Local Development Framework Consultation

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.

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