proposals are concerned, there is a major issue that is affecting all potential housing development sites across Lancaster, South Lakeland and the North-West Region in general – and that is flooding and flood risk assessment. Piecemeal assessments are perhaps not the best way of dealing with this issue and a sub-regional or regional approach may well be more productive. Of the sites listed in this DPD, most of them have flooding risks associated with them, either directly on the sites themselves, or indirectly through run-off from hard surfaces leading to flooding elsewhere in the catchment. The site at Arnside station is very close to the Kent estuary, as is the Sandside site. The Beetham site is close to the River Bela and significant flooding took place at the end of November 2017. Additional run-off from more housing there can only add to the risk. The situation in Warton could be on a much grander scale, in view of the large area of flooded ground on the east/south of the village. A significant conservation/ wetland scheme is under discussion to take place here and it may be that this can assist with potential flood problems from proposed new housing. There may well be a significant case to be made to put all new housing proposals on hold until comprehensive drainage/flood assessment work has been undertaken across the two districts and the sub- region/region. Only then will people feel they have sufficient confidence to feel comfortable with new housing proposals.

Please notify me

I have read the guidance notes

2.1.1

Yes

The following comments are made with a view to further late improvements and additions to the DPD, before submission to the Planning Inspectorate.

The importance of building on the strong links with the 2014 Management Plan would be further enhanced if the word ‘managed’ could be added to the vision in the opening sentence of para. 2.1.1. It would then read ‘…whose distinctive character is conserved, managed and enhanced for future generations’.

Please notify me

I have read the guidance notes

3.1.6

Yes

The following comments are made with a view to further late improvements and additions to the DPD, before submission to the Planning Inspectorate.

Greater clarity is needed to distinguish, within local housing needs which will clearly drive housing policy within the AONB, between affordable local housing needs and market local housing needs(paras.3.16/7).

Please notify me

I have read the guidance notes

AS01 - Development Strategy

Yes

The following comments are made with a view to further late improvements and additions to the DPD, before submission to the Planning Inspectorate.

Although Policy AS01 is broadly supported, the interpretation of the exceptions remains open to debate and should be made clearer. For example, in the case of development on the edge of and outside settlements, might it be allowed if it could be demonstrated that it would help to sustain an existing business, including farm diversification schemes(vi), although there could be an adverse impact on settlement or landscape character(iv), or that it did not represent a sensitive and appropriate reuse, redevelopment or extension of an existing building(viii)?

Please notify me

I have read the guidance notes

AS09 - Economic Development & Community Facilities

Yes

The following comments are made with a view to further late improvements and additions to the DPD, before submission to the Planning Inspectorate.

Policy AS09 is supported and in particular, the strong support for retention of existing community facilities. However, since these are not solely within the gift of local authorities, how do you intend to implement and enforce the retention of such community facilities and services when pushed by market forces? Can strong use be made of protection of the ‘last’ facility or service argument?

Please notify me

I have read the guidance notes

4.7.3

Yes

The following comments are made with a view to further late improvements and additions to the DPD, before submission to the Planning Inspectorate.

The importance of Policy AS10 is recognised. The specific infrastructure needs as set out in para. 4.7.3 are supported, but you might consider adding railway station improvements (including car parking) at Silverdale (crossing the line is still by an open boarded crossing, since there is no access from the RSPB car park side), and bus services enhancements. There should be a clear link made here to the Management Plan, since there could be overlaps with landscape features such as drystone walls and roadside vegetation management.

Please notify me

I have read the guidance notes

7.1.5

Yes

The following comments are made with a view to further late improvements and additions to the DPD, before submission to the Planning Inspectorate.

In terms of monitoring and implementation, there is considerable concern expressed over para.7.1.5 and the message that this will send to developers with an interest in the AONB. For planning professionals to spend so much time and resources on this ground breaking DPD, with a set of excellent policies for an AONB, and then put it at risk by hopping on to the back foot and spreading the word that …’some adjustment may be justified in order to reduce costs and enable a scheme to go forward….’ is unfortunate. This is a ‘loophole’ that potential developers will not be slow to take full advantage of. Perhaps paragraph 7.1.5 could be safely removed from the submitted version, although the genie may already be out of the bottle? An independent assessment of viability may well be an acceptable Plan B?

Please notify me

I have read the guidance notes

General comment / comment on procedure

Yes

Yes

I attended the Parish Council meeting relating to the plan and consulted documents which were made available. The public were given adequate opportunities to comment on the proposed plan. I support the legal compliance & soundness of the DPD, and it's compliance with the duty to cooperate.

Please notify me

I have read the guidance notes

I have read the guidance notes

General comment / comment on procedure

Yes

Yes

I support the proposed DPD for the Arnside & Silverdale AONB and recommend its acceptance as drafted. In particular, my support is based on the following points;
* I compliment the officers of both South Lakeland District & Lancaster City Councils and the staff of the Arnside & Silverdale AONB team on a thorough document which clearly states the national policies and land use criteria applicable to the AONB with protection of the landscape as the overriding objective,
* it selects development sites which are consistent with those policies and protects the general open character of the settlements within the AONB Landscape as well as meeting other key criteria,
*it recognises that development should only be permitted to fulfil essential local needs,
* it further states that the main essential local need is that for affordable housing,
* it sets a ratio of affordable versus market housing development which is consistent with all the relevant criteria for the AONB.

While I understand that achieving this ratio will be challenging for commercial developers and may make some sites inappropriate for commercial development, I also maintain that commercial development within the AONB is not appropriate unless it produces a very high yield of affordable housing. To do otherwise would sacrifice highly valued landscape for no benefit to meeting essential local needs.

I also understand that there are good prospects that bodies such as housing associations will step in to finance affordable housing needs.

For these reasons I strongly recommend that the DPD should be considered “sound”.

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

Please notify me

I have read the guidance notes

I have read the guidance notes

I support the proposed DPD for the Arnside & Silverdale AONB and recommend its acceptance as drafted. In particular, my support is based on the following points;
* I compliment the officers of both South Lakeland District & Lancaster City Councils and the staff of the Arnside & Silverdale AONB team on a thorough document which clearly states the national policies and land use criteria applicable to the AONB with protection of the landscape as the overriding objective,
* it selects development sites which are consistent with those policies and protects the general open character of the settlements within the AONB Landscape as well as meeting other key criteria,
*it recognises that development should only be permitted to fulfil essential local needs,
* it further states that the main essential local need is that for affordable housing,
* it sets a ratio of affordable versus market housing development which is consistent with all the relevant criteria for the AONB.

While I understand that achieving this ratio will be challenging for commercial developers and may make some sites inappropriate for commercial development, I also maintain that commercial development within the AONB is not appropriate unless it produces a very high yield of affordable housing. To do otherwise would sacrifice highly valued landscape for no benefit to meeting essential local needs.

I also understand that there are good prospects that bodies such as housing associations will step in to finance affordable housing needs.

For these reasons I strongly recommend that the DPD should be considered “sound”.

General comment / comment on procedure

Yes

Yes

Yes, I wish to participate at the oral examination

To support the DPD as proposed and to help deal with any objections to it

Please notify me

I have read the guidance notes

AS18(part of A9) - Land on Hollins Lane, Arnside

Yes

No

The DPD is not effective

Sound infrastructure delivery planning is not achieved.
The section of the lane subject to this plan is only wide enough for one vehicle. Two vehicles can only pass if they do this very slowly and carefully and are able to use driveways at any point in the lane.If the proposed 6 homes were built then there could be about 12 owners' cars plus service traffic accessing Hollins Lane and we think this could significantly increase the danger to pedestrians. Apart from local use, Hollins Lane is used as a shortcut (sat. nav. prompted) to and from the Silverdale Road and often pedestrians have to dodge into a drive to get out of the way of a car going at speed. Pedestrian use is not only by local adults and children, but by walkers heading for Arnside Knott from the railway station. The plan does not address this existing infrastructure problem and will make it worse.

Our suggestion is that Hollins Lane should be closed to motorised traffic near the point where the lane meets Plantation Avenue. This closure need only be for a few metres, enough to ensure that the lane could no longer be used as a viable shortcut to Silverdale Road. A narrower entrance to the development could be provided, allowing a considerably longer stretch of wall and hedge to be preserved. Vehicular access to AS18 would only be possible from the Silverdale Road, allowing the residents of Hollins Lane from this road, down to the house called “Sandpiper”, to have safer access to their homes. The rest of Hollins Lane would also become safer for pedestrians and cyclists because only drivers with a need to be on the lane would use it.

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

Please notify me

I have read the guidance notes

AS18(part of A9) - Land on Hollins Lane, Arnside

Yes

No

The DPD is not effective

The DPD should be deliverable over its period and based on effective joint working on crossboundary
strategic priorities.

With respect to AS18 the DPD does not comply with the following the Management Plan priority 1.2.4(ll).
A lane, in one of the generally accepted meanings of the word, is narrow and often bounded by hedges, walls or fences. Such lanes, in urban areas, are rare and need to be protected from too much change. Hollins Lane currently meets this definition in the section bounded by the wall and hedge of this A18 proposal, and if adopted, over half of this would disappear and the lane would be considerably widened. The character of the lane would disappear and there would be a loss of wildlife habitat. Also the current field holds sheep and gives a rural feel to the environment.
If the proposal were adopted, then, apart from a narrow glimpse of the field in between the houses, the field would , for all intents and purposes,disappear from view. All over the country, in towns and villages, every little plot of green land is being built on, with little thought to the change in character of the habitation. Arnside has a certain uniqueness and should be careful it does not lose this. N.B. AS18 incorrectly states: " Access, retaining the remainder of the site as public open space and opening up long views are key issues". The field is not POS (not listed in appendix 2) and it would not be possible to replace the view from the Hollins Lane gate.

Remove AS18 from the plan.

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

Please notify me

I have read the guidance notes

AS18(part of A9) - Land on Hollins Lane, Arnside

No

The DPD is not effective

Sound infrastructure delivery planning

Hollins lane appears to have only two drain holes in its entire length, both near to the junction with Plantation Avenue. During heavy rainfall, water runs from Silverdale Rd., down the upper part of Hollins lane and if it misses the two drain holes, it continues to flow down Hollins on the east side of the road, possibly impacting all the houses on that side. There is a public combined sewer running down part of the lane, and we understand that there have been cases of sewage overflowing during heavy rain. Clearly the current infrastructure needs examination and possibly updating. This is not covered by the plan.

Current infrastructure needs to be updated with respect to drainage and sewers.

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

Please notify me

I have read the guidance notes

Policy Omission

Climate Change

No

The DPD is not effective

The DPD is not consistent with national policy

The National Planning Policy Framework includes the requirements for local authorities to adopt proactive strategies to mitigate and adapt to climate change in line with the provisions and objectives of the Climate Change Act 2008, and co-operate to deliver strategic priorities which include climate change.

There is no strategy which specifically covers the above.

A cohesive strategy and delivery plan is needed.

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

Please notify me

I have read the guidance notes

AS18(part of A9) - Land on Hollins Lane, Arnside

No

The DPD is not effective

The field was once a playing field for a private school and there is an old pavilion (wooden?) still in existence.
There will be some in Arnside who know the history of this field and we submit that this is part of the tapestry of the village.

Remove from plan.

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

Please notify me

I have read the guidance notes

General comment / comment on procedure

Yes

Yes

I support the AONB DPD because it reflects the purpose of the AONB to conserving landscape wildlife and natural beauty for future generations. Once lost cannot be retrieved.

I have read the guidance notes

AS01 - Development Strategy

Yes

Yes

I fully support the soundness of AONB DPD decisions.
As this was a joint consultation between both Councils and AONB officers I
sincerely hope this will now safeguard this area of Outstanding Natural Beauty
for future generations.

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

Please notify me

I have read the guidance notes

AS18(part of A9) - Land on Hollins Lane, Arnside

No

The DPD has not had regard to national planning policy

No

The DPD is not positively prepared

I believe that the DPD has not had regard to national planning policy in that a new development accessed from a country track thus creating a crossroads, constitutes urbanisation of a rural area.

I believe that the DPD is not positively prepared as repeated warnings about the safety of this site have been ignored. Hollins Lane is shown as a track on the OS map and is without any form of pedestrian walkways apart from a short stretch at the top. It is the oldest track in the village and the narrowest. Thorough risk assessment s and traffic surveys need to be carried out. Various hazards mean there is a moderate risk of injury to road users.

Please note that traffic has increased considerably since the site was first put forward several years ago, the lane has become a fast cut through.

Look at any alternative site accessible from a wider road.

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

I have read the guidance notes

Site Omission

Site S50

Yes

Yes

Please notify me

I have read the guidance notes

AS03 - Housing Provision

Yes

Yes

Please notify me

I have read the guidance notes

Inset Map - Station Yard, Arnside

Yes

Yes

Although we consider that the DPD is legally compliant and sound we feel that more consideration should be given to the impact of the Station Yard development on the adjoining properties. Due to the higher elevation of the Station yard relative to the adjoining properties and the potential for them to be over looked, we feel that the sensitive boundaries should be extended beyond the existing buildings to the entire boundaries of the adjoining properties.

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

Please notify me

I have read the guidance notes

General comment / comment on procedure

Yes

Yes

Final Comments on The Arnside and Silverdale AONB Development Plan Document

I generally support the AONB DPD because it reflects the statutory purpose of the AONB and gives great weight to the conservation of the landscape.

In particular:
• policy AS 01 Development Strategy – that all development should be consistent with primary purposes of the AONB and its special qualities as set out in the AONB management plan.
• policy AS 02 Landscape - the reference to rural nature, local distinctiveness, visual amenity, tranquillity, dark skies and the sense of place.
• AS 04 Natural Environment – the protection of designated sites that depends on holistic protection of the quality of the whole AONB and surrounding areas.
• AS 06 Key Settlement Landscapes – “bringing the country into the settlements and reinforcing their rural character” As for the natural environment a holistic protection of all the open space from farmland, woodland to semi-wild habitats and coastal areas are equally important. The coastal land should be included, particularly the small valley, parallel to Lindeth Road and Whinney Lots, extending from Kayes Nursery to Whinney Fold at Silverdale.
• AS 08 Design - A high standard of design that results in development that adds to the outstanding quality of the landscape still remains the fundamental requirement for any new building and these additional sites.

Implementation
The final plan seems to have taken account of the comments I and others have previously made and as suggested with by Green group implantation will require:

• As a priority a much stronger planning presence on the ground with rapid and effective enforcement if these new policies are to carry the full weight that they deserve.





Individual sites
In particularly mixed use prominent sites, AS 16 such as AS23, (AS 26/27) Station Yard at Arnside, where a well designed Master Plan with strong public consultation is essential and similarly AS 25 (B 35/38/81 and 125) land on Sandside Road and Quarry Lane, Sandside.

Planning Topics not covered by the plan
In recent years the drained mosslands of the Yealand Parishes (like similar areas elsewhere) have deteriorated and are becoming more prone to flooding and rush infested. Rather than resist what now appears to be an inevitable process it would be more sensible to concentrate on overall landscape restoration. One way of doing this would be investment to combine woodland planting with the creation of new lakes and tarns as a first stage to restoring natural wetland ecosystems.

The RSPB have demonstrated the success of creative conservation with their new reed beds at Barrow Scout and Silverdale Moss and I understand that they are now in negotiation for similar creation of mires in the flooded fields at Warton. As stated previously I welcome this ‘development’ but consider that it should be classed as major landscape development and included in the planning process (not the statutory development control) but based on a comprehensive planning survey of existing and potential land uses, with proper public consultation of options, as besides extending and supplementing existing wetlands these land use changes have both costs and benefits for the local residents. They can be designed and managed (not just as single interest nature reserves) but as multi purpose basis land management projects, with wider public access, landscape improvement by tree planting as well as the creation of linked lakes and tarns for fishing, wild life and low input farming on the surrounding land, producing sensible quantities of high quality meat, wild game, and possibly eventually some timber on a truly sustainable basis.

Conclusion
I consider the AONB DPD is an exemplary document, based on extensive study and wide local public consultation and can only hope that the implementation of the policies will be equally enlightened and thorough.

Roger Cartwright `13th December 2017

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

Please notify me

I have read the guidance notes

I have read the guidance notes

AS06 - Key Settlement Landscapes

B79 and B116

Yes

Yes

Whilst I consider the Arnside and Silverdale AONB DPD to be both legally compliant and sound, I wish to propose a modification which I believe will make it more complete and resilient
The Plan, Inset 4, Storth, shows by horizontal green hatching, areas B79 and B116 as "Key Settlement Landscapes".
Immediately to the east is pasture land - white on the plan.
This white land is the same on the ground as the green hatched land. Indeed there is no field boundary (fence, hedge, wall etc.) on the green line extending south west from the southern corner of B116, thus that part of it is one continuous field.
It is therefore logical that the designation of "Key Settlement Landscape" be continued eastwards to abut the large grey area of land to the east, and northwards to abut B81.
This would avoid leaving an island of undesignated land which is untidy.
I therefore propose this as a modification which I hope can be accepted at this stage.

Please see my comments regarding 1.5 above.

Yes, I wish to participate at the oral examination

In order to ensure that my suggested modification is fully considered.

Please notify me

I have read the guidance notes

General comment / comment on procedure

Yes

Yes

I fully support the soundness of the AONB DPD as it reflects the statutory aim of the AONB in conserving landscape and scenic beauty. The planners have listened to feedback from residents and the community.
In particular I support:
The reasons for preparing the DPD (para 1.25)
Its understanding of the National Planning Policy Framework that this should be a nationally protected landscape (para 1.3.6)
The objectives (para 2.2.1)
That all developments should fit within the primary purpose of the AONB (Policy AS01)
The fact that it is not necessary for the AONB DPD to identify any housing requirements (paras 3.1.3, 3.1.4)
References to the landscape character respecting the rural nature, the local distinctiveness, the protection of open views and undeveloped seascape, tranquility and dark skies (Policy AS02)
References to visual permeability and open areas which are inherent to the character of Silverdale (Policy AS08)
References to water quality, sewerage and drainage (Policy AS12) and the problems relating to the lack of mains sewerage system in Silverdale (4.9.2)
In excluding any sites in Silverdale as none were found to be appropriate. In particular excluding the land at Whinney Fold which was excluded based on a combination of factors including landscape impact, drainage, highway safety and
biodiversity (Policy AS16)

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

Please notify me

I have read the guidance notes

AS01 - Development Strategy

Yes

Yes

We fully support the published AONB DPD in every respect. Planners have clearly listened to all interested parties resulting in a DPD which is legally compliant and sound reflecting the statutory purpose of the AONB in conserving landscape and natural beauty.
We strongly support the exclusion of any proposals for housing development in Silverdale thereby helping to preserve the special character and qualities of the landscape in this part of the AONB.
We especially support the exclusion of any development on land at Whinney Fold, recognising the major impact that it would have on the landscape, drainage, biodiversity and very real highways access and safety issues.
Roy and Sylvia Davies

Please notify me

I have read the guidance notes

AS01 - Development Strategy

Yes

Yes

I believe the DPD is both legal and sound.

The DPD is an important means of ensuring that the objectives for which the
AONB was set up are fulfilled, particularly the conservation of landscape.

I have read the guidance notes

AS18(part of A9) - Land on Hollins Lane, Arnside

No

The DPD has not had regard to national planning policy

No

The DPD is not positively prepared

I believe that the DPD has not had regard to national planning policy in that a new development accessed from a country track, thus creating a crossroads, constitutes urbanisation of a rural area.

I believe that the DPD is not positively prepared as repeated warnings about the safety of this site have been ignored. Hollins Lane is shown as a 'track' on the OS Map and is without any form of pedestrian walkways apart from a short stretch at the top. It is the oldest track in the village, and the narrowest.

Thorough risk assessments & traffic surveys need to be carried out. Various hazards mean there is a moderate risk of injury to road users. Please note that traffic has increased considerably since the site was first put forward, several years ago. The lane has become a fast 'cut through'.

Look at an alternative site accessible from a wider road.

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

Please notify me

I have read the guidance notes

AS18(part of A9) - Land on Hollins Lane, Arnside

No

The DPD is not included in the councils' Local Development Schemes and the key stages have not been followed

The DPD does not comply with the Town and Country Planning (Local Planning) (England) Regulations 2012

A Sustainability Appraisal Report has not been published and/or its baseline information and conclusions have not been used to inform the DPD

The DPD has not had regard to national planning policy

No

The DPD is not positively prepared

The DPD is not justified

The DPD is not effective

The DPD is not consistent with national policy

1. Most of it is not in line with NPPF, paragraph 182.
2. No health & safety survey
3. No historic landscape survey
4. No biodiversity considered
5. Does not conform to AONB guideline F13

The Arnside AONB DPD is drawn up by an unelected quango.

Let Arnside Parish Council have more of a say. They are not an unelected quango.

Yes, I wish to participate at the oral examination

The inspector will be able to listen to all points of view.

Please notify me

I have read the guidance notes

I have read the guidance notes

General comment / comment on procedure

Yes

Yes

I support the proposed DPD for the Arnside & Silverdale AONB and recommend its acceptance as drafted. In particular, my support is based on the following points;
* I compliment the officers of both South Lakeland District & Lancaster City Councils and the staff of the Arnside & Silverdale AONB team on a thorough document which clearly states the national policies and land use criteria applicable to the AONB with protection of the landscape as the overriding objective,
* it selects development sites which are consistent with those policies and protects the general open character of the settlements within the AONB Landscape as well as meeting other key criteria,
*it recognises that development should only be permitted to fulfil essential local needs,
* it further states that the main essential local need is that for affordable housing,
* it sets a ratio of affordable versus market housing development which is consistent with all the relevant criteria for the AONB.

While I understand that achieving this ratio will be challenging for commercial developers and may make some sites inappropriate for commercial development, I also maintain that commercial development within the AONB is not appropriate unless it produces a very high yield of affordable housing. To do otherwise would sacrifice highly valued landscape for no benefit to meeting essential local needs.

I also understand that there are good prospects that bodies such as housing associations will step in to finance affordable housing needs.

For these reasons I recommend that the DPD should be considered “sound”.

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

Please notify me

I have read the guidance notes

I have read the guidance notes

General comment / comment on procedure

Yes

Yes

I support the proposed DPD for the Arnside & Silverdale AONB and recommend its acceptance as drafted. In particular, my support is based on the following points;
* I compliment the officers of both South Lakeland District & Lancaster City Councils and the staff of the Arnside & Silverdale AONB team on a thorough document which clearly states the national policies and land use criteria applicable to the AONB with protection of the landscape as the overriding objective,
* it selects development sites which are consistent with those policies and protects the general open character of the settlements within the AONB Landscape as well as meeting other key criteria,
*it recognises that development should only be permitted to fulfil essential local needs,
* it further states that the main essential local need is that for affordable housing,
* it sets a ratio of affordable versus market housing development which is consistent with all the relevant criteria for the AONB.

While I understand that achieving this ratio will be challenging for commercial developers and may make some sites inappropriate for commercial development, I also maintain that commercial development within the AONB is not appropriate unless it produces a very high yield of affordable housing. To do otherwise would sacrifice highly valued landscape for no benefit to meeting essential local needs.

I also understand that there are good prospects that bodies such as housing associations will step in to finance affordable housing needs.

For these reasons I recommend that the DPD should be considered “sound”.

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

Please notify me

I have read the guidance notes

General comment / comment on procedure

Yes

We support the proposed DPD for the Arnside & Silverdale AONB and recommend its acceptance as drafted. In particular, our support is based on the following points;

* We compliment the officers of both South Lakeland District & Lancaster City Councils and the staff of the Arnside & Silverdale AONB team on a thorough document which clearly states the national policies and land use criteria applicable to the AONB with protection of the landscape as the overriding objective,

* it selects development sites which are consistent with those policies and protects the general open character of the settlements within the AONB Landscape as well as meeting other key criteria,

* it recognises that development should only be permitted to fulfil essential local needs,

* it further states that the main essential local need is that for affordable housing,

* it sets a ratio of affordable versus market housing development which is consistent with all the relevant criteria for the AONB.

While we understand that achieving this ratio will be challenging for commercial developers and may make some sites inappropriate for commercial development, we also maintain that commercial development within the AONB is not appropriate unless it produces a very high yield of affordable housing. To do otherwise would sacrifice highly valued landscape for no benefit to meeting essential local needs.

We also understand that there are good prospects that bodies such as housing associations will step in to finance affordable housing needs.

For these reasons we recommend that the DPD should be considered “sound”.

Mr & Mrs J.S. Fisher

I have read the guidance notes

General comment / comment on procedure

Yes

Yes

I support the soundness of the whole of the DPD especially AS01, AS11 and AS12.

AS01 I welcome the Development Strategy and in particular that there is no specific housing requirement for the AONB
AS11 This policy needs to be reinforced to maintain a balance between residential properties and visitor/second home use.
AS12 Flooding has become a major concern in the AONB.
The water table in many areas is being maintained at levels above what they used to be. This means water cannot flow freely out to sea at low tides and causes severe problems in many areas.

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

Please notify me

I have read the guidance notes

AS01 - Development Strategy

Yes

Yes

First, I wish to congratulate the AONB officers and all those involved from SLDC and LCC for their hard work in producing a balanced and well thought out DPD, which has now been approved by both Councils. It is clear, rational and very positive.

I wholly agree with the vision and aims. In my view it is entirely sound because it reflects national policy and the statutory purpose of the AONB with its primary focus on protecting the landscape which should be at the forefront of all policy.


The AONB is the second smallest in the country. It is unique in many respects and is of international importance. Visitors and residents alike help it to thrive. But it is vital that we preserve it for future generations. At only 75 square kms and with a scattered population of under 8,000, it is fragile and must be protected for the enjoyment of all against those who would abuse it, purely for commercial gain. The DPD if adopted and enforced would achieve that.

None.

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

Please notify me

I have read the guidance notes

AS15 - Housing Allocations

Yes

Yes

I support the strategy for housing provision. Any additional housing must be governed by local need and be sympathetic to overriding landscape considerations. I note and welcome that none is allocated to Silverdale. There simply are no suitable sites there for any significant development. In particular, any proposals for further development at Whinney Fold are inappropriate on grounds of landscape impact, access difficulties, highway safety, biodiversity, drainage and density of development.

None.

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

Please notify me

I have read the guidance notes

AS11 - Camping, caravan and Visitor Accommodation

Yes

Yes

As stated, the policy continues the current restrictive approach to caravan development, along with some additional criteria and clarifications, providing a bespoke AONB approach.

I wholly endorse this.

There are someting like 1,700 static and touring caravan pitches in a relatively small area. If all the caravans were parked on the road end to end, they would stretch from Silverdale to Morecambe and beyond. I apologise for this apocalyptic vision, but it makes the point. There are already too many caravans in such a small fragile area, particularly statics. If numbers cannot be curbed, they should not be allowed to increase.


Of course visitors and even caravanners are most welcome in the AONB, but the sites detract from the landscape and cause horrendous traffic problems. The amount of overall economic gain for the area is debateable.

The AONB needs to be more diverse and sustainable in its offering to visitors, with a new focus on true camping, yurts, shepherd's huts and low impact accomodation.

A good example is the Leeds Children's Holiday Camp, where the new owner seeks to create a new site of 25 static caravans plus warden's housing and reception on a grassy and very prominent headland. This involves the demolition of a much loved existing art deco building. With flair and imagination, a diverse visitor offering could be created. It might be an outward bounds centre, or a cycling hostel for the new Morecambe Bay cycleway, or a restaurant with rooms or a boutique hotel or a wedding venue or an educational summer school. It would make an excellent children's camp. But please, no more ugly, inappropriate static caravans. The DPD would prevent this. In doing so, it reinforces current policy. I heartily approve.

None.

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

Please notify me

I have read the guidance notes

AS01 - Development Strategy

I strongly agree that the DPD is sound, as it closely follows the rationale of what an AONB sets out to achieve, with its clear concerns for the natural habitat in relation to development and the conservation of the landscape. The Planning Policy Department has dealt with the vagaries of land being in, then withdrawn and then included again very patiently and accorded the same consultation to the ‘extra’ later land additions well. Locally it has encouraged the community to become more involved in the sensitive development of their area. I fully support the entire document for these reasons.
In Silverdale we have been concerned by the effects on the ground water caused by large developments since we have no mains drainage in the village. Apparently there is an EU directive restricting such villages as ours, with no mains drainage, to a certain number of homes, a number which when I checked we far exceeded if one takes into account the permanent and many holiday caravans in the area. The recent heavy rainfall has caused a recurrence of the flooding in our cemetery, which was reported in The Westmorland Gazette. This has caused great distress as you would imagine.
Again I would like to thank the Planning Policy Officers for conducting a very thorough, all-encompassing and rigorous review.

Yes

Yes

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

Please notify me

I have read the guidance notes

General comment / comment on procedure

Yes

Yes

I fully support the legal compliance and soundness of the AONB DPD because of it reflects faithfully the primary purpose of an AONB to conserve landscape and natural beauty.
I support particularly:
The reasons for the preparation of the DPD (para. 1.25)
Its understanding of the NPPF (para.1.3.6)
Its objectives (para.2.2.1)
Policy AS01 - that any development should fit within the primary purpose of an AONB.
The paragraphs (3.1.3, 3.1.4) which show it is not necessary for an AONB DPD to identify housing requirements.
The references in Policy AS02 to local distinctiveness, visual amenity and the sense of space and place.
Policy AS08 and the references to visual permeability and open areas which are important to Silverdale's character.
The references to water quality, sewerage and drainage (Policy AS12) and the implied presumption against development in areas not connected to mains drainage.
Policy AS16 in excluding any sites in Silverdale as no appropriate sites were found and in particular excluding the land at Whinney Fold because of a combination of considerations including landscape impact, drainage, highway access and biodiversity.

Please notify me

I have read the guidance notes

General comment / comment on procedure

Yes

Yes

I support the soundness of the DPD as, guided by the National Planning Policy Framework relating to AONBs, it gives great weight to conserving the beauty of the landscape and protecting the natural environment and is consistent with the statutory purpose of the AONB.

I support the reasons for preparing the AONB DPD set out in paragraph 1.2.5 and the objectives set out in paragraph 2.2.1.

I support among others, policy AS12 relating to water quality, sewerage and sustainable drainage, which is especially relevant in areas, such as Silverdale, not connected to mains drainage.

Please notify me

I have read the guidance notes

General comment / comment on procedure

Yes

We support the proposed DPD for the Arnside & Silverdale AONB and recommend its acceptance as drafted. In particular, our support is based on the following points;

* We compliment the officers of both South Lakeland District & Lancaster City Councils and the staff of the Arnside & Silverdale AONB team on a thorough document which clearly states the national policies and land use criteria applicable to the AONB with protection of the landscape as the overriding objective,

* it selects development sites which are consistent with those policies and protects the general open character of the settlements within the AONB Landscape as well as meeting other key criteria,

* it recognises that development should only be permitted to fulfil essential local needs,

* it further states that the main essential local need is that for affordable housing,

* it sets a ratio of affordable versus market housing development which is consistent with all the relevant criteria for the AONB.

While we understand that achieving this ratio will be challenging for commercial developers and may make some sites inappropriate for commercial development, we also maintain that commercial development within the AONB is not appropriate unless it produces a very high yield of affordable housing. To do otherwise would sacrifice highly valued landscape for no benefit to meeting essential local needs.

We also understand that there are good prospects that bodies such as housing associations will step in to finance affordable housing needs.

For these reasons we recommend that the DPD should be considered “sound”.

For the above reasons and the following, the application (SL/2017/0935) should be refused because it is within a protected site in which development is prohibited in both the current and proposed planning policies.

Plus, there is strong evidence that this part of the site regularly floods and affects properties further down Lawrence Drive and Parkside Drive. On Wednesday 22nd November, Parkside Drive was flooded again after heavy rain requiring the fire service to assist by pumping flood water away. This was due, in part, to run off from the hill above and from this particular field where the development is proposed. It is likely that any building or hard-landscaping in this area could have an adverse impact on adjoining properties and Parkside Drive.

Steve and Paula Harrison

I have read the guidance notes

I have read the guidance notes

General comment / comment on procedure

Yes

Yes

I support the AONB DPD and believe it properly takes into account the statutory purpose of the AONB in giving great weight to conserving landscape and natural beauty. In particular I support:
- the reasons for preparing the DPD set out in paragraph 1.25
- the interpretation of the NPPF in paragraph 1.3.6, which is particularly important
- the objectives in paragraph 2.2.1
- Policy AS01 Development Strategy, especially that all development should be consistent with the primary purpose of the AONB and support the Special Qualities of the AONB as set out in the Management Plan
- Paragraphs 3.1.3 and 3.1.4 in stating that it is not necessary for the AONB DPD to identify a specific housing requirement
- Policy AS02 on Landscape, especially the references to rural nature, local distinctiveness, visual amenity, tranquillity, dark skies and the sense of space and place
- Policy AS06 on Key Settlement Landscapes relating to 'bringing the country into the settlements and reinforcing their rural character'
- Policy AS08 on Design, in particular the references in paragraphs 4.5.3 to visual permeability and 4.5.23 to open areas forming an important part of Silverdale's character
- Policy AS12 on Water Quality, Sewerage and Sustainable Drainage, especially in relation to the need for evidence in areas not connected to mains drainage (but consider the volume of any discharge should be considered in addition to quality. I also consider that this could contain a stronger presumption against development in such areas and not merely a statement of process as drafted)
- Policy AS16 in excluding any sites from Silverdale, not because of any objection in principle but because no sites were found to be appropriate in the light of the statutory purposes, especially supporting the exclusion of land at Whinney Fold on the basis that a combination of factors related to landscape impact, drainage, biodiversity (including impact on the Morecambe Bay designated site), and highways safety rule this site out.

Please notify me

I have read the guidance notes

General comment / comment on procedure

Yes

Yes

I support the legal compliance and soundness of the DPD, and the compliance with the duty to cooperate. I attended the Parish Council meeting relating to the plan & consulted document which were made available on the web. The public were given adequate opportunities to comment on the proposed plan.

Please notify me

I have read the guidance notes

AS19(A11) - Land on Briery Bank, Arnside

No

The DPD is not justified

The DPD is not effective

The plan to develop land on Briery Bank Arnside does not consider existing parking problems on the
adjacent area of Briery Bank and how the development will avoid adding to these problems. Illegal
parking on the bend just below Stoneycroft Drive and opposite the Stoneycroft Drive junction with Briery Bank
is already dangerous, likey to cause accidents and no parking enforcement appears to have occured. Parking is
a particular problem on a Saturday afternoon when the upper part of Briery Bank is frequently down to one
lane only without passing places and traffic coming up Briery Bank not slowing down before the StoneyCroft
Drive junction. Parking on the bends further down Briery Bank is also a problem and is likely to result in accidents
from allowing insufficent space for two way traffic on the hill to pass. These problems are already progressively
getting worse. Adequate parking for two vehicles per new home needs to be considered and how parking will
controlled on Briery Bank to prevent use of a new junction on or near a bend not being hazadous. Although a
small carpark was provided for a recent housing development on Briery Bank just below the telephone exchange
this is only poorly used with residents prefering to park on Briery Bank.

Adequate parking provision of more than 1 vehicle per houshold is needed for the proposed new homes and
parking control on Briery Bank to prevent existing illegal and dagerous parking is required for this
development.

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

Please notify me

I have read the guidance notes

General comment / comment on procedure

Yes

Yes

I support the legal compliance and soundness of the DPD and its duty to cooperate.

I am satisfied that the Councils supplied relevant information and made this available at several consultation meetings which I attended.

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

Please notify me

I have read the guidance notes

General comment / comment on procedure

Yes

Yes

I support the legal compliance and the soundness of the DPD and its compliance with the duty to cooperate. Opportunities for the public to view the plans, hear the opinions and offer points of view and arguments have been publicised. I have attended meetings at which the DPD has been discussed.

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

Please notify me

I have read the guidance notes

AS06 - Key Settlement Landscapes

Yes

Yes

Please notify me

I have read the guidance notes

I have read the guidance notes

General comment / comment on procedure

Yes

Yes

I support the AONB DPD and sincerely hope that the implementation of this document will 'safeguard' this area of 'outstanding natural beauty'.
I appreciate the amount of work that has gone into this DPD, and thank all those involved for their efforts.
I am pleased that this was a joint consultation document between both Councils and AONB Officers. Its successful completion, will hopefully encourage other 'joint' projects. After all, it is only a line on the map that separates us in most places!
Post script;
In connection with Silverdale, I hope Planners/Developers will take special note of recent 'flooding' issues in the Village - especially in areas close to sites, which have previously been considered for Building!
Thank you.

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

Please notify me

I have read the guidance notes

AS11 - Camping, caravan and Visitor Accommodation

Yes

Yes

It contains all that is necessary to maintain a well run and maintained AONB
Especially it recognises that there is no need for any further housing in silverdale. Secondly and very important that it recognises the saturation level of static caravans in the area. We cannot allow anymore static caravans or camping sites

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

Please notify me

I have read the guidance notes

AS01 - Development Strategy

Yes

Yes

AS01
General
I have lived in the Arnside and Silverdale AONB for 17 years, first in Yealand Conyers, and for the last 15 years in Silverdale. I have worked in both Arnside and Silverdale. I have taken an interest in planning issues during that time, for both work and personal reasons.

Both Councils and the AONB Partnership are to be congratulated on the effort they have put into this DPD, and on the result. This document has been based on thorough investigation and extensive consultation. That is not to say that I wholeheartedly agree with every word of it, but I do think it is a sound, positive and justified document, and very clearly the product of co-operation between Councils. A joint, ‘cross-border’ DPD for the AONB has, to my certain knowledge, been proposed as a sensible measure since at least 2002. The reasons for it set out in paragraph 1.2.5 are cogent, based on principle, and practical.

The approach of the DPD, and the policies in it, all put the purpose of designation at the heart of policy. In that, they reflect the legal duties required of Councils under s. 85 of the 2000 Act in respect of AONBs and the requirement of the NPPF (para. 115) regarding AONBs. At the same time, they take due account of other aspects and requirements of the NPPF.

The landscape-capacity approach adopted is appropriate given that this is not only a designated area but one that is small in size, and small in the physical scale of much of its landscape.

In general terms, I welcome the specific policies that cover aspects of development that are sometimes overlooked, or paid notional attention – design, materials, relationship to surroundings, settlement characteristics and the need to retain some open spaces within settlements (particularly important in Silverdale, where the open spaces are one of its most distinguishing features).

I would like to comment on two aspects of the proposed policies that might seem at first sight to be restrictive or ‘negative’, but are in fact positive in effect, and another that might seem unnecessary. The last is brownfield sites, dealt with in AS01 and the comments below. The others are housing allocations generally (AS03) and camping and caravan sites (AS11) – dealt with in separate responses.

Brownfield sites
There are not that many brownfield sites in the AONB, but there are some, and a number are in prominent positions – for instance, on the coast, or on the shore of the Kent estuary, between Arnside and Milnthorpe.

I fully support the draft DPD in making it clear in AS01 that the brownfield nature of a site is a factor to be considered in development proposals, but should not trump or outweigh other policy considerations. This may seem so obvious that it does not need stating, but arguments have been made, and are still being made, that if a development proposal is of the same sort of scale and size as the previous development, then it should be permitted, irrespective of any other considerations, such as the nature of the development and the sensitivity of the location.

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

Please notify me

I have read the guidance notes

AS03 - Housing Provision

Yes

Yes

Housing AS03
The draft DPD identifies relatively few areas as suitable for housing development.
But this is for good reasons. The size of the area, the nature of the landscape, the geology (large areas of limestone on or close to the surface) and the fact that much of the AONB is designated for its wildlife and habitat (e.g. as SSSI), plus the narrowness of the roads and limited public transport and facilities, all combine to mean that land suitable for housing development is indeed in short supply. Where land is identified as suitable, it is surely reasonable that any development makes at least some contribution to identified local housing needs.

I have seen an argument, made on behalf of developers and landowners, that because this AONB is small and more densely populated than others, that more land should be made available rather than less. That seems to me to be looking down the wrong end of the telescope.

It is also fair to say, I think, that there are far more substantial opportunities for development on the immediate boundaries of the AONB, in the small towns of Carnforth (Lancaster District) and Milnthorpe (South Lakeland), where there is a broader range of services, shops, transport, etc.

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

Please notify me

I have read the guidance notes

AS11 - Camping, caravan and Visitor Accommodation

Yes

Yes

I believe the restrictions set out in AS11 are justified, consistent with national policy and indeed positive, given the background and recent history.

My comments on this are detailed because, when I logged in to make them, I came across the response made to this policy by Steven Abbott Associates on behalf of Holgates Caravan Parks. That response seems to me to demand to be challenged, so my original comments have been augmented.

It has long been recognised by both Councils, and by local residents, that while caravan development (of which there is a great deal in this AONB) has brought economic benefits it is also damaging to the landscape.

Despite already restrictive policies, caravan development in the AONB has increased significantly in size, scale, spread and visibility in the last 15 years. Touring sites now frequently offer seasonal pitches, so caravans are on site most of the year. Statics are more visible because of increased size, tree felling, decks, balustrades, lighting, etc. Some areas of the AONB are becoming dominated by caravan development, with more static development being applied for at the time of writing this.

The response on behalf of Holgates claims that AS11 is contrary to the NPPF and to paragraph 28, especially bullet point three. The draft DPD policy seems to me to be entirely consistent with the NPPF, especially para. 115, but also with bullet point three of para. 28. Plans should:

support sustainable rural tourism and leisure developments that benefit
businesses in rural areas, communities and visitors, and which respect the
character of the countryside. This should include supporting the provision
and expansion of tourist and visitor facilities in appropriate locations where
identified needs are not met by existing facilities in rural service centres.

Key words phrases here are 'sustainable rural tourism', 'developments..which respect the character of the countryside', 'appropriate' locations where ' identified needs are not met by existing facilities'.

Caravan development usually does not respect the character of the countryside, is therefore not sustainable and in this area there are plenty of facilities already (nearly 1400 static pitches).

The Holgates response also claims that the NPPF supports caravan expansion because it requires that plans support rural businesses. But most caravan park businesses do not require help and encouragement from planning policy. Holgates, for instance, is a multi-million pound business with net annual profits of some £3m and net assets of nearly £20m.

The Holgates response asks why the AONB policy should be more restrictive that that in the Lake District. If this is true,there are a number of answers to this:
- This is a smaller area.
- It has a smaller and more intimate landscape.
- The density of static caravans is already high. I believe it used to be the case, and may still be, that there were more static caravans in the Arnside and Silverdale AONB than in the whole of the Lake District National Park.
- The pressure from caravan site owners, or potential site owners for development may well be higher in the AONB than in the National Park.

The Holgates response also paints a picture of caravan site owners that are sensitive to the landscape and exercise restraint and imagination in proposing developments. This is not my observation.

Over the last 15 years, I have seen various site owners or would-be site owners:
- Carry out significant development without prior planning permission
- Make clearly exaggerated claims for certificates of lawful use
- Make clearly untrue statements about the (in)visibility of proposed caravan development, e.g. from highways, footpaths or open access areas
- Twist the normal meaning of words to try to claim, wrongly, that their proposal fits within the exceptions of the current caravan policy T5.
And what they propose or install is always more of the same offer – statics, tourers (with seasonal pitches if they can), with some tents and a few camping ‘pods’. And this is in a small AONB where there are already over 1,600 licensed pitches, including nearly 1,400 for statics.

The Holgates response mentions – indeed, makes much of- their current application in respect of the Leeds Children’s Holiday Camp, just outside Silverdale. The story of this proposal illustrates my point well, so I wish to say more about it.

Holgates have bought the site of a financially embattled children’s holiday camp. It is on a cliff-top site in the AONB, visible from the other side of Morecambe Bay, and from the largest local area of public open access. It is on the edge of a village where there are already a large number of static and touring pitches nearby (most of them run by Holgates) and where the increase in caravan development and the traffic it brings is a well-known source of concern and grievance for many local residents.

Against this background, what development do Holgates propose? Twenty-five standard, rectangular static caravans in fake timber, in rigid rows, with decks, parking, lighting, etc. There is not much imagination or sensitivity to the landscape in evidence here. Just 25 more caravans (plus an ancillary building) when there are more than 500 static caravans within 10 minutes’ walk (most of them run by Holgates). And set out in a way that spreads caravan development along the coast and turns a key route into Silverdale village into an entrance through a caravan park, as there would be entrance gates/security barriers on both sides of the road, plus a new reception building/manager’s house on the new site.

The Holgates response claims it will create ecological benefit, because 1,000 trees will be planted as part of the development. If the trees are for screening, a development proposal that requires an average of 40 trees per caravan is obviously an inappropriate development. If the trees are supposed to be largely for ecological benefit and biodiversity, they are also inappropriate in such numbers as this area is defined within the AONB Landscape and Seascape Assessment as ‘coastal limestone pasture’ character type. The proposed development and planting would lead to the loss on this site of many of the key characteristics of that landscape type, and be contrary to the guidance given on their enhancement and conservation.

(Holgates are generally keen to claim that they provide ecological as well as economic benefits. For example, in their response on this policy, their agent claims that ‘my client is one of only 3 caravan parks in the whole of the UK’ to receive a David Bellamy Gold award. It is not clear to me exactly what the relevance of that is in this context, but the claim is puzzling. These awards are made by the industry, and while no doubt worthy and to be encouraged, the award does not in fact appear to put Holgates upon a pinnacle of special conservation achievement, as suggested. The relevant website (www.ukparks.com) shows and maps 428 camping and holiday parks in the UK which currently hold the David Bellamy Gold Award. The Holgates parks at Silverdale, Silver Ridge and Hollins Farm are indeed shown. But so are 425 others, including three in the Arnside and Silverdale AONB alone (not including those run by Holgates) – Scout Cragg, Hall More and Fell End.)

Finally, to cap all this, the original application claimed that the development ‘responded well’ to policy T5 (no more static caravan development, unless small, and within the general screened boundaries of an existing site, and subject to further other criteria) when it was neither small, not within the screened boundaries of an existing site. Even now, the appeal documentation claims that there is only ‘some friction’ with T5.

Given, therefore, the numbers of static and touring pitches already available, plus the lack of imagination and restraint historically shown by site developers, a strengthened policy which requires owners to be more imaginative, and proposals to be more sensitive to the landscape, is a positive move. It puts the landscape first, not caravan development.

I do have reservations about, for instance, yurts – which in the wrong materials or colours might be just at intrusive in the landscape as seasonal caravans – but a principle that constant caravan expansion is not appropriate or sustainable must surely be right.

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

Please notify me

I have read the guidance notes

I have read the guidance notes

General comment / comment on procedure

Yes

We, Karen Longhorn and Kenneth MacKinnon, of [ADDRESS REMOVED], support the proposed DPD for the Arnside & Silverdale AONB and recommend its acceptance as drafted. In particular our support is based on the following points:

• We compliment the office of both South Lakeland District & Lancaster City Councils and the staff of the Arnside & Silverdale AONB team on a thorough document which clearly states the national policies and land use criteria applicable to the AONB with protection of the landscape as the overriding objective.

• It selects developments sites which are consistent with those policies and protects the general open character of the settlements within the AONB landscape as well as meeting other key criteria.

• It recognises that development should only be permitted to fulfil essential local needs.

• It further states that the main essential local need is that for affordable housing.

• It sets a ratio of affordable versus market housing development which is consistent with the relevant criteria for the AONB.

• Whilst we understand that achieving this ratio will be challenging for commercial developers and may make some site inappropriate for commercial development, we also maintain that commercial development within the AONB is not appropriate unless it produces a very high yield of affordable housing. To do otherwise would sacrifice highly valued landscape for no benefit to meeting essential local needs.

• We also understand that there are good prospects that bodies such as housing associations will step in to finance affordable housing needs.

For these reason we recommend that the DPD should be considered sound.

Yours faithfully,

Karen Longhorn and Kenneth MacKinnon

I have read the guidance notes

AS01 - Development Strategy

Yes

Yes

*Reflects purpose of AONB
* history of reliable decision making
*Design
*Considers drainage, sewerage and flooding issues
*"Brings the country into settlements and reinforces rural character"
* Specific housing requirement does not need to be identified
*Protection of historical, natural, environmental characteristics

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

Please notify me

I have read the guidance notes

I have read the guidance notes

AS12 - Water quality, sewerage and sustainable drainage

Yes

Yes

Pleased to see recognition of problems of septic tank drainage and risks of flooding, and the need to ensure waste is properly managed, although not much detail about how these problems are to be addressed. However I could see nothing to address the cumulative impact on the fragile environment of actions such as concreting and tarmacking, cutting down trees and building patios all of which serve to damage subterranean stratas in ways not fully understood. We know they serve to raise the water table, overload drains and cause flash flooding. In this area such floodwaters are foul. This requires both public education and efforts by councils to encourage more responsible stewardship by individuals and businesses.

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

Please notify me

I have read the guidance notes

I have read the guidance notes

AS04 - Natural Environment

Yes

Pleased to see recognition of problems of septic tank drainage and risks of flooding, and the need to ensure waste is properly managed, although not much detail about how these problems are to be addressed. However I could see nothing to address the cumulative impact on the fragile environment of actions such as concreting and tarmacking, cutting down trees and building patios all of which serve to damage subterranean stratas in ways not fully understood. We know they serve to raise the water table, overload drains and cause flash flooding. In this area such floodwaters are foul. This requires both public education and efforts by councils to encourage more responsible stewardship by individuals and businesses.

I have read the guidance notes

I have read the guidance notes

General comment / comment on procedure

Yes

It is good that the Counties have worked together over this plan. There are other important issues which require joint working, such as public transport, which is needed to access services as well as help maintain friendship and family links. For example, there is no bus service between Arnside and Silverdale yet there is a GP surgery which services the 2 villages.

I have read the guidance notes

AS03 - Housing Provision

Yes

Yes

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

Please notify me

I have read the guidance notes

AS01 - Development Strategy

Yes

Yes

AS01

The DPD is a sound piece of work. The purpose of the AONB is to conserve the landscape and natural beauty of the area. It gets the balance between development and conservation right.

I fully support the lack of development in Silverdale. There are already significant issues on drainage, sewerage and water quality in and around Silverdale. To have significant development will simply make these issues worse. The main example of which is the recently declined Whinney Fold development.

There are no brownfield sites in Silverdale and taking greenfield land such as Whinney Fold will degrade the visual amenity and local landscape for no other reason than profit.

Silverdale is a coastal village with a high reputation for visual amenity, tranquillity and natural beauty. The DPD takes this onboard and supports the continuing conservation of the village by the absence of areas for housing development. To modify the DPD and identify areas for development in Silverdale cuts directly across any AONB or statutory obligation. We should have confidence in their conclusions and recommendations.

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

I have read the guidance notes

I have read the guidance notes

General comment / comment on procedure

Yes

Yes

I strongly agree that the DPD is sound, as it closely follows the rationale for the existence of the AONB, with its clear concerns for the natural habitat in relation to development and the conservation of the landscape. I am surprised that this is the first such AONB DPD in England, but suspect it will be followed by others. Locally it has encouraged the community to become more involved in the sensitive development of their area. I fully support Para.1.2.5 for this reason, and indeed, the entire document.
In our village of Silverdale we have been concerned by the effects on the ground water caused by large developments since we have no mains drainage in the village. The recent heavy rainfall has caused a recurrence of the flooding in the area behind Whinney Fold which had been considered for development until a review of the drainage, sewage,landscape impact, biodiversity, and pedestrian safety concerns ruled it out. I was personally greatly encouraged by one of the planners at a local meeting, who mentioned a previous submission of mine about a specific pedestrian safety problem in Whinney Fold caused by the proposed access road. It is clear - and very comforting - to realise the planners do read all the submissions, consider them, and act upon them if appropriate!

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

Please notify me

I have read the guidance notes

General comment / comment on procedure

Yes

Yes

I support the soundness of the AONB DPD because it embodies the reasons that the AONB exists. The protection of intrinsic beauty and geography is recognised in the DPD. Although I don't have technical knowledge in the area of statutory obligations I recognise that the way the plan interprets statute and holds to the purpose of the AONB is clearly represented in the plan. I support the way the plan protects the distinctiveness of local nature and amenity. Drainage is a particular issue in Silverdale and I'm glad the plan acknowledges the peculiar issues this presents to development here.

Please notify me

I have read the guidance notes

AS19(A11) - Land on Briery Bank, Arnside

This proposed development should not take place. OPen areas forma a very important part of Arnside character particularly on this intensively developed hillside viewed from many aspects. The ex orchard should be replanted or opened up as part of the adjoining field.

Yes

Yes

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

I have read the guidance notes

AS18(part of A9) - Land on Hollins Lane, Arnside

Yes

Yes

This proposed development should not take place. Open areas form a very important part of Arnside character particularly on this intensively developed hillside viewed from many aspects.

I have read the guidance notes

AS20(B108) - Church Street, Beetham

Yes

Yes

I doubt if the local residents are pleased with this proposal! A loss of good agricultural land. If this proposed development went ahead the fairy steps path will become an urban eyesore, hence relocate it to the end of the proposed development as existing path.

I have read the guidance notes

AS21(W88) - North West of Sand Lane, Warton

Yes

Yes

This proposal is eating into agricultural land, where would it eventually stop. The land is much higher than the road level consequently any buildings would be over powering to the existing houses across the road set at a much lower level.

I have read the guidance notes

AS24(S70) - Railway Goods Yard, Silverdale

Yes

Yes

Silverdale has managed many years without a goods yard. Being a rural station without any industry, retain it that way. If any development took place it should be domestic properties on the style of railway-mans cottages, with parking for those traveling by train only.

I have read the guidance notes

AS25 (B35/B38/B81/B125) - Sandside Rd & Quarry Lane, Sandside

Yes

Yes

Any development should be residential only and not like the two most in-appropriate concrete blocks close by. Any proposed business may be a shop if considered viable. The existing car company adjacent should be encouraged to move to a more appropriate location.

I have read the guidance notes

AS18(part of A9) - Land on Hollins Lane, Arnside

Yes

No

The DPD is not effective

The plans for the new development on Hollins lane again have failed to take into account the current situation in relation to traffic use. The road is very narrow and is not only used my residents but many who use the road as a through road.

There are no passing spaces on the road which requires drivers to pull into residents private driveways to allow others to pass.

Adding more vehicles to this would cause further danger and possibility of accidents. During the construction with machinery and HGV's the current road could not manage and would be seriously dangerous for the current residents.

Using the Field on Hollins Lane is completely unsuitable for any development that would add to the traffic that currently use the road. Please use a wider road that has adequate pavements and room for two cars to pass with endangering pedestrians, cyclists and drivers.

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

Please notify me

I have read the guidance notes

AS18(part of A9) - Land on Hollins Lane, Arnside

Yes

No

The DPD is not positively prepared

I believe that the DPD has not had regard to national planning policy in that a new development accessed
from a country track thus creating a crossroads, constitutes urbanisation of a rural area.

I believe that the DPD is not positively prepared as repeated warnings about the safety of this site have been
ignored. Hollins Lane is shown as a track on the OS map and is without any form of pedestrian
walkways apart from a short stretch at the top.

It is the oldest track in the village and the narrowest.

Thorough risk assessments and traffic surveys need to be carried out. Various hazards mean there is a
moderate risk of injury to road users.

There is abundance of wildlife that inhabit the hedgerow and dry stone walls including newts and bats.
I am unaware of any survey that has been carried out regard the flora and fauna of this area.

There are also problems with drainage which will be exacerbated if the field is developed.

Please note that traffic has increased considerably since the site was first put forward several years ago, the lane has become a fast cut through.

This proposed development should not take place. Open areas form a very important part of Arnside character particularly on this intensively developed hillside viewed from many aspects.

Using the Field on Hollins Lane is completely unsuitable for any development that would add to the traffic
that currently use the road. Please use a wider road that has adequate pavements and room for two cars to
pass without endangering pedestrians, cyclists and drivers.

Yes, I wish to participate at the oral examination

I would like to be able to put my point of view and the concerns I have regarding the development of the site.

Please notify me

I have read the guidance notes

AS18(part of A9) - Land on Hollins Lane, Arnside

Yes

No

The DPD is not effective

I believe that the DPD has not had regard to national planning policy in that a new development accessed from a country track thus creating a crossroads, constitutes urbanisation of a rural area.

I believe that the DPD is not positively prepared as repeated warnings about the safety of this site have been ignored. Hollins Lane is shown as a track on the OS map and is without any form of pedestrian walkways apart from a short stretch at the top. It is the oldest track in the village and the narrowest. Thorough risk assessments and traffic surveys need to be carried out.

The plans for the new development on Hollins lane again have failed to take into account the current situation in relation to traffic use. The road is very narrow and is not only used my residents but many who use the road as a through road. Please note that traffic has increased considerably since the site was first put forward several years ago.

There are no passing spaces on the road which requires drivers and pedestrians to pull into residents private driveways to allow others to pass.

There is abundance of wildlife that inhabits the hedgerow and dry stone walls including newts and bats. I believe that the AONB DPD is unsound because it does not protect wild species of flora and fauna or their habitats. I am also unaware of any survey that has been carried out regarding the flora and fauna of this area.

There are also problems with drainage which will be exacerbated if the field is developed.

Please use a wider road that has adequate pavements and room for two cars to pass without endangering pedestrians, cyclists and drivers. Using the Field on Hollins Lane is completely unsuitable for any development that would add to the traffic that currently uses the road.

Yes, I wish to participate at the oral examination

I would like the inspector to hear my concerns.

Please notify me

I have read the guidance notes

General comment / comment on procedure

Yes

Yes

I support the soundness of the AONB DPD because it reflects well the statutory purpose of the AONB in giving great weight to conserving landscape and natural beauty. in particular I support:
- the reasons for preparing the DPD set out in paragraph 1.25
- the interpretation of the NPPF in paragraph 1.3.6
- the objectives in paragraph 2.2.1
- Policy AS01 Development Strategy, especially that all development should be consistent with the primary purpose of the AONB and support the Special Qualities of the AONB as set out in the Management Plan
- Paragraphs 3.1.3 and 3.1.4 in stating that it is not necessary for the AONB DPD to identify a specific housing requirement
- Policy AS02 on Landscape, especially the references to rural nature, local distinctiveness, visual amenity, tranquillity, dark skies and the sense of space and place
- Policy AS06 on Key Settlement Landscapes relating to 'bringing the country into the settlements and reinforcing their rural character' (but consider that further locations around Silverdale could meet that definition)
- Policy AS08 on Design, in particular the references in paragraphs 4.5.3 to visual permeability and 4.5.23 to open areas forming an important part of Silverdale's character
- Policy AS12 on Water Quality, Sewerage and Sustainable Drainage, especially in relation to the need for evidence in areas not connected to mains drainage (but consider that this could contain a stronger presumption against development in such areas and not merely a statement of process as drafted)
- Policy AS16 in excluding any sites from Silverdale, not because of any objection in principle but because no sites were found to be appropriate in the light of the statutory purposes, especially supporting the exclusion of land at Whinney Fold on the basis that a combination of factors related to landscape impact, drainage, biodiversity (including impact on the Morecambe Bay designated site), and highways safety rule this site out.

Yes, I wish to participate at the oral examination

In order to express the views of residents concerned about the potential allocation of land at Whinney Fold, Silverdale from the point of view of both a resident and a qualified town planner with over 40 years' experience in local and strategic planning.

Please notify me

I have read the guidance notes

AS12 - Water quality, sewerage and sustainable drainage

The second paragraph of Policy AS12

Yes

While supporting the plan as generally sound, I consider that Policy AS12, second paragraph, is a statement of process rather than policy and that it should be strengthened.

Policy AS12, second paragraph, should be amended to read as follows:
'In areas not connected to mains drainage, development proposals that will increase drainage discharges will only be approved if the condition and capacity of the existing infrastructure is adequate or if proposed sewerage treatment plant would not have an adverse impact on the environment or landscape.'

Yes, I wish to participate at the oral examination

As a local resident and town planner with over 40 years' experience I consider that this matter should be considered in relation to its impact on a potential site at Whinney Fold which may be subject to an omission objection from developers.

I have read the guidance notes

General comment / comment on procedure

Yes

I support the proposed DPD for the Arnside & Silverdale AONB and recommend its acceptance as drafted. In particular, our support is based on the following points;

* I compliment the officers of both South Lakeland District & Lancaster City Councils and the staff of the Arnside & Silverdale AONB team on a thorough document which clearly states the national policies and land use criteria applicable to the AONB with protection of the landscape as the overriding objective,

* it selects development sites which are consistent with those policies and protects the general open character of the settlements within the AONB Landscape as well as meeting other key criteria,

* it recognises that development should only be permitted to fulfil essential local needs,

* it further states that the main essential local need is that for affordable housing,

* it sets a ratio of affordable versus market housing development which is consistent with all the relevant criteria for the AONB.

While I understand that achieving this ratio will be challenging for commercial developers and may make some sites inappropriate for commercial development, I also maintain that commercial development within the AONB is not appropriate unless it produces a very high yield of affordable housing. To do otherwise would sacrifice highly valued landscape for no benefit to meeting essential local needs.

I also understand that there are good prospects that bodies such as housing associations will step in to finance affordable housing needs.

For these reasons I recommend that the DPD should be considered “sound”.

C A Ryan

I have read the guidance notes

I have read the guidance notes

General comment / comment on procedure

Yes

Yes

I feel that the Published DPD is legally compliant and sound. Planners have listened to all interested parties.

In leaving out proposals for housing development in the village of Silverdale the plan clearly helps preserve the
character and special qualities of the landscape in this part of the AONB.

The problems caused by sewage issues and drainage in the Whinney fold site have quite properly
been recognised.

Similarly note has been taken of the very real highways issues.

I strongly support the published DPD

Please notify me

I have read the guidance notes

General comment / comment on procedure

Yes

We believe that the AONB DPD is sound because it gives proper weight to the intrinsic purposes of the AONB, which are to conserve landscape and natural beauty, and to do this through protecting wild species of flora and fauna and their habitats, indeed enhancing these where possible.

We applaud the policy of supporting local distinctiveness, visual amenity, and tranquillity, with special allowance made for openness in the settlement pattern, integrating fields with housing areas - certainly this is a notable feature of Silverdale. We are also pleased that due note has been taken of the sewerage issues in Silverdale which has no mains drainage; it would seem to us that this is a powerful argument against further development in terms of housing. More housing inevitably means more sewage to be dealt with, and here requiring high levels of householder responsibility and management, in order to protect the environment and especially Morecambe Bay.

We think it enormously important that the DPD gains legal status as soon as possible, since there are those even now seeking approval for developments that would be entirely against the values espoused in the DPD.

Yours sincerely,

Professor Malcolm Stevens OBE FRS
Mrs Valerie Stevens

Please notify me

I have read the guidance notes

General comment / comment on procedure

Yes

Yes

I support the soundness of the ANOB DPD because it reflects the statutory purpose
of the ANOB in giving great weight to conserving the landscape and natural beauty.
In particular I support:
: the reasons for preparing the DPD set out in para;1.25
: the interpretation of the NPPF in para; 1.3.6
: the objectives in para; 2.2.1
Policy AS01 Development Statergy that all development should be consistent with the
primary purposeof the AONB and support the special qualities as set out in the
Management Plan.
Paras; 3.1.3 and 3.1.4 it is not necessary for the ANOB DPD to identify specific
housing requirements.
Policy AS02 on Landscape, reference to the rural nature, visual amenity, tranquility,
sense of place and space.
Policy AS06; key settlement landscapes relating to 'bringing the country into the
settlements and and reinforcing their rural character' but consider that further locations
around Silverdale could meet that definition.
Policy AS08; on Design in particular the references in papas; 4.5.3 to visual permeability
and 4.5.23 to open areas forming an important part of Silverdale's character.
Policy AS12; on Water Quality, Sewerage and Sustainable Drainage: especially in relation to
the need for evidence in areas not connected to mains drainage.
Policy AS16; in excluding any sites from Silverdale, not because of any objection in principle
but because no sites were found to be appropriate in the light of the statutory purposes,
I especially support the exclusion of land at Whinney Fold on the basis that a combination
of factors related to landscape impact, drainage, biodiversity (including impact on the
Morecambe Bay designated site and high ways safety rule this site out.

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

Please notify me

I have read the guidance notes

General comment / comment on procedure

Yes

Yes

I support the soundness of the AONB DPD because it reflects well the statutory purpose of the AONB in giving great weight to conserving landscape and natural beauty. In particular I support:
- the reasons for preparing the DPD set out in paragraph 1.25
- the interpretation of the NPPF in paragraph 1.3.6
- the objectives in paragraph 2.2.1
- Policy AS01 Development Strategy - this is an AONB but set in a wider area which is Carnforth and its rural hinterland. Needs for the whole area need to take into account those parts of the area which have been designated as of special interest such as AONBs.
- Paragraphs 3.1.3 and 3.1.4 Meeting the needs for the area as a whole must be the right answer - as you intimated in your response to my submission during one of the earlier consultation phases. Therefore, I agree most strongly that it is not necessary for the AONB DPD to identify a specific housing requirement within the AONB.
- Policy AS12 on Water Quality, Sewerage and Sustainable Drainage, especially in relation to the need for evidence in areas not connected to mains drainage (but consider that this could contain a stronger presumption against development in such areas and not merely a statement of process as drafted). Even if developers were to argue that treatment facilities with soak aways might be able to provide a solution, it should be noted that the fields between Whinney Fold and Lindeth Road are waterlogged for much of the year. The landowners who are attempting to sell this land to developers is well aware of this as his workers refuse to drive farm vehicles onto the fields other than in the summer months. Attempting to provide a soak away in ground which is waterlogged would be a disaster for residents in any new properties and for the biodiversity in the AONB and out into Morecambe Bay to which the ground water eventually runs.
- Policy AS16 in excluding any sites from Silverdale, not because of any objection in principle but because no sites were found to be appropriate in the light of the statutory purposes, especially supporting the exclusion of land at Whinney Fold on the basis that a combination of factors related to landscape impact, drainage, biodiversity (including impact on the Morecambe Bay designated site).

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

Please notify me

I have read the guidance notes

General comment / comment on procedure

Yes

Yes

I support the soundness of the AONB DPD because it follows the underlying principle to help conserve and enhance the
landscape of the area and places the landscape at the heart of shaping development.
In particular I support:
- the reasons for preparing the DPD set out in paragraph 1.25
- the interpretation of the NPPF in paragraph 1.3.6
- the objectives in paragraph 2.2.1
- Policy AS01 Development Strategy, especially that all development should be consistent with the primary purpose of the AONB and support the Special Qualities of the AONB as set out in the Management Plan
- Paragraphs 3.1.3 and 3.1.4 in stating that it is not necessary for the AONB DPD to identify a specific housing requirement
- Policy AS02 on Landscape, especially the references to rural nature, local distinctiveness, visual amenity, tranquillity, dark skies and the sense of space and place
- Policy AS06 on Key Settlement Landscapes relating to 'bringing the country into the settlements and reinforcing their rural character' (but consider that further locations around Silverdale could meet that definition)
- Policy AS08 on Design, in particular the references in paragraphs 4.5.3 to visual permeability and 4.5.23 to open areas forming an important part of Silverdale's character
- Policy AS12 on Water Quality, Sewerage and Sustainable Drainage, especially in relation to the need for evidence in areas not connected to mains drainage.
- Policy AS16 in excluding any sites from Silverdale because no sites were found to be appropriate in the light of the statutory purposes, especially supporting the exclusion of land at Whinney Fold on the basis that a combination of factors related to landscape impact, drainage; being at the bottom of the valley this floods, biodiversity;this is an important extension of Morecambe Bay designated site for ducks and coastal birds, migratory redwings and fieldfares, plus bats, and highways safety rule this site out.

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

Please notify me

I have read the guidance notes

General comment / comment on procedure

Yes

Yes

I support the proposed plan in every respect.

Please notify me

I have read the guidance notes

General comment / comment on procedure

Yes

Yes

Local Services will not support any more development without DRASTIC improvement.
Traffic and Car parking already over safety limits - particularly on Saturday mornings - and awaiting serious
casualties/death.

I have read the guidance notes

AS18(part of A9) - Land on Hollins Lane, Arnside

Yes

No

The DPD is not effective

The plans for the new development on Hollins lane again have failed to take into account the current situation in relation to traffic use. The road is very narrow and is not only used my residents but many who use the road as a through road.

There are no passing spaces on the road which requires drivers to pull into residents private driveways to allow others to pass.

Adding more vehicles to this would cause further danger and possibility of accidents. During the construction with machinery and HGV's the current road could not manage and would be seriously dangerous for the current residents.

Using this end of the field in completely unsuitable for any development that would add to the vehicle usage.

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

Please notify me

I have read the guidance notes

General comment / comment on procedure

Yes

Yes

I firmly endorse the approval of the DPD. It is sound, legally compliant and the duty to cooperate was observed and I was able to attend the Parish Council meetings at which it was discussed and opportunities for comments were offered.

Please notify me

I have read the guidance notes

General comment / comment on procedure

Yes

Yes

The 2 Councils are to be congratulated on their joint work to bring the DPD to its current point. There has been a thorough consultation process, with evidence of incorporating policies which reflect the feedback from residents of the AONB.

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

Please notify me

I have read the guidance notes

AS21(W88) - North West of Sand Lane, Warton

This site is possibly the worst place one could consider developing in Warton for a variety of reasons; namely: flooding, access, visual amenity, ecological corridor destruction and contravention of sustainable development. I will explain why in the following paragraphs.

Though the local planning officer seemed unaware of it, there is a substantial issue of flooding at the bottom of Sand Lane (the village was cut off during the last round of flooding), that is caused by runoff from this slope exceeding drainage capacity. Due to increased precipitation in recent years, or a deviation in the subterranean watercourses of the landscape, a spring has also broken through the road in the middle of the junction between Sand Lane and Main Street/Mill Lane. Also during the last flooding event a bulge developed in the middle of the road leading to fears of the potential for a sink hole to open up, due to the typology of the landscape (the police kept the road closed until it had subsided). Building on this slope will further exacerbate this issue for two reasons. (1) Reduced infiltration (with roofs being a large point source) will cause increased surface runoff into the existing drains which are already over capacity. (2) The use of SuDS will increase input of water into the groundwater which will also increase strain on the subterranean water courses. Though no more water will be added to the surface water discharge, the way in which the water moves will be functionally changed to the detriment of existing buildings.

As one of the members of the community who was helping neighbours during the latest flooding event, I do not wish to see developers greed cause more suffering in the village. I hope the developers noted the permenant flood defences in people's doorways down-slope of the proposed development. Successful mitigation could be achieved if the drains along Main Street are upgraded. However, this would not fully solve the overall issue of flooding, which is primarily due to the way in which the land is farmed rather than excessive precipitation (I have a degree in Environmental Science and wrote my dissertation on the Water Framework Directive). The drains will still get choked and blocked with silt (a lot comes down the public footpath from higher fields) causing the existing problems to persist. Also, implementation of mitigation measures which could be secured through a CIL payment (although Lancaster City Council has no policy in regard to CIL), will most probably result in the developer arguing that they are unable to offer affordable housing as the infrastructure investment will make affordable housing unviable. This has already occured in the AONB on an ongoing development in Milhead where the developer argued that they could not build a proportion of affordable housing due to development costs, and the Council had to waste time and money to prove that they could. In short, I do not see how this issue may be mitigated, but I can see how the development will exacerbate the existing flooding issues.

Though I am not directly commenting on the other site in Warton (W130), it is also above the area of land that floods, and though it does not run off into the road, the comments regarding infiltration above the village exacerbating ground water is still applicable, as the subterranean water pathways have not been mapped; both developments will increase artesian water pressure and put vital road infrastructure at risk. I simply wish the planners had listened to the Parish Council's concerns that building up slope of the village as any development up slope will exacerbate flooding issues for the above reasons!

Access to this site will be dangerous! The access point is suggested to be just down slope of a blind summit and the main road to Silverdale. Though none of us like it, the sad reality is that people speed along Sand Lane because it is a long straight road. In an ideal world this would not be the case, but most people are realists and we should act in accordance with the world that exists, rather than a hypothetical one where nothing goes wrong. Regulations suggest that no new entry or exit points are within 100m of a corner for this reason, yet this entrance will be within 100m of a blind summit. In this point I am merely following the logic of accepted policy. I fail to see how this is different?

The impact on visual amenity is not as easy to quantify, but is still a significant issue. As we are talking about a development in an Area of Outstanding Natural Beauty, it is a salient point. Many of the residents of Sand Lane bought their houses for the view of the Crag and/or have grown up, looking at it. The vista of those visiting the AONB for tourism will be similarly disrupted as the best view of Warton Crag and the remnants of the hillfort on top (the top 'crag ledge' was part of the battlements) will be obscured as you leave Warton and though it is in keeping with the historic development style of following roads, it will make the village much bigger as you will be driving through a seemingly urban (ish) area for longer. As it stands, there are houses on one side and an outstanding view on the other, which if development were to proceed, will no longer be the case. The best driving view in Warton is on that stretch of road and that will be lost forever.

The removal of hedgerows will cause an inherent destruction of wildlife corridors that is just a matter of fact. Guidance suggests that where this can be avoided, hedgerows should be preserved. If there are sites that require hedgerow removal I would suggest that this is in contravention of that guidance. It is suggested that the destruction is mitigated through replanting of another hedgerow, but a line of saplings does not make a wildlife corridor. Also, species diversity and structure will be virtually impossible to reconstruct, as existing hedgerows contain deadwood (through historic hedge laying) which would only be naturally replaced after decades, of no hundreds, of years. There is no need for this hedgerow to be removed and thus I would suggest it should be kept in situ.

Contravention of sustainable development is a much more difficult issue to tackle, due to the non-descript definition. How does one define needs? I need a coffee in the morning? (Is this really a need, or simply a desire?). Nonetheless, I would argue that this development does not meet the needs of current generations without damaging the needs of future generations for the following reasons.
First; What does Warton need? I would argue that Warton does not need any more family houses, there are plenty already! That is not to say that people would not buy them. On the contrary, they would be snapped up by anybody with the money to do so as Warton is a desirable place to live. When I say Warton I am not talking about buildings, I am talking about the community. I have come up with my own definition of "community" in this context; here I would define "community" as, "continuity of connection over time", i.e. that community is built up over generations of shared stories and experiences, such as running the fell race and watching your grandchild do the same. I have been fortunate to watch such things happen, but as a result of the recent house price increases (both locally and nationally), I fear that the days of that happening may be gone. I have friends who grew up in the village who wanted to raise their family in the village, but were unable to do so, due to them being priced out of the market. Though the friend in question may service the community through his trade, he is unable to live here. What the community of Warton needs is affordable housing, preferably local occupancy affordable housing. We need a first rung on the ladder so that it is viable for people who were raised in the village to be able to raise their children here and keep the community alive. If not, the real fear is that Warton will just become a collection of expensive bricks and mortar. Case in point, is that there are very few people left in the village who still have a connection to local institutions such as the village sports day; so it has been left to myself, a single, childless guy, who lives with his parents, to carry it on. The last committee wanted to pass the torch to the next generation. Unfortunately there is nobody left to pass it onto. My desire is to move out of my parents house and support myself, but there is no chance I can afford house prices in the village and I would significantly struggle to buy my own house without genuinely affordable housing being provided in the village.
For that reason alone I face the real prospect of having to leave the community I grew up in.
At the start of this paragraph I said 'firstly', because I defined a distinction between the needs of current and future generations. However, whilst writing this, it has become apparent that there is no distinction in a cohesive community -but there is one adage. There is a significant lack of smaller homes for people to downsize into, thus there are many family homes in the village that are under-occupied. If there was provision for older people to downsize, this would enable them to remain in the communities they have lived in their whole lives. This would free up more family houses for growing families to move into, thereby maintaing a sustainable, inter-generational and dynamic local community Though this is not a consideration for this development, it is a point which I wish the Council had paid attention to during the consultation!
For the community to survive, we need to keep the people we have. People moving into the village with no affinity to the place, or its history, will just be another nail in the coffin of this dwindling community.

I hope that the above representation is not too lengthy and thank you for reading this far. I am more than happy to answer questions regarding any of the points made.

Yes

No

The DPD is not positively prepared

The DPD is not justified

The DPD is not effective

The DPD has not been positively prepared, in that it does not meet an objective assessment of development and infrastructure requirements. There is no mention of a provision for affordable housing, and it does not address the need for infrastructure improvements in regard to local flooding issues. This puts the village at risk from further development without a Council CIL policy which could secure necessary infrastructure improvements.

The proposed DPD is not justified as I do not believe it is the most appropriate strategy (as discussed above) - it does not give enough consideration of reasonable alternatives. Also, I would argue that the evidence base is not credible, given that the planning officer, while in the village hall, did not see that flooding would be a likely consequence from this development; spatially it functionally does!

The DPD is ineffective in that it does not take into account sound infrastructure considerations to deliver planning & drainage objectives. It could be effective if it provided more flexibility to changing circumstances (e.g. if it takes into account the consequences of storms, such as Storm Desmond, which are becoming an annual occurrence).

The other main deficiency in the preparation of the DPD is the lack of an objective assessment of sites being proposed [in Warton] for housing.

Since my original representations to the Extra Sites Consultation in Mar-May 2016, the land in our family's ownership [Proposed Site W128 - Land to the rear of 1-2 Howard Cottages] has been identified by an affordable housing developer who is interested in providing affordable homes in perpetuity for local occupancy, at around 30% below market value.

I would propose that the land at the rear of 1-2 Howard Cottages, Sand Lane, Warton (W128, in consultation) be reconsidered for development. I would like to see site W128 included in the housing allocation in the AONB DPD. The land owner is a member of the community and would like to see development that is in the best interests of the community and does not view this as a potential to make a lot of money. With this in mind it is he who has contacted a affordable housing development company in order to secure housing for the community. I must stress that the interest from this affordable housing developer is a recent development, however, it does not change my views in terms of the other sites on Sand Lane, which were highlighted during the earlier consultation period, by myself and others.

Though the council refused this site sighting distance from facilities and its distance from the village centre I would suggest that it is icluded for the following reasons:

1. The site is ready for development at any time and is supported by an affordable housing developer, who is able to start development forward as soon as possible.

2. W128 would put the first rung on the housing ladder for those raised in Warton and surrounding area in perpetuity due them being sold at 70% of market rate compared to national standards of 80% and the development will comprise 75% affordable compared to 50% (on a good day) respectively. The affordable homes would be delivered by Afordable Homes Ltd, who are about to start a comparable project in Cheshire.

3.Though W128 does extend the village this is in line with historic trends of building along the main roads while maintaining the view. The development will be screened by mature trees bordering a disused railway line which is in essence a scar on the local landscape which could be remediated through being filled in as part of the development. The site is also spacially hemmed in by a road, railway, line, arterial farm track and an existing house and garden. The geographical constraints mean that this development can never spill over and result in development encroaching over time.

4. There is a significant disparity of the number of objections the council received regarding sites W88 & W130 which have been included in the plan. Those objection generally associated the problems I have identified above with this development. The fact that these objections as well as the fact that the parish councils wisher were seemingly ignored in that both developments are up slope of the village. I do consider this decision to be contrary to the communities wishes which does not sit right with me.

Site W128 is in the communities interest due to its allocation of affordable housing but it will also:
1. Reinstate a historic dry stone wall (currently in disrepair to the north of the site)
2. Remove an over-head power line
3. Make use of a brownfield site (the wooded area is actually an old railway line that ran through the garden under the bridge)
4. Not destroy any hedgerows
5. Not detract from the visual amenity of the surrounding area, as it will be fully screened by mature woodland (other than from 1-2 Howard Cottages);
6. Make it viable for 1 and 2 Howard Cottages to connect to mains drainage, whereas they are currently on a septic tank (due to historic location between two railway lines)
7. Not make Sand Lane any less dangerous in terms of highways safety, due to clear and open access
8. Not increase the chances of flooding (either on site or elsewhere)
9. Contribute to much needed local affordable housing provision; delivering genuinely affordable housing for local people in perpetuity, at affordable prices, at least 30% below market values

I think that bringing this development forward with a proven developer would satisfy many of the concerns that the community raised during the consultation period. I feel that the concerns of the community have been under appreciated and that is why I would call on the inspector to accept this submission of a change of plan in line with the flexibility that is a fundamental part of effective policy making as identified in the AONB DPD guidance documents.

I therefore maintain my position that Site W128 should be allocated for housing development instead of W88 and, if possible W130, as Warton does not need anymore expensive executive housing. Warton needs a first rung on the housing ladder and bringing forward Site W128 would fulfil the sustainable objectives of the AONB DPD.

Yes, I wish to participate at the oral examination

I would like to participate in the oral part of the EIP, because I have a passion for the village and a keen understanding of the landscape and issues surrounding it. To anyone from Warton this plan makes no sense. Even if it is not me who personally who speak at the EIP, I would like to see a local resident represented, to put the village's case forward to the Inspector. This plan leaves our community once again open to exploitation by developers whose main objective is greed. We already have a number of monoliths to developers greed in the village - we do not need anymore. I and virtually none of the residents I have spoken to are against development per se.
We just want development that is in the community's best interest, not just for the sole benefit of the landowners and developers interests; we have to realise these are not mutually exclusive where profit is not the modus opperandi.

Please notify me

I have read the guidance notes

Site Omission

Since promoting Site W128 for residential development in the AONB DPD Extra Sites consultation [Mar-May 2016], we have received interest from a housing developer specialising in private, affordable housing, who are interested in developing the site on Sand Lane for an affordable-led, local needs based housing scheme. They are a proven developer who will develop the site in line with what I and a number of residents, who signed petitions during consultation, believe to be in the communities best interest. I actually bought the field in order to stop the development of the land and spoiling the view from my house but after watching how developers squeeze so many building on to a plot and do not deliver community value I decided to put my land forward so I could steer the development in a more progressive direction than previous ones. I will actually have to sell the land to the developer at a reduced rate, based on the value of the land with such an allocation, but I want to know that I left this village in the best state I could for my children and grandchildren.

Yes

No

The DPD is not justified

This response is written primarilly by myself (the land owner), but I have sought advice from Affordable homes as they are far more knowledgeable on these issues.

We do not believe that due consideration has been given to the assessment of potential housing sites in Warton. The level of objections against the two proposed allocations - W88 & W130 - far outweigh the objections against W128. Issues raised against these two sites are not applicable to Site W128 and bringing forward this land for affordable housing would appear to have a less detrimental impact on the village, in terms of visual impact, traffic congestion, drainage and flooding.

We resubmit Site W128 as a potential housing allocation in the AONB DPD, as there is a willing landowner and willing developer who can bring forward an affordable housing led scheme that will provide affordable housing for the people of Warton.

Despite the Council’s response that the proposed Site W128, is outside the centre of Warton and some distance from local services, we consider that the site should be reconsidered for affordable housing, for the following reasons:

•The site is immediately available for development and is supported by an affordable housing developer, who is able to fund and bring forward the land for development

•The site will provide affordable housing for local people in perpetuity - at least 75% affordable

•The site is a sustainable location, is self contained by natural boundaries, including a railway line and Sand Lane, which is screened by mature trees

•Site W128 only received a handful of objections, compared to the significant objections against both proposed allocations - W88 & W130. Both sites were questioned in terms of suitability for housing based on a number of reasons, including drainage & flood risk; traffic/access and impact on the surrounding landscape and housing

We therefore maintain our position that Site W128 be allocated for housing development.

We have also included a case study of an ongoing development pioneered by Affordable Homes.

Afordable Homes is currently progressing a planning application with Cheshire West & Cheshire planning authority which is due to be determined at the 9 January 2018 planning committee, with a recommendation for approval.

During the last 12 months, Afordable Homes has been working closely with Planning Officers and Housing Officers at Cheshire West & Chester to agree an affordable housing scheme that will be supported by the Council.

Afordable Homes Proposal - Cheshire West & Chester

The site comprises circa 1.2 acres of greenbelt land and is designated a Rural Exception Site, which allows for 100% affordable housing provided that the homes are affordable in perpetuity and are for people with a local connection to the village. A small element of open market housing is considered to be acceptable where it is demonstrated that it is commercially necessary on viability grounds, in order to deliver the affordable housing provision.

The scheme comprises 15 properties, 11 of which are affordable (75%), and 4 being open market homes (25%). The affordable homes will be 100% ownership private for sale; affordable in perpetuity; and purchasers will be required to live, work or have a family connection in the village. The homes have been priced at an affordable level enabling younger people on an an average working salary to buy an affordable home.


•An independent Housing Needs Survey was commissioned by Afordable Homes in order to prove that there is local need for affordable housing

•A presentation was made to the Parish Council to explain the proposals

•Local residents were invited to a public consultation event to view the proposals and ask the developer & planning consultant questions about the proposed development

•Many local people were in support of the proposals and local residents were given the opportunity to register their interest in buying an affordable home

•There were Expressions of Interest in all of the affordable homes, with more people registering interest than homes available

•12 comments of support were received during the consultation period, with only two objections


The proposals have attracted a lot of support as there are many young people in the village who cannot afford to buy a home on the open market, and there is a shortage of affordable housing in the village

Yes, I wish to participate at the oral examination

I feel that if I am going to state that I am doing this for the benefit of the community it is only beholden on me to come and say why I am doing it in an official capacity.

Please notify me

I have read the guidance notes

AS12 - Water quality, sewerage and sustainable drainage

Yes

Yes

As a Civil Engineer with a whole career spent dealing with sewage I feel that the DPD, while generally sound in dealing with above ground elements, is not sound in setting out requirements for sewage disposal.
The natural drainage area between Arnside Knott and Warton Crag has no public sewers and all properties have either cesspits, septic tanks or a handful of package treatment plants. Every day an estimated 300,000 litres of liquid flows into the ground - varying from crude sewage to treated effluent. This contaminates ground water which ultimately reaches the Bay. The population discharging in this area continues to grow, mainly through increases in caravan numbers.
To date, Lancaster City Council and the Environment Agency seem unconcerned about this situation. Almost all new building is allowed to proceed even though the regulations on sewage disposal are not enforced and in many cases cannot be achieved. It appears that there is a lack of understanding of the requirements.
In particular my comments on AS12 are
• Any development will overload almost all existing infrastructure which generally does not meet current standards.
• Upgrade of septic tank is a suggested option – this is not acceptable under current regulations.
• Consideration of impact due to proximity – not done now and generally not achievable. This is essential to achieve satisfactory treatment.
• The Councils must from now on enforce the points made in 4.9.2, 4.9.4 and 4.9.6.

Until steps are taken to properly deal with sewage disposal in the area and reduce ground water contamination then no further development should be allowed.

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

I have read the guidance notes

General comment / comment on procedure

Yes

Yes

The document is soundly based upon facts,wisdom and local knowledge of unbiased specialists.
It recognises the benefits of having a haven of tranquility so that current and future generations can gain the benefits from an area of outstanding natural beauty whilst setting aside possible areas for development as needs arise now and in future without compromising the environment.
We are but custodians of that which nature provides.
Thanks to all who contributed.

None

Please notify me

I have read the guidance notes

AS01 - Development Strategy

Yes

Yes

The DPD appropriately supports the statutory purpose of the AONB and will strengthen the protection of landscape and natural environments in the area. It has been drawn up after substantial local consultation and with the praiseworthy collaboration of local authorities in the two counties/districts: a worthwhile and eminently sound achievement.

I am pleased to note that the plot of land behind St John's Avenue in Silverdale is not under consideration for residential development: many local residents objected strongly and rationally to its inclusion in an earlier list. Similarly, land at Whinny Fold which is not appropriate for development has not been included. The inclusion of AS24
(S70) :Railway Goods Yard, Silverdale for "Employment and car parking" is welcome as it might alleviate drivers' fear of not being able to park to use a train: in the absence of buses in evenings or on Sundays, reliable access to car parking is essential to encourage rail use.

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

Please notify me

I have read the guidance notes

AS01 - Development Strategy

No

The DPD is not positively prepared

The DPD is not justified

The DPD is not effective

The DPD is not consistent with national policy

Applethwaite Ltd supports the identification of Silverdale as a Local Service Centre. Silverdale is a defined Sustainable Rural Settlement in the Lancaster settlement hierarchy and an identified location for rural housing growth in both the adopted Lancaster City Council Development Management DPD (Policy DM42) of December 2014, and the emerging Review of the Development Management DPD (Policy DM4) Consultation Version of January 2017. It is the principal settlement within the part of the AONB within the Lancaster City Council area.

Silverdale is a sustainable village and a suitable location for growth, and 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, public transport (bus and rail), 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 throughout the plan period as there is strong local need and market demand.

Applethwaite Ltd does not support the section of the policy titled “Development on the edge of and outside settlements.” In the absence of settlement boundaries to provide a reference point, the proposed policy wording is vague and imprecise in terms of what constitutes and defines “on the edge of settlements”. In addition, as the AONB designation applies across the whole area and no distinction in made in the Publication DPD between the acceptability of new development within, on the edge or outside a settlement, as unplanned development is
managed by reference to landscape-led capacity and not an adopted strategic housing requirement, it is not justified to treat housing development on the edge or outside settlements as “exceptions” and to include the word “only” in the text.

Applethwaite considers that the section of the policy relating to “Major Development” is unnecessary and differs to national policy at paragraph 116 of the Framework.

The paragraph related to “Development on the edge of and outside settlements” should be revised to read;
Development proposals on the edge of and outside settlements, including in hamlets and the open countryside, will be permitted where they demonstrate that:

(IV) there would be no adverse impact on settlement or landscape character; and that
(V) there is an essential need for a rural location; or
(VI) it will help to sustain an existing business, including farm diversification schemes; or
(VII) it contributes to the meeting of a proven and essential housing need in that location; or
(VIII) it represents a sensitive and appropriate reuse, redevelopment or extension of an existing building.

The paragraph related to “Major Development” should be deleted and replaced with;

Development proposals for major development will be assessed against national policy at paragraph 116 of the National Planning Policy Framework and any other relevant policies of this DPD.

Yes, I wish to participate at the oral examination

The representation raises matters and evidence that Applethwaite Ltd wishes to present to the Inspector.

Please notify me

I have read the guidance notes

3.1.3

No

The DPD is not positively prepared

The DPD is not justified

The DPD is not effective

The DPD is not consistent with national policy

3.1.3 to 3.1.7

Applethwaite Ltd considers that notwithstanding the approach taken to not apportion a figure of the overall respective OAN for South Lakeland and Lancaster to the AONB, the objectively identified affordable housing need arising within the AONB (Housing Needs Survey 2014), should be given greater weight and treated as a minimum housing requirement target. This should be rolled forward over the plan period and supplemented with sufficient open market housing to facilitate delivery, as paragraph 3.1.5 indicates and Applethwaite supports, and the DPD should take a balanced approach to make every effort to meet identified affordable
housing needs within the AONB, as far as is consistent with the policies set out in the Framework and a landscape-led capacity approach.

It is not a sound approach to identify local affordable housing needs and then not plan to meet them, acknowledging that sites outside the AONB would have to be found if sufficient suitable sites are not available within, based simply on high-level landscape capacity assessment evidence.

The objectively identified affordable housing need arising within the AONB (Housing Needs Survey 2014) should be treated as a minimum housing requirement target for the plan. This should be rolled forward over the plan period and supplemented with sufficient open market housing to facilitate delivery, and a more balanced development strategy should be proposed to accommodate a greater level of housing growth to ensure local needs can be met particularly in the Local Service Centres where they arise.

Yes, I wish to participate at the oral examination

The representation raises matters and evidence that Applethwaite Ltd wishes to present to the Inspector.

Please notify me

I have read the guidance notes

3.1.8

No

The DPD is not positively prepared

The DPD is not justified

The DPD is not effective

The DPD is not consistent with national policy

Applethwaite Ltd agrees that the DPD should ensure that new housing development is focused in the settlements which contain and offer the most services and facilities to local communities. The DPD does not do this however as the adoption of solely a landscape-led capacity approach to accommodating new development does not guarantee that the most appropriate development will take place in the most appropriate locations. For example, it is not the most appropriate outcome if local older people’s needs or key worker and young family needs arising in Silverdale, can only be met in remote locations outside the AONB. This approach may minimise landscape and visual impacts on the AONB but it will increase social and community impacts and increased travel impacts from greater car use, to the detriment of the AONB.

Applethwaite suggests that paragraph 3.1.8 is deleted or rewritten to suit, following the review and revision of the proposed DPD Development Strategy and Policy AS01.

Yes, I wish to participate at the oral examination

The representation raises matters and evidence that Applethwaite Ltd wishes to present to the Inspector.

Please notify me

I have read the guidance notes

AS03 - Housing Provision

No

The DPD is not positively prepared

The DPD is not justified

The DPD is not effective

The DPD is not consistent with national policy

Applethwaite Ltd considers the policy is unsound as it is currently written as it fails to set out the types of local housing needs arising in the AONB that the DPD should ensure are met. These include homes for young and growing families that want to remain within the AONB, homes for key workers employed in essential local services and facilities like schools, care homes, police and emergency services within the AONB, homes for older and retired people that want to downsize to smaller houses and especially bungalows and release larger
stock, and homes for specialist needs including assisted living and care provision.

The policy is also unsound as it does not recognise the point acknowledged at paragraph 3.1.5 of the Publication DPD, that affordable housing, and especially at a target level of 50% on small sites, cannot be delivered without subsidy from a sufficient supply of market housing. This is a fundamental omission from the policy.

The policy should set out the types of local housing needs arising in the AONB and it should make clear, with cross reference to paragraph 3.1.5, that expected levels of affordable housing delivery of at least 50% for all sites regardless of size, will be subsidised by a sufficient number and type of market houses.

Yes, I wish to participate at the oral examination

The representation raises matters and evidence that Applethwaite Ltd wishes to present to the Inspector.

Please notify me

I have read the guidance notes

AS15 - Housing Allocations

No

The DPD is not positively prepared

The DPD is not justified

The DPD is not effective

The DPD is not consistent with national policy

Applethwaite Ltd has an interest in 0.76 ha of land to the south of Whinney Fold at Silverdale
(including Omission Site S56) as shown edged red on the attached plan [SEE ATTACHED], and control as necessary, over the adjacent blue land.

Silverdale is identified as a Local Service Centre in the AONB in Policy AS01 - Development Strategy of the Publication DPD. It is a defined Sustainable Rural Settlement in the Lancaster settlement hierarchy and an identified location for rural housing growth in both the adopted Lancaster City Council Development Management DPD (Policy DM42) of December 2014, and the emerging Review of the Development Management DPD (Policy DM4) Consultation Version of January 2017. It is the principal settlement within the part of the AONB within the Lancaster City Council area.

Silverdale is a sustainable village and a suitable location for growth, and 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, public transport (bus and rail), 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 throughout the plan period as there is strong local need and
market demand.

The Publication DPD does not propose to allocate any housing sites in Silverdale. This means local market and affordable housing needs will not be met where they arise and local households will not be able to continue living in the village. This will result in a declining population and falling demand for the village school, shops, local businesses and community services. The result will be an ageing and unsustainable local community.

The DPD evidence base report “Housing Needs Survey Report – May / June 2014” confirms that 30% of all affordable housing needs in the AONB arise in Silverdale Parish, compared to 23% in Beetham, 22% in Arnside, 16% in Warton and 9% in Yealand Conyers and Yealand Redmayne combined.

The affordable housing need in Silverdale is for a mix of smaller and newly forming households (50%), larger family homes (25%) and housing for older people wanting to downsize to bungalows and/or needing specialist sheltered / assisted living accommodation (25%). This scale and pattern of need is likely to increase over the DPD plan period if sufficient new affordable and market housing is not provided, and a sufficient amount and type of market housing will be required to help facilitate its delivery as supply reduces and land values increase. There is clearly an objectively assessed need for affordable and market homes in Silverdale Parish and it is a fundamental flaw of the Publication DPD not to allocate land in Silverdale. Silverdale is the most sustainable settlement in the AONB and has the largest identified and objectively assessed housing need, and the DPD must make every effort to meet this need. A blanket approach of only meeting needs according to landscape capacity is not sustainable for these reasons and exceptional circumstances clearly exist to justify a better balance of meeting development needs whilst protecting the AONB landscape as a whole.

The land identified by Applethwaite, which includes Omission Site S56, is suitable for moderate housing development and especially bungalows. It comprises developable agricultural land immediately adjoining residential development in the southern part of the village, and does not contain any important features and has no technical, environmental, infrastructure and ownership constraints. The land is well contained and enclosed by hedging, trees and woodland. Development will not adversely impact the amenities of adjacent property; it will not affect the setting or significance of any designated heritage assets; the site is not ecologically sensitive in terms of protected habitat or species; it does not flood and can be provided with suitable infrastructure and surface and foul drainage; the land is not contaminated; development will not have a significant adverse impact upon landscape character, landscape features and visual amenity and the special landscape value and scenic beauty of the AONB.

The site is provided with direct vehicular access from Shore Road and is within 450m walking and cycling distance of the village centre and local amenities and local bus stops providing direct services to Carnforth and Lancaster. There is also a bus connection to Silverdale Railway Station which lies just outside the village.

The site is therefore a suitable, sustainable and appropriate location for new housing development. It is available and deliverable and it can be brought forward in the short term making a valuable contribution to the 5 year affordable and market housing land supply within the AONB. The land has capacity for a mix of up to 20 no. market and affordable bungalows and/or houses.

The site has been promoted previously and although Applethwaite considers the whole site can be acceptably developed without harming the landscape beauty of the AONB, as comprehensive landscape mitigation can be provided within the blue land in its control, the first iterations of the DPD and evidence base (SHLAA), identified the site as being suitable for development and proposed to allocate it for 6 no. dwellings. The draft allocation has been removed from the Publication DPD, leaving the most sustainable settlement in the Lancaster area of the AONB without any planned housing development over the plan period, with little explanation and without compelling justification.

The sole explanation given for why Site S56 has been deleted from the Publication DPD is at paragraphs 5.3.5 and 5.3.6 of the October 2017 Sustainability Appraisal Report. These state;

5.3.5 All sites excluded by that point were considered not to represent ‘reasonable alternatives’ for the purposes of SA and as such, only those sites remaining after these assessments were subject to SA.

5.3.6 However, two sites were subject to SA but are not allocated for development in the AONB DPD. These are S50 St John's Avenue, Silverdale and S56 South of Whinney Fold, Silverdale. The site assessment matrices for these two sites are provided in Appendix H. Taking into account the findings of the site assessment, the HRA and SA results and the public and stakeholder consultation, it was decided that these sites, whilst not ruled out by any single stage in the process described above, raised a range of issues that cumulatively would have unacceptable impacts on the AONB and its communities.

Removing Site S56 on the weak and unexplained basis that it “raised a range of issues that cumulatively would have unacceptable impacts on the AONB and its communities” is unaccountable and is not sound justification to leave Silverdale without any planned housing allocation site/s to meet its affordable and market needs within the plan period. An allocation is necessary as a policy approach relying on planning applications to deliver new housing in Silverdale, is unlikely to deliver new homes as the DPD does not propose a threshold or criteria to define ‘major development’ and applications are therefore unlikely to succeed when assessed against paragraph 116 of the Framework.

The proposed DPD therefore does not provide any certainty that housing needs will be met in Silverdale during the plan period and it is not positively prepared on that basis. As the first AONB DPD of its kind in England, it is essential that it delivers the best available outcome for all, and balances the protection and sustainability of the rural communities and local economies within the AONB, with environmental and landscape protection. The overall approach and soundness of the DPD to planned new housing delivery is key in this respect.

The proposed DPD should positively allocate land for new affordable and market housing development at Silverdale. The 0.76 ha of land identified by Applethwaite Ltd south of Whinney Fold, Silverdale, incorporating Omission Site S56 and including control over the adjacent blue land to the south and east to provide landscape mitigation, should be included in Policy AS15 as a Housing Allocation for an estimated number of 20 dwellings including, or solely comprising, bungalows. This is consistent with the scale of allocations in Arnside and Warton where identified affordable housing needs are similar, albeit slightly lower, to Silverdale.

Yes, I wish to participate at the oral examination

The representation raises matters and evidence that Applethwaite Ltd wishes to present to the Inspector.

Please notify me

I have read the guidance notes

General comment / comment on procedure

Yes

Yes

The comments below explain in more detail the main reasons why we consider the DPD to be sound, firstly overall and then in relation to certain policy matters.

Positively prepared
The DPD is positively prepared and seeks to find an appropriate balance in terms of contributing to meeting local needs in the context of a highly sensitive nationally designated landscape located in a small part of two wider districts. Positive engagement with the AONB Partnership and local communities has been undertaken throughout the process.

Justified
The strategy taken within the AONB DPD is justified because of the area’s national landscape importance and many other significances. We consider the landscape capacity-led approach to development to be fundamental to this.
The Arnside & Silverdale AONB Landscape and Seascape Character Assessment (2015) assesses all of the Landscape and Seascape Character Types that occur within the AONB as being of a ‘high’ or ‘very high’ level of inherent sensitivity with 'very limited' capacity to accommodate change without compromising key characteristics.

The landscape capacity-led approach is justified because only by putting the primary purpose of designation at the heart of the planning strategy can an appropriate and sustainable development management approach be achieved which results in positive outcomes for the landscape. As the DPD makes clear, the special character of the area requires a different approach to local planning to that outside nationally important landscapes (1.2.5 III) and the AONB Management Plan is a material consideration in planning decisions (1.3.15).

Independent landscape, biodiversity and viability assessments provide clear evidence underpinning and supporting the DPD’s approach. The landscape assessments have been prepared by an independent appropriately-qualified landscape professional using a consistent methodology. This provides a robust and credible evidence base that fully justifies the approach taken.

The policies and land allocations encourage appropriate development while supporting the AONB designation and purpose. The special qualities of the area that contribute to its national importance are well referenced and explained, and respected, throughout the DPD document.

Public consultation has demonstrated good engagement with the process and overall strong support from local communities, who care deeply about the landscape and special qualities of the area.

Effective
We are confident that the DPD will be effective. We welcome the close collaboration that has been employed throughout the process by SLDC and LCC. I confirm that the Councils have cooperated with Arnside & Silverdale AONB Partnership under the Duty to Cooperate in the preparation of the DPD. This is an exemplar for joint working on the cross-boundary long-term strategic priority of conserving and enhancing the AONB. Once the DPD is adopted, the same planning policies will apply across the AONB for the first time enabling the local authorities to effectively and consistently deliver their statutory duties in relation to the AONB.

Viability evidence shows that the DPD is deliverable over its period. The Councils have worked with land owners to ensure that allocated sites are available and feasible to develop.

The various policies provide a framework for dealing with a range of different scenarios in a consistent way and as such is flexible to changing circumstances, offering a robust approach to carry forward into the future.

Consistent with national policy
We consider that the DPD is consistent with national policy relating to AONBs, namely National Planning Policy Framework (NPPF) Paragraphs 115 and 116.

The DPD also appropriately articulates the approach to sustainable development to be taken within the designated AONB, consistent with Paragraph 14 and Footnote 9.

Policy matters
We support all the policies in the DPD and consider them to be justified in the context of the AONB and consistent with NPPF 115, 116, other relevant NPPF policies and the statutory AONB Management Plan.

We wish to emphasise the following policy matters as essential to the soundness of the DPD:

AS01 - Development Strategy
We strongly support that great weight will be given to the principle of conserving landscape and natural beauty, wildlife and cultural heritage in the AONB, and that all development in the AONB should be sustainable and consistent with the primary purpose of AONB designation and support the Special Qualities of the AONB. This is fully justified in the context of the AONB and is consistent with NPPF 115 and the statutory AONB Management Plan.
We strongly support the approach to be taken to major development within the AONB and the requirement for consideration of the local context and scale, form, character and nature of development. This is justified in the context of the AONB and consistent with NPPF 116 and the statutory AONB Management Plan.

AS02 – Landscape
We strongly support the detail provided in this policy on what needs to be taken into account in order to conserve and enhance the AONB. It will ensure that development does not harm and in fact contributes positively to the landscape and visual amenity of the area. This approach is justified in the context of the AONB and consistent with NPPF 115 and the statutory AONB Management Plan.

AS03 - Housing Provision
We support the policy of requiring new developments to provide at least 50% affordable housing, and for all new housing to ‘closely reflect identified local needs’ in accordance with current AONB housing needs evidence, because this will ensure that sites that are appropriate for development are used to help meet evidenced local needs arising within the area, while still remaining viable and deliverable. Considering the sensitivity of the landscape and the limited number of appropriate development sites available, it is critical to ensure that this happens. Otherwise the need for affordable and local needs housing will remain. This approach is justified in the context of the AONB and consistent with NPPF 115 and the statutory AONB Management Plan.

AS04 - Natural Environment
The high quality of the natural environment is an essential part of the natural beauty and landscape of the AONB. This policy acknowledges the importance and the contribution of biodiversity (in terms of both habitats and species) and trees and woodland to the natural beauty of the area. The policy covers the wide range of important natural environment aspects in the AONB and we strongly support the detailed approach taken in policy to conserving and enhancing these assets.
We welcome the inclusion of reference to ecosystem services provided by the natural environment of the AONB and acknowledgement in the DPD that these public benefits provide a strong case for protecting and enhancing the natural environment. This approach is justified in the context of the AONB and consistent with NPPF 115 and 109, and the statutory AONB Management Plan.

AS06 - Key Settlement Landscapes
This policy protects sites within settlements and their characteristics, particularly open green spaces reflecting the rural character, that make an important contribution to landscape and settlement character and natural/scenic beauty. This approach will help to conserve both the distinctive settlement characters in the AONB, one of the area’s special qualities, and the natural beauty and landscape character of the area overall. Landscape assessments provide strong and robust evidence to support this policy approach.
We strongly support the inclusion of the Key Settlement Landscape policy; the approach is justified in the context of the AONB and consistent with NPPF 115 and the statutory AONB Management Plan.

AS07 – Historic Environment
This policy will support conservation of the wide range of local heritage assets important to the area’s rich sense of history, one of the special qualities of the AONB. The policy acknowledges and supports conservation of the historic landscape character of the area, a key element of the natural /scenic beauty. We strongly support this policy; the approach is justified in the context of the AONB and consistent with NPPF 115 and the statutory AONB Management Plan.

AS08 - Design
This policy provides the detail required to ensure that new development makes a positive contribution to the AONB’s special character through appropriate design. We strongly support the inclusion of this policy; the approach is justified in the context of the AONB and consistent with NPPF 115 and the statutory AONB Management Plan.

AS11 – Camping, Caravan and Visitor Accommodation
This policy addresses an issue of particular local relevance to Arnside & Silverdale AONB where large numbers of static and touring caravans are already present. Existing and cumulative impacts of caravan development are such that the continuation of a restrictive policy approach to further caravan development is justified in order to avoid harm to the landscape and tranquillity of the AONB and not exceed the capacity of the surrounding road system of narrow rural lanes. The evidence collated clearly illustrates the existing supply of visitor accommodation in the AONB and supports the policy approach of restricting caravan development while encouraging other forms of appropriate small scale low impact visitor accommodation.
We strongly support this policy; the approach is justified in the context of the AONB and consistent with NPPF 115 and the statutory AONB Management Plan.

Yes, I wish to participate at the oral examination

As a key partner involved in the preparation of the DPD we would like to briefly express our support for the approach.

Please notify me

I have read the guidance notes

5.2.1

No

The process of community engagement for the DPD is not in general accordance with the councils' Statements of Community Involvement

The councils have not followed the 'Duty to Cooperate' requirements set out in Section 110 of the Localism Act 2011

No

The DPD is not justified

The DPD is not effective

Arnside Parish Council believes that the designation of area A15/16 should be included in the housing allocations forming policy AS15. The decision was based on inaccurate/ false information that the land is woodland, has historic value and is public access land. Also that the authority it has not shown due regard for the evidence presented or the opinions of consultees. The documentation used for the designation of the site was inaccurate this was highlighted by APC at the outset. It has not been used for village fairs/fetes or any other communal use since the purchase of the memorial Playing Fields in 1947. It is not designated on the Historic Environment Record.
Its current use is as grazing land that backs on to Redhills Road not woodland - the properties on that side of the field have all benefitted from mains sewerage put in by the current owner when planning permission to develop the site was granted circa 1973.
The Landscape and Visual Field Survey carried out suggests that it would be detrimental to the Character of the AONB only if the whole site is developed but does allow for a small amount of development as suggested by Arnside Parish Council during consultation without a detrimental effect
“Landscape and Visual Field Survey Sheet Project Name: Lancaster City Council SHLAA Sites (AONB). Project Number: UA001453. Receptor Ref: Site A15, Red Hills Road, Arnside (Development / Open space) Date of Survey: 07/03/2016…. Surveyor: R Kitch Arcadis Ltd Page 5 Landscape and Visual Field Survey Sheets Recommendations There is the potential for open space use on Site a15 with some associated small scale single story vernacular building and associated landscape proposals within the north west corner of the site. The open, undeveloped remainder of the site should be retained to contribute to the urban / pasture farmland mosaic character. The nature of Site A15 is considered to have the capacity to accommodate a vernacular style building with appropriate landscape proposals without resulting in harm to the character and visual amenity of the AONB.”
It is therefore not a justified decision when the evidence and alternatives are considered. Other sites Hollins Lane AS18 has been split to allow a small area for development without the detriment caused by developing the whole area.

The inclusion of a small amount of development in this area would increase the number of houses available to enable the DPD to meet its duty to meet the objectively assessed needs for the AONB and therefore become effective. It also considers evidence and comparative treatment with alternatives to ensure the plan is justified.

Yes, I wish to participate at the oral examination

In order to make sure that the information concerning this site is accurate and fairly assessed.

Please notify me

I have read the guidance notes

General comment / comment on procedure

Yes

Yes

The Trust supports the proposed DPD for the Arnside & Silverdale AONB and recommend its acceptance as drafted. In particular, our support is based on the following points;

* We compliment the officers of both South Lakeland District & Lancaster City Councils and the staff of the Arnside & Silverdale AONB team on a thorough document which clearly states the national policies and land use criteria applicable to the AONB with protection of the landscape as the overriding objective,

* it selects development sites which are consistent with those policies and protects the general open character of the settlements within the AONB Landscape as well as meeting other key criteria,

*it recognises that development should only be permitted to fulfil essential local needs,

* it further states that the main essential local need is that for affordable housing,

* it sets a ratio of affordable versus market housing development which is consistent with all the relevant criteria for the AONB.

While we understand that achieving this ratio will be challenging for commercial developers and may make some sites inappropriate for commercial development, I/we also maintain that commercial development within the AONB is not appropriate unless it produces a very high yield of affordable housing. To do otherwise would sacrifice highly valued landscape for no benefit to meeting essential local needs.

For these reasons, we recommend that the DPD should be considered sound and legally compliant.

Best regards,

Pete McSweeney

Chairman – Arnside Parish Plan Trust.

Please notify me

I have read the guidance notes

AS03 - Housing Provision

Yes

Yes

Please notify me

I have read the guidance notes

General comment / comment on procedure

Yes

Yes

For your information, please note that Beetham Parish Council fully support the latest plan from AONB.

John Scargill, Clerk to Beetham PC

Please notify me

I have read the guidance notes

General comment / comment on procedure

Yes

Yes

Please notify me

I have read the guidance notes

AS02 - Landscape

Yes

No

The DPD is not justified

The DPD is not consistent with national policy

On behalf of our client, Bourne Leisure Ltd., please find below representations in response to South Lakeland District Council’s consultations on the Arnside & Silverdale AONB Development Plan Publication Document.

By way of background to these representations, Bourne Leisure operates Lakeland Leisure Park which is located to the south of Flookburgh.

This letter supplements completed representation forms on both consultations and demonstrates that a number of policies are considered at present to be unsound in the context of the tests that are set out in the National Planning Policy Framework [the Framework].

The Framework [§182] states that to be sound, a plan must meet the following tests:

- Positively Prepared: the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development.

- Justified: the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence.

- Effective: the plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities.

- Consistent with National Policy: the plan should enable the delivery of sustainable development in accordance with the policies in the Framework.

Policy AS02

Bourne Leisure endorses the Council’s overall approach to the conservation and enhancement of the landscape and natural beauty of the Arnside & Silverdale AONB. Whilst policy AS02 as stated refers to sites within the AONB, Bourne Leisure considers that explicit clarification that for sites falling within the setting of the AONB rather than being within it, it may be possible and appropriate to mitigate against any harmful impact, whether that be through design, screening or other means.
It is therefore considered that this policy is unsound as it fails to meet the tests requiring the plan to be: positively prepared; justified; and, consistent with national policy. It also needs to be consistent with the suggested approach to be taken in the Council’s Development Management DPD’s policies, including DM1 and 18.

It is therefore suggested that the following clause be added to the policy as drafted:

“(VII) demonstrate that any identified harm can and will be mitigated against in such a way that meets the requirements and limitations of clauses (I) through (V) above.”

Yes, I wish to participate at the oral examination

In order to fully state our case.

Please notify me

I have read the guidance notes

AS03 - Housing Provision

Yes

No

The DPD is not justified

The DPD is not effective

The DPD is not consistent with national policy

The Policy is not justified, effective or compliant with national planning policy guidance.

The Housing Allocations in Policy AS15 comprise sites of between 0.1ha and 0.56ha intended to accommodate between 6 and 12 dwellings.

Policy AS03 indicates that the affordable housing requirement Is for no less than 50% with the caveat that where this is demonstrably unachievable a lower percentage will be acceptable.

The initial viability appraisal (October 2016) considered that 50% affordable housing would not be viable. A later viability study, completed in September 2017, considered that such a level of provision was viable. There are concerns regarding the viability assumptions to justify 50% affordable housing.

There are both market housing and affordable housing needs in the AONB but a requirement for a particularly high affordable housing may jeopardise the delivery of affordable housing.

Planning Practice Guidance indicates that contributions should not be sought for developments of 10 units or less, and which have a maximum combined gross floorspace of no more than 1,000 square metres (gross internal area). This threshold, is likely to be applicable to 5 out of 6 of the housing allocations.

Planning Practice Guidance indicates that in designated rural areas, local planning authorities may choose to apply a lower threshold of 5-units or less. Neither planning authority has made a decision to apply lower affordable housing thresholds, but if they did then for any scheme of between 6 and 10 dwellings affordable housing should be in the form of cash payments which are commuted until after completion of units within the development.

The policy indicates that the delivery of affordable housing should be phased to ensure the market is not over supplied at any one time. As any affordable housing is most likely to be delivered on sites with market housing, the implication is that planning permissions for individual sites will be phased. This is not appropriate and does not assist individual landowners in brining forward housing developments. If there is no demand for affordable housing at any one time then there can be no justification for requiring it on a particular site.

Delete second sentence from first paragraph - "Proposals for new housing...50% affordable housing."
Replace with "For housing developments of over 10 dwellings, 35% affordable housing will be required. For housing developments of 6-10 dwellings, with a maximum combined gross floorspace of no more than 1,000 square metres (gross internal area) a contribution towards off-site affordable housing shall be made in the form of cash payments which are commuted until after completion of units within the development."

Insert additional paragraph that states:-
"A lower requirement for affordable housing provision will be acceptable where there is evidence that full provision would make the development unviable."

Delete last paragraph - "Affordable housing needs are forecast...Registered Providers of affordable housing."

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

Please notify me

AS11 - Camping, caravan and Visitor Accommodation

Yes

No

The DPD is not positively prepared

The DPD is not consistent with national policy

I am writing on behalf of Holgates Caravan Parks who have significant facilities within the Arnside & Silverdale AONB and at Far Arnside in particular.

My client's two key business interests are a camping and caravan site at Hollins Farm and also the larger Holgates site on Cove Road at Silverdale. Both are significant facilities within the AONB and both have been subject to considerable investment in recent years, including
additions to the accommodation at the site as well as a new swimming pool, alterations to the reception and the addition of a bowling alley. A new toilet block has also been constructed at the Hollins Farm site. All of the work has been carried out in a sympathetic manner and has added significantly to the economic and employment opportunities within the AONB. The swimming pool facility in particular is much used by local people as well as visitors to the site.

I would point out that my client is one of the largest employers within the AONB, employing approximately 160 full and part time staff.

My client has recently won a David Bellamy Gold Award because of the amount of work he has carried out in terms of planting trees and hedgerows in the area. My client is one of only 3 caravan parks in the whole of the UK to receive such an award.

Paragraph 4.8.1 openly acknowledges that the DPD takes a restrictive approach to new development.

The policy itself considers development proposals for new caravan, chalet, cabin or lodge style developments will not be permitted in order to conserve the landscape character and natural beauty of the AONB.

It is argued that this policy is too restrictive and that each case should be dealt with on its own merits. We consider that there is a lack of soundness in the plan in that it does not respond to the NPPF paragraph 28, which points out that planning policies should support economic growth in rural areas in order to create jobs and prosperity by taking a positive approach to sustainable new development. An emphasis is placed on a strong rural economy.

The third bullet point under paragraph 28 of the NPPF considers that:
Plans should:
- Support sustainable rural tourism and leisure developments that benefit businesses in rural areas, communities and visitors which respect the character of the countryside. This should include supporting the provision and expansion of tourist and visitor facilities in appropriate locations where identified needs are not being met by existing facilities in Rural Service Centres.

In light of the above we feel that the Plan does not comply with this bullet point in particular. The sensitive landscape of the AONB is recognised but in our view the policy is too restrictive.

The policy is restrictive towards the use of land for static caravans because of their unsuitable appearance within the protected landscape. However, existing sites do exist and it is considered that the redevelopment of those sites should be considered on their merits on a case by case basis and it is considered that there are ample landscape and environmental protection policies elsewhere within the DPD as a whole to ensure that unacceptable schemes are rejected.

In terms of modification to the policy it is argued that the policy should state that new caravans, chalet, cabin or lodge style development will only be permitted within the approved boundaries of an existing caravan or camping site where it involves the redevelopment of previously developed land.

The AONB has the same level of protection under the NPPF as a National Park and the nearby Lake District National Park runs a policy where new static caravan and camping sites are not acceptable and neither are extensions to them. However, the redevelopment and reconfiguration of existing sites, including additional caravans or chalets, is acceptable.
We do not see why the policy within the AONB should be more restrictive than that in a National Park which has the same restrictions under paragraph 116 of the NPPF.

At paragraph 4.86 the Council appear to welcome low impact visitor accommodation and the point we have been making with the Council is that increasingly visitors are looking for quirky and innovative forms of accommodation. However, the fact that this excludes chalets, cabins and lodges is of concern as the design of such accommodation can be some of the most interesting around. I attach, for instance, some images of the Lazy Duck Hostel located in the Cairngorms National Park where a range of innovative accommodation has been provided and which has actually won a design award with the Park Authority. We would consider that the ability to provide such accommodation within the existing approved boundaries of camping and caravan sites or on brownfield land within the AONB needs to be accepted as part of the policy.

In terms of the issue of brownfield development we are currently running an appeal for the replacement of the former Leeds Children’s Camp building opposite my client’s existing operation, for redevelopment for static caravans. The application was recommended for approval by Planning Officers but rejected by Planning Committee. This is an example where previously developed land can be redeveloped for the benefit of economic purposes to provide tourism income and also to protect the landscape as over 1,000 trees are to be planted as part of this proposal.

As set out above there are ample landscape and natural environment protection policies contained within the remainder of the DPD to make sure that inappropriate schemes are rejected.

We would suggest that the policy allows for redevelopment and additions within the approved boundaries of a site and also for addition on previously developed land or, where appropriate, new sites on previously developed land.

Attachment:
Images of the Lazy Duck Hostel in the Cairngorms National Park. (See attached).

Yes, I wish to participate at the oral examination

To ensure that the plan provides for economic activity within the AONB in line with the NPPF.

Please notify me

Site Omission

Y101 Yealand Redmayne

Yes

No

The DPD is not positively prepared

The DPD is not effective

The DPD is not consistent with national policy

Site: Y101 and Y102 – Silverdale Road, Yealand Redmayne
Mr Miles Proudlove and Mr Michael Holgate
Arnside Silverdale AONB Development Plan Document Publication Version Consultation Response

I am writing on behalf of my clients who between them own sites that were referenced as Y101 and Y102 in the draft Development Plan Document Allocation and Background Papers.

It is noted that the sites have not been taken forward for housing particularly because of concerns about landscape.

As far as I am aware only 9 sites are being taken forward through the process out of 130 submitted.

Policy AS01, Development Strategy, in effect breaks down two categories of development to Local Service Centres and development at small villages. However, with regard to Yealand Redmayne there is reference to development being limited to conversion of buildings, reuse of brownfield land or regeneration opportunities. We feel that this does not go far enough given the limited number of sites put forward and the limited number of dwellings proposed. We have rehearsed elsewhere the arguments regarding viability and affordability and feel that the low number of sites put forward, taken together with their size, raises serious concerns about whether the aspirations of the Plan can be delivered.

Despite the approach of policy AS01, Yealand Redmayne is a specific settlement and will continue to function in tandem with Yealand Conyers and we are aware that the public house has now reopened as a community business. For the Yealands to be sustainable and thriving moving forward it is considered that some level of allocation should be provided. Again, arguments have been rehearsed elsewhere relating to the age of the population and the need for a supply of housing for younger people to ensure that communities can continue to function in a viable manner and retain and foster services such as public houses.

In any decision about an allocation or a planning application balance must be struck between the effects on the natural environment and the effects of not allocating or granting housing within a community, and in this instance we feel that the balance has tipped away from the Yealands being able to be considered as vibrant local communities.

I attach the relevant maps for sites Y101 and Y102.

In terms of policy AS01, Development Strategy, the reference to development on the edge and outside of settlements is welcomed because it is considered that the site has the potential to comply with this generic policy. Given the small scale of allocations we would consider that sites Y101 and Y102 should be allocated to provide a small and sustainable development at Yealand Redmayne to assist in continuing to foster the services that both Yealand Redmayne and Yealand Conyers contain.

Yes, I wish to participate at the oral examination

Site Omission

Y102 Yealand Redmayne

Yes

No

The DPD is not positively prepared

The DPD is not effective

The DPD is not consistent with national policy

Site: Y101 and Y102 – Silverdale Road, Yealand Redmayne
Mr Miles Proudlove and Mr Michael Holgate
Arnside Silverdale AONB Development Plan Document Publication Version Consultation Response

I am writing on behalf of my clients who between them own sites that were referenced as Y101 and Y102 in the draft Development Plan Document Allocation and Background Papers.

It is noted that the sites have not been taken forward for housing particularly because of concerns about landscape.

As far as I am aware only 9 sites are being taken forward through the process out of 130 submitted.

Policy AS01, Development Strategy, in effect breaks down two categories of development to Local Service Centres and development at small villages. However, with regard to Yealand Redmayne there is reference to development being limited to conversion of buildings, reuse of brownfield land or regeneration opportunities. We feel that this does not go far enough given the limited number of sites put forward and the limited number of dwellings proposed. We have rehearsed elsewhere the arguments regarding viability and affordability and feel that the low number of sites put forward, taken together with their size, raises serious concerns about whether the aspirations of the Plan can be delivered.

Despite the approach of policy AS01, Yealand Redmayne is a specific settlement and will continue to function in tandem with Yealand Conyers and we are aware that the public house has now reopened as a community business. For the Yealands to be sustainable and thriving moving forward it is considered that some level of allocation should be provided. Again, arguments have been rehearsed elsewhere relating to the age of the population and the need for a supply of housing for younger people to ensure that communities can continue to function in a viable manner and retain and foster services such as public houses.

In any decision about an allocation or a planning application balance must be struck between the effects on the natural environment and the effects of not allocating or granting housing within a community, and in this instance we feel that the balance has tipped away from the Yealands being able to be considered as vibrant local communities.

I attach the relevant maps for sites Y101 and Y102.

In terms of policy AS01, Development Strategy, the reference to development on the edge and outside of settlements is welcomed because it is considered that the site has the potential to comply with this generic policy. Given the small scale of allocations we would consider that sites Y101 and Y102 should be allocated to provide a small and sustainable development at Yealand Redmayne to assist in continuing to foster the services that both Yealand Redmayne and Yealand Conyers contain.

Yes, I wish to participate at the oral examination

AS01 - Development Strategy

Yes

No

The DPD is not positively prepared

The DPD is not effective

The DPD is not consistent with national policy

Policy AS01, Development Strategy, in effect breaks down two categories of development to Local Service Centres and development at small villages. However, with regard to Yealand Redmayne there is reference to development being limited to conversion of buildings, reuse of brownfield land or regeneration opportunities. We feel that this does not go far enough given the limited number of sites put forward and the limited number of dwellings proposed. We have rehearsed elsewhere the arguments regarding viability and affordability and feel that the low number of sites put forward, taken together with their size, raises serious concerns about whether the aspirations of the Plan can be delivered.

Despite the approach of policy AS01, Yealand Redmayne is a specific settlement and will continue to function in tandem with Yealand Conyers and we are aware that the public house has now reopened as a community business. For the Yealands to be sustainable and thriving moving forward it is considered that some level of allocation should be provided. Again, arguments have been rehearsed elsewhere relating to the age of the population and the need for a supply of housing for younger people to ensure that communities can continue to function in a viable manner and retain and foster services such as public houses.

In any decision about an allocation or a planning application balance must be struck between the effects on the natural environment and the effects of not allocating or granting housing within a community, and in this instance we feel that the balance has tipped away from the Yealands being able to be considered as vibrant local communities.

In terms of policy AS01, Development Strategy, the reference to development on the edge and outside of settlements is welcomed because it is considered that the site has the potential to comply with this generic policy. Given the small scale of allocations we would consider that sites Y101 and Y102 should be allocated to provide a small and sustainable development at Yealand Redmayne to assist in continuing to foster the services that both Yealand Redmayne and Yealand Conyers contain.

Yes, I wish to participate at the oral examination

Site Omission

Site Omission A7

Yes

No

The DPD is not positively prepared

The DPD is not effective

The DPD is not consistent with national policy

I am writing on behalf of my client, Mr Donoghue, who owns land at High Close, Arnside which was put forward for residential development under the AONB Call for Sites, and was registered as Site A7.

It is noted that the site has not been taken forward for housing because it is not considered to meet the criteria set out for sites to be sustainable, and that there are also concerns with regard to landscape and the proximity of the site to Arnside Knott.

In response to this we would point out that a number of sites on Knott Lane have received planning permission for dwellings in recent years, identifying that the area, including my client's site, could be considered to be part of the settlement of Arnside. Indeed, we
understand that some encouragement has been given to a proposal for a dwelling very close to this site.

I would specifically wish to comment on policy AS03, Housing Provision. It is welcomed that the development strategy AS01 accepts Arnside as a Local Service Centre, as it is bound to do under the provisions of the Core Strategy identifying it as such.

You will be aware that I have made other representations on behalf of other clients with regard to the limited size of the AONB and the relatively high population.

This brings a situation about whereby, to maintain the viability of the population and to make sure that the Arnside & Silverdale AONB as a thriving area from an aspect of human occupation, then there must be room for some growth.

The area hosts a population that is skewed towards older age groups with over 40% of the population being over 65. This is compared to a 17.7% UK average in 2014. Because of this a greater number of allocations have to be made to ensure that Arnside is sustainable in terms of population.

We have been looking at what is a proposal of 3 or 4 houses on this site but, as you will know from my previous correspondence, the allocation of the site would also enable development to come forward that would give a 4 acre woodland to the village or, potentially, the local wildlife trust.
Again, as was seen from the earlier representation, we view that an exemplar development could be brought forward on this site that would have both landscape and ecological benefits, rather than being viewed as being in conflict with it. The considerable grounds of High Close would allow for much additional enhancement both from a landscape and ecological perspective.

Given the extremely limited number of allocated sites for Arnside we are of the view that in the Plan the intention of policy AS01 and AS03 mean that Arnside does not fulfil its role as a Local Service Centre, as required by the Core Strategy.

With direct reference to policy AS03 this requires that not less than 50% of proposals are affordable homes. We have specific concerns about this because the original viability appraisal put forward in support of the plan considered that even 35% was marginal, but we now have a situation where the policy sponsors 50% provision with the Community Infrastructure Levy (CIL). This does not reflect the constrained nature of many of the sites within the AONB and also the fact that the ones that have been allocated are aimed at smaller developers, many of whom do not exist in the current housing market since the recession and I know that this is something that the Policy Planners at Lancaster City Council recognise.

The allocations are not aimed at very small self-builders who might take one or two houses and neither are they aimed at medium sized housebuilders, which is another reason why in our view they are not likely to be delivered.

We are also of the view that the increase in build costs since the viability assessment was prepared and also taking into account the higher level of specification that would be required by the design and landscape policies themselves, simply will not result in viable schemes at this scale with 50% affordable in combination with CIL.

In the light of the above and our previous representations we would again offer the site for a low density, landscape based development that could allow considerable enhancement of what is essentially a large lawned area. Photographs previously provided show how well screened the site is from the Knott and any proposal would help to reinforce this.

I trust that these representations will be taken into account in consideration of the publication
version of the plan.

I attach a plan which indicates how the site could be developed.

Allocate site A7 for 3 to 5 dwellings.

Yes, I wish to participate at the oral examination

Please notify me

AS03 - Housing Provision

Yes

No

The DPD is not positively prepared

The DPD is not effective

The DPD is not consistent with national policy

I would specifically wish to comment on policy AS03, Housing Provision.

Given the extremely limited number of allocated sites for Arnside we are of the view that in the Plan the intention of policy AS01 and AS03 mean that Arnside does not fulfil its role as a Local Service Centre, as required by the Core Strategy.
With direct reference to policy AS03 this requires that not less than 50% of proposals are affordable homes. We have specific concerns about this because the original viability appraisal put forward in support of the plan considered that even 35% was marginal, but we now have a situation where the policy sponsors 50% provision with the Community Infrastructure Levy (CIL). This does not reflect the constrained nature of many of the sites within the AONB and also the fact that the ones that have been allocated are aimed at smaller developers, many of whom do not exist in the current housing market since the recession and I know that this is something that the Policy Planners at Lancaster City Council recognise.

The allocations are not aimed at very small self-builders who might take one or two houses and neither are they aimed at medium sized housebuilders, which is another reason why in our view they are not likely to be delivered.

We are also of the view that the increase in build costs since the viability assessment was prepared and also taking into account the higher level of specification that would be required by the design and landscape policies themselves, simply will not result in viable schemes at this scale with 50% affordable in combination with CIL.

I trust that these representations will be taken into account in consideration of the publication
version of the plan.

Yes, I wish to participate at the oral examination

Please notify me

AS01 - Development Strategy

Yes

No

The DPD is not positively prepared

The DPD is not effective

The DPD is not consistent with national policy

It is welcomed that the development strategy AS01 accepts Arnside as a Local Service Centre, as it is bound to do under the provisions of the Core Strategy identifying it as such.

Given the extremely limited number of allocated sites for Arnside we are of the view that in the Plan the intention of policy AS01 and AS03 mean that Arnside does not fulfil its role as a Local Service Centre, as required by the Core Strategy.

I trust that these representations will be taken into account in consideration of the publication
version of the plan.

Yes, I wish to participate at the oral examination

General comment / comment on procedure

Yes

No

The DPD is not positively prepared

The DPD is not effective

The DPD is not consistent with national policy

You will be aware that I have made other representations on behalf of other clients with regard to the limited size of the AONB and the relatively high population.

This brings a situation about whereby, to maintain the viability of the population and to make sure that the Arnside & Silverdale AONB as a thriving area from an aspect of human occupation, then there must be room for some growth.

The area hosts a population that is skewed towards older age groups with over 40% of the
population being over 65. This is compared to a 17.7% UK average in 2014. Because of this a
greater number of allocations have to be made to ensure that Arnside is sustainable in terms of population.

I trust that these representations will be taken into account in consideration of the publication
version of the plan.

Yes, I wish to participate at the oral examination

Site Omission

Y101 Yealand Redmayne

Yes

No

The DPD is not positively prepared

The DPD is not effective

The DPD is not consistent with national policy

Site: Y101 and Y102 – Silverdale Road, Yealand Redmayne
Mr Miles Proudlove and Mr Michael Holgate
Arnside Silverdale AONB Development Plan Document Publication Version Consultation Response

I am writing on behalf of my clients who between them own sites that were referenced as Y101 and Y102 in the draft Development Plan Document Allocation and Background Papers.

It is noted that the sites have not been taken forward for housing particularly because of concerns about landscape.

As far as I am aware only 9 sites are being taken forward through the process out of 130 submitted.

Policy AS01, Development Strategy, in effect breaks down two categories of development to Local Service Centres and development at small villages. However, with regard to Yealand Redmayne there is reference to development being limited to conversion of buildings, reuse of brownfield land or regeneration opportunities. We feel that this does not go far enough given the limited number of sites put forward and the limited number of dwellings proposed. We have rehearsed elsewhere the arguments regarding viability and affordability and feel that the low number of sites put forward, taken together with their size, raises serious concerns about whether the aspirations of the Plan can be delivered.

Despite the approach of policy AS01, Yealand Redmayne is a specific settlement and will continue to function in tandem with Yealand Conyers and we are aware that the public house has now reopened as a community business. For the Yealands to be sustainable and thriving moving forward it is considered that some level of allocation should be provided. Again, arguments have been rehearsed elsewhere relating to the age of the population and the need for a supply of housing for younger people to ensure that communities can continue to function in a viable manner and retain and foster services such as public houses.

In any decision about an allocation or a planning application balance must be struck between the effects on the natural environment and the effects of not allocating or granting housing within a community, and in this instance we feel that the balance has tipped away from the Yealands being able to be considered as vibrant local communities.

I attach the relevant maps for sites Y101 and Y102.

In terms of policy AS01, Development Strategy, the reference to development on the edge and outside of settlements is welcomed because it is considered that the site has the potential to comply with this generic policy. Given the small scale of allocations we would consider that sites Y101 and Y102 should be allocated to provide a small and sustainable development at Yealand Redmayne to assist in continuing to foster the services that both Yealand Redmayne and Yealand Conyers contain.

Yes, I wish to participate at the oral examination

Site Omission

Y102 Yealand Redmayne

Yes

No

The DPD is not positively prepared

The DPD is not effective

The DPD is not consistent with national policy

Site: Y101 and Y102 – Silverdale Road, Yealand Redmayne
Mr Miles Proudlove and Mr Michael Holgate
Arnside Silverdale AONB Development Plan Document Publication Version Consultation Response

I am writing on behalf of my clients who between them own sites that were referenced as Y101 and Y102 in the draft Development Plan Document Allocation and Background Papers.

It is noted that the sites have not been taken forward for housing particularly because of concerns about landscape.

As far as I am aware only 9 sites are being taken forward through the process out of 130 submitted.

Policy AS01, Development Strategy, in effect breaks down two categories of development to Local Service Centres and development at small villages. However, with regard to Yealand Redmayne there is reference to development being limited to conversion of buildings, reuse of brownfield land or regeneration opportunities. We feel that this does not go far enough given the limited number of sites put forward and the limited number of dwellings proposed. We have rehearsed elsewhere the arguments regarding viability and affordability and feel that the low number of sites put forward, taken together with their size, raises serious concerns about whether the aspirations of the Plan can be delivered.

Despite the approach of policy AS01, Yealand Redmayne is a specific settlement and will continue to function in tandem with Yealand Conyers and we are aware that the public house has now reopened as a community business. For the Yealands to be sustainable and thriving moving forward it is considered that some level of allocation should be provided. Again, arguments have been rehearsed elsewhere relating to the age of the population and the need for a supply of housing for younger people to ensure that communities can continue to function in a viable manner and retain and foster services such as public houses.

In any decision about an allocation or a planning application balance must be struck between the effects on the natural environment and the effects of not allocating or granting housing within a community, and in this instance we feel that the balance has tipped away from the Yealands being able to be considered as vibrant local communities.

I attach the relevant maps for sites Y101 and Y102.

In terms of policy AS01, Development Strategy, the reference to development on the edge and outside of settlements is welcomed because it is considered that the site has the potential to comply with this generic policy. Given the small scale of allocations we would consider that sites Y101 and Y102 should be allocated to provide a small and sustainable development at Yealand Redmayne to assist in continuing to foster the services that both Yealand Redmayne and Yealand Conyers contain.

Yes, I wish to participate at the oral examination

AS01 - Development Strategy

Yes

No

The DPD is not positively prepared

The DPD is not effective

The DPD is not consistent with national policy

Policy AS01, Development Strategy, in effect breaks down two categories of development to Local Service Centres and development at small villages. However, with regard to Yealand Redmayne there is reference to development being limited to conversion of buildings, reuse of brownfield land or regeneration opportunities. We feel that this does not go far enough given the limited number of sites put forward and the limited number of dwellings proposed. We have rehearsed elsewhere the arguments regarding viability and affordability and feel that the low number of sites put forward, taken together with their size, raises serious concerns about whether the aspirations of the Plan can be delivered.

Despite the approach of policy AS01, Yealand Redmayne is a specific settlement and will continue to function in tandem with Yealand Conyers and we are aware that the public house has now reopened as a community business. For the Yealands to be sustainable and thriving moving forward it is considered that some level of allocation should be provided. Again, arguments have been rehearsed elsewhere relating to the age of the population and the need for a supply of housing for younger people to ensure that communities can continue to function in a viable manner and retain and foster services such as public houses.

In any decision about an allocation or a planning application balance must be struck between the effects on the natural environment and the effects of not allocating or granting housing within a community, and in this instance we feel that the balance has tipped away from the Yealands being able to be considered as vibrant local communities.

In terms of policy AS01, Development Strategy, the reference to development on the edge and outside of settlements is welcomed because it is considered that the site has the potential to comply with this generic policy. Given the small scale of allocations we would consider that sites Y101 and Y102 should be allocated to provide a small and sustainable development at Yealand Redmayne to assist in continuing to foster the services that both Yealand Redmayne and Yealand Conyers contain.

Yes, I wish to participate at the oral examination

I have read the guidance notes

Site Omission

Site A15 (Redhills Road)

Yes

No

The DPD is not positively prepared

The DPD is not justified

The DPD is not effective

The DPD is not consistent with national policy

This response is written on behalf of Russell Armer Homes and represents a general response in relation to the policies contained within the DPD, followed by reference to two specific sites that have been put forward by my client at Arnside. The two sites have not been taken forward into this document and they have previously been referenced as:
* Redhills Road Site Reference A15; and
* Station Road Site Reference A18.

Plans of these sites are attached to this representation.

This consultation response works through the DPD document quoting the paragraph number of any paragraphs that we wish to make comment upon.
Paragraph 1.2.4
With regard to paragraph 1.2.4 of the DPD it is noted that an emphasis is placed upon the Arnside & Silverdale Statutory Management Plan 2014. This document sets out the overall strategy for managing, conserving and enhancing the AONB. While the Statutory Management Plan is an important over-arching document for the area, it does not form part of the Development Plan and we are of the view that too great an emphasis has been placed upon following a plan which has a strategy that involves much more than development, yet it has been used as a strategic director for the AONB DPD.
Paragraph 1.2.7
It is noted that the AONB covers 75 km² with a population of around 7,800. The main settlements are Arnside, Warton, Silverdale and Storth/Sandside but Arnside is the largest settlement within the AONB and was identified by the South Lakeland Core Strategy as a Local Service Centre, where policy CS1.2 of the Core Strategy sets out that 21% of new housing and employment development would be in the network of Local Service Centres.

We view the population of the AONB at approximately 7,800, and that of Arnside itself, as significant and presumably South Lakeland were of the same view when their Core Strategy identified Arnside as a Local Service Centre.

The Arnside & Silverdale AONB is quite heavily populated for its size when considered against many larger AONBs with much sparser population densities. The reason this is mentioned is because there is clearly a significant functioning population within the area and at Arnside in particular that requires a level of services and commensurate growth to ensure that the AONB functions as a sustainable economy and as a place for people to live and work. Consequently, the Plan is questioned in terms of its compliance with the NPPF and how effective the Plan is in responding to the needs of the area.

This is of particular concern given that the Arnside & Silverdale AONB is possibly the smallest AONB in England and Wales, while it has a significant population. Some comparisons of population by area for other AONBs within England and Wales are set out below: [SEE ATTACHED DOCUMENT]

Paragraph 1.3.13
This paragraph of the DPD sets out that the relevant parts of the South Lakeland Local Plan include the Core Strategy 2010, which sets out the overall development strategy and vision for the district. This includes identifying Arnside as a Local Service Centre. It is welcomed that Arnside is indicated as a Local Service Centre by Policy AS01.

Arnside is one of the largest villages in Cumbria and the largest within the AONB. At the 2011 Census it had a population of 2,235. Over 40% of the population are over 65. This is compared to 17.7% as a national (UK) average in 2014. We would question whether the sites put forward later in the document really meet the needs of the community (their effectiveness) and whether they are likely to result in any new house building being brought forward within the AONB given the limited number of sites put forward and the constraints associated with them, some of which are derived from policies within this document (e.g. the affordable housing target).

Paragraph 1.3.15
This paragraph points out that the statutory AONB Management Plan is a critical document. It accepts that the document is not part of the Local Plan for the area but that it is a material consideration in making planning decisions. With regard to this it is again emphasised that while this is an important material consideration, it is not part of the Development Plan and the Core Strategy that indicates Arnside as a Local Service Centre is. We feel there is an imbalance between the emphasis upon the AONB Management Plan and the existing Core Strategy for the area. It is important that the AONB designation has not changed in its legislative position or level of protection since the Core Strategy was adopted in 2010. Consequently the effectiveness and compliance of the Plan with the NPPF is questioned.

Paragraph 2.1.2
Under section 2 of the Plan Vision and Objectives, paragraph 2.1.2 considers that the vision of the AONB DPD is to reflect and supplement the adopted Management Plan Vision as well as the two relevant Local Plans, national policy and the evidence gathered and the wider context. The text in the box below paragraph 2.1.2 considers that within the Arnside & Silverdale AONB:
- housing, employment, services, infrastructure and other development has managed to contribute towards meeting the needs of those who live in, work and visit the area in a way that conserves and enhances the landscape, natural beauty and the special qualities of the AONB;
- creates vibrant, diverse and sustainable communities with a strong sense of place; and
- maintains a thriving local economy.
With regard to this part of the vision the Plan does not meet the needs of those who live, work and visit the area in a way that will create vibrant, diverse and sustainable communities. We are of the view that the allocations put forward within the document will not be brought forward and therefore this vision will not be achieved and neither would the aspiration of maintaining a thriving local economy with a vibrant, diverse and sustainable community.

Paragraph 2.2.1
Under this paragraph, Objectives, the fourth objective is to provide a sufficient supply and mix of high quality housing to contribute to meeting the needs of the AONB’s communities, with an emphasis on affordable housing and protecting the landscape character. However, given the limited number of allocated sites and the policy requirements (affordable housing) it is considered that the allocations put forward will not meet the objective to provide a sufficient supply and mix of high quality housing and therefore cannot be deemed to be positively prepared or effective.

Policy AS01, Development Strategy
In terms of this policy the reference to Local Service Centres within the policy is welcomed. The policy itself considers that to promote vibrant local communities and to support services small scale growth and investment will be supported in the identified Local Service Centres where it closely reflects identified local needs within the AONB and conserves and enhances landscape and settlement character. The reference to Arnside being a Local Service Centre is welcomed. However, there is some concern about the definition of small scale growth and what this means when such a definition is not included within policy CS1.2, the development strategy of South Lakeland District Council’s Core Strategy document. Reference to policy CS1.2 of the Core Strategy considers that the exact scale and level of development supported will be dependent upon individual character, impacts on environmental capacity and infrastructure provision. We are of the view that this element of Core Strategy policy CS1.2 should be contained within policy AS01, Development Strategy, so that the DPD is consistent with the Core Strategy and also to ensure that decisions are based on the characteristics of a particular development project rather than a reference to “small scale” which is not a defined concept.

Paragraph 3.1.3 to 3.1.7
These paragraphs relate to objectively assessed needs and the text points out that it is difficult to apportion a specific figure to the AONB as a whole or in line with the two Authority parts, and that no precedent exists for such an approach.

Paragraph 3.1.4 considers that it is not necessary to identify a specific housing requirement for the AONB and that an emphasis should be placed on meeting identified affordable and other local housing needs within the capacity of the landscape.

The conclusion of the approach to housing is that the difficulties in apportioning the OAN, and the limited capacity of the landscape to accommodate development, means that the Councils have not identified a specific housing requirement for the AONB. Interestingly, despite this the Guidance Notes for this consultation note that to be positively prepared the DPD should be based upon a strategy that seeks to meet objectively assessed development and infrastructure requirements. However, regardless of the need for the Plan to meet the OANor not it must still fulfil its objectives of creating vibrant, diverse and sustainable communities and also maintaining a thriving local economy.
The restrictive approach to housing does not, in our view, achieve that given the restrictive policies and the cumulative policy impacts upon viability. Consequently, the effectiveness and compliance of the Plan is questioned given that the NPPF is overtly focused upon growth, while accepting that this must be filtered by paragraph 115 of the NPPF.
In the light of the information presented above about the age structure of the population of the AONB there is a particular issue with regard to the ageing population and there will be a continuing requirement for a range of services to meet the needs of that elderly population. This can only be based upon new development to maintain a working age population, including new houses that will create a sustainable population to meet those needs. The primary school also needs to be sustained into the future and the level of growth allowed for is unlikely to assist this.
The Plan must be compatible with the South Lakeland Core Strategy and the vision within that Core Strategy for the eastern part of the district. However the DPD appears to lean heavily towards the Management Plan as opposed to the Core Strategy. Again it is emphasised that the Management Plan is not a land use planning document.
Paragraph 3.1.7 notes that the Councils have not sought to set targets for the amount of development to be achieved but that this should be achieved within what can be accommodated without harm to landscape, whilst maintaining a positive approach. Without a clear picture of what the specific needs are within the AONB we feel that the wider approach of the plan in relation to the allocation of sites is overly restrictive. Work that we have carried out on 2 sites in Arnside indicates that there would not be any unacceptable harm to the landscape of the AONB. The key point is that they are both located within the Local Service Centre of Arnside where the approach would anticipate development in principle. However, despite the professional landscape evidence put forward the sites have been designated as Key Settlement Landscapes.
Policy AS02, Landscape
With regard to this policy we have noted that certain changes have been made since our last representation and would generally welcome those changes. However, from the final criteria of this policy it appears that a landscape assessment could be required for any level of development and in our view reference should be made within this to whether one will be required or not, as it should be proportionate to the scale of the proposal and the level of impact as well as the scale of development, indicating the scale of the landscape study required. It may be disproportionate to ask for a landscape study for, for instance, an infill plot or a house extension. Officer discretion needs to be allowed.
Policy AS03, Housing Provision
The comments in relation to the nature of the population within the AONB and whether the Plan meets the needs of the area as a sustainable community moving forward goes to the heart of policy AS03.
This policy stipulates that proposals for new housing development will be supported where they deliver no less than 50% affordable housing and that only where this is demonstrably unachievable will a lower percentage be acceptable. The policy considers that affordable housing needs are forecast to apply over a period of time and that not all of the identified need is required straightway and that, consequently, this should be phased in line with demand. However, we consider that a 50% requirement is not viable and sets very high expectations within local communities that should not be raised. My client, Russell Armer, as a developer within Cumbria and North Lancashire for a number of years, does not see anything in the Plan that would sponsor this level of provision. The specific site constraints and the number of houses that can be achieved from each site allocated, in our view, strongly mitigates against any aspiration to provide 50% affordable. An approach via a Supplementary Planning Document called I-Path was introduced in South Lakeland some years ago which required 50% affordable housing. However this policy was abandoned and any such approach would now be further compounded by the requirements of the Community Infrastructure Levy which would apply within the South Lakeland part of the AONB, in which Arnside is located.
Paragraph 4.1.3
This paragraph notes that a requirement for 50% of new homes to be affordable is justified because the AONB is a sensitive landscape protected at a national level. It is considered inappropriate to use those sites that are suitable for development in the AONB to deliver development that does not help to meet local affordable or other local needs. The paragraph goes on to note that doing so would mean that those needs would remain unmet and the most sensitive sites would have to be developed in order to meet the affordable needs.
We have particular concern about this because it appears that a landscape approach is being used to identify the level of affordable housing provision as opposed to a viability approach. It is our view that the housing policy and strategy would fail with such a high level of affordable requirement, but it appears from the policy that this is being justified on landscape grounds rather than viability grounds. This creates a clear tension between the aspirations of the document to serve the landscape character and to provide a high level of affordable housing.
We noted that the viability report originally produced by HDH in support of the Draft Plan recognised that no sites would be viable under a 50% affordable policy. It was further noted at the time by HDH that even under the Council’s current adopted target of 35% in the South Lakeland District a number of sites would not be viable. In terms of the original HDH viability report it was noted that South Lakeland District Council achieves 35% affordable housing on almost all target sites. However, we would have some concerns for the following reasons:
- The sites achieving 35% are generally large scale, greenfield sites providing economies of scale.
- Much of this track record of achieving 35% is prior to the introduction of the Community Infrastructure Levy (CIL).
- The larger sites often have fewer constraints than those put forward by the AONB DPD.
- Drainage requirements are becoming stricter and this has a significant impact on viability.
With regard to viability we have concerns as to why the HDH report considers that no sites were viable under a 50% affordable housing policy, but the latest viability study contained within the DPD document library considers that 50% affordable even with CIL is considered to be viable.
The conclusions are based on a broad set of assumptions and typologies for the sites put forward. However, my client’s experience on a site by site basis as a developer that has a long history of working in the area and within the challenging landscapes and topographies associated with it, is that this broad based approach does not take account of the reality of developing particular sites.
For instance, many of the sites within the AONB that are allocated have some difficult topography, access or drainage requirements.
It is noted that in paragraph 4.71 of the Aspinall Verdi report that the TLVs are for higher level plan viability purposes. The report does emphasise that the adoption of a particular TLV in no way implies that this figure can be used by applicants to negotiate site specific applications. It goes on to note that where sites have obvious abnormal costs (e.g. retaining walls for sloping sites) these costs should be deducted from the value of the land. We would question where this assumption comes from given that it is the Council’s role to provide a supply of and policies for housing within any given area. We are concerned about the statement that costs for abnormals should be deducted from the value of the land and we would disagree with this approach given it is the Local Authorities responsibility to provide appropriate housing policies. However, we have been in discussions on a number of sites elsewhere where the view of the Local Authority is that the pain of abnormal costs should be shared across all parties, including the affordable housing percentage, landowner and developer profits. However, simply directing abnormals to a reduction in the value of the land will, again, result in proposals not being brought forward.
We have concerns that the build costs will not necessarily reflect the higher quality required within the AONB. We also have concern that the affordable housing prices are based on a low specification and not a high specification that would be required within the AONB.
We note that originally the viability appraisals were run at 17.5% profit to the developer, but this has been raised to 20%. We do not see why 20% should necessarily be an upper limit but in our view this should be a minimal margin. In addition 20% would be an OMV only. On affordable housing we understand that this would be 6%, giving a blended rate across a site at well below 20%.
We would also point out that the allocations put forward largely rely upon small and medium sized developers bringing sites forward. The sites would be likely to attract small or medium sized builders who do not have the economies of scale of medium and larger sized developers and, consequently, we would question the practical deliverability of the sites other than in theoretical plan form. This questions whether the Plan is positively prepared and effective in bringing housing development forward.
Paragraph 4.2.8
This paragraph states that all planning applications will need to be accompanied by ecological surveys that are proportionate to the nature and scale of the development. However, it will be the case that some very small scale developments that require planning permission would clearly not need an ecological survey and this should be made clear either in the policy or the text supporting it.
Policy AS08, Design
With regard to this policy there are no particular comments but the requirements would appear to be in excess of those required throughout South Lakeland and we would ask for evidence that this has been factored into the viability considerations outlined above.
Proposed Development Allocations:
I have, on behalf of my client, had previous correspondence pointing out that Russell Armer have an interest two sites that have not been allocated for development in Arnside. One is at Redhills Road, where we currently have in a planning application for 5 homes, and the other at Station Road. My client considers that the sites could accommodate housing in a sustainable manner. Despite the plan allocating neither site for development we were aware that Arnside Parish Council felt that some limited development may be appropriate at the Redhills Road site. This reflects their comment upon our current planning application.
It is of concern to us that both sites were put forward as suitable for housing by South Lakeland District Council at the examination of the Land Allocations DPD for the whole of the district. This inferred the acceptability of housing on both sites. The AONB DPD takes a different view and we are concerned that the sites put forward by SLDC on the back of a landscape evidence base at that time in 2012/2013 are now being rejected on landscape grounds. The landscape character of these sites has not changed over this time and neither has the overarching policy requirement relating to protected landscapes. Consequently, we ask for evidence of what has changed.
The site at Station Road is subject to a Key Settlement Landscape designation A18 and the site at Redhills Road is subject to the same designation, reference A15. This severely restricts development opportunity in Arnside, which is regarded by the South Lakeland District Council Core Strategy and the DPD itself as a Local Service Centre. We regard both sites as being sustainable sites within the settlement with the one at Station Road being next to an important public transport facility and, in our view, the lack of allocation of this sites is failing to create a vibrant, diverse and sustainable community at Arnside into the future on sites that have not previously been subject to concerns about landscape.
Site AS17, land off Queens Drive, is allocated for approximately 6 dwellings. However, the site is likely to yield as a maximum 6 dwellings and it is in effect a brownfield site with an existing garage block. On top of this presumably 50% affordable housing would be required. We simply do not see this as being deliverable with the 50% affordable housing policy and CIL.
Site AS18 may be developable but with 50% affordable housing requirement as well as the CIL, taken together with 6 dwellings being ambitious if the rear part of the site is not be used, we have concerns about deliverability.
Site AS19, Briery Bank, the same concerns apply to this site.
Policy AS23
This policy allocates Station Yard, Arnside, for mixed uses including some potential for residential live/work units, but this is noted as just potential so cannot be regarded as a housing allocation that will yield any particular number of units.
In our view, given the constraints identified, the effective allocation of housing for Arnside for the plan period is probably something in the order of 14 homes and we would question whether any can be delivered under the current affordable housing policy.
To turn to the lack of allocation of my client’s two sites, in an attempt to understand why my client’s sites have not been allocated a Landscape Analysis has been commissioned from the Landscape Agency.
From the start we have had concerns about comments that the sites are not suitable in landsape terms because they form part of the settlement and form the next logical areas for extension, with good access and infrastructure available and are sites that have development adjacent and are in part enclosed by it.
The Redhills Road site, A15, is a contained site bounded by residential development and the wooded slopes on the opposite side of the site. The constrained nature of the site limits the opportunities to appreciate this landscape within the wider context of Redhills Road, Arnside Knott and the AONB.
The site itself is open though, given the contained nature of it, the open site makes only a limited contribution to defining open space in the wider context due to its overlooked character.
In the light of the above the site has very limited wider visual connectivity with Redhills Road, Arnside Knott and the AONB, and that the experience of the site is overlooked by residential development. The loss of this space within the wider AONB and setting of Arnside would have a very limited visual impact on the character of the village. This is presumably why it was suggested for allocation by South Lakeland District Council in the first place during the 2012/2013 Land Allocations process.
We are encouraged by the fact that the Parish Council considered that some limited development can be accommodated at the site. We are also aware of a consultation response from a local resident who considers this site much more appropriate for development than one of the allocated sites.
A number of interventions could be made to assist with the development of any housing at the site. A generous open corridor could be maintained adjacent to the public right of way and properties could be set back from the Redhills Road frontage to maintain the line of development on Redhills Road.
Any development could ensure a high quality gable end to enhance property facing Redhills Road to provide a positive character to the street scene, which is highly visible in this location.
In addition it would be possible to maintain clear lines of sight along the green corridor, allowing additional tree planting to ensure that the existing woodland canopy is a dominant feature. This has the potential of offering the illusion of a more generous, uncluttered corridor and of course would also have ecological benefits.
An application is currently being considered for 5 dwellings at the west of the site; however, this does not preclude further development and given the previous landscape evidence we consider that the site remains to be suitable for allocations for a larger scheme.
In summary the visual containment of the site presents a good opportunity for residential development and the access opportunities are already there. At the western end of the site it is clear that there was an intention to extend into this area by the way in which development is terminated. Consequently, given the limitation of the sites allocated in terms of their overall numbers and quantum of development, taken together with their associated difficulties, it would seem perfectly reasonable to allocate at least part of this site for residential development.
With regard to the Station Road site you will be aware that Russell Armer have explored how this might be developed with South Lakeland District Council.
My client commissioned the Landscape Agency to prepare a response to the LVFSS recommendation and the finding of this response could allow South Lakeland District Council/Lancaster City Council to support the inclusion of site A24 for residential development.
As has been pointed out previously the site is essentially located within a developed area. Development is to four sides including Station Road and Ashleigh Court, Ashleigh Road and the southern farmstead. This existing development creates a strong sense of enclosure to the site and that anyone visiting has already arrived at Arnside. The character of development varies along these boundaries in scale, age and form which provides a disjointed and uncohesive character. We consider that this is not a strong representation of the built or landscape character of Arnside in this location for the following reasons:
- Ashleigh Court is a dominating structure within this view and is not characteristic to the scale of Arnside or its location.
- Existing development has already broken the natural skyline.
- A public right of way dissects the site connecting residential areas with the station.
- A distant view from the Station is only permitted in the south west over the rising fields between the developed edges of the site.
- The field view from the south west corner of the site is partially bounded with residential development which breaks the natural skyline.
- Views from B5282 are restricted by mature hedgerows and a high quantity of on street parking associated with the station.
- Views from the B5282 are limited to immediately adjacent to the site due to the dense development along the road. The volume of views from the B5282 are limited and experienced only briefly.
- Views from the station and footbridge are elevated. Views from this vantage point of the distant south west fields are a strong feature and development at low level would not obscure these views.
The Landscape Agency have made a number of recommendations which could bring benefits to the site in addition to the obvious provision of housing.
The low lying fields within site A24 would not restrict views of the distant farmland landscape to the south west from the railway station and therefore maintain the intrinsic existing urban pasture landscape character of the site.
The cohesive rounding off of the existing incremental stages of historic development and softening of the less characteristic development scale of Ashleigh Court will be a key benefit.
Positive reinforcement of the Station Road character by active frontages to the street would provide strategic opportunities to provide views of the distant fields between development.
This would also ensure that the Plan is justified, effective and consistent with national policy.

Development of the site could provide a stronger arrival experience for train users and for the general arrival experience to Arnside.
The key message from this consultation response is that we feel the document is generally over restrictive and, as it stands, fails to meet the needs of the local communities within the area, with particular reference to how the plan in its current form can create vibrant, diverse and sustainable communities with a strong sense of place and how it can maintain a thriving local economy.

Both of the above aspirations require some level of growth to ensure that as a place the AONB is sustainable into the future.

The AONB needs future growth to maintain the local economy and prevent further imbalance of the age structure within the area. We are not arguing that this should be at a cost to the purpose of conserving and enhancing the AONB but in our view the key challenge of such a document is to ensure how that growth fits within the context of protecting and enhancing the landscape and surely this should be the innovative approach, rather than the innovative approach being one of restriction.

Attachments:
- Redhills Road Plan.
- Station Road Plan.
- Landscape Agency Report: Redhills Road.
- Landscape Agency Report: Station Road.

Allocate Redhills Road Site Ref A15 and Station Road Site A18 to ensure a greater level of provision that is likely to be deliverable. The requirement for 50% affordable housing is untenable and will not deliver any affordable housing. This should be reduced to a maximum of 35% as per the wider requirement in South Lakeland.
Greater emphasis should be placed on the NPPF and Core Strategy be ensure
compliance with the NPPF (Criteria 4).

Yes, I wish to participate at the oral examination

Please notify me

I have read the guidance notes

Site Omission

A18 (Station Road)

Yes

No

The DPD is not positively prepared

The DPD is not justified

The DPD is not effective

The DPD is not consistent with national policy

This response is written on behalf of Russell Armer Homes and represents a general response in relation to the policies contained within the DPD, followed by reference to two specific sites that have been put forward by my client at Arnside. The two sites have not been taken forward into this document and they have previously been referenced as:
* Redhills Road Site Reference A15; and
* Station Road Site Reference A18.

Plans of these sites are attached to this representation.

This consultation response works through the DPD document quoting the paragraph number of any paragraphs that we wish to make comment upon.
Paragraph 1.2.4
With regard to paragraph 1.2.4 of the DPD it is noted that an emphasis is placed upon the Arnside & Silverdale Statutory Management Plan 2014. This document sets out the overall strategy for managing, conserving and enhancing the AONB. While the Statutory Management Plan is an important over-arching document for the area, it does not form part of the Development Plan and we are of the view that too great an emphasis has been placed upon following a plan which has a strategy that involves much more than development, yet it has been used as a strategic director for the AONB DPD.
Paragraph 1.2.7
It is noted that the AONB covers 75 km² with a population of around 7,800. The main settlements are Arnside, Warton, Silverdale and Storth/Sandside but Arnside is the largest settlement within the AONB and was identified by the South Lakeland Core Strategy as a Local Service Centre, where policy CS1.2 of the Core Strategy sets out that 21% of new housing and employment development would be in the network of Local Service Centres.

We view the population of the AONB at approximately 7,800, and that of Arnside itself, as significant and presumably South Lakeland were of the same view when their Core Strategy identified Arnside as a Local Service Centre.

The Arnside & Silverdale AONB is quite heavily populated for its size when considered against many larger AONBs with much sparser population densities. The reason this is mentioned is because there is clearly a significant functioning population within the area and at Arnside in particular that requires a level of services and commensurate growth to ensure that the AONB functions as a sustainable economy and as a place for people to live and work. Consequently, the Plan is questioned in terms of its compliance with the NPPF and how effective the Plan is in responding to the needs of the area.

This is of particular concern given that the Arnside & Silverdale AONB is possibly the smallest AONB in England and Wales, while it has a significant population. Some comparisons of population by area for other AONBs within England and Wales are set out below: [SEE ATTACHED DOCUMENT]

Paragraph 1.3.13
This paragraph of the DPD sets out that the relevant parts of the South Lakeland Local Plan include the Core Strategy 2010, which sets out the overall development strategy and vision for the district. This includes identifying Arnside as a Local Service Centre. It is welcomed that Arnside is indicated as a Local Service Centre by Policy AS01.

Arnside is one of the largest villages in Cumbria and the largest within the AONB. At the 2011 Census it had a population of 2,235. Over 40% of the population are over 65. This is compared to 17.7% as a national (UK) average in 2014. We would question whether the sites put forward later in the document really meet the needs of the community (their effectiveness) and whether they are likely to result in any new house building being brought forward within the AONB given the limited number of sites put forward and the constraints associated with them, some of which are derived from policies within this document (e.g. the affordable housing target).

Paragraph 1.3.15
This paragraph points out that the statutory AONB Management Plan is a critical document. It accepts that the document is not part of the Local Plan for the area but that it is a material consideration in making planning decisions. With regard to this it is again emphasised that while this is an important material consideration, it is not part of the Development Plan and the Core Strategy that indicates Arnside as a Local Service Centre is. We feel there is an imbalance between the emphasis upon the AONB Management Plan and the existing Core Strategy for the area. It is important that the AONB designation has not changed in its legislative position or level of protection since the Core Strategy was adopted in 2010. Consequently the effectiveness and compliance of the Plan with the NPPF is questioned.

Paragraph 2.1.2
Under section 2 of the Plan Vision and Objectives, paragraph 2.1.2 considers that the vision of the AONB DPD is to reflect and supplement the adopted Management Plan Vision as well as the two relevant Local Plans, national policy and the evidence gathered and the wider context. The text in the box below paragraph 2.1.2 considers that within the Arnside & Silverdale AONB:
- housing, employment, services, infrastructure and other development has managed to contribute towards meeting the needs of those who live in, work and visit the area in a way that conserves and enhances the landscape, natural beauty and the special qualities of the AONB;
- creates vibrant, diverse and sustainable communities with a strong sense of place; and
- maintains a thriving local economy.
With regard to this part of the vision the Plan does not meet the needs of those who live, work and visit the area in a way that will create vibrant, diverse and sustainable communities. We are of the view that the allocations put forward within the document will not be brought forward and therefore this vision will not be achieved and neither would the aspiration of maintaining a thriving local economy with a vibrant, diverse and sustainable community.

Paragraph 2.2.1
Under this paragraph, Objectives, the fourth objective is to provide a sufficient supply and mix of high quality housing to contribute to meeting the needs of the AONB’s communities, with an emphasis on affordable housing and protecting the landscape character. However, given the limited number of allocated sites and the policy requirements (affordable housing) it is considered that the allocations put forward will not meet the objective to provide a sufficient supply and mix of high quality housing and therefore cannot be deemed to be positively prepared or effective.

Policy AS01, Development Strategy
In terms of this policy the reference to Local Service Centres within the policy is welcomed. The policy itself considers that to promote vibrant local communities and to support services small scale growth and investment will be supported in the identified Local Service Centres where it closely reflects identified local needs within the AONB and conserves and enhances landscape and settlement character. The reference to Arnside being a Local Service Centre is welcomed. However, there is some concern about the definition of small scale growth and what this means when such a definition is not included within policy CS1.2, the development strategy of South Lakeland District Council’s Core Strategy document. Reference to policy CS1.2 of the Core Strategy considers that the exact scale and level of development supported will be dependent upon individual character, impacts on environmental capacity and infrastructure provision. We are of the view that this element of Core Strategy policy CS1.2 should be contained within policy AS01, Development Strategy, so that the DPD is consistent with the Core Strategy and also to ensure that decisions are based on the characteristics of a particular development project rather than a reference to “small scale” which is not a defined concept.

Paragraph 3.1.3 to 3.1.7
These paragraphs relate to objectively assessed needs and the text points out that it is difficult to apportion a specific figure to the AONB as a whole or in line with the two Authority parts, and that no precedent exists for such an approach.

Paragraph 3.1.4 considers that it is not necessary to identify a specific housing requirement for the AONB and that an emphasis should be placed on meeting identified affordable and other local housing needs within the capacity of the landscape.

The conclusion of the approach to housing is that the difficulties in apportioning the OAN, and the limited capacity of the landscape to accommodate development, means that the Councils have not identified a specific housing requirement for the AONB. Interestingly, despite this the Guidance Notes for this consultation note that to be positively prepared the DPD should be based upon a strategy that seeks to meet objectively assessed development and infrastructure requirements. However, regardless of the need for the Plan to meet the OANor not it must still fulfil its objectives of creating vibrant, diverse and sustainable communities and also maintaining a thriving local economy.
The restrictive approach to housing does not, in our view, achieve that given the restrictive policies and the cumulative policy impacts upon viability. Consequently, the effectiveness and compliance of the Plan is questioned given that the NPPF is overtly focused upon growth, while accepting that this must be filtered by paragraph 115 of the NPPF.
In the light of the information presented above about the age structure of the population of the AONB there is a particular issue with regard to the ageing population and there will be a continuing requirement for a range of services to meet the needs of that elderly population. This can only be based upon new development to maintain a working age population, including new houses that will create a sustainable population to meet those needs. The primary school also needs to be sustained into the future and the level of growth allowed for is unlikely to assist this.
The Plan must be compatible with the South Lakeland Core Strategy and the vision within that Core Strategy for the eastern part of the district. However the DPD appears to lean heavily towards the Management Plan as opposed to the Core Strategy. Again it is emphasised that the Management Plan is not a land use planning document.
Paragraph 3.1.7 notes that the Councils have not sought to set targets for the amount of development to be achieved but that this should be achieved within what can be accommodated without harm to landscape, whilst maintaining a positive approach. Without a clear picture of what the specific needs are within the AONB we feel that the wider approach of the plan in relation to the allocation of sites is overly restrictive. Work that we have carried out on 2 sites in Arnside indicates that there would not be any unacceptable harm to the landscape of the AONB. The key point is that they are both located within the Local Service Centre of Arnside where the approach would anticipate development in principle. However, despite the professional landscape evidence put forward the sites have been designated as Key Settlement Landscapes.
Policy AS02, Landscape
With regard to this policy we have noted that certain changes have been made since our last representation and would generally welcome those changes. However, from the final criteria of this policy it appears that a landscape assessment could be required for any level of development and in our view reference should be made within this to whether one will be required or not, as it should be proportionate to the scale of the proposal and the level of impact as well as the scale of development, indicating the scale of the landscape study required. It may be disproportionate to ask for a landscape study for, for instance, an infill plot or a house extension. Officer discretion needs to be allowed.
Policy AS03, Housing Provision
The comments in relation to the nature of the population within the AONB and whether the Plan meets the needs of the area as a sustainable community moving forward goes to the heart of policy AS03.
This policy stipulates that proposals for new housing development will be supported where they deliver no less than 50% affordable housing and that only where this is demonstrably unachievable will a lower percentage be acceptable. The policy considers that affordable housing needs are forecast to apply over a period of time and that not all of the identified need is required straightway and that, consequently, this should be phased in line with demand. However, we consider that a 50% requirement is not viable and sets very high expectations within local communities that should not be raised. My client, Russell Armer, as a developer within Cumbria and North Lancashire for a number of years, does not see anything in the Plan that would sponsor this level of provision. The specific site constraints and the number of houses that can be achieved from each site allocated, in our view, strongly mitigates against any aspiration to provide 50% affordable. An approach via a Supplementary Planning Document called I-Path was introduced in South Lakeland some years ago which required 50% affordable housing. However this policy was abandoned and any such approach would now be further compounded by the requirements of the Community Infrastructure Levy which would apply within the South Lakeland part of the AONB, in which Arnside is located.
Paragraph 4.1.3
This paragraph notes that a requirement for 50% of new homes to be affordable is justified because the AONB is a sensitive landscape protected at a national level. It is considered inappropriate to use those sites that are suitable for development in the AONB to deliver development that does not help to meet local affordable or other local needs. The paragraph goes on to note that doing so would mean that those needs would remain unmet and the most sensitive sites would have to be developed in order to meet the affordable needs.
We have particular concern about this because it appears that a landscape approach is being used to identify the level of affordable housing provision as opposed to a viability approach. It is our view that the housing policy and strategy would fail with such a high level of affordable requirement, but it appears from the policy that this is being justified on landscape grounds rather than viability grounds. This creates a clear tension between the aspirations of the document to serve the landscape character and to provide a high level of affordable housing.
We noted that the viability report originally produced by HDH in support of the Draft Plan recognised that no sites would be viable under a 50% affordable policy. It was further noted at the time by HDH that even under the Council’s current adopted target of 35% in the South Lakeland District a number of sites would not be viable. In terms of the original HDH viability report it was noted that South Lakeland District Council achieves 35% affordable housing on almost all target sites. However, we would have some concerns for the following reasons:
- The sites achieving 35% are generally large scale, greenfield sites providing economies of scale.
- Much of this track record of achieving 35% is prior to the introduction of the Community Infrastructure Levy (CIL).
- The larger sites often have fewer constraints than those put forward by the AONB DPD.
- Drainage requirements are becoming stricter and this has a significant impact on viability.
With regard to viability we have concerns as to why the HDH report considers that no sites were viable under a 50% affordable housing policy, but the latest viability study contained within the DPD document library considers that 50% affordable even with CIL is considered to be viable.
The conclusions are based on a broad set of assumptions and typologies for the sites put forward. However, my client’s experience on a site by site basis as a developer that has a long history of working in the area and within the challenging landscapes and topographies associated with it, is that this broad based approach does not take account of the reality of developing particular sites.
For instance, many of the sites within the AONB that are allocated have some difficult topography, access or drainage requirements.
It is noted that in paragraph 4.71 of the Aspinall Verdi report that the TLVs are for higher level plan viability purposes. The report does emphasise that the adoption of a particular TLV in no way implies that this figure can be used by applicants to negotiate site specific applications. It goes on to note that where sites have obvious abnormal costs (e.g. retaining walls for sloping sites) these costs should be deducted from the value of the land. We would question where this assumption comes from given that it is the Council’s role to provide a supply of and policies for housing within any given area. We are concerned about the statement that costs for abnormals should be deducted from the value of the land and we would disagree with this approach given it is the Local Authorities responsibility to provide appropriate housing policies. However, we have been in discussions on a number of sites elsewhere where the view of the Local Authority is that the pain of abnormal costs should be shared across all parties, including the affordable housing percentage, landowner and developer profits. However, simply directing abnormals to a reduction in the value of the land will, again, result in proposals not being brought forward.
We have concerns that the build costs will not necessarily reflect the higher quality required within the AONB. We also have concern that the affordable housing prices are based on a low specification and not a high specification that would be required within the AONB.
We note that originally the viability appraisals were run at 17.5% profit to the developer, but this has been raised to 20%. We do not see why 20% should necessarily be an upper limit but in our view this should be a minimal margin. In addition 20% would be an OMV only. On affordable housing we understand that this would be 6%, giving a blended rate across a site at well below 20%.
We would also point out that the allocations put forward largely rely upon small and medium sized developers bringing sites forward. The sites would be likely to attract small or medium sized builders who do not have the economies of scale of medium and larger sized developers and, consequently, we would question the practical deliverability of the sites other than in theoretical plan form. This questions whether the Plan is positively prepared and effective in bringing housing development forward.
Paragraph 4.2.8
This paragraph states that all planning applications will need to be accompanied by ecological surveys that are proportionate to the nature and scale of the development. However, it will be the case that some very small scale developments that require planning permission would clearly not need an ecological survey and this should be made clear either in the policy or the text supporting it.
Policy AS08, Design
With regard to this policy there are no particular comments but the requirements would appear to be in excess of those required throughout South Lakeland and we would ask for evidence that this has been factored into the viability considerations outlined above.
Proposed Development Allocations:
I have, on behalf of my client, had previous correspondence pointing out that Russell Armer have an interest two sites that have not been allocated for development in Arnside. One is at Redhills Road, where we currently have in a planning application for 5 homes, and the other at Station Road. My client considers that the sites could accommodate housing in a sustainable manner. Despite the plan allocating neither site for development we were aware that Arnside Parish Council felt that some limited development may be appropriate at the Redhills Road site. This reflects their comment upon our current planning application.
It is of concern to us that both sites were put forward as suitable for housing by South Lakeland District Council at the examination of the Land Allocations DPD for the whole of the district. This inferred the acceptability of housing on both sites. The AONB DPD takes a different view and we are concerned that the sites put forward by SLDC on the back of a landscape evidence base at that time in 2012/2013 are now being rejected on landscape grounds. The landscape character of these sites has not changed over this time and neither has the overarching policy requirement relating to protected landscapes. Consequently, we ask for evidence of what has changed.
The site at Station Road is subject to a Key Settlement Landscape designation A18 and the site at Redhills Road is subject to the same designation, reference A15. This severely restricts development opportunity in Arnside, which is regarded by the South Lakeland District Council Core Strategy and the DPD itself as a Local Service Centre. We regard both sites as being sustainable sites within the settlement with the one at Station Road being next to an important public transport facility and, in our view, the lack of allocation of this sites is failing to create a vibrant, diverse and sustainable community at Arnside into the future on sites that have not previously been subject to concerns about landscape.
Site AS17, land off Queens Drive, is allocated for approximately 6 dwellings. However, the site is likely to yield as a maximum 6 dwellings and it is in effect a brownfield site with an existing garage block. On top of this presumably 50% affordable housing would be required. We simply do not see this as being deliverable with the 50% affordable housing policy and CIL.
Site AS18 may be developable but with 50% affordable housing requirement as well as the CIL, taken together with 6 dwellings being ambitious if the rear part of the site is not be used, we have concerns about deliverability.
Site AS19, Briery Bank, the same concerns apply to this site.
Policy AS23
This policy allocates Station Yard, Arnside, for mixed uses including some potential for residential live/work units, but this is noted as just potential so cannot be regarded as a housing allocation that will yield any particular number of units.
In our view, given the constraints identified, the effective allocation of housing for Arnside for the plan period is probably something in the order of 14 homes and we would question whether any can be delivered under the current affordable housing policy.
To turn to the lack of allocation of my client’s two sites, in an attempt to understand why my client’s sites have not been allocated a Landscape Analysis has been commissioned from the Landscape Agency.
From the start we have had concerns about comments that the sites are not suitable in landsape terms because they form part of the settlement and form the next logical areas for extension, with good access and infrastructure available and are sites that have development adjacent and are in part enclosed by it.
The Redhills Road site, A15, is a contained site bounded by residential development and the wooded slopes on the opposite side of the site. The constrained nature of the site limits the opportunities to appreciate this landscape within the wider context of Redhills Road, Arnside Knott and the AONB.
The site itself is open though, given the contained nature of it, the open site makes only a limited contribution to defining open space in the wider context due to its overlooked character.
In the light of the above the site has very limited wider visual connectivity with Redhills Road, Arnside Knott and the AONB, and that the experience of the site is overlooked by residential development. The loss of this space within the wider AONB and setting of Arnside would have a very limited visual impact on the character of the village. This is presumably why it was suggested for allocation by South Lakeland District Council in the first place during the 2012/2013 Land Allocations process.
We are encouraged by the fact that the Parish Council considered that some limited development can be accommodated at the site. We are also aware of a consultation response from a local resident who considers this site much more appropriate for development than one of the allocated sites.
A number of interventions could be made to assist with the development of any housing at the site. A generous open corridor could be maintained adjacent to the public right of way and properties could be set back from the Redhills Road frontage to maintain the line of development on Redhills Road.
Any development could ensure a high quality gable end to enhance property facing Redhills Road to provide a positive character to the street scene, which is highly visible in this location.
In addition it would be possible to maintain clear lines of sight along the green corridor, allowing additional tree planting to ensure that the existing woodland canopy is a dominant feature. This has the potential of offering the illusion of a more generous, uncluttered corridor and of course would also have ecological benefits.
An application is currently being considered for 5 dwellings at the west of the site; however, this does not preclude further development and given the previous landscape evidence we consider that the site remains to be suitable for allocations for a larger scheme.
In summary the visual containment of the site presents a good opportunity for residential development and the access opportunities are already there. At the western end of the site it is clear that there was an intention to extend into this area by the way in which development is terminated. Consequently, given the limitation of the sites allocated in terms of their overall numbers and quantum of development, taken together with their associated difficulties, it would seem perfectly reasonable to allocate at least part of this site for residential development.
With regard to the Station Road site you will be aware that Russell Armer have explored how this might be developed with South Lakeland District Council.
My client commissioned the Landscape Agency to prepare a response to the LVFSS recommendation and the finding of this response could allow South Lakeland District Council/Lancaster City Council to support the inclusion of site A24 for residential development.
As has been pointed out previously the site is essentially located within a developed area. Development is to four sides including Station Road and Ashleigh Court, Ashleigh Road and the southern farmstead. This existing development creates a strong sense of enclosure to the site and that anyone visiting has already arrived at Arnside. The character of development varies along these boundaries in scale, age and form which provides a disjointed and uncohesive character. We consider that this is not a strong representation of the built or landscape character of Arnside in this location for the following reasons:
- Ashleigh Court is a dominating structure within this view and is not characteristic to the scale of Arnside or its location.
- Existing development has already broken the natural skyline.
- A public right of way dissects the site connecting residential areas with the station.
- A distant view from the Station is only permitted in the south west over the rising fields between the developed edges of the site.
- The field view from the south west corner of the site is partially bounded with residential development which breaks the natural skyline.
- Views from B5282 are restricted by mature hedgerows and a high quantity of on street parking associated with the station.
- Views from the B5282 are limited to immediately adjacent to the site due to the dense development along the road. The volume of views from the B5282 are limited and experienced only briefly.
- Views from the station and footbridge are elevated. Views from this vantage point of the distant south west fields are a strong feature and development at low level would not obscure these views.
The Landscape Agency have made a number of recommendations which could bring benefits to the site in addition to the obvious provision of housing.
The low lying fields within site A24 would not restrict views of the distant farmland landscape to the south west from the railway station and therefore maintain the intrinsic existing urban pasture landscape character of the site.
The cohesive rounding off of the existing incremental stages of historic development and softening of the less characteristic development scale of Ashleigh Court will be a key benefit.
Positive reinforcement of the Station Road character by active frontages to the street would provide strategic opportunities to provide views of the distant fields between development.
This would also ensure that the Plan is justified, effective and consistent with national policy.

Development of the site could provide a stronger arrival experience for train users and for the general arrival experience to Arnside.
The key message from this consultation response is that we feel the document is generally over restrictive and, as it stands, fails to meet the needs of the local communities within the area, with particular reference to how the plan in its current form can create vibrant, diverse and sustainable communities with a strong sense of place and how it can maintain a thriving local economy.

Both of the above aspirations require some level of growth to ensure that as a place the AONB is sustainable into the future.

The AONB needs future growth to maintain the local economy and prevent further imbalance of the age structure within the area. We are not arguing that this should be at a cost to the purpose of conserving and enhancing the AONB but in our view the key challenge of such a document is to ensure how that growth fits within the context of protecting and enhancing the landscape and surely this should be the innovative approach, rather than the innovative approach being one of restriction.

Attachments:
- Redhills Road Plan.
- Station Road Plan.
- Landscape Agency Report: Redhills Road.
- Landscape Agency Report: Station Road.

Allocate Redhills Road Site Ref A15 and Station Road Site A18 to ensure a greater level of provision that is likely to be deliverable. The requirement for 50% affordable housing is untenable and will not deliver any affordable housing. This should be reduced to a maximum of 35% as per the wider requirement in South Lakeland.
Greater emphasis should be placed on the NPPF and Core Strategy be ensure
compliance with the NPPF (Criteria 4).

Yes, I wish to participate at the oral examination

Please notify me

I have read the guidance notes

1.2.4

Yes

No

The DPD is not positively prepared

The DPD is not justified

The DPD is not effective

The DPD is not consistent with national policy

This response is written on behalf of Russell Armer Homes and represents a general response in relation to the policies contained within the DPD, followed by reference to two specific sites that have been put forward by my client at Arnside. The two sites have not been taken forward into this document and they have previously been referenced as:
* Redhills Road Site Reference A15; and
* Station Road Site Reference A18.
Plans of these sites are attached to this representation.
This consultation response works through the DPD document quoting the paragraph number of any paragraphs that we wish to make comment upon.

Paragraph 1.2.4
With regard to paragraph 1.2.4 of the DPD it is noted that an emphasis is placed upon the Arnside & Silverdale Statutory Management Plan 2014. This document sets out the overall strategy for managing, conserving and enhancing the AONB. While the Statutory Management Plan is an important over-arching document for the area, it does not form part of the Development Plan and we are of the view that too great an emphasis has been placed upon following a plan which has a strategy that involves much more than development, yet it has been used as a strategic director for the AONB DPD.
[SEE ATTACHED DOCUMENT FOR ADDITIONAL REFERENCES TO THE DPD]

Allocate Redhills Road Site Ref A15 and Station Road Site A18 to ensure a greater level of provision that is likely to be deliverable. The requirement for 50% affordable housing is untenable and will not deliver any affordable housing. This should be reduced to a maximum of 35% as per the wider requirement in South Lakeland.
Greater emphasis should be placed on the NPPF and Core Strategy be ensure
compliance with the NPPF (Criteria 4).

Yes, I wish to participate at the oral examination

Please notify me

I have read the guidance notes

1.2.7

Yes

No

The DPD is not positively prepared

The DPD is not justified

The DPD is not effective

The DPD is not consistent with national policy

This response is written on behalf of Russell Armer Homes and represents a general response in relation to the policies contained within the DPD, followed by reference to two specific sites that have been put forward by my client at Arnside. The two sites have not been taken forward into this document and they have previously been referenced as:
* Redhills Road Site Reference A15; and
* Station Road Site Reference A18.
Plans of these sites are attached to this representation.
This consultation response works through the DPD document quoting the paragraph number of any paragraphs that we wish to make comment upon.

Paragraph 1.2.7
It is noted that the AONB covers 75 km² with a population of around 7,800. The main settlements are Arnside, Warton, Silverdale and Storth/Sandside but Arnside is the largest settlement within the AONB and was identified by the South Lakeland Core Strategy as a Local Service Centre, where policy CS1.2 of the Core Strategy sets out that 21% of new housing and employment development would be in the network of Local Service Centres.

We view the population of the AONB at approximately 7,800, and that of Arnside itself, as significant and presumably South Lakeland were of the same view when their Core Strategy identified Arnside as a Local Service Centre.

The Arnside & Silverdale AONB is quite heavily populated for its size when considered against many larger AONBs with much sparser population densities. The reason this is mentioned is because there is clearly a significant functioning population within the area and at Arnside in particular that requires a level of services and commensurate growth to ensure that the AONB functions as a sustainable economy and as a place for people to live and work. Consequently, the Plan is questioned in terms of its compliance with the NPPF and how effective the Plan is in responding to the needs of the area.

This is of particular concern given that the Arnside & Silverdale AONB is possibly the smallest AONB in England and Wales, while it has a significant population. Some comparisons of population by area for other AONBs within England and Wales are set out below: [SEE ATTACHED DOCUMENT]

[SEE ATTACHED DOCUMENT FOR ADDITIONAL REFERENCES TO THE DPD]

Allocate Redhills Road Site Ref A15 and Station Road Site A18 to ensure a greater level of provision that is likely to be deliverable. The requirement for 50% affordable housing is untenable and will not deliver any affordable housing. This should be reduced to a maximum of 35% as per the wider requirement in South Lakeland.
Greater emphasis should be placed on the NPPF and Core Strategy be ensure
compliance with the NPPF (Criteria 4).

Yes, I wish to participate at the oral examination

Please notify me

I have read the guidance notes

1.3.13

Yes

No

The DPD is not positively prepared

The DPD is not justified

The DPD is not effective

The DPD is not consistent with national policy

Paragraph 1.3.13
This paragraph of the DPD sets out that the relevant parts of the South Lakeland Local Plan include the Core Strategy 2010, which sets out the overall development strategy and vision for the district. This includes identifying Arnside as a Local Service Centre. It is welcomed that Arnside is indicated as a Local Service Centre by Policy AS01.

Arnside is one of the largest villages in Cumbria and the largest within the AONB. At the 2011 Census it had a population of 2,235. Over 40% of the population are over 65. This is compared to 17.7% as a national (UK) average in 2014. We would question whether the sites put forward later in the document really meet the needs of the community (their effectiveness) and whether they are likely to result in any new house building being brought forward within the AONB given the limited number of sites put forward and the constraints associated with them, some of which are derived from policies within this document (e.g. the affordable housing target).
[SEE ATTACHED DOCUMENT FOR ADDITIONAL REFERENCES TO THE DPD]

Allocate Redhills Road Site Ref A15 and Station Road Site A18 to ensure a greater level of provision that is likely to be deliverable. The requirement for 50% affordable housing is untenable and will not deliver any affordable housing. This should be reduced to a maximum of 35% as per the wider requirement in South Lakeland.
Greater emphasis should be placed on the NPPF and Core Strategy be ensure
compliance with the NPPF (Criteria 4).

Yes, I wish to participate at the oral examination

Please notify me

I have read the guidance notes

1.3.15

Yes

No

The DPD is not positively prepared

The DPD is not justified

The DPD is not effective

The DPD is not consistent with national policy

This response is written on behalf of Russell Armer Homes and represents a general response in relation to the policies contained within the DPD, followed by reference to two specific sites that have been put forward by my client at Arnside. The two sites have not been taken forward into this document and they have previously been referenced as:
* Redhills Road Site Reference A15; and
* Station Road Site Reference A18.
Plans of these sites are attached to this representation.
This consultation response works through the DPD document quoting the paragraph number of any paragraphs that we wish to make comment upon.

Paragraph 1.3.15
This paragraph points out that the statutory AONB Management Plan is a critical document. It accepts that the document is not part of the Local Plan for the area but that it is a material consideration in making planning decisions. With regard to this it is again emphasised that while this is an important material consideration, it is not part of the Development Plan and the Core Strategy that indicates Arnside as a Local Service Centre is. We feel there is an imbalance between the emphasis upon the AONB Management Plan and the existing Core Strategy for the area. It is important that the AONB designation has not changed in its legislative position or level of protection since the Core Strategy was adopted in 2010. Consequently the effectiveness and compliance of the Plan with the NPPF is questioned.
[SEE ATTACHED DOCUMENT FOR ADDITIONAL REFERENCES TO THE DPD]

Allocate Redhills Road Site Ref A15 and Station Road Site A18 to ensure a greater level of provision that is likely to be deliverable. The requirement for 50% affordable housing is untenable and will not deliver any affordable housing. This should be reduced to a maximum of 35% as per the wider requirement in South Lakeland.
Greater emphasis should be placed on the NPPF and Core Strategy be ensure
compliance with the NPPF (Criteria 4).

Yes, I wish to participate at the oral examination

Please notify me

I have read the guidance notes

2.1.2

Yes

No

The DPD is not positively prepared

The DPD is not justified

The DPD is not effective

The DPD is not consistent with national policy

This response is written on behalf of Russell Armer Homes and represents a general response in relation to the policies contained within the DPD, followed by reference to two specific sites that have been put forward by my client at Arnside. The two sites have not been taken forward into this document and they have previously been referenced as:
* Redhills Road Site Reference A15; and
* Station Road Site Reference A18.
Plans of these sites are attached to this representation.
This consultation response works through the DPD document quoting the paragraph number of any paragraphs that we wish to make comment upon.


Paragraph 2.1.2
Under section 2 of the Plan Vision and Objectives, paragraph 2.1.2 considers that the vision of the AONB DPD is to reflect and supplement the adopted Management Plan Vision as well as the two relevant Local Plans, national policy and the evidence gathered and the wider context. The text in the box below paragraph 2.1.2 considers that within the Arnside & Silverdale AONB:
- housing, employment, services, infrastructure and other development has managed to contribute towards meeting the needs of those who live in, work and visit the area in a way that conserves and enhances the landscape, natural beauty and the special qualities of the AONB;
- creates vibrant, diverse and sustainable communities with a strong sense of place; and
- maintains a thriving local economy.
With regard to this part of the vision the Plan does not meet the needs of those who live, work and visit the area in a way that will create vibrant, diverse and sustainable communities. We are of the view that the allocations put forward within the document will not be brought forward and therefore this vision will not be achieved and neither would the aspiration of maintaining a thriving local economy with a vibrant, diverse and sustainable community.
[SEE ATTACHED DOCUMENT FOR ADDITIONAL REFERENCES TO THE DPD]

Allocate Redhills Road Site Ref A15 and Station Road Site A18 to ensure a greater level of provision that is likely to be deliverable. The requirement for 50% affordable housing is untenable and will not deliver any affordable housing. This should be reduced to a maximum of 35% as per the wider requirement in South Lakeland.
Greater emphasis should be placed on the NPPF and Core Strategy be ensure
compliance with the NPPF (Criteria 4).

Yes, I wish to participate at the oral examination

Please notify me

I have read the guidance notes

2.2.1

Yes

No

The DPD is not positively prepared

The DPD is not justified

The DPD is not effective

The DPD is not consistent with national policy

This response is written on behalf of Russell Armer Homes and represents a general response in relation to the policies contained within the DPD, followed by reference to two specific sites that have been put forward by my client at Arnside. The two sites have not been taken forward into this document and they have previously been referenced as:
* Redhills Road Site Reference A15; and
* Station Road Site Reference A18.
Plans of these sites are attached to this representation.
This consultation response works through the DPD document quoting the paragraph number of any paragraphs that we wish to make comment upon.
Paragraph 2.2.1
Under this paragraph, Objectives, the fourth objective is to provide a sufficient supply and mix of high quality housing to contribute to meeting the needs of the AONB’s communities, with an emphasis on affordable housing and protecting the landscape character. However, given the limited number of allocated sites and the policy requirements (affordable housing) it is considered that the allocations put forward will not meet the objective to provide a sufficient supply and mix of high quality housing and therefore cannot be deemed to be positively prepared or effective.
[SEE ATTACHED DOCUMENT FOR ADDITIONAL REFERENCES TO THE DPD]

Allocate Redhills Road Site Ref A15 and Station Road Site A18 to ensure a greater level of provision that is likely to be deliverable. The requirement for 50% affordable housing is untenable and will not deliver any affordable housing. This should be reduced to a maximum of 35% as per the wider requirement in South Lakeland.
Greater emphasis should be placed on the NPPF and Core Strategy be ensure
compliance with the NPPF (Criteria 4).

Yes, I wish to participate at the oral examination

Please notify me

I have read the guidance notes

3.1.3

Yes

No

The DPD is not positively prepared

The DPD is not justified

The DPD is not effective

The DPD is not consistent with national policy

This response is written on behalf of Russell Armer Homes and represents a general response in relation to the policies contained within the DPD, followed by reference to two specific sites that have been put forward by my client at Arnside. The two sites have not been taken forward into this document and they have previously been referenced as:
* Redhills Road Site Reference A15; and
* Station Road Site Reference A18.
Plans of these sites are attached to this representation.
This consultation response works through the DPD document quoting the paragraph number of any paragraphs that we wish to make comment upon.

Paragraph 3.1.3 to 3.1.7
These paragraphs relate to objectively assessed needs and the text points out that it is difficult to apportion a specific figure to the AONB as a whole or in line with the two Authority parts, and that no precedent exists for such an approach.
[SEE ATTACHED DOCUMENT FOR ADDITIONAL REFERENCES TO THE DPD]

Allocate Redhills Road Site Ref A15 and Station Road Site A18 to ensure a greater level of provision that is likely to be deliverable. The requirement for 50% affordable housing is untenable and will not deliver any affordable housing. This should be reduced to a maximum of 35% as per the wider requirement in South Lakeland.
Greater emphasis should be placed on the NPPF and Core Strategy be ensure
compliance with the NPPF (Criteria 4).

Yes, I wish to participate at the oral examination

Please notify me

I have read the guidance notes

3.1.4

Yes

No

The DPD is not positively prepared

The DPD is not justified

The DPD is not effective

The DPD is not consistent with national policy

This response is written on behalf of Russell Armer Homes and represents a general response in relation to the policies contained within the DPD, followed by reference to two specific sites that have been put forward by my client at Arnside. The two sites have not been taken forward into this document and they have previously been referenced as:
* Redhills Road Site Reference A15; and
* Station Road Site Reference A18.
Plans of these sites are attached to this representation.
This consultation response works through the DPD document quoting the paragraph number of any paragraphs that we wish to make comment upon.

Paragraph 3.1.4 considers that it is not necessary to identify a specific housing requirement for the AONB and that an emphasis should be placed on meeting identified affordable and other local housing needs within the capacity of the landscape.

The conclusion of the approach to housing is that the difficulties in apportioning the OAN, and the limited capacity of the landscape to accommodate development, means that the Councils have not identified a specific housing requirement for the AONB. Interestingly, despite this the Guidance Notes for this consultation note that to be positively prepared the DPD should be based upon a strategy that seeks to meet objectively assessed development and infrastructure requirements. However, regardless of the need for the Plan to meet the OANor not it must still fulfil its objectives of creating vibrant, diverse and sustainable communities and also maintaining a thriving local economy.
The restrictive approach to housing does not, in our view, achieve that given the restrictive policies and the cumulative policy impacts upon viability. Consequently, the effectiveness and compliance of the Plan is questioned given that the NPPF is overtly focused upon growth, while accepting that this must be filtered by paragraph 115 of the NPPF.
In the light of the information presented above about the age structure of the population of the AONB there is a particular issue with regard to the ageing population and there will be a continuing requirement for a range of services to meet the needs of that elderly population. This can only be based upon new development to maintain a working age population, including new houses that will create a sustainable population to meet those needs. The primary school also needs to be sustained into the future and the level of growth allowed for is unlikely to assist this.
The Plan must be compatible with the South Lakeland Core Strategy and the vision within that Core Strategy for the eastern part of the district. However the DPD appears to lean heavily towards the Management Plan as opposed to the Core Strategy. Again it is emphasised that the Management Plan is not a land use planning document.

[SEE ATTACHED DOCUMENT FOR ADDITIONAL REFERENCES TO THE DPD]

Allocate Redhills Road Site Ref A15 and Station Road Site A18 to ensure a greater level of provision that is likely to be deliverable. The requirement for 50% affordable housing is untenable and will not deliver any affordable housing. This should be reduced to a maximum of 35% as per the wider requirement in South Lakeland.
Greater emphasis should be placed on the NPPF and Core Strategy be ensure
compliance with the NPPF (Criteria 4).

Yes, I wish to participate at the oral examination

Please notify me

I have read the guidance notes

3.1.7

Yes

No

The DPD is not positively prepared

The DPD is not justified

The DPD is not effective

The DPD is not consistent with national policy

This response is written on behalf of Russell Armer Homes and represents a general response in relation to the policies contained within the DPD, followed by reference to two specific sites that have been put forward by my client at Arnside. The two sites have not been taken forward into this document and they have previously been referenced as:
* Redhills Road Site Reference A15; and
* Station Road Site Reference A18.
Plans of these sites are attached to this representation.
This consultation response works through the DPD document quoting the paragraph number of any paragraphs that we wish to make comment upon.

Paragraph 3.1.7 notes that the Councils have not sought to set targets for the amount of development to be achieved but that this should be achieved within what can be accommodated without harm to landscape, whilst maintaining a positive approach. Without a clear picture of what the specific needs are within the AONB we feel that the wider approach of the plan in relation to the allocation of sites is overly restrictive. Work that we have carried out on 2 sites in Arnside indicates that there would not be any unacceptable harm to the landscape of the AONB. The key point is that they are both located within the Local Service Centre of Arnside where the approach would anticipate development in principle. However, despite the professional landscape evidence put forward the sites have been designated as Key Settlement Landscapes.

[SEE ATTACHED DOCUMENT FOR ADDITIONAL REFERENCES TO THE DPD]

Allocate Redhills Road Site Ref A15 and Station Road Site A18 to ensure a greater level of provision that is likely to be deliverable. The requirement for 50% affordable housing is untenable and will not deliver any affordable housing. This should be reduced to a maximum of 35% as per the wider requirement in South Lakeland.
Greater emphasis should be placed on the NPPF and Core Strategy be ensure
compliance with the NPPF (Criteria 4).

Yes, I wish to participate at the oral examination

Please notify me

I have read the guidance notes

4.1.3

Yes

No

The DPD is not positively prepared

The DPD is not justified

The DPD is not effective

The DPD is not consistent with national policy

This response is written on behalf of Russell Armer Homes and represents a general response in relation to the policies contained within the DPD, followed by reference to two specific sites that have been put forward by my client at Arnside. The two sites have not been taken forward into this document and they have previously been referenced as:
* Redhills Road Site Reference A15; and
* Station Road Site Reference A18.
Plans of these sites are attached to this representation.
This consultation response works through the DPD document quoting the paragraph number of any paragraphs that we wish to make comment upon.

Paragraph 4.1.3
This paragraph notes that a requirement for 50% of new homes to be affordable is justified because the AONB is a sensitive landscape protected at a national level. It is considered inappropriate to use those sites that are suitable for development in the AONB to deliver development that does not help to meet local affordable or other local needs. The paragraph goes on to note that doing so would mean that those needs would remain unmet and the most sensitive sites would have to be developed in order to meet the affordable needs.
We have particular concern about this because it appears that a landscape approach is being used to identify the level of affordable housing provision as opposed to a viability approach. It is our view that the housing policy and strategy would fail with such a high level of affordable requirement, but it appears from the policy that this is being justified on landscape grounds rather than viability grounds. This creates a clear tension between the aspirations of the document to serve the landscape character and to provide a high level of affordable housing.
We noted that the viability report originally produced by HDH in support of the Draft Plan recognised that no sites would be viable under a 50% affordable policy. It was further noted at the time by HDH that even under the Council’s current adopted target of 35% in the South Lakeland District a number of sites would not be viable. In terms of the original HDH viability report it was noted that South Lakeland District Council achieves 35% affordable housing on almost all target sites. However, we would have some concerns for the following reasons:
- The sites achieving 35% are generally large scale, greenfield sites providing economies of scale.
- Much of this track record of achieving 35% is prior to the introduction of the Community Infrastructure Levy (CIL).
- The larger sites often have fewer constraints than those put forward by the AONB DPD.
- Drainage requirements are becoming stricter and this has a significant impact on viability.
With regard to viability we have concerns as to why the HDH report considers that no sites were viable under a 50% affordable housing policy, but the latest viability study contained within the DPD document library considers that 50% affordable even with CIL is considered to be viable.
The conclusions are based on a broad set of assumptions and typologies for the sites put forward. However, my client’s experience on a site by site basis as a developer that has a long history of working in the area and within the challenging landscapes and topographies associated with it, is that this broad based approach does not take account of the reality of developing particular sites.
For instance, many of the sites within the AONB that are allocated have some difficult topography, access or drainage requirements.
It is noted that in paragraph 4.71 of the Aspinall Verdi report that the TLVs are for higher level plan viability purposes. The report does emphasise that the adoption of a particular TLV in no way implies that this figure can be used by applicants to negotiate site specific applications. It goes on to note that where sites have obvious abnormal costs (e.g. retaining walls for sloping sites) these costs should be deducted from the value of the land. We would question where this assumption comes from given that it is the Council’s role to provide a supply of and policies for housing within any given area. We are concerned about the statement that costs for abnormals should be deducted from the value of the land and we would disagree with this approach given it is the Local Authorities responsibility to provide appropriate housing policies. However, we have been in discussions on a number of sites elsewhere where the view of the Local Authority is that the pain of abnormal costs should be shared across all parties, including the affordable housing percentage, landowner and developer profits. However, simply directing abnormals to a reduction in the value of the land will, again, result in proposals not being brought forward.
We have concerns that the build costs will not necessarily reflect the higher quality required within the AONB. We also have concern that the affordable housing prices are based on a low specification and not a high specification that would be required within the AONB.
We note that originally the viability appraisals were run at 17.5% profit to the developer, but this has been raised to 20%. We do not see why 20% should necessarily be an upper limit but in our view this should be a minimal margin. In addition 20% would be an OMV only. On affordable housing we understand that this would be 6%, giving a blended rate across a site at well below 20%.
We would also point out that the allocations put forward largely rely upon small and medium sized developers bringing sites forward. The sites would be likely to attract small or medium sized builders who do not have the economies of scale of medium and larger sized developers and, consequently, we would question the practical deliverability of the sites other than in theoretical plan form. This questions whether the Plan is positively prepared and effective in bringing housing development forward.

[SEE ATTACHED DOCUMENT FOR ADDITIONAL REFERENCES TO THE DPD]

Allocate Redhills Road Site Ref A15 and Station Road Site A18 to ensure a greater level of provision that is likely to be deliverable. The requirement for 50% affordable housing is untenable and will not deliver any affordable housing. This should be reduced to a maximum of 35% as per the wider requirement in South Lakeland.
Greater emphasis should be placed on the NPPF and Core Strategy be ensure
compliance with the NPPF (Criteria 4).

Yes, I wish to participate at the oral examination

Please notify me

I have read the guidance notes

4.2.8

Yes

No

The DPD is not positively prepared

The DPD is not justified

The DPD is not effective

The DPD is not consistent with national policy

This response is written on behalf of Russell Armer Homes and represents a general response in relation to the policies contained within the DPD, followed by reference to two specific sites that have been put forward by my client at Arnside. The two sites have not been taken forward into this document and they have previously been referenced as:
* Redhills Road Site Reference A15; and
* Station Road Site Reference A18.
Plans of these sites are attached to this representation.
This consultation response works through the DPD document quoting the paragraph number of any paragraphs that we wish to make comment upon.

Paragraph 4.2.8
This paragraph states that all planning applications will need to be accompanied by ecological surveys that are proportionate to the nature and scale of the development. However, it will be the case that some very small scale developments that require planning permission would clearly not need an ecological survey and this should be made clear either in the policy or the text supporting it.
[SEE ATTACHED DOCUMENT FOR ADDITIONAL REFERENCES TO THE DPD]

Allocate Redhills Road Site Ref A15 and Station Road Site A18 to ensure a greater level of provision that is likely to be deliverable. The requirement for 50% affordable housing is untenable and will not deliver any affordable housing. This should be reduced to a maximum of 35% as per the wider requirement in South Lakeland.
Greater emphasis should be placed on the NPPF and Core Strategy be ensure
compliance with the NPPF (Criteria 4).

Yes, I wish to participate at the oral examination

Please notify me

I have read the guidance notes

AS01 - Development Strategy

Yes

No

The DPD is not positively prepared

The DPD is not justified

The DPD is not effective

The DPD is not consistent with national policy

This response is written on behalf of Russell Armer Homes and represents a general response in relation to the policies contained within the DPD, followed by reference to two specific sites that have been put forward by my client at Arnside. The two sites have not been taken forward into this document and they have previously been referenced as:
* Redhills Road Site Reference A15; and
* Station Road Site Reference A18.
Plans of these sites are attached to this representation.
This consultation response works through the DPD document quoting the paragraph number of any paragraphs that we wish to make comment upon.

Policy AS01, Development Strategy
In terms of this policy the reference to Local Service Centres within the policy is welcomed. The policy itself considers that to promote vibrant local communities and to support services small scale growth and investment will be supported in the identified Local Service Centres where it closely reflects identified local needs within the AONB and conserves and enhances landscape and settlement character. The reference to Arnside being a Local Service Centre is welcomed. However, there is some concern about the definition of small scale growth and what this means when such a definition is not included within policy CS1.2, the development strategy of South Lakeland District Council’s Core Strategy document. Reference to policy CS1.2 of the Core Strategy considers that the exact scale and level of development supported will be dependent upon individual character, impacts on environmental capacity and infrastructure provision. We are of the view that this element of Core Strategy policy CS1.2 should be contained within policy AS01, Development Strategy, so that the DPD is consistent with the Core Strategy and also to ensure that decisions are based on the characteristics of a particular development project rather than a reference to “small scale” which is not a defined concept.
[SEE ATTACHED DOCUMENT FOR ADDITIONAL REFERENCES TO THE DPD]

Allocate Redhills Road Site Ref A15 and Station Road Site A18 to ensure a greater level of provision that is likely to be deliverable. The requirement for 50% affordable housing is untenable and will not deliver any affordable housing. This should be reduced to a maximum of 35% as per the wider requirement in South Lakeland.
Greater emphasis should be placed on the NPPF and Core Strategy be ensure
compliance with the NPPF (Criteria 4).

Yes, I wish to participate at the oral examination

Please notify me

I have read the guidance notes

AS02 - Landscape

Yes

No

The DPD is not positively prepared

The DPD is not justified

The DPD is not effective

The DPD is not consistent with national policy

This response is written on behalf of Russell Armer Homes and represents a general response in relation to the policies contained within the DPD, followed by reference to two specific sites that have been put forward by my client at Arnside. The two sites have not been taken forward into this document and they have previously been referenced as:
* Redhills Road Site Reference A15; and
* Station Road Site Reference A18.
Plans of these sites are attached to this representation.
This consultation response works through the DPD document quoting the paragraph number of any paragraphs that we wish to make comment upon.

Policy AS02, Landscape
With regard to this policy we have noted that certain changes have been made since our last representation and would generally welcome those changes. However, from the final criteria of this policy it appears that a landscape assessment could be required for any level of development and in our view reference should be made within this to whether one will be required or not, as it should be proportionate to the scale of the proposal and the level of impact as well as the scale of development, indicating the scale of the landscape study required. It may be disproportionate to ask for a landscape study for, for instance, an infill plot or a house extension. Officer discretion needs to be allowed.
[SEE ATTACHED DOCUMENT FOR ADDITIONAL REFERENCES TO THE DPD]

Allocate Redhills Road Site Ref A15 and Station Road Site A18 to ensure a greater level of provision that is likely to be deliverable. The requirement for 50% affordable housing is untenable and will not deliver any affordable housing. This should be reduced to a maximum of 35% as per the wider requirement in South Lakeland.
Greater emphasis should be placed on the NPPF and Core Strategy be ensure
compliance with the NPPF (Criteria 4).

Yes, I wish to participate at the oral examination

Please notify me

I have read the guidance notes

AS03 - Housing Provision

Yes

No

The DPD is not positively prepared

The DPD is not justified

The DPD is not effective

The DPD is not consistent with national policy

This response is written on behalf of Russell Armer Homes and represents a general response in relation to the policies contained within the DPD, followed by reference to two specific sites that have been put forward by my client at Arnside. The two sites have not been taken forward into this document and they have previously been referenced as:
* Redhills Road Site Reference A15; and
* Station Road Site Reference A18.
Plans of these sites are attached to this representation.
This consultation response works through the DPD document quoting the paragraph number of any paragraphs that we wish to make comment upon.

Policy AS03, Housing Provision
The comments in relation to the nature of the population within the AONB and whether the Plan meets the needs of the area as a sustainable community moving forward goes to the heart of policy AS03.
This policy stipulates that proposals for new housing development will be supported where they deliver no less than 50% affordable housing and that only where this is demonstrably unachievable will a lower percentage be acceptable. The policy considers that affordable housing needs are forecast to apply over a period of time and that not all of the identified need is required straightway and that, consequently, this should be phased in line with demand. However, we consider that a 50% requirement is not viable and sets very high expectations within local communities that should not be raised. My client, Russell Armer, as a developer within Cumbria and North Lancashire for a number of years, does not see anything in the Plan that would sponsor this level of provision. The specific site constraints and the number of houses that can be achieved from each site allocated, in our view, strongly mitigates against any aspiration to provide 50% affordable. An approach via a Supplementary Planning Document called I-Path was introduced in South Lakeland some years ago which required 50% affordable housing. However this policy was abandoned and any such approach would now be further compounded by the requirements of the Community Infrastructure Levy which would apply within the South Lakeland part of the AONB, in which Arnside is located.
[SEE ATTACHED DOCUMENT FOR ADDITIONAL REFERENCES TO THE DPD]

Allocate Redhills Road Site Ref A15 and Station Road Site A18 to ensure a greater level of provision that is likely to be deliverable. The requirement for 50% affordable housing is untenable and will not deliver any affordable housing. This should be reduced to a maximum of 35% as per the wider requirement in South Lakeland.
Greater emphasis should be placed on the NPPF and Core Strategy be ensure
compliance with the NPPF (Criteria 4).

Yes, I wish to participate at the oral examination

Please notify me

I have read the guidance notes

AS08 - Design

Yes

No

The DPD is not positively prepared

The DPD is not justified

The DPD is not effective

The DPD is not consistent with national policy

This response is written on behalf of Russell Armer Homes and represents a general response in relation to the policies contained within the DPD, followed by reference to two specific sites that have been put forward by my client at Arnside. The two sites have not been taken forward into this document and they have previously been referenced as:
* Redhills Road Site Reference A15; and
* Station Road Site Reference A18.
Plans of these sites are attached to this representation.
This consultation response works through the DPD document quoting the paragraph number of any paragraphs that we wish to make comment upon.

Policy AS08, Design
With regard to this policy there are no particular comments but the requirements would appear to be in excess of those required throughout South Lakeland and we would ask for evidence that this has been factored into the viability considerations outlined above.
[SEE ATTACHED DOCUMENT FOR ADDITIONAL REFERENCES TO THE DPD]

Allocate Redhills Road Site Ref A15 and Station Road Site A18 to ensure a greater level of provision that is likely to be deliverable. The requirement for 50% affordable housing is untenable and will not deliver any affordable housing. This should be reduced to a maximum of 35% as per the wider requirement in South Lakeland.
Greater emphasis should be placed on the NPPF and Core Strategy be ensure
compliance with the NPPF (Criteria 4).

Yes, I wish to participate at the oral examination

Please notify me

I have read the guidance notes

AS23(A26/A27) - Station Yard, Arnside

Yes

No

The DPD is not positively prepared

The DPD is not justified

The DPD is not effective

The DPD is not consistent with national policy

This response is written on behalf of Russell Armer Homes and represents a general response in relation to the policies contained within the DPD, followed by reference to two specific sites that have been put forward by my client at Arnside. The two sites have not been taken forward into this document and they have previously been referenced as:
* Redhills Road Site Reference A15; and
* Station Road Site Reference A18.
Plans of these sites are attached to this representation.
This consultation response works through the DPD document quoting the paragraph number of any paragraphs that we wish to make comment upon.

Policy AS23
This policy allocates Station Yard, Arnside, for mixed uses including some potential for residential live/work units, but this is noted as just potential so cannot be regarded as a housing allocation that will yield any particular number of units.
In our view, given the constraints identified, the effective allocation of housing for Arnside for the plan period is probably something in the order of 14 homes and we would question whether any can be delivered under the current affordable housing policy.
To turn to the lack of allocation of my client’s two sites, in an attempt to understand why my client’s sites have not been allocated a Landscape Analysis has been commissioned from the Landscape Agency.
From the start we have had concerns about comments that the sites are not suitable in landsape terms because they form part of the settlement and form the next logical areas for extension, with good access and infrastructure available and are sites that have development adjacent and are in part enclosed by it.
The Redhills Road site, A15, is a contained site bounded by residential development and the wooded slopes on the opposite side of the site. The constrained nature of the site limits the opportunities to appreciate this landscape within the wider context of Redhills Road, Arnside Knott and the AONB.
The site itself is open though, given the contained nature of it, the open site makes only a limited contribution to defining open space in the wider context due to its overlooked character.
In the light of the above the site has very limited wider visual connectivity with Redhills Road, Arnside Knott and the AONB, and that the experience of the site is overlooked by residential development. The loss of this space within the wider AONB and setting of Arnside would have a very limited visual impact on the character of the village. This is presumably why it was suggested for allocation by South Lakeland District Council in the first place during the 2012/2013 Land Allocations process.
We are encouraged by the fact that the Parish Council considered that some limited development can be accommodated at the site. We are also aware of a consultation response from a local resident who considers this site much more appropriate for development than one of the allocated sites.
A number of interventions could be made to assist with the development of any housing at the site. A generous open corridor could be maintained adjacent to the public right of way and properties could be set back from the Redhills Road frontage to maintain the line of development on Redhills Road.
Any development could ensure a high quality gable end to enhance property facing Redhills Road to provide a positive character to the street scene, which is highly visible in this location.
In addition it would be possible to maintain clear lines of sight along the green corridor, allowing additional tree planting to ensure that the existing woodland canopy is a dominant feature. This has the potential of offering the illusion of a more generous, uncluttered corridor and of course would also have ecological benefits.
An application is currently being considered for 5 dwellings at the west of the site; however, this does not preclude further development and given the previous landscape evidence we consider that the site remains to be suitable for allocations for a larger scheme.
In summary the visual containment of the site presents a good opportunity for residential development and the access opportunities are already there. At the western end of the site it is clear that there was an intention to extend into this area by the way in which development is terminated. Consequently, given the limitation of the sites allocated in terms of their overall numbers and quantum of development, taken together with their associated difficulties, it would seem perfectly reasonable to allocate at least part of this site for residential development.
With regard to the Station Road site you will be aware that Russell Armer have explored how this might be developed with South Lakeland District Council.
My client commissioned the Landscape Agency to prepare a response to the LVFSS recommendation and the finding of this response could allow South Lakeland District Council/Lancaster City Council to support the inclusion of site A24 for residential development.
As has been pointed out previously the site is essentially located within a developed area. Development is to four sides including Station Road and Ashleigh Court, Ashleigh Road and the southern farmstead. This existing development creates a strong sense of enclosure to the site and that anyone visiting has already arrived at Arnside. The character of development varies along these boundaries in scale, age and form which provides a disjointed and uncohesive character. We consider that this is not a strong representation of the built or landscape character of Arnside in this location for the following reasons:
- Ashleigh Court is a dominating structure within this view and is not characteristic to the scale of Arnside or its location.
- Existing development has already broken the natural skyline.
- A public right of way dissects the site connecting residential areas with the station.
- A distant view from the Station is only permitted in the south west over the rising fields between the developed edges of the site.
- The field view from the south west corner of the site is partially bounded with residential development which breaks the natural skyline.
- Views from B5282 are restricted by mature hedgerows and a high quantity of on street parking associated with the station.
- Views from the B5282 are limited to immediately adjacent to the site due to the dense development along the road. The volume of views from the B5282 are limited and experienced only briefly.
- Views from the station and footbridge are elevated. Views from this vantage point of the distant south west fields are a strong feature and development at low level would not obscure these views.
The Landscape Agency have made a number of recommendations which could bring benefits to the site in addition to the obvious provision of housing.
The low lying fields within site A24 would not restrict views of the distant farmland landscape to the south west from the railway station and therefore maintain the intrinsic existing urban pasture landscape character of the site.
The cohesive rounding off of the existing incremental stages of historic development and softening of the less characteristic development scale of Ashleigh Court will be a key benefit.
Positive reinforcement of the Station Road character by active frontages to the street would provide strategic opportunities to provide views of the distant fields between development.
This would also ensure that the Plan is justified, effective and consistent with national policy.

Development of the site could provide a stronger arrival experience for train users and for the general arrival experience to Arnside.
The key message from this consultation response is that we feel the document is generally over restrictive and, as it stands, fails to meet the needs of the local communities within the area, with particular reference to how the plan in its current form can create vibrant, diverse and sustainable communities with a strong sense of place and how it can maintain a thriving local economy.

Both of the above aspirations require some level of growth to ensure that as a place the AONB is sustainable into the future.

The AONB needs future growth to maintain the local economy and prevent further imbalance of the age structure within the area. We are not arguing that this should be at a cost to the purpose of conserving and enhancing the AONB but in our view the key challenge of such a document is to ensure how that growth fits within the context of protecting and enhancing the landscape and surely this should be the innovative approach, rather than the innovative approach being one of restriction.
[SEE ATTACHED DOCUMENT FOR ADDITIONAL REFERENCES TO THE DPD]

Allocate Redhills Road Site Ref A15 and Station Road Site A18 to ensure a greater level of provision that is likely to be deliverable. The requirement for 50% affordable housing is untenable and will not deliver any affordable housing. This should be reduced to a maximum of 35% as per the wider requirement in South Lakeland.
Greater emphasis should be placed on the NPPF and Core Strategy be ensure
compliance with the NPPF (Criteria 4).

Yes, I wish to participate at the oral examination

Please notify me

I have read the guidance notes

AS17(A6) - Land off Queen's Drive, Arnside

Yes

No

The DPD is not effective

The DPD is not consistent with national policy

The DPD is not positively prepared

The DPD is not justified

This response is written on behalf of Russell Armer Homes and represents a general response in relation to the policies contained within the DPD, followed by reference to two specific sites that have been put forward by my client at Arnside. The two sites have not been taken forward into this document and they have previously been referenced as:
* Redhills Road Site Reference A15; and
* Station Road Site Reference A18.
Plans of these sites are attached to this representation.
This consultation response works through the DPD document quoting the paragraph number of any paragraphs that we wish to make comment upon.

Site AS17, land off Queens Drive, is allocated for approximately 6 dwellings. However, the site is likely to yield as a maximum 6 dwellings and it is in effect a brownfield site with an existing garage block. On top of this presumably 50% affordable housing would be required. We simply do not see this as being deliverable with the 50% affordable housing policy and CIL.
[SEE ATTACHED DOCUMENT FOR ADDITIONAL REFERENCES TO THE DPD]

Allocate Redhills Road Site Ref A15 and Station Road Site A18 to ensure a greater level of provision that is likely to be deliverable. The requirement for 50% affordable housing is untenable and will not deliver any affordable housing. This should be reduced to a maximum of 35% as per the wider requirement in South Lakeland.
Greater emphasis should be placed on the NPPF and Core Strategy be ensure
compliance with the NPPF (Criteria 4).

Yes, I wish to participate at the oral examination

Please notify me

I have read the guidance notes

AS18(part of A9) - Land on Hollins Lane, Arnside

Yes

No

The DPD is not positively prepared

The DPD is not justified

The DPD is not effective

The DPD is not consistent with national policy

This response is written on behalf of Russell Armer Homes and represents a general response in relation to the policies contained within the DPD, followed by reference to two specific sites that have been put forward by my client at Arnside. The two sites have not been taken forward into this document and they have previously been referenced as:
* Redhills Road Site Reference A15; and
* Station Road Site Reference A18.
Plans of these sites are attached to this representation.
This consultation response works through the DPD document quoting the paragraph number of any paragraphs that we wish to make comment upon.
Site AS18 may be developable but with 50% affordable housing requirement as well as the CIL, taken together with 6 dwellings being ambitious if the rear part of the site is not be used, we have concerns about deliverability.

[SEE ATTACHED DOCUMENT FOR ADDITIONAL REFERENCES TO THE DPD]

Allocate Redhills Road Site Ref A15 and Station Road Site A18 to ensure a greater level of provision that is likely to be deliverable. The requirement for 50% affordable housing is untenable and will not deliver any affordable housing. This should be reduced to a maximum of 35% as per the wider requirement in South Lakeland.
Greater emphasis should be placed on the NPPF and Core Strategy be ensure
compliance with the NPPF (Criteria 4).

Yes, I wish to participate at the oral examination

Please notify me

I have read the guidance notes

AS19(A11) - Land on Briery Bank, Arnside

Yes

No

The DPD is not positively prepared

The DPD is not justified

The DPD is not effective

The DPD is not consistent with national policy

This response is written on behalf of Russell Armer Homes and represents a general response in relation to the policies contained within the DPD, followed by reference to two specific sites that have been put forward by my client at Arnside. The two sites have not been taken forward into this document and they have previously been referenced as:
* Redhills Road Site Reference A15; and
* Station Road Site Reference A18.
Plans of these sites are attached to this representation.
This consultation response works through the DPD document quoting the paragraph number of any paragraphs that we wish to make comment upon.

Site AS19, Briery Bank, the same concerns apply to this site.
[SEE ATTACHED DOCUMENT FOR ADDITIONAL REFERENCES TO THE DPD]

Allocate Redhills Road Site Ref A15 and Station Road Site A18 to ensure a greater level of provision that is likely to be deliverable. The requirement for 50% affordable housing is untenable and will not deliver any affordable housing. This should be reduced to a maximum of 35% as per the wider requirement in South Lakeland.
Greater emphasis should be placed on the NPPF and Core Strategy be ensure
compliance with the NPPF (Criteria 4).

Yes, I wish to participate at the oral examination

Please notify me

I have read the guidance notes

5.2.1

Yes

No

The DPD is not positively prepared

The DPD is not justified

The DPD is not effective

The DPD is not consistent with national policy

This response is written on behalf of Russell Armer Homes and represents a general response in relation to the policies contained within the DPD, followed by reference to two specific sites that have been put forward by my client at Arnside. The two sites have not been taken forward into this document and they have previously been referenced as:
* Redhills Road Site Reference A15; and
* Station Road Site Reference A18.
Plans of these sites are attached to this representation.
This consultation response works through the DPD document quoting the paragraph number of any paragraphs that we wish to make comment upon.
Proposed Development Allocations:
I have, on behalf of my client, had previous correspondence pointing out that Russell Armer have an interest two sites that have not been allocated for development in Arnside. One is at Redhills Road, where we currently have in a planning application for 5 homes, and the other at Station Road. My client considers that the sites could accommodate housing in a sustainable manner. Despite the plan allocating neither site for development we were aware that Arnside Parish Council felt that some limited development may be appropriate at the Redhills Road site. This reflects their comment upon our current planning application.
It is of concern to us that both sites were put forward as suitable for housing by South Lakeland District Council at the examination of the Land Allocations DPD for the whole of the district. This inferred the acceptability of housing on both sites. The AONB DPD takes a different view and we are concerned that the sites put forward by SLDC on the back of a landscape evidence base at that time in 2012/2013 are now being rejected on landscape grounds. The landscape character of these sites has not changed over this time and neither has the overarching policy requirement relating to protected landscapes. Consequently, we ask for evidence of what has changed.
The site at Station Road is subject to a Key Settlement Landscape designation A18 and the site at Redhills Road is subject to the same designation, reference A15. This severely restricts development opportunity in Arnside, which is regarded by the South Lakeland District Council Core Strategy and the DPD itself as a Local Service Centre. We regard both sites as being sustainable sites within the settlement with the one at Station Road being next to an important public transport facility and, in our view, the lack of allocation of this sites is failing to create a vibrant, diverse and sustainable community at Arnside into the future on sites that have not previously been subject to concerns about landscape.


[SEE ATTACHED DOCUMENT FOR ADDITIONAL REFERENCES TO THE DPD]

Allocate Redhills Road Site Ref A15 and Station Road Site A18 to ensure a greater level of provision that is likely to be deliverable. The requirement for 50% affordable housing is untenable and will not deliver any affordable housing. This should be reduced to a maximum of 35% as per the wider requirement in South Lakeland.
Greater emphasis should be placed on the NPPF and Core Strategy be ensure
compliance with the NPPF (Criteria 4).

Yes, I wish to participate at the oral examination

Please notify me

I have read the guidance notes

General comment / comment on procedure

Yes

Yes

The Lancashire branch of CPRE, the Campaign to Protect Rural England, warmly welcomes the opportunity to comment on this pioneering Development Plan Document (DPD). As the first of its kind, it will be closely scrutinised by other AONB Partnerships, as well as by Local Planning Authorities with AONBs in their area and by landowners and developers with interests in and around AONBs. The process of developing policies, assessing sites, and consulting the community, as well as the final form that the Document and its policies take, will inevitably influence the future development of other AONB DPDs and of AONB-specific policies in Local Authority Local Plans.

It is widely recognised that inappropriate development provides one of the most significant threats to the primary purpose of AONBs, i.e. to conserve and enhance their natural beauty, and this threat is growing. Recent research commissioned by CPRE shows there has been an 82% increase in new housing units given planning permission in England’s 34 AONBs in the past five years, despite repeated commitments by the Government to ‘maintain national protections for AONBs for the benefit of future generations’. This represents almost 15,500 housing units since 2012. The research also shows that the pressure on Local Authorities is set to increase, with applications for a further 12,741 homes in AONBs currently awaiting decision. It shows clear evidence that housing developers are applying increasing pressure on local authorities to build new homes on AONBs by exploiting poorly defined and conflicting national planning policy (CPRE, November 2017: Beauty Betrayed, available at http://bit.ly/2jxW1KM). The production of individual AONB DPDs is clearly a necessary step in the right direction, enabling a much more focused and fine-grained management of development in these most important national landscapes.

We are therefore delighted to be able to strongly support this DPD overall as being both sound and legally compliant. As it sets out in its introduction, the landscape capacity-led approach is clearly consistent with national policy and legislation – indeed, we are of the view that this is the only possible approach to an AONB DPD that would be consistent with national policy and legislation. Within this baseline parameter, the DPD positively seeks opportunities for development that will support the social and economic wellbeing of the area without compromising this primary purpose, based on detailed evidence and a rigorous site assessment process. It allocates sites that will contribute towards its development needs, and provides criteria-based policies that allow the flexibility for development to come forward on non-allocated sites within the capacity of the landscape and settlement character to absorb it without adverse impact. As indicated by the Sustainability Appraisal, it will have a net positive impact on sustainability overall, by striking the right balance, in light of its nationally significant status, between its social, economic and environmental roles. It clearly demonstrates compliance with the Duty to Co-operate and could indeed be cited as one of the most successful interpretations of the Duty, providing consistency for planning decisions across the AONB in a way that will conserve and enhance its landscapes, natural beauty and special qualities.

We make more detailed comments on individual policies and other elements of the DPD separately.

Yes, I wish to participate at the oral examination

With its public interest remit of promoting and protecting a beautiful and thriving countryside that is valued and enjoyed by everyone, CPRE has a strong interest in the development and outcome of this DPD. It is of great importance to the protected landscape of Arnside and Silverdale, but also, as the first ever AONB DPD, it will be closely scrutinised by other AONB Partnerships, as well as by Local Planning Authorities with AONBs in their area and by landowners and developers with interests in and around AONBs. The process of developing policies, assessing sites, and consulting the community, as well as the final form that the Document and its policies take, will inevitably influence the future development of other AONB DPDs and of AONB-specific policies in Local Authority Local Plans. CPRE would like to be able to bring their decades of experience in planning and protected landscapes to bear at this very significant Examination.

Please notify me

I have read the guidance notes

AS01 - Development Strategy

Yes

Yes

CPRE strongly supports this policy and its purpose of ensuring that the primary purpose of the AONB - to conserve and enhance the natural beauty of the area - is at the heart of the overall approach to development, and that new development supports this general purpose and the specific Special Qualities for which the area was designated. It provides a clear hierarchy for preferred development locations and appropriate types of development. It reflects the increasing emphasis in national policy on prioritising previously developed land and buildings, while also providing suitable protection for brownfield sites that have become environmentally or socially valuable. Consistent with para 3.1.2, CPRE believes that any approach to development in an AONB that was not landscape capacity-led would fail to strike the correct balance between meeting the social and economic needs of the community and enacting “the highest status of protection in relation to landscape and scenic beauty” (NPPF: 115).

We are however concerned by the potential ambiguity generated by the section “Development on the edge of and outside settlements”. While we endorse the content of the policy, if the DPD is not in any way to define what counts as the edge of a settlement (cf para 3.1.8), the policy becomes open to interpretation and provides decision-takers with less certainty than could be desired about whether any given site is “within”, “on the edge of”, or “outside” a settlement, and therefore which section of the policy should be applied. While we appreciate the reasons for not wishing to draw hard settlement boundaries, perhaps a written description of what is considered to be the current settlement boundaries might help.

We support the approach set out in paras 3.1.3 – 3.1.7 dealing with Objectively Assessed Needs (OAN), which is consistent with the landscape capacity-led approach deriving from the area’s national designation and primary purpose. As established in para 1.3.6, the effect of NPPF para 14 and footnote 9 is that the AONB is not required to meet its OAN – even if it were possible to apportion an OAN to the area with any degree of accuracy. Given this, and the acknowledged difficulty and challenges of effectively and appropriately allocating sub-Local Authority OAN, setting specific housing targets is unnecessary and would risk undermining national policy and legislation by prioritising a specific quantum of development above the capacity of the landscape to absorb it without significant harm. The positive approach taken of establishing the criteria that development must comply with in order to uphold the primary purpose, with the flexibility for any proposals that meet those criteria to come forward without relying on the blunt tool of numerical targets, is more appropriate to the area’s designation.

It is clearly in line with national policy that development in the AONB should not be seen as an opportunity to meet wider district housing targets – and it would clearly contradict national policy to do otherwise. As an area where policies indicate that development should be restricted in order to offer the highest status of protection to its landscapes and scenic beauty, higher level strategic development needs should not be sought to be met here.

This is particularly the case given the current uncertainty around acceptable methodologies for calculating OAN. Under the proposed national methodology recently consulted on by the Government, the district-wide OAN of both councils would be substantially reduced – by almost 30% in the case of South Lakeland and by around 40% in Lancaster District. A number of LPAs around the country have paused (or accelerated) their plan preparation processes to take account of this methodology. While we would not advocate interrupting the plan preparation process, particularly not at this late stage, this does indicate that there is at the very least a substantial probability that the OAN of the two districts will be significantly different next time it is calculated. In the face of that uncertainty, on top of the issues noted above, apportioning any fixed level of OAN to the AONB does not seem wise.

Yes, I wish to participate at the oral examination

With its public interest remit of promoting and protecting a beautiful and thriving countryside that is valued and enjoyed by everyone, CPRE has a strong interest in the development and outcome of this DPD. It is of great importance to the protected landscape of Arnside and Silverdale, but also, as the first ever AONB DPD, it will be closely scrutinised by other AONB Partnerships, as well as by Local Planning Authorities with AONBs in their area and by landowners and developers with interests in and around AONBs. The process of developing policies, assessing sites, and consulting the community, as well as the final form that the Document and its policies take, will inevitably influence the future development of other AONB DPDs and of AONB-specific policies in Local Authority Local Plans. CPRE would like to be able to bring their decades of experience in planning and protected landscapes to bear at this very significant Examination.

Please notify me

I have read the guidance notes

AS02 - Landscape

Yes

Yes

CPRE strongly supports this policy. The supporting text helps to justify, explain, and guide implementation of the policy and should be retained in full. We are particularly supportive of the strong emphasis in this overarching policy on landscape and natural beauty, tranquillity, dark skies, local distinctiveness & sense of place, and on cumulative and incremental impacts, issues which are far too often neglected and which are central to the AONB’s character.

Yes, I wish to participate at the oral examination

With its public interest remit of promoting and protecting a beautiful and thriving countryside that is valued and enjoyed by everyone, CPRE has a strong interest in the development and outcome of this DPD. It is of great importance to the protected landscape of Arnside and Silverdale, but also, as the first ever AONB DPD, it will be closely scrutinised by other AONB Partnerships, as well as by Local Planning Authorities with AONBs in their area and by landowners and developers with interests in and around AONBs. The process of developing policies, assessing sites, and consulting the community, as well as the final form that the Document and its policies take, will inevitably influence the future development of other AONB DPDs and of AONB-specific policies in Local Authority Local Plans. CPRE would like to be able to bring their decades of experience in planning and protected landscapes to bear at this very significant Examination

Please notify me

I have read the guidance notes

AS03 - Housing Provision

Yes

Yes

We strongly support the focus on meeting local affordable and other locally identified housing needs. The requirement of a minimum 50% affordable housing is appropriate given the area’s recognised need for affordable homes while also prioritising protection of the environment and the area’s protected status. CPRE research from earlier this year shows that the proportion of affordable homes being provided by non-metropolitan local authorities has halved in five years, emphasising the general trend of under-delivery of affordable housing in rural areas (CPRE, June 2017, available from http://bit.ly/2AlxYa2). While the overarching priority must be the conservation and enhancement of the landscape, the social need for affordable housing to enable mixed and diverse communities to continue to thrive should take precedence over market housing. A target of 50% affordable will ensure that those sites that are best suited for housing will contribute significantly to meeting local need. A lower target would reduce the capacity of the area to meet its own social needs in favour of delivering market housing which national policy indicates would generally be more properly located outside of the protected landscape. A lower target delivering less affordable housing would put greater pressure for the release of sites that are not suitable for housing and would risk unnecessary harm to the beauty and special qualities of the AONB.

Yes, I wish to participate at the oral examination

With its public interest remit of promoting and protecting a beautiful and thriving countryside that is valued and enjoyed by everyone, CPRE has a strong interest in the development and outcome of this DPD. It is of great importance to the protected landscape of Arnside and Silverdale, but also, as the first ever AONB DPD, it will be closely scrutinised by other AONB Partnerships, as well as by Local Planning Authorities with AONBs in their area and by landowners and developers with interests in and around AONBs. The process of developing policies, assessing sites, and consulting the community, as well as the final form that the Document and its policies take, will inevitably influence the future development of other AONB DPDs and of AONB-specific policies in Local Authority Local Plans. CPRE would like to be able to bring their decades of experience in planning and protected landscapes to bear at this very significant Examination

Please notify me

I have read the guidance notes

AS04 - Natural Environment

Yes

Yes

CPRE strongly supports this policy. There are some changes which should be made to the policy wording for sense and clarity, without which the policy is open to interpretation.

2nd paragraph: replace “extent, value or integrity” with “extent, value and/or integrity”.

“Trees and woodlands” section: Reword 1st paragraph to read: “New development should protect and enhance existing trees unless there are clear and demonstrable reasons why their removal would aid delivery of a better development overall, and positively seek opportunities to incorporate new trees.”

The level of detail is excellent, providing strong guidance and certainty for applicants, communities and decision-takers alike as to requirements. We are particularly supportive of the emphasis on ecological networks, the mosaic approach, and the importance of non-designated habitats, features and species for the functional integrity of biodiversity at the landscape scale, in recognition of the shift in direction at national and international level away from site-based biodiversity protection to a broader focus on ecosystem health, as set out in para 4.2.16.

Yes, I wish to participate at the oral examination

With its public interest remit of promoting and protecting a beautiful and thriving countryside that is valued and enjoyed by everyone, CPRE has a strong interest in the development and outcome of this DPD. It is of great importance to the protected landscape of Arnside and Silverdale, but also, as the first ever AONB DPD, it will be closely scrutinised by other AONB Partnerships, as well as by Local Planning Authorities with AONBs in their area and by landowners and developers with interests in and around AONBs. The process of developing policies, assessing sites, and consulting the community, as well as the final form that the Document and its policies take, will inevitably influence the future development of other AONB DPDs and of AONB-specific policies in Local Authority Local Plans. CPRE would like to be able to bring their decades of experience in planning and protected landscapes to bear at this very significant Examination

Please notify me

I have read the guidance notes

AS06 - Key Settlement Landscapes

Yes

Yes

CPRE strongly supports this policy. The recognition that specific, relatively small scale plots of undeveloped green space are essential to the rural character and local distinctiveness of settlements is one of the key underpinning bases for understanding the character of the settlements in this AONB. It is also vital to recognise that development physically outwith such parcels can adversely affect their functionality in this regard, particularly given that a significant part of their role is to maintain visual connectivity with the surrounding countryside and a sense of the countryside inter-penetrating with the settlement itself. These sites not only make a significant contribution to the character and charm of each of the settlements, but precisely by virtue of their location they are also in many cases particularly vulnerable to development pressures. Their contribution to the special qualities of the AONB as a whole, through their contribution to the character of individual settlements, needs to be protected in policy in order to discourage any speculative interest in development. Parcels of open land fulfilling an equivalent function of course occur in and around towns, villages and hamlets throughout the countryside. However, the approach to be taken to such land must clearly be markedly different within the AONB in order to give effect to national policy. This policy provides an efficient way of protecting a vital element of settlement character from intrusion.

Yes, I wish to participate at the oral examination

With its public interest remit of promoting and protecting a beautiful and thriving countryside that is valued and enjoyed by everyone, CPRE has a strong interest in the development and outcome of this DPD. It is of great importance to the protected landscape of Arnside and Silverdale, but also, as the first ever AONB DPD, it will be closely scrutinised by other AONB Partnerships, as well as by Local Planning Authorities with AONBs in their area and by landowners and developers with interests in and around AONBs. The process of developing policies, assessing sites, and consulting the community, as well as the final form that the Document and its policies take, will inevitably influence the future development of other AONB DPDs and of AONB-specific policies in Local Authority Local Plans. CPRE would like to be able to bring their decades of experience in planning and protected landscapes to bear at this very significant Examination

Please notify me

I have read the guidance notes

AS07 - Historic Environment

Yes

Yes

CPRE supports this policy. Supporting text para 4.4.4 is particularly useful in emphasising that the full range of heritage assets needs to be recognised and taken into account, and with a sense of context not in isolation.

Yes, I wish to participate at the oral examination

With its public interest remit of promoting and protecting a beautiful and thriving countryside that is valued and enjoyed by everyone, CPRE has a strong interest in the development and outcome of this DPD. It is of great importance to the protected landscape of Arnside and Silverdale, but also, as the first ever AONB DPD, it will be closely scrutinised by other AONB Partnerships, as well as by Local Planning Authorities with AONBs in their area and by landowners and developers with interests in and around AONBs. The process of developing policies, assessing sites, and consulting the community, as well as the final form that the Document and its policies take, will inevitably influence the future development of other AONB DPDs and of AONB-specific policies in Local Authority Local Plans. CPRE would like to be able to bring their decades of experience in planning and protected landscapes to bear at this very significant Examination

Please notify me

I have read the guidance notes

AS08 - Design

Yes

Yes

CPRE strongly supports this policy. The guidance given in paras 4.5.6 and the last sentence of 4.5.7 is particularly crucial.

Para 4.5.9 appears to be policy rather than supporting text, in that it actively directs the way in which development will be delivered, rather than providing a list of factors for consideration, as other sections of supporting text do (e.g. para 4.4.4). It should therefore be included as an integral part of Policy AS08 and the end of the existing draft policy, as follows:
• Replace “the following factors are important” with “development should”
• Begin each bullet point with the imperative rather than the gerund, e.g. “retain” instead of “retaining”

This policy should also encourage the use of recycled and secondary materials in construction and ensure that new development incorporates recycling opportunities, as recommended in the Sustainability Appraisal 5.2.16

Yes, I wish to participate at the oral examination

With its public interest remit of promoting and protecting a beautiful and thriving countryside that is valued and enjoyed by everyone, CPRE has a strong interest in the development and outcome of this DPD. It is of great importance to the protected landscape of Arnside and Silverdale, but also, as the first ever AONB DPD, it will be closely scrutinised by other AONB Partnerships, as well as by Local Planning Authorities with AONBs in their area and by landowners and developers with interests in and around AONBs. The process of developing policies, assessing sites, and consulting the community, as well as the final form that the Document and its policies take, will inevitably influence the future development of other AONB DPDs and of AONB-specific policies in Local Authority Local Plans. CPRE would like to be able to bring their decades of experience in planning and protected landscapes to bear at this very significant Examination

Please notify me

I have read the guidance notes

AS09 - Economic Development & Community Facilities

Yes

Yes

CPRE supports this policy and its objective of meeting the social and economic needs of the communities within the restrictions applied by national policy and legislation for the purpose of designation as an AONB. The guidance at para 4.6.3 is particularly useful.

With its public interest remit of promoting and protecting a beautiful and thriving countryside that is valued and enjoyed by everyone, CPRE has a strong interest in the development and outcome of this DPD. It is of great importance to the protected landscape of Arnside and Silverdale, but also, as the first ever AONB DPD, it will be closely scrutinised by other AONB Partnerships, as well as by Local Planning Authorities with AONBs in their area and by landowners and developers with interests in and around AONBs. The process of developing policies, assessing sites, and consulting the community, as well as the final form that the Document and its policies take, will inevitably influence the future development of other AONB DPDs and of AONB-specific policies in Local Authority Local Plans. CPRE would like to be able to bring their decades of experience in planning and protected landscapes to bear at this very significant Examination

Please notify me

I have read the guidance notes

AS10 - Infrastructure for New Development

Yes

Yes

CPRE supports this policy, especially the emphasis on active travel and sustainable transport networks.

With its public interest remit of promoting and protecting a beautiful and thriving countryside that is valued and enjoyed by everyone, CPRE has a strong interest in the development and outcome of this DPD. It is of great importance to the protected landscape of Arnside and Silverdale, but also, as the first ever AONB DPD, it will be closely scrutinised by other AONB Partnerships, as well as by Local Planning Authorities with AONBs in their area and by landowners and developers with interests in and around AONBs. The process of developing policies, assessing sites, and consulting the community, as well as the final form that the Document and its policies take, will inevitably influence the future development of other AONB DPDs and of AONB-specific policies in Local Authority Local Plans. CPRE would like to be able to bring their decades of experience in planning and protected landscapes to bear at this very significant Examination

Please notify me

I have read the guidance notes

AS12 - Water quality, sewerage and sustainable drainage

Yes

Yes

CPRE supports this policy.

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

Please notify me

I have read the guidance notes

AS13 - Energy & Communications

Yes

Yes

CPRE strongly supports this policy in its attempt to strike an appropriate balance between the need to protect the character of the landscape and the need to decarbonise our energy supplies and extend effective broadband coverage. It offers opportunities for low carbon energy supply and reduced energy demand through increased energy efficiency in the context of giving priority to protecting the landscapes and special qualities of the AONB.

We absolutely support the restriction of renewables deployment to the small scale, but believe that it is also important to enable community renewables projects of greater than domestic scale to go ahead if – and only if – they rigorously comply with the rest of the policies in the DPD and they have the support of the community. An example from near the AONB might be the district heating and hydro power schemes at Halton Mill near Lancaster (see https://haltonmill.org.uk/eco-credentials/). It is important that such schemes are not precluded or discouraged by a requirement that renewable development should “usually serv[e] only a single dwelling, business or community building” – provided any such schemes comply in full with the requirements of the rest of this DPD.

We strongly support the policy with regards to overhead cables.

The penultimate paragraph requires new development to provide “sufficient” onsite broadband infrastructure. Without some indication of what counts as “sufficient”, this leaves the policy open to interpretation. Reference to current standards or expectations for contemporary urban development may be appropriate in order to avoid rural communities being left behind with effectively sub-standard infrastructure.

Yes, I wish to participate at the oral examination

With its public interest remit of promoting and protecting a beautiful and thriving countryside that is valued and enjoyed by everyone, CPRE has a strong interest in the development and outcome of this DPD. It is of great importance to the protected landscape of Arnside and Silverdale, but also, as the first ever AONB DPD, it will be closely scrutinised by other AONB Partnerships, as well as by Local Planning Authorities with AONBs in their area and by landowners and developers with interests in and around AONBs. The process of developing policies, assessing sites, and consulting the community, as well as the final form that the Document and its policies take, will inevitably influence the future development of other AONB DPDs and of AONB-specific policies in Local Authority Local Plans. CPRE would like to be able to bring their decades of experience in planning and protected landscapes to bear at this very significant Examination

Please notify me

I have read the guidance notes

AS14 - Advertising and Signage

Yes

Yes

CPRE strongly supports this policy. Inappropriate advertising and signage can be highly detrimental to local distinctiveness, sense of place and landscape and settlement character, while traditional signage and sensitive treatment of signage and advertising can positively contribute to their conservation and enhancement.

With its public interest remit of promoting and protecting a beautiful and thriving countryside that is valued and enjoyed by everyone, CPRE has a strong interest in the development and outcome of this DPD. It is of great importance to the protected landscape of Arnside and Silverdale, but also, as the first ever AONB DPD, it will be closely scrutinised by other AONB Partnerships, as well as by Local Planning Authorities with AONBs in their area and by landowners and developers with interests in and around AONBs. The process of developing policies, assessing sites, and consulting the community, as well as the final form that the Document and its policies take, will inevitably influence the future development of other AONB DPDs and of AONB-specific policies in Local Authority Local Plans. CPRE would like to be able to bring their decades of experience in planning and protected landscapes to bear at this very significant Examination

Please notify me

I have read the guidance notes

General comment / comment on procedure

Yes

Yes

Site assessment process

In the context of the primary purpose of the AONB enshrined in legislation, and the highest status of protection given to its landscape and scenic beauty through national policy, the site assessment process used in this case has been entirely appropriate, i.e. a rigorous multi-stage approach, beginning with exclusion criteria and followed by successive stages of landscape, biodiversity, and viability assessment, with sites being removed from consideration at each stage. It is fitting that sites screened out during the first three stages were not considered to be reasonable alternatives to the Plan and therefore did not require sustainability assessment. To consider sites that had significant, non-mitigatable adverse impacts on the landscape as ‘reasonable’ would be to undermine the primary purpose of, and national policy relating to, AONBs. The approach taken successfully enacts national policy by prioritising the conservation of the landscape while positively enabling settlements to take opportunities to meet their economic and social development needs. It is an effective implementation of the landscape capacity-led approach; indeed, it is hard to see how alternative approaches could be consistent with the level of protection that national policy is supposed to offer to AONB landscapes.

The extent to which this assessment process has thoroughly engaged with the material realities of the sites and the views of the local communities, as opposed to being the kind of tick-box exercise that assessment can sometimes be limited to, is indicated in particular by the exclusion of two sites, S50 and S56. These sites were not ruled out mechanistically by any single element of the assessment process, but when considering the multi-stage site assessment alongside the Habitats Regulations Assessment, Sustainability Appraisal, and public and stakeholder consultation responses, it was concluded that they would in the round have unacceptable impacts on the AONB and its residents (cf Sustainability Appraisal 5.3.6). This implies a careful and meticulous approach which should be commended

Yes, I wish to participate at the oral examination

With its public interest remit of promoting and protecting a beautiful and thriving countryside that is valued and enjoyed by everyone, CPRE has a strong interest in the development and outcome of this DPD. It is of great importance to the protected landscape of Arnside and Silverdale, but also, as the first ever AONB DPD, it will be closely scrutinised by other AONB Partnerships, as well as by Local Planning Authorities with AONBs in their area and by landowners and developers with interests in and around AONBs. The process of developing policies, assessing sites, and consulting the community, as well as the final form that the Document and its policies take, will inevitably influence the future development of other AONB DPDs and of AONB-specific policies in Local Authority Local Plans. CPRE would like to be able to bring their decades of experience in planning and protected landscapes to bear at this very significant Examination

Please notify me

I have read the guidance notes

AS15 - Housing Allocations

Yes

Yes

Mini-briefs

The mini-briefs and site maps are helpful. The maps in particular are user-friendly and indicate at a glance to communities, developers and decision-takers alike some of the main site parameters and requirements. The mini-briefs, while in principle an excellent idea, are in practice at times somewhat generic and could be improved with more site-specific detail, to give greater certainty to communities and decision-takers about what will be acceptable, without unnecessarily constraining the freedom of developers to propose creative solutions within the parameters set out.

Yes, I wish to participate at the oral examination

With its public interest remit of promoting and protecting a beautiful and thriving countryside that is valued and enjoyed by everyone, CPRE has a strong interest in the development and outcome of this DPD. It is of great importance to the protected landscape of Arnside and Silverdale, but also, as the first ever AONB DPD, it will be closely scrutinised by other AONB Partnerships, as well as by Local Planning Authorities with AONBs in their area and by landowners and developers with interests in and around AONBs. The process of developing policies, assessing sites, and consulting the community, as well as the final form that the Document and its policies take, will inevitably influence the future development of other AONB DPDs and of AONB-specific policies in Local Authority Local Plans. CPRE would like to be able to bring their decades of experience in planning and protected landscapes to bear at this very significant Examination

Please notify me

I have read the guidance notes

AS16 - Mixed-Use Allocations

Yes

Yes

Mini-briefs

The mini-briefs and site maps are helpful. The maps in particular are user-friendly and indicate at a glance to communities, developers and decision-takers alike some of the main site parameters and requirements. The mini-briefs, while in principle an excellent idea, are in practice at times somewhat generic and could be improved with more site-specific detail, to give greater certainty to communities and decision-takers about what will be acceptable, without unnecessarily constraining the freedom of developers to propose creative solutions within the parameters set out.

Yes, I wish to participate at the oral examination

With its public interest remit of promoting and protecting a beautiful and thriving countryside that is valued and enjoyed by everyone, CPRE has a strong interest in the development and outcome of this DPD. It is of great importance to the protected landscape of Arnside and Silverdale, but also, as the first ever AONB DPD, it will be closely scrutinised by other AONB Partnerships, as well as by Local Planning Authorities with AONBs in their area and by landowners and developers with interests in and around AONBs. The process of developing policies, assessing sites, and consulting the community, as well as the final form that the Document and its policies take, will inevitably influence the future development of other AONB DPDs and of AONB-specific policies in Local Authority Local Plans. CPRE would like to be able to bring their decades of experience in planning and protected landscapes to bear at this very significant Examination

Please notify me

I have read the guidance notes

Other - misc

Yes

Thank you for your consultation in relation to the Arnside and Silverdale AONB DPD. The Lancaster Canal passes to the west of the area covered by the DPD. Having reviewed the document and proposed allocations the Canal & River Trust have no comments to make as our waterway and assets would not be impacted.

Please notify me

I have read the guidance notes

General comment / comment on procedure

Yes

As set out in the letters as provided by Angela Jones attached we consider that both the Arnside and Silverdale AONB DPD and Development Management Policies DPD are considered sound but would be enhanced with the changes we have suggested.

We welcome the Arnside and Silverdale AONB DPD and are generally supportive of its content. In particular we welcome greater weight being given to ensuring proposals conserve and enhance the landscape of the AONB under Policy AS02 and proposals requiring to be of a scale and nature to avoid adverse impact under Policy AS09.

Please notify me

I have read the guidance notes

AS10 - Infrastructure for New Development

Yes

Comment

There is a need to strengthen the weight given for new developments to support access to sustainable forms of transport to and through the AONB. New infrastructure to improve access on foot, by bike, bus and train is vital to meeting the needs of the local community and growing the visitor economy. Sustainable transport improvements being delivered through the Morecambe Bay Partnership such as the Bay Cycle Way are key drivers for a strong local economy.

Suggested Change

The Policy should be revised to incorporate that new developments should support access to sustainable forms of transport including bus and rail services.

Proposed Wording

Add a 2nd sentence to the 2nd paragraph of the Policy:
“Development should support access to sustainable forms of transport including bus services and the rail network. “

Please notify me

I have read the guidance notes

AS17(A6) - Land off Queen's Drive, Arnside

Yes

As set out in the letters as provided by Angela Jones attached we consider that both the Arnside and Silverdale AONB DPD and Development Management Policies DPD are considered sound but would be enhanced with the changes we have suggested.

For Highways, Flooding & Drainage and Education comments on AS17, SEE ATTACHED DOCUMENT.

Please notify me

I have read the guidance notes

AS18(part of A9) - Land on Hollins Lane, Arnside

Yes

As set out in the letters as provided by Angela Jones attached we consider that both the Arnside and Silverdale AONB DPD and Development Management Policies DPD are considered sound but would be enhanced with the changes we have suggested.

For Highways, Flooding & Drainage and Education comments on AS18, SEE ATTACHED DOCUMENT.

I have read the guidance notes

AS19(A11) - Land on Briery Bank, Arnside

Yes

As set out in the letters as provided by Angela Jones attached we consider that both the Arnside and Silverdale AONB DPD and Development Management Policies DPD are considered sound but would be enhanced with the changes we have suggested.

For Highways, Flooding & Drainage and Education comments on AS19, SEE ATTACHED DOCUMENT.

Please notify me

I have read the guidance notes

AS20(B108) - Church Street, Beetham

Yes

As set out in the letters as provided by Angela Jones attached we consider that both the Arnside and Silverdale AONB DPD and Development Management Policies DPD are considered sound but would be enhanced with the changes we have suggested.

For Highways, Flooding & Drainage and Education comments on AS20, SEE ATTACHED DOCUMENT.

Please notify me

I have read the guidance notes

AS23(A26/A27) - Station Yard, Arnside

Yes

As set out in the letters as provided by Angela Jones attached we consider that both the Arnside and Silverdale AONB DPD and Development Management Policies DPD are considered sound but would be enhanced with the changes we have suggested.

For Highways, Flooding & Drainage and Education comments on AS23, SEE ATTACHED DOCUMENT.

Please notify me

I have read the guidance notes

AS25 (B35/B38/B81/B125) - Sandside Rd & Quarry Lane, Sandside

Yes

As set out in the letters as provided by Angela Jones attached we consider that both the Arnside and Silverdale AONB DPD and Development Management Policies DPD are considered sound but would be enhanced with the changes we have suggested.

For Highways, Flooding & Drainage and Education comments on AS25, SEE ATTACHED DOCUMENT.

Please notify me

Other - misc

Yes

Yes

Cumbria GeoConservation is a voluntary geological conservation group working to record and protect important Local Geological Sites (LGS) in Cumbria, formerly Regionally Important Geological Sites (RIGS). Please note that geological sites in the Lancashire part of the AONB come under the Geo-Lancashire group.

Cumbria GeoConservation is pleased to support this Plan, and notes that our previous comments of last year have been included. We confirm that we believe that this Plan is sound and legally compliant.
It is good to see that the ‘unique limestone geology’ (p3, 14, 21) and its contribution to the landscape is fully recognised in this plan as underlying the special landscapes and beauty of the area. It is also good that drumlins are mentioned for their landscape contribution. The area certainly has high geological diversity (AS02 p21). We are pleased to see that Local Geological Sites are mentioned (p33) and are listed in the Glossary. We note that LGS are mentioned in the Geology and Geomorphology section p35 4.2.22.

There are four LGS in the Cumbria part of the AONB, 5/013 Arnside Foreshore, 5/014 Arnside Blackstone Point, 5/034 Far Arnside shoreline and 5/041 Arnside Sandside Railway Cutting, this latter being also a GeoTrail. Full details of their designations are held by the Cumbria Biodiversity Data Centre (CBDC) in Carlisle.

We can confirm that the sites identified for housing allocations in Arnside, Beetham and Sandside are unlikely to have any impact on geological sites.

Please notify me

I have read the guidance notes

Other - misc

Yes

Thank you for consulting us on the above document, which we received 2 November 2017.

Environment Agency position
We have appreciated the opportunity to be consulted on the development of this document, and have no further comment to make concerning this Submission version.

Yours faithfully,

Mrs Liz Locke
Sustainable Places Officer

I have read the guidance notes

Other - misc

Yes

Thank you for the opportunity to provide any further comments on the above document prior to publication. I can confirm that Highways England has no further comments to make with regard to the publications document. We are content that the comments previously made by Highways England have been taken into account and we have no further comments to make.

Please notify me

I have read the guidance notes

AS07 - Historic Environment

Yes

No

The DPD is not consistent with national policy

Thank you for consulting Historic England on the Arnside and Silverdale DPD Publication document. As the Government’s statutory adviser on all matters relating to the historic environment in England, we are pleased to offer our comments. We champion and protect England’s historic places, providing expert advice to local planning authorities, developers, owners and communities to help ensure our historic environment is properly understood, conserved and enjoyed.

We welcome the very positive approach taken by the local planning authorities in pioneering the first DPD for an AONB. We have looked through the Plan, and have the following minor comments in terms of ensuring that it is sound.

Positive Strategy: The National Planning Policy Framework (NPPF) sets out in various places the requirements for Local Plans in respect of the historic environment. A key element is the need to set out a positive and clear strategy for the conservation, enjoyment and enhancement of the historic environment. This DPD clearly achieves this, with a strong heritage policy (subject to amendment – see below), and recognition of the role that the historic environment plays throughout. For example, it is mentioned in the vision and objectives, and in policies AS02, section 4.5 and AS08, AS09, and AS13. In this respect the Plan is sound.

Adequate and relevant evidence: The NPPF (paragraph 169) requires that the Plan is based upon the ‘up to date evidence about the historic environment’. There is a list of much of the evidence used in paragraph 4.4.3, along with further evidence within the Document Library. In this respect the Plan is sound, although it would benefit from a fuller description of the richness of the historic environment within the AONB. For example, the natural environment section in 4.2 goes into some detail on the sites and species found within the area, but the historic environment section is a lot less informative. It would, for example, be helpful to have a synopsis of numbers and type of designated assets, any heritage at risk etc.

Strategic policies for the historic environment: The NPPF (in its paragraph 156) refers to the need to identify strategic priorities, and states that Neighbourhood Plans must be in ‘general conformity with the strategic policies of the Local Plan’ (paragraph 184 of the NPPF). Given the role of this plan, and its straddling two local authority boundaries, it would be helpful to clarify exactly which are the strategic policies which would need to be referenced should Neighbourhood Plans be developed.

Identification of areas where development would be inappropriate: Site allocations should avoid harming the significance of both designated and undesignated heritage assets, including effects upon their setting. At the same time, proposed development sites may present opportunities for enhancing the historic environment. Site allocations should therefore be informed by sufficient robust evidence to help identify heritage assets likely to be affected, and consider the likely constraints or opportunities. The Plan therefore needs to be able to demonstrate that:
i. The sites that are allocated will be likely to “contribute to protecting or enhancing the historic environment” and are therefore delivering sustainable development in terms of the historic environment (NPPF Paragraph 7).
ii. The allocated sites are likely to “conserve heritage assets in a manner appropriate to their significance”. (NPPF Paragraph 17).
iii. It has complied with the statutory duties under sections 66 and 72 of the Planning (Listed Buildings and Conservation Areas) Act, 1990.

We note that the impact of the sites upon the historic environment has been assessed as part of the Sustainability Appraisal, and opportunities for conserving and enhancing any heritage assets affected have been picked up within the mini briefs. We therefore consider that in this respect the Plan is sound.

Policy AS07 Historic Environment: We are concerned that the Plan may not be fully in compliance with the NPPF for the historic environment policy, AS07. While we fully appreciate the intent of the policy, some of the wording needs amending to be fully consistent with national policy.

The first paragraph refers to ‘locally important heritage assets…’. We are unclear of the distinction here, as this seems to imply that nationally important heritage assets are not covered by this policy? Yet the AONB contains a wealth of nationally significant assets, including listed buildings and Scheduled Ancient Monuments, as well as Conservation Areas. As it stands, this policy is not providing adequate protection to designated assets, and is therefore not complying with national legislation and advice. In addition, it is not referring to the significance of the heritage assets, which is a critical concept and included throughout the historic environment advice within the NPPF.

We would therefore reword the wording of this first paragraph to read:

‘…including built, natural and historic features, and protect, conserve and enhance the significance of heritage assets (including any contribution made by their setting), historic landscape character, and the distinctiveness of settlements.’

Reference to significance should also be incorporated into the bullet point (1), which at present does not adequately protect archaeological assets (which may be below ground, or have no architectural interest). For example, we would suggest:
(1) Conserve and enhance the significance of the asset…

The penultimate paragraph refers to where development proposals will not be permitted. The NPPF makes it clear that where a development proposal will lead to harm to the significance of an asset, it must be weighed against public benefits or a number of criteria apply (NPPF paragraphs 133-135). The need for this balanced judgement need to be reflected in the wording, to ensure that the policy is compliant with the NPPF.

Please see comments above.

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

Please notify me

I have read the guidance notes

AS03 - Housing Provision

Yes

No

The DPD is not effective

Thank you for consulting with the Home Builders Federation on the Publication Draft of the Arnside and Silverdale AONB DPD.

The HBF is the principal representative body of the house-building industry in England and Wales. Our representations reflect the views of our membership, which includes multi-national PLC’s, regional developers and small, local builders. In any one year, our members account for over 80% of all new “for sale” market housing built in England and Wales as well as a large proportion of newly built affordable housing.

Policy AS03 – Housing Provision
This policy is not considered to be sound, as it is not considered to be effective.
This policy requires that proposals for new housing development will be supported where they deliver no less than 50% affordable housing. It goes on to state that only where this is demonstrably unachievable will a lower percentage be acceptable.

Whilst the HBF supports the delivery of affordable housing, the delivery of affordable housing must, however, be balanced against economic viability considerations. The HBF consider that the affordable housing requirement proposed is not viable and will hinder the delivery of both market and affordable housing if development cannot occur. The evidence contained within the Viability Study (October 2016) also highlights that the 50% affordable housing requirement is not viable, and that a number of sites are not viable even at the lower 35% level.

HBF propose that the policy is modified as follows:
• ‘Proposals for new housing development will be supported where they contribute to the provision of affordable housing.'

instead of,

'Proposals for new housing development will be supported where they deliver no less than 50% affordable housing. Only where this is demonstrably unachievable will a lower percentage be acceptable.'

Yes, I wish to participate at the oral examination

To debate the comments made within our representations further and in greater detail. To ensure that the industry can respond to any additional evidence provided by the Council or others following submission of the plan.

Please notify me

I have read the guidance notes

4.7.3

Yes

Dear Sir/Madam,

I am writing to express our active support for the identified infrastructure need for the AONB set out at paragraph 4.7.3 of the Publication Document which identifies the pedestrian and cycle link across the Arnside viaduct. We understand that Network Rail has determined that the project is technically viable. The Lake District National Park Authority supports this infrastructure improvement for the following reasons;

It will significantly improve connections between the communities of Arnside and Grange over Sands along the northern shores of the bay and improve accessibility for visitors. It will link with the England Coast Path (to be open by 2020) and the Morecambe Bay Cycleway and therefore strengthen the tourism offer and the local economy for this part of South Lakeland. It will promote sustainable tourism because of its connections with the Cumbrian Coastal Line and improve health and wellbeing of the community and visitors alike.

Yours,

Hanna Latty
Team Leader Strategy and Planning Policy
Lake District National Park Authority

General comment / comment on procedure

Yes

Observations and Recommendations

Highways:
The three sites identified within Lancashire all appear to be sustainable. The only concern from a Highways point of view is the formation of the access onto the public highway. We are constrained by certain guidelines and criteria and these would need to be applied irrespective of the AONB designation. HGV access to Silverdale in the event that planning permission is granted for a development site also needs to be considered.

Please notify me

I have read the guidance notes

AS04 - Natural Environment

No

The DPD is not justified

The DPD is not effective

The DPD is not consistent with national policy

Further to your consultation on the above, this is to confirm that The Wildlife Trust for Lancashire, Manchester & North Merseyside is broadly content with the draft and supportive of the policies on nature conservation, as far as those go.

However, we have one major reservation: the DPD lacks any identification of (and supporting justification for) the conjoined ecological networks within and adjoining the AONB and straddling the two districts and counties. This identification and justification is required in order that these may be effectively and efficiently protected, maintained, enhanced, restored and, where practicable, reconnected and expanded in association with development (planning conditions and obligations, and CIL where relevant) and also through and in concert with other mechanism outside the planning system (e.g. targeted agri-environment support to individual landowners and managers). Identification of such networks is necessary to afford certainty when seeking to restore and improve ecosystem functionality within and across the AONB.

As the National Planning Policy Framework requires such a network to be identified* to assist the Government’s ambition to leave nature in a better state than we find it**, we believe the Development Plan to be unsound and un-evidenced in that particular cross-boundary regard.

*The planning system should contribute to and enhance the natural and local environment by: protecting and enhancing valued landscapes….; recognising the wider benefits of ecosystem services; minimising impacts on biodiversity and providing net gains in biodiversity where possible... including by establishing coherent ecological networks that are more resilient to current and future pressures’ (NPPF paragraph 109)

**‘moving from a net loss of bio-diversity to achieving net gains for nature’ - making a direct reference to the Natural Environment White Paper. (NPPF Paragraph 9)

You should consult your local authorities’ respective ecological advisers in respect of this, and also the site-specific allocation policies.

Please notify me

I have read the guidance notes

Other - misc

Yes

We have no issues with the proposals from a health point of view and my GP colleagues with whom I have spoken didn’t see any issues.

Please notify me

I have read the guidance notes

Appendix 3 - List of Key Settlement Landscapes

Yes

No

The DPD is not justified

The DPD is not consistent with national policy

The supporting text for Policy AS06 (paragraph 4.3.2) clarifies that the intention of the policy is to conserve areas of open space “that make a particular and important contribution to the character of settlements in the AONB”. As a major landowner and manager in the AONB, The National Trust recognises the importance of conserving the areas of open space identified by the policy, and is strongly supportive of the approach in principle.

We are concerned however, in regard to the specific area of coverage identified as ‘S260’ in the Inset Map Book at our property at Bank House Farm, Silverdale. The proposed designation includes the farm and farmyard. Bank House Farm is a working farm, and the base for the National Trust countryside management team in the AONB.

The proposed policy wording for AS06 is very restrictive with regard to new development proposals. This is consistent with the aims outlined in the supporting text, and as noted, we are supportive in principle of this approach, where it applies to open space. We do not feel that it is appropriate to apply such a restrictive approach to a working farm/team base however. Whilst we do not envisage major development taking place at the farm, we would wish to ensure that the flexibility is retained to enable any suitable small-scale developments which may be required in due course, necessary to the on-going effective management of the farm.

In the National Trust’s view therefore, the area currently identified as ‘S260’ fails the tests of soundness. We do not consider that it is justified or effective. It raises conflict with the NPPF presumption in favour of sustainable development, specifically in regard to paragraph 28, ‘Supporting a prosperous rural economy’.

We have attached a plan, indicating the area (in red) [SEE ATTACHED] which in our view should be removed from S260, in order for it to be considered sound.

Yes, I wish to participate at the oral examination

The Trust would wish to ensure that this issue is suitably addressed. We appreciate that there may be a variety of alternatives to the option we have suggested, which may require debate.

Please notify me

I have read the guidance notes

AS01 - Development Strategy

Yes

Yes

The National Trust is strongly supportive of the proposed Development Strategy, as set out in
Policy AS01. The Trust owns a significant amount of land in the AONB, (including Arnside Knott), which it also manages.

The great majority of the National Trust land in the AONB has been declared inalienable. This is a power conferred on the National Trust by the National Trust Acts, which seeks to ensure that the special qualities of the land in question are protected and conserved in perpetuity, for the benefit of the nation.

Policy AS01 adopts a landscape capacity-led approach to development in the AONB. Given the wide range of special qualities - notably its landscape character, but also its high ecological and cultural heritage value - and associated sensitivities of the AONB, it is appropriate that a landscape capacity-led approach is taken. The supporting text to the policy explains the reasons why the Councils have not sought to set targets for the amount of development to be achieved. This approach is consistent with NPPF policy (notably paragraph 115), and the statutory purposes of AONB designation.

Please notify me

I have read the guidance notes

2.1.1

Yes

Yes

The National Trust is strongly supportive of the proposed Vision and Objectives, as set out in
Chapter 2. The Trust owns a significant amount of land in the AONB, (including Arnside Knott),
which it also manages.

The great majority of the National Trust land in the AONB has been declared inalienable. This is a power conferred on the National Trust by the National Trust Acts, which seeks to ensure that the special qualities of the land in question are protected and conserved in perpetuity, for the benefit of the nation.

The Vision and Objectives for the Plan reflect the statutory Managment Plan for the AONB, in
placing recognition of the many varied special qualities of the area at the heart of the DPD, and in seeking to ensure that the conservation of these qualities is given priority. This is consistent with the National Trust's approach to the managment of its own land in the AONB, and is consistent with the statutory purposes of AONB designation.

The approach the DPD takes, as specified in the Vision and Objectives, is therefore legally compliant and sound. It is based on a comprehensive range of data, which has been compiled by the Councils and the AONB Unit, which enables wider understanding of the environmental characteristics and sensitivities of the AONB, and its socio-economic profile. The approach taken is consistent with NPPF guidance - notably paragraph 115, in regard to the approach to be taken in AONB.

Please notify me

I have read the guidance notes

Other - misc

Yes

NATS has no comments to make on the DPD Publication.

Regards
S. Rossi
NATS Safeguarding Office

Please notify me

I have read the guidance notes

AS04 - Natural Environment

No

The DPD is not consistent with national policy

Thank you for your consultation on the above dated and received by Natural England on 02 November 2017.

Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.

We have reviewed the Publication version of the DPD and the accompanying documents and have the following comments to make.

There are still some outstanding issues which could make the plan unsound. However, we feel that these issues could be overcome with minor changes to wording in both the DPD and HRA.

DPD Policy AS04 Natural Environment

As the AONB DPD is advancing ahead of both LPA local plans, we think this policy could be strengthened by including reference to the mitigation hierarchy and Habitats Regulations Assessment. Currently the policy contains no wording about the hierarchy of international, national and locally designated sites and areas or that development proposals resulting in significant harm or adversely affecting a European site or SSSI should not normally be permitted (NPPF, paragraph 118).

Given that European/Ramsar designations account for nearly 50% of the AONB area, we advise that explicit reference is made to the Habitats Regulations within this policy, as well as the policy justification.

Adding this wording will make the policy requirements for developments clear.

Ancient Woodland – Soundness Issue

We have previously raised concerns about the section in policy AS04 about ancient woodland and these have not been addressed. The policy still suggests that ancient woodland and veteran trees can be replaced. Ancient woodland and veteran trees cannot be replaced and the current wording of the policy does not make this clear and is therefore not wholly consistent with national planning policy.

Ancient woodland is an irreplaceable resource of great importance for its wildlife, its history and the contribution it makes to our diverse landscapes. Local authorities have a vital role in ensuring its conservation, in particular through the planning system. NPPF (Para. 118) states:

‘Planning permission should be refused for development resulting in the loss or deterioration of irreplaceable habitats, including ancient woodland and the loss of aged or veteran trees found outside ancient woodland, unless the need for, and benefits of, the development in that location clearly outweigh the loss.’

You should refuse planning permission for developments - unless the need for, and benefits of, the development in that location clearly outweigh the:
- loss or deterioration of ancient woodland
- loss of veteran trees
You should also consider:
- conserving and enhancing biodiversity
- reducing the level of impact on ancient woodland and veteran trees - see [Avoid impacts, reduce impacts, and compensate as a last resort] (https://www.gov.uk/guidance/ancient-woodland-and-veteran-trees-protection-surveys-licences#avoid-impacts-reduce-impacts-and-compensate-as-a-last-resort)

In order to ensure this policy is sound (with regard to national policy) Natural England advises that the policy is reworded to make clear that ancient woodlands and trees cannot be replaced with new planting. If the planning authority decides to grant planning permission in line with the National Planning Policy Framework, it should seek appropriate mitigation or compensation from the developer. As ancient woodland and veteran trees are irreplaceable, discussions on compensation should not form part of the assessment of the merits of the development proposal.

Information about ancient woodland can be found in Natural England’s standing advice https://www.gov.uk/guidance/ancient-woodland-and-veteran-trees-protection-surveys-licences

Landscape Capacity Approach
Natural England supports the overall landscape capacity approach used in creating this DPD and in particular policy AS01 and the sites which have been allocated. We feel that the approach to protecting key areas of landscape in this way is sound and supports and protects the AONB landscape designation.

Please notify me

I have read the guidance notes

Other - misc

No

The DPD is not justified

Thank you for your consultation on the above dated and received by Natural England on 02 November 2017.

Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.

We have reviewed the Publication version of the DPD and the accompanying documents and have the following comments to make.

There are still some outstanding issues which could make the plan unsound. However, we feel that these issues could be overcome with minor changes to wording in both the DPD and HRA.

In-combination Impacts – Soundness Issue

We have previously agreed with your conclusions, in relation to recreational disturbance on Morecambe Bay, that whilst the site allocations are unlikely to produce a likely significant effect alone, in-combination impacts need to be assessed and addressed. However, the HRA now concludes no likelihood of significant effects in-combination and we do not agree with this conclusion.

At Para 8.2.6 in the HRA, it states all proposed dwellings in the DPD ‘are within the 3.5 km distance identified as the average distance that visitors to Morecambe Bay who were on a day-trip/short visit from home travelled.’ Whilst individual proposed housing numbers are small, collectively they will make an impact and if other development within a set distance to the designated site is expected to contribute to future measures (through Lancaster/ South Lakeland Local Plan), then development within the AONB should too (if it falls within the zone of influence).

Therefore all AONB development within the 3.5km zone needs to provide mitigation against recreational disturbance in the same way as development in Lancaster and South Lakeland. And it is important that there is reference within the DPD to the emerging mitigation strategies for Morecombe Bay to ensure compliance with the outcomes of the HRA and to ensure consistency with neighbouring approaches.

Landscape Capacity Approach
Natural England supports the overall landscape capacity approach used in creating this DPD and in particular policy AS01 and the sites which have been allocated. We feel that the approach to protecting key areas of landscape in this way is sound and supports and protects the AONB landscape designation.

Please notify me

I have read the guidance notes

AS23(A26/A27) - Station Yard, Arnside

The DPD is not justified

Thank you for your consultation on the above dated and received by Natural England on 02 November 2017.

Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.

We have reviewed the Publication version of the DPD and the accompanying documents and have the following comments to make.

There are still some outstanding issues which could make the plan unsound. However, we feel that these issues could be overcome with minor changes to wording in both the DPD and HRA.

Policy AS23 Station House and Yard, Arnside & Policy AS25 Land at Sandside Road and Quarry Lane, Sandside – Soundness Issue

Regarding these two sites, we disagree with the reasoning of no likelihood of significant effects in the HRA. The HRA needs to be clear that a conclusion of no likelihood of significant effects can only be made because wording has been added to the policy requiring a project level HRA.

Landscape Capacity Approach

Natural England supports the overall landscape capacity approach used in creating this DPD and in particular policy AS07 and the sites which have been allocated. We feel that the approach to protecting key areas of landscape in this way is sound and supports and protects the AONB landscape designation.

The DPD site allocation policy wording for both these sites also needs amending to say that a project level HRA will be required to assess impacts of the developments on the nearby designated sites. The project level HRA will need to include avoidance and mitigation measures necessary to conclude no likelihood of significant effects.

The current wording in the AONB DPD HRA says no likelihood of significant effects alone and both the DPD site allocation policies refer the developer back to the conclusion of the HRA for the AONB DPD. This is misleading and it needs to be clear, in both the HRA and DPD site allocation policy, that a project level HRA is required to assess and mitigate the impacts for both these site allocations.

Please notify me

I have read the guidance notes

AS25 (B35/B38/B81/B125) - Sandside Rd & Quarry Lane, Sandside

No

The DPD is not justified

Thank you for your consultation on the above dated and received by Natural England on 02 November 2017.

Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.

We have reviewed the Publication version of the DPD and the accompanying documents and have the following comments to make.

There are still some outstanding issues which could make the plan unsound. However, we feel that these issues could be overcome with minor changes to wording in both the DPD and HRA.

Policy AS23 Station House and Yard, Arnside & Policy AS25 Land at Sandside Road and Quarry Lane, Sandside – Soundness Issue

Regarding these two sites, we disagree with the reasoning of no likelihood of significant effects in the HRA. The HRA needs to be clear that a conclusion of no likelihood of significant effects can only be made because wording has been added to the policy requiring a project level HRA.

Landscape Capacity Approach

Natural England supports the overall landscape capacity approach used in creating this DPD and in particular policy AS01 and the sites which have been allocated. We feel that the approach to protecting key areas of landscape in this way is sound and supports and protects the AONB landscape designation.

The DPD site allocation policy wording for both these sites also needs amending to say that a project level HRA will be required to assess impacts of the developments on the nearby designated sites. The project level HRA will need to include avoidance and mitigation measures necessary to conclude no likelihood of significant effects.

The current wording in the AONB DPD HRA says no likelihood of significant effects alone and both the DPD site allocation policies refer the developer back to the conclusion of the HRA for the AONB DPD. This is misleading and it needs to be clear, in both the HRA and DPD site allocation policy, that a project level HRA is required to assess and mitigate the impacts for both these site allocations.

Please notify me

I have read the guidance notes

Other - misc

Yes

Yes

Thank you for consulting North Yorkshire County Council (NYCC) on the Publication draft of the Arnside and Silverdale AONB DPD.

Officers have reviewed the consultation documentation and do not consider that this raises any strategic cross boundary issues with North Yorkshire.

We consider that South Lakeland District Council and Lancaster City Council have co-operated with North Yorkshire County Council under the Duty to Co-operate in the preparation of the DPD for the AONB and, in so far as NYCC’s interests are concerned, we consider the DPD to be sound and legally compliant.

NYCC does not intend to be represented at the Hearing.

Yours faithfully,

Mark Rushworth
Senior Policy Officer

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

Please notify me

I have read the guidance notes

Other - misc

Yes

The Office of Rail and Road (ORR) has no comment on the development plan.

Please notify me

I have read the guidance notes

AS03 - Housing Provision

No

The DPD is not positively prepared

The DPD is not justified

The DPD is not effective

The DPD is not consistent with national policy

Thank you for giving Persimmon Homes the opportunity to comment on the Arnside & Silverdale AONB DPD. Persimmon is one of the largest house builders nationally. This reflects the growing demand for more to meet the variety of need that is prevalent in all locations, urban and rural.

Our representations will consider the impact of the DPD on Arnside, specifically as this is where Persimmon's interests lie. As demonstrated in previous consultation, Persimmon has land holdings in Arnside. Persimmon's view is that these sites can be delivered for housing, meet unmet need, and the Arnside & Silverdale AONB Should be amended to support this.

As an overarching principle, there is little recognition within the DPD on the actual need for development in the AONB. Little support if given for new development that are thoughtful and fit with the landscape. The DPD needs to recognise that there are social and economic needs that need to be addressed and that this can be done while protecting the special qualities of the AONB. The DPD needs to be pro-active and actively manage land use and development rather than allocate a very small proportion of housing that will contribute to a continually growing affordability problem.

Policy AS03 - Housing Provision

Persimmon Homes supports the need for affordable housing, however this policy requires that proposals for new housing development will be supported where they deliver no less than 50% affordable housing. It goes on to state that only where this is demonstrably unachievable will a lower percentage be acceptable. Introducing the need for 50% affordable housing within the AONB would make development unviable. We recommend that this figure is lowered to 25-30% affordable contribution in line with affordable housing policies from local planning authorities.

Please notify me

I have read the guidance notes

AS01 - Development Strategy

Yes

Yes

Silverdale Parish Council wishes to express its strong support for the publication of the Arnside & Silverdale Area of Outstanding Natural Beauty (AONB) Development Plan Document, for the following reasons:

1. It considers that both the Parish Council and the wider community has had the opportunity and been encouraged, to participate extensively in the creation of the document at all stages of the process.

2. Communication of the intent, purpose, process and content as it evolved, has in the Council’s opinion, been carried out widely by clear and accessible means, helping to ensure the community was made aware and, where they chose to, could readily participate.

3. Feedback with adequate explanation of how decisions were reached, has been provided to help community understanding, especially for points relating to more complex and contentious matters.

4. The Parish Council strongly supports the landscape led approach to the task which it regards as particularly important in order to respect and support the founding reasons for the AONB designation and its future continuance.

5. In view of recent experiences, we are particularly supportive of the proposal to require Affordable housing provision of at least 50% of new development. This is considered most important due to the current, acute, lack of, smaller and more affordable starter homes for young people and families in the village. If this can be upheld and implemented, it would begin a movement towards balancing the age profile of the village and improve the vibrancy, inclusiveness and sustainability of the community.

6. Silverdale, its surrounding hamlets and holiday lodge parks is one of the largest agglomerations of population in the country not having a public wastewater system. All properties have either individual, or shared, private facilities ranging from primitive through to a few instances of more modern treatment plants. One of the principal reasons being the proximity to the surface of the limestone bedrock, which in many places has only a thin soil covering. The complexities and costs of providing a full public system are understood to be extremely high, due to these ground issues. The water services provider, United Utilities, has confirmed it has no plans in place for a public wastewater system, nor anything envisaged in its long-term programme.

7. The wastewater provisions in the DPD were requested to help protect the environment and public health from further risk from private wastewater discharges. We ask that these measures are upheld.

8. We have become aware of the European Waste Water Directive which has been interpreted as placing an absolute restriction on any further new development in areas where the agglomeration of population in the drainage zone exceeds 2000 persons equivalent. For the Silverdale area drainage zone, it has been calculated that approximately 3250 persons equivalents has already been reached.

9. The Parish Council welcomed the joint collaborative team approach by South Lakes District Council and Lancaster City Council to the task of creating the DPD. We believe this has enabled the creation of a strong document, which should help ensure consistency in development decisions throughout the AONB. We would like to express our gratitude to the team members from both authorities for their work on our behalf and the manner in which it has been carried out.

Please notify me

AS15 - Housing Allocations

No

Thank you for seeking the views of United Utilities as part of the Development Plan Document preparation.
In accordance with national planning policy (specifically paragraph 162 of the National Planning Policy Framework and its predecessor PPS12), as well as the status of United Utilities Water Limited as a statutory consultee in the preparation of Development Plan Documents, we would like to continue engagement with South Lakeland District Council throughout the preparation of your planning documents.
United Utilities Water Limited is the statutory water and wastewater undertaker for the North West of England. This includes working with Planning Authorities on the creation of appropriate planning policies and developers on detailed proposals to most appropriately manage the impact on infrastructure.
In the full spirit of the plan-making process and in accordance with paragraph 162 of the NPPF, United Utilities remains engaged in meaningful discussions with South Lakeland District Council regarding their aspirations for future development.
United Utilities wishes to build a strong partnership with all Planning Authorities to aid sustainable development and growth within its area of operation.
We aim to proactively identify future development needs and share our information. This helps:
- ensure a strong connection between development and infrastructure planning;
- deliver sound planning strategies; and
- inform our future infrastructure investment submissions for determination by our regulator.

When preparing the Development Plan and future policies, we can most appropriately manage the impact of development on our infrastructure if development is identified in locations where infrastructure is available with existing capacity. It may be necessary to co-ordinate the delivery of development with the delivery of infrastructure in some circumstances.

SPECIFIC COMMENTS
We wish to highlight to the Council and any other interested parties, the following information which should be taken into consideration and included in the final version of the document.

Draft Policy AS15 – Housing Allocations

We wish to reiterate our comments that were submitted previously (United Utilities’ representations to the Draft Plan Consultation Document – Arnside & Silverdale AONB, letter dated 2nd February 2017).
We do have significant concerns about the deliverability of some of the sites, which we wish to discuss further with the Council in more detail as soon as possible. Without repeating in full our previous comments, the two sites which appear to be most constrained by our assets and may result in development not be deliverable comprise:
AS17 (A6) Land off Queen’s Drive, Arnside; and
AS25 (B35/ B38/ B81/ B125) Land on Sandside Road and Quarry Lane

United Utilities requests that each of the ‘Site Mini-Briefs’ should include a summary of relevant constraints as a means to ensure potential developers are aware of their possible impact at an early stage, particularly in advance of any negotiations involving land values.

We also advise any interested parties to contact United Utilities Developer Services (WastewaterDeveloperServices@uuplc.co.uk) to discuss the site allocations in more detail to understand how we can provide water and wastewater services. United Utilities offers a free pre-application enquiry service.

Summary
Moving forward, we respectfully request that South Lakeland District Council continues to consult with United Utilities during the ongoing preparation of all their planning policies and documents. We are keen to continue working in partnership with the Council to ensure that all new growth can be delivered sustainably, and with the necessary infrastructure available, in line with delivery targets.

United Utilities requests that each of the ‘Site Mini-Briefs’ should include a summary of relevant constraints as a means to ensure potential developers are aware of their possible impact at an early stage, particularly in advance of any negotiations involving land values.

We also advise any interested parties to contact United Utilities Developer Services (WastewaterDeveloperServices@uuplc.co.uk) to discuss the site allocations in more detail to understand how we can provide water and wastewater services. United Utilities offers a free pre-application enquiry service.

Please notify me

I have read the guidance notes

General comment / comment on procedure

Yes

Yes

Members of Warton Parish Council wish me to inform you that they are in agreement with the plan, particularly in its emphasis that land allocated for housing should be for local need with family and affordable dwellings making a large proportion.

John Ball
Clerk to Warton Parish Council

Please notify me

I have read the guidance notes

Other - misc

Yes

National Grid has appointed Amec Foster Wheeler to review and respond to development plan consultations on its behalf.

We have reviewed the above consultation document and can confirm that National Grid has no comments to make in response to this consultation.

Please notify me