20 January 2023 Complaint about South Lancaster Area Action Plan Consultation

Over Christmas I struggled to make sense of the South Lancaster Area Action Plan topic papers. Eventually I decided that it was not fit for purpose and sent this complaint to Mark Davies, Lancaster City Council CEO on 9 January 2023

My complaint

Dear Mr Davies,

I am writing this complaint in exasperation after 6 years constructively responding to every other Local Plan and Bailrigg Garden Village consultation, speaking at Local Plan Hearings and helping others put together responses to consultations. I am a resident of Chapel Lane Galgate, and founder member of the campaign organisation CLOUD. We advised our members to engage with the South Lancaster Area Action Plan (SLAAP) consultation as soon as it was announced. Having done battle over Christmas with the 6 topic papers I feel a deep concern that the consultation is not fit for purpose because of the way it has been constructed and the time commitment required. This concern is set against a 6 year background of difficulties with the South Lancaster proposals.

My concerns relate to:

1. The onerous nature of the Planning consultation which is daunting and unclear in its purpose, at least to the layman, after years of unsatisfactory consultation on Bailrigg Garden Village See Appendix 1 Bailrigg Garden Village Consultation Timeline

2. Secrecy surrounding the terms of Housing Infrastructure Fund (HIF) grant not mirrored by other Local Authorities.

3. No discussion or consultation on 9185 houses linked to the HIF bid - first announced in March 2020 Treasury Statement; no press release from either City and County, no discussion or explanation until August 2021 when dismissed by a senior Council officer as merely the ‘business case’ for HIF.

4. The contradictions between the South Lancaster Growth Policy and Lancaster City Council’s declaration of a Climate Emergency

5. The financial risks

1. The onerous nature of the Planning consultation which is daunting and unclear in its purpose, at least to the layman, after years of unsatisfactory consultation on Bailrigg Garden Village

In the winter of 2021 members of the public were so frustrated by the Bailrigg Garden Village Master Planning process that they launched a petition to Lancaster City Council which very quickly attracted 718 signatures

The petition was not about stopping Bailrigg Garden Village. Instead petitioners called for Councillors : to withdraw the consultation on Bailrigg Garden Village Masterplan currently being undertaken by JTP Architects and to put in place a consultation process which properly addresses the objections of local residents.

On 24 March 2021 the Full Council unanimously agreed that the subsequent South Lancaster Area Action Plan should include structured questions and provide feedback to those registering comments/objections’

Full details of the petition and the speech are available here. This is a report on the decision

The current consultation does not address the essence of those concerns. The 6 topic papers alone amount to around 240 pages of jargon rich and often confusing description. Do the Planners genuinely believe that members of the public have the time to read and make sense of this volume of material before then completing detailed questionnaires for specific topic(s)? The 4 minute introductory video, whilst attractive, gives no real introduction to the topics or how to interpret them.

The public have certainly been provided with ‘structured questions’ in each of the questionnaires for the 6 topics. But the language of the texts is verbose and hard to engage with. The following is an example from the Transport section. It reads more like an unpunctuated examination question for someone doing a Master’s Degree in Planning, than a request for views from local residents:

Question T2.1: Do you feel the evidential basis towards transport and highways described in this section represents a logical approach to the assessment of implications of proposed development within the ‘Broad Location for Growth’ and establishing the Council’s ambitions around the delivery of modal shift? If not, please explain the rationale to your answer.

Over Christmas I received an email from a retired, senior professor asking what he was supposed to do with the SLAAP consultation which he found almost unintelligible, hardly a sign of consultation that was encouraging engagement . Set against a background of 6 years of ‘consultations’ where members of the public took the trouble to respond but were apparently not listened to, this is deeply frustrating - See Appendix 1 below - the Bailrigg Garden Village Consultation Timeline for details.

The objectives of the current exercise are not clear. At the 2019 Local Plan Hearings much was made of Bailrigg Garden Village being put aside for detailed discussion and shaping in the South Lancaster Area Action Plan. So everything from the Garden Village, to the Cycle Superhighway, to public transport plans, to the re configured Jt 33 was ‘aspirational in 2019. 3 years down the line and much is still aspirational.

I was especially interested in the topic entitled Travel Transport and securing a modal shift.

Reading it I was reminded of a speech in the Local Plan Hearings of May 2019. It was given by a Parish Council Chair who was also a cyclist. He spoke of his enthusiasm for the idea of a ‘Cycle Superhighway’ but asked how were cars and cyclists going to be separated given the A6, through Scotforth, is lined by Victorian houses without parking, and asked which houses were going to be demolished. The reply from one of the Planners was ‘It is aspirational’. The impression remains of aspiration rather than reality for the whole of the 40 pages about transport. In 2019 Highways England observed : “there is no robust transport evidence to demonstrate that these forms of sustainable transport infrastructure and services will provide the necessary modal shift to achieve the sustainable movement of people and goods, particularly in relation to the level of proposed growth in South Lancaster.”

There are many words but few pieces of hard evidence to explain how and when this desirable shift will be achieved.

QUESTION How will this be funded given the HIF money was for road only (and then at 2019 prices before the current high rate of inflation) and included no funding for the cycle superhighway or bus rapid transit?

QUESTION

Could you let me know whether you agree that they are too verbose and lengthy for Lancaster residents to have any chance of understanding them?

QUESTION Is the issuing of topic papers suitable for public consultation on what the Council Leader has described as the most important decision facing the City in a generation. Should not the Council be arranging public meetings as with the Local Plan back in 2017?

2, Secrecy surrounding the Housing Infrastructure Fund (HIF) bid

The lack of consultation surrounding Bailrigg Garden Village is also reflected in the extreme secrecy surrounding the bid. This does not seem to be mirrored in nearby Carlisle, where there is also planned garden village and a HIF bid. There the determination agreement with Homes England is publicly available. Clearly this is a decision made by both Cumbria County Council and Carlisle County Council.

QUESTION Why is documentation of this sort not readily available for the Lancashire/Lancaster Bid?

3, No prior discussion or consultation regarding the 9185 houses

Perhaps the biggest breach of public trust came in March 2020 when the following announcement appeared in the Treasury statement for the government’s budget:

£140m from Housing Infrastructure Fund for South Lancaster Growth Catalyst which will unlock 9185 houses.

QUESTION Why was there no public consultation on this fundamental shift away from the Local Plan?

QUESTION Why was there no press release either by Lancaster City Council or Lancaster County Council in March 2020?

QUESTION Why did this only become openly discussed during the summer of 2021, shortly before the vote on the Collaboration Agreement between Lancaster City Council and Lancashire County Council?

4. The contradictions between the South Lancaster Growth Policy and Lancaster City Council’s declaration of a Climate Emergency

A recent article in the iNewspaper on 27 December 2022 had the strapline Campaigners say they fear councils are not taking their climate commitments seriously as many continue to support high carbon - Here is link. The article goes on to identify Lancaster as just one of those councils:

Lancaster City Council - Declared a climate emergency in 2019 and has a target for the council to become net zero by 2030. In 2021, the council approved a masterplan for 9,000 new homes south of the city. The project will involve a remodelling of the M6 and the building of new roads. Critics have said the development makes a “mockery” of the council’s climate commitments and will lead to more cars on the road.

QUESTION How can the City Council justify this anomaly?

5. Financial Risks

Given exceptional and unpredicted inflationary pressures over the last year or so, with construction materials being particularly badly affected- with some estimates of rises of up to 27%, the financial risks seem exceptionally high.. The HIF bid depends on a roof tax to be paid by developers based on 9185 houses to cover the original £98M shortfall, a figure that has now risen substantially with inflation and continues to rise..

QUESTION How will rising Council tax or cuts to other developer obligations be avoided,at a time of inflationary pressure and financial difficulties for Councils?

I very much look forward to hearing from you.

Yours sincerely

Mary Breakell

Appendix 1 Bailrigg Garden Village Consultation Timeline