Local Development Framework Consultation

With reference to the Plan, I would like to point out that sufficient attention has not been paid to the issue of potential flooding, due to a unique combination of natural drainage channels in the underlying limestone, local topography, the coastal railway embankment preventing surface rainwater run-off from flowing into Morecambe Bay and the lack of spare capacity in the Victorian combined sewer. This information needs to be added as does a requirement for a comprehensive hydrological survey to confirm that future developments will not cause or exacerbate flooding.

Secondly, there is no mention of the need to improve traffic flow in the town centre. The provision of a one-way system perhaps and/or imposition of weight restrictions for through traffic should improve traffic flow and parking and should be an essential part of the PLan, given the huge burden that will be placed on present infrastructure by the addition of so many new houses/businesses, not to mention the present infrastructure's potential to cause a number of traffic and pedestrian accidents.

Thirdly, why is there no mention of the reinstatement of Berner's Bridge? A recent report to SLDC identified its reinstatement as essential for the success of any Lido project, an amenity which would enhance the tourist potential but would also benefit residents. Many of us residents contributed considerably to the new swimming pool, only to see it close in a ridiculously short time and for houses to be built instead.

Janet Eccles

I would like to suggest the inclusion of the following item in the transport section of the plan.

1. Make Kents Bank Road one way (travelling from West to East) between the Park Road Junction and the Pig Lane Junction. On road parking to be restricted to the left hand side of the road only to ensure drivers have good visibility when pulling out of parking spaces.
2. I believe that this change would improve traffic flow on Kents Bank Road for residents visiting the shops on this road.
3, Traffic traveling from East to West that would currently use Kents Bank Road would still be able to use Pig Lane, The Esplanade and Park Road in future.
4. I believe that West to East would be the best one way alternative as pulling out of Kents Bank Road onto Park Road is difficult due to the need to look back over your left shoulder at a sharp angle for Westbound traffic.

Thank you for you consideration of this suggestion.

Peter Gould

[SEE ATTACHED DOCUMENT]

The Local Development Framework Core Strategy Document adopted by SLDC in October 2010 said this of Grange-over-Sands:

‘5.13 Grange-over-Sands is a highly walkable and compact town. However it suffers from problems associated with the impact of the private car on the built environment. For pedestrians, the Grange-over-Sands environment is noticeably poor. In general terms, footpaths are narrow and there is a strong sense that the car is the dominant feature on Kents Bank Road and Main Street. Improving linkages, infrastructure and the quality of the pedestrian environment are key priorities.’

‘5.26 The area strategy for Cartmel Peninsula aims to address the following challenges:
Improving the quality of the pedestrian environment is a priority for Grange.’

‘5.32 Given the problem of town centre congestion in Grange at peak times, it is imperative that improvements are made to reduce dependency on private car use. Significantly higher traffic levels could well threaten the core economic activity of the town, namely tourism. Developers of major sites will be required to contribute to the improvement of local bus services, with the aim of providing good quality integration between modes and services.’

‘Cartmel Peninsula Tomorrow – The quality of the pedestrian environment in Grange-over-Sands has improved, including...the town centre.’

‘How we will get there – The Council and its partners will aim to improve the pedestrian experience of Grange town centre.’

As it is now over 7 years since the Core Strategy was adopted it is pertinent to ask what action has been taken to improve the quality of the pedestrian environment in Grange as a key priority. The answer is – absolutely nothing. In fact the situation as described in 2010 has only been exacerbated by the increase in private cars associated with 149 additional households across 3 new housing developments. Neither is there any evidence of improvements to local bus services funded by contributions from any of the 3 developers.

So what is the town centre environment for residents and visitors?
Significant stretches of Main Street and Kents Bank Road have all the visual attraction of a badly planned linear car park.
Traffic flow through the town is regularly disrupted both by vehicles attempting to parallel park in the on-street parking bays or having to negotiate badly parked and oversized vehicles obtruding into the roadway. Pedestrians in their turn are subject to a barrage of vehicles manoeuvring at low speed creating higher levels of pollution. As a pedestrian it is often necessary to take evasive action to avoid vehicles mounting the pavement. This latter problem can impact particularly on those less mobile or with young children.
The situation in Kents Bank Road with the combined effect of two-way traffic, on street parking bays and narrow pavements is particularly chaotic as anyone who has travelled through Grange by bus will have experienced. On at least 2 occasions I have been brushed by moving vehicles when walking on a narrow stretch of pavement in Kents Bank Road.

The GOSNP acknowledges that there is a problem:

‘Objective 2. Improve town centre safety and accessibility for non-car users and those with mobility problems.’

‘2.2.5 Within the town, the pedestrian experience and quality of the built environment has suffered as a result of the impact of greater car usage.’
‘3.3.1 The SLDC Core Strategy states the importance of...improving the pedestrian experience in the town centre.’

‘4. Challenges – The pedestrian experience and quality of the built environment has suffered as a result of the impact of greater car usage, and access into and through the town itself is limited due to the geography’.

With the problem identified it is disappointing to note that the GOSNP is noticeably devoid of any practical proposals to provide a solution. Indeed in contrast with the vision for ‘Cartmel Peninsula Tomorrow’ in the CS document the GOSNP does not make mention of an improved experience for pedestrians in its 4.2 Vision for Grange. Section 5.1.8 refers to ‘A “joining up” of the two distinct shopping areas’ with no suggestion as to how this could be achieved.

Challenging problems require radical solutions and one thing that would improve the town centre experience for residents and visitors alike would be a radical and imaginative traffic management scheme. This could include, but not be limited to:

1. Extending the existing one way system to create a clockwise circulatory route along The Esplanade and Kents Bank Road.
2. Abolishing all on street parking bays with the exception of a few strategically sited for mobility users.
3. A combination of the above would facilitate the widening of pedestrian pinch points and restoring our pavements for the exclusive use of pedestrians etc.
4. Transforming the section of Main Street from Crown Hill to the junction with Kents Bank Road into a paved traffic free zone with appropriate provision for exempt vehicles.
5. Imposing a 20mph speed restriction through the town centre.
6. Imposing a weight restriction through the town centre.
7. Transforming Main Street from the junction with Windermere Road into a continental style paved shared space with appropriate restrictions and parking exemptions.
8. Extending the continental style shared space to include Kents Bank Road to the junction with Cross Street or even Park Road.

My vision for Grange is a town centre through which traffic flows freely at a safe speed with low levels of pollution, where I can walk safely along a pavement without having to avoid road traffic or badly parked vehicles and where I can enjoy the amenities of our conservation area without feeling that I am in the middle of a linear car park.

Ken Taylor
Grange-over-Sands
17.2.18

I note that the English Coastal Footpath to and through Grange does not appear to have been included in the documentation and or commented on, I debate this is unsatisfactory.

Currently, Natural England are unfortunately recommending that it will only be in place from Grange Railway Station westwards, and not eastwards up to Levens Bridge.

Re local environmental/walking interest and those of visitors it could be debated that this is not in the best neighborhood interest.

Please notify me

RE: Grange-Over-Sands Parish Neighbourhood Plan, Submission Version September 2017

The Brookhouse Group is a north-west based property developer, with a series of active developments in Cumbria and nationwide. We have a development agreement in place with the landowners of the Kents Bank allocated site, and have held pre-application meetings with both SLDC & CCC (as LPA and infrastructure consultee) and the Neighbourhood Plan (NP) Steering Group (GOSNPSG) in respect of the Kents Bank site. It is in this regard that we submit the following comments to the consultation on the above.

Representations were submitted by Garner Planning in June 2016 on behalf of the landowner, and we are disappointed that points therein have not been responded to this latest draft. As such, and in the interests of keeping Inquiry submission documents to a minimum, we would iterate that that representation remains valid.

In addition to this however, we would make the following broad observations:

• Housing need & mix: we recognise the GOSNPSG’s informed opinions on these very complex issues, and in meetings with their representatives, including the Chair, we have agreed to work with these issues. But we must re-assert the very serious issues that arise from overly prescriptive policy on these matters: need and mix are very complex, and regularly changing issues. The NP is already based on data that is 7/8 years old (the Core Strategy and the Census), as well as data that is not officially recognised in the formulation of housing needs assessments (local surveys). The NP is due to be valid for another 9 years (at which point it would be relying on 17 year old data). Instead, the plan must be able to respond to changing circumstances. Being overly prescriptive could undermine the delivery of any housing at all, let alone the housing the NP seeks. Instead, the NP’s aspirations should be explicitly set out as aspirations, and the NP policy should instead explicitly defer to the most up to date data available at the time development is proposed: be that SLDC data, or robust data presented by the developer, etc. The NP aspirations would then become a material consideration to inform the LPA. Government is quite clear that town planning (including neighbourhood planning) must be Development Plan led.

• Employment: we recognise and applaud the aspirations to bring meaningful additional employment to the area. We have discussed this at length with the GOSNPSG, and understand that that group recognises and supports the provision of employment across a range of different types, including within retail, and within care facilities; such uses can provide the employment that the GOSNPSG seek, including roles from skilled to unskilled, part and full time, etc. The need for retail and care facilities is clearly recognised by the GOSNPSG, and the NP should explicitly state that employment can be generated by a number of sources, including retail and care home facilities.

• Extra-Care Housing: there is strong evidence to suggest that there is a market for the delivery of extra care housing in the NP area, and that the demand is likely to increase. The NP however should be careful however not to preclude its delivery in the NP area by explicitly prioritising one site, as per policy 9. We have no concerns the GOSNPSG expressing a desire to see this site come forward for this use, but this aspiration should not be at the expense of other sites where this growing need could be met. The NP should explicitly recognise that care facilities can be delivered elsewhere in the NP area.

• Design Guide: enclosed with this representation are specific comments on the Guide by our architect. In addition, we enclose the Urban Design Framework that has been worked up for the Kents Bank site, and presented to GOSNPSG (and to the LPA) at our most recent meetings: it would be helpful if this graphic were included within the NP, as a meaningful response to the Development Brief and the NP.

We would be grateful for the consideration of these representations, and we would record now our intention to appear before the NP inspector, in due course.

Kind regards,


Tom Whitehead MRTPI MCIPR
Brookhouse Group
Group Town Planning Manager

Please notify me

[SEE ATTACHED DOCUMENT]

[SEE ATTACHED DOCUMENT]

Note: The response letter is purely to highlight any major hazard risks within the Neighbourhood Plan boundaries at an early stage that may impact on any further potential development – in this case a major accident hazard pipeline.

South Lakeland Borough Council should be aware that when a development with specific sensitivity levels does encroach on a major hazard or pipeline they obtain HSEs advice by using the WebApp (as explained in the letter).

Thank you for the opportunity to comment on the above consultation document with regards to Grange-over-Sands proposal for a Neighbourhood Plan.

I can inform you that Highways England has no objection to this proposal and have no comments therefore to make at this time.

Please feel free to contact me if I can provide any further assistance.

Kind Regards

Lindsay
Lindsay Alder, Assistant Asset Manager

[SEE ATTACHED DOCUMENT]

As a person who worked in Grange for over 20yrs and still has an interest as a joint owner of Lime Kiln Wood, I think the plan as a whole is very well focused on the needs of the townsfolk and the new wave of commuters and retirees. My interest as a Walking for Health volunteer and lifelong environmentalist is the lack of reference to the natural assets, the hills and woods of Windermere Road and Lindale Road. Both roads are lethal to walk along because of the lack of footways on long stretches. There should be safe walkways to Lindale by either route, giving access to Eggerslack, Brown Robin and Lime Kiln Wood. A footpath link between these woods is a sensible aspiration which could be added to the plan. For our part as a trust dedicated to enhancing wildlife and public access we would be happy to work with the local authorities to bring it about. At the moment I believe the draft plan has concentrated too much on the field and copse at Kents Bank.

Please notify me

Thank you for consulting Natural England on Grange-over-Sands Neighbourhood Plan. We have no comments to make.

Kind Regards

Kate Berry

Sustainable Development Adviser
Sustainable Development and Marine Team
Cumbria Area Team
Natural England

As you are aware Network Rail is a statutory consultee for any planning applications within 10 metres of relevant railway land (as the Rail Infrastructure Managers for the railway, set out in Article 16 of the Development Management Procedure Order) and for any development likely to result in a material increase in the volume or a material change in the character of traffic using a level crossing over a railway (as the Rail Network Operators, set out in Schedule 4 (J) of the Development Management Procedure Order); in addition you are required to consult the Office of Rail and Road (ORR).

The proposal area includes or is close to several level crossings:

Kents Bank
Grange Over Sands Footpath
Bailey Lane
Bathing Pool
Cart Lane

The policy mentions:
5.17.8 There is interest in making additional extra care housing provision in Grange-over-Sands as part of developments that might come forward. Provision within Grange-over-Sands will not only address these needs but will provide new jobs in the Parish, a key component of this Neighbourhood Plan
5.17.9 The site at Berner’s Pool, excluding the Lido site, provides the ideal location for this as it has many advantages for people who would live here:
• It is within easy walking distance of Grange-over-Sands Town Centre, a key component of Policy 1 and on the local circular bus route connecting to the main bus service into Kendal and Barrow, for Westmorland General Hospital and Furness General Hospital (Policy 2)
• With easy links to the town centre, local people moving to this facility will be enabled to maintain their social networks and support, particularly if they move from other properties in Grange
• In addition, the site (excluding the Lido site) is adjacent to an accessible, level, traffic-free route along the Promenade to the railway station and the shops, the ornamental gardens and cafes at the Yewbarrow Terrace end of town. This would enable ease of access for those with mobility scooters, walking aids or limited walking ability
• The proposed site at Berner’s Pool is also a short, level walk to Kents Bank Rd for daily shopping needs, churches, cafes, convenience foods, hairdressers and chemists
• The wider allocated site includes a recently developed Medical Centre, which provides easy access to key health services

THE Neighbourhood Plan also refernces the aging population of GOS:

“2.6.2 The Parish has a notably ageing population with an age profile differing significantly from both the district as a whole and England, with a larger older population and smaller younger population

Grange-over-Sands South Lakeland England
2.6.3 The percentage of residents who said their day to day activities were limited a little or a lot due to health problems or disability was 9% higher than the SLDC average and 10% higher than the England average
2.6.4 Just over 14% of the population of Grange-over-Sands said they provided some level of unpaid care, considerably more than the SLDC and England average
2.6.5 82% of households have access to at least 1 car, significantly more than the England average
2.6.6 Over a quarter of all households in Grange-over-Sands are one-person pensioner households
2.6.7 Over 33% of residents classed as “economically active” were officially retired, 20% higher than the England average.”

In light of the above, Network Rail would comment as follows:

(1)
In relation to your comment regarding the use of Bathing Pool Level Crossing:

Bathing Pool Level Crossing is of Accommodation status with only one authorised user, South Lakeland District Council (SLDC). The accommodation crossing is governed by an agreement dated 1987, which was entered into with SLDC, for works that had been agreed with the British Railways Board (BRB) to widen and improve the crossing. SLDC sought agreement from BRB as they needed an improved access onto their promenade for maintenance purposes with wider vehicles than the previous crossing could accommodate.

There are no public rights of way scheduled over the crossing. The public footpath which is scheduled adjacent to Bathing Pool Level Crossing, does not cross the railway on the level. It was scheduled to cross over the railway by way of the former footbridge. This footbridge was owned, maintained and removed (in 2006), by SLDC.

No use of Bathing Pool Level Crossing can be made in relation to any development. If there was a requirement for the public to have access onto the promenade and Lido development at this location, then this has to be via a new footbridge.

(1) The responsibility to reinstate a footbridge, would rest with SLDC.
(2) The level crossing must be securely gated or closed prior to the residential extra care facility being occupied.
(3) Appropriate engineering and property agreements to be agreed with Network Rail. Early engagement is advised.

Below is a link to the page on Network Rail’s website which includes the Shared Value policy. This may be relevant to the Neighbourhood Plan, where a developer requires rights to cross the railway to access/serve a development site. See last document under the heading ‘Brochures and Documents’.

https://www.networkrail.co.uk/industry-commercial-partners/network-rail-property/network-rail-property/development/

(2)
Developments within the neighbourhood area should be accompanied by a TS/TA which includes consideration of the impact of proposals upon level crossings with mitigation implemented as required. We would encourage the Council / neighbourhood forum to adopt specific policy wording to ensure that the impact of proposed new development (including cumulative impact) on the risk at existing level crossings is assessed by the developer(s), and suitable mitigation incorporated within the development proposals and funded by the developer(s). We would encourage the Council to adopt specific policy wording to ensure that the impact of proposed new development (including cumulative impact) on the risk at existing level crossings is assessed by the developer(s), and suitable mitigation incorporated within the development proposals and funded by the developer(s).

TS/TAs should be undertaken in conjunction with the local highways authority with advice from Network Rail.

Contributions will be sought where proposals impact on level crossings to mitigate the impacts of those developments. Wherever possible level crossings will be closed, and either replaced with a footbridge or by a diversionary route.

Councils are urged to take the view that level crossings can be impacted in a variety of ways by planning proposals:
• By a proposal being directly next to a level crossing
• By the cumulative effect of developments added over time in the vicinity of a level crossing
• By the type of level crossing involved e.g. where pedestrians only are allowed to use the level crossing, but a proposal involves allowing cyclists to use the route
• By the construction of large developments (commercial and residential) where road access to and from the site includes a level crossing or the level / type of use of a level crossing increases as a result of diverted traffic or of a new highway
• By developments that might impede pedestrians ability to hear approaching trains at a level crossing, e.g. new airports or new runways / highways / roads
• By proposals that may interfere with pedestrian and vehicle users’ ability to see level crossing warning signs
• By any developments for schools, colleges or nurseries where minors in numbers may be using the level crossing
• By any proposal that may cause blocking back across the level crossing
• By any proposal which may see a level crossing impacted by the introduction of cycling or walking routes
• By outside party proposals where there is an increase in the number of ‘vulnerable users’* (see below).

(3)
Should the development of any of the plots identified with the neighbourhood plan require any land interests or rights from Network Rail, then such will be subject to the prior approval of all relevant rail industry consents. Additionally the appropriate property documentation and engineering agreements would need to be agreed and entered into with Network Rail prior to any use of any such land or rights.

(4)
Consideration should be given in Transport Assessments to the potential for increased footfall at Grange-Over-Sands Railway Station as a result of proposals for residential development, employment areas within the Neighbourhood Plan area. Location of the proposal, accessibility and density of the development, trip generation data should be considered in relation to the station. Where proposals are likely to increase footfall and the need for car parking at Grange-Over-Sands Railway Station, the council should consider developer contributions (either via CIL, S106) to provide funding for enhancements.

Any proposed development at this location should include a Transport Assessment that takes into consideration the level crossing with the developer fully funding any mitigation measures.

Regards

Diane Clarke AssocRTPI
Town Planning Technician LNW
Network Rail

Thank you for consulting Sport England on the above neighbourhood plan.

Government planning policy, within the National Planning Policy Framework (NPPF), identifies how the planning system can play an important role in facilitating social interaction and creating healthy, inclusive communities. Encouraging communities to become more physically active through walking, cycling, informal recreation and formal sport plays an important part in this process. Providing enough sports facilities of the right quality and type in the right places is vital to achieving this aim. This means that positive planning for sport, protection from the unnecessary loss of sports facilities, along with an integrated approach to providing new housing and employment land with community facilities is important.

It is essential therefore that the neighbourhood plan reflects and complies with national planning policy for sport as set out in the NPPF with particular reference to Pars 73 and 74. It is also important to be aware of Sport England’s statutory consultee role in protecting playing fields and the presumption against the loss of playing field land. Sport England’s playing fields policy is set out in our Planning Policy Statement: ‘A Sporting Future for the Playing Fields of England’.
http://www.sportengland.org/playingfieldspolicy

Sport England provides guidance on developing planning policy for sport and further information can be found via the link below. Vital to the development and implementation of planning policy is the evidence base on which it is founded.
http://www.sportengland.org/facilities-planning/planning-for-sport/forward-planning/

Sport England works with local authorities to ensure their Local Plan is underpinned by robust and up to date evidence. In line with Par 74 of the NPPF, this takes the form of assessments of need and strategies for indoor and outdoor sports facilities. A neighbourhood planning body should look to see if the relevant local authority has prepared a playing pitch strategy or other indoor/outdoor sports facility strategy. If it has then this could provide useful evidence for the neighbourhood plan and save the neighbourhood planning body time and resources gathering their own evidence. It is important that a neighbourhood plan reflects the recommendations and actions set out in any such strategies, including those which may specifically relate to the neighbourhood area, and that any local investment opportunities, such as the Community Infrastructure Levy, are utilised to support their delivery.

Where such evidence does not already exist then relevant planning policies in a neighbourhood plan should be based on a proportionate assessment of the need for sporting provision in its area. Developed in consultation with the local sporting and wider community any assessment should be used to provide key recommendations and deliverable actions. These should set out what provision is required to ensure the current and future needs of the community for sport can be met and, in turn, be able to support the development and implementation of planning policies. Sport England’s guidance on assessing needs may help with such work.
http://www.sportengland.org/planningtoolsandguidance

If new or improved sports facilities are proposed Sport England recommend you ensure they are fit for purpose and designed in accordance with our design guidance notes.
http://www.sportengland.org/facilities-planning/tools-guidance/design-and-cost-guidance/

Any new housing developments will generate additional demand for sport. If existing sports facilities do not have the capacity to absorb the additional demand, then planning policies should look to ensure that new sports facilities, or improvements to existing sports facilities, are secured and delivered. Proposed actions to meet the demand should accord with any approved local plan or neighbourhood plan policy for social infrastructure, along with priorities resulting from any assessment of need, or set out in any playing pitch or other indoor and/or outdoor sports facility strategy that the local authority has in place.

In line with the Government’s NPPF (including Section 8) and its Planning Practice Guidance (Health and wellbeing section), links below, consideration should also be given to how any new development, especially for new housing, will provide opportunities for people to lead healthy lifestyles and create healthy communities. Sport England’s Active Design guidance can be used to help with this when developing planning policies and developing or assessing individual proposals.

Active Design, which includes a model planning policy, provides ten principles to help ensure the design and layout of development encourages and promotes participation in sport and physical activity. The guidance, and its accompanying checklist, could also be used at the evidence gathering stage of developing a neighbourhood plan to help undertake an assessment of how the design and layout of the area currently enables people to lead active lifestyles and what could be improved.

NPPF Section 8: https://www.gov.uk/guidance/national-planning-policy-framework/8-promoting-healthy-communities

PPG Health and wellbeing section: https://www.gov.uk/guidance/health-and-wellbeing

Sport England’s Active Design Guidance: https://www.sportengland.org/activedesign

(Please note: this response relates to Sport England’s planning function only. It is not associated with our funding role or any grant application/award that may relate to the site.)

Yours sincerely

Planning Administration Team

Grange-over-Sands Neighbourhood Plan Submission Version

Thank you for consulting The Coal Authority on the above.

Having reviewed your document, I confirm that we have no specific comments to
make on it.

Should you have any future enquiries please contact a member of Planning and
Local Authority Liaison at The Coal Authority using the contact details above.

Yours sincerely,

Rachael A. Bust B.Sc.(Hons), MA, M.Sc., LL.M., AMIEnvSci., MInstLM, MRTPI
Chief Planner / Principal Manager
Planning and Local Authority Liaison

Submission of the Grange-over-Sands Neighbourhood Plan

Thank you for your email and links to the amendment to the above neighbourhood plan.

United Utilities work closely with South Lakeland District Council to understand future development sites so we can facilitate the delivery of the necessary sustainable infrastructure at the appropriate time. We would encourage further consultation with us at an early stage should further sites be allocated.

It would be useful for you to be aware that it is the applicant's responsibility to demonstrate the exact relationship between any United Utilities' assets and any proposed development. In addition, to accord with the National Planning Policy Framework (NPPF) and the National Planning Practice Guidance (NPPG), any new development site should be drained on a separate system with foul water draining to the public sewer and surface water draining in the most sustainable way.

It is important that all future planning applications, including condition discharges, must reflect the site drainage principles set out within the Surface Water Hierarchy within paragraph 80 of the National Planning Practice Guidance (NPPG): Flood Risk and Coastal Change. The NPPG clearly outlines the hierarchy to be investigated by the developer when considering a surface water drainage strategy. The following drainage options should be considered order of priority:

1. into the ground (infiltration);
2. to a surface water body;
3. to a surface water sewer, highway drain, or another drainage system;
4. to a combined sewer.

Surface water discharge to a combined sewer would be the last resort, and it is strongly discouraged.

[SEE ATTACHED DOCUMENT]