Local Development Framework Consultation

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 effective

The DPD is not consistent with national policy

The DPD is not positively prepared

The DPD is not justified

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