Local Development Framework Consultation

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