Local Development Framework Consultation

South Lakeland Core Strategy Preferred Options Consultation

Thank you for the opportunity to comment on the above document. The following represent officer level comments on the consultation.

I would like to take this opportunity to inform you of the current situation regarding the Regional Spatial Strategy. As you are aware the Adopted RSS Regional Planning Guidance for the North West (RPG13) now forms an integral part of the development plan and should be given due consideration when assessing planning applications. In addition the Submitted Draft Regional Spatial Strategy for the North West of England has now undergone a number of periods of consultation, with an Examination in Public which ended on the 15th February 2007. The panel report was published on the 8th May 2007 and the Proposed Changes (RSS) prepared by Government Office North West (GONW) were published in March 2008 . As the document is now someway progressed in towards its adoption, it should also be given consideration when assessing planning applications.

You will be aware that the Assembly previously commented on the Issues and Options Stage of the Core Strategy in January 2006 and February 2008, which I have attached for your reference.


PO1 - Locational Strategy

Since we made previous comments on options and informal preferred options the policy context has changed, given that RSS is unlikely to name Key Service Centres. The criteria based approach which is set out in the proposed changes gives more 'flexibility' to authorities to identify Key Service Centres. We previously made comments about concerns that the inclusion of functional areas would not ensure that the majority of development is focused towards the principal or key service centre. However considering PO3 and supporting text alongside PO1 would address those concerns. We note that there is a clear focus development in the main centres.

While this approach is somewhat consistent with policy DP1 of both Adopted and Submitted Draft RSS, In previous responses you will note we have drawn the councils attention to the fact that the EiP panel report recommended a number of quite substantial changes to Submitted Draft RSS policy DP1, including an enhanced sequential approach to development.


PO2 – Rural Areas
In the Assemblies previous response we have offered support for a combination of option 2 and 4, however we note that preferred option being taken forward is a combination of option 1 and 4. The NWRA can broadly support the preferred option which allows development in rural areas to meet local need within tightly defined criteria, but it is unclear how infill or rounding off development referred to in the policy will be defined without settlement boundaries being defined. Please note that the policy builds on the rural exception sites concept which is supported in Policy L6 in GONW Proposed Changes published in March 2008.

The Assembly advise that where paragraphs 3.48 outlines that 100% affordable requirement will apply on sites over 10 dwellings, is policy text and should appear in the policy section rather than in the supporting text. The same applies to the following paragraph.



PO3 – Distribution of Development

You will note that in previous responses the NWRA have raised concerns about the use of functional areas and ensuring the differentiation in scale of development taking on board the capacity or areas to accommodate development. The preferred option appears to address these concerns and clearly focuses development on Kendal, Ulverston, Grange and Milnthorpe, and to a lesser extent Kirby Lonsdale.


PO4 – Balanced Housing Market

The Assembly have recently identified 27 Housing Market Areas in the North West. South Lakeland DC is covered by three of those HMAs - Central Lakes, Dales/Rural Kendal and Ulverston/Cartmel. The HMAs were based on a range of evidence, and on the previous 20 HMA boundaries identified in Cumbria. We are happy for sub-regions and Local Authorities to further subdivide the 27 HMAs identified at the regional level to better reflect local variations.

Emerging work being undertaken for the Assembly, assembling a regionally consistent set of Strategic Housing Market Assessments is beginning to show a significant shortage of affordable housing in the three HMAs which cover SLDC. Therefore support high percentage requirements and low thresholds for affordable housing provision, alongside the consideration of viability of development.

We would like to state that the NWRA broadly support Policy PO4 and also please note the approach to affordable housing also appears to be broadly consistent with Adopted RSS policy UR9 and Submitted Draft RSS policy L5.

However you should be aware of the changing policy context on housing figures. The Assembly is currently carrying out a Partial Review of RSS which will cover a number of issues including revised housing figures. This Draft RSS will be developed over the next 12 months and is due to be submitted to the SOS in June 2009. See www.northwestplanpartialreview.org.uk for further details.


PO5 – Sustainable Economy

This preferred option does highlight the range of employment land and market sectors required over the plan period in line with EC1 (RPG 13). However clear definitions of employment land could ensure that adequate supply and amount of in the right locations was provided for the different market sectors and ensure consistency with EC2 and EC3, EC4, EC7 and EC8.In line with EC1 and UR5, this preferred option should highlight the need to undertake a review of existing commitments of employment land.

The site is some distance from Kendal and would appear to require significant investment in infrastructure. Without a thorough assessment of all the potential alternative sites it would not be possible to confirm whether the site satisfies the most sustainable location for development of such significance.
None of the other locations considered are particularly well related to the existing built up area and would require significant investment in infrastructure. The LPA should give a full assessment of all potential strategic locations within the site allocations DPD.

To improve consistency with WR3, it should refer to a comprehensive review of commitments to qualify that the right sites at the right location will be identified and to be consistent with W4, we would also welcome the indication of where sites are to be de-allocated consideration should be given to a range of alternative uses.


PO6 – Town Centres and Retail Strategy

Policy W5 in (draft) RSS (Retail Development) , states that investment in the centres not identified within the policy (of which only Kendal is) will still be encouraged in order to maintain and enhance their vitality and viability, including investment to ensure that centres meet the needs of the local community, as identified by Local Authorities. However we would like reiterate our earlier comments that the council need to be satisfied that the development proposed outside the Key Service Centres originally identified with draft RSS (and indeed within them) are of an appropriate scale and nature to the size and function of that settlement.

P07 – Green Infrastructure

The Green Infrastructure Guide has now been published for the North West , the Guide provides a detailed definition of green infrastructure, as outlined in Policy EM3 of the Submitted Draft RSS. The guide offers broad advice on how to plan and enhance green networks.

The policy is broadly in accordance with Policy UR10 of the Adopted RSS, which provides a policy framework for green infrastructure. There are a number of Submitted Draft RSS policies which would also offer further support to the document, in particular policy DP1, EM1 and EM3.

PO8 – Accessibility and Transport

PO8 is inline with the transport policies with ion draft RSS. However in order to improve consistency RT2 within the draft RSS, Policy PO8 should include reference to maximum parking standards which are included in the RSS.

P09 – Development Management Framework/Sustainable Development Principles

PO9 states that only a % of homes will be required to meet lifetime homes standards. The NWRA have objected to the (GONW) Proposed Changes of RSS around Lifetime Homes standards in light of the new National Strategy for Housing in an Ageing Society, which has an aspiration for all new homes to be built to lifetime homes standards by 2013.


PO21 Education and Skills

To be consistent with L1 (Draft RSS) the provision of facilities should be based on strategic assessment of demographic needs in local communities

PO22 Community Well Being

To be consistent with L1 (Draft RSS) the provision of facilities should be based on strategic assessment of demographic needs in local communities


I hope this is of assistance. If you require anything more then please contact me.