Arnside & Silverdale AONB Development Plan Document: Lancaster City Council and South Lakeland District Council

Duty to Co-operate Statement

Submission, February 2018

Contents

1. Executive Summary ...... 2 2. Introduction ...... 3 3. Strategic Cross-Boundary Matters and Priorities ...... 4 Has engagement been constructive from the outset?...... 5 Has engagement been active? ...... 6 Has engagement been on-going? ...... 6 Has engagement been collaborative? ...... 7 Has every effort been made to secure the necessary co-operation? ...... 7 Has engagement been diligent? ...... 8 Is the evidence robust? ...... 8 Has engagement been of mutual benefit (the broad outcomes)? ...... 8 Appendix 1: Schedule of Duty to Co-operate meetings and engagement ...... 10 Appendix 2: Summary of key issues and outcomes arising from Duty to Co-operate discussions with principal local authorities ...... 12 Appendix 3 – Evidence of correspondence with Neighbouring authorities and statutory bodies 14

1

1. Executive Summary

1.1 This Duty to Co-operate Statement supports the submission of the Arnside & Silverdale Area of Outstanding natural Beauty Development Document (AONB DPD), which has been produced jointly by South Lakeland District Council and Lancaster City Council. It sets out how the Councils have met the provisions of the Localism Act 2011 with regard to the duty to co-operate in their preparation of the AONB DPD in terms of engagement and cooperation with the prescribed bodies specified in the Act. It will demonstrate how this activity meets the provisions of the Act with regard to the AONB DPD and the issues it raises of a strategic and cross-boundary nature. 1.2 The AONB DPD includes a development strategy for the Arnside & Silverdale AONB as a whole and allocates sites to contribute to meeting local, AONB-specific development needs. It does not include any specific requirements in terms of the quantum of development or seek to meet all local needs or those arising elsewhere. Such requirements are included in the District-wide elements of the Local plan for each of the two Districts, which the DMDPD supports and complements, as are allocations to meet the full needs of the Districts. 1.3 The AONB DPD adds to, complements and in some cases supersedes certain strategic policies, or elements of strategic policies set out in the District-wide Local Plans. It provides a consistent planning approach for the whole AONB to ensure that the approach to planning in the area takes into full account the primary purpose of AONB designation and has the conservation and enhancement of the area’s landscape character at it’s heart. The joint preparation of the DPD, which has included very close working with the AONB partnership, represents a very positive example of cooperation in strategic planning. The focus of engagement and cooperation has been relevant and proportionate to the AONB and the issues covered in the AONB DPD. It is in this context this statement should be considered. The statement should be read in conjunction with the Consultation Statement, which provides a clear record of engagement throughout the AONB DPD preparation process.

2

2. Introduction

2.1 Section 110 of the Localism Act 2011 establishes the legal duty to co-operate (DtC) in relation to planning of sustainable development and stipulates that councils are required to engage constructively, actively and on an on-going basis in any process relating to the preparation of development plan documents. Lancaster City Council and South Lakeland District Council (the councils) must have regard to the activities (insofar as they relate to a strategic matter) of any relevant local planning authority, county council or other prescribed body or person. The engagement should include considering whether to consult on and prepare, and enter into and publish, agreements on joint approaches to the undertaking of a number of activities, including the preparation of development plan documents. 2.2 The legislation refers to strategic matters which are, in summary, sustainable development or the use of land that would have a significant impact on at least two planning areas. Further guidance, however, is included within the National Planning Policy Framework (NPPF) and the Planning Practice Guidance (PPG). The NPPF refers to Strategic Priorities (e.g. paragraph 156) and the PPG to both Strategic Priorities (e.g. paragraph 002) and Strategic Matters (e.g. paragraph 001). Whilst such advice cannot over-ride the statutory provisions (which refer to strategic matters), it is clear that it must be taken into account because it includes national guidance on the DtC. 2.3 The NPPF (paragraph 178) confirms that public bodies have a duty to co-operate on planning issues that cross administrative boundaries, particularly those that relate to strategic priorities, such as the delivery of homes and jobs needed in an area and the provision of infrastructure, for example in relation to transport. Strategic priorities across local boundaries should be properly co-ordinated and clearly reflected in individual local plans. The implication is that local planning authorities should, for example, work together to assess the opportunities that exist for the substantiated unmet development requirements of one local authority to be met within the area of one or more nearby local authorities. The emphasis is on diligence and collaboration. 2.4 For the Arnside & Silverdale AONB Development Plan Document (DPD) to be found sound (as opposed to legally compliant) it must be positively prepared and effective. This means it must be based on effective joint working on cross-boundary strategic priorities and where appropriate and sustainable, on a strategy which seeks to meet unmet requirements from neighbouring authorities. 2.5 Further advice is included in the PPG which confirms that a proactive, ongoing and focussed approach to strategic planning and partnership working is required. Active and sustained engagement is required, evidence of co-operation must be robust and co- operation should produce effective and deliverable policies on strategic cross-boundary matters. The exchange of correspondence, conversations or consultations between authorities alone is unlikely to be sufficient.

3

3. Strategic Cross-Boundary Matters and Priorities

3.1 The first sentence of paragraph 156 of the NPPF is unambiguous – local planning authorities should set out the strategic priorities for the area in the Local Plan. Paragraph 178 goes on to explain that public bodies have a duty to co-operate on planning issues that cross administrative boundaries, particularly those that relate to the strategic priorities. Paragraph 179 confirms that local planning authorities should work collaboratively to ensure that strategic priorities across local boundaries are properly co- ordinated and clearly reflected in individual local plans. 3.2 In interpreting the NPPF, the first point to clarify is that the Arnside & Silverdale AONB DPD forms a part of two Local Plans, one covering Lancaster District and one covering South Lakeland District. The DPD is not in itself a Local Plan, but covers a protected landscape that lies within not just two districts but two counties, Lancashire and Cumbria. The finer grain of the DPD is emphasised by its small land area and population, applying the district-wide policies which are supplemented by policies and allocations that shape and direct development in the area. In most respects, the DPD is not the main focus of either district’s strategic priorities in their Local Plan, but the AONB contains significant natural, historic and built environment assets and its designation requires the councils to protect and enhance these features. 3.3 The Objectives for the AONB DPD reflect the objectives set out in the AONB Management Plan, the two relevant Local Plans, national policy, the evidence gathered and wider context. They are: (I) To conserve and enhance the landscape, and the natural beauty of the AONB, including landscape character and visual amenity, wildlife, geology, heritage and settlement character; (II) To ensure that all development is appropriate and sustainable in its location and design and is of high quality;

(III) To ensure that planning policy is shaped by effective community engagement;

(IV) To provide sufficient supply and mix of high quality housing to contribute to meeting the needs of the AONB’s communities, with an emphasis on affordable housing and without adverse impact on the landscape character of the AONB;

(V) To support rural employment and livelihoods, and sustainable tourism;

(VI) To provide the necessary services and infrastructure to support both existing and new development;

(VII) To support the development of a safe and sustainable transport network, including paths and cycleways, to improve connectivity, reduce the need to travel and encourage sustainable forms of transport.

3.4 The Arnside & Silverdale AONB is entirely contained within the two districts and counties, with no other districts close to or adjoining its boundaries, and so the development of the DPD has not been a prominent discussion point with other neighbours. The level of co-operation and joint working between Lancaster and South Lakeland is underpinned by a formal Memorandum of Understanding, but at a practical

4

level it is akin to the merging of the two planning policy teams to ensure that the common purpose of preparing the DPD has been fully realised. The councils have worked closely with the relevant county councils, statutory stakeholders and organisations including the AONB Unit (which is responsible for preparing the AONB Management Plan) and utility providers, to prepare a DPD that ensures that any cross-boundary impacts have been fully considered. 3.5 The remainder of this report sets out how the two Councils have acted together, structured around eight key questions. It brings the record of duty to co-operate activities together in a way that may be updated periodically during the preparation of the DPD and its evidence. The eight questions represent the requirements of the duty:  Has engagement been constructive from the outset?  Has engagement been active?  Has engagement been on-going?  Has engagement been collaborative?  Has every effort been made to secure the necessary co-operation?  Has engagement been diligent?  Is the evidence robust?  Has engagement been of mutual benefit (the broad outcomes)?

Has engagement been constructive from the outset?

3.6 It needs to be demonstrated that cross-boundary issues, for example in terms of housing, employment and infrastructure provision, have been fully addressed and that opportunities to be constructive have been given appropriate consideration and where necessary have been acted upon. 3.7 As soon as the decision was made to jointly prepare the AONB DPD, a Memorandum of Understanding was drawn up to provide a framework for and to set out a shared vision for and commitment to the preparation and delivery of the DPD. 3.8 Without exception, all duty to co-operate engagement has been conducted in a positive and constructive manner. Whilst there are formal meetings to discuss strategic and district-wide matters, and others to set the course for managing the DPD, most engagement between the two districts has been at a practical everyday level, requiring officers to work together to collect and evaluate relevant evidence, to draft options and policies and to communicate progress with stakeholders. 3.9 The purpose of the joint working is to ensure that officers understand the whole of the AONB, can develop joint approaches to evidence gathering and evaluation, establish the relative importance of the issues under discussion, and decide how best to develop a joint approach to policy wording and land allocations within the AONB. The results of this process have been an improved understanding of the cross-boundary and cross- council matters that need to be accommodated in the AONB DPD. 3.10 Both Councils have adopted or are preparing district-wide plans that set out to meet their own strategic needs for development outside protected landscapes including the Arnside & Silverdale AONB. This allowed the councils to agree to take a landscape capacity-led approach to development within the AONB.

5

Has engagement been active?

3.11 Can the Council show that it has been sufficiently active in seeking engagement with nearby local planning authorities (those with which it acknowledges it has a strong economic and spatial relationship) with a view to quantifying and tackling cross-boundary matters and priorities, particularly (but not exclusively) in terms of housing provision. 3.12 The councils have seven immediate neighbouring local authorities (Wyre, Craven, Barrow-in-Furness, Craven, Copeland, Eden and Ribble Valley), and have regular contact with several other authorities in Lancashire, Cumbria and North Yorkshire, including the county councils. The councils have undertaken regular duty to co-operate meetings with their immediate neighbours, pro-actively organising specific meetings, or responding to neighbour requests (see appendices 1 and 2, below). In the interests of proportionality, for more distant neighbours which do not adjoin the AONB, contact is less frequent and more usually conducted by formal email or as a part of a meeting organised for other purposes (such as regular meetings of Lancashire’s and Cumbria’s planning policy officers, or a technical officers’ meeting for the Forest of Bowland AONB). Co-operation also takes place through joint working with other councils, including:  Combined authority arrangements with the county, district and unitary councils in Lancashire and Cumbria.  The Planning Performance Agreement with eight local authorities collaborating together with National Grid on the North West Coast Connections NSIP project.  Bids for infrastructure funding from the Regional Growth Fund.  Engagement with the Yorkshire Dales National Park Authority (both councils) and the Lake District National Park Authority (South Lakeland).

3.13 The same approach is taken with other public bodies1, including statutory organisations, utility providers and the Local Enterprise Partnerships (LEP) in Lancashire and Cumbria. 3.14 A full record of duty to co-operate meetings has been maintained (see appendices), with details of agreed actions and outcomes recorded in the notes of formal meetings. Further information is also available in the Consultation statement to demonstrate the engagement with neighbouring and more distant neighbours. Has engagement been on-going?

3.15 In order to achieve this objective, there should be continuing and frequent engagement, even if that engagement is only to provide an up-date on issues of strategic relevance. 3.16 Yes. The DPD itself was prompted by the direction of the Inspector at the SLDC Land Allocations examination in 2013, and informed by earlier duty to co-operate discussions between the two councils. The summary table below shows the key actions from duty to co-operate meetings attended by officers and members from the councils. Most of these meetings were initiated by council officers. Some include arrangements for follow-up

1 As set out in Part 2 of the Town & Country Planning (Local Planning) (England) Regulations 2012.

6

meetings or other actions. Where follow-up meetings are not highlighted, the usual practice has been for the councils to arrange duty to co-operate meetings at key stages of plan preparation, such as just prior to the consultation stage on the DPD. 3.17 The arrangements for the Arnside & Silverdale AONB DPD are more sophisticated than for most district-wide co-operation, involving much closer day to day working relationships. This includes the joint commissioning of evidence, joint working on report preparation, site visits and consultation with interested parties including local stakeholders. These projects also include regular involvement of elected members, through reporting, consultation and stakeholder briefings. Has engagement been collaborative?

3.18 The Council needs to demonstrate that it has worked with the relevant bodies in a co- operative and positive manner. There is no obligation on the Council to agree with its neighbours but unless it has entered fully into the debate, it is difficult to conclude that there has been collaboration. 3.19 The tone of all duty to co-operate engagement involving the councils is co-operative and positive. The purpose of the meetings is always to understand the key issues faced by each party and the implications that follow: neighbouring authorities routinely invite each other to scrutinise draft briefs and reports covering topics such as housing needs, viability, habitat regulations assessment or sustainability appraisal, which have the benefit of improving cross-boundary collaboration. In this way there is a closer understanding of key issues and the need to work together to find optimal strategies and solutions. 3.20 Collaboration with other public bodies and utility providers often takes a different approach, requiring the councils to understand more about funding cycles and priorities for investment. Even where this introduces a constraint on some aspect of development, it adds to the understanding of strategic issues and helps the councils to improve the deliverability of the DPD. 3.21 In preparing the Arnside & Silverdale AONB DPD, joint evidence was commissioned by the two councils into issues including housing needs, Habitats Regulation Assessment and Sustainability Appraisal. Officers from the two councils began day to day joint working from the start of the process, including regular engagement with the AONB Unit. The joint working always been on basis of listening to each other’s ideas, suggestions, issues and then discussing to reach agreement, or appropriate compromise if necessary during every aspect of the process, resulting in a successful process and excellent working relationships. A key piece of work was the assessment of site suggestions throughout the whole AONB, to build up a robust evidence base to support the suitability of sites for development. The result of the collaboration is that officers have a much better understanding of the key strategic planning issues and special circumstances of the whole AONB. Has every effort been made to secure the necessary co-operation?

3.22 The Council needs to demonstrate that no stone has been left unturned in the pursuit of co-operation. Active and sustained engagement should be the objective.

7

3.23 This has never been a problem in the experience of the councils. Whilst all duty to co- operate partners are busy, it is apparent that all will respond to reasonable requests for meetings or feedback on some aspect of common strategic interest. On occasion it has been necessary to chase up replies to correspondence, and for this we would always ensure that we obtain replies from our immediate neighbours or other key co-operation partners. For the AONB DPD, joint working between the two councils has been led by named individuals throughout the plan preparation process. A range of methods of co- operation have been employed, including flexibility of meeting and working arrangements such as officers working in the other Council’s offices where this made for more efficient progress on the AONB DPD to be made. Has engagement been diligent?

3.24 In order to demonstrate diligence it is reasonable to conclude that the Council’s approach should have been careful, thorough and with commitment. 3.25 We give thought to the frequency and nature of our engagement. There is a high degree of commitment to the process from both Councils and this is reflected in the extent and quality of the collaboration. Key points include the formal commitment of the Memorandum of Understanding for joint working, commissioning or reporting of new evidence on housing needs, and key stages in the preparation of DPDs. All engagement is noted and for formal meetings minutes are circulated and agreed. Is the evidence robust? Do the Council’s submissions strike the right balance between necessary and comprehensive co-operation?

3.26 Whilst no council has the resources to co-operate full time with all potential partners, the Councils have sought to take a proportionate approach by committing the most time and resources to the activities and partners most relevant to each stage. Different methods were used to engage relevant stakeholders and different stakeholders were the focus of engagement at particular stages of preparing the plan: for example the site assessment methodology consultation targeted parishes, land-owners and organisations such as Natural England whereas the Issues and Options stage focused on awareness raising amongst residents. In assessing the 130 sites put forward for development in the AONB, all sites were reviewed by officers from both councils, and most also involved advice from officers at the AONB Unit. Has engagement been of mutual benefit (the broad outcomes)?

3.27 It may not be possible to achieve a high level of mutual benefit and there is no requirement for Councils to agree. However, if that is the case then robust evidence has to be available to demonstrate that at least the achievement of mutual benefit has been sought. 3.28 Yes, insofar as the Councils are attempting to develop a DPD containing policies and allocations that are based on joint working and a joint evidence base, supported by widespread consultation and engagement. The benefits will come about if a joint DPD is adopted and then used to guide the protection and development of land in the AONB. 3.29 Plan-making in the Arnside & Silverdale AONB has been a very positive experience of partnership and collaborative working between the key officers involved, between the two councils and between these parties and the communities and organisations

8

representing the AONB – a successful process to date, praised and welcomed by many stakeholders.

9

Appendix 1: Schedule of Duty to Co-operate meetings and engagement

Reports n/a n/a n/a n/a n/a n/a Reports to LCC Councils/Committees 05-03-2013 23-04-2013 17-07-2013 05-11-2014 04-11-2015 27-01-2016 09-11-2016 13-06-2017 27-09-2017 n/a n/a n/a Reports to SLDC Councils/Committees 26-10-2016 13-09-2017 12-10-2017 n/a n/a n/a Joint Report to AONB Executive (Parish councils, 09-10-2013 14-10-2015 09-03-2016 19-10-2016 15-03-2017 18-10-2017 district and county councils, statutory bodies, and a range of other relevant organisations represented) Officer meetings n/a n/a n/a n/a n/a n/a General Lancaster/SLDC DtC Meeting 05-12-2012 03-12-2015 07-02-2017 n/a n/a n/a Specific Lancaster/SLDC AONB DPD DtC Meeting 25-06-2013 28-05-2015 12-08-2015 18-08-2015 12-07-2016 30-08-2016 14-09-2016 27-09-2016 27-02-2017 30-03-2017 24-04-2017 08-05-2017 22-06-2017 17-05-2017 30-06-2017 16-08-2017 23-08-2017 06-10-2017 AONB Technical Officers’ Group meetings (includes 27-02-2013 25-09-2013 03-03-2014 25-09-2014 26-02-2015 09-07-2015 key stakeholder representatives such as County Councils) 23-09-2015 11-10-2016 11-10-2017 n/a n/a n/a Lancaster Barrister Conference 07-02-2013 n/a n/a n/a n/a n/a Stakeholder Meetings n/a n/a n/a n/a n/a n/a AONB Unit 19-03-2013 02-07-2013 20-08-2013 09-09-2013 03-03-2014 23-05-2014 15-08-2014 25-09-2014 01-04-2015 05-05-2015 12-05-2015 03-09-2015 22-09-2015 26-02-2016 20-04-2016 06-05-2016 26-07-2016 28-07-2016 11-10-2016 07-04-2017 28-04-2017 18-05-2017 26-07-2017 n/a Parish, district and county councils, statutory bodies, 20-05-2014 12-11-2014 09-06-2015 14-11-2016 07-11-2017 n/a and other relevant organisations and groups PAS 01-12-2014 22-01-2015 n/a n/a n/a n/a Infrastructure Providers 05-07-2016 n/a n/a n/a n/a n/a Environment Agency 23-01-2017 17-08-2017t n/a n/a n/a n/a RSPB 15-01-2013 n/a n/a n/a n/a n/a Meeting with LDNPA officers 03-07-2014 n/a n/a n/a n/a n/a Meeting with YDNPA officers 07-04-2017 n/a n/a n/a n/a n/a Meeting with Registered Providers 26-09-2014 n/a n/a n/a n/a n/a 10

Developer/Site meetings n/a n/a n/a n/a n/a n/a AS17 (A6) developer meeting 24-01-2017 n/a n/a n/a n/a n/a AS18 (A9) developer meeting 06-01-2017 n/a n/a n/a n/a n/a AS19 (A11) developer meeting 15-02-2017 n/a n/a n/a n/a n/a AS20 (B108) developer meeting 18-09-2015 05-01-2017 n/a n/a n/a n/a AS21 (W88) developer meeting 22-06-2017 06-09-2017 n/a n/a n/a n/a AS22 (W130) developer meeting 27-02-2017 n/a n/a n/a n/a n/a AS23 (A26/A27) developer meeting 09-03-2017 n/a n/a n/a n/a n/a AS24 (S70) developer meeting 05-01-2017 n/a n/a n/a n/a n/a AS25 (B35) developer meeting 04-01-2017 n/a n/a n/a n/a n/a AS25 (B38) developer meeting 18-09-2015 05-01-2017 n/a n/a n/a n/a AS25 (B81) developer meeting 23-01-2017 n/a n/a n/a n/a n/a AS25 (B125) developer meeting 26-01-2017 n/a n/a n/a n/a n/a Evidence commissioning n/a n/a n/a n/a n/a n/a SA/HRA commissioning 13-02-2015 n/a n/a n/a n/a n/a Landscape commissioning 14-06-2015 n/a n/a n/a n/a n/a Ecology commissioning 31-03-2016 n/a n/a n/a n/a n/a Viability commissioning (AV) 17-04-2017 n/a n/a n/a n/a n/a Joint working arrangements n/a n/a n/a n/a n/a n/a Memorandum of Understanding 15-11-2013 n/a n/a n/a n/a n/a

Several stages of consultation held including formal and extra/informal consultation. These included consultation with statutory bodies, duty to cooperate bodies and the general public and are documented in the Consultation Statement. Informal meetings held between officers and relevant Ward Councillors during the plan-making process. Informal telephone calls held between officers and AONB Unit staff and between LCC and SLDC officers to discuss day to day matters relating to the process. SLDC Officer worked, from time to time, at LCC’s office and vice versa as the process required or benefited from this – for example when working jointly to process and agree action resulting from responses to consultation.

Grey shading: verbal report Blue shading: formal meeting Orange shading: Council report/resolution t = telephone call 11

Appendix 2: Summary of key issues and outcomes arising from Duty to Co-operate discussions with principal local authorities

Council Shared Issue Identified Outcomes or Resolutions How reflected in Local Plan or DPD? South  OAN methodology and calculation  Shared information (SLDC use Arc4).  Informed the need for Lancaster to review Lakeland/ (HMA overlap).  Shared information. its Green Belt and propose release of Lancaster  Resolution to prepare a joint AONB DPD, land for development in South Carnforth.  Employment and jobs strategies. beginning with a Memorandum of  None. No conflicts between the two Understanding, signed in November districts’ employment strategies.  Opportunity for common approach to 2013.  Full co-operation on the preparation of a planning within the protected  Joint evidence prepared for: joint AONB DPD, and the modification of landscape of the Arnside & Silverdale - Habitats Regulations Assessment several DM policies. AONB. - Sustainability Appraisal  Joint evidence applied to develop policies  Need for joint evidence for AONB - Housing Needs and allocations in the DPD. DPD. - Housing Viability - Landscape and Ecological assessments - Open Space - Caravan site capacity Lancashire  Duty to Co-operate Memorandum of  Memorandum covers sustainable  Provides structure for liaison and joint Understanding between Lancashire transport; economic growth; education; work with Lancashire, resulting in policy and Lancaster signed in March 2016. public health; heritage asset protection; changes. natural heritage protection.  Education provision.  Regular meetings to understand new education provision and plan how it  Informed policy wording and allocation of relates to housing and infrastructure strategic sites for development. provision.

 Extensive collaboration on Local Plan and  Alignment of Local Plan and Masterplan, LCC Highways and Transportation  Highways and Transportation. especially in respect of transport Masterplan. modelling and M6 junction 33 re-design.  Shadow Combined Authority began  Combined Authority status will improve operation in 2017, with structured joint joint working and co-ordination of

12

Council Shared Issue Identified Outcomes or Resolutions How reflected in Local Plan or DPD?  Collaboration on county-wide strategic working arrangements on planning investment in infrastructure, as set out in issues as part of Combined Authority. issues. the Local Plan.

Cumbria  Sub-regional NSIP projects requiring  Lancaster and SLDC’s participation in  Land allocation and DM policy changes in collaboration, including Walney PPA arrangements with Cumbria County respect of approach to major energy Extension Offshore Windfarm and Council, Lancashire County Council and projects. NWCC electricity transmission. several Cumbrian district councils.  Principal benefit is for development  Mapping of vertical infrastructure.  Lancaster’s existing and proposed management, especially for new vertical infrastructure mapped on infrastructure applications close to county Cumbrian database. boundary.

13

Appendix 3 – Evidence of correspondence with Neighbouring authorities and statutory bodies

1. Barrow Borough Council ...... 15 2. Copeland Borough Council ...... 15 3. Eden District Council ...... 16 4. Craven District Council ...... 17 5. Cumbria County Council ...... 18 6. Wyre Council ...... 19 7. Ribble Valley Borough Council ...... 19 8. Lancashire County Council ...... 20 9. Lake District National Park Authority ...... 20 10. Yorkshire Dales National Park Authority ...... 21 11. North Yorkshire County Council ...... 22 12. Environment Agency ...... 23 13. Historic England ...... 24 14. Natural England ...... 26 15. Civil Aviation Authority ...... 26 16. Homes and Communities Agency ...... 27 17. Morecambe Bay Clinical Commissioning Group ...... 28 18. NHS Trust ...... 28 19. Office of Rail and Road ...... 29 20. Highways England ...... 29 21. Marine Management Organisation ...... 30 22. Morecambe Bay Local Nature Partnership ...... 30 23. Cumbria Local Nature Partnership ...... 31 24. Arnside & Silverdale AONB Partnership ...... 32

14

1. Barrow Borough Council

2. Copeland Borough Council

15

3. Eden District Council

16

4. Craven District Council

17

5. Cumbria County Council

18

6. Wyre Council

7. Ribble Valley Borough Council

19

8. Lancashire County Council

9. Lake District National Park Authority

20

10. Yorkshire Dales National Park Authority

21

11. North Yorkshire County Council

22

12. Environment Agency

23

13. Historic England

24

25

14. Natural England

15. Civil Aviation Authority

26

16. Homes and Communities Agency

27

17. Morecambe Bay Clinical Commissioning Group

18. NHS Trust

28

19. Office of Rail and Road

20. Highways England

29

21. Marine Management Organisation

22. Morecambe Bay Local Nature Partnership

30

23. Cumbria Local Nature Partnership

31

24. Arnside & Silverdale AONB Partnership

32