Executive Minutes 6 March 2012

Appendix 2

Lakes to Dales Landscape Designation Project Formal Consultation Response Agreed by Eden District Council on 6 March 2012

As such, the following issues remain of concern to Eden District Council:

1. Inclusion of Orton Fells in the Yorkshire Dales National Park

In particular the authority is concerned by the following implications of designation:

Democratic deficit The area is remote from the majority of the Yorkshire Dales, and is not an intrinsic part, therefore making it more difficult to access local planning and other services. This is already an issue in such a sparsely populated district as Eden, but designation would exacerbate this still further.

Also, although the composition of the Yorkshire Dales National Park Board includes nominated member representation from the relevant County and Districts the majority of the Board is made by appointment and are not democratically accountable to local people.

Affordable housing Affordable housing is one of the Council’s corporate priorities as reflected by the adopted Core Strategy. In our experience it is near impossible to achieve affordable housing that meets the need of local people without an element of market led housing to make developments viable. Within the Orton Fells area there are six designated Local Service Centres where we would consider such market led housing but we are concerned that YDNPA’s housing policies lack the degree of flexibility required to deliver affordable housing (Appendix 2 of the attached report summarises the two approaches).

1 Furthermore, Eden’s housing market is one of the least affordable areas in the country. As house prices are somewhat higher in national parks, designation can only exacerbate this problem further; undoubtedly increasing the number of local households in housing need whilst reducing the authority’s powers to address the issue as we would no longer be the local planning authority.

Planning Eden has a good record in managing development in the proposed areas and we remain unconvinced that the Orton Fells would be better protected by YDNPA’s planning policies or that the inevitable administrative disruption and confusion would be justified. In any event the future of planning is set to change once the Localism Bill is enacted. In Eden we have piloted a number of Big Society vanguard areas such as the Upper Eden where progress on its Community Plan may be adversely affected as some parishes would fall within the YDNP and others not.

2. Proposed boundaries Local Members have requested that the boundaries of Reagill, Sleagill and Kirkby Stephen be reviewed so that a parish falls entirely in one administrative area.

3. Strategic Environmental Assessment and the Equality Impact assessment We have no specific comments to make on the Strategic Environmental Assessment or the Equality Impact assessment.

In conclusion there is no merit as to why, after sixty years of successful stewardship and land management, the Orton Fells now need to be additionally protected by a national park designation.

Your Reference: Our Reference: RA/PCA3/1/1 Enquiries to: Ruth Atkinson Direct Dial: (01768) 212202 Date: 8 March 2012

The Right Honourable Caroline Spelman Secretary of State for the Environment, Food and Rural Affairs Department for Environment, Food and Rural Affairs Protected Landscape Team Zone 1/09, Temple Quay House The Square, Temple Quay Bristol BS1 6EB

Dear Mrs Spelman

Lakes to Dales Landscape Designation Project

Formal Consultation Response Agreed by Eden District Council on 6 March 2012

I am writing to advise you that Eden District Council is in opposition to the Orders of variation to the boundaries of the Lake District and Yorkshire Dales National parks within Eden. This response was agreed by Eden District Council’s Executive on the 6 March 2012 and I attach a copy of both the report and the minutes for your information. This response reiterates and summarises that made to Natural England in a letter dated 27 June 2011; also attached for your information (appendix 1). The council recognises that there are differing views that exist within the district on the proposed extensions. In recording opposition to the Variation Order, we note that this triggers a public enquiry and we believe that is will be beneficial for an enquiry to be held, thereby allowing all the views expressed to be heard in public and considered. The council present its comments below and does not intend to appear in person at the enquiry to defend them. You requested views on the following issues: 1. Inclusion of Orton Fells in the Yorkshire Dales National Park

We appreciate the special character of this landscape but we are unconvinced that the protection of it would be best achieved by national park designation and believe that the area does not need such designations to protect it from inappropriate development. The Orton Fells have long been subject to local farming and land management regimes as well as this authority’s and Cumbria County Council’s planning policies, and the fact that this area still meets the national park designation criteria is testament to its successful protection already in place. In particular the authority is concerned by the following implications of designation: Democratic deficit The area is remote from the majority of the Yorkshire Dales, and is not an intrinsic part, therefore making it more difficult to access local planning and other services.

3 This is already an issue in such a sparsely populated district as Eden, but designation would exacerbate this still further. Also, although the composition of the Yorkshire Dales National Park Board includes nominated member representation from the relevant County and Districts the majority of the Board is made by appointment and are not democratically accountable to local people.

Furthermore, Eden’s housing market is one of the least affordable areas in the country. As house prices are somewhat higher in national parks, designation can only exacerbate this problem further; undoubtedly increasing the number of local households in housing need whilst reducing the authority’s powers to address the issue as we would no longer be the local planning authority.

2. Proposed boundaries Local Members have requested that the boundaries of Reagill, Sleagill and Kirkby Stephen be reviewed so that a parish falls entirely in one administrative area.

3. Strategic Environmental Assessment and the Equality Impact assessment. We have no specific comments to make on the Strategic Environmental Assessment or the Equality Impact assessment. In conclusion there is no merit as to why, after sixty years of successful stewardship and land management, the Orton Fells now need to be additionally protected by a national park designation. Yours faithfully/sincerely

Ruth Atkinson Director of Communities

4 Your reference: Our reference:RA/PCA3/1/1 Enquiries to:Ruth Atkinson Direct Dial:(01768) 212202 Date:27 June 2011

Town Hall Penrith Cumbria CA11 7QF Telephone: (01768) 817817 Lakes to Dales Landscape Designation Project Facsimile: (01768) 212138 Natural England Internet: www.eden.gov.uk Email: [email protected] Bridgewater House 60 Whitworth Street Manchester M1 6LT Dear Sir/Madam Lakes to Dales Landscape Designation Project Formal Consultation Response Agreed by Eden District Council on 16 June 2011 I am writing to you to advise you that Eden District Council maintains its opposition to extensions of the Lake District and Yorkshire Dales National Parks within Eden. This response was agreed by Eden District Council on 16 June 2011 and I attach a copy of both the report and the minutes for your information. This response supplements that made last year and agreed by the Council on 25 February 2010. You requested views on the following issues: 1 Inclusion of Orton Fells in the Yorkshire Dales National Park Our position remains unchanged in that we still remain unconvinced that it is desirable to designate this, or indeed any, of the proposed extensions and additions as national park irrespective of whether this is the Lake District or the Yorkshire Dales National Park. The area does not need to be included in a National Park to be protected from inappropriate development. As previously we have no issue with your general assessment of Orton Fells’ natural beauty and its opportunities for open-air recreation, but do not agree that the long term protection of this sensitive landscape is best achieved by national park designation. Furthermore we are surprised that extensions to the national parks are being considered at this time of financial austerity and severe restrictions in public sector finance. That this area has a high natural and cultural landscape value is evidenced by the range and number of European, national and local designations that are in place to protect them. These safeguards were not in place sixty years ago when the national parks were designated and at that time there was a concern that development pressures would erode the natural beauty of the areas and the opportunities for outdoor recreation. The Orton Fells have been subject to local farming and land management regimes as well as this authority’s planning policies and those of Cumbria County Council since 1974 and by the local government bodies that preceded them. The fact that this area now still meets the designation criteria for a national park is testament to sufficient protection already being in place from current status and planning and land

5 management arrangements. In our opinion the case has yet to be made as to why, after sixty years of successful local stewardship, the Orton Fells now need to be additionally protected by national park designation. The words of one of our Orton Fells Members best sums it up – “If it ain’t broke, don’t fix it”. In particular this authority is concerned by the following implications of designation: Democratic deficit The area is remote from the majority of the Yorkshire Dales, is not an intrinsic part of the Yorkshire Dales and the people of the area would not have an effective representation on the Board given the lack of democratic arrangements and distances to offices. The composition of the Yorkshire Dales National Park Board includes nominated member representation from the relevant County and Districts however the majority of the Board is made by appointment. The Boards have considerable powers and yet are not democratically accountable to local people. The offices of the YDNPA are remote from the Orton Fells making it more difficult to access local planning and other services. This is already an issue in such a sparsely populated district as Eden, but designation would exacerbate this still further. Affordable Housing The Authority is not satisfied that provision of housing will be met sufficiently and appropriately if the area is subject to the YDNPA’s housing policies as it does not take account of the area’s specific and particular needs. Affordable housing is one of the Council’s corporate priorities and through the recent adoption of key planning policy documents we are now beginning to deliver much needed affordable housing on the ground. It is our experience that it is difficult to achieve affordable housing that meets local needs without an element of market led housing to make such development economically viable in sustainable locations. Within the Orton Fells area there are six designated Local Service Centres (Orton; Crosby Garrett; Nateby; Great Asby; Crosby Ravensworth and Mauds Meaburn) where we would consider such market led housing. Although similar in many ways to our own approach we are nevertheless concerned that YDNPA’s emerging housing policies lack the degree of flexibility required to deliver affordable housing. We would refer you to Appendix 4 of the attached report to Council which contains a summary of the two approaches. Currently our local housing market is one of the least affordable areas in the country, which inhibits economic growth in the district. As house prices are somewhat higher in national parks with an inevitable ripple effect for those areas on the fringes, designation can only exacerbate this problem further. It is therefore likely that the number of local households in housing need will increase whilst the authority’s powers to address the issues will decrease as we would no longer be the local planning authority. Planning Eden has a good record in managing development in the proposed areas, having successfully safeguarded the landscape from inappropriate wind farm development and leisure proposals. We remain unconvinced that the Orton Fells would be better protected by YDNPA’s planning policies or that the inevitable administrative disruption and confusion would be justified. In any event the future of planning is set to change once the Localism Bill is enacted. In Eden we have piloted a number of Big Society vanguard areas such as the Upper Eden where progress on its Community Plan may be adversely affected as some parishes would fall within the YDNP and others not.

6 2 Proposed boundaries Local Members have requested that the boundaries of Reagill, Sleagill and Kirkby Stephen be reviewed so that a parish falls entirely in one administrative area. 3 Strategic Environmental Assessment and the Equality Impact assessment. We have no specific comments to make on the Strategic Environmental Assessment or the Equality Impact assessment. Yours faithfully

Ruth Atkinson Director Policy and Performance