Local Development Framework Consultation

Land Allocations Emerging Options Consultation Document *

9

Prioritisation - how do we allocate sites?

Oppose

FINDING AND PRIORITISING HOUSING SITES – THE BALANCE BETWEEN SETTLEMENTS
In his examination of the Core Strategy, the Inspector removed the specific development targets for individual settlements smaller than Principal Service Centres (PCSs) and replaced these with grouped targets. The Core Strategy sets the combined overall target for the three Key Service Centres of Grange, Kirkby Lonsdale and Milnthorpe, and the criteria for distributing development between them. This is reiterated in section 2.5 of The Land Allocations DPD.

The Inspector’s report following his examination of the Core Strategy states that: ‘more detailed work looking at balancing local needs and environmental capacities outside the PCSs can properly be conducted as part of the Allocations of Land DPD process’. The inspector’s report also states that ‘further detail will be necessary to firm up specific plans (for the Cartmel Peninsula) but in my mind the level of further detail necessary is more appropriate to the forthcoming Allocation of Land DPD’.

The Land Allocations DPD states that the distribution will be based on the following:
• The capacity of existing services to accommodate development;
• Critical thresholds for new service investment;
• Size, character and environmental capacity of the settlement;
• The need to secure regeneration or investor confidence.

The criteria used to identify those settlements that are designated as Key Service Centres are:
• Good public transport links to outlying settlements;
• A primary school, secondary school, library, doctor’s surgery and a town centre function providing at least a post office and 2,000 sq m of retail floorspace;
• A population of more than 1,500.

Grange Town Council believes that Grange is less able to manage development which is sustainable than the other Key Service Centres for a number of reasons, namely access to services, the infrastructure (especially the road network) and the impact on the viability and vitality of Grange. The Town Council is also concerned about the lack of assessment of flood risk in the settlement fact files, and the lack of proper community involvement in the assessment of viable development targets and in the preparation of the Land Allocations DPD.

The Sustainability Appraisal assesses sites solely against those within the same settlement. Grange Town Council believes that, in deciding the split of development between Kirkby Lonsdale, Milnthorpe and Grange, sites within all three Key Service Centres should be assessed against each other.

The relative ability of each Key Service Centre to cope with development should also be assessed in order to guide the development split between Grange, Milnthorpe and Kirkby Lonsdale, and should take account of the impact of development in smaller neighbouring settlements on each of the three Key Service Centres.

ACCESS TO SERVICES
Compared to the other Key Service Centres, Grange is significantly further from the following essential services:
• Hospitals
• Trunk road system
Both Kirkby Lonsdale and Milnthorpe are on an ‘A’ road; access to the A590 for the vast majority of residents in Grange, and from all of the proposed development sites, means negotiating the narrow roads of the town centre.
• Motorway
Grange is significantly further from the M6 than either Kirkby Lonsdale or Milnthorpe, and again most traffic accessing the M6 from Grange has to pass through the narrow town centre streets.
• Principal Service Centre
Grange is further from Kendal than Milnthorpe is, and is significantly further away from Lancaster, the nearest city, than either Milnthorpe or Kirkby Lonsdale is.
• Secondary School and FE College
Of the three towns designated as Key Service Centres, Grange is the only one which does not have a secondary school. The nearest secondary school is in Cartmel, 2 miles from Grange, with some secondary age pupils also attending Dallam School in Milnthorpe, Ulverston Victoria High School, Lancaster Boys’ Grammar School, Lancaster Girls’ Grammar School and Queen Elizabeth School in Kirkby Lonsdale.

There is no possible route from Grange to Cartmel (where the nearest secondary school is located) that does not involve using narrow, winding roads, very steep in parts, with an unrestricted speed limit.

A safe walking or cycling route to Cartmel school from Grange cannot be created, so secondary school age children living in Grange all require transport to get to and from school. Although standard practice is for free bus travel to be offered only to children who live three miles or more from school, children in Grange attending Cartmel school are offered free transport because of the lack of a safe route. Children undertaking after school activities are not catered for by school buses and require collection by private vehicle.

As well as secondary school facilities, the other two Key Service Centres each have sixth form colleges. Pupils living in the Cartmel peninsula area who wish to continue their education post 16 have to travel to Milnthorpe, Ulverston, Lancaster, Kirkby Lonsdale, Kendal or Barrow.

The lack of a secondary school and FE College in Grange means that any additional housing development will put far greater demand on the transport network than commensurate development in the other Key Service Centres. Whilst some of this demand might be met through improved public transport, it would lead to significant additional journeys by private car.

SUSTAINABLE DEVELOPMENT
The Land Allocations DPD states that, for Kirkby Lonsdale, ‘as many dwellings as possible (should be) within walking distance of the town centre.’
For Milnthorpe, the aspiration is for ‘new homes and workplaces ... within easy walking distance of the village centre.’
No such ambition is given for Grange, though the relative accessibility of sites in Kirkby Lonsdale and Milnthorpe compared with Grange points to the potential for more sustainable growth in the other Key Service Centres.

Grange is bordered on three sides by Morecambe Bay, the Lake District National Park and Hampsfell and steep, wooded hillsides which severely limit the number of possible development sites, particularly those within walking distance of the town centre.

The proposed sites on the outskirts of Grange are not within walking distance of the town centre, and will inevitably increase the amount of traffic on the Esplanade, Kents Bank Road, the Pig Lane one-way system and down Main Street. This contradicts CS4 which states that the Council and its partners will aim to ‘improve the pedestrian experience of Grange Town Centre’. These sites cannot be developed sustainably.

Sufficient sites have been identified for Kirkby Lonsdale and Milnthorpe in the Land Allocations DPD to meet their current indicative development targets twice over. All the emerging sites in Milnthorpe and Kirkby Lonsdale are within walking distance of shops and essential services, including a secondary school.

In Grange, all of the identified sites would need to be developed in order to meet the current indicative target, even though many of these sites cannot be developed as sustainably as those identified in the other Key Service Centres.

The topography of Grange is not considered in the Land Allocations DPD, though the very steep hills in the town mean that the town centre is not accessible either by bicycle or on foot from some of the proposed development sites. Development on these sites contradicts CS10.1 ‘Accessing services’ which states that the Council will work with partners to improve accessibility within and beyond the plan area (which) will centre on:
‘Promoting a network of safe cycle and walking routes linking residential areas with employment areas, town and local centres, schools, recreational open space and facilities’.
This is simply not achievable for some of the sites proposed in Grange because of the steepness of the inclines.

ROAD NETWORK
Grange Town Council has consistently expressed concern about the level of development outlined for the town, and the inability of the infrastructure to cope with the proposed increase.

Grange is a tourist town, and in the visitor season (which runs from April to October) there is a huge increase in traffic through the town centre. Large numbers of vehicles and caravans travel through Grange to access the caravan sites in the area, including a large caravan site in Flookburgh, which has over 800 static units and space for 50 tourers. The Holiday Property Bond development of the Merlewood site on Windermere Road will create more than 50 apartments and cottages, and bring additional traffic through the centre of town. Local events such as Cartmel Races, Holker Garden Festival and Cumbria Steam Gathering bring significant numbers of vehicles through the town, including many larger vehicles that cannot easily pass through the town’s narrow road system.

Any additional development in Grange, and in the nearby local service centres of Allithwaite, Cark, Flookburgh and Cartmel, will have to travel through Grange to reach the train station, the A590 and the M6 beyond. The Land Allocations DPD gives an indicative target for Grange of a further 501 dwellings between now and 2025. A further 306 dwellings are planned across the Cartmel Peninsula for the Local Services Centres, smaller centres and open countryside within this period.

Whilst the Core Strategy seeks to encourage additional public transport provision, which Grange Town Council supports, the rural nature of the Cartmel peninsula means that increases to the number of dwellings in the area will inevitably lead to increased car use.

CS5.12 notes that ‘Access into the peninsula is poor, limited mainly to the B5277/8 looping off the A590 to run through Grange, Allithwaite and Cark, the B6271 from Lindale and minor roads north of Cartmel’.

By contrast, the Core Strategy notes that the East (including Kirkby Lonsdale and Milnthorpe) ‘benefits from excellent strategic transport links’ (CS6.11) and that ‘the Key Service Centres (of Milnthorpe and Kirkby Lonsdale) are easily accessible by road’ (CS6.12).

CS5.13 notes that Grange ‘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...footpaths are narrow and there is a strong sense that the car is the dominant feature on Kents Bank Rd and Main St’.

Extrapolating from the figures in the 2001 census for car and van ownership in the area, it is reasonable to assume an increase of at least 1.4 cars or vans for each additional household in the area. Developing 807 new dwellings in the Cartmel peninsula would therefore be likely to lead to more than 1130 extra vehicles in the peninsula, the vast majority of which would be regularly using the narrow and congested roads in Grange town centre to access essential services in the town and beyond.

There are currently 5 car parks in Grange, all operated by the district council. The town centre car parks are busy and well-used, with spaces often at a premium in the tourist season. Planning permission has been granted for redevelopment of 2 of the car parks in the town, which will reduce the numbers of car parking spaces available to visitors and residents. The planned developments (mixed development at Berners Close car park and old pool site, Booths supermarket at Windermere Road car park) will increase the demand for car parking spaces, and add to the volume of traffic through the town centre.

The Inspector’s report into the Core Strategy states in paragraph 6.5 that ‘where necessary, further assessment may be required to assess the scale of impact of proposed development sites on traffic levels in different settlements, most notably Ulverston and Grange over Sands where there are known traffic congestion issues’.

Within the Core Strategy itself, CS10.2 ‘Transport impact of new development’ states that development proposals will be considered against criteria, including the following:
‘The expected nature and volume of traffic generated by the proposal could be accommodated by the existing road network without detriment to the amenity and character of the surrounding area, local air quality or highway safety’ and
‘The proposal provides for safe and convenient access on foot, cycle, public and private transport, addressing the needs of all, including those with a disability’.

The Core Strategy Preferred Options document outlines the need for a Travel Assessment/Travel Plan for both ‘Land off Grange Fell Road’ and ‘Land at Kents Bank’. Grange Town Council believes that a comprehensive survey of traffic flows and congestion both within Grange and within the Cartmel peninsula as a whole are required as part of the Allocations of Land process.

The only developments in Local Service Centres which would be likely to impact on traffic levels in and through Milnthorpe are those at Arnside and Sandside/Storth.

Because of its location, there would be no likely additional traffic levels in Kirkby Lonsdale from developments in Local Service Centres.

In effect, the impact of the indicative development numbers for Kirkby Lonsdale would bring an increase in car numbers using the village of approximately 165, compared with additional car numbers accessing and travelling through Grange of 1130. This must be taken into account when deciding on the level of development that is sustainable for each of the Key Service Centres.

The problems associated with Grange’s highways infrastructure cannot be improved; the footpaths cannot be widened without narrowing the roads, and the roads, already too narrow to cope with current traffic levels, cannot be widened.

Whilst the Core Strategy gives an aspiration to improve the situation for pedestrians in Grange by ‘upgrading the promenade, rebuilding footbridges and developing new links’, these measures would have little impact on the effect of the car on the main shopping streets of Kents Bank Rd and Main St. Neither would they affect the increased vehicular traffic in town that would be a consequence of additional development in the Cartmel Peninsula.

IMPACT ON VIABILITY OF GRANGE
Grange relies on tourism to maintain its viability and vitality. The Core Strategy notes that ‘Tourism is a fundamental part of the local economy’ (CS5.7). CS4 (Cartmel Peninsula) states that the Council and its partners will ‘Maintain and enhance the strength of tourism across the area’.

The Core Strategy accepts that Grange currently suffers from the impact of private cars, and this already has a considerable bearing on the attractiveness of the town to tourists. Alongside significantly higher car use and congestion in the town centre, the proposed levels of development will damage what Grange has to offer tourists by impacting negatively on the quality of the landscape surrounding the town centre. This is itself contrary to CS4.5. By contrast, Milnthorpe’s economy does not rely on tourism, so increasing the planned level of development in this area will not damage the core economy of the town.

The April 2008 version of the Core Strategy Preferred Options gave the population of Milnthorpe as 2,106. This figure is taken from the 2001 census, which gives an equivalent household figure of 921 (from the Key Figures for Milnthorpe ward in the 2001 census). The household figure now provided by the Development Plans Team for Milnthorpe, which has been used to set the current indicative target, is the smaller figure of 761, giving a smaller ‘pro rata’ development target for the town. It appears that different boundaries for Milnthorpe are now being used compared to 2008 Core Strategy Preferred Options, though no explanation has been given for this change.

FLOODING
The flooding assessments in the Sustainability Appraisal take no account of flooding from surface water run-off. The most recent flooding in the town (late summer 2008) was caused solely by run-off. The Environment Agency notes that ‘Surface Water Flooding...is much more difficult to predict and pinpoint...than river or coastal flooding.’

Risk of flooding from run-off should be considered fully, alongside EA flood risk zones. It is unacceptable, in an area with Grange’s topography and recent history of flooding from surface water, to take no account of this risk to proposed and existing dwellings when outlining possible development sites. Local knowledge regarding incidents of flooding from run-off should be sought in order to understand properly the current risk, and the likely impact of further development.

NEIGHBOURHOOD PLANNING
The Localism Bill sets out the intention for Local Planning Authorities to work with communities to produce Neighbourhood Plans. Grange Town Council accepts the need for some development in the town, to meet the need for affordable housing. The current Development Plan is being imposed on communities by the District Council, and there is no evidence that responses to earlier rounds of consultation have influenced the current Land Allocations documents.

Grange Town Council considers the Core Strategy to be an urban based model, which doesn’t fit a rural area like Grange and the Cartmel Peninsula.

Grange Town Council would like to work with the District Council to develop a Neighbourhood Plan that involves meaningful engagement with the local community.

Land Allocations Emerging Options Consultation Document *

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Draft Policy G1

Oppose

The Town Council does not consider the proposed sites adjoining the development boundary to be suitable sites for development. The distance from these sites to town centre facilities would result in considerable additional traffic on the already congested town centre roads. Additional concerns are provided in the response to ‘Draft Policy G3 Land for New Housing in Grange-over-Sands’.

Land Allocations Emerging Options Consultation Document *

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Draft Policy G2

Support

The Town Council considers the proposed town centre area to be suitable as the preferred location for key town centre uses including offices, leisure, and food and drink.

Land Allocations Emerging Options Consultation Document *

68

Draft Policy G3

Oppose

The Town Council does not accept that the level of development outlined for the town is sustainable, and believes that the district council should work with local communities and town and parish councils to develop a neighbourhood plan. The Town Council has specific objections to the following areas of land outlined in the Allocations of Land DPD:

RN34 – Land North of Grange Fell Road
The Town Council is strongly opposed to development on this site. During earlier rounds of consultation, the Town Council opposed development on these fields and supported local residents’ request that this land be designated as Important Privately-Owned Open Space. The Town Council supports the view of local residents that this land should not be developed, for the following reasons:
• Increased flooding risk to other properties.
In the settlement fact file for this site, the comment from SLDC’s Environment Protection Team notes ‘Surface water from hills. Possible culverts crossing site. The more development there is in this part of Grange, the more drainage problems there will be in future’. The site visit notes ‘There are surface water issues on this site.’ Given that the site lies on the lower slopes of Hampsfell and above the town, any development on these fields is likely to have a significant effect in terms of increasing flood risk below the site. There are underground springs in the area, which already cause subsidence to the road surface.
• The impact on the attractiveness of Hampsfell to tourists and residents, in an area of the town that already has high population density.
The site visit notes ‘Site would form an extension into very open countryside and an historic limestone landscape. The setting of the listed field barn immediately north of the site would be negatively affected if (this site were) developed.’

R89 – Land North of Carter Road
The Town Council is opposed to development on this site, for the following reasons:
• In previous plans this site’s designation for residential development was withdrawn.
• There are issues relating to drainage (the settlement fact file notes the presence of limestone beneath the surface) which have not been investigated sufficiently.
• The Douglas Wheeler Regeneration Study of 2007 (which is a key source of evidence in the Core Strategy) concludes that ‘residential development of (this) site is likely to be controversial because of the Greenfield nature of the site’.

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Draft Policy G4

Support

EEA4 - Station Yard
The Town Council agrees that this site should be safeguarded as an existing employment area.

EN34M – Land Adj Station Yard
The Town council agrees that this site is suitable as a local employment site.

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Draft Policy G5

Support

R381, R383, M378M - Berners Pool
The Town Council agrees that these sites should be allocated for the mixed uses identified in the Land Allocations Development Document, namely Residential, Employment, Health Care and Leisure.

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Draft Policy G5

Oppose

M25M - Land at Allithwaite Road
The Town Council is opposed to development on this site, for the following reasons:
• The large scale of the site.
• Use of the site by wildlife has not been properly explored.
• There are issues relating to drainage (the settlement fact file notes the presence of limestone beneath the surface) which have not been investigated sufficiently.

Given the large size of this site and its deliverability, Grange Town Council believes that if this site were to be developed, the target for affordable dwellings on the site should be increased above the minimum 35%.