STATEMENT OF COMPLIANCE.

(REGULATION 28 STATEMENT). Lancaster District Core Strategy

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Table of Contents

1. Introduction...... 1 2. Consultation under Regulation 25 (Issues and Options Consultation) ...... 2 Statutory Requirement ...... 2 Statement of Community Involvement Requirements...... 2 Measures Undertaken...... 2 Representations Received...... 3 How the Council addressed Issues Raised ...... 3 3. Regulation 26 Consultation (Preferred Options) ...... 5 Statutory Requirement ...... 5 Statement of Community Involvement Requirements;...... 5 Methods of Consultation ...... 5 Tier 1 – Consultation Leaflet; ...... 6 Tier 2 - ‘Let’s plan the future together’ Core Strategy Consultation (Booklet and separate response form);...... 6 Tier 3- The Core Strategy Preferred Option Document; ...... 6 Response...... 7 4. Preferred Options – Addendum Consultation...... 8 APPENDIX 1 - DPD BODIES...... 9 APPENDIX 2 – ISSUES AND OPTIONS CONSULTATION – FORMAL RESPONSES ...... 15 APPENDIX 3 – ISSUES AND OPTIONS CONSULTATION – REPORTS OF SEMINARS AND EVENTS AND SUBSEQUENT REPRESENTATIONS MADE...... 27 APPENDIX 4 – PREFERRED OPTIONS CONSULTATION - DPD MATTERS ...... 53 APPENDIX 5 – RESPONSES TO PREFERRED OPTIONS CONSULTATION ...... 57 COMMENTS ON CORE STRATEGY INTRODUCTION ...... 59 COMMENTS ON CONTEXT SECTION...... 59 COMMENTS ON REQUIREMENTS AND OPTIONS SECTION...... 61 COMMENTS ON SPATIAL DEVELOPMENT STRATEGY SECTION ...... 62 COMMENTS ON SDF 1 – URBAN CONCENTRATION and associated text ...... 63 COMMENTS ON SDF 2 – ECONOMIC GROWTH and associated text ...... 66 COMMENTS ON SDF 3 – REGENERATION PRIORITY AREAS and associated text ...... 69 COMMENTS ON SDF 4 – SUSTAINABILITY and associated text ...... 71 COMMENTS ON SDF 5 – ENVIRONMENTAL CAPITAL and associated text ...... 75 COMMENTS ON SDF 6 –TRANSPORT and associated text ...... 77 COMMENTS ON SDF 7 – RURAL AREAS and associated text ...... 79 COMMENTS ON POLICY ER1 – HIGHER EDUCATION and associated text ...... 81 COMMENTS ON POLICY ER2 – EMPLOYMENT LAND ALLOCATIONS ...... 82 and associated text ...... 82 COMMENTS ON POLICY ER2 – EXISTING EMPLOYMENT AREAS and associated text ...... 83 COMMENTS ON POLICY ER4 –RETAIL HIERARCHY and associated text...... 85 COMMENTS ON POLICY ER5 – NEW RETAIL DEVELOPMENT and associated text ...... 86 COMMENTS ON POLICY ER6 – DEVELOPING TOURISM and associated text ...... 86 COMMENTS ON POLICY HS1 – MEETING THE DISTRICT’S HOUSING REQUIREMENTS and associated text ...... 87 COMMENTS ON POLICY HS2 – ACHIEVING QUALITY IN DESIGN and associated text...... 90 COMMENTS ON POLICY HS3 – COMMUNITY SAFETY and associated text ...... 91 COMMENTS ON POLICY HS4 – RURAL COMMUNITIES and associated text...... 92 COMMENTS ON POLICY CE1 – IMPROVING THE ENVIRONMENT and associated text ...... 92 APPENDIX 6 – RESPONSES TO PREFERRED OPTIONS ADDENDUM CONSULTATION ..... 98

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1. Introduction .

1.1 As part of its Local Development 1.4 The Council’s Statement of Framework, the Council is preparing Community Involvement was adopted a Core Strategy which sets out the in June 2006, after all consultation Council’s proposed overall spatial exercises were undertaken and planning framework for the period compliance is required only with 2003-2021. minimum regulatory requirements to meet Soundness Test 2. 1.2 This Statement sets out the Notwithstanding the above, consultation measures undertaken, consultations were carried out in line the responses received and the with the Statement of Community Council’s response to those Involvement where these could have objections. been anticipated.

1.3 Soundness Test 2 for Local 1.5 Two rounds of consultation have Development Documents states that already taken place. The first stage the Development Plan Document has was consultation on Issues and been prepared in compliance with the Options during the first half of 2005 Statement of Community Involvement (known as Regulation 25 (SCI), or with the minimum Consultation) and one on the requirements set out in the Council’s Preferred Options for a regulations where no SCI exists; Core Strategy (known as Regulation 26 Consultation).

1.6 The latter incorporated a short addendum consultation on additional matters related to the rejected options. This document describes both consultation processes, the responses received, the key issues raised and how the Council has responded to these concerns.

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2. Consultation under Regulation 25

(Issues and Options Consultation) .

2.4 In order to facilitate discussion, an Statutory Requirement Issues and Options paper was circulated which set out six strategic 2.1 1Government regulations require that options for the Core Strategy and the Council consult on Issues and asked 38 questions. Options with specific and general consultation bodies 2.5 We also held Seminars on Issues and Options with the Local Strategic Statement of Community Partnership (July 25th 2005), Involvement Requirements members of the Council (September 26th 2005) and Parish and Town 2.2 The Council’s Statement of Councils (November 26th 2005). Community Involvement, adopted in Records of all of these events are June 2006 requires that the following attached in Appendix 3. measures be undertaken during Issues and Options consultation; 2.6 The bodies consulted included • Consultation on Issues and • the North West Regional Options with bodies set out in Assembly, Appendix 1 of this document; • the North West Development • Issues and Options papers Agency and Yorkshire Forward; published on Council website; • the Highways Agency, • Issues and options raised with • the Environment Agency; Local Strategic Partnership • English Heritage; • Press release • English Nature; • Comment invited from all stakeholders on key questions. • Neighbouring District Councils, • Consultation period of 4 months • the Yorkshire Dales National Park Authority, Measures Undertaken • , North Yorkshire and Cumbria County Councils and 2.3 Issues and Options Consultation was • Parish Councils within the District. carried out between January and November 2005. Before preparing 2.7 Although Parish Councils adjoining the Core Strategy, we consulted by the District boundary were omitted at letter, and (where available) e-mail, this stage, they were consulted at with the bodies listed in Appendix 1 to Preferred Options stage. No gather their views on Issues and responses were received from them. Options for a Core Strategy.

1.1 1 Statutory Instrument 2004 no 2204 Town and Country Planning (Local Development)() Regulations 2004 Regulation 25

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• A general consensus that Representations Received development in villages should be restricted to that required for local 2.8 27 organisations submitted needs; representations on the Core Strategy • Requests to identify large sites for Issues and Options document. development at Whinney Carr, Representations have been received and Luneside West; from developers, members of the public and local and national amenity • Concern that the role of Lancaster groups. A schedule of responses City Centre needs to be received is attached as Appendix 2. strengthened; • Concern that the Strategy should 2.9 In terms of the six development address renewable energy issues; options, the majority of responses favoured Option 1 – Urban • Support for high quality design. Concentration although there was also support for Option 4 (Regeneration) and Option 6 (No How the Council addressed Strategy). There was concern that Issues Raised any option suggested should be compatable with the Regional Spatial 2.11 We have addressed these issues by; Strategy. Finally United Utilities were concerned that the Strategy should • In response to the fact that most have regard to existing utilities respondents who expressed a infrastructure. preference favoured Option 1 (Urban Concentration), we 2.10 Some issues raised included; adopted Urban Concentration as • Concern from the North West our preferred option. Regional Assembly that the Core • In response to NWRA’s concerns, Strategy timetable should allow for we delayed preferred options the emerging policy framework consultation until January 2006, to developed through revisions to the allow for the publication of the Regional Spatial Strategy; submission RSS. • Need for documents to be more • In response to concerns about approachable in terms of language presentation, we have sought to and presentation; make our documents as user • Commendation for the user friendly as possible in spite of the friendly approach of the complexity demanded by documents; requirements of the new system. • Concern that Issues and Options • We also commissioned a graphic paper did not adequately address design consultancy to produce a environment and sustainability design identity for LDF documents issues; and presentational material. The preferred options consultation will be described in following sections of the document.

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• Environment and Sustainability • In response to the need for the issues have been addressed in Core Strategy to address considerable detail in the renewable energy issues, a policy Sustainability Appraisal Report. on renewable energy was included The Council’s approach to in the Submission edition of the sustainability appraisal has been Strategy which seeks to maximise widely praised by local the proportion of energy in the stakeholders. district from renewable sources, identifies South as a key • The Core Strategy cannot allocate renewable energy resource and sites and therefore requests for promote micro-renewables site allocations and we could not through its development control therefore address these policies; objections. • In response to the need for the • In response to the need to Core Strategy to support high strengthen the role of Lancaster quality design, leading the North City Centre, the preferred options West in design quality was document identified a strong role incorporated within the spatial for Lancaster City Centre as a vision, and a strategic design shopping centre, a visitor policy included within the destination, a historical and Preferred Options document which cultural centre and a sustainable defines areas in the district where location for new employment. This high quality design will be role will be re-inforced with the essential. preparation of a Lancaster City Centre Spatial Strategy as one of the Council’s first Supplementary Planning documents;

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3. Regulation 26 Consultation

(Preferred Options) . documents are available for inspection and the places and Statutory Requirement times at which they can be inspected. 3.1 2Government regulations require that the Council

• make copies of the pre-submission proposals documents and a statement of the proposals matters available for inspection during Statement of Community normal office hours Involvement Requirements; ‰ at their principal office, and • Advertisement in both Lancaster ‰ at such other places within Guardian and Visitor their area as the authority • Press release consider appropriate; • • publish on their website- All participants at Issues and Options stage notified by letter or ‰ the pre-submission proposals e-mail documents, ‰ the proposals matters; • Two deposit locations (Lancaster ‰ a statement of the fact that the and Morecambe) pre-submission proposals • Copies to be placed for documents are available for information in Public, College and inspection and the places and University Libraries, times at which they can be inspected; • Public Exhibitions to be held for • send to the DPD bodies- major documents where necessary or cost effective; ‰ the authority's proposals for a DPD, • Notification by leaflet for major ‰ such supporting documents as documents where necessary or are relevant to the body to cost effective ; which the documents are being sent, ‰ notice of the proposals Methods of Consultation matters, ‰ the statement of the fact that 3.2 A Preferred Options Document was the pre-submission proposals prepared setting out the preferred documents are available etc. options for a Core Strategy and • carried out consultation on this give notice by local advertisement document for a six week period from of- 27th January 2006 to 17th March 2006 ‰ the proposals matters, between 8:45 am and 5:15 pm. A firm ‰ the fact that the pre- of graphic designers were employed submission proposals to produce a standard identity. Three different levels of publication were

produced . These were 1.2 2 2 Statutory Instrument 2004 no 2204 Town and Country Planning (Local Development)(England) Regulations 2004 Regulation 25

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Tier 1 – Consultation Leaflet; Town Hall. Copies were also made available in all public libraries A simple A5 leaflet to introduce the wihin the District (Lancaster, Core Strategy, also provided details Morecambe, Heysham, Caton on how to obtain further information, (now closed), Halton, Hest Bank plus the venues, dates and times for (now closed), Bolton-le-Sands, the staffed public exhibitions of the Carnforth, Warton (now closed) Core Strategy Preferred Option. and Silverdale. Copies were also made available for the District’s mobile library. Copies were also Tier 2 - ‘Let’s plan the future made available in Kirkby Lonsdale together’ Core Strategy Library (which, although located in Consultation (Booklet and Cumbria, is the nearest library for separate response form); people in the upper Lune Valley. Copies were also made available A more involved A4 leaflet which in the libraries in Lancaster aimed to aid understanding and make University, Lancaster and accessible the key principles of the Morecambe College and the Core Strategy Preferred Options University College of St Martins; document’ to help those with little or no planning knowledge to understand • An advertisement which was and who wish to comment. carried in the Morecambe Visitor on February 1st and 7th 2006 and in the Lancaster Guardian on the Tier 3- The Core Strategy 27th January and 3rd February Preferred Option Document; 2006 . • 3.3 The Core Strategy document itsself, Copies of the document, by e-mail supported by the Sustainability where possible, along with the Appraisal Report and a document DPD matters, the Sustainability explaining the other options Appraisal Report and details of considered and the reasons for their where the documents were rejection. All documents were made available for inspection, to the available free of charge. bodies listed in Appendix 1. Where no e-mail address was available, 3.4 The following measures were bodies were notified by letter and employed to publicise the Preferred offered a copy of the document if Options document; they so wished; • A5 leaflets (Tier 1) and posters • Manned Exhibitions in St Nicholas distributed throughout the District Arcade, Lancaster (13-16th prior to the exhibitions February), (18th February), Arndale Centre, • The document, DPD matters and Morecambe (20-22nd February), Sustainability Report were Douglas Park, Heysham (23rd- available on our website 24th February), Carnforth (27th (www.lancaster.gov.uk), with a February-2nd March), Bolton-le- statement explaining where and Sands (3rd March), Hornby (7th when paper copies of the March), Galgate (8th March), document were available for Caton (9th March) and Silverdale inspection; (10th March). • The Preferred Options Document, DPD matters, Sustainability Report 3.5 A copy of the DPD matters is and Options Considered document included in Appendix 4. were made available in Palatine Hall, Lancaster and Morecambe

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3.8 Major issues arising from the Response consultation were the following; 3.6 101 organisations submitted • Concern that the amount of representations on the Core Strategy development outside larger Preferred Options Document. Of villages in rural areas was these, sixty submitted their response insufficient; by e-mail. A total of 640 individual • Concern from a number of representations were received. A full households in the Torrisholme schedule of representations and the area about the impacts of the Council’s response is set out in Heysham-M6 Link; Appendix 5. • Concerns that at the present time, 3.7 The North West Regional Assembly there is no mechanism or confirmed that the preferred option programme for implementing a strategy is in general conformity with River Crossing at Luneside; the adopted Regional Spatial • Major concern from Government Strategy. 80% of respondents Office for the North West that the supported the urban concentration preferred options consultation had strategy whilst 75% thought that the not made it clear that it was still Strategy identified the right open to objectors to support one of regeneration areas. The largest the rejected options, that number of negative responses were insufficient detail had been put on whether the strategy does enough forward on the alternative options to protect the environment (49% and that it was not made clear that believed it did not) and whether the objectors could put forward strategy did enough to meet rural options of their own. needs (45% believed it did not). 3.9 In response to the concerns of Government Office, an addendum document to the Core Strategy was published setting out the options in greater detail and evaluating them in terms of their effectiveness in implementing the Strategy vision (see below).

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4. Preferred Options – Addendum Consultation

Background Measures Undertaken

4.1 In response to the concerns of 4.3 A four week consultation was Government Office, further undertaken between 28th April and consultation was carried out on an 26th May 2006. All bodies identified in addendum document to the Core Appendix 1 were consulted by letter Strategy. This document explained or e-mail. The document was also the options which the Council publicised on the Council’s website considered and why ‘Urban and a notice placed in the Lancaster Concentration’ was considered to be Guardian. The following questions the most sound option. were asked; • Whether Urban concentration is Regulatory and Statutory the best strategy for managing Requirements development in Lancaster District and realising the vision for the 4.2 This exercise was a non-statutory Core Strategy? supplementary consultation outside • Whether the Strategy would be the scope of Development Plan more sound, and its vision more regulations and the Statement of effectively delivered, if one of the Community Involvement. other options were adopted and if so why? • Whether there are additional options not put forward by the Council which would result in a more sound Strategy and realise the Vision more effectively?

Response

4.4 As a result of this additional consultation, 65 individual responses were recieved from 20 respondents. Of these only one was in support of an option other than urban concentration (dispersal). Responses to the addendum consultation are listed in full in Appendix 6.

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APPENDIX 1 - PROPOSALS BODIES .

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Government Departments and Government Agencies Countryside Agency Forestry Commission North MoD Defence Estates Crown Estates Commissioners West England North West Arts Board Department of Constitutional Government Office for the North North West Development Affairs West Agency Department of Work and Health and Safety Executive - North West Regional Assembly Pensions Chemical Industries Directorate Office of Government English Heritage Highways Agency - NS North Commerce English Nature West, Sport England Environment Agency HM Land Registry Farming and Rural Home Office Conservation Agency (FRCA) Learning and Skills Council

Local Authorities and Local Public Bodies Arnside/Silverdale Area of Lancashire County Council - Morecambe Bay NHS Primary Outstanding Natural Beauty Community Strategy Officer Care Trust - Lancaster Health Management Committee Lancashire County Council - Morecambe Bay Primary Care Business Link Lancashire Property Group Trust - Admin and Support Craven District Council Lancashire County Council - Morecambe Bay Primary Care Cumbria and Lancashire Social Services Trust - Director of Public Health Strategic Health Authority Lancashire County Council - Morecambe Bay Primary Care Cumbria County Council Youth and Community Service Trust - Public Health Hyndburn Borough Council Lancashire Fire and Rescue North Yorkshire County Council Lancashire and Blackpool Service Ribble Valley Borough Council Tourist Board Lancashire RIGS South Lakeland District Council Lancashire Archaeological Unit Lancaster and Morecambe South Ribble Borough Council College University College of St Martin Lancashire County Council Lancaster University Wyre Borough Council Lancashire County Council - Merseyside Policy Unit Yorkshire Dales National Park Adult Services Morecambe Bay Health Authority Lancashire County Council - Authority (HQ) Yorkshire Forward Childcare Morecambe Bay Hospitals NHS Trust

Local Commercial and Development Interests Arndale Shopping Centre Lune Industrial Estate Limited Joseph Storey & Co. Ltd Morecambe (Taken over by Hurstwood SWS UK Bailrigg Property Company Group q.v.) Thomas Armstrong Limited Lune Valley Housing Construction R Banks Lyon Association Mr T Thornborrow Messrs Boddy, Sharp, Luneside Engineering Group Mr C Tudor Whelan Graveson and Barker Limited R Townley and Sons C Bowker Ltd Maple Grove Developments Ltd D J Townley and Sons Dalesmoor Homes Marketgate Centre Manager Ultramark Adhesive Products Mr B Dearlove Marks & Spencer PLC Ltd Alan Dick Engineering Ltd Merchant Ferries Ltd R Williams Direct Logic Ltd Merewood Homes Ltd (Now Mr G Ellis Persimmon Homes) Fats & Proteins (UK) Ltd Mitchells of Lancaster (Brewers) Fish Estate Ltd (Now Pub Management Gilesgate Ltd Company) Ltd (now Peel Morecambe Bay Radio Estates) North British Housing Home Housing Association Association Imperial Home Decor Group Northern HI-TEC Ltd Intec (UK) ltd Oglethorpe, Sturton & Gillibrand Inventures Persimmon Homes Norman Jacksons Contractors (Lancashire) Ltd Ltd Pye Motors Limited Mr A Johnson Reid Hamilton & Co Kidd's Transport Ltd Russell Armer Ltd Kitchin Builders S J Bargh Ltd Lancaster & Morecambe Safeguard Storage Agricultural Society and Vale of Sea Containers Property Lune Rugby Club Services Lancaster Port Commission Solrec Ltd Lancaster Synthesis Ltd (Now Sowerby Family Alfa Aesar) SPSS (UK) Ltd William Lawrence St Nicholas Arcades Shopping Centre

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Local Interest Groups Age Concern, Lancaster Lancashire Wildlife Trust Lancaster, Morecambe and Butterfly Conservation Lancaster and Cumbria Cyclists District Rail User Group Campaign for Real Ale Touring Club Lancaster, Morecambe and Carer's Forum Lancaster and District Council District Sports Council Carnforth Chamber of Trade for Voluntary Services Lonsdale District Scout Council Castle Area Residents Lancaster and District YMCA Mental Health User Forum Association Lancaster and Morecambe Middlewood Trust Community Futures Lions Club Morecambe and District Diocese of Blackburn Lancaster and Westmorland Chamber of Trade and Duchy of Lancaster Society of Architects (LAWSA) Commerce Duke's Theatre Lancaster Archaeological and Morecambe Bay Hotel & Dynamo Historical Society Business Association Freehold Community Trust Morecambe Bay Partnership Association Lancaster Civic Society National Trust Lancashire and Friends of Carnforth Station Lancaster CVS - Physical South Cumbria Coast Friends of the Earth (North Disability or Sensory North Lancashire and Cumbia Lancashire) Impairment Inland Waterways Association Friends of the Midland Hotel Lancaster District Chamber of Parochial Church Council, St Friends of the Victoria Pavilions Commerce, Trade and Industry Pauls Scotforth Guide Association - Lancaster Lancaster Farmers Auction Mart Poulton Residents Association and Division Lancaster Footlights Club Real Planning for Lancaster Haverbreaks Residents Lancaster Girls Grammar South Lancaster Residents Association School Association Heysham to M6 Link Road Lancaster Green Spaces Stodday Residents Committee Lancaster Moor Sports and Storey Gallery Joint Groups Against the Social Club The Adult College Western By-Pass Lancaster Roman Catholic The Duke's Theatre Lancashire Badger Group Diocesan Trustees The Grand Theatre Lancashire CPRE Lancaster Royal Grammar The Ramblers Lancashire Playing Fields School Transport 2000 North Lancs Association Warton Village Society

Members of Lancaster City Council Cllr J Airey Cllr Ms G Dowding Cllr P Lee Cllr Mrs E Archer Cllr Mrs S Fishwick Cllr J R Mace Cllr E Ashworth Cllr J Fretwell Cllr Mrs J Pritchard Cllr I Barker Cllr P M Gardener Cllr Mrs P Quinton Cllr J Barry Cllr Ms R Gerrard Cllr J Ravetz (replaced by Cllr J Cllr G Baxter Cllr J Gilbert Blakeley) Cllr Mrs E Blamire Cllr C M Grattan Cllr R Redfern Cllr Mrs S Bray Cllr M Greenall Cllr P Robertson Cllr K Brown Cllr Mrs J Hanson Cllr Mrs S Rogerson Cllr A C Bryning Cllr J Harrison Cllr R Sands Cllr K Budden Cllr E Heath Cllr Mrs E Scott Cllr Mrs S Burns Cllr Mrs H Helme Cllr R J Sherlock Cllr Ms M Chadwick Cllr Mrs J Horner (Replaced by Cllr Ms C Stamp Cllr Ms A Chapman Councillor R Smith) Cllr A P T Stone Cllr Mrs S Charles Cllr A G Johnson Cllr Mrs J Taylor Cllr Mrs T Clifford Cllr A P Jones Cllr J M Thomas Cllr I Clift Cllr Mrs J Jones Cllr A M B Wade Cllr C Coates Cllr D Kerr Cllr D Whitaker Cllr R J Day Cllr Mrs J Kirkman Cllr J Whitelegg Cllr Mrs J Dent Cllr G Knight Cllr G Wilson Cllr Mrs S Denwood Cllr S Langhorn Cllr P Woodruff

Members of Lancashire County Council (Lancaster Wards only) (Changes following 2005 election shown in parenthesis) Cllr Mrs S Fishwick Cllr J Sear (replaced by Cllr C Cllr D Wood (replaced by Cllr Cllr Mrs R Henig (Replaced by Coates) Mrs S Charles) Cllr Ms L Scott) Cllr D Stanley (Replaced by Cllr Cllr Mrs J E Yates Cllr A P Jones Ms J Hanson) (New Ward created May 2005 Cllr Ms N D Penney Cllr A H Thornton Cllr P Elliot)

Members of Parliament Geraldine Smith MP Hilton Dawson MP (replaced in May 2005 by Ben Wallace MP)

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National Commercial and Development Interests Aldi Stores Ltd Countryside Properties McDonalds Alfred McAlpine Developments (Northern) CPRE North West Morbaine Ltd Crosby Homes (North West) Ltd Natwest Group Property AMC David Wilson Homes North Northcountry Homes Applethwaite Ltd West Northern Counties Housing Banks Development Division E H Booth & Co Ltd Association Barratt Manchester Edinburgh House Estates Royal and Sun Alliance Boots the Chemists Fairclough Homes Sainsbury's Homebase Bovis Homes Limited Gleeson Homes Shell UK Ltd Briery Homes Hanson Brick Ltd Tesco Stores Ltd Capital and Regional PLC Hurstwood Group The Windmill Housing Caring Homes Ltd Hutt Pharmacy Projects Association Professor Carruthers Johnson Fellows Trent City Securities Ltd Charles Topham and Sons Lidl UK GmbH - Property Urban Splash Chelford Homes Department Wimpey Homes Holdings Ltd Church Commissioners Lloyds TSB Network Property Wm Morrisons Supermarkets City Link Holman Management PLC - Property and Consolidated Property Group McCarthy and Stone Wolverhampton and Dudley Contour Housing Group Developments Ltd Breweries

National Interest Groups ACERT Joint Committee for National Royal Institute of Chartered Bridgewater Meeting Room Amenity Societies Surveyors Trust Land Access and Recreation Royal Society for the Protection British Marine Federation Association of Birds Civic Trust National Farmers Union Save Britain's Heritage Council for British Archaeology National Gypsy Council Theatres Trust Country Land and Business National Playing Fields Traveller Law Research Unit Association Association (TLRU) Gypsy Council/Romani Kris National Trust Twentieth Century Society House Builders Federation North West Inland Waterways Victorian Society Housing Corporation Association Woodland Trust Prince's Foundation

Planning Consultants Steven Abbott Associates Derek Hicks & Thew MCP Planning and Adams Holmes Development Planning Development (Formerly Michael Graham Anthony Associates Partnership Courcier Associates) P H Armistead DPDS Mellor Architects Ashton Associates Drivers Jonas John Moore & Partners Aspden Gallagher Mortimer Dunlop Heywood Lorenz Peacock and Smith Royle Entwistle Design Services Peill and Company ATC Construction Design Michael Fisher Associates Planning and Development Chris Barber Ted Fletcher Architects Network Barden Planning Consultants FPD Savills Planning Bureau James Barr Mr R Gee Ian J Potts Associates Barton Willmore Planning Gill Dockray Architects Rae Watson Development Partnership – Northern T Gill Surveyors Graham Bolton Partnership Gough Planning Services John Rose Associates Planning G V A Grimley RPS Planning Broadway Malyan Planning Hagan Roberts Ltd Christopher Rushton Chartered Colin Buchanan & Partners N Hakeman Architects Building Plan Services Michael Harrison Gordon Smith Architect Paul Butler Associates Harrison & Pitt Smiths Gore Bywater & Tweedale G L Hearn and Partners Richard Stirrup Associates Alan Camm Hepher Dixon D Tarbun Ian Campbell How Planning Thomas Associates Architects Capita Symonds Howard Associates Martin Tonks Carter Jonas Irvine Taylor Town Planning Consultancy CgMs Planning Archaeology Terry Jackson Transportation Planning and Environmental Consultants Jones Day Partnership Colliers CRE Jones Lang Lasalle URBED Corstorphine and Wright, Hills (Manchester) Weatherall, Green and Smith Erwin Ltd JTS Partnership H R Wheatman Cronshaw & Harrison Malcolm Judd & Partners White Young Green David Couttie Associates Kenyon and Company Woolerton Dodwell Associates Cunnane Town Planning Alan Kinder Associates Erica Wright Paul Dance Consultancy Gary Kirby Architects Wright Design Partnership Development Services Mason Gillibrand Architects WS Atkins Planning DH Design Matthews and Goodman Consultants De Pol Associates McDyre & Co

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Parish and Local Councils within the District

Arkholme with Cawood Parish Heysham Neighbourhood Quernmore Parish Council Council Council Roeburndale Parish Meeting Bolton-le-Sands Parish Council Hornby-with-Farleton Parish Scotforth Parish Council Borwick Parish Meeting Council Silverdale Parish Council Burrow-with-Burrow Parish Hutton Roof Parish Council Slyne-with-Hest Parish Council Meeting Ireby and Leck Parish Council Tatham Parish Council Cantsfield Parish Meeting Melling-with-Wrayton Parish Thurnham Parish Council Carnforth Town Council Council Tunstall Parish Council Caton-with-Littledale Parish Middleton Parish Council Warton Parish Council Council Morecambe Neighbourhood Wennington Parish Council Claughton Parish Council Council Whittington Parish Council Cockerham Parish Council Nether Kellet Parish Council Wray with Botton Parish Council Ellel Parish Council Parish Yealand Conyers Parish Gressingham Parish Council Council Council Halton-with-Aughton Parish Over Kellet Parish Council Yealand Redmayne Parish Council Parish Council Council Heaton-with-Oxcliffe Parish Overton Parish Council Council Priest Hutton Parish Meeting

Parish Councils in neighbouring Authorities Craven South Lakeland Wyre Bentham Town Council Arnside Parish Council Parish Council Burton-in-Lonsdale Parish Beetham Parish Council Forton Parish Council Council Burton in Kendal Parish Council Nether Wyresdale Parish Lawkland Parish Meeting Casterton Parish Council Council Thornton in Lonsdale Parish Dent Parish Council Over Wyresdale Parish Council Council Hutton Roof Parish Council Parish Council Ribble Valley Kirkby Lonsdale Town Council Parish Council] Slaidburn and Easington Parish Council Note Neighbouring Parish Councils were omitted from Issues and Options Consultation. They were however consulted at preferred option stage and none raised any issues of substance.

Utilities/Statutory Undertakers British Energy - Heysham National Air Traffic Services - Stagecoach Cumberland British Telecom plc Navigation Services Strategic Rail Authority British Waterways National Grid Company PLC, Transco British Waterways - Lancaster Planning & Environment Group United Utilities - External Waterways Office Network Rail Planning Liaison First North Western NHS Executive North West Virgin Trains Mobile Operators Association Port of Heysham

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APPENDIX 2 – ISSUES AND OPTIONS CONSULTATION – FORMAL RESPONSES

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SUMMARY OF REPRESENTATIONS RECEIVED ON ISSUES AND OPTIONS DOCUMENT;

General Representations and Comments on Issues and Options Document

North West Regional The timetable for the development of preferred option should enable the Council to account for the Assembly emerging policy framework that is being developed in the revision of RSS. Lancaster Civic Welcome the aim at involving the public more actively. Society Lancaster Civic LDF documents are not at present readily available to the public. Hope that easily accessible in public Society places. Prominent articles in the local press might help and staffed displays in public areas. Travelling exhibitions and talks might also be useful and perhaps a prominent display in libraries. Lancaster Civic Documents are structured and written in a language that the General public is likely to find Society unapproachable. All documents should be critically reviewed with the aim of remedying this. The National Trust Para 2.9 none of the strategies includes either rural or a landscape character dimension. These are necessary components of the core strategy and should be key considerations in influencing it. The National Trust Diagram Page 10 excludes any ref. To who is responsible for the protection and enhancement of the natural and built environment.

The National Trust Para 2.11 absence of any environmental policy for built heritage, nature conservation or landscape character is a serious omission The National Trust Para 2.21 climate change issues should be specifically referred to in the Council’s Core Strategy. The National Trust Para 2.21 mention should be made of the AONBs

The National Trust Para 2.24 The Northern Way should be given only limited weight at this time The National Trust Para 2.28 table 1 needs to be up dated. PPS 1 places a particular emphasis on an integrated approach. PPS 9 is only draft. Unclear why PPS 10 has been omitted. PPS 23 issued Nov 04.

The National Trust Para 3.1 eight bullet point supplemented with ‘and their settings’

English Nature Para 3.1 makes no mention of the need to safeguard of non-statutory Biological Heritage sites and also Geological Heritage sites serious omission. Woodland Trust Concerned at the lack of consideration of the environment and green space within the core strategy. Recommend including a section on planning for the environment and green spaces.

E H Booth and Co Ltd. Para 1.9 word ‘recommending’ should be replaced with ‘requiring’. E H Booth and Co Ltd. Para 3.1 the words ‘strengthens existing centres’ are appropriate. They seem a little narrow in the context of what PPG 6 and PPG13 are seeking to achieve.

Bailrigg Property The core strategy should acknowledge the importance of the University “Lancaster University is already Company a major employer and is increasingly a focus for the further creation of knowledge based employment opportunities. The Bailrigg Science/Business Park will capitalise on these existing strengths and provide considerable potential for future sustainable growth. The area already has excellent links to public transport, the M6 Motorway and the A6 corridor, together with excellent local opportunities to walk and cycle’

Bailrigg Property The LDF through its separate development documents, should create an ‘Academic, Working and Company Living Quarter’ focused upon the University’s existing site, the proposed science park and adjoining land, beyond the existing and designated northern boundaries at Bailrigg.

The Theatres Trust Pleased that other activities that influence the local environment and quality of life, especially the Cultural strategy and tourism strategy. However, these strategies do not appear to be sustained or assessed within the issues and options Paper.

Yorkshire Forward Commends the clear and ‘user friendly’ approach of these documents; particulary the use of maps to illustrate options and their potential outcomes.

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Question 1 - What should the District’s strategy be for the location of new development?

North West Regional The preferred option will need to take account of the emerging policy framework in the full review Assembly of the RSS. The National Trust Approach must be consistent to the approach within the Spatial Development Framework in RSS. Commercial Estates Approach should not be any one individual option in isolation. Key is a strategy that provides flexibility for developers to seek to promote individual sites on their own merits in accordance to planning policy at all levels Fats and Proteins Option 1 Urban conc. as it fulfils the key aims of the Regional Spatial Strategy. However there should be an exception for their client’s (an animal rendering plant) needs. Wm. Morrison Plc Options 1 and 4 most likely to encourage sustainable patterns of development. Favour Option 4 regeneration but recognising that Lancaster should still be allowed to fulfil role as sub regional centre. English Nature Natural environment does not feature prominently within the introductory sections. Suggest insert para 2.6 ‘ Lancaster District is of considerable environmental importance since it supports some of the most diverse and richest landscapes and wildlife habitats in the country as a whole. Its natural resources include Morecambe Bay, one of the largest estuarine complexes in the country of international importance for wildfowl and wading birds; the Arnside/ Silverdale AONB, includes numerous nationally and internationally important sites of nature conservation interest supporting rare limestone pavements, areas of open water and reedbed habitat eg Gait Barrows NNR and Leighton Moss RSPB Reserve; AONB, includes herb rich pastures and hay meadows, upland oak/ash woodlands and the Bowland fells SPA, a large area of moorland habitat of particular importance for birds of prey eg hen harrier. Ask any future documents concerning LDF refer specifically to the importance of such natural resources within the district in a more prominent way. English Nature Preferred Option 1 ( noting the omissions of SSSIs, BHSs and GHSs in the box on advantages.) This should be the main emphasis of the LDF in order to ensure sustainable development. English Nature Not opposed to limited expansion of urban areas i.e. option 3 or option 2 English Nature Whatever option is finally chosen every opportunity is taken to ensure that biodiversity is built into new development English Nature Suggest produce and adopt relevant SPG for areas taking into account of advice and design principles in Biodiversity by Design: A guide for sustainable communities. United Utilities Support Option 1 and 4 as it utilises existing utility infrastructure. Gill Dockray Option 6 for a strategy is more appropriate than the others bearing in mind the disadvantages have been overstated Fairclough Homes Ltd. Option 1 Lancashire County Council In accordance with Policy 1 (C) new development should be located in such a place that it can contribute to achieve a balanced land use within area and helps to achieve sustainable patterns of development. Development should be away from areas of landscape and wildlife importance, principally the open coastal areas and from areas at potential risk of flooding. Steven Abbot Associates- Suggest making it clear, perhaps by introducing further options, that the best strategy is the one which draws strengths from several of them. Steven Abbot Associates- Is it a good idea referring to the ‘built up areas ‘? Wonder if it is too restrictive given the policy constraints available otherwise. Steven Abbot Associates- ‘sites will be required in the longer term’ illustrates the need to build in flexibility.- MCP Planning and Option 1. Development on behalf Countryside Properties Ltd. Matthews & Goodmans on A final choice of option would sensibly focus upon a combination of regeneration within the behalf of the Bailrigg Morecambe and Heysham are; further concentration on the existing urban areas, and an element Property Company of urban extension(depending on urban capacity). The final strategy must also be coupled with an application of market realism, (in preference to the phase “market driven”. Ramblers Association Option 4 with 1

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Question 2 - Should development be permitted in villages which do not provide basic services?

The National Trust Only on a very limited basis. Gill Dockray Yes as demand can create the basic services Fairclough Homes Development in villages without basic services should be limited to small scale backland and infill development on small windfall sites Lancashire County Council Development should be focussed on villages, which provide access to basic services to reduce the need to travel. Ramblers Association No

Question 3. Should affordable or local needs housing be permitted in villages without access to basic services?

The National Trust Only when it is pressing and there is a case that can be made to justify it. Expect such development to contribute towards addressing the lack of access to basic services.

Gill Dockray Yes Fairclough Homes Affordable housing should be steered towards towns and villages where access is available to basic services and public transport facilities Ramblers Association No

Question 4. What level of development is acceptable in larger villages?

The National Trust Related to the extent of local needs. Fairclough Homes Limited to the re use of brownfield windfall sites, in addition to backland and infill development. Lancashire County Council Consistent with the scale and function of the area Ramblers Association Little Gill Dockray Infill development

Question 5. What should the District’s approach be to development outside villages?

The National Trust Strongly restrictive approach is imperative. Consistent with existing national and regional planning policies. Gill Dockray Judge on the merits of the case Lancashire County Council Consistent with the scale and function of the area Ramblers Association Tough and restrictive Fairclough Homes Follow approach in PPS7 ‘ sustainable development in Rural areas which allows for economic and residential development in rural areas where appropriate.

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Question 6. What will be the implications of the completion of a Heysham – M6 Link Road for land use in the District?

The National Trust If objectives are to be met successfully then it is reasonable to expect existing allocations for employment land to be safeguarded, but if the congestion in Lancaster are to be addressed that it would be appropriate to resist requests to release new areas of land for commercial, or housing development. Gill Dockray Whole point of the link is presumably to stimulate regeneration Morecambe and Heysham so development should be concentrated in this zone Fairclough Homes Failure to develop such sites would constitute the profligate use of brownfield land and may harm regeneration efforts.

Question 7. Should development in the urban parts of the District be focused on locations with access to a choice of means of transport?

The National Trust yes

Gill Dockray Not necessary. Let market decide. Ramblers Association Not a choice Bailrigg Property Company Is far to simplistic in that there can be no case for any approach other than to focus development in locations where access is available by a choice of means of transport.

Question 8. Will there be a need to identify large sites and if so when and where?

Commercial Estates Given the accepted merits of sustainable development at Whinney Carr Site, should be identified in due course on the proposals map as site for future development in the longer term.. Wm. Morrison Plc In order to assist regeneration of M/c development should be encouraged in appropriate locations. Mixed used land such as Frontierland. Steven Abbot Associates- Advanced identification of sites is prudent – how can you plan properly without doing so.

Question 9. Does the current stock of housing meet need and are there specific needs for specific types of housing which are not being met?

Gill Dockray Small scale housing to stitch communities together Ramblers Association Yes Bailrigg Property Company Re: University. The student housing need having been addressed the new ‘University Quarter’ should look to provide residential opportunities for employees (University and SciencePark) in the immediate area of the University and future knowledge based employers.

Question 10. Is there sufficient capacity in urban areas to meet development needs?

Gill Dockray Probably but environment has to be made more attractive Ramblers Association Yes

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Question 11. Are there special needs which are not being met?

The British Wind Energy Emphasises the contribution that small scale renewable energy developments can make, urges Association the council to consider policy for the mandatory requirement of all new buildings and renovations to provide electricity for at least 10% of the buildings needs from renewable energy sources. Gill Dockray First time buyers Ramblers Association No

Question 12. Should the following considerations influence what type of site is allocated? 1. Proximity to services 2. Proximity to employment 3. Access to public transport 4. Access to cycle network and pedestrian 5. Whether previously used or green field 6.Whether development has regeneration benefits 7. Whether development is energy efficient 8. Whether the area is at risk of flooding.

The National Trust All considerations listed should. In addition to impacts on landscape character Tesco Proximity to services is important Gill Dockray 1,2,3,4 not critical 5, brownfield 6,7,8 yes Lancashire County Council Any site should be allocated based on the long term feasibility of the site considering the physical, socio – economic and environmental factors. Ramblers Association Yes, all United Utilities List should include ‘ access to appropriate utility service capacity’.

Question 13. What should the Council’s approach be to local needs housing in villages?

The National Trust See response to 2 & 3 Gill Dockray Positively encourage regardless of quotas Ramblers Association Improve in larger villages without facilities

Question 14. What should the Council’s approach be to low-impact housing?

The National Trust Supportive. Should not override the General location principles relating to new housing. In practice all new housing should meet at least some ideals of low impact housing. Gill Dockray If low impact means the odd house slotted here and there regardless of quotas then support should be given.

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Question 15. How will residential development be phased to ensure that previously developed land in sustainable locations is developed first and over-provision is avoided?

The National Trust By incorporating a suitable phasing policy into the Core Strategy and, for major sites, producing development/design briefs to an agreed timescale that reflects appropriate phasing for bringing sites forward. Gill Dockray Positive encouragement and cooperation

Question 16. Is the existing shopping offer of the District good enough?

Commercial Estates There is a need for additional food retailing in the South of Lancaster. The policies should identify sites to meet this existing need and also to reflect growth in resident and student population. Gill Dockray The town centre shops aren’t attractive enough to counter the traffic and parking problems. Easing of the latter may bring success.

Question 17. What role should Lancaster and Morecambe centres be looking to perform relative to other centres outside the District?

Tesco Recommended that Lancaster continues as main centre, supported by Morecambe. For Lancaster to remain the premier centre, the Council should emphasise the possibilities of developing sites on the edge of the city centre, or outside the centre, because the city centres historic makeup makes it very difficult or unviable for larger retailers to locate there. Gill Dockray Lancaster somehow needs to rival Preston and Carlisle Lancashire County Council The roles of the centres relative to other centres should be based on the hierarchical positions of the centres.

Question 18. What should be the relative roles of Lancaster and Morecambe centres?

Tesco Lancaster and Morecambe are allocated as tier one and two towns. Therefore both of these centres should provide a comprehensive selection of convenience and comparison goods. Wm. Morrison Plc Should seek to strengthen the sub regional role of Lancaster City Centre by encouraging high quality, high order comparison-shopping. Lancaster will remain the dominant centre in the district. The Districts other areas should be allowed to grow to meet the shopping needs of their catchment areas. Consider Morecambe is dominated by Lancaster and should encourage developing its retail offer, appropriate size scale and type not to undermine Lancaster City Centre. Gill Dockray Lancaster needs to be much better than Kendal and Morecambe will have to ultimately target the Kirby Lonsdale market.

Question 19. What should the Council’s approach be to development around the edges of Lancaster and Morecambe centres?

DPP on behalf Tesco Supported fully Gill Dockray Keep it within

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Question 20. Are there additional centres which should be identified as local centres?

No response.

Question 21. Are there identified centres which no longer function as local centres?

No responses.

Question 22. Is there a need for additional food , non-food or specialist shopping in District?

Gill Dockray No

Question 23. If there is a need, how should this be accommodated?

No responses.

Question 24. What should be the approach to uses such as food and drink, amusements and financial and professional services in town centres?

Gill Dockray Encourage and maintain mix

Question 25. What should the Council’s approach be to the loss of rural shops and pubs and is there a role for village plans in developing solutions?

Gill Dockray Yes Lancashire County Council The loss of economic activities in the rural areas is not acceptable. Therefore provision of different services could be made on an integrated basis to enhance the efficiency of each of the service.

Question 26. What is the demand for new business and employment floorspace and is there a demonstrable shortage of serviced employment land?

Gill Dockray Lancaster is severely blighted by traffic and LCC will never know what the demand could have been.

Question 27. How can the local economic benefits of Lancaster University be maximised?

Gill Dockray Permit further research expansion on campus

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Question 28. Is there a significant shortage of office space?

No responses.

Question 29. Where are the most appropriate locations for new office development?

The National Trust Follow the sequential approach – directed in main centre where previously developed land, local services and a choice of modes of travel are, or readily made available. Gill Dockray At the end of the Heysham link

Question 30 What should the approach be to proposals for retail, leisure and other non- employment development in established and successful employment areas such as Caton Road?

Gill Dockray Discourage

Question 31. What should be the future of the Luneside West area?

Countryside Properties Like many other existing employment areas and brownfield sites are no longer appropriate for employment use because of their location or proximity to sensitive uses. It is felt that this area would benefit from some local restructuring of land use distribution in order to respond to significant regeneration initiatives. Re allocation of land for Mixed Use schemes

Question 32. What should be the future of green-field employment allocations which have remained undeveloped for many years?

Gill Dockray Remain Greenfield Lancashire County Council A business option survey revealed that there were no overriding or strong preferences for Greenfield sites for future leisure and industrial development. The future of any Greenfield or other site should be determined based on a long term feasibility study of the site for the intended purpose. Bailrigg Property Company Suggest that Greenfield employment allocations which have remained undeveloped, where no progress is being made, should be removed from the plan

Question 33. What should be the future of large under-used sites in the South Heysham area?

Gill Dockray Await the link

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Question 34. What should the Council’s approach be to employment development in locations with poor public transport?

Gill Dockray Its up to applicant Lancashire County Council In case of areas with poor public transport the development will contribute to achieving good quality public transport.

Question 35. How can alternatives to car travel be provided to the White Lund Industrial Estate?

Gill Dockray Why resist? If there is an prolonged oil crises other means will be found as technologies exist. The National Trust Key issue is to ensure high quality is achieved and that appropriate scale, materials and local distinctiveness. Peacock and Smith on Supports high quality design, design solutions must be appropriate to the location and reflect the behalf Wm. Morrison Plc commercial realities of development, particularly where investment returns are low.

Question 36. Is there scope to introduce high quality modern architecture in Lancaster?

Ramblers Association ‘High quality’ is subjective

Question 37. What safeguards can be put in place to ensure that new development is of genuine quality?

Lancaster Civic Society Good quality architects; Competitions (though recognising these are expensive for participants); Design Panels. The National Trust Variety of mechanisms, use of design competitions for major sites, design briefs, independent design briefs and the use of independent architectural/ urban design experts to review proposals

Question 38. Are there important parts of the District where securing investment and employment creation is a more important consideration than achieving the highest quality design?

Lancaster Civic Society Possibly, on pragmatic grounds, on industrial estates, for example, but not in the city The National Trust No

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APPENDIX 3 – ISSUES AND OPTIONS CONSULTATION – REPORTS OF SEMINARS AND EVENTS AND SUBSEQUENT REPRESENTATIONS MADE

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SEMINAR – LOCAL STRATEGIC PARTNERSHIP

The LSP, the Community Strategy and the New Planning System Monday 25 July 2005 between 1.00pm and 4.30pm, in Block D, Second Floor, Room 282, The Roeburn Room, Lancaster & Morecambe College

Attendance

Councillor Gina Dowding Chair - Lancaster Local Strategic Partnership; Ann Morris Chamber Services Manager - Lancaster District Chamber of Commerce, Trade and Industry; Brian Jones The Ramblers; Jonathan Seer Chair – Sustainable Transport Forum; Mark Fletcher Lancashire County Council – Social Services; Michelle Emery Lancaster Community Safety Partnership; Phil Coope Lancashire Constabulary; Dr Joy Grayson Lancaster City Council – Agenda 21 Co-ordinator; Allan Kenny Lancaster Vision Board; Barbara Parkinson Morecambe Bay Hospital Trusts; Jon Sharples North West Development Agency; David Wood Lancaster and Morecambe College; Councillor Ron Sands Lancaster City Council; Stuart Lock Groundwork Lancashire West; Mike Fisher Lancaster District Chamber of Commerce, Trade and Industry; Nick Pilkington Lancaster District Chamber of Commerce, Trade and Industry; Jim Lancaster Vision Board; Jerry Sutton Inward House Projects; Austin Staunton Citizens Advice Bureau; Ron Eckersley Lancaster City Council (Engineers) Finlay Hodge Community Futures; Pauline Grabek Surestart Ralph Henderson Silverdale Parish Council; Joyce Dalton The Adult College; Gill Fenna Lancaster Sustainability Partnership; Councillor Peter Robinson Lancaster City Council; Nick Howard Lancaster City Council; (Public Protection) Mike Harrison Chairman Lancaster District Chamber of Commerce, Trade and Industry; John Pratt Lancashire Association of Parish and Town Councils; Bob Roe Lancashire Association of Parish and Town Councils; John Heath Signposts; Phil Corris Lancashire Constabulary; David Lawson Lancaster City Council – Planning; Maurice Brophy Lancaster City Council – Planning; Dan Hudson Lancaster City Council – Planning; Julian Inman Lancaster City Council – Planning; Sarah Hind Lancaster City Council – Planning; Elaine Clarke Lancaster City Council – Planning; Rob Bracewell Lancaster City Council – Planning; Andrew Dobson Lancaster City Council – Planning; Wendy Thompson Lancashire County Council

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Programme Welcome and Introduction – Who we are and What we do Thanks for coming; The purpose of today is for us to listen to you.– We want to hear what you think; We will be asking questions and facilitating discussion but today is about your views; We are the Forward Planning Team – run through key personnel; Community Strategy – Planning potentially has an important role;

QUESTION TO AUDIENCE CAN ANYONE TELL ME WHAT PLANNING IS…. THE SORTS OF THINGS WHICH PLANNERS MIGHT DO…? Planning is primarily to do with the development of land and the change of use of buildings –Our main tool is approving or refusing planning permission. This is called Development Control. Where a development proposal is unacceptable, we can either refuse it or approve it with conditions attached.

QUESTION TO AUDIENCE WHAT MIGHT MAKE A DEVELOPMENT PROPOSAL UNACCEPTABLE?

QUESTION TO AUDIENCE CAN THE COUNCIL TAKE WHATEVER PLANNING DECISIONS IT LIKES…?

WHAT SORTS OF THINGS MIGHT IT HAVE TO THINK ABOUT WHEN IT DECIDES WHETHER TO ALLOW A DEVELOPMENT PROPOSAL…? Objections from neighbours; Applicant can appeal; Government Policies; Regional policies;

WHAT SORT OF THINGS CAN WE NOT DO? Planning cannot close down existing lawful businesses or force them to relocate; Planning cannot interfere in commercial competition between existing businesses or discriminate between different types of businesses; Planning cannot magic development out of the ground – we can grant planning permission but almost all development proposals are carried out by private developers who acquire land, secure all other necessary permissions and build whatever is being built. In exceptional cases, where there is clear public interest, we can acquire sites through compulsory purchase. This process is long, expensive and carries considerable risks;

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Introduction to the New Planning System So far so straightforward; Now it gets a bit more complicated.

QUESTION TO AUDIENCE HAS ANYONE EVER HEARD OF THE LANCASTER DISTRICT LOCAL PLAN…? WHAT DOES A DEVELOPMENT PLAN DO? Sets out how development needs will be met; Identifies priority areas for regeneration; Allocates sites; Protects sites from development – eg Green Belts, Nature Conservation sites, mineral reserves and land needed for infrastructure.

WHAT WAS WRONG WITH THE OLD SYSTEM ? District Local Plans took a long time to prepare. Our Local Plan took ten years from commencement to adoption. By the time they get adopted, the world has moved on and much of the plan is out of date. People didn’t feel involved. Documents too big and too complicated. THE NEW PLANNING SYSTEM New statutory purpose of planning – sustainable development; Sustainability Appraisal WHAT IS SUSTAINABLE DEVELOPMENT ? Spatial Planning – Co-ordinating land-use planning with other functions – LSP link WHAT OTHER FUNCTIONS AFFECT THE ENVIRONMENT ? Highways Parks Housing Property Economic Development NEW SYSTEM Local Development Framework – bundle of documents; Core Strategy Development Control policies Land allocations

Core Strategy – Talk and Practical Exercise What the Core Strategy has to do ? Regional Spatial Strategy Housing Numbers Green Belt/AONBs Bailrigg Heysham-M6 link. WHAT ARE THE OPTIONS? Advantages/Disadvantages of options – discussion. WHICH STRATEGIC OPTION IS THE BEST? ARE THERE OTHER OPTIONS WHICH HAVE NOT BEEN CONSIDERED ?

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Breakout Sessions

Economic Regeneration Sustainable Communities Cleaner Environment Do we try to focus employment Do we have enough brown-field How can the planning system creation on Morecambe and sites; contribute to reducing CO2 Heysham or do we focus on What factors should we look at emissions? growth areas such as the when we decide whether to What should the Council’s University? allocate sites ? planning response be to the How important is sustainable How important is public transport implementation of the Heysham- transport to new employment and what should our approach be M6 link? development? to housing in rural areas? What are the implications of Should we be focusing new What is the right approach to climate change for planning – employment development in town density? flooding, land-use change? centre locations or on out-of- How can planning influence centre business parks? change in the rural economy ?

What should our approach be to new edge of centre and out of centre retail development?

Plenary Discussion and Session Feedback on Working Groups ? General conclusions ? How does the LSP wish to be involved in the LDF process ?

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Notes of Discussion

Core Strategy Options & Discussion - Questions Raised: Market driven option – is the planning system capable of withstanding market driven pressure in favour of community views/community preferred options? AD: Planning is always under pressure from market forces . The new planning systems address the need for community views and community options. Why are there still such stark differences between the settlements of Lancaster & Morecambe? AD: Similar situation in Crewe and Nantwich, in that circumstances change. The challenge is to recognise a central place, as there are not geographic differences but cultural differences. The market forces depend on perceptions and confidences. Morecambe currently lacks the good perceptions and confidence. Why was the dispersal strategy option not discussed in the seminar? What does its exclusion mean for rural areas? DL: The first three options faired best on the sustainability appraisal and the market driven option has been included as an example of a less sustainable option. JI: As a council we have not yet decided on the options. The options are still subject to further consultation. However the sustainability Appraisal it was very clear that dispersal had an adverse affect on the achievement of sustainability. Dispersal increases travel demands, traffic and road miles, and limit’s the usage of social support services which are based in urban centres. This is not an option that will benefit everybody. Are all options determined by national/regional spatial strategies? DL: Around 70% of the strategic decisions our outside the Council’s control. National and regional policies need to be taken into account. The options at local level are limited but there are still some fairly meaty decisions to be taken at local level. In reference to the question raised through the seminar ‘what is the definition of sustainability?’ – why do we always assume that it is a balance/a compromise between factors e.g. economic versus environment? Is there a possibility of being more pro-active and seeking out what kind of development activity would be acceptable to both economic/environmental/social factors? In other words, can we seek out more desirable types of development e.g. clean technology, in order to achieve a good outcome on all three indicators, rather than waiting for development to come along and be tested according to the sustainability factors? JI: Can give it a go! If that is what the Councillors and the LSP wish to take forward. Has a risk analysis of all the options been carried out on all the options? Several factors may result in the options being more or less successful. DL: No formal risk analysis has been carried at this early stage. This will come at a later stage. It is commendable that LCC has come up with its own local definition of sustainability in the absence of clear central government guidance. However, if each planning district throughout the country comes up with its own local definition and method of analysis of sustainable development does this create an opportunity for developers to challenge the discrepancies between LPAs? Lack of consistency? Therefore, is there an opportunity for LPAs to discuss between themselves in order to reduce this 'challengibility'? JI: As a County there is a network to try to synchronise definition this has proven to be a lengthy process as all districts are at different stages in the development of their LDF– how long do we wait? It may be challengeable down the line -but we have told everyone openly what we have done at each process. AD: The Council needs to define sustainability to reflect local circumstances. There is much discussion about the Core Strategy. If a strategy is a statement of how to achieve an outcome and an outcome is a series of aims and objectives, then wouldn’t the strategy be easier to

33 determine if we know what our outcomes/objectives should be? In other words, is there scope to reverse this approach? Questions we should be asking at this stage include, ‘as a district do we want to see population growth? How much? How many new houses? Where? What kind?’ before we can determine the appropriate strategy. As a Planning Team how far are you away from knowing what our desired outcomes are/should be? DL: These are the key questions that need to be answered. The intention of the break out sessions is to address these issues. That is why we have involved the LSP. How do you see transportation informing these different options? M6 Link? DL: Transport is critical; we are obliged to work to the decisions that the County Council have made. All options appear to be demand led rather than a ‘vision’ based approach, is this an adequate assessment? Why? DL: A clear vision needs to be developed. How can we come up with an appropriate vision and take this forward? GD: The first attempt of a vision that was created and widely used by the community strategy needs to be developed however the key principles behind the vision have not been challenged. Therefore the vision could be used to inform the LDF Vision. Allotments are both community resources and vulnerable assets – how can the new planning system help to protect these assets and identify new sites for allotments? DL: Allocations of land/ vulnerable sites is a stage of the process further down the line. A number of questions have implied the need for a vision for the future. However, has a sustainability appraisal been carried out for where we are at the moment? JI: No. An appraisal of the existing Local Plan would be a useful exercise for comparison.

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Breakout Group 1: Regeneration What can we do through planning to bring jobs to areas of need? Develop the Heysham-M6 Link Road The Lancaster Business Park is an and improve accessibility to transport unsatisfactory development and care between Lancaster and Morecambe. must be taken with the Bailrigg Business Improve bus times within Lancaster and Park that this situation does not recur. Morecambe. Lancaster is on a major national We have low unemployment although broadband trunk route giving major there is a lot of part time and public opportunities for web based IT sector employment. Earnings remain low. businesses. There is an opportunity to Worklessness through incapacity, which widen broad-band access off the trunk does not show up in the figures, remains route throughout the District. high and business formation rates are There is a risk that low cost basic low. business space could be lost if all The North West Regional Economic employment areas are regenerated or Strategy prioritises the knowledge lost to housing or other development. economy and the Bailrigg Business Park South Heysham and Lancaster Moor will be a key element in achieving this. Hospital could offer the opportunity to meet this need.

Should we be focusing office-based employment in town centre locations or on out of centre business parks and industrial estates? Strong preference for office-based Is the performance of Lancaster a employment to be located in town function of the free market? Preston and centres. Questionable whether Lancaster Blackpool don’t seem to think so. University should be defined as a town Concern at performance relative to centre and location for office competing destinations. development. Lancaster and Morecambe could develop What should be our strategy for a role as a weekend destination building Lancaster and Morecambe Centres and attractive retail, hotel and public realm what should our attitude be to out of offer. Need to develop specialist retailing centre shopping development? in both Lancaster and Morecambe. Midland Hotel will be crucial to Morecambe. What should our Strategy be for major derelict or under-used areas such as Luneside and South Heysham? Need some form of bridge crossing to massive impact on the degree to which open up Luneside. people will walk to Luneside West Need to force the pace on existing sites South Heysham Waste Technology and drive innovation on public transport Park/Renewable energy Wind turbines solutions. opportunity. Address symptoms before developing Nuclear decommissioning and the future solution of the power stations will be a major issue. Need to apply Sustainability tests to existing sites Population influence – demographic, young people and South Lakeland The way in which the waterfront area of Linkages. Luneside East is treated will have a

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Breakout Group 2: Communities Do we have enough brownfield sites to meet the housing needs of the community? Type of housing Density Affordability What are the General housing needs? A recent housing needs study recently Policy to control the TYPE of revealed that a hidden population – development on brownfield sites to require 2 bed flats rather than terraced generate steps in the housing ladder. housing Consideration to given to affordability, density and design. Homelessness requirements need to addressed – housing strategy. Carnforth to grow? – Being so close to the motorway junction Carnforth is Are there enough brownfield sites in the becoming a commuter town with no- one right location? using the town centre. Not just about brownfield sites – many Economic consequences vacant and derelict buildings need to be addressed. What factors should we look at when we identify sites for residential development? Brown field - What the site is already used for Not in floodplains The needs of surrounding districts e.g. South Lakeland Existing Infrastructure Business Development could be Climate change focussed on areas where the school Distance to education 1 mile max – any population is declining in order to further generates to much traffic maintain a viable school role. Access to bus routes Using a point system to test their sustainability could prioritise sites. Ability to move community – need for affordable housing stock How much new housing should be built in our villages? There is a need for affordable housing in village who otherwise find it financial the villages to allow the villages to difficult to get on the property ladder in continue operating as villages the village. Level of the Development needs to be We need to think about the villages and controlled with certain areas of land housing for the future not for the present. allocated to developing affordable The local economy in villages needs to housing. match the housing types – a BALANCE New developments should be affordable is required. and shared between the open market and those with some connection with the

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Breakout Session 3: Environment Can we make better/less use of natural resources in new development? YES!For example, an average of 25% More remodelling of existing buildings to recycled materials (from blocks to light utilise existing resources HOWEVER switches) can be used in new build – questions raised over whether it is apart from being better (re) use of always justified to preserve at the resources this also means that expense of achieving more efficient new developers can save money! build – are we being governed too much by central government (listed buildings) How available are resources? It is better rather than making local decisions? to use on-site supplies i.e. from demolition or local suppliers to avoid the Barn conversions - in need for extensive transportation of villages/periphery of villages = good use goods – Council stone bank – ready of existing resources and more supply of natural reusable materials sustainable, make use of existing services and generates more critical Need to use traditional materials such as mass to create/maintain services in rural lime mortars so that stone can be re- locations which reduces need to travel t used in the future– the extensive use of cement in modern construction may in remote locations – is this sustainable?. negate this! Generates unnecessary travel? However, new technology e.g. broadband for We need to carefully consider the live/work units may negate this? balance between aesthetics/visual concern and the need to achieve better There is not a straightforward rural/urban energy efficiency targets using split e.g. Carnforth a rural/urban market sustainable materials e.g. upvc windows town? We need to decide on what we versus tropical hardwoods? We also want its role to be. need to think carefully about how they Sustainability is about people’s lifestyles will be disposed of in the future? – we need to make choices and people may need to reduce their standards of living = more energy efficient homes

What can we do through spatial planning to reduce growth in road traffic? Main thing: we need to provide a real Better links required between spatial alternative to car travel – a good public planning and transport planning – we transport system need a transport VISION Lancaster District people have negative Air quality is a real problem (in Lancaster perceptions of public transport District) – Planning needs to tackle this Better rural transport system needed – Planning to learn from elsewhere e.g. bus routes Manchester trams – clean, efficient and reliable services as alternative to car Planning needs to learn lessons from the travel – when will things get bad enough past e.g. ‘meshing’ of development – to address this issue?! housing workforce near the workplace to reduce need to travel – more MIXED Should we create more car free or car USE development – self sustaining limited new developments? developments? Patterns of employment Lancaster one way system – create to encourage shared travel priority bus routes? More small scale retailing – building up shopping centres rather than dispersal

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What more can we do to improve the amenity of urban areas? Poor urban areas are a real problem in residents/pedestrians and vehicles e.g. some parts of the district – creates very more HOMEZONE type development real stresses for some residents with no Materials and design of urban streets are access to healthy outdoor amenities key consideration – lighting, street Are our developments too dense? E.g. furniture and trees historic industrial terraces? New NIMBYism is a problem – creates development provides good opportunities pockets of neglect and high crime areas to improve opportunities for recreation, gardens are v important However, need to balance the re- prioritisation of pedestrians with the need Even in high density developments there to maintain vital and vibrant (and are opportunities for creating high quality accessible) retail centres e.g. Carnforth – outdoor space e.g. roof gardens would traffic reduction destroy retail CARS dominate our urban streets – we centre? need to redress the imbalance between Can we do more to protect and enhance wildlife and landscape/seascape? Seascape is a distinctive part of our an otherwise sterile agricultural district and has much potential to be environment? Negative views concerning enhanced and better utilised wind turbines and their locations are often held by people with little SSSIs/AONBs and other areas with understanding of issues. special designations should rightly have high levels of protection Lancaster District has a good wildlife corridor that should be encouraged – we Wind turbines – a big issue! But need to do more to encourage wildlife welcomed as an amenity and landmark – into our urban areas. they are actually an asset that enhances

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Formal Response of Chair of Lancaster Local Strategic Partnership

From: Dowding,Gina Sent: 30 September 2005 21:14 To: Brophy, Maurice Cc: Kinnon, Alison Subject: Core Strategy Consultation

Dear Maurice Somewhat last minute I am responding to the consultation ( deadline midnight tonight?) regarding the core strategy consultation. As chair of the LSP I think that the urban concentration model as an option would most closely fit with all the aims in the Community strategy. however I think that it would be good for the LSP as a whole to consider this once again during the next couple of months as has been suggested. I would like the Building Blocks to be given the chance to comment at that stage as well. However many of the partnerships are under a lot of pressure - both in terms of information and consultation overload so it would be good to explore with you how the consultation could be kept brief. The presentations by the planning department were certainly very useful and I am pleased that the LSP is being consulted on this important issue. Best Wishes Gina Dowding Councillor - Duke's Ward Tel (01524) 811 562

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Response of Lancaster University Students Union It appears to me that the most appropriate option for taking forward the development of Lancaster District is a version of Option 1 – urban concentration, with significant (but not exclusive) focus on the Regional Regeneration Priority area. Some development of services in villages / rural areas should also be encouraged in order to make them more sustainable as functional, working communities and less reliant on private car use to access basic amenities. Schemes such as Business in the Community’s Rural Action Programme and the Pub is the Hub should be taken advantage of where possible, with an emphasis on making better use of the services and infrastructure already available. Priority should be given to low-impact housing and sustainable construction techniques (including use of local and recycled materials), including prioritising previously-developed land with consideration given to good (or potentially good) public transport links and access to cycle paths and pedestrian links, access to employment opportunities, amenities and services. However, care should also be taken with new developments that they fit in with the character of their location. They should both respond to and cohere with their settings, fitting in with them and adding to them in a sensitive and considered way. Affordable housing, mixed-tenure housing and mixed-use developments (ie intermixing housing and amenity developments, eg healthcare, education, small- scale retail (especially food), recreation and social facilities) should also be prioritised. New housing on undeveloped land outside urban areas or villages should be strongly discouraged. Public transport networks, especially in rural areas, need to be developed in order to reduce reliance on private car use and promote social inclusion for households without access to a car. Bus and cycle lanes in and between Lancaster and Morecambe town centres should be given serious consideration. Sensible energy policy should focus on micro developments, with all new build (housing, industrial or commercial) required to assess the potential for providing for their own energy needs, eg through small, site-specific wind turbines, solar panels as integral design features, energy efficient construction features etc. Large-scale wind turbine developments should be considered, but with due regard to their impact on the distinctive beauty and tranquility of the natural environment and the views of local communities. Local production and consumption should be strongly supported and promoted. Local food production and procurement is one good example of a positive chain reaction - local organic waste is composted and used to grow organic food which is then bought locally. Waste is reduced, food miles are cut, soil condition is enhanced, jobs are created locally in small scale growing and distribution, and the local environment benefits. Lancaster, and especially Morecambe and Carnforth town centres, should be supported and strengthened, and out-of-town retail and leisure developments resisted. Securing investment and employment should not take priority over high quality design and considerations of social and environmental sustainability if we wish to develop a district that is, in the long term, an attractive place to live, work, visit and invest. These aims should be seen as complementary, not in conflict. Social enterprise and socially and environmentally benign development (eg ‘green’ technology and tourism, organic farming, co-operative ventures) should be actively pursued as a key part of the strategy. Lancaster district has the potential to achieve flagship status for green development, especially with the focus on environmental issues at the university. A clear decision to focus the strategy on genuine sustainability will open up a range of significant funding streams for a variety of avenues of development.

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Response of Lancaster District Food Forum I am sending this in my capacity as Chair of Lancaster District Food Forum which is a topic group of the Sustainability Partnership, not with a specific choice of option, but some comments relating to questions asked regarding shopping etc. Hopefully these may be taken into consideration when making a final decision. Lancaster is very fortunate in having a “green awareness” and in terms of food, should strive to promote itself as a local food specialist and build on the success of the Farmers Markets. We are continually seeing the loss of local shops and skills such as bakers, butchers etc due to the stifling of local businesses by the supermarkets. There has recently been an increasing public awareness and outcry about the need to buy more local foods. It has a beneficial effect on the local economy, more money being returned than when spent in a supermarket and there are also the environmental factors. Food miles are reduced, less packaging and subsequently less waste, less pollution, less Carbon dioxide emissions etc. There is a change in public attitude to mass-produced foods and the negative impact on health and the environment. Lancaster and District does not need more Supermarkets, but a variety of local shops supplying more locally produced foods and there has to be incentives for traders to establish these. We will soon be working with the County Council using a Food Mapping tool which links to the GIS system to identify the areas of the district where food access is limited, due to lack of shopping facilities. This may be a useful exercise for the City council to take on board when considering the development plan. I hope you find these comments useful.

Diane Watson, Food and Health Adviser, Morecambe Bay PCT.

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Cllr Peter Robinson KEY QUESTIONS Vision and Overall Strategy To reduce the number of unnecessary journeys… be it travel to work, to shop or for basic leisure activities. THUS Any new development must take into account the above criteria. THIS Will result in a combination of the six options provided by the forward planning team: Essentially URBAN concentration, focusing employment on the priority REGENERATION areas of Morecambe & Heysham, with selective DISPERSAL and MARKET DRIVEN options. This will provide employment opportunities to complement the housing led regeneration within Morecambe and Heysham and thus stimulate the local economy. At the same time it reduces the need to travel across the to access work, retail and leisure. It also provides an opportunity to tackle the present unbalanced housing market that exists between Morecambe & Lancaster. Any forward strategy must redress this issue, in particular the over supply of cheap flats in the buy to let market in Morecambe in contrast to the high rent, high value property in Lancaster, which leads to very poor infrastructure in parts of Morecambe & Heysham. Good schools, in Morecambe will help persuade parents not to send their offspring to schools in Lancaster, while better and more accessible GP and dental practises will lead to shorter car trips. Selective development in the rural areas will ensure that market towns like Carnforth and rural settlements like Silverdale and the Kellets will survive and succeed as viable communities and reduce the need to travel for work, retail and a leisurely drink. Similarly, selective distribution centres close to motorway junctions will reduce the number of HGVs imposed on the shopping centres of Lancaster, Morecambe and Carnforth. Urban concentration, however, should not detract from the need to limit, if not seek to prevent, housing development on the recognised flood envelope within Morecambe & Heysham. Indeed, rising ground water levels would suggest that this is inappropriate, unless buildings are to be designed on stilts and the favoured mode of transport is the Gondola. In order to reduced unnecessary car journeys, employment opportunities ought not to be concentrated on single sites, such as the proposed Centre for Creative Industries and Bailrigg business park for knowledge based industries, which will only result in increase traffic to and from the various parts of the district, adding to the existing congestion (for which the Northern By Pass will provide no solution). A far more strategic option is to disperse knowledge based/ IT/ Hi Tec employment to selective parts of the district. This would not only tie in with the selective dispersal element of the “VISION” for maintaining the viability of Carnforth and the rural villages, but also enable unpopular, unattractive and unviable housing in the urban core, to be converted into business premises or live and work premises or managed workspace. Similarly, office space should not be focused solely in Lancaster, but deployed in other parts of the district, notably Morecambe and Heysham. It may be necessary, therefore, to seek amendments to any Regional spatial and/or economic strategies which seek to focus on site specific projects only. Any future housing developments must meet the criteria specified in the ‘vision’, so that land must also be identified which can be developed into ‘off road’ cycle lanes to access schools, shops, employment and leisure/ sport uses within the location being considered. Housing needs identified in the David Coutie survey, such as two bedroom flats, whether for rent or sale, need to address the strategic imbalance within the housing market between Lancaster and Morecambe. More family homes for sale in Poulton and the West End, more rented property, particularly affordable, in Lancaster.

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It must also be remembered, that the David Coutie survey of ‘preferred’ housing type from ‘hidden’ households, is a snapshot and, as history determines, trends change over time. Two bedroom flats may be the preferred choice today, but in 10 or 15 years time, this may change, leaving the Council with a tranche of unpopular housing type, exploited by unscrupulous landlords and letting agents. This is clearly not sustainable. There needs to be a strategy to tackle any problems of "voids”, whether in the public or private sector to avoid ghettoisation in the future. Moreover, as the population grows older, is living longer, with a dramatic fall in the local birth rate, more provision needs to be in place for the elderly, the disabled elderly (physical, visual and mental impairments), and the disabled per se. To enable the elderly to live as independent a lifestyle as possible, access to shops and leisure is vital. This applies to the elderly in all parts of the district, but perhaps more so to those in rural areas. The quality of design is also vital to ensure a balanced housing market. It the better quality design is focused in Lancaster, this will exacerbate the strategic imbalance, attracting named retail outlets, bars and restaurants and financial services into Lancaster to the detriment of other parts of the district which, of course, will increase the need to make unnecessary car journeys, with all the attendant problems of air pollution, asthma, use of dwindling fossil fuels.

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Councillors LDF and Core Strategy Event The Platform 26th September 2005 Attendance

Councillor A. Bryning Councillor E. Archer Councillor S. Rogerson Councillor R. Sherlock Councillor S. Denwood Councillor J. Pritchard Councillor S. Fishwick Councillor S. Bray Councillor E. Blamire Councillor P. Quinton Councillor K. Brown Councillor C. Coates Councillor J. Hanson Councillor E. Ashworth Councillor R. Sands Councillor P. Robinson Councillor K. Stamp Councillor I. Barker Councillor S. Charles Councillor M.Thomas

Questions and Answers: General Discussion Session Question: Cllr Barker – The Core Strategy is being produced at the same time as the Regional Spatial Strategy – to what extent have we taken RSS draft strategies into consideration. Answer: D. Lawson – We have to feed into RSS e.g. house building numbers, in developing these options we have had to 2nd guess what will come out of the RSS. Answer: M. Brophy – two regional documents (1) Regional Economic Strategy which was consulted on in July and sets the parameters for growth and (2) The Regional Spatial Strategy which is informed by Regional Economic Strategy. These two documents are intended to work in parallel with each other. The RSS will be published in draft at the end of October and will set out the things like population growth for each District and this is what we plan for – in accordance with the this process. Question: Cllr Bray – the options concentrate on urban are there no plans for the rural? Answer: D. Lawson – That is an important question – how we deal with rural areas – we are not ignoring the rural areas but have no answer yet! An 80/20 split for urban/ rural Government guidance discourages countryside development. Other issues focus on urban development Answer: Cllr Quinton – The Council is addressing the importance of development and regeneration in rural areas. Rural affairs have considered the RES and the City Council have responded with rural areas not being forgotten. Question: Cllr Blamire – Will regional body make decisions on quarrying and waste? Answer: M.Brophy – The RSS will contain policies but Development Control will still be by County Councils. Question: Cllr Bryning – So far options are land based but as coastal authority what proposals for bridges/ offshore development – who is responsible? Answer: D. Lawson – Planning Controls stop at land – offshore is Central Government approval. Question: Will the issue of Regional Parks be addressed? Answer: Julian Inman: This issue will be addressed in the RSS Question & Discussion: Cllr Robinson – The key issue is transport – traffic movement a reduction in the amount of car journeys made is needed. Another issue is the housing moratorium – concentrated in very limited areas, which is not ideal. How can we as planners prevent the loss of essential facilities? Promoting development on Brownfield sites puts stress on existing services Greenfield site question- if things score badly on environmental aspect can we negate this disadvantage but promoting high environmental spec e.g. eco homes and public transport. Question: Cllr Fishwick – Will a similar thing happen in Lancaster as Morecambe creation of HMOs when University downturns? Answer: This issue will be raised in Maurice’s group.

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Breakout Group 1: Regeneration

Facilitation: David Lawson and Dan Hudson

What can we do through planning to bring jobs to areas of need? Identify areas of need for different businesses – Look at current market sectors e.g. Tourism in specific to areas Morecambe, expansion of University Make things easier for business Need for inward investment? Specify in the Core Strategy Self Sufficiency? Flexibility Encourage small businesses – deregulation, parking, shutters Look at real economic benefits i.e. net benefits Offices above shops, internet Transport – hi tech solutions Should we be focusing office-based employment development in town centre locations or on out of centre business parks and industrial estates? Parking easier – move traffic Closer to customer base Demand in Morecambe? Traffic and transport Edge of centre – cheaper- aid regeneration, lower Joined up with housing strategy rents Green travel plans – company buses More attractive to commuters – lose money Home working – boost rural areas, PO’s. Restrictions in historic centres – flexible What should be our strategy for Lancaster and Morecambe Centres, and, what should our attitude be to out of centre shopping centres? Easier to get to but raises many sustainability Travel and traffic issues Make centres more attractive – pedestrianisation, Disagree with out of town allows mix of uses, café culture More choice a myth How much parking? Need individual approach to Lancaster, Impact on local shops, butchers, greengrocers Morecambe and Carnforth etc. Rural shops? Need for more houses! B&Q – jobs, traffic, alternatives for workers, buses, bikes. What should our strategy be for major derelict or under-used areas such as Luneside and South Heysham? Access problems – especially Luneside South Heysham – Access – railway , waste transfer ( community enterprise – furniture Luneside – Urban Park, riverside Park ,new Lune matters) – opp along new road , Pointins crossing , Prison to replace castle What can we do to promote tourism ? Still loosing bedspace – though Tern project has Cafes/bars/ Restaurants/ dwellings mix been helpful Link to the Lake District /Bay Authority Bubbles site competition will raise profile Bay regional Park – joint working Easyjet syndrome –shared with other resorts Rural tourism – not just Lune Valley! Must look at Lancaster Lancaster Canal – extend walking and cycling Day trippers /weekend/coach parties Morecambe dropped further than other resorts

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Breakout Group 2: Communities

Facilitation: Maurice Brophy and Sarah Hind

Do we have enough homes to meet the needs of the community? How do we know what the housing needs of local Enough housing for those that can afford them! residents are? But not enough for those who can not afford them! David Couttie Report – provides answers about need Housing Associations – limited in what they can do, homeless, shared ownership Regional Planning provides a housing requirement Re-address balance of one bed flats (too many in West End) First time buyers – rural areas OK – with commuters living in the District Restriction on new builds as these increase prices NEEDS FOR Selling off council housing was a bad move Mixed developments Housing needs survey (3- 4 years) Affordable discounted system Certain sectors Stop raising expectations What factors should we look at when we identify sites for residential development? Amenities can be added to larger sites – schools, Brownfield Sites to be developed first shops, Doctors, Dentists, Parks playgrounds Infill Existing amenities Greenfield Infrastructure – public transport And last: Isolated Countryside Affordable How much housing should be built in our villages? Family needs? Flats Sustain villages Need to identify needs No second homes – heavily taxed Affordable homes What characteristics should new housing have? Focus on Affordable Homes Gardens/ Outside space Varied types to reflect the variety of needs Homes for the future Eco homes – efficient for energy and Life-time homes – adaptable and accessible for economically all.

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Breakout Group 3: Environment

Facilitation: Julian Inman and Elaine Lee Can we make better use or less use of resources in new development? Design – solar panels, grey water use etc. Luneside East - high environmental demands More imaginative development – underground Old buildings to modern efficiency standards garaging etc. semi detached and terraces to Lifetime homes reduce energy loss-built into design at outlet INDUSTRY – planning can provide policies to Greenfield –mitigate low scores of some encourage appropriate forms of industry. development by insisting on energy saving Design/Aesthetics versus energy efficiency e.g. Park and Ride solar panels …. Materials Bailrigg – is this being pushed on this proposal? Biomass Future thinking industries that should have Park and Rides nvironmental issues at forefront Re-education of peoples needs/priorities What can we do through spatial planning to reduce growth in road traffic? Integrated rural ( and public generally) transport Park and Ride – in strategic locations e.g. Carnforth Station –LDF needs to address How to overcome geographical problem and social/economic imbalance in the District? Political and Economic objectives Buses are not desirable to the majority? Communication with rail authorities and other transport bodies Trams as an alternative? More MIXED USE – more jobs in local areas – M6 LINK – Congestion tackled by internal public less travel? transport system Opportunity for locally operated rail systems What more can we do to improve the look and feel of places in urban areas? SPACES in urban areas should be useable, Car parking provision –what level? attractive and meaningful Pedestrian areas – encourage walking and Connectivity in urban areas – opportunities to cycling – more/better and cleaner routes design out crime, safe lit routes Police and planning authority Avoid overcrowding? High density not Disparate views – secure by design overcrowding Enforcement of planning Gardens –better designed Cleanliness public realm – seats, bins Introduce community based activities and facilities e.g. village halls –ensure no over provision (viability) Can we do more to protect and enhance our landscape and our wildlife habitats? Difference between AONBs and other Members and community involvement – parish plans Small pockets requiring protection Balance between principle and detail application Development in rural areas needs to be sympathetic to unique local conditions Wide strategy to be agreed and signed up to to negate problems further down the line. Carry on with good track record… Wildlife corridors in towns Reusing existing assets e.g. barn, conversions to reduce landscape impact Wind farms? visual issues and viability ( each one is unique);

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LDF Parish Councils’ Evening Monday 21st November 2005 Lancaster Town Hall

NAME PARISH

J.Thomas Borwick B.Fell Borwick Ken Bond Carnforth John Pratt Carnforth Peter Whalley Heysham Eric Briggs Heysham Tony Sunderland Priest Hutton Ruby Murray Tatham J.Dent Warton C.Peacock Warton Frank Senior Warton Mr Ball Warton Alison Rennie LancsCC (Community Engagement Team) Andrew Wilkes Hornby Summary of Questions and Answers asked in Open Session: Why is the economic section in the ‘sustainability wheel’ smaller than the environmental and social section? Is this significant? Does this affect the overall sustainability outcome/achieve a balanced view? As the conclusion reached by the process of sustainability appraisal takes consideration of the impacts of a policy or proposal in the round the objectivity of the sustainability wheel process does not require equal numbers of considerations in each of the three areas of sustainability consideration. It should be remembered that the purpose of sustainability appraisal is to consider the relative purpose of a range of options, thus the consideration process compares each policy or proposal against alternative policies or proposals, it is never a comparison of whether, for example, for any given policy or proposal, the evidence from the Environmental Protection segments outweigh the evidence from the Economic Growth and Employment segments. Is the scale (i.e. –2 to +2) arbitrary? Could having a larger scale have a more accurate assessment? It is difficult to make an informed judgement about the implications of a policy or proposal on any of the segments. To be effective and understandable the system has to be simple enough to be applied in practice. The evaluators will really be making a determination of whether the policy or proposal will have some impact (+1 or –1) or a quite significant impact (+2 or –2). It would be unrealistic and no more helpful to the process if we asked evaluators to determine any finer a scale of consideration. A major aim of the process is to highlight any policies or proposals that score particularly badly. How does this (new planning system) help to resolve the problem of having development plans that a lot of local people don’t want or accept? The discussion this evening is about policy development, not about determining individual planning applications. Ultimately the City Council, as the Local Planning Authority, has responsibility for making judgements about the desireability of policies or proposals that are included in development plans. It does this by balancing the considerations. Clearly any single policy or proposal will have its proponents – for example landowners and developers and it opponents – for example local residents. Thus when, for example, allocating land for development it is still entirely possible that, even with the wider consultation that takes place through the new forward planning system that local residents may be displeased when a site allocated. However a Local Planning Authority will have made that decision by taking account of the variety of competing views.

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Can there be a mixture of (core) options rather than just one preferred? In effect, yes, the general approach that the Council may be shortly recommended to proceed with will be the Urban Concentration Option, however this still anticipates that around 15% of development with the LDF period will occur in the non-urban areas. The Core Strategy will set a general direction that will be informed by local development considerations and circumstances. Will you be looking at which rural settlements should have priority for growth? Yes, the settlements where some growth maybe directed will be those with the best range of services. Has any thought been given to how you can achieve more affordable housing in rural areas? Yes, this is a very significant issue to which there is no easy solution. While the market has caused house prices to soar the Council is not in a position to build housing itself to service as social stock. How can you ensure that affordable housing goes to the people that really need it? E.g. give priority to people with local connections? There are existing well-used mechanisms for people with local connections can occupy ensuring that new housing. Parish Councils should develop a view themselves about the housing need in their villages. In rural areas land can be identified for local needs housing only .In any case housing development in the rural areas can only be developed where it is intended to meet local needs. This subject is explored more fully explored in the Communities breakout discussion session. Is it the intention to modify your monitoring document to show the area of land that has been granted planning permission to better reflect the amount of land that has been committed (not 35 hectares according to calculations carried out by member of audience & more like 70 hectares to date which is not sustainable!)? In making decisions about individual planning applications [for employment related developments] the Council must come to a view in the context of the information available to it and the views of both developers and objectors. Whilst employment land monitoring is not subject to the same point-in-time commitment and rolling land supply considerations that inform housing land monitoring the Council can look at the issue of commitment in monitoring the take up of employment land again. Will you be publishing similar monitoring reports for the new system? As well as continuing to publish the existing detailed monitoring reports on employment land, retailing and housing land the new planning system also requires the Council to publish an Annual Monitoring Report (AMR) that describes progress on preparing the Local Development Framework Documents and implementing the polices that they contain. The first AMR is currently being prepared and will be published for consultation purposes shortly.

Breakout session key issues

Regeneration How much employment development should we aim to achieve in our rural areas? Must be allowed or villages die Some grants and schemes available AONB Must be small scale – not big industry Is information reaching rural areas? Role for the Council Needs complementary investment e.g. public transport Demand for small scale affordable premises Increased isolation Links between prosperity in urban areas Where will cash come from? NWDA, EP and Europe What types of employment should we encourage in our rural areas? Businesses start working from home Start up units in key villages When successful – need bigger picture But how to keep them local? Availability in rural areas What about Barns? Depends on location

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Can add character of area More farm break ups But less likely to use rural services More help for farm diversification…but transport!!! Home workers could support services e.g. PO Need policy to ensure complementary community facilities Agriculture still losing jobs – more sub contracting Less people wanting to go into farming

Environment How can we make better use or less use of resources in new development? Developing brownfield sites Wind farms? ‘In scale’ with the landscape assess each individual site on its merits All new housing use new ‘green’ technologies – solar panels etc. – minimising use and generation Mixture of various technologies of energy Tidal power? Priority of sustainable technologies over design and aesthetic appearance What can we do through spatial planning to reduce growth in road traffic? Free busing of all children to school (over 1 mile) Development attached to existing development e.g ‘care centres’ CCTV on school buses Shared equity development (led by housing Balancing suitable employment development in associations) example York? areas where existing employment is Affordable housing for young people to keep Mixed use development them in villages led by parish Councils at outset. Question 3: Can we do more to protect and enhance our landscape and our wildlife habitats? Reduce consumption of green field sites Encourage more footpaths to link rural areas and between villages Develop brownfield sites in villages (not farms) Community to the countryside (county policy) Support for barn conversions – dependent on location ( how sustainable?) Wildlife corridors – not islands!! Protect Morecambe Bay

Communities How much new housing should be aimed to build in our rural areas? Price stock for each village – to determine what Smaller accommodation 1-2 bedroom dwellings housing is needed. freeing up 3-4 family homes HOUSING NEED STUDY – simplified? Specify allocations as affordable housing 8-10 years time or now schools will have to close Broad cross section – happened in Heysham down HOUSES FOR LIFE For whom should new housing in our rural areas be provided? If affordable homes then - locals first time buyers % of new build to be affordable Elderly Affordable and not aspirational How should housing built in our villages differ from housing built in our towns? Match the character of village Energy efficiency measures Solar panels / Wind Turbines – may increase the affordability

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APPENDIX 4 – PREFERRED OPTIONS CONSULTATION – DPD MATTERS

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Lancaster City Council Lancaster Local Development Framework Development Planning Document Matters Core Strategy Preferred Option January 2006

The preferred option of the Core Strategy has now been published for consultation purposes and your comments are invited. The Core Strategy covers the whole of Lancaster District and provides a spatial vision and strategy including the broad location of development up to 2021, along with policies for the regeneration and revitalisation of Lancaster City Centre, the creation of sustainable rural communities, distinctiveness and the protection of environmental assets.

The consultation period will run from 27th January to 17th March 2006. Paper copies of the preferred option of the Core Strategy and accompanying volume of supporting information and sustainability report are available to view at Palatine Hall and Morecambe Town Hall.

Copies of the preferred option can be obtained from reception at Palatine Hall, Lancaster. You can also download the documents from the Council’s website (www.lancaster.gov.uk).

Any person wishing to comment on the Core Strategy should do so by filling in the response form that accompanies the document. Response forms can be obtained from Michelle Williams on (01524) 582383 or E-mail: [email protected]. They can also be downloaded from the Council’s website and returned on-line. Please note that any comments will be publicly available.

If you would like us to keep you informed about the progress of the Core Strategy (i.e. when it has been submitted to the Secretary of State for independent examination and when it has been adopted by the City Council), please tell us in your response and provide an address for further correspondence. If you have any queries about the preferred option, the sustainability report, or the consultation process, please ring (01524) 582383 or email your question to [email protected]

Andrew Dobson Head of Planning and Building Control Services Palatine Hall Lancaster LA1 1PW

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APPENDIX 5 – RESPONSES TO PREFERRED OPTIONS CONSULTATION

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Representor P Para Comment Type Level Council’s Grounds Proposed Change COMMENTS ON CORE STRATEGY INTRODUCTION Countryside 1 1.6 Fully welcome the Council's decision to Support General None Supporting Properties Plc select Urban Concentration as it's Representation Preferred Option. Miller Homes 1 1.6 a Number of sites in Lancaster Observation Site Specific None Site Specific available for redevelopment - including Representation land at Lancaster Leisure Park and the neighbouring Lancaster Abattoir on Wyresdale Road. This site lies in a sustainable location in the urban area. Government 5 1.14 No specific indication (in any Objection Procedural Consult on To meet a key test of Office for the document) that the preferred option is Options soundness North West still open to rejection or that Addendum representations can be made in favour of alternative options. COMMENTS ON CONTEXT SECTION Dr D Alexander 6 2.1 Summary profile of Lancaster District is Support Detailed None Supporting very useful & provides a clear link to Representation the Community Strategy. English Nature 6 2.1 Should refer to the importance of the Observation Structural None Restructuring natural environment in a more upfront document would manner at the beginning of the have no impact on document its substance Mr P Robinson 6 2.1 Not aware of any Bangladeshi Observation Detailed None Information taken population in Heysham North, Is this from Census from the 2001 Census Dr D Alexander 7 2.4 How far does Lancaster being self- Observation Detailed None This section is contained contribute to the the overall factual. It is true sustainability of the district? however that a district which is an attractive place both to live and to work, has the potential to minimise out- commuting and the pollution that goes with it English Nature 7 2.7 Could this be expanded or an Objection Detailed Revised For clarity additional paragraph inserted to paragraph on highlight (see suggested paragraph). natural environment including reference to coast as requested. National Trust 7 2.7 Makes no specific mention of the coast, Objection Detailed Revised For clarity doesn't identify key components such paragraph on as the cliff coast at Heysham. natural environment including reference to coast as requested. Lancs County 7 2.8 Should also refer to the Lancs wide Objection Detailed Include reference For clarity Council - Community Strategy (Ambition Lancs) to Ambition Locality Focus produced by Lancs Partnership. Lancaster. Group for Lancaster Dr D Alexander 8 2.10 Vision for rural area is bland, could be Observation General None This section quotes sharper focus. Morecambe as an the Council’s office, administrative and service corporate vision as a centre could complement the resident matter of fact. community. Where is the vision for Carnforth?

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Representor P Para Comment Type Level Council’s Grounds Proposed Change English Nature 8 2.10 Should include the words "and wildlife Objection Detailed None This section quotes habitats" after precious landscapes in the Council's the last bullet point. corporate vision as a matter of fact. Lancs County 8 2.10 Suggest that the document should refer Objection Detailed Change 'Council' For clarity Council - to Lancaster City Council's Vision not to 'City Council' Locality Focus just "the Council". Group for Lancaster Dr D Alexander 9 2.11 Could the six priorities be displayed Observation General None This section quotes differently - are they intended in the Council's hierarchy? corporate vision as a matter of fact English Nature 9 2.11 Should change "cleaner environment" Observation General None This section quotes to "Greener" or "sustainable" the Council's environment. corporate vision as a matter of fact Lancaster Civic 9 2.11 Priority 4 - Greater prominence should Observation General None This section quotes Society be given to the problem of the evening the Council's economy and to anti-social behaviour corporate vision as a in General. matter of fact National Trust 9 2.11 Does not address the pressing issue of Observation General None This section quotes climate change - measures to reduce the Council's the extent of change etc. corporate vision as a matter of fact Dr D Alexander 10 2.12 The Spatial Vision could be shown in Observation Detailed Review Figure 1 For clarity diagram form, linked to and emerging from the Council's Vision. English Nature 10 2.12 Supports the over-arching Spatial Support General None Supporting Vision. Representation Government 10 2.12 Not totally clear how objectives flow Observation General Review Structure For clarity Office for the from Spatial Vision. of Document North West National Trust 10 2.12 Final document should be more far- Objection Detailed Refer to seeing and practical ie promote and "enhancing " achieve the enhancement of the built distinct identity and natural environment. Setting and "a conserved, standards is useful but limited for a enhanced and 'vision'. diversified" Coast and Countryside National Trust 10 2.12 Concerned that the vision does not Objection Detailed None For represent an integrated approach to sustainable development eg - aspirations for Lancaster are solely economic. No reference to enhancement under the heading "Coast and Countryside". English Nature 11 2.14 Should ensure plans, policies and Objection Detailed Insert additional For completeness proposals protect the overall nature bullet on natural conservation resource of an area. environment policies in RSS English Nature 11 2.14 Should have an extra bullet point Objection Detailed Insert additional For completeness stating "To protect and enhance some bullet on natural of the finest landscapes and environment outstanding habitats for wildlife". policies in RSS English Nature 11 2.14 Should enrich biodiversity through Objection Detailed Insert additional For completeness conservation, restoration and re- bullet on natural establishment of key resources. environment policies in RSS Mr P Robinson 11 2.14 At odds with the RSS to 'regenerate Observation General None Issue addressed in areas of housing market failure' in Sustainability General and in Morecambe in Appraisal and particular. Addendum consultation Dr D Alexander 11 2.16 Would be helpful to include - Securing Objection Detailed Update list of For factual updating the Future, Cm 6467 - Delivering the PPSs in Appendix UK Sust Dev Strategy, DEFRA 4 2005;Action for Sustainability - Regional Sust Dev Framework for the NW; NWRA, 2004; The Rural Strategy, DEFRA,2004. PPS3 & PPS25?

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Representor P Para Comment Type Level Council’s Grounds Proposed Change Mr P Robinson 12 2.17 The thrust of the NWDA's drive towards Observation General None Issue addressed in making 'coastal resorts a regeneration Sustainability priority' would appear undermined by Appraisal and allowing new development south of the Addendum river Lune. consultation Dr D Alexander 12 2.21/ Should the cross-border and Observation General None The Council is 2.22 neighbouring authorities sections form making a case for a part of a sub-regional section covering Bay authority North Lancs? separately. This part of the document is intended to be factual

COMMENTS ON REQUIREMENTS AND OPTIONS SECTION Countryside 13 3.1 Refers only to the North Lancs Objection Detailed Refer to For completeness Agency Green Belt and the AONB's and conserving and makes no mention of other enhancing countryside or coast. Coast and Countryside Dr D Alexander 13 3.1 How do you decide between Observation General None No change suggested market attractiveness and sustainability in case of conflict and how are they compatible? English Nature 13 3.1 Request the addition of the words Objection Detailed None This section lists what "and County Heritage Sites the core strategy (Biological, Geological and must do. Whilst the Archaeological), thus conforming Council as a matter of to Policy 21 of the Joint Lancs practise chooses to Structure Plan. protect sites of County Importance, it is not obliged to do so in the same sense as it is with sites of national and international importance English Nature 13 3.1 Again "Greener" or "Sustainable" Objection Detailed Amend in line For factual updating would be better than "Cleaner" with new Corporate Strategy Government 13 3.1 Are the Council's objectives Observation General Review For clarity Office for the related to your priorities and/or Structure of North West key principles? Document Government 13 3.1 References to "Regional Planning Objection Detailed Change " Correction Office for the Guidance" should be changed to Planning North West "Regional Spatial Strategy". Guidance" to " Spatial Strategy". Halton-with- 13 3.1 Regenerate the Local economy - Observation General None The County Council Aughton Parish last bullet: Should this not refer to has selected its Council managing the Lancaster relief preferred route road without specifying which route is finally built? McCarthy & 13 3.1 Suggests listing those specialised Observation Detailed None Referred to on Page Stone housing needs which need to be 43 (Communities with Developments provided, be they for the elderly special needs) Ltd or for the disabled or students. National Trust 13 3.1 "Create a Cleaner Environment" - Objection Detailed None This section lists what only considers landscapes in the the core strategy context of the green belt, AONB's must do. Whilst the and designated sites. Council as a matter of practise chooses to conserve and enhance locally important landscapes and countryside, it is not obliged to do so in the same sense as it is with the Green Belt and AONBs

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Representor P Para Comment Type Level Council’s Grounds Proposed Change Dr D Alexander 14 3.3 A footnote could be included Observation Detailed Insert footnote For information stating the forthcoming merger of referring to English Nature, The Countryside "Natural Agency and the Rural England" Development Service - Natural England would then cover all. Lancs County 14 3.3 Lancaster Vision Board is not part Objection Detailed Insert new For Information Council - of the LSP. paragraph on Locality Focus Vision Board Group for Lancaster Development 15 3.4 Should include a planned element Objection General None Extension Option Services of urban extension in conjunction considered in with urban concentration. No valid Sustainability reasons why this policy could not Appraisal be pursued - careful planning and landscaping would prevent urban sprawl. Government 15 3.4 - Would like to see the Preferred Objection Procedural Consult on To meet a key test of Office for the 3.7 Options document itself present Options soundness North West information on the 5 alternative Addendum options beyond that contained in these paragraphs, with more detail on the other 2 potential options so that consultees get a clearer picture of the effects Government 15 3.7 Would benefit from further Objection Procedural Consult on To meet a key test of Office for the expansion - justification for the Options soundness North West selection of urban concentration Addendum as the preferred option. Government 15 3.7 Do you propose to include in the Objection Procedural Consult on To meet a key test of Office for the submission document anything to Options soundness North West address this issue? Addendum

COMMENTS ON SPATIAL DEVELOPMENT STRATEGY SECTION Lancs County 16 4.1 The box "Spatial Vision for Objection Detailed None Because the Vision is Council - Lancaster District" is a duplication the starting point of Strategic of the box on page 10 and is not the strategy, it is Planning and necessary. worth re-iterating. Transport North West 16 4.1 Duplication of para 2.12 which is Objection Detailed None Because the Vision is Regional not necessary. the starting point of Assembly the strategy, it is worth re-iterating Dr D Alexander 16 4.2 Principle 4 underpins all other six Objection Structural Review For clarity principles, should be placed first Structure of or shown differently. Document English Nature 16 4.2 There should be no net loss of Objection Detailed Refer to wildlife For clarity wildlife habitats or species habitats in Part theough location of new 5 development. This can be avoided through careful design and planning for sustainable communities. English Nature 16 4.2 Safeguarding and Enhancement Objection Presentational Review For clarity of it's Environmental Capital Structure of should be in bold text Document Lancs County 16 4.2 Heysham not mentioned in this Objection Detailed Refer to For clarity Council - box, however, is listed in SDF "Morecambe Strategic Principle 1. Needs clarifying. and Heysham" Planning and in spatial vision Transport Lancs County 16 4.2 3) should read "….to contribute to Objection Typo amend to read Correction Council - the development of a …" "….to contribute Strategic to the Planning and development of Transport a …" National Trust 16 4.2 Based on the premise that the Objection General None Read in conjunction whole District needs regeneration with other objectives. - sustainable development in Regeneration Priority accordance with PPS1 is lacking. Areas identified later

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Representor P Para Comment Type Level Council’s Grounds Proposed Change National Trust 16 4.2 Excludes an "environmental" Objection General None Refers explicitly to dimension. sustainable development and environmental capital

COMMENTS ON SDF 1 – URBAN CONCENTRATION and associated text Development 18 4.5 Population would probably prefer Objection General None Market driven option Services planned development near the based on motorway motorway junctions 33, 34 and 35 junctions is rather than be surrounded by a considered at length concentrated build up of property through the which would be required to meet sustainability local needs - exception being appraisal process areas in need of regeneration. and found no favour with the public Development 18 4.5 A review should be made of the Objection General None Council's approach to Services fundamental objectives of a green Green Belt and belt, strategic gaps, open Countryside is countryside and urban open entirely aligned with space. It should balance RSS environmental policies on sustainability against pressing needs for housing and economic development. Development 18 4.5 Restrictive nature of this strategy Observation General None Observation Services exclusively would lead to over unsupported by inflated land values, increased evidence congestion, lack of outside investment as developers turn to more desirable prospects outside the area. E H Booth & Co 18 4.5 Consistent with PPS6 and socially Observation General None Supporting Ltd inclusive to enable people to shop Representation close to where they live. National Trust 18 4.5 The District's built heritage needs Observation General None Picked up in to be cherished for the benefits Environmental that it brings to Lancaster. Capital section Barratt 18 4.6 Urban concentration makes good Objection General None Issues considered in Manchester use of brownfield land and Sustainability reduces the need to travel but Appraisal would lead to town cramming and may place a strain on facilities and services. Dr D Alexander 19 4.6 Should show how specific figures Objection Detailed None Addendum document are arrived at, what would the makes scale of minimum figures have to be for it development in to be an urban concentration Carnforth clear strategy? Countryside 18 SDF 1 The Council should follow the Objection Detailed None No obvious conflict Properties Plc approach set out in PPS7 in with PPS7 - Council's considering policy for approach aligned with development outside of villages. RSS

Countryside 18 SDF 1 Suggested the guidance should Objection Detailed None Issue to be Properties Plc be provided as to what constitutes considered through "exceptional justification" for Development Control development outside the eight policies larger villages listed. English Nature 18 SDF 1 Recommend that some form of Observation Detailed Insert qualifying For clarity cross reference is made within text relating to the accompanying explanatory greenspace text to make the point that careful design and planning will be needed to prevent the risk of losing areas of green space and urban nature conservation sites.

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Representor P Para Comment Type Level Council’s Grounds Proposed Change English Nature 18 SDF 1 Strongly support preferred option, Observation Detailed Insert qualifying For clarity however, runs the risk of placing text relating to greater pressure on areas of greenspace urban green space and sites of urban nature conservation importance. Ref to TCPA (2004) document Biodiversity by Design - A Guide for Sustainable Communities Lancs County 18 SDF 1 Concerned that urban boundaries Objection General None Boundary lines drawn Council - will end up as a straight jacket for in allocations Locality Focus development, is it possible to document Group for make boundaries more fuzzy? Lancaster Lancs County 18 SDF 1 Proposals seem overly Objection Detailed Review list of For clarity Council - prescriptive in what constitutes an essential Locality Focus 'urban' area and what defines a facilities but Group for village where service provision underlined by Lancaster will be focused. The 5 key the principle that services in the structure plan are essential not appropriate for these services should purposes. be delivered locally and having regard to County Structure Plan targets Lancaster 18 SDF 1 Recommend that Sustainable Objection Structural Review For clarity District Development becomes Key Structure of Sustainability Principle 1. Document Partnership Lancaster Local 18 SDF 1 Would like further information on Observation Detailed None Detailed matter, Strategic how empty properties are inappropriate in Core Partnership factored into household growth Strategy - addressed calculations. in Housing Monitoring Report Lancaster Local 18 SDF 1 Would like the document to Observation General Yes Addressed in Strategic describe the considerations that Addendum document Partnership will influence how development will be distributed within the district's urban areas. Residential development could usefully be directed to morecambe to assist the regeneration process. Mason 18 SDF 1 Problems with urban Observation General None Addressed through Gillibrand concentration - precludes Sustainability Architects sensible exceptions in rural areas, Appraisal fails to see the district in the context of it's neighbours, does not take account of peoples employment patterns in terms of travel to work. Mason 18 SDF 1 No need to enshrine Urban Observation General None Addressed through Gillibrand Concentration in Spatial Policy. Sustainability Architects Appraisal Miller Homes 18 SDF 1 Guidance should be provided as Objection Detailed None Issue to be to what might consitute considered through "exceptional justification" for Development Control development outside the 8 larger policies villages. Miller Homes 18 SDF 1 Agree with proposed spatial Objection Detailed None No obvious conflict development framework, Council with PPS7 - Council's should follow approach set out in approach aligned with PPS7. RSS National 18 SDF 1 There is a need for affordable Objection General None Principle allows for Farmers Union rural housing for those wishing to affordable housing work in the countryside along with all associated services.

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Representor P Para Comment Type Level Council’s Grounds Proposed Change Sport England 18 SDF 1 The option does not provide an Observation General Yes Addressed in intra spatial element giving a Addendum document relative dimension within and between these named settlements. The Vision 18 SDF 1 Agree that most development Observation General None Addressed through Board should take place within urban Sustainability areas but concerned over Appraisal sustainablility of rural communities given past and continuing trends towards their becoming little more than commuter and retirement centres. The Vision 18 SDF 1 Workspaces need creating in our Observation Detailed None Strategy supports Board villages workspace in villages Lancaster 18 SDF 1 Question the knock on effect of Observation Detailed None Bailrigg Business District development at Bailrigg on other Park is a unique Sustainability rural settlements. proposal of regional Partnership significance Lancaster 18 SDF 1 The proposal for Bailrigg Objection Detailed None Existing allocation District Business Park is contradictory to and identified as Sustainability this principle. Suggest that the being of County and Partnership Business Park is located within Regional significance the boundaries of Lancaster & Morecambe with excellent public transport to campus. North West 18 SDF 1 Inconsistent with SD3 of the Objection General Yes Addendum document Regional adopted RSS.- Carnforth and makes scale of Assembly Lancaster/Morecambe are not of development in equal status Carnforth clear North West 18 SDF 1 Inconsistency between this and Objection Detailed Refer to For clarity Regional the "Guiding Principles and "Morecambe Assembly Spatial Vision" in para 4.1. (role of and Heysham" Heysham) in spatial vision G L Hearn and 19 SDF 1 Should add that derelict and Objection Detailed None Unnecessary - picked Partners - Lune under used land within urban up in employment Industrial Estate areas should be considered as a land allocations policy destination to accommodate some of the 95% of new employment floorspace that SDF Principle 1 seeks to accommodate within urban areas. E H Booth & Co 19 SDF 1 refers to 98% of retail floorspace Objection Detailed None Target reflects town Ltd being in Lancaster, this appears centre emphasis of high and may conflict with Key retail policy Principle 1. Lancs County 19 SDF 1 Should be made clear that Objection General Yes Addendum document Council - Carnforth, a key service centre makes scale of Strategic should accommodate development in Planning and proportionally less development Carnforth clear Transport than Lancaster and Morecambe. National Trust 19 SDF 1 Would be helpful for it to be made Observation Detailed Insert qualifying For clarity explicit that the level of text relating to development anticipated can be greenspace accommodated within the existing boundaries without the need for either urban extensions or the use of greenspaces. National Trust 19 SDF 1 Query the high proportion of new Observation Detailed None Makes allowance for economic and retail development farm shops, garden outside the urban areas that is centres, etc expected to take place in 'other rural' locations rather than within the large villages. The Vision 19 SDF 1 GP is a luxury in many villages - Objection Detailed In principle For clarity Board list should be extended to those essential with just the other 4 basic services should services. be delivered locally

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Representor P Para Comment Type Level Council’s Grounds Proposed Change The Vision 19 SDF 1 Concerned at the definition of the Objection Detailed Review list of For clarity Board types of villages which will be essential almost exclusively targeted in facilities but respect of new workspace and underlined by housing development. the principle that essential services should be delivered locally and having regard to County Structure Plan targets

COMMENTS ON SDF 2 – ECONOMIC GROWTH and associated text Lancaster 20 4.7 Needs to refer to high quality jobs Observation Detailed add "that meet Planning will not have District that meet the needs of local the needs of much influence on Sustainability communities local this. Economic vision Partnership communities" to prepared by Vision bullet 1 Board will be more influential National Trust 20 4.7 Bullet point 4: it is also necessary Observation Detailed None No Change - Picked to ensure the natural environment up under including valued landscapes are 'Environmental managed to maintain their quality, Capital' equally requires investment. Carnforth Town 20 SDF 2 Seems to be mismatch between Objection Detailed None Bailrigg Business Council existing permissions for Park is outside employment land and the target employment land for additional development in the targets. form of the bailrigg business park. Department for 20 SDF 2 Principle should be amended to Objection Detailed None City Centre already Constitutional state "Lancaster City Centre and has high resident Affairs fringes will develop as a major population. Key issue centre for shopping, leisure, is need to find culture, tourism, creative sustainable locations industries, financial, professional for lower value uses services and residential." Department for 20 SDF 2 By excluding mixed use Objection Detailed None The Strategy does Constitutional development the Council is not exclude mixed- Affairs disregarding policy in PPG3 use development. Housing - Local authorities should Balances on promote developments which individual sites will be combine a mix of land uses. assessed through the allocations document Department for 20 SDF 2 No mention of residential Objection Detailed None No evidence put Constitutional development in Lancaster City forward to support the Affairs Centre as a means of promoting contention that City economic growth. Centre housing will promote economic growth Dr D Alexander 20 SDF 2 Would be useful to have more Observation Detailed None Detailed matter - detail about the kinds of office address in local area development proposed. strategy G L Hearn and 20 SDF 2 Consider that this preferred option Objection Site Specific None Core Strategy cannot Partners - Lune should be improved by address site specific Industrial Estate encouraging the protection of key issues General employment areas and allowing for the expansion of the Lune Industrial Estate. Lancs County 20 SDF 2 Should refer to the infrastructure Objection Detailed None Picked up in Rural Council - required to support growth in rural Communities section Locality Focus businesses and tourism Group for Lancaster Lancs County 20 SDF 2 Needs to be more inclusive and Objection Detailed None Addressed in Council - reflect the needs of customers Customer Services Locality Focus across our society. section Group for Lancaster

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Representor P Para Comment Type Level Council’s Grounds Proposed Change Lancaster 20 SDF 2 Recommend that 'Economic Objection Detailed None Economic Growth is a District Growth' be replaced by 'Economic RSS objective Sustainability Development.' Partnership Lancaster Local 20 SDF 2 Would like the Council to be more Objection Detailed None Addressed in Strategic specific about what transport and Transport policy Partnership traffic management measures it wants to see implemented eg Park and Ride scheme for Lancaster Matthews and 20 SDF 2 Additional weight should be given Objection Detailed None Not appropriate in Goodman to the future potential for the Core Strategy continued growth of the "knowledge nucleus" and the manner in which any such growth could be physically accommodated. Matthews and 20 SDF 2 The importance of the University, Objection Detailed None Not appropriate in Goodman the Bailrigg Business Park and Core Strategy the "knowledge economy" should be given the appropriate weight in a more detailed analysis of potential development locations in the future. Lancs County 20 SDF 2 Don't understand how "thriving Objection Detailed None Addressed in EDZ Council - knowledge economy" benefits will Strategy Locality Focus extend significantly to the whole Group for of Lancaster. Lancaster Lancs County 20 SDF 2 Tourism should also appear on Objection Detailed None Addressed in Tourism Council - the list of economic growth areas policy Locality Focus Group for Lancaster Lancs County 20 SDF 2 Should be some Objection Detailed None Unclear how it is Council - acknowledgement that expected that this is Locality Focus employment opportunities should delivered through Group for be encouraged which are planning or spatial Lancaster appropriate for the skills of those planning already living in Morecambe. Lancs County 20 SDF 2 The potential to move freight Objection Detailed None Addressed in Council - should also be recognised employment land Strategic allocations policy Planning and Transport Lancaster Civic 20 SDF 2 Concerned that "easing the Objection Detailed None Addressed in Urban Society regulatory burden" should not Design policy come at the expense of good design. Lancaster 20 SDF 2 Emphasis should be placed on Objection Detailed None Little opportunity to District shortening supply chains and address this through Sustainability local food production for local planning but intention Partnership consumption wherever possible. addressed in Rural policy Lancaster 20 SDF 2 Bullet 2 - Should add at the end of Objection Detailed while retaining For clarity District the sentence "while retaining it's it's character Sustainability character and identity in terms of and identity. Partnership architecture, design, construction materials and strong presence of independent outlets." Lancaster 20 SDF 2 Bullet 3 - There may be need to Objection General None Little opportunity to District diversify Morecambe's economy address this through Sustainability further. planning but intention Partnership addressed in Rural policy Lidl UK GmbH - 20 SDF 2 Suggest that third bullet should be Objection Detailed None Regeneration in Property amended to: "MORECAMBE will Morecambe needs to Department refine and develop it's visitor and be focused on the retail offer, regenerate it's built Centre and West End heritage and develop it's role as an office centre".

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Representor P Para Comment Type Level Council’s Grounds Proposed Change Lancaster 20 SDF 2 Bullet 5 - Should refer to Objection Detailed None Addressed in District improved sustainable surface Transport policy Sustainability links to the Port of Heysham, in Partnership line with the Councils adoption of the sustainable transport hierarchy. National Trust 20 SDF 2 Bullet point 6: Could greatly be Observation Detailed Amend to read For clarity improved if the aspirations behind "managing 'managing landscape change' change to were made clear. maintain and enhance the quality of the landscape" Lancaster 20 SDF 2 Bullet 6 - Should refer to Objection Detailed None Addressed in District managing landscape change Environmental Sustainability sensitively, particularly with Capital policy Partnership regard to developing sustainable tourism and renewable energy. Lancaster 20 SDF 2 Bullet 7 - Needs to explicitly state Objection Detailed None Addressed in other District that the "clear, simple policies" parts of the Strategy Sustainability and "simplified planning Partnership permission" will be in conformity with the key principles of this strategy and with the principles of sustainable development. Lancaster 20 SDF 2 Do not consider targets Objection Detailed Review Targets For Soundness District appropriate. throughout Sustainability Partnership McCarthy & 20 SDF 2 Suggests that the Council Objection Detailed None Housing addressed Stone recognise the potential for new elsewhere Developments residential properties to add to the Ltd viability and vitality of local economies. North West 20 SDF 2 "Historic Towns and Cities in Observation Detailed None No Change Development Englands North West" that was requested Agency sent to Chief Exec Dec 2005 has yet to be considered by the Agency. North West 20 SDF 2 Should be strengthened by Observation Detailed None Clear from Spatial Development recognising the wider value of Vision Agency Lancaster's historic environment as a driver for economic growth North West 20 SDF 2 States that Caton Road and Observation Detailed None There does not Regional White Lund are identified as appear to be any Assembly business development zones - reason why local not recognised in adopted RSS Business Development Zones need to be identified in RSS

North West 20 SDF 2 Recommended that the Core Observation General Include Policy For completeness Regional Strategy is amended to include a on renewable Assembly policy that specifically relates to energy renewable energy to other appropriate locations The Vision 20 SDF 2 Worth noting in this section our Observation Detailed Include new For completeness Board views and targets in respect of job paragraph on growth and corresponding Vision Board population growth. The Vision 20 SDF 2 Doesn't touch upon the threat to Observation Detailed None Facts on future of Board the jobs at Heysham's power Heysham are too stations. unclear to be reliable

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Representor P Para Comment Type Level Council’s Grounds Proposed Change

COMMENTS ON SDF 3 – REGENERATION PRIORITY AREAS and associated text National Trust 21 4.8 Should specifically include access Objection General None Addressed in considerations, provision of Sustainability and footpaths, cycle routes and Transport policies bridleways should be addressed. National Trust 21 4.8 Should refer to the role of Objection Detailed Add "restoring For completeness heritage in regeneration - derelict and especially in urban areas, historic including the built environment. buildings" to bullet 1 Barratt 22 4.9 There are benefits to the Objection General None The Regeneration of Manchester regeneration options however, the Morecambe is a option singles out Morecambe regional priority. and Heysham rather than Regeneration in Lancaster or Carnforth. Lancaster and Carnforth can be tackled through the Urban Concentration option Dr D Alexander 21 4.9 The regeneration of Morecambe Supporting General None Supporting as a regional priority is fully Representation Representation supported. English Nature 21 SDF 3 Morecambe should be mentioned Objection Detailed Add "drawing on For completeness as having potential for being its natural and marketed as a natural heritage built heritage" resource for Green Tourism Development - should be referred to if the concept is still alive. G L Hearn and 21 SDF 3 Object to the non Objection Site Specific None Core Strategy cannot Partners - Lune designation/allocation of Lune address site specific Industrial Estate Industrial Estate and attached issues land for employment uses. Proposals for the mixed-use regeneration of Luneside East to be extended west should be extended further. Lancaster Local 21 SDF 3 Would like the Core Strategy to Objection General None Difficult to see the Strategic consider the social and economic relevance of this to Partnership implications of much rented Spatial Planning or property in Morecambe is now the scope of planning occupied by economically active to influence it. new arrivals to the UK Lancaster Local 21 SDF 3 Would like the Core Strategy to Objection Detailed None Difficult to see the Strategic consider the potential implications relevance of this to Partnership of increased second home Spatial Planning or ownership in Morecambe that the scope of planning may result following the resorts to influence it. continuing regeneration and improving confidence levels. Miller Homes 21 SDF 3 Supported - Recommend that the Objection Site Specific None Core Strategy cannot Leisure Park and Abattoir also be address site specific identified as a priority for issues regeneration through residential development.

National 21 SDF 3 There is a duty to ensure that Objection Detailed None Addressed in Farmers Union rural life is made accessible to all Transport policy with the regeneration and provision of improved public transport. Lancaster 21 SDF 3 Simply designating almost any Objection General None Statement District development as regeneration will unsupported by Sustainability weaken the essential case to be evidence Partnership made for the 4 pillars of regeneration set out in para 4.8

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Representor P Para Comment Type Level Council’s Grounds Proposed Change Lancaster 21 SDF 3 Morecambe needs to made a Objection General None Addressed in District place where people want to live Corporate Vision - Sustainability not just visit, work or invest in. Core Strategy does Partnership Socila regeneration should not not focus heavily on take second place to physical. social issues because they are not readily tackled through spatial planning Lancaster 21 SDF 3 Morecambe is the area most in Objection General Review Targets For Soundness District need of multiple regeneration and throughout Sustainability feel that at least one of the targets Partnership should address this directly. Lancaster 21 SDF 3 The Bailrigg Business Park does Observation Detailed None Bailrigg Business District not appear to contribute towards Park is a unique Sustainability any of these aspects of proposal of regional Partnership regeneration. Should be sited significance within existing urban boundaries to potentially contribute to all 4. North West 21 SDF 3 Question the statement that Objection General None Whilst Morecambe Development Morecambe will be reinvented as does need to develop Agency a visitor destination and suggest futures other than more emphasis on the need to tourism, it will retain a make Morecambe a nicer place to role as a day and live and work. short stay visitor draw and initiatives such as the Midland hotel and Tern project re- inforce this North West 21 SDF 3 Interested to know of any Objection General None Examined as part of Development research undertaken into the Economic Baseline Agency market demand for office Study for Vision development in Morecambe. Board. Likely that office role will be public sector led Dr D Alexander 22 SDF 3 Concerned about how far any Objection General None County Highway river crossing for Luneside is Authority has major dependent on current proposals concerns about for M6 Link. Would such a river further development crossing be necessary. in the Luneside area in the absence of infrastructure Countryside 22 SDF 3 Concerned that the Council are Objection General None County Highway Properties Plc seeking to sterilise redevelopment Authority has major in Luneside area until both the M6 concerns about Link and a Luneside river further development crossing are completed. in the Luneside area in the absence of infrastructure Countryside 22 SDF 3 Unreasonable to thwart the Objection General None County Highway Properties Plc redevelopment potential since Authority has major access to open up the Luneside concerns about site does not require a bridge. further development in the Luneside area in the absence of infrastructure G L Hearn and 22 SDF 3 Proposals for the mixed-use Objection Site Specific None Core Strategy cannot Partners - Lune regeneration of Luneside East to address site specific Industrial Estate be extended west should be issues extended further to include the designation for employment uses (B1,B2,B8) of the land adjacent to Luneside Industrial Estate. Lancs County 22 SDF 3 Would benefit from inclusion of Objection General Address in For completeness Council - "Communications Infrastructure". Transport policy Locality Focus Group for Lancaster

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Representor P Para Comment Type Level Council’s Grounds Proposed Change Lancs County 22 SDF 3 Would like the Core Strategy to Objection Detailed None Difficult to see the Council - consider the potential implications relevance of this to Locality Focus of increased second home Spatial Planning or Group for ownership in Morecambe that the scope of planning Lancaster may result following the resorts to influence it. continuing regeneration and improving confidence levels. Lancs County 22 SDF 3 Don't understand why Lancaster Objection Detailed Include For completeness Council - University is included as one of University Locality Focus the partners for this. Group for Lancaster Lancs County 22 SDF 3 The Northern Reaches of the Objection Detailed None Northern Reaches Council - Lancaster Canal have ben proposal is Strategic identified as a priority for re- considered in the Planning and instatement which will have section on Transport significant tourism potential for neighbouring the district. This should be authorities reflected in the text. Lancs County 22 SDF 3 The planning application for the Objection Detailed None County Highway Council - M6 Link and the related Regional Authority has major Strategic Funding Allocation submission do concerns about Planning and not make provision for a bridge to further development Transport Luneside. in the Luneside area in the absence of infrastructure North West 22 SDF 3 Appears to introduce additional Objection Detailed Differentiate For completeness Regional RPA's which are not identified in between Assembly adopted RSS - Luneside, Caton Regional Road, Lancaster City Centre and Regeneration Canal Corridor, Carnforth and Priorities and White Lund. Local Regeneration Priorities North West 22 SDF 3 Caton Road and White Lund are Observation Detailed None There does not Regional to be identified as Business appear to be any Assembly Development Zones. reason why local Business Development Zones need to be identified in RSS The Hurstwood 22 SDF 3 Could usefully make reference to Objection Detailed Additional text For completeness Group a specific timescale and the on Lune relevant Transport Plan. Crossing stating Additional para requested. where, when, who and how. The Hurstwood 22 SDF 3 In respect of Luneside (inc Ind Objection General None County Highway Group Est) regeneration benefits be Authority has major given priority over wider access concerns about issues. Word change requested. further development in the Luneside area in the absence of infrastructure The Hurstwood 22 SDF 3 Request word change confirming Objection Detailed None Matter for allocations Group both mixed use development and document exclusively B1/B2/B8 uses would be supported by the Council in principle. G L Hearn and 23 SDF 3 Proposals for the mixed-use Objection Site Specific None Core Strategy cannot Partners - Lune regeneration of Luneside East to address site specific Industrial Estate be extended west should be issues extended further to include the designation for employment uses (B1,B2,B8) of the land adjacent to Luneside Industrial Estate.

COMMENTS ON SDF 4 – SUSTAINABILITY and associated text Dr D Alexander 23 4.10 Wording used suggests that it Objection Structural None Structural Change - needs to come first as an all no difference to the embracing and cornerstone substance of the principle. document

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Representor P Para Comment Type Level Council’s Grounds Proposed Change E H Booth & Co 23 4.10 Would benefit from making the Objection Structural None LDDs should not Ltd link with this same point, as duplicate PPSs expressed in para 2.9 of PPS6 FPD Savills 23 4.10 Should be added that PPS6 para Objection Structural None LDDs should not 2.9 emphasizes that part of the duplicate PPSs Government's sustainability agenda means that people's everyday shopping needs are met at local level. National Trust 23 4.10 The weakness is confirmed in the Objection General Replace 'issues' For clarity Target which states that schemes with 'matters' must address all these issues - as set out these are not issues. National Trust 23 4.10 The Council needs to be Objection General None Negative objection - developing policies that will no positive change ensure all strands of sustainability suggested are advanced together - PPS1 para's 4,13. Lancaster 23 4.11 Bullet 2 - "Significant" should be Objection General None Small applications for District deleted. advertisements, Sustainability fences, small Partnership extensions, satellite dishes etc, will not raise sustainability issues and including them within this policy would detract from its credibility Government 23 4.12 Will have to provide specific Objection General None Unclear how this Office for the information including maps and/or relates to Paragraph North West diagrams to ensure that people 4.12 can understand the implications of their preferred options Dr D Alexander 24 4.12 Final bullet point should Objection Detailed Add reference to For clarity incorporate some reference to local landscape compatibility with local landscape character character National Trust 23 SDF 4 Should be strengthened by Objection General Replace'will For completeness replacing the words "will have have regard to regard to" with "will critically the following assess" or "will require". Needs to factors' with 'will clearly state what it will seek to apply the achieve. following criteria' Lancaster 23 SDF 4 Target word "major" should be Objection General None Small applications for District deleted or at least explained. advertisements, Sustainability fences, small Partnership extensions, satellite dishes etc, will not raise sustainability issues and including them within this policy would detract from its credibility Countryside 23 SDF 4 Welcome the inclusion of Supporting General None Supporting Properties Plc sustainable development Representation Representation principles in new and proposed developments. Development 23 SDF 4 Must be sustainable in every Objection General None Addressed through Services sense of the word, not just in Sustainability environmental and economical Appraisal terms, should recognise that some green belt and open countryside will be developed.

Development 23 SDF 4 Adequate provision must be Objection General None Unclear how this Services made for strategic transport links relates to Paragraph to facilitate the freedom of 4.12 movement of freight and personnel so the economy reamins strong and continues to be a competitive area and nation.

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Representor P Para Comment Type Level Council’s Grounds Proposed Change Environment 23 SDF 4 Fully supported Supporting General None Supporting Agency Representation Representation Miller Homes 23 SDF 4 Welcome the inclusion of Supporting General None Supporting sustainable development Representation Representation principles. The Leisure Park & Abattoir site performs well against the sustainable redevelopment criteria, should come forward as a priority. Lancaster 23 SDF 4 Tackling climate change should Objection General None All of the items listed District be an explicit high level policy contribute to tackling Sustainability within SDF 4 climate change Partnership Dr D Alexander 24 SDF 4 Final bullet point should Objection Detailed Add reference to For clarity incorporate some reference to local landscape compatibility with local landscape character character Countryside 24 SDF 4 Bullet 5 - Would also like to see Objection Detailed Add reference to For clarity Agency reference to the landscape local landscape character of the area. character English Nature 24 SDF 4 Under the Heading "Design" there Objection Detailed Add reference to For completeness needs to be a reference to the BAP objectives delivery of UK and :ancashire in targets BAP objectives and targets rather than just increased tree-cover and habitat creation. Lancs County 24 SDF 4 Other partners should be included Objection Detailed Review list of For completeness Council - in the 'implementation by' section. partners Locality Focus Group for Lancaster Lancs County 24 SDF 4 A policy encouraging renewable Objection Detailed None Address in Council - energy sources for existing as Development Control Locality Focus well as new buildings could help policies Group for alleviate some of the issues when Lancaster applying for permission to install renewable energy systems on existing buildings. Lancs County 24 SDF 4 Affordable housing needs to Objection Detailed None Address in Council - actually be affordable. Development Control Locality Focus policies Group for Lancaster Lancs County 24 SDF 4 Previous comments about access Observation Detailed None No change suggested Council - to services in rural areas also Locality Focus relate to this key principle. Group for Lancaster Lancs County 24 SDF 4 Under design there needs to be Objection Detailed Add reference to For completeness Council - more than an increase tree cover BAP objectives Strategic and habitat creation, needs to be in targets Planning and engagement with delivery of UK Transport and Lancs BAP objectives and targets. Lancs County 24 SDF 4 Nature conservation, archaeology Objection Detailed Add reference to For completeness Council - and built heritage should also treatment of Strategic come under the "design" heading. archaeology and Planning and tree cover to DC Transport section Lancaster and 24 SDF 4 Some 'knock on' design issues Objection Detailed Address in For completeness Westmorland which need to be considered. Design Code Society of Architects (LAWSA) Lancaster 24 SDF 4 Should include specific reference Objection General None All of the items listed District to climate change contribute to tackling Sustainability climate change Partnership

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Representor P Para Comment Type Level Council’s Grounds Proposed Change Lancaster 24 SDF 4 Point 4 should also make Objection Detailed None Addressed in Design District reference to total energy Bullet 2 Sustainability consumption/demand over the Partnership lifecycle of development Lancaster 24 SDF 4 Add 2 further points under design Objection Detailed None Address in District - "Meet or exceed Eco-Homes or Development Control Sustainability BREEAM 'very good' Standards" policies Partnership and "Coherence with the character of the locality". Lancaster 24 SDF 4 Point 2 under design should read Objection Detailed None Inappropriate in Core District "sustainable waste management Strategy - Address in Sustainability practices over the life cycle of the Design Code SPD Partnership development and…." Ref Oxford City Council SPD called Natural Resource Impact Assessment. Lancaster 24 SDF 4 Point 5 should include landscape Objection Detailed Add reference to For clarity District importance. local landscape Sustainability character Partnership Lancaster 24 SDF 4 Point 3 under location needs Objection Detailed None Addressed in Design District clarification. Bullet 3 Sustainability Partnership Lancaster 24 SDF 4 Should be strengthened so the Objection General Replace'will For completeness District Council do more than "have have regard to Sustainability regard for" the factors noted. the following Partnership factors' with 'will apply the following criteria' Lancaster 24 SDF 4 Should be policy SDF 1 Objection Structural None Structural Change District would make no Sustainability difference to the Partnership substance of the document Lancaster Local 24 SDF 4 Should address the issue of Objection Detailed None Inappropriate in Core Strategic improving functionality of cycle Strategy - Address in Partnership routes by enhancing the Design Code SPD permeablility of development through the addition of extra access points and links to join up existing routes. Lancaster Local 24 SDF 4 Should include consideration of Objection Detailed None Inappropriate in Core Strategic how readily a site can be Strategy - Address in Partnership accessed by car. Design Code SPD Lancaster Local 24 SDF 4 The Core Strategy should refer to Objection Detailed None Transport hierarchy Strategic the Transport Hierarchy no longer included in Partnership established through the Local replacement LTP Transport Plan process Mason 24 SDF 4 The re-use of existing buildings is Objection Detailed None Re-use of buildings Gillibrand barely mentioned, this is surely a mentioned in Architects sustainable objective. Location bullet 2 Matthews and 24 SDF 4 Should also accept the inter- Objection General None Objection too vague Goodman relationship between future for a meaningful economic growth, residential response development, community provision, recreation facilities and investment in public transport which could be promoted in the context of specific development proposals. McCarthy & 24 SDF 4 Many of the matters listed are Objection Detailed None Spatial Planning Stone subject to other regulatory involves looking Developments approval. Should recognise that beyond the regulatory Ltd the determinants of these matters framework of land- lies outside the control of the use planning Council. Mr P Robinson 24 SDF 4 By developing University IT Objection General None Addressed in cluster,1000 jobs will be accessed Sustainability by people north of the river Appraisal Development should be on Heysham peninsula.

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Representor P Para Comment Type Level Council’s Grounds Proposed Change

COMMENTS ON SDF 5 – ENVIRONMENTAL CAPITAL and associated text Dr D Alexander 25 4.14 Perhaps the word "threat" is too Objection Gen None Threat makes negative position abundantly clear Lancaster 25 4.14 Needs to clarify what it means by Objection General None Urban fringe is a well- District "Urban fringe areas need understood term Sustainability upgrading" Partnership Dr D Alexander 26 4.14 First point should include Objection Detailed Refer to local For completeness protecting local landscape landscape character and local biodiversity; character point 4 needs to convey the message that new developments are undertaken without environmental changes. Stronger monitoring and enforcement needed here. Environment 25 SDF 5 Fully supported Supporting General None Supporting Agency Representation Representation Mason 25 SDF 5 Should have a strategy relating to Objection Detailed None Re-use of buildings Gillibrand existing buildings and mentioned in Architects sustainability - Refer to PPS7 Location bullet 2 para 17. National Trust 25 SDF 5 The text and SDF Principle do not Objection Detailed None Do not accept this give due consideration to the settings of designated features of the natural and built environment. National Trust 25 SDF 5 The District's coast, landscape, Objection Detailed None The policy seeks to built heritage and biodiversity do exactly that in a need to be appreciated, protected fraction of the words and enhanced for the value they add to the populations quality of life, theraputic worth, attracting investment, tourism and jobs. National Trust 25 SDF 5 The means to achieve this is far Objection Detailed None Negative objection - too limited no positive measures suggested National Trust 25 SDF 5 The coast should feature in it's Objection Detailed None Unclear what own right in accordance with the substantive difference stated vision. this would make Countryside 26 SDF 5 Support bullet points 2 - 5 Supporting General None Supporting Agency particularly point 4. Representation Representation Countryside 26 SDF 5 Should not just refer to Objection Detailed Refer to local For completeness Agency "landscapes of national landscape importance' but should aim to character 'conserve and enhance the character and quality of all landscapes'. Countryside 26 SDF 5 The safeguarding and Supporting General None Supporting Properties Plc enhancement of environmental Representation Representation capital is supported. English Nature 26 SDF 5 No reference to Lancs's Objection Detailed Add reference to For completeness Biodiversity Action Plan targets BAP objectives and objectives for key habitats in targets and species. English Nature 26 SDF 5 Both PPS 9 and RPG 13 need to Objection Detailed Change protect For completeness be addressed within this to protect and statement, with some reference to enhance restoring ecological connectivity between wildlife habitats through the development of habitat linkages. Lancs County 26 SDF 5 Areas of international importance Objection General None Planning Policies for Council - for wildlife should be made more International sites set Locality Focus of in this section. out in PPS9 - should Group for not duplicate Lancaster

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Representor P Para Comment Type Level Council’s Grounds Proposed Change Lancs County 26 SDF 5 Lancs County Council should be Objection Detailed Add Lancs For completeness Council - included in the "implementation County Council Locality Focus by" section. to the Group for "implementation Lancaster by" section. Lancs County 26 SDF 5 Reference to climate change and Objection General Add new policy For completeness Council - flooding should appear in this on development Locality Focus section. and flooding Group for Lancaster Lancs County 26 SDF 5 Non-listed buildings are omitted, Objection Detailed Change 'listed For completeness Council - why? buildings' to Strategic Listed and Planning and Historic Transport Buildings Lancs County 26 SDF 5 No reference to biodiversity or the Objection Detailed Add reference to For completeness Council - delivery of UK and Lancs BAP objectives Strategic Biodiversity Action Plans targets in targets Planning and and objectives. Transport Lancs County 26 SDF 5 National guidance is looking for Objection Detailed Change protect For completeness Council - enhancement not just protection, to protect and Strategic this needs to be addressed along enhance Planning and with the lack of any mention of Transport restoring connectivity and develop habitat linkage. Lancs County 26 SDF 5 A reference specifically referring Objection Detailed Refer to local For completeness Council - to the character of the District landscape Strategic would be helpful. character Planning and Transport Lancs County 26 SDF 5 Should note that re-use of Objection Detailed None Unnecessary Council - existing buildings and sites can Strategic offer positive benefits to a Planning and development listing positive Transport examples such as the Midland and St Georges Quay. Lancs County 26 SDF 5 The phrase "landscapes of Objection Detailed None Phrase anticipates Council - national importance" suggests potential changes to Strategic that all landscapes have already AONB and National Planning and been assessed and graded which Park boundaries Transport is not the case. Lancs County 26 SDF 5 Redevelopment of important Objection Detailed Change 'listed For completeness Council - historical townscape features is buildings' to Strategic not mentioned, should be added Listed and Planning and into bullet one. Historic Transport Buildings Lancaster 26 SDF 5 Bullet 5 should read "Requiring Objection Detailed None Council cannot District the use of sustainable drainage 'require' use of Sustainability systems, materials and waste SUDS. SUDs is not Partnership management solutions, and the always appropriate or minimisation of construction practical waste and encouraging the creation of habitats, woodland planting and improved land management…" Lancaster 26 SDF 5 Should be noted that it is usually Objection Detailed None Existing habitat District preferable to protect existing protection is taken as Sustainability habitats than to create new ones, read and monitored Partnership should be reflected in the targets through the RSS process

Lancaster 26 SDF 5 Bullet 4 should read "Making sure Objection Detailed None In some areas, eg District that new development is of high low-cost employment Sustainability quality and complements or premises for small Partnership improves it's surroundings and is businesses, gypsy sensitively incorporated into sites and community existing townscapes and buildings, high cost, landscapes" high quality design may not be appropriate

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Representor P Para Comment Type Level Council’s Grounds Proposed Change Lancaster 26 SDF 5 Bullet point 1 should read Objection Detailed Refer to local For completeness District "Protecting and where landscape Sustainability appropriate enhancing nature character Partnership conservation sites, urban greenspaces, allotments, important landscapes, listed buildings, conservation areas, archaeological sites and areas of renewable energy potential" McCarthy & 26 SDF 5 Caution against any policy which Objection Detailed None Policy in line with Stone sought the retention of buildings RSS Developments that have outlived their useful life, Ltd subject to other policy caveats. Mr P Robinson 26 SDF 5 82% of all future development Objection General None Unsupported by focused on brownfield sites is evidence likely to reduce wildlife habitats in the urban areas. Mr P Robinson 26 SDF 5 This will put pressure on the built Objection General None Unsupported by environment while creating an evidence underutilisation of historical buildings in the rural areas. Mr P Robinson 26 SDF 5 If no development in rural areas Objection General None Unsupported by the logical outcome is stagnation evidence and eventual decline of village life and with it professionally managed and biodiverse land. The Vision 26 SDF 5 Also need to improve some of the Observation General None Picked up in Design Board entrances into urban centres, policy Morecambe in particular.

COMMENTS ON SDF 6 –TRANSPORT and associated text Dr D Alexander 27 4.15 Excellent points on the effects of Supporting General None Supporting traffic growth on sustainable Representation Representation communities. Dr D Alexander 27 4.15 Additonal point to be made about Supporting General None Not strategic issue increasingly undesirable effects of Representation vehicle parking on the environment including flood risk, biodiversity and the quality of urban greenspace. Lancaster 27 4.15 Transport also contributes very Observation General None Refers to air pollution District significantly to climate change. - climate change is Sustainability implicit in this Partnership Mr P Robinson 27 4.15 Road improvements do not Objection General None See SACTRA report alleviate congestion - statement is etc made without any corroborating evidence. Mr P Robinson 27 4.15 What evidence is there for the Objection General None See SACTRA report statement that new road etc improvements do not alleviate congestion. The Vision 27 4.15 Must not allow congestion to build Observation General None Picked up in Board back up to present levels once Transport Policy the link to Heysham and Morecambe has opened. The Hurstwood 27 4.15 Request additional information in Objection Detailed Additional text For completeness Group respect of timescales for the on Lune provision of links/improvements Crossing stating with ref to transport plan. where, when, who and how. Countryside 27 SDF 6 Would like to see specific mention Objection Detailed Mention quiet For completeness Agency of Quiet Lanes or Greenways lanes in rural added to this section. areas policy Countryside 27 SDF 6 Exercise caution in safeguarding Objection Detailed Additional text For completeness Properties Plc land for the Luneside Link road - on Lune no strategic backing or funding Crossing stating therefore it's future is uncertain. where, when, who and how.

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Representor P Para Comment Type Level Council’s Grounds Proposed Change Lancs County 27 SDF 6 What is the right amount of Objection Detailed None Address in DC Council - parking? policies Locality Focus Group for Lancaster Lancs County 27 SDF 6 Target around 400m of bus Objection Detailed None Lancaster- Council - service to Lancaster & Morecambe Train Locality Focus Morecambe would be more does not have 1/2 Group for flexible if it also included trains, hour frequency Lancaster urban areas, service frequency of 30 mins or more were removed. Lancs County 27 SDF 6 Need a Surface Access Strategy Objection Detailed None Heysham-M6 Link Council - for Heysham Port. Road well advanced Strategic Planning and Transport Lancs County 27 SDF 6 Relating Cycle Networks to the Objection Detailed Mention Cycle For completeness Council - National Cycle City Project needs city and Strategic to be addressed. sustrans Planning and Transport Lancs County 27 SDF 6 The need for an integrated Objection General Refer to AQMP For completeness Council - transport strategy for City Centre Strategic that integrates with Air Quality Planning and Strategy needs to be addressed. Transport Lancs County 27 SDF 6 Development generating a large Objection Detailed None Address in DC Council - number of trips and major policies Strategic development require definition. Planning and Transport Lancs County 27 SDF 6 Parking levels should be in line Objection Detailed None Address in DC Council - with JLSP standards policies Strategic Planning and Transport Lancs County 27 SDF 6 Luneside Bridge is not currently in Objection Detailed Additional text For completeness Council - the Heysham-M6 Link proposals. on Lune Strategic Crossing stating Planning and where, when, Transport who and how. Lancs County 27 SDF 6 LTP2 target for cycling relate Objection Detailed Review all For soundness Council - more to outcomes rather than targets Strategic outputs. Planning and Transport Lancaster 27 SDF 6 Note that the Council has adopted Objection Detailed None Transport Hierarchy District the sustainable transport has been deleted Sustainability hierarchy and explain what that from replacement Partnership means. Local Transport Plan Lancaster 27 SDF 6 Bullet point one should read Objection Detailed None Jargon heavy District "Focusing development in areas Sustainability which provide the most Partnership sustainable transport options/perform best against the transport hierarchy." Lancaster 27 SDF 6 Add to point 3, to clarify " Objection Detailed None Picked up in detailed District Establishing pedestrian and cycle transport policy Sustainability networks and for leisure use and Partnership to access workplaces, services and amenities, creating new links and removing barriers. Lancaster 27 SDF 6 Alter bullet 4 to read "Ensuring Objection Detailed None Jargon heavy District that new development prioritises Sustainability pedestrian, cycle and public Partnership transport access and provides for improvements to pedestrian and cycle networks" in order to comply with the transport hierarchy.

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Representor P Para Comment Type Level Council’s Grounds Proposed Change Lancaster 27 SDF 6 Alter bullet 5 to read Objection Detailed None Adds nothing of District "Safeguarding land for strategic substance Sustainability transport movements, bearing in Partnership mind the need to reduce travel by car and freight transport by road, encourage and facilitate other forms of transport and reduce greenhouse gas emissions" Lancaster Local 27 SDF 6 Would like the Core Strategy to Objection Detailed None Not an issue for the Strategic consider the case for developing Core Strategy - Partnership a new purpose designed public pursue through entertainment venue/conference Cultural Strategy facility in Morecambe that would feature greater audience capacity than offered by the existing Platform and Dome venues. Lancaster Local 27 SDF 6 Concerned that culture related Objection Detailed None Not an issue for the Strategic development should occur in Core Strategy - Partnership Morecambe/Heysham as well as pursue through in Lancaster. Cultural Strategy Mr P Robinson 27 SDF 6 Commercial development south Objection General None Unsupported by of the river Lune is likely to evidence increase the need to travel greater distances to work. Need to improve public transport and reduce the cost. National Trust 27 SDF 6 Only specific projects are road Objection General None Non-land-use based based schemes - should see a public transport range of public transport initiatives are picked initiatives. up in the Local Transport Plan National Trust 27 SDF 6 Introductory text should make a Objection General None This would add direct link to climate change nothing of substance impacts and the contribution to the Core Strategy made by transport. National Trust 27 SDF 6 Why is there not a specific Objection General None Objection unclear question about this?

COMMENTS ON SDF 7 – RURAL AREAS and associated text Mr S Booth 28 4.17 Concerned about University Objection General None University is key expansion. economic driver. Parameters of growth to be set by allocations document The Vision 28 4.17 Need to be more ambitious than Objection General None It is not explained Board purely encouraging home-working how it is expected - ensure there is local workspace. that such workspace be provided Dr D Alexander 28 4.18 Point about Parish Councils is Supporting Detailed None Supporting well made and fully supported. Representation Representation Dr D Alexander 28 4.18 SDF Principle 7 could make a Observation Detailed None Addressed in detailed specific reference to Parish Plans rural policies in the policy itself. Mr S Booth 28 4.18 Take note results of Ellel Parish Objection General None No change suggested Plan - 64.61% response rate. Countryside 28 SDF 7 Does not seek to conserve or Objection Detailed Refer to local For completeness Agency enhance the distinctive landscape characteristics of the rural character landscape. Countryside 28 SDF 7 No definition of what "important" Objection Detailed Refer to local For completeness Agency means in bullet point 1 - landscape concerned about ALL rural character landscapes. FPD Savills 28 SDF 7 By imposing development Objection Detailed Adjust ratio For completeness restrictions in rural villages in between large terms of housing and economy, villages and rest rural economic and social growth of rural area will be hindered.

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Representor P Para Comment Type Level Council’s Grounds Proposed Change Lancs County 28 SDF 7 Concerned to make sure that Objection Detailed Adjust ratio For completeness Council - rural areas aren't further between large Locality Focus disadvantaged in terms of their villages and rest Group for access to services and of rural area Lancaster employment. Mr S Booth 28 SDF 7 There should be no further Objection General None Plan already seeks to expansion in Scotforth or Hala, focus development greenfield at Bailrigg should be on existing urban protected from development, areas fields at southern edge of campus should be protected, no further developments of the roads south of Lancaster. Mr S Booth 28 SDF 7 Concerned about flooding from Objection Detailed Addressed in For completeness Whitley and Ou Beck. Document sustainability should take the threat of flooding policy following new developments into account National 28 SDF 7 Important that the Core Strategy Objection General None Unclear what Farmers Union helps meet rural needs, with the changes are being changes taking place in the sought industry, when planning applications are sought. English Nature 28 SDF 7 Should add on that it is socially Objection Detailed None Rural deprivation unacceptable to see the decline already addressed and deprivation of populations within rural communities under bullet point 4. English Nature 28 SDF 7 Not adverse to small Objection Detailed Adjust ratio For completeness developments in the countryside between large where rural family businesses villages and rest would be able to benefit from rural of rural area tourism or food production. Lancs County 28 SDF 7 Lancs County Council should also Objection Detailed Include Lancs For completeness Council - be included in the "implemented County Council Locality Focus by" section. in list of partners Group for Lancaster Lancs County 28 SDF 7 Bridal ways should also get some Objection Detailed Include mention For completeness Council - mention in this section. of bridleways Locality Focus Group for Lancaster Lancs County 28 SDF 7 Opportunities for small business Objection Detailed Adjust ratio For completeness Council - units in the more sparsely between large Locality Focus populated rural areas should be villages and rest Group for included. of rural area Lancaster Lancs County 28 SDF 7 Concerned that proposals are not Objection Detailed Adjust ratio For completeness Council - sufficiently flexible to meet the between large Locality Focus needs of rural communities for villages and rest Group for employment and housing. of rural area Lancaster Lancs County 28 SDF 7 The Rights of Way Improvement Objection Detailed Include mention For completeness Council - Plan should be mentioned under of Rights of Way Strategic "means" improvement Planning and plan Transport Lancs County 28 SDF 7 Would be beneficial to mention Objection Detailed Mention quiet For completeness Council - Quiet Lanes/Greenways and lanes in rural Strategic Bridleways in the final bullet as areas policy Planning and these have a major contribution. Transport Lancaster 28 SDF 7 Suggest replacing bullet 4 with Objection Detailed None Unclear what this District "Supporting sustainable adds Sustainability agriculture and environmentally Partnership sensitive land management, including sympathetic agricultural diversification and sustainable rural tourism”

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Representor P Para Comment Type Level Council’s Grounds Proposed Change Lancaster 28 SDF 7 Would be helpful to make explicit Objection Detailed None Detailed issue for District reference to priority for housing consideration in Sustainability outside urban areas going to Parish Plans Partnership affordable housing for people with local connections. Lancaster Local 28 SDF 7 Would like the Council to consider Objection Detailed Review For soundness Strategic if there is justification for Settlement list Partnership expanding the list of 8 rural and services settlements, development in other well-chosen rural settlements could support existing services.

COMMENTS ON POLICY ER1 – HIGHER EDUCATION and associated text Green Group 29 5.3 Energy services and renewable Objection General Add policy on For soundness energy should be added to the list renewable of areas with growth potential. energy Lancs County 29 5.3 "Higher Education has majore Objection Typo Delete second Correction Council - growth potential" and "other areas reference to Strategic with growth potential are higher Higher Planning and education" needs clarifying. Education Transport Development 29 Chapt Economic growth as seen in East Objection General None Unsupported by Services er 5 Lancs, Preston etc would not be evidence possible if the proposed strategy was adopted. Dr D Alexander 30 5.5 Evidence needs to be provided Objection General None Employment land with regard to the take up of study in preparation employment land. Lancs County 30 5.5 Final paragraph is incomplete. Objection Typo Add 'may be For completeness Council - deterred from Strategic locating on the Planning and Morecambe/Hey Transport sham peninsula Mr P Robinson 30 5.5 The probable impact on the Objection General None No change suggested housing market is likely to increase the pressure of affordability. Carnforth Town 30 5.6 Should be extra detail in the Objection General None Employment land Council information available on study in preparation employment land supply so as to show clearly the extent of land for which planning permission has been given but where development has not started. Dr D Alexander 30 5.6 The priority should now be one of Objection General None Employment land improving the quality of the "very study in preparation large supply of land allocated for employment use and vacant land within extant employment areas" National Trust 30 5.6 Unclear what the Councils Objection General None No change suggested strategy is for contaminated/derelict land. Dr D Alexander 31 5.7 Could see some evidence of the Observation General None No change suggested impact of concentrating new student accommodation on campus, with the 'village' that has now been constructed. Green Group 31 5.7 Object to the phrase "it is in the Observation General None Economic Baseline interests of the local and regional Study identifies economy that the university University as the key continues to grow" Further growth economic driver in would not necessarily be a good the District thing. Mr P Robinson 31 5.7 What evidence is there that Observation General None The increasing Lancaster University is increasing numbers of students student numbers. at Lancaster University

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Representor P Para Comment Type Level Council’s Grounds Proposed Change Green Group 31 ER1 Pleased to see recognition of the Supporting Detailed None Supporting traffic problems caused by the Representation Representation university and that this policy supports expansion only within the existing built up part of the campus. Lancs County 31 ER1 The recognition of the importance Supporting Detailed None Supporting Council - of enhancing transport links and Representation Representation Strategic the role of travel plans is Planning and supported. Transport Lancaster 31 ER1 Include "walking and cycling" after Objection Detailed Add "cycling and For completeness District public transport in bullet 5. walking links to Sustainability the institution Partnership they are supposed to serve Lancaster 31 ER1 Change bullet point 2 to read Observation Detailed None Bailrigg Business District "Develop a business park in an Park is a unique Sustainability urban setting with close functional proposal of regional Partnership links to the University as a high significance quality sustainable location for knowledge based industries" National Trust 31 ER1 Reasonable for the Spatial Observation Detailed None Not strategic issue Strategy and the Travel Plans to go beyond standard initiatives such as encouraging car sharing to more substantial matters such as the provision of new cycle/pedestrian routes and new bus facilities. COMMENTS ON POLICY ER2 – EMPLOYMENT LAND ALLOCATIONS and associated text Barratt 32 5.8 Employment sites to be on Observation Detailed None No change Manchester previously developed land - no suggested information to the contrary, current employment is also likely to be a source of land for future residential development. Carnforth Town 32 5.8 Essential that known constraints Observation Detailed None No change Council do not lead to 'cherry picking' of suggested better/less constrained areas for development. Dr D Alexander 32 5.8 A thorough employment land Supporting Detailed None Supporting study is supported and should be Representation Representation focused on the range of employment types that form the vision for the district. Lancaster 32 5.9 Should end with the words "and Objection Detailed None Unclear what District on the wider environment" this relates to Sustainability Partnership G L Hearn and 32 ER2 Insist that the Lune Industrial Objection Site Specific None Core Strategy Partners - Lune Estate is designated as cannot address Industrial Estate Employment Land. site specific issues Lancs County 32 ER2 Essential that "realistic choice of Objection Detailed None Not a strategic Council - public transport" is defined and issue Strategic means for measuring it identified. Planning and Transport Lancs County 32 ER2 Carnforth should accommodate Objection Detailed Addressed in For Council - less development than Lancaster addendum completeness Strategic and Morecambe. Scale of document Planning and development should be Transport appropriate for the size of the town.

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Representor P Para Comment Type Level Council’s Grounds Proposed Change Lancaster 32 ER2 Alter bullet 6 to read "Be Objection Detailed None Insistance on District connected to the strategic employment Sustainability transport network, especially the sites with rail Partnership West Coast Mainland and Inland and canal Waterways" connections would generate industrial sites in unsustainable rural locations McCarthy & 32 ER2 Advice of PPG 3 paragraph 42A Objection Detailed None No conflict with Stone should be considered. PPG3 Developments Ltd Mr P Robinson 32 ER2 Brownfield sites North of the river Observation General None No change Lune will see competition suggested between commercial and residential developers. Mr P Robinson 32 ER2 Major employment sites appear to Observation General None No change be south of the river Lune, yet if suggested there is to be no early construction of the M6 Link then the lack of a bridge over the Lune to Luneside makes further development unsustainable. North West 32 ER2 Provides more detail than Observation General None Policy is in line Regional required by adopted RSS. with ODPM Assembly guidance on employment land reviews North West 32 ER2 Carnforth should accommodate Objection Detailed Addressed in For Regional less development than the urban addendum completeness Assembly area of Lancaster and document Morecambe. Inconsistent with SD3 of adopted RSS.

COMMENTS ON POLICY ER2 – EXISTING EMPLOYMENT AREAS and associated text

Lancs County 33 5.13 Appears to be missing text. Objection Detailed Add 'is imperative Correction Council - Strategic Planning and Transport Lancaster 33 5.13 Appears to be missing text. Objection Detailed Add 'is imperative Correction District Sustainability Partnership Mr P Robinson 33 5.14 How viable is Luneside without a Objection Detailed Additional text on Lune For soundness new bridge over the Lune Crossing stating where, when, who and how. Countryside 33 5.14 Luneside West area would benefit Objection Detailed None Matter for Properties Plc from some local restructuring of allocations land use distribution document Lancs County 33 5.14 Luneside Bridge is not currently in Objection Detailed Additional text on Lune For soundness Council - Heysham M6 link proposals. Crossing stating Strategic where, when, who and Planning and how. Transport The Hurstwood 33 5.14 Request word change to: the Objection Detailed Additional text on Lune For soundness Group Heysham M6 Link Road and a Crossing stating link bridge across the Lune will where, when, who and give the Luneside area increased how. importance allowing alternative and additional HGV access and the provision of further and additional transport cycle links.

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Representor P Para Comment Type Level Council’s Grounds Proposed Change Lancs County 33 5.15 South Heysham should be linked Objection Detailed None Addressed in Council - to a broader Surface Access Transport Strategic Strategy for Heysham Port. policy Planning and Transport Lancaster 33 5.16 Reference should be made to rail Objection Detailed None Proposals must District infrastructure improvements be deliverable Sustainability rather than the Heysham M6 Link. to be Partnership considered sound Mr P Robinson 33 5.16 If Heysham South is such an Observation General None No change unattractive location why was it suggested included in the EDZ Programme? Dr D Alexander 35 5.17 What are the broad relocation Observation General None Not an issue of options, what are the implecations District for the existing site. significance Mr P Robinson 35 5.17 What evidence is there that a) Objection Detailed Additional text on Lune For soundness there will eventually be a new Crossing stating bridge over the Lune [with or where, when, who and wiothout an M6 Link Road] and b) how. that such a scenario will be developed by 2016. Barratt 35 ER3 Fails to consider the approach Objection General None Employment Manchester which will be taken where land study in proposals are made for residential preparation or mixed-use schemes on sites currently in employment use. Countryside 35 ER3 No commitment to Luneside river Objection Detailed Additional text on Lune For soundness Properties Plc crossing, why stipulate Crossing stating development will not occur until where, when, who and these road schemes are how. completed? Countryside 35 ER3 Strategy is overly prescriptive and Objection Detailed Additional text on Lune For soundness Properties Plc onerous in terms of timescales for Crossing stating development. where, when, who and how. G L Hearn and 35 ER3 Object to the failure to include Objection Site Specific None Core Strategy Partners - Lune Lune Industrial Estate as an cannot address Industrial Estate employment land allocation. site specific Should add that the regeneration issues of Luneside West should include Lune Industrial Estate. Lancs County 35 ER3 Not clear from the text on Caton Objection Detailed refer to heavy goods For clarity Council - Road whether it is goods vehicle Strategic movements that is referred to or Planning and high levels of traffic generation. Transport Lancs County 35 ER3 No commitment to Luneside river Objection Detailed Additional text on Lune For soundness Council - crossing, why stipulate Crossing stating Strategic development will not occur until where, when, who and Planning and these road schemes are how. Transport completed? National Trust 35 ER3 Emphasis predominantly on road Objection Detailed None Incorrect access. Consideration needs to interpretation be given to accessibility for the potential workforce end especially for those who do not have a car. National Trust 35 ER3 Unclear whether the anticipated Objection Detailed None Objection development is to be unclear accommodated within the existing area allocated for industrial use or in the wider area. The Hurstwood 35 ER3 Request "B8 uses will not be Objection Detailed None Highway Group permitted until access issues are Authority has resolved" amended to "In respect major concerns of B8 uses the Council will about further continue to determine each development in application on it's merits and will the Luneside seek to examine the impact of area in the each proposal on the local absence of highway net infrastructure

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Representor P Para Comment Type Level Council’s Grounds Proposed Change

COMMENTS ON POLICY ER4 –RETAIL HIERARCHY and associated text

E H Booth & Co 36 5.18 Need to acknowledge the Observation Detailed None Policy follows Ltd requirement to bolster local PPS6 shopping facilities in order to approach reduce the need to travel for everyday goods. E H Booth & Co 36 5.18 Appears to have been written Objection General None No significant Ltd without up-to-date empirical data change and WYG Lancaster Retail Study. required in Assertations on shopping patterns response to may need reviewing. WYG FPD Savills 36 5.18 Appears to have been written Objection General None No significant without up to date impirical data change and WYG Retail Study. required in response to WYG Mr P Robinson 38 5.25 Park & Ride is not realistic Objection General None Relevance objective, has been in the LTP unclear since 1991 and sites on Caton Road now earmarked for employment which will be safeguarded under the LDF. E H Booth & Co 36 ER4 Clarification is needed over what Objection Detailed Delete small local Recommended Ltd is meant by Scotforth Road, the centres by WYG report Scotforth Road Local Centre would be better described as Scotforth Road/Hala Road E H Booth & Co 36 ER4 Need to consider a more Observation Detailed None Policy follows Ltd equitable distribution of food PPS6 shopping in the City. approach FPD Savills 36 ER4 Fails to acknowledge the potential Observation Detailed None Policy follows requirement to bolster local PPS6 shopping facilities in order to approach reduce the need to travel for everyday goods. Does not grapple with para 2.9 of PPS6 regarding local shopping hierarchies. E H Booth & Co 38 Questioning whether the Objection General None Supported by Ltd ER4 University is a sustainable WYG report location given the distance from the urban area - Areas south of Burrow Beck are out-of-town. Lancs County 38 Supported - helps deliver high Supporting Detailed None Supporting Council - ER4 accessibility. Representation Representation Strategic Planning and Transport Lancaster 38 Supporting text should refer to the Objection Detailed None Council has no District ER4 need to reserve some low-rent control over Sustainability space in Lancaster City Centre for private sector Partnership independent retailers in order to rentals maintain it's character and identity Lancaster 38 Targets should include "No loss of Objection Detailed None Can't define District ER4 village shops or associated fresh healthy Sustainability facilities" and "% of population food or enforce Partnership within easy walking distance of what shops sell shop selling fresh healthy food" Lidl UK GmbH - 38 Request that the wording of this Observation Detailed None Policy follows Property ER4 policy is amended to make PPS6 Department reference to the suitability of retail approach of an appropriate scale to allow local needs to be met at the local level in line with advice contained with PPS 6. Lidl UK GmbH - 38 Insertion of additional wording at Observation Detailed None Policy follows Property ER4 the end of 4th bullet: "including PPS6 Department retail development of an approach appropriate scale".

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Representor P Para Comment Type Level Council’s Grounds Proposed Change McCarthy & 38 Should be re-drafted to include Observation Detailed None Not strategic Stone ER4 reference to the contribution that issue Developments residential scheme, whether stand Ltd alone or as part of a mixed use development, can deliver to existing town centres. Should be cross referred with Policy HS3.

COMMENTS ON POLICY ER5 – NEW RETAIL DEVELOPMENT and associated text FPD Savills 39 The policy should adhere to Observation Detailed None No conflict with ER5 PPS6. PPS6 FPD Savills 39 Consideration should be given to Observation Detailed None No conflict with ER5 imposing a 'floorspace ceiling' for PPS7 various types of centres/areas of deficiency, based upon a clear assessment of future capacity. FPD Savills 39 The notion that food retail Observation Detailed None No conflict with ER5 development should be focused in PPS8 town centres may conflict with the parallel policy of ensuring areas of deficiency are addressed. FPD Savills 39 The setting of town centre and Observation Detailed None No conflict with ER5 edge of centre floorspace targets PPS9 will predetermine development patterns. FPD Savills 39 The provisions of this draft policy Observation Detailed None No conflict with ER5 conflict with advice in PPS6 PPS10 Lancaster 39 Should include local, healthy food Observation Detailed Mention need to Cannot dictate District ER5 retailing as a priority and should foster independent to property Sustainability include a target amount or % of sector in text owners who Partnership floorspace to be reserved as they let to but independent local business. can promote independent retailing through BIDs etc Lidl UK GmbH - 39 Additional text should make Observation Detailed None No conflict with Property ER5 reference to locations which serve PPS10 Department the needs of deprived areas and an allowance for sites which include significant material considerations such as physical regeneration, employment, economic growth and social inclusion. Lidl UK GmbH - 39 Wording is out of kilter with advice Observation Detailed None No conflict with Property ER5 contained within PPS6 - 'Town PPS11 Department Centres' Should be amended to detail that retail development should be focused in existing centres in order to strengthen & regenerate them. 39 The policy pre-empts the Observation Detailed None No conflict with Lidl UK GmbH - ER5 allocation of sites in the Local PPS12 Property Development Framework which is Department an issue for future determination.

COMMENTS ON POLICY ER6 – DEVELOPING TOURISM and associated text Lancs County 40 5.29 The Rights of Way Improvement Objection Detailed Identify Rights of For Council - Plan should be identified in the Way Improvement completeness Strategic final bullet. Plan in final bullet. Planning and Transport Lancaster 40 5.29 Bullet one should refer to Objection Detailed None Matter of Fact District improved public transport links, Sustainability especially via the West Coast Partnership Mainline or proposed high-speed link rather than heysham M6 Link.

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Representor P Para Comment Type Level Council’s Grounds Proposed Change Countryside 41 Support the part that seeks to Supporting Detailed None Supporting Agency ER6 encourage opportunities for quiet Representation Representation recreation, new walking and cycling routes in the District's countryside. Department for 41 Greater consideration should be Objection Detailed None Detail Constitutional ER6 given in the supporting text as to inappropriate in Affairs how the historic environment Core Strategy including the Castle will be used to enhance the city. English Nature 41 Should recognise the value of Objection Detailed None addressed in ER6 Lancaster District's Natural 5.29 Bullet 4 (Biological and Geological) and Historic Heritage in the widest terms of tourism Green Group 41 No strategic thought on the Objection Detailed None Detail ER6 development potential of the inappropriate in Lancaster Canal, no clear Core Strategy policies. Should include policy on tourism potential, canalside development, residential moorings. Lancs County 41 Suggested that paragraph be Objection Detailed None Too much Council - ER6 expanded to " the Castle and it's unnecessary Strategic environs" as this would include wording Planning and the Priory Church, Vicarage Transport Fields, Roman Bathhouse and the Wery Wall as well as St Georges Quay and the Maritime Museum. Lancaster 41 3rd para replace "creating" with Objection Detailed Replace 'creating' For clarity District ER6 "Maintaining and enhancing" and with 'maintaining Sustainability at the end of the sentence replace and enhancing' Partnership "enhance the city" with "maintain and enhance the character of the city" Lancaster 41 Headline should refer to Objection Detailed Retitle policy For clarity District ER6 sustainable tourism 'Developing Sustainability Sustainable Partnership Tourism' National Trust 41 Should make specific reference to Objection Detailed None Addressed ER6 the potential related to a) the adequately in AONB's and b) the coast as reasoned identified in the supporting text. justification North West 41 The Core Strategy could usefully Objection Detailed None Not clear how Development ER6 address the issue of reducing the this relates to Agency impact of the A6 Loop as part of tourism Policy CE2. North West 41 Suggest that the Castle Quarter Objection Detailed None Not a Core Development ER6 and St Georges Quay could be Strategy Issue Agency explicitly identified as priority locations for developing COMMENTS ON POLICY HS1 – MEETING THE DISTRICT’S HOUSING REQUIREMENTS and associated text Department for 42 6.2 In order to address the priority to Objection Detailed None The Strategy Constitutional minimise expansion of the urban already does this Affairs area the Core Strategy must clearly promote opprtunities to maximise the use of sites within urban areas, either through conversion or redevelopment. Dr D Alexander 42 6.2 Little evidence to suggest that Observation Detailed None No change population retention in rural areas suggested will automatically support the retention of existing local services.

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Representor P Para Comment Type Level Council’s Grounds Proposed Change Dr D Alexander 42 6.2 Need to be more specific about Observation Detailed None Disagree - better 'other employment requiring a to place the rural location' onus on the proposal to demonstrate need Lancaster 42 6.2 Add bullet " Encourage the Observation Detailed Entitle section For Clarity District development of mixed-tenancy Balanced Sustainability areas, including market owned Communities Partnership and rented, intermediate and social rented housing" Lancs County 43 6.2 Communities with Special Needs - Observation Detailed None Judgemental to Council - 'Frail' might be a more appropriate assume elderly Locality Focus word than 'elderly'. people to be frail Group for - non-frail elderly Lancaster may also have distinct needs Countryside 44 6.3 Sufficient land should be identified Observation Detailed None Matter for Properties Plc to meet the RSS housing land allocations requirement for Lancaster up to document 2021 therefore sites which meet the sequential test set out in PPG3 should be allocated for residential use in the LDF Lancaster 44 6.3 If the lower requirement of 380 Observation Detailed None Strategy must be District houses was successful in compatable with Sustainability directing investment into the RSS Partnership regeneration of Morecambe, it may be sensible to retain this lower figure. Mr P Robinson 44 6.3 Contradicts the 'edict' from the Observation Detailed None No change ODPM in 2003 in order to aid suggested areas of low demand housing in the North West Countryside 44 6.4 The Council will need to identify Observation Detailed None Matter for Properties Plc additional land that is capable of allocations being developed for housing. document Countryside 44 6.4 Should there be insufficient Observation Detailed None Matter for Properties Plc capacity in the urban area to meet allocations the RSS requirement up to 2021 document the Council should identify additional sites following the search sequence set out in PPG3. Countryside 44 6.5 In managing the release of sites Observation Detailed None Matter for Properties Plc for residential development the allocations LDF should adopt the phasing document approach set out in the companion guide to PPG3 'The Managed Release of Housing Sites: Towards Better Practice'. Countryside 44 6.5 Housing figures alone should not Observation Detailed None Matter for Properties Plc be used to suppress regeneration allocations of large sites that could have a document positive benefit on the locality within which they are located. Barratt 44 6.6 Need to take into account Observation Detailed None Matter for Manchester guidance in emerging PPS3 and development changes to the GeneralPermitted control Development Order with regard to document the information to accompany valid planning application. Department for 44 6.6 This paragraph places an onerous Observation Detailed None Matter for Constitutional requirement on developers and allocations Affairs does not comply with national document planning policy. Should be removed from supporting text. Dr D Alexander 44 6.6 Sentiments set out on housing Supporting Detailed None Supporting requirements strongly supported, Representation Representation given the supporting evidence you have available for housing needs.

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Representor P Para Comment Type Level Council’s Grounds Proposed Change Lancaster 44 6.6 Add " maximise the use of Objection Detailed None addressed in District environmentally friendly, locally Sustainable Sustainability sourced and recycled construction Development Partnership materials and minimise waste" policy McCarthy & 44 6.6 Welcomes the Council's desire to Supporting Detailed None Supporting Stone permit housing that meets local Representation Representation Developments needs subject to carrying out up Ltd to date assessments of such need across all tenures and types of housing both within the social and private sectors. Russell Armer 44 6.6 Seems to imply that there will be Objection Detailed None No change Ltd many additional costs required of suggested developers in the future and that we should take this onboard. Barratt 44 6.7 Residential development of Objection General None No change Manchester existing landholdings must be suggested viable Redevelopment for housing will be less attractivfe as short term option in comparison with other end uses, failing to achieve LDF Strategy. Countryside 44 6.7 These requirements may Objection General None No change Properties Plc introduce onerous obligations on suggested developers which may thwart regeneration initiatives due to significant costs of meeting LDF requirements. Mr P Robinson 45 6.7 The definition of affordablility is so Objection General None No change wishy-washy that given the figures suggested this only equates to 9.5% of the total new housing stock under the RSS Barratt 45 Unlikely that the Council's higher Objection General None No change Manchester HS1 target can be achieved over the suggested plan period in such a way as to achieve adequate housing choice, sufficient affordable housing and services and infrastructure. Government 45 Figures should not be used in Objection General Review figures in For updating Office for the HS1 emerging LDD's at this stage as light of submission North West provisions have limited weight. RSS Lancs County 45 The Draft RSS Reference should Objection Typo Correct typo Correction Council - HS1 be Table 8.1 not Table 7.1. Strategic Planning and Transport Lancaster 45 Urge adoption of the targets from Objection General None Draft PPS can District HS1 draft PPS3 have only limited Sustainability weight Partnership Lancaster 45 PDL target could be even higher. Objection General None PDL target District HS1 How does 82% PDL figure follows Structure Sustainability compare to 90% of dwellings Plan. Must be Partnership being built in urban areas and 9% realistic in large villages. Matthews and 45 Should also acknowledge the Objection General None No evidence Goodman HS1 possibility of a complementary provided in need for a new residential support of this development over and above the obvious student housing need. McCarthy & 45 Should be a presumption in favour Objection General None Unequivocal Stone HS1 of the provision of housing that presumption in Developments meets local identified needs favour of Ltd development unwise Miller Homes 45 The LDF should make full use of Objection General None The LDF has to HS1 all land available for residential balance the development. need for housing against other land-use needs

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Representor P Para Comment Type Level Council’s Grounds Proposed Change Miller Homes 45 The Council should identify Objection General None Matter for HS1 additional sites following the allocations search sequence set out in PPG3, document starting with urban extensions and finally new development around nodes in good public transport corridors. Miller Homes 45 Assume that figures have been Supporting Detailed None Supporting HS1 the subject of consultation with Representation Representation the Council and support the use of the draft RSS figures on this basis. Mr P Robinson 45 82% of new dwellings to be built Objection General None PDL target HS1 on previously developed land far follows Structure exceeds the previously agreed Plan. Must be target of 60% and may be realistic unsustainable in the long term. North West 45 Does not conform to UR7 of Objection General Amend Address non- Regional HS1 adopted RSS conformity issue Assembly but must also have regard to emerging RSS

COMMENTS ON POLICY HS2 – ACHIEVING QUALITY IN DESIGN and associated text Halton-with- 46 6.8 Last sentence makes no Obervation Detailed add missing Correction Aughton Parish grammatical sense. "and" Council Lancaster Civic 46 6.8 The principle of good design Observation Detailed None Balance is right Society should be expressed more strongly, exceptional designs should be positively encouraged. Lancaster 46 6.10 Appears to be an excuse for Objection Detailed None There are areas such District allowing bad design - all as areas of low-cost Sustainability development should meet the employment Partnership aims of SDF 4. premises for small businesses, gypsy sites and community buildings where high cost, high quality design may not be appropriate Mason 46 6.10 Can the Council ensure good Observation Detailed None No change suggested Gillibrand design is sought in all Architects development. National Trust 46 6.10 Unclear what comparisons are Observation Detailed None No change suggested being made, specific example of Heysham port as being "less sensitive" needs some interpretation. Countryside 47 the requirements for sustainable Observation Detailed None Matter for Design Agency HS2 design (including choice of Code materials, drainage etc) should be set out briefly in the policy. Countryside 47 Preferred wording would be "to Observation Detailed Refer to For completeness Agency HS2 ensure that new development is of landscape a quality which reflects and impacts enhances the positive characteristics of it's surroundings, including the character of the landscape". Lancs County 47 Suggested that the whole section Observation Detailed None Current balance of Council - HS2 "Seeking to ensure….Other rural policy is right Strategic areas" is deleted or that a Planning and sentence is added to show that Transport high quality design will always be required but that in the areas noted particular care will be taken.

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Representor P Para Comment Type Level Council’s Grounds Proposed Change Lancs County 47 As presented the policy does not Observation Typo Delete Correction Council - HS2 make sense, it should be re- 'ensuring that' Strategic ordered. from Para 3 Planning and Transport Lancaster and 47 Would like to be considered a Observation Detailed List LAWSA For inclusiveness Westmorland HS2 partner in developing and advising as partner Society of on design on the Policy HS2. Architects (LAWSA) Lancaster and 47 Does not go far enough in Observation Detailed None Implementation Issue Westmorland HS2 describing about how that policy Society of can be enforced. Architects (LAWSA) Lancaster and 47 This can only be enforced with Observation Detailed None Implementation Issue Westmorland HS2 appropriately trained personnel Society of who can formally comment on Architects Design Matters. As the Council do (LAWSA) not emply such personnel, therefore not in a position to enforce this policy. Lancaster 47 Delete "Seeking to ensure that Objection Detailed None There are areas such District HS2 within the following areas" and the as areas of low-cost Sustainability following bullet points. Not employment Partnership consistent with the principles of premises for small sustainable development to allow businesses, gypsy poor design. sites and community buildings where high cost, high quality design may not be appropriate McCarthy & 47 Seeks a higher test than exists in Observation Detailed None Current balance of Stone HS2 Conservation Areas and may policy is right Developments preclude maximisation of a sites Ltd potential, in accord with PPS1 and PPG3. Suggest that the Council adopt the wording of para 38 of PPS1. National Trust 47 Suggest that text is amended after Objection Detailed None Unnecessary, HS2 the 8 bullet points: "Ensuring that locational issues locations where new development considered elsewhere is appropriate that it is of a quality…."

COMMENTS ON POLICY HS3 – COMMUNITY SAFETY and associated text Lancaster Local 48 6.11 Would like to see reference made Objection Detailed Refer to For completeness Strategic to reducing anti-social behaviour Antisocial Partnership in this introductory paragraph. Behaviour Mr P Robinson 48 6.11 Delete the existing 4th bullet and Objection Detailed None Matter for add "steel roller shutters will be development control approved where crime statistics document and evidence from CBM's, PCSO's, CSO's, PACT meetings identify an urgent need, subject to negotiating a suitable design." National Trust 48 6.11 The approach to lighting needs to Objection Detailed None Matter for be tempered with adequate development control consideration of it's document appropriateness in particular locations and the quality of it's design. Lancaster Local 48 6.12 Should include reference of the Objection Detailed None Unclear how this Strategic relationship between the need for relates to community Partnership regeneration and areas of low safety demand for housing.

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Representor P Para Comment Type Level Council’s Grounds Proposed Change Lancaster Civic 49 Should be beefed up to Objection Detailed None Policy relates to Society HS3 emphasise the importance of Council’s role as tackling anti-social, rowdy and Local Planning aggressive behaviour more authority – limited effectively. scope for direct action on antisocial behavour.

COMMENTS ON POLICY HS4 – RURAL COMMUNITIES and associated text Halton-with- 50 6.13 Add bullet point "Dereliction of Objection Detailed None Not strategic issue Aughton Parish sight railings, lay-bys, car parks Council and signage in lesser used rural routes adding to economic decline of the agricultural areas" Mason 50 6.14 Very "Lancaster centred" Upper Objection Detailed None Upper Lune Valley is Gillibrand Lune Valley is not in the Lancaster ONS ward name Architects District. 50 6.15 Suggested policies for Low Impact Objection Detailed None Development control Developments - Sustainable Land- matter Based Economic Activities & Sustainable Affordable Rural Housing. Green Group 50 6.15 Needs to be a definition of what is Objection Detailed None Matter for meant by "low impact housing" - development control suggest criteria along the lines of document those adopted by Milton Keynes in their draft Local Plan. Green Group 50 6.15 Suggest Residential Moorings Objection Detailed None Matter for Policy to come under Sustainable development control Low Impact housing policy - document Example from Oxford Local Plan. Halton-with- 50 6.15 Add "The provision of Objection Detailed None Detailed local issue Aughton Parish maintenance funds in rural areas Council for public access and safety measures" Dr D Alexander 51 6.16 Why not include low impact Objection Detailed Mention Low For completeness housing in Policy HS4 - Identifying Impact rural housing needs, including a Housing in need for low impact housing and HS4 opportunities. Russell Armer 51 6.16 Explanation of the term 'low Objection Detailed None Matter for Ltd impact housing' would be useful to development control developers. document Countryside 51 Would be helpful to have a Objection Detailed Amalgamate For clarity Agency HS4 statement on rural transport with CE2 included here as an issue as well as in CE2. Lancs County 51 Concerned to make sure that rural Objection Detailed None No change suggested Council - HS4 communities aren't further Locality Focus disadvantaged in terms of their Group for access to services and Lancaster employment. Lancaster 51 Add bullet "Promote and Objection Detailed Address in For clarity District HS4 encourage sustainable agriculture amalgamated Sustainability initiatives, including local food policy Partnership production for local consumption" COMMENTS ON POLICY CE1 – IMPROVING THE ENVIRONMENT and associated text

Lancaster 52 7.6 Add bullet "Valuing and protecting Objection Detailed None Unnecessarily wordy District the built and natural environments Sustainability for their own sake, for their Partnership contribution to quality of life, and as economic assets" Dr D Alexander 54 7.6 Does not state which forms of Objection Detailed New policy For completeness renewable energy and where it is onf likely to be located - on or off Renewable shore. Energy

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Representor P Para Comment Type Level Council’s Grounds Proposed Change Countryside 54 Would like to see specific Objection Detailed Add reference For completeness Agency CE1 reference to Quiet Lanes or to Quiet Greenways. Lanes English Nature 54 Should change the heading to "A Objection Detailed None Link to Corporate CE1 Greener more Sustainable Plan Environment, with Natural and Cultural Assets to be proud of" in this context biodiversity and geological heritage does not fit under "Cleaner Environment". English Nature 54 Recommend addition of the words Objection Detailed Agree For completeness CE1 "natural features and wildlife wording habitats" after "the Council will change seek to safeguard" in addition to the words "and enhance environmental quality by restoring and creating new habitats, whilst creating….." English Nature 54 Does not go far enough in terms Objection General None No change suggested CE1 of biodiversity and habitat defragmentation. Environment 54 Fully supported - some mention of Objection General None Addressed in Agency CE1 the use of sustainable drainage Sustainable should be included Development policy Green Group 54 Should be mention of micro- Objection General None Addressed in CE1 renewables on buildings. Would Sustainable like to see a permissive approach Development policy to micro wind turbines, solar panels etc, including in conservation areas and on listed buildings. Lancaster 54 First bullet - replace "non- Objection Detailed Agree For clarity District CE1 renewable energies" with wording Sustainability "energy". change Partnership Lancaster 54 Bullet 8 - add "with respect for the Objection Detailed None Landscape character District CE1 character of the landscape" addressed elsewhere Sustainability Partnership McCarthy & 54 Objections as for SDF Principle 4. Objection Detailed None Spatial Planning Stone CE1 addresses non-land- Developments use issues Ltd National Trust 54 Unclear how the proposed policy Objection General None No change suggested CE1 will address the concerns regarding poor biodiversity of parts of the district. National Trust 54 Bullet point 8 is unclear - request Objection General None Coast is major area CE1 that the words "particularly in of renewable energy coastal areas" are deleted. potential National Trust 54 No specific reference to the Objection General None Addressed elsewhere CE1 protection of the settings of designated built and natural environmental assets. National Trust 54 Bullet 10 refers to the protection Objection General None Coast is major area CE1 and enhancement of existing of renewable energy valued habitats, not how areas potential devoid of wildlife will be turned around.

COMMENTS ON POLICY CE2 –MANAGING TRANSPORT and associated text Dr D Alexander 56 7.8 The transport measures make no Objection Detailed Agree Mention Heysham reference to rail freight at wording Heysham. change Countryside 56 Redevelopment of Luneside West Objection Detailed Additional text For soundness Properties Plc CE2 should not be dependant upon on Lune completion of road schemes which Crossing have no certainty. stating where, when, who and how.

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Representor P Para Comment Type Level Council’s Grounds Proposed Change Green Group 56 Object to first bullet point on the Objection General No In line with Local CE2 Heysham/M6 link road Transport Plan Green Group 56 Object to implications that more Objection General No In line with Local CE2 road space for buses and 'other Transport Plan innovative solutions' are only to be considered after completion of Heysham/M6 link road. Highways 56 Identify what is meant by "realistic Objection General No Matter for Local Agency - NS CE2 choice of transport". Transport Plan North West, Highways 56 Should be made explicit that Objection General Agree For soundness Agency - NS CE2 further growth and redevelopment wording North West, should be based upon an change adequate infrastructure and will, where necessary be dependant on highways improvement. We seek that this is acknowledged in the Core Strategy. Highways 56 Network implications of new Observation General No No change suggested Agency - NS CE2 development should be North West, considered in broad terms with the Core Strategy and in more detail in the Land Allocations. Lancaster 56 Bullet 1 - replace "road access" Objection General No In line with Local District CE2 with "sustainable surface access" Transport Plan Sustainability and remove reference to Partnership Heysham M6 link. Lancaster 56 Bullet 2 - add "cycle and Objection General No Cycling and walking District CE2 pedestrian access" after "public addressed elsewhere Sustainability transport" in policy Partnership Lancaster 56 Move bullet 9 higher up the list to Objection Detailed None Order of bullets has District CE2 reflect it's place in the transport no implication for Sustainability hierarchy and therefore in the priority Partnership Council's priority. Lancaster 56 Add a new bullet at the top of the Objection General No Address through District CE2 list "Strongly support the transport Local Transport Plan Sustainability hierarchy for people and freight Partnership and apply it to all plans and proposals" Lancaster 56 Change target of completion of M6 Objection General No In line with Local District CE2 link to "improved sustainable Transport Plan Sustainability surface links to Heysham and the Partnership district in General" Mason 56 Council needs to do some Observation General No No change suggested Gillibrand CE2 analysis of how much people Architects travel to work. Mr P Robinson 56 Assumption that public will utilise Observation General No No change suggested CE2 public transport unlikely to occur unless service is cheap and reliable. This will undermine sustainable objectives. North West 56 Core Strategy should be amended Observation General No Address through Regional CE2 to include a policy that specifically Development Control Assembly relates to planning obligations. Sanderson 56 Should be greater clarity including Observation General No Address through Weatherall CE2 a list of possible contributions Development Control which set out financial agreements and to which type of developments they would relate to. Should be covered within the supplementary planning document stage.

COMMENTS ON POLICY CS1 – IMPROVING CUSTOMER SERVICES and associated text Lancaster 57 8.4 Final bullet - replace "choice of Objection General No In line with Local District means of transport" with Transport Plan Sustainability "sustainable transport" Partnership Lancaster 58 First bullet - add "and improving Objection General No Not much opportunity District CS1 phione and web based service to do this through

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Representor P Para Comment Type Level Council’s Grounds Proposed Change Sustainability provision" planning Partnership

COMMENTS ON APPENDICES Lancs County 62 App Needs to be completely reviewed Objection Detailed Amend Updating Council – 2 as it is incorrect in some respects reference to Locality Focus (including road maintenance and roads Group for social care) and does not Lancaster accurately represent the relationship between the two councils. Dr D Alexander 64 App Perhaps draft PPS3 and 25 can Objection Detailed Update Updating 4 be added here. Russell Armer 64 App Would be useful to list PPS3 even Objection Detailed None Draft PPS has no Ltd 4 if it is suffixed as a draft weight document. Dr D Alexander 65 App A table in the main text would be Objection Structural None No impact on 5 more attractive to readers. substance Lancs County 67 10.1 It is possible that Structure Plan Objection Structural Refer to For completeness Council – 1 policies may be saved beyond possibility of Strategic 2008. Saved Policies Planning and Transport Lancs County 67 App It is noted that a number of targets Observation General Review and For completeness Council – 5 are under-developed. update targets Strategic Planning and Transport

GENERAL COMMENTS AND OMISSIONS English Gen Primary consideration is the Observation Omission Consider East For completeness Partnerships preservation, enhancement and Lancaster as redevelopment of Lancaster Moor RPA Hospital. Environment Gen Little specific reference to Objection Omission None Address in Agency watercourses - should be Development Control considered when formulating DC policies policies. Environment Gen Take account of brownfield sites - Objection Omission Include For completeness Agency can represent important wildlife reference to habitat, public green space or part previously used of urban green networks. An sites of wildlife appropriate balance should be or amenity struck. importance Environment Gen Concerned about flood risk - Objection Omission SRA in For completeness Agency Strategic Flood Risk assessment preparation should be carried out as part of the Sustainability Appraisal for any Spatial Plans. Environment Gen New development should not Objection Omission SRA in For completeness Agency increase flood risk elsewhere preparation Environment Gen Any mitigation required would Objection Omission None Matter for DC Agency need to be funded or provided by document the developer. Environment Gen Need to maintain the integrity of Objection Omission None Matter for DC Agency existing flood defences and to document maintain access for maintenance to defences and watercourses. Environment Gen Avoidance of culverting for all but Objection Omission None Matter for DC Agency access purposes document Environment Gen Specific considerations should be Objection Omission None Matter for DC Agency made of infrastructure problems or document non mains drainage when formulating the Development Control Policies and looking at site allocations. Forton Parish Gen Little mention of a Lancaster Objection General No In line with Local Council Bypass which was thought Transport Plan imperitive for the prosperity of the area.

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Representor P Para Comment Type Level Council’s Grounds Proposed Change Forton Parish Gen Bypass should be at the top of the Objection General No In line with Local Council 'want and needs' list. Transport Plan Government Gen Regard should be made clear to Objection General Show clearer For soundness Office for the the authority's community linkage to North West strategy. Community Strategy Government Gen Soundness is open to question - Objection General Addendum For soundness Office for the advisable to repeat the regulation consultation North West 26 stage. Alternatively provide justification for the approach taken - risk that the Inspector will find DPD unsound. Government Gen The policy wording should give Objection General Addendum Matter for Office for the more certainty in decision making consultation Development control North West by making it clear what will be and allocations acceptable where, when and how. documents Government Gen It is noted that a number of targets Observation General Review and For completeness Office for the are under-developed. update targets North West Government Gen Does not make any explicit Observation General Introduce Para For completeness Office for the reference to the evidence base on Information North West that has informed the proposals. Base Highways Gen Ensure all major development Objection Omission None Matter for DC Agency - NS proposals are accompanied by document North West, Transport Assessments. Lancs County Gen Wish to see loosening of planning Objection Omission None Difficult to Council - restriction on development of local discriminate between Locality Focus businesses addressed in the LDF different types of Group for Core Strategy. business Lancaster Lancs County Gen Local Area Agreement needs to Objection Omission Mention LAA in For completeness Council - be reflected in the LDF context Locality Focus Group for Lancaster Lancs County Gen The significance of this document Objection Omission None No change suggested Council - to the future of the district has not Locality Focus been understood by many. Group for Lancaster Lancaster Gen The Principles' significant Objection Omission None Meaning unclear District interconnection should be drawn Sustainability out so strengthen them as drivers Partnership of the Strategy. Martindale & Co Gen Request that The Core Strategy is Objection Site Specific None Site specific issues to amended to include a wider range be considered in of land uses in respect of Caton allocations document Road to include a mix of residential, retail and employment uses. Matthews and Gen The University Masterplan should Objection Site Specific None Site specific issues to Goodman be extended to acknowledge the be considered in land surrounding Bailrigg itself as allocations document an existing resource in the event that future complementary development is appropriate. McCarthy & Gen Housing needs of the district to be Observation Omission None Already addressed Stone taken into account, including the Developments provision of specialised homes for Ltd the elderly - namely the beneficial use of brownfield land close to town centres, utilising other forms of transport than the private car. National Trust Gen Lack of consideration of Observation Omission Refer to For completeness landscape quality issues is landscape disappointing. character Sport England Gen Monitoring the success of this Observation General Review and For completeness DPD needs to be measured, update targets based on the examples given, spatially throughout the district with targets set for urban, village

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Representor P Para Comment Type Level Council’s Grounds Proposed Change and rural areas. Sport England Gen A Key Principle not expressed as Observation General Review and For completeness an output indicator is how quality update targets of life is to be measured - this should lie at the heart of the Core Strategy. Sport England Gen Reference to sport and recreation Observation General Insert policy on For completeness is minimal. Sport and Recreation in Sustainable Communities bit The Vision Gen Pleasing that the Core Strategy Supporting Detailed None Supporting Board and the draft Vision seem to be Representation Representation largely in tandem Theatres Trust Gen Concerned that there is no Objection Omission Insert policy on For completeness Generalprovision for the protection culture in of theatres - surprised that no Sustainable mention of Nuffield Theatre, The Communities bit Dukes and Grand Theatre. Theatres Trust Gen Should include an additional key Objection Omission Insert policy on For completeness policy relating to theatre within an culture in Arts, Culture and Tourism Section. Sustainable Policies should be linked to the Communities bit Councils Cultural Strategy and the Tourism Strategy. Theatres Trust Gen Should include a review and Objection Omission None Progress through assessment of existing venue cultural strategy provision and future needs. United Utilities Gen In relation to potable water Objection Detailed None Address in conservation, the document is Development Control encouraging but does not give any policies specific water saving measures. United Utilities Gen Would advise attention to building Objection Detailed None Address in design to conserve potable water Development Control policies Development Gen Ultimately we need to ensure our Observation General None No change suggested Services area remains competitive and forward looking as opposed to being introspective and narrow minded.

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APPENDIX 6 – RESPONSES TO PREFERRED OPTIONS ADDENDUM CONSULTATION

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Organisation Preferred Option Reasons Addendum Detailed Comment Document Paragraph Valerie Taylor - - - St Nicholas Urban Concentration The choice proves the most - Arcades beneficial for the district David Alexander - - Spatial Vision How is "conserved and diversified Coast and Countryside.." likely to be different from the more traditional vision of coast and countryside across the District? National Trust - - General Urban Concentration is the best strategy for managing development in Lancaster District and realising the vision for the Core Strategy Lancashire County Urban Concentration Most consistent with JLSP, - Council - regional and national policies. 3 Environment is against the principle of PPS6, Directorate 3 and 4 conflict with policies 4 and 5 of JLSP. Option 1 best achieves the spatial vision set out in the Core Strategy. Option 1 more sustainable approach. Choices Urban Concentration Having the ability to pull on a - Employment number of key areas will not clog up the already busy area around Lancaster, Morecambe and Heysham. We have a large area in which to build and diversity will help create wealth all around the area & give people more choice. Environment - - General No opinion on the proposed adopted Agency options or the other options considered. Comments contained in letter of 16 March 2006 are still relevant. Martindale & Co Urban Concentration As concluded by the Council at - paragraphs 2.13 and 3.19, Option 1 is the approach which best matches the various policies of the Core Strategy. British Waterways - - General Support the Council's preferred option of 'Urban Concentration' St Martins College Urban Concentration Supports the Council's aim of - promoting Lancaster as a thriving knowledge economy. Will facilitate accessibility of students to the college campus & to other services, minimizing impact on transport. Most sustainable option. In line with RSS. Marion McClintock Dispersal Urban regeneration is too - narrow for the good of the area - see previous response. John Stelfox Urban Concentration This will provide sustainable - development, reduce road traffic and therefore pollution and maintain the countryside and wildlife. Winifred Clark Urban Concentration Represents the best - compromise solution, effort should be made to safeguard and increase urban greenspace, consideration should be given to allowing some flexibility in rural areas over affordable housing and any employment/retail opportunities. Lancaster Civic Urban Concentration Attempts to share development - Society across the whole of the district.

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Organisation Preferred Option Reasons Addendum Detailed Comment Document Paragraph The highest possible standards of design and high quality development are most likely to be achieved through the adoption of the Urban Concentration option. Tesco Stores - - General Welcome the Urban Concentration approach which is in line with government policy for the re-use of Brownfield land. Centros Miller - - General Support the strategy of Urban Concentration which fulfils Government requirements for sustainable development by locating major developments in areas where there is existing infrastructure. Yorkshire Forward - - General Welcomes the Urban Concentration approach of the Core Strategy, which seeks to focus development within the main urban area and demonstrates a clear commitment to sustainable development. Lancashire County Urban Concentration Any developments need to - Council - Older ensure good access to services Peoples Services and to good public transport links across all major centres of population. Urban Concentration seems to have the best potential for delivering this David Barnes Urban Concentration Best option to regenerate the - district with a good ratio of development across the district, limits urban sprawl, less reliant on road transport for residents, concerned about detailed consultation, communities need to be listened to more. David Alexander - - 2.1 Urban Concentration is the PREFERRED Option with regeneration seen as a key tool with which to implement it(Option 4) National Trust - - General The Strategy would be less sound, and it's vision less effectively delivered, if one of the other options was adopted British Waterways - - General Agree that this approach will help to make the best use of the District's resource of previously used land. This includes land along Lancaster Canal. Tesco Stores - - General Note that option one does not preclude retail development within any of the settlements within the borough, rather it seeks to focus it within Lancaster, as well as Morecambe Centros Miller - - General This is the most sustainable strategy of all those considered. Concentrating development and investment in the existing urban areas will in turn reinforce the district identity in accordance with the vision for the Strategy.gy David Alexander - - 2.1 Options 2,5 and 6 all involve rejection of important and broadly accepted professional planning principles and philosophy National Trust - - General It is not considered that there are any additional options that would result in a more sound Strategy and realise the Vision more effectively British Waterways - - General The regeneration of previously used land has an important role to play in

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Organisation Preferred Option Reasons Addendum Detailed Comment Document Paragraph delivering urban potential and the Government's overall aim of sustainable development, in turn it's redevelopment will assist in fulfilling the potential of the Canal. Tesco Stores - - General It would be helpful if the Core Strategy could make clear that any proposals should be considered on their merits and 'edge of centre' and 'out of centre' proposals should be permitted where they meet the tests set out in PPS6. Centros Miller - - General Consider that a policy of urban concentration must also have regard to the appropriate scale of development. In particular it is important that the scale of development in Lancaster and Morecambe is appropriate given their proximity. David Alexander - - 2.1 option 3 does have some professional planning merits but recent observations of this approach in action at Poundbury on the edge of Dorchester suggests that it is undermining parts of Dorchester and is now in need of some regeneration initiatives. National Trust - - Option 1 This best conforms to the relevant adopted Development Plans for Lancaster i.e. the Regional Spatial Strategy and the Lancashire Structure Plan British Waterways - - General Whilst we support a strategy of urban concentration, such a strategy must allow for development elsewhere to meet recognised needs, including the provision of new leisure, recreation and tourism facilities in association with the Canal. Centros Miller - - General There should not be over-development in Morecambe, particularly for retail development where opportunities exist in Lancaster, which plays a more strategic role. David Alexander - - 2.5 Advantages are clearly expressed, majority of disadvantages are capable of being addressed and managed by planning and related policies National Trust - - Option 1 This best conforms to national planning policy guidance as set out in PPS's and PPG's especially PPS1, PPS3 and PPS7 Centros Miller - - General Urban Concentration most closely meets the objectives of the Government for efficient use of previously developed land, to encourage regeneration & allow high density development where the environment and infrastructure allow David Alexander - - 2.5 Final disadvantage on the provision of a "few crumbs" for rural communities will to some extent depend on the accepted definition of urban concentration National Trust - - Option 1 Option 1 will optimise the use of brownfield land in the District Centros Miller - - General Whilst the other strategies do have benefits, these are strongly outweighed by the negative impacts, which include incompatibility with sustainability aims and conflict with the Regional Spatial Strategy and Government Guidance. David Alexander - - 2.6 Urban concentration can surely operate

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Organisation Preferred Option Reasons Addendum Detailed Comment Document Paragraph within a percentage band range and some adjustment to this could provide for the rural provision? National Trust - - Option 1 Provides the greatest opportunity to reduce the demand for travel and to encourage the use of public transport for those journeys that are necessary. Centros Miller - - General Of those strategies considered in detail, none match as closely with the tests of soundness and sustainability appraisal as option one. David Alexander - - 2.10 The percentage of respondents favouring this option - 55% is a telling figure in it's favour. National Trust - - Option 1 Will best meet the essential requirement of safeguarding and enhancing the District's coast and countryside, respecting landscape character and promoting local distinctiveness. Centros Miller - - General Alternative options will not deliver the Governments aims for the use of brownfield land and efficient use of land & buildings, maximise the choice of transport, ensure regeneration of the urban areas and allow for high density development where appropria David Alexander - - Option 2 This runs contrary to accepted professional planning principles and to both central government and regional policies and can hardly be a serious contender. It need not seriously detain consultees here. National Trust - - Option 3 Could have adverse implications for investment in Lancaster which would be detrimental to the key consideration of maintaining and enhancing it's significant heritage resource Centros Miller - - General Whilst it is an important policy objective to increase non-car borne travel, it must be recognised that given the rural nature of much of Lancaster's catchment, it will continue to be heavily reliant on car-borne trade David Alexander - - Option 3 This option has professional merit and in certain circumstances it could be an acceptable option. National Trust - - Options 2, 5 & 6 Are clearly unacceptable under any reasonable assessment of their sustainability credentials and their lack of support in previous consultation exercises recognises this David Alexander - - Option 3 In Lancaster District could undermine investment already placed in urban regeneration as it has done elsewhere in the country, thus create more planning problems than it might solve. National Trust - - General The Trust concludes that there are significant benefits to be gained from pursuing Option 1 rather than 5 or 6. David Alexander - - Option 3 The Council might like to examine the impact of this approach elsewhere in order to build up stronger evidence David Alexander - - Option 4 Might also be seen as an approach to urban concentration, a tool to help ensure that resources are first directed to urban areas of greatest need. David Alexander - - Option 4 Might also include some element of rural regeneration needs David Alexander - - Option 4 Given the broad range of regeneration needs across the district, there seems

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Organisation Preferred Option Reasons Addendum Detailed Comment Document Paragraph no reason to focus this approach solely on Morecambe and Heysham. David Alexander - - Option 5 Simply an abandonment of planning responsibilities David Alexander - - Option 6 Not a serious option for consideration David Alexander - - 2.92 Agree that options 3, 5 and 6 are 'fundamentally flawed' David Alexander - - 2.93 Agree that options 1, 3 and 4 are worthy of further appraisal against the vision and objectives of the Core Strategy David Alexander - - 3.4 How rigid is the definition of urban concentration expressed in this paragraph? Is there some scope for adjustment that would still give a strong emphasis on urban concentration but allow for necessary development to support the needs of rural facilities? David Alexander - - 3.4 What evidence is available for the figure of 90% and how flexible is it? David Alexander - - 3.16 There seems little difference in how options 1, 3 and 4 would affect rural areas, how does this differ from the present pattern and is there evidence for for slight but locally significant adjustments? David Alexander - - 3.19 The case for urban concentration is a strong and sound one, but there seems to be room for some adjustment to the agreed percentage, if evidence of the needs of rural communities points to it.

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