Response from Mr. Christopher Rowley, Westmorland & Lonsdale Green Party
1. Mr. Christopher Rowley, Westmorland & Lonsdale Green Party : 5 Dec 2018 21:01:00
Please make your comments in the box below. When referring to the schedule, please include the appropriate reference number e.g. MM1.
Overall Comment Whilst we support most of the modifications we wish to express concern that the urgency of climate change is not adequately mentioned overall. In the last 5 years it has become evident that there will be significant impacts in our area. Given that, we feel the planning system needs to recognise that some developments (particularly those which are energy related) have significantly negative effects on the atmosphere whilst others have significantly positive effects. Planners need to ability to recognise this distinction in making decisions and the DPD does not always offer the structure required to do so.
MM1-4, pages 27-35.
We recognise that the DPD excludes the two national parks but landscape character doesn't recognise man-made boundaries and the two national park assessments are, in our opinion, still relevant.
MM1 and MM4 – We welcome and support the inclusion and strengthening of the of net gain principles for biodiversity and green and blue infrastructure.
MM1 – Policy DM1, point 9: We recommend the addition to the bullet point list of landscape assessments to be taken account of: Lake District National Park Landscape Character Assessment and Guidelines (2008) or its successor documents and the Yorkshire Dales National Park Landscape Assessment. These needs to be included to ensure that the Landscape assessments of the National Parks are taken account of as well as the Cumbria Landscape Character Assessment and Toolkit. Taking account of the National Park Landscape Assessments will ensure that the special qualities, settings and views in and out are fully understood and addressed in a development proposal.
DM6 Flood Risk and Sustainable Drainage Systems page 36
It is noted that this section aligns with the National Planning and Policy Framework and its purpose is to ensure that existing and new development is not exposed to flood risk and to prioritise the promotion of Sustainable Drainage Systems .
It is noted that the policy requires drainage solutions to comply with DEFRA non statutory technical standards for sustainable drainage systems .
The amendments to this policy are supported, as they appear to support the reduction of flood risk by better management and treatment of surface and foul water and consideration of watercourses and flood defences .
We note the addition of new policy requirements relating to master drainage systems:
Master Drainage Strategy (page 37)
Proposed modification : "Applications for developments on sites which are part of a wider development proposal, especially wider development plan allocations, will be expected to demonstrate how the drainage proposal for the site relates to a wider master drainage strategy for the entire site. Any drainage in early phases of development should have regard to future interconnecting development phases."
Our comment : While this addition is welcome, we would propose this could be extended to requiring developments which are in close proximity to each other in order to show how the drainage infrastructure interconnects.
Habitats Regulating Assessment of the South Lakeland Development Management Policies.
Modifications to the Policy Document
DM1
P.109
Our main comment is that they appear to be strengthening of protection and conservation of habitats and diversity, but retain the ability to use caveats in certain cases by “a competent authority” We are not sure who that would be in this instance – a Minister?
There is no mention of climate change in the modifications and barely in the main report. The whole piece is written as if it’s “business as usual” whereas there will be significant changes to habitats resulting from climate change in the coming years.