The goverment published The Landscapes Review (Glover Review) on 21 September 2019.
National Parks England submitted a response to the consultation on behalf of the ten national park authorities.
Below is our consultation response to the findings of that review, it was submitted via an online form on 6 April 2022.
No
Lake District National Park Authority
Email: richard.leafe@lakedistrict.gov.uk
North West
National Park Authority or the Broads Authority
Yes
We would like to see the government adopt a strengthened first purpose, which is “Protect and improve landscape and scenic beauty, biodiversity and natural capital, cultural heritage, and the Special Qualities of the National Park”.
It is not clear from the Government response whether the revised first purpose will just focus on nature and nature recovery, or still include reference to landscape and cultural heritage. Whilst we fully support the need to recover and strengthen nature we would not support the omission of reference to landscape and cultural heritage within the first purpose. Amendments to this purpose should not be detrimental to the existing purposes.
All English National Parks are statutorily required to identify what Special Qualities they have. Special Qualities distinguish National Parks from each other and other areas of the country. Being clear about what these Special Qualities are enables more effective management. By including Special Qualities within the first purpose it becomes relevant to each national park and adds clarity to what we are trying to achieve. It is much more specific and less general, and the strategies in the management plan are much better aligned. AONBs could easily identify their own Special Qualities.
We do not support the vision (presented in page 3 of the consultation document) suggested by DEFRA preferring to see the renewed vision for Protected Landscapes strengthened to include the cultural heritage element as well. We suggest the following alternative ‘A coherent national network of beautiful, nature-rich and culture-rich spaces that all parts of society can easily access and enjoy. Protected landscapes will support thriving local communities and economies, improve our public health and wellbeing, drive forward nature recovery, sustain our cultural landscapes and build our resilience to climate change.’
We are very concerned that insufficient attention is given to climate change throughout the government’s response. We urge government to reconsider and address more fully the urgent need for Protected Landscapes to progress to net zero, as well as adapt to the inevitable impacts of climate change that are very evident already. As a minimum we propose that the duty be amended to read “To seek to foster the economic and social well-being of local communities, and address climate change”.
Designing the environmental land management schemes in a way that works for all farmers and land managers, including the specific circumstances for those in protected landscapes, recognising that farmers in these areas are well-placed to deliver on our environmental priorities.
Using Local Nature Recovery Strategies to identify projects or habitats within protected landscapes.
Monitoring the effectiveness and uptake of the new environmental land management schemes in protected landscapes. Using this to inform whether further interventions are needed to ensure we are on track for wider nature recovery ambitions.
Creating a clear role for protected landscape organisations in the preparation of Local Nature Recovery Strategies.
Our recent LNRS consultation specifically asks for views on the role of different organisations in the preparation of LNRSs, including protected landscapes.
Building on FiPL, empowering protected landscapes to support decision-making and delivery against agreed priorities, including through dedicated project coordinators and advisers.
The Lake District National Park Partnership has recently adopted its new Management Plan for the National Park and English Lake District World Heritage Site. In it, the Partnership have integrated the themes of farming, forestry, nature and climate in order to address these challenges and opportunities in a holistic way.
https://www.lakedistrict.gov.uk/caringfor/lake-district-national-park-partnership/management-plan/future-of-farming-and-forestry,-nature-recovery-and-climate-change
The key approach across the majority of the National Park will be “farmer led nature recovery” combining viable farm businesses with a nature and culture rich landscape.
The Environmental Land Management Schemes need to be designed and delivered in a way that ensures that they are fit for purpose for achieving farmer led nature recovery and holistic land management in Protected Landscapes, as outlined in our support to Question 8 bullet points 1 to 5. Such schemes need to be based on co-creation, with farmers and Protected Landscape bodies working together to design and implement locally tailored schemes that address the Special Qualities of the Protected Landscape, combining national priorities with local priorities identified in the Management Plan. We welcome the statement that new schemes must work for all farmers, it is important to highlight that unless farmers in the Lake District are able to access the same amount of public support through ELMs as through BPS, there is a real risk that traditional farming in the Lake District will be lost, undermining the World Heritage site inscription.
We ask government to ensure ELM, when applied to Protected Landscapes, uses the four themes of Farming in Protected Landscapes: Climate; Nature; People; and Place, thereby ensuring the continuity of the holistic land management approach securing nature recovery whilst sustaining culture rich landscapes. We also ask that Protected Landscape bodies are integral to delivery. This more devolved approach to ELM will increase collaboration, and local traction and accountability. Our experience of leading the Cumbria Pioneer ELM Test and Trial and delivering Farming in Protected Landscapes (FiPL) provides evidence that supports this.
FiPL with the help of trusted local advisors is helping farmers to collaborate to deliver landscape scale change. With ELM we could roll this out over a much larger area. Farmers and land managers trust holistic advice from Protected Landscape organisations. Our Test and Trial demonstrated the value of local collaborative co-created area plans for public goods that inform and supplement individual land management plans. The four FiPL themes of Climate, Nature, People, and Place, have demonstrated the demand for and ability to fund themes and projects that are not funded through other schemes and the potential to deliver multiple benefits, demonstrating that the four themes are in fact intrinsically linked. Empowering Protected Landscapes to act in this way needs to include appropriate levels of resourcing to cover all costs incurred.
Protected Landscapes should have a role in ELM in the following ways: Agreeing local priorities with local stakeholders based on their Statutory
Management Plans; providing trusted advice, guidance and facilitation with farmers and land managers; and monitoring and evaluating the outcomes of ELM schemes. For more detail on the role of National Parks in ELM see National Parks England Delivery Plan for Sustainable Farming and Land Management: https://www.nationalparksengland.org.uk/__data/assets/pdf_file/0024/369321/Sustainable-Farming-and-Land-Management-Delivery-Plan-FINAL.pdf
We reiterate our ask that ELM reflect the four pillars of FiPL in at least the Protected Landscapes. We are concerned that the current omission of culture and accessibility/ inclusivity are retrograde steps that will undermine the holistic approach needed if government is to deliver the Purposes and Duty of Protected Landscapes. Our inscription as a World Heritage Site, in part due to the agro-pastoral attributes of the property, further fuels this concern. As set out above in our experience from FiPL, the four themes are not mutually exclusive and are intrinsically linked, particularly when combined with traditional farming practices that form part of our agro-pastoral tradition. Further, our experience of FiPL shows an equal level of demand for applications for funding across the four pillars of FiPL.
FiPL local case studies:
West Lakes Community Interest Company – Farmer Led Nature Recovery
The West Lakes CIC is promoting and supporting the conservation and improvement of the physical and natural environment of the Western Lakes while empowering farmers to maintain and develop sustainable food production. Year One FiPL funding is helping with scoping studies, in preparation for landscape scale projects. This includes engaging with farmers and commoners; collecting data on the natural environment, including carbon audits and habitat surveys; and mapping these datasets.
Robinson Place, Great Langdale - Farm and Garden Volunteer Group
This project is setting up a volunteer group on the farm that will participate in various practical projects from historic garden restoration to woodland pasture creation. The group of volunteers are receiving regular access to the farms therapeutic green space for mental wellbeing. In addition to the health benefits the project is providing opportunities to learn practical skills like tree planting, stone wall restoration, coppicing, gardening, and restoring historical features. Whilst also developing the regenerative agricultural practices on this farm.
The role of Commoning
It is unclear how the new environmental land management system will work within the context of the commoning system that sustains the landscapes of the Lake District, and also exists in many other National Parks. Here in the Lake District we are working closely with Natural England, the National Trust and other key stakeholders to consider the intrinsic links of traditional commoning and achieving nature recovery, in order to identify a mutually beneficial model for delivery which could help inform how the new system may work when it is implemented in 2024.
Yes
Yes
We support a stronger mission to connect all people with our Protected Landscapes, and therefore support the principle of a stronger second purpose which is more proactive in supporting opportunities for understanding and enjoyment in national landscapes. Changing demographics, physical and mental health, and technology mean there are new challenges for society today, but recent research1 has clearly demonstrated the value of spending time in nature and the outdoors to children, individuals, and societal health and well-being which would be supported by a strengthened second purpose. The historic environment, cultural and heritage assets also contribute to and support people’s health and well-being hence their importance to be recognised by the first purpose.
It is critical that any changes to the second purpose retain reference to the “special qualities” of Protected Landscapes in legislation. Special qualities enable different national landscapes to identify the unique qualities that set them apart from other areas and other national landscapes. We believe that the function of national landscapes should continue to reference “understanding” (i.e. opportunities for discovery, education and lifelong learning whether this is through outdoor providers, volunteering, or visitor giving), and “enjoyment” (i.e. opportunities for recreation, arts and culture, physical and mental wellbeing, and access) as part of the second purpose.
We agree that each of these points should form part of a strengthened second purpose:
We support a stronger mission to connect all people with our Protected Landscapes, and therefore support the principle of a stronger second purpose which is more proactive in supporting opportunities for understanding and enjoyment in national landscapes. Changing demographics, physical and mental health, and technology mean there are new challenges for society today, but recent research1 has clearly demonstrated the value of spending time in nature and the outdoors to children, individuals, and societal health and well-being which would be supported by a strengthened second purpose. The historic environment, cultural and heritage assets also contribute to and support people’s health and well-being hence their importance to be recognised by the first purpose.
It is critical that any changes to the second purpose retain reference to the “special qualities” of Protected Landscapes in legislation. Special qualities enable different national landscapes to identify the unique qualities that set them apart from other areas and other national landscapes. We believe that the function of national landscapes should continue to reference “understanding” (i.e. opportunities for discovery, education and lifelong learning whether this is through outdoor providers, volunteering, or visitor giving), and “enjoyment” (i.e. opportunities for recreation, arts and culture, physical and mental wellbeing, and access) as part of the second purpose.
We agree that each of these points should form part of a strengthened second purpose:
The Lake District National Park Partnership has also commissioned research to understand the challenges and barriers to “access for all”. Whilst data suggests that visitors aged over 65 are not disconnected from accessing the Lake District, the other findings were consistent with the Landscapes Review findings. Evidence, prior to the pandemic, did demonstrate challenges and inequity of access to the countryside and nature by particular audiences, and although, anecdotally at least, reports suggest a positive change in some audiences accessing the countryside we can and should be doing more to address these challenges:
There is also a significant opportunity to improve our engagement outside Protected Landscapes. Data highlights there are almost 800,000 people within 40 miles of the Lake District, and 253 primary schools classified as being in deprived areas. Recognising that travelling to the Lake District may be unaffordable or unattainable for some people, success may mean that some people do visit the Lake District but people may also visit other Protected Landscapes in order to secure health and wellbeing benefits, and outdoor experiences resulting from addressing this key challenge. The research “Lake District for everyone: Finding Common Ground” by Place Innovation, March 2021, made the following recommendations:
We welcomed these recommendations to go beyond our boundaries, but they require resource to deliver them beyond our existing capacity, especially given the additional visitor management activities of the past two years. We know we can do more, faster, with additional resourcing to ensure Protected Landscapes connect people to places wherever this may be, and would seek to work with Government and the National Landscapes Partnerships to consider how this can be done.
Tick all that apply.
Where visitor pressures are experienced in the Lake District National Park and byelaws are being infringed, our principle approach is to engage and educate first, and to only enforce as a last resort. In our current staffing structure and resource limitation, we would currently only use these powers on our lakes. Issuing Fixed Penalty Notices for existing byelaw infringements on our lakes would deliver significant efficiencies in comparison to the lengthy and resource intensive process of using the court system. It is estimated that fixed penalty notices would save the Lake Rangers on average 7.5 hours per prosecution and the LDNPA Solicitor 1 hour per prosecution. Based on the last 3 year average of about 50 offences per year this would save an average annual total staff time of about 442 hours.
However, taking a longer term view, we would give cautious support to securing powers for our land rangers to also serve Fixed Penalty Notice, albeit as a last resort. Our caution relates to the findings of the Glover review: applying these powers on land has a high risk of creating another barrier to poorer and more disadvantaged groups, it could lessen the chances of them returning and stymie the benefits such groups should rightly gain from Protected Landscapes. A more appropriate means to addressing visitor management issues would be to adequately resource visitor education across Protected Landscapes and to ensure that Protected Landscapes undertake root and branch work on equality issues. This would ensure that there is an embedded understanding or experience of the equality issues that were highlighted so powerfully in the Glover Review findings.
We would only anticipate applying the powers on land in the event of equality training referenced above and with resource changes which would enable land Rangers or other specific enforcement staff, to take on enforcement responsibilities and to enable responsiveness to visitor management need. If the Government did legislate to grant National Park Authorities greater enforcement powers through issuing Fixed Penalty Notices for byelaw infringements, we would recommend a frequent and consistent method of monitoring and data sharing publically and across all National Park Authorities for reasons of transparency around how these powers are being applied. This is to ensure National Parks can be held to account if Fixed Penalty Notices are disproportionately issued to certain groups in society.
There have been occasions when powers to introduce TROs on sealed roads would have supported visitor management in the Lake District to mitigate impacts on landscape and/or our communities. Currently, National Park Authorities must seek TROs on sealed roads through their Highways Authority, this process is often bureaucratic and lengthy and it does not provide consideration to National Park purposes. As Highways Authorities have a different intent to National Parks, therefore we recommend that we are granted powers to introduce TROs on roads for the purposes of mitigating visitor impacts on sensitive landscapes and/or communities
Unsure
If the Government’s desire is to remove all potential harm and conflict caused by Mechanically Propelled Vehicles (MPV) use on unsealed routes, then national legislation may be the only practical solution. Ideally this would be applied everywhere, as this would remove any potential confusion. However, in order to balance the ability of MPV users to still exercise their rights, we can understand why any prohibition could be limited to protected areas.
Our starting point is our current position statement on the use of unsealed public roads within the Lake District National Park. This is in full on our website https://www.lakedistrict.gov.uk/visiting/things-to-do/unsealed-roads#position. A very brief summary of our overall position is that we remain concerned about MPV usage on unsealed routes in the Lake District, but accept the legality of such activity. And where we consider there is clear and substantial evidence that MPV usage is harming the Outstanding Universal Values of the World Heritage Site (or the Special Qualities of the National Park) then we will seek to restrict such usage through Traffic Regulation Orders (TROs).
We have recently carried out a detailed assessment on a popular unsealed road in the Lake District, and concluded that, in our view, the evidence of harm was not strong enough at present to warrant a TRO. This decision has been hotly contested, and we fully accept that the grounds for a TRO as currently written are open to interpretation and subjectivity. It is not that grounds do not exist in legislation for National Park Authorities to use, it is the difficulty in applying without challenge that is more the issue.
As set out in our response to Question 15, the tests often require the assessment of intangible aspects such as nuisance – where people have different levels of tolerance and considerations of what ‘nuisance’ actually is. Consequently we do not see that the introduction of similarly subjective new or additional grounds would necessarily assist the decision-making process.
Given the difficulties of applying the current legislation on a case-by-case basis, and the lack of guidance on what additional powers could be introduced; we consider that if the aim and desire of Government is to encourage the removal or reduction of recreational MPV use on unsealed roads in the countryside, especially in the protected areas, then we would conclude that the only realistic way to achieve this would be to introduce national legislation to this effect.
NPAs already have full powers to make TROs on all unsealed public routes (including roads and byways open to all traffic) where required. Most of the above reasons already exist or can be assessed within the scope of the current grounds. Our concern lies in the risk of challenge to what constitutes evidence of impact on amenity because of the subjective nature of the evidence therefore, further guidance or definition of what constitutes impact on amenity could be helpful if, importantly, it provided confidence that the evidence could be accepted without the risk of challenge. We are concerned that adding additional grounds may not assist the issue of challenge to the evidence.
Yes – everywhere
If the Government’s desire is to remove all potential harm and conflict caused by Mechanically Propelled Vehicles (MPV) use on unsealed routes, then national legislation may be the only practical solution. Ideally this would be applied everywhere, as this would remove any potential confusion. However, in order to balance the ability of MPV users to still exercise their rights, we can understand why any prohibition could be limited to protected areas.
Our starting point is our current position statement on the use of unsealed public roads within the Lake District National Park. This is in full on our website https://www.lakedistrict.gov.uk/visiting/things-to-do/unsealed-roads#position. A very brief summary of our overall position is that we remain concerned about MPV usage on unsealed routes in the Lake District, but accept the legality of such activity. And where we consider there is clear and substantial evidence that MPV usage is harming the Outstanding Universal Values of the World Heritage Site (or the Special Qualities of the National Park) then we will seek to restrict such usage through Traffic Regulation Orders (TROs).
We have recently carried out a detailed assessment on a popular unsealed road in the Lake District, and concluded that, in our view, the evidence of harm was not strong enough at present to warrant a TRO. This decision has been hotly contested, and we fully accept that the grounds for a TRO as currently written are open to interpretation and subjectivity. It is not that grounds do not exist in legislation for National Park Authorities to use, it is the difficulty in applying without challenge that is more the issue.
As set out in our response to Question 15, the tests often require the assessment of intangible aspects such as nuisance – where people have different levels of tolerance and considerations of what ‘nuisance’ actually is. Consequently we do not see that the introduction of similarly subjective new or additional grounds would necessarily assist the decision-making process.
Given the difficulties of applying the current legislation on a case-by-case basis, and the lack of guidance on what additional powers could be introduced; we consider that if the aim and desire of Government is to encourage the removal or reduction of recreational MPV use on unsealed roads in the countryside, especially in the protected areas, then we would conclude that the only realistic way to achieve this would be to introduce national legislation to this effect.
Exemptions should be built into any legislation for those who need to use these roads to access property/premises, and for emergency / mobility vehicles – much as many TROs currently do.
Please give us your views:
No comment
Not Answered
Not Answered
We support the government’s intention that our governance structure be carefully balanced in terms of democratic accountability, essential skills and diversity of experiences. With the exception of Secretary of State appointment of chair we are supportive of all other measures identified but we do not underestimate the challenges presented.
Yes
Yes
Yes
25 If you have any further comments on any of the proposals in this document, please include them here.
We support the detailed submission by National Parks England, submitted on behalf of this Authority and the other National Park Authorities in England. And we welcome the Government’s Landscapes Review and the value it has placed on Protected Landscapes and the recognition of the important role Protected Landscapes can play in national and globally significant issues such as biodiversity, and health and wellbeing.
Cultural Heritage
As a World Heritage Site as well as National Park we are very concerned by the lack of reference to the importance of cultural heritage within the government’s response. In our response to Question 7 we underline the importance that any amendments to these purposes should not be to the detriment of the existing purposes. Additionally in Question 9 we ask that government recognises the importance of culture within the new ELMs. Whilst we appreciate that cultural heritage may be outwith Defra’s key responsibilities we stress that it is imperative a more holistic approach is taken by government if Protected Landscapes are to be sustainably managed to inspire our future generations.
We welcome the proposal to reinvigorate Natural England’s role as DEFRA’s statutory advisor to support protected landscapes, better recover nature and provide good quality access to it, but the statutory purposes for National Parks are wider than this (specifically in respect of cultural heritage). Natural England is not our sole statutory advisor, particularly given our role as a World Heritage property. We also work closely with Historic England and DCMS. We ask government to ensure that any statutory adviser sponsors all aspects of the purposes and duty of Protected Landscapes and not just focus on their own narrow priorities, particularly ensuring nature and culture are equally valued, as in reality they often intrinsically linked. We welcome the proposal for Natural England to update their guidance on management plans for protected landscapes and hope the guidance recognises best practice for engaging and partnership working to deliver management plans fit for the 21st century. To supplement our support to Question 8, bullet 3 regrading monitoring; we are in agreement that monitoring is essential however it is important to highlight the issue of how monitoring is undertaken and by whom; monitoring of existing agri-environment schemes is too infrequent to ensure the conservation targets will be met. We would like to see an approach which empowers land managers, creates incentives for innovation and ‘stretch targets’ and involves land managers in monitoring with public sector or third party organisations to provide quality assurance. This approach will require investment in facilitation and skills development but has the potential for long-term benefits and more cost effective delivery.
Sustainable Transport and recommendation 19
Sustainable transport is a hugely important issue for our residents, businesses and visitors as the Lake District welcomes approximately 19 million visitors every year (and rising). We have been working with the Local Highway Authority, Cumbria County Council, to develop joint proposals reflecting Proposal 19 of the Landscapes Review, albeit we are concerned that Local Government Reorganisation here in Cumbria could disrupt this progress (we will share our joint proposal separately with Defra via the consultation email). The draft proposal identifies a number of desired outcomes that we are further exploring with Cumbria County Council, including:
We were particularly pleased that the Local Transport Plan for Cumbria recognises the heart of the Lake District corridor. One positive move forward to the benefit of all National Park Authorities would be for government to strengthen the requirement for transport authorities to consult NPAs to one of involve as recognised in Governments Response to the Landscapes Review.
Visitor Engagement and Management
We welcome the government’s intention to establish a national coordination function through the new national landscape partnership. However we are concerned the government’s response lacks ambition on this extremely important topic, including lack of commitment to investment in an expanded ranger services, a lack of promotion of “a night under the stars” or a similar venture, and lack of clear commitment to greater collaboration between the Protected Landscapes and the National Health Service. Whilst we appreciate this may be limited by resource availability we feel the government is missing the opportunity to underline the need to create Landscapes for Everyone.
Within the Protected Landscape bodies it is imperative that additional resources, including provision for infrastructure, are provided to support the additional scope to the mission for national landscapes at a local level. The Lake District has been at the forefront of welcoming increases in visitors post lockdown, whilst dealing with the impacts of such increases. In 2020, Cumbria formed The Tactical Visitor Management Group (TVMG), specifically to address the visitor management challenges of COVID-19 and to help facilitate post-pandemic recovery. It has worked tirelessly to support economic recovery and maximise the enjoyment of all visitors, including welcoming the change in visitor profile to one that better reflects wider society, whilst safeguarding Cumbrian communities. The management of these pressures has necessitated a diversion of the Authority’s attention and resources from other priorities which simply cannot be sustained without additional resource. One such example is our rights of way network which has experienced a huge increase in visitors, with visitors accessing more routes and in increased numbers. The strain of increased wear and tear on the rights of way networks risks impacting on the fabric of the landscape at a time when our Ranger resources are ever more constrained. Sustained capital investment is needed in visitor infrastructure, projects and programmes if relevant authorities are to improve opportunities and remove barriers for all parts of society to access the outdoors.
Experience from the past two years suggests, anecdotally at least, there has been a shift in visitor demographics and people from different ethnic groups, but there have also been significant decreases in young people undertaking residential and other education trips. As part of cost saving reviews, we have been approached by a number of consultants seeking to establish alternative uses for Local Authority Outdoor Centres. Such centres provide unique opportunities to connect young people with the outdoors. The loss of such outdoor learning opportunities for young people can be ill afforded if the second purpose is strengthened. It would clearly make a significant difference to the opportunity to visit the outdoors if society tackled exclusion due to poverty. The benefits of being outdoors for these communities is also disproportional, in this case providing positive experiences addressing matters of health and wellbeing.
Affordable housing/ second homes/ holiday homes
There is immense pressure on the existing housing stock in many areas of the Lake District resulting in a declining resident population that is also an aging population. In some settlements in the Lake District, as recognised in Simon Reeve’s recent documentary “The Lakes” in one village near Ambleside, just two out of 28 houses are lived in full-time. Therefore, in addition to policy and mechanisms to increase the delivery of new affordable homes the loss of existing homes needs to be controlled.
Our recently adopted Management Plan and Local Plan clearly highlighted the issue of affordable housing and the detrimental impact second homes and holiday homes are having on our working population and community vibrancy and vitality. We feel the Government’s response to the Landscape Review misses the opportunity to review primary legislation regarding the opportunity to address these issues. For example, the Welsh Government is considering proposals to amend the development management system and planning policy in Wales to help local planning authorities manage second homes and short-term holiday lets. They propose to amend the Town and Country Planning (Use Classes) Order 1987 to create new use classes for Primary Homes, Secondary Homes and Short-term Holiday lets. This change would create an effective mechanism to manage the loss of any further dwellings in protected landscapes. The Welsh Council tax changes are also an interesting initiative.
We ask government to consider amends to the planning legislation in England to split C3 (dwellings) Use Class into different classes thereby creating an effective mechanism to manage the loss of any further dwellings to holiday/second homes in protected landscapes unless planning permission is sought.
Our Members also request that Government remove the small business rates exemption for furnished homes in protected landscapes. The outcome of this would also contribute to more houses being made available for permanent occupation, or increase the revenue stream for local councils to spend in supporting local services and facilities to help maintain community vibrancy.
Affordable housing is delivered through public funding via the Affordable Housing Programme, administered by Homes England. However, the criteria for delivering shared ownership housing is not aligned with the Government’s position on delivering housing in National Parks as set out in The Circular and National Planning Policy Framework2. Homes England do not provide grants for Shared Ownership properties where a local occupancy condition exists, yet this local occupancy is critical to meet the housing needs for residents in the Lake District. We request that Government ensures Homes England funding is aligned to support housing developments that reflect local needs.
We are also concerned about the effect the Energy Performance Certificates (EPC) rating requirement is having on the private sector rental market as a number of our larger estates, who typically let older traditional properties associated with the local vernacular of the Lake District, are reporting that the Minimum Level of Energy Efficiency requirements is forcing them to consider transferring significant elements of their housing stock from private rental to visitor accommodation for holiday letting. We are concerned about the inconsistency of EPC rating requirement across our built environment and ask that the Government brings about equity across all buildings, as a minimum requiring holiday lets to have the same EPC standard as private rentals. We also seek to understand what further support Government can offer property owners of traditional properties to prevent the loss of more private rental properties as this will further exacerbate the affordable housing situation.
Planning reform
We welcome government’s acknowledgment that greater weight be given to Protected Landscapes. However we ask that the government’s position on permitted development rights should be stronger than “continue to monitor”, asking that they be reviewed in National Parks. Permitted development rights have the real potential to undermine our special qualities in terms of distinctive buildings and settlements. We are also concerned that we are experiencing increasing pressure to use non-local materials impacting on the appearance of traditional vernacular buildings and the character of settlements. We intend to explore this issue further through our involvement in the Design Code Pathfinder.
The LDNPA looks forward to working with the government to achieve these ambitions. We are confident we could go further and faster with appropriate resourcing.
