Response from Mrs Lorayne Woodend Wall, Friends of the Lake District
1. Mrs Lorayne Woodend Wall, Friends of the Lake District : 21 Nov 2018 12:15:00
Please make your comments in the box below. When referring to the schedule, please include the appropriate reference number e.g. MM1.
MM1
Friends of the Lake District welcomes the inclusion of the requirement for it to be demonstrated through proportionate landscape assessments that developments will not have adverse effects upon the landscape character and visual amenity of the Lake District and Yorkshire Dales National Parks and the Arnside and Silverdale Area of Outstanding Natural Beauty. However, at DM1 point 9, we suggest that the relevant landscape character evidence for the Lake District and Yorkshire Dales National Parks is also referred to along with those for the Arnside & Silverdale AONB and the rest of Cumbria. This is because views into and out of these areas must be taken into account as stated in the policy, but also because the character areas identified in the Lake District National Park Landscape Character Assessment in particular straddle the boundary of the Park in places and re therefore relevant to areas covered by the DM DPD. This will also better reflect new para. 2.1.8, which specifically refers to the setting of both National Parks.
MM4
Friends of the Lake District welcomes the inclusion of references to specifically include biodiversity and habitats as part of this Main Modification but has concerns about the removal from DM4 of reference to qualitative gains. It is unclear why this reference has been dropped.
- Increasing the quantity of GI is of much less value if the existing and/or the new GI is of poor quality
- There will be cases where a qualitative net gain can be achieved (by improving the quality of an existing GI feature) on a site where a quantitative gain is not possible due to space etc. Referring only to quantitative gains only rules out this option and so creates a loop-hole allowing no gains at all.
- Dropping the reference to qualitative gains at the top of the second section of DM4 is also confusing because references to ‘the enhancement/increased functionality of existing assets’ and ‘improved management or restoration of existing habitat’ (both of which are qualitative gains – an improvement in quality rather than extent) have been added in to the policy, suggesting that qualitative gains are still sought. As such, it is not clear what value there is in making the amendment to remove reference to qualitative gains and we suggest reinstating the reference for clarity and to ensure a comprehensive policy.
