Local Development Framework Consultation

Thank you for your recent consultation relating to the South Lakeland Local Development Framework Core Strategy Preferred Options document. Barrow Borough Council welcomes the opportunity to comment on this document and I hope that you find the comments useful. Due to Committee deadlines, however, the views expressed are Officer comments only. These will be presented to Members for endorsement at the Council's Executive Committee meeting on the 25 June 2008.

The Secretary of State's Proposed Changes to the Draft Regional Spatial Strategy was published in March 2008. As the Core Strategy Preferred Options document (the Core Strategy) was prepared prior to this, it is appreciated that it was prepared without sight of the Proposed Changes and it is anticipated that the Submitted version of the Core Strategy will be amended to better reflect the changes in terminology and strategy.

Locational Strategy
PO1 of the Core Strategy makes it clear that the location for new development and service provision should be guided by two main principles. Firstly, there is a settlement hierarchy of Principle Service Centres (PSC), Key Service Centres (KSC) and Local Service Centres (LSC) and secondly, allocations and development proposals should be directed towards previously-developed land within existing built up boundaries; where this is not possible then greenfield land within the built up boundaries may be considered and then finally, where neither of these options are possible, then greenfield extensions may be considered.

Principle Service Centres are not recognised within the draft RSS. The PSCs classified within the Core Strategy are Kendal Functional Area (incorporating Burneside, Oxenholme and Natland) and Ulverston Functional Area (incorporating Swarthmoor). Classifying these Functional Areas as PSC will have the effect of concentrating development within and around the settlements of the two areas. It is clear that Kendal and, to a lesser extent, Ulverston do differ from the remaining KSC in terms of their population, range of services and facilities as well as in terms of the populations that they serve. On this basis it is understandable that the two towns have an elevated status. However, raising the status of the settlements of Burneside, Oxenholme, Natland and Swarthmoor in this manner would effectively make them sequentially preferable to other Key Service Centres such as Grange and Kirkby Lonsdale.

I am not convinced of this approach, particularly in relation to the scale of development likely to result in the smaller settlements which I consider would conflict with the principles of the RSS. This approach, which elevates some Local Service Centres (LSCs) (as identified in Appendix D) to the status of PSC and then elevates other LSCs to the status of KSC as part of the Functional Areas of the identified KSC of Grange and Milnthorpe is somewhat confusing.

In practice, this appears to mean that proposals for new housing and employment development will be directed firstly to the settlements of Ulverston, Kendal, Natland, Burneside, Oxenholme and Swarthmoor, with edge of settlement locations in these towns and villages being the next sequentially preferable location.

Housing Development

PO3 of the Core Strategy sets out the scale of new development that would be allowed throughout the plan area up to 2025. The distribution of development reflects the preferred locational strategy set out in PO1 and therefore the PSCs are earmarked for considerable growth. The UFA is allocated a total of 20.5% of the overall requirements for housing and employment as set out by the RSS and in its crudest form this equates to a total of 28 hectares of housing land to accommodate 1804 net additional dwellings, and 20 hectares of employment land.

Specifically in relation to housing, PO4 of the Core Strategy suggests that in order to achieve a balanced market;

"Policies will integrate the plan, monitor and manage approach into the Core Strategy to ensure a continuous supply of residential land in line with the requirements in PO3. Measures will include the phasing of allocated land to ensure that allocations deliver the housing requirement. In a situation of oversupply or potential oversupply, policies will seek to control the release of unallocated sites (windfall
sites) or allocated greenfield sites."

This suggests that in order to avoid oversupply, there may be a situation whereby the Council would refuse applications on allocated sites or on unallocated sustainable brownfield sites should suitable, although not necessarily preferable, unidentified sites come forward first. Although the advise of PPS3 is noted, by not allowing for windfall sites within the calculation of the housing figures when this is likely to represent a significant contribution to supply (no figures are given in your AMR but this is considered likely to be the case), there is concern that this approach would be difficult to manage and is likely to result in an oversupply. An allowance for windfalls would not only be more realistic, but would limit the amount of greenfield land required to be allocated for housing development.
Given the preferred levels of distribution set out in PO3, the Core Strategy suggests that it will be necessary to significantly encroach into the open countryside around both Kendal and Ulverston for employment and housing development. As there are usually less constraints associated with the development of greenfield sites as opposed to previously-developed sites, it is likely that the greenfield sites identified in the Core Strategy would be pursued ahead of brownfield allocations and at the expense of previously-developed sites that inevitably will become available during the lifetime of the plan.

The scale of the greenfield extensions to the settlements indicated within the Core Strategy, the close relationship that the UFA and Barrow Borough share and the potential for oversupply, means it is possible that allocated greenfield sites and/or freestanding development sites may be pursued at the expense, not only of previously developed windfall sites within UFA but also of previously developed sites within Barrow Borough. This would conflict with the draft RSS and the findings of the Secretary of State in the Proposed Changes to the draft RSS which states at paragraph 7.21;

'Where housing market areas cross administrative (and in some cases
regional) boundaries, or where major disparities in levels of previously developed land exist between neighbouring authorities, cooperation and joint working will be necessary to ensure that sites are released in a way that supports sustainable patterns of development. The Local Planning Authorities involved should take care not to either pursue Local Development Framework Allocations or else grant planning permissions that result in over provision and early release of land in one district to the detriment of urban renaissance either in the same district or in other Local Authority areas. Where a particular a particular district has insufficient, sustainable sites that match the above criteria to meet their target, they should consider working with their neighbours to find ways of meeting the balance elsewhere in the sub region.'
In accordance with regional policy, Barrow Borough Council is in the process of implementing a Housing Market Renewal initiative and Regeneration projects. The two primary areas identified as regeneration opportunities for Barrow Borough are Barrow Town Centre and the Barrow Port Area, for which the Council is currently preparing Area Action Plans. The Barrow Port Area Action Plan (BPAAP) will include significant allocations of land for housing and employment uses to assist in meeting the Borough's previously developed land target of 80%, which is significantly higher than South Lakeland's target.

Employment Development

The general approach to housing development is also applied to employment development and although PO5 reiterates the sequential approach set out in PO1, it is clear from the Area Strategies that the majority of land necessary to meet with the requirements set out in PO5 will be met by greenfield extension to settlements.

PO5 of the Core Strategy seeks to establish a local strategic employment site in the Kendal area to meet a significant proportion of the employment land need. Clarity is sought as to how the sequential approach, which is set out within PO5, will be applied. It would appear that the three areas specified within PO5 (town centres, existing urban areas and sustainable urban extensions) directly relate to the settlement hierarchy set out in PO1. If this is the case, then the search for a local strategic employment site would not be limited to Kendal town but would include the surrounding villages that form the Kendal Functional Area and these would have preference, in policy terms, over and above sites located directly at the edge of Kendal town or on the edge of each of the villages identified. However, PO11 doesn't acknowledge this sequential approach and clearly requires the development of a new locally strategic business employment area at Shenstone. Requiring the development of a specific freestanding site appears to undermine the principles set out in PO1 and PO5.

Lindal-in-Furness

PO17 of the Core Strategy indicates that Lindal-in-Furness would be suitable for expansion to accommodate both new residential and new employment development. However, the key diagram that illustrates the broad location of new development and the type of development preferred, suggests that it is specifically new employment development that would be sought in this location.

The village enjoys a number of facilities and services including two public houses, a shop, a primary school and a regular bus service. Its identification as a Local Service Centre is unlikely to prejudice this Council's findings with regard that part of Lindal that falls within Barrow Borough. However, its suitability for growth, particularly in relation to new employment uses is questioned.

The assessment of development required in Lindal and any subsequent identification of sites should be a joint matter for South Lakeland District Council and Barrow Borough Council to agree together to ensure the most appropriate sites are identified. These should be allocated within a site allocation DPD.

General Comments

With regard to housing and employment development, a large number of specific preferred locations have been identified in the Core Strategy (e.g. Shenstone near Kendal for employment, Ulverston Canal Head for Employment and Croftlands near Ulverston for Housing). Whilst approaches to the scope and nature of Core Strategies vary, with some Authorities identifying broad strategic locations for development in these documents
- an approach which has been accepted by the Secretary of State, this approach is not generally supported by this Council unless the sites are of such significance as to be fundamental to the delivery of the Core Strategy as a whole.

It is considered that identifying sites at this stage prevents the proper consideration of the suitability of the sites and any alternatives put forward through the later Site Allocations DPD or Area Action Plans. Respondents would be at a significant disadvantage, as alternative sites would need to conform to the Core Strategy - that is if the preferred sites had not already been granted planning permission on the basis of their identification in the Core Strategy. Despite the statements that the Core Strategy is not 'outlining specific sites', Policy PO11 for example, clearly seeks to allocate the land at Shenstone for employment use. Other such Area Strategy policies such as PO12 clearly identify sites, if not precise boundaries. This approach is certainly not supported for smaller sites, the identification of which is not considered appropriate for a Core Strategy.