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.

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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’.

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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).

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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)?

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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?

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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.

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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?

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