Local Development Framework Consultation

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