Local Development Framework Consultation

1.1 - 1.13 Introduction and Context

pp4-5

Neither support nor oppose - just want to comment

I appreciate the value of displays and officer supported events around the district to help inform this consultation process. However, given the strategic importance of this document for future SLDC development planning and given its length and complexity I feel the consultation period has been too short. I am particularly concerned that Parish Councils do not appear to have been automatically consulted as they would be for individual planning applications - and surely this present exercise is a greatly magnified equivalent.

As the Core Strategy continues to be worked on, ensure further fine tuning consultation with Parish Councils between now and final draft.

Adopted by the District Council

Submitted to the Secretary of State for independent examination

3.17 The Preferred Option - PO1 - Locational Strategy

p37

Oppose

I am concerned that Local Service Centres will be subject to undue development pressures because smaller rural settlements will not be taking their share of required population growth. This principle is likely to result in each LSC growing beyond its present attractive (and sustainable) character.

A more even apportionment of development between LSCs and smaller settlements should be laid down.

Submitted to the Secretary of State for independent examination

Adopted by the District Council

The Preferred Option - PO2 - Rural Areas

p46

Oppose

For the retention of the character of such smaller settlements it is vital that where infill would be on greenfield land it is not automatically viewed as a better option than the use of greenfield land on the outskirts. Sometimes green spaces among traditional buildings contribute as much to the character of a place as the buildings themselves.

Change PO2-2 wording to 'It is small-scale and, where appropriate, comprises...'.

Submitted to the Secretary of State for independent examination

Adopted by the District Council

2.16 - 2.17 Key Issues to be Addressed

2.16 - bullet 1

Oppose

The Regional Spatial Plan sets a guideline that 50% of Lakes and Morecambe Bay housing development should be on brownfield land. Figures for brownfield development are notably lacking from this Core Strategy. Indeed there are only two uses of the term 'brownfield' throughout the document. The considerable inroads into good agricultural or amenity countryside are a completely unacceptable part of SLDC's strategy.

The underlying principles for the whole strategy need to be reassessed in the light of the North West's brownfield guidelline.

Submitted to the Secretary of State for independent examination

Adopted by the District Council

3.69 - 3.78 PO4 - Balanced Housing Market - You Told us That & Introduction

3.69

Oppose

The Core Strategy's overall housing development target is 8,800 as compared with the figure of 7,200 in the NW RSS. Accepting that the problem of affordable housing is particularly acute in South Lakeland, this higher figure undoubtedly puts additional pressure on solutions acceptable to local communities.

It would be more realistic to compromise on the affordable housing target in order to ensure a level and rate of housing development with which the existing South Lakeland population would be more comfortable.

Submitted to the Secretary of State for independent examination

Adopted by the District Council

4.53 - 4.59 Policy Context and Justification

4.58

Oppose

Preserving the 'historic environment' which is acknowledged to be Cartmel's 'main attraction' does not depend solely on protecting the older heritage area of the village. The additional number of residents envisaged will put pressure on the village in all sorts of respects (e.g. size of primary school, size of village store, vehicular access to racecourse for recreation, busyness of main through roads, pedestrian access through non-pavemented area of village) which will affect safety within the village and the village's tranquillity within the context of the surrounding valley.
If 60% of the housing development is affordable, this itself will put greater pressures on local infrastructure issues such as schools and pedestrian safety. Moreover, the need for residents of affordable homes to travel to their employment - which may not be well paid - creates both an issue in terms of additional commuter traffic and of affordable travel. Much additional traffic will create very real problems on the Haggs Lane hill, lined with residential housing and concealed entrances, and in Grange Fell Road, lined with parked vehicles.
In addition more needs to be made of the countryside of which Cartmel is a part: protecting the natural environment, maintaining the tranquillity of the countryside and taking account of and enhancing landscape character and features are in their various ways, of course, all emphasised in the RSS as well as the Core Strategy.

The amount of housing being allocated to Cartmel needs to be reconsidered, along with its physical and visual impact on the surrounding area, of such importance to its attractiveness to tourists.

Adopted by the District Council

Submitted to the Secretary of State for independent examination

The Preferred Option - PO13 - Grange-over-Sands Functional Area 2025

p151 para 4.50

Oppose

Cartmel is referred to as both a village and a town within the same paragraph. While presumably an oversight, this may also reflect an ambivalence towards the place. Cartmel should be seen as a village and any proposed development planning viewed in this context. To begin defining Cartmel as a town can all too easily become the thin end of the wedge in deciding appropriate levels of new development.

Change 'town' to 'village'.

Submitted to the Secretary of State for independent examination

Adopted by the District Council

4.53 - 4.59 Policy Context and Justification

p161 Table 5 point 4

Oppose

As a general point I believe it is misguided to regard a single direction of growth as preferable in LSCs.
Specifically I strongly oppose the Pit Farm option as the only direction for growth in Cartmel. I fully appreciate points such as walking distance from amenities but there are a number of serious reasons for objection.
1. Visibility from Hampsfell and particularly the footpaths down towards the village. The issue of visibiliity from the surrounding countryside is cited in a number of other options (e.g. option 12 West Allithwaite p154). While existing development would screen the field from the roads at village level, much of Cartmel's charm to tourists is the way it nestles into its valley as viewed from the higher points to east and west. A large new development (50-90 houses between now and 2005?) would absolutely destroy this effect and no amount of screening would conceal it from these elevated positions. In any case Town End Meadow and Orchard Close, the eastern limits of the village at the present time, show no such attempt to screen - and the tight margins for a developer providing 60% affordable housing will not be conducive to 'unprofitable' landscaping and planting.
2. One reason for the choice of this site over the other Cartmel options is apparently the ready access through Orchard Close. However, this would be a disaster from a traffic and safety perspective. During commuter/school run hours the road onto which all the additional traffic would emerge is already congested, putting pedestrians and vehicles alike at risk. Frequent deliveries to the Spar store can be added to this picture - and presumably these will become more frequent or longer if the store's turnover increases significantly with a larger customer base. The consequent traffic chaos and danger make this option unacceptable.
3. Light pollution from streetlamps on the new development would be seriously detrimental to the impact of the street light-free nature of the historic part of the village - orange lighting among the newer houses is already compromising this feature.

It is vital that the pressure of the proposed extra housing, if it is to be, should be spread across at least three separate areas around the village. Option 5 on p153 and Option 6 p154 (the infill proposal near the campsite) would be far more discreet locations as viewed from Hampsfell/Howbarrow, would disgorge into different roads and would avoid the creation of a concentrated area of street lighting.

Adopted by the District Council

Submitted to the Secretary of State for independent examination

4.52 Alternative Options: Options 1-3

Option 3 pp153-4

Support partly

I broadly agree with the assessments set out under all the alternatives except for points 3, 9 and 12.

I suggest that a greater range of the assessed options are proposed as preferred directions of growth rather than the narrowing down which has taken place.

Submitted to the Secretary of State for independent examination

Adopted by the District Council

3.60 - 3.66 Policy Context and Justification

p57 para 3.62

Oppose

I strongly challenge the allocation of only 4% growth requirements to Kirkby Lonsdale at the expense of Grange and Milnthorpe. While I cannot comment in detail of the topography of Milnthorpe, surely it can be argued as strongly for Grange as for Kirkby that its environmental capacity for expansion is limited. Grange is a town bounded on the one hand by Morecambe Bay, on the other by Hampsfell and with important woodland to the north. Points 1-4 on p153 spell out how little room for manoeuvre the town has.

A more equitable distribution of development between these three Key Service Centres.

Submitted to the Secretary of State for independent examination

Adopted by the District Council

The Preferred Option - PO13 - Grange-over-Sands Functional Area 2025

p156

Oppose

While I accept that Grange must contribute to the need for housing and employment development, there seems to be insufficient recognition in the Core Strategy of the topographical and infrastructure difficulties of the town. I have commented on the former elsewhere. One significant infrastructure problem is that all traffic growth will be funnelled down Main Street without any feasible alternative route through or round the town. This growth will arise from Grange's regeneration as a tourist resort and so will not simply be proportionate to the expansion of the resident population in its functional area.

A realistic reduction in the development demands to be made of Grange between now and 2025.

Submitted to the Secretary of State for independent examination

Adopted by the District Council

3.17 The Preferred Option - PO1 - Locational Strategy

p37

Oppose

I feel that some of the premises on which this preferred option is based are unsound.
1. The definition of service provision gives equal weighting to six factors. But to suggest that a village hall or pub, important though they are as symbols of community, are as important as good bus links is a nonsense. Similarly open space if it means a playing field is of less importance where accessible open countryside exists. Other services could as easily have been chosen, e.g. train service, secondary school, post office, doctor's surgery. To require a LSC to tick five out of six of the currently suggested list of services is a very shaky basis for deciding settlement distribution.
The key services are surely public transport (bus or train), a primary school and a shop. The aim should be to apply criteria which ensure an expansion of the number of defined LSCs to help build a wider distribution of small but viable local settlements.
2. The preservation of green gaps seems to me a lesser principle than many other features of the district which we should be trying to preserve. There needs to be a significant reassessment of such gaps and whether the notional separation of settlements along a roadway (as opposed to preserved countryside away from the road) is to be enshrined in tablets of stone.
3. The definition of functional areas according to the rule of 1.5k distance between a LSC and a KSC is unsound. A longer distance from the centre to centre of each settlement is essential. It is of little use that Cartmel may be only 1.5k from the edge of Grange if it takes the same distance again to reach the library or post office or butcher's. The current definition adds pressure to the closing in of settlements to each other because it reinforces the idea that communities whose edges are close will operate more and more as a single functional community.

1. Review the services criteria. Apply them so as to increase the proposed number of LSCs.
2. Review the principle of green gaps and, if retained, rigorously question how vital each one is compared with the demands of other factors.
3. Replace the 1.5k principle with a centre to centre measure (centre being defined as that part of a town which offers a sufficient cluster of services, particularly retail).

Adopted by the District Council

Submitted to the Secretary of State for independent examination

The Preferred Option - PO13 - Grange-over-Sands Functional Area 2025

p156 & map p157

Oppose

The proposal to preserve the green gap between Allithwaite and Grange seriously inhibits Grange's necessary directions of growth. This area offers very suitable land for development and is of little importance as a 'green lung'. Moreover, ribbon development already lines most of the one side of Kirkhead Road and all the other side as far as Jack Hill. The important green gap between the two settlements is the whole Wart Barrow area. What happens along this stretch of road is of relatively little importance. Communities have sufficient ways to preserve their identity without physical separateness having to be retained as an immutable principle.

Abandon this green gap, or at least the portion of it south of the B5277.

Adopted by the District Council

Submitted to the Secretary of State for independent examination

4.52 Alternative Options: Options 1-3

Option 3 pp153-4

Oppose

Point 3. Is there not an area of land SW of Castle Head which is suitable for development?
Point 9. This area is certainly very suitable for development, being very level. The proposed extent could easily be increased by making the limit a line drawn west from the end of current housing on Wart Barrow Lane. This would not represent significant encroachment beyond existing development.
Point 12. I am not sure how and where from the issue of visibility is significant. Certainly the field north of Vicarage Lane and west of the church is very suitable for development. Further west beyond Boarbank Lane towards Boarbank Hall and Farm other small scale development could be sited.

Further review the locations referred to and increase the number of preferred directions of growth listed on pp160-1.

Adopted by the District Council

Submitted to the Secretary of State for independent examination

3.83 The Preferred Approach - PO4 - Balanced Housing Market

PO4 summary pp70-1 and related section generally

Oppose

The general feeling seems to be that the only need for additional housing in the Cartmel area is for more affordable housing for local people. In the Core Strategy affordability and local occupancy seem to be discussed as two related but separate issues. In fact what local people want is affordable houses for locals, not for incomers settling into the area nor indeed residents of the wider locality proposed in Option 5 p66. It is not evident on the ground in Cartmel that the local lower income workforce needs to be augmented by further incomers.

To get more affordable homes built, developers have to be permitted to sell other houses in a new development at a higher market price in order to make a reasonable overall profit. However, this dilution greatly increases the requirement for house building in any particular area - and still fails to fulfil the affordable housing need.

The Core Strategy (pp61 & 73) points out that 119% of all proposed housing development on the Cartmel Peninsula would need to be affordable to meet local needs. Even if all developments required a 60% affordability proportion, by 2025 still only half the number of affordable homes needed would have been built (approx 29 annually as against an annual requirement of 57).

So what happens in 2025 when the LDF is reviewed? A significant shortfall of affordable housing will still be identified – and this shortfall will be potentially even bigger if market demand in an area with a fixed stock of non-local occupancy homes will have pushed average house prices still higher. The argument will be for a similar level of annual development on into the distant future.

This is not a sustainable approach, either locally or nationally. p78 of the Sustainability Appraisal acknowledges this:

‘It is expected that some headway will be made towards addressing the affordable housing problems, however, it is recognised that this issue cannot be entirely addressed through the provision of affordable homes as the number of affordable homes needed per year (416) exceeds the total quota of homes to be built per year (400 under the draft RSS).’

In areas of high priced housing the problem of affordability is by definition that much more extreme. In Cartmel Peninsula Rural the multiple of actual to affordable house price based on median household incomes in 2006 was 4.7 (South Lakeland Housing Needs and Market Assessment Executive Summary p7). The income level is in reality the same in Ulverston but, because of lower market values the multiple is only 2.2. Affordability levels are thus far easier to deliver in Ulverston than Cartmel. Given that employment opportunities in the Cartmel area are limited, it makes far more sense to concentrate the affordability housing drive in the KSCs, from where – past evidence suggests – people will otherwise migrate to fill much of the affordable housing built in places such as Cartmel.

The whole basis by which the housing need statistics are turned into development policy needs to be revisited.
Other innovative solutions to achieving affordable housing need urgently to be explored - relying on the traditional approach of subsidised building developments is neither efficient nor effective.

Adopted by the District Council

Submitted to the Secretary of State for independent examination

3.83 The Preferred Approach - PO4 - Balanced Housing Market

PO4 summary specifically and the PO4 section generally

Oppose

I am concerned about the 'stickability' of practical policies to deliver affordable and local occupancy housing.

Firstly, is there a constraint which will ensure that housing made initially affordable by some modification of normal market mechanisms will remain equally affordable when subsequently sold on?

Secondly, will the Council be introducing a proactive system for assessing the local occupancy credentials of purchasers? The current reactive arrangement seems to rely on retrospective discovery, complaint by a third party, etc and is undoubtedly a weakened system as a result.

Mechanisms to ensure the delivery of sufficient affordable and local occupancy housing need to be clearly formulated and spelt out.

Submitted to the Secretary of State for independent examination

Adopted by the District Council

2.28 - 2.38 Strategic Objectives

General comment about strategic way forward

Oppose

The sacrifice that local communities are being asked to make warrants something more accountable than simply good intentions on the part of SLDC. In places there is a disturbing lack of convincing assurances in the Strategy where, for example, references are made to the problem of second homes, viability of the formulae governing developments, enhanced employment opportunities and improvements in infrastructure such as public transport.

Whatever the final planning detail set out in the Local Development Framework it will be vital that progress is monitored regularly (at least biennially). There must be built in room for manoeuvre in case intentions are not being fulfilled. Targets for reducing affordability/local occupancy need, the suitability of selected directions of growth, the sensitivity of development, the necessary infrastructure improvements, etc all need to be rigorously monitored.

Submitted to the Secretary of State for independent examination

Adopted by the District Council