2 responses from Mr Stephen Reed (Individual)
1. Mr Stephen Reed (Individual) : 24 Apr 2012 16:44:00
Paragraph No.
0.0 Whole Document
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
1. The current proposals are based on out-of-date and unreliable evidence: The Strategic Housing Market Assessment (SHMA) is based on out of date statistics, save for the 2011 Housing Survey, which had responses from less than 10% of households in South Lakeland (4,363 responses out of 45,792 occupied dwellings) – a sample both unrepresentative of need and so unreliable as a base for long-term housing policy. Moreover, many of those replies were bald statements of personal wishes (i.e. “I wish to move home.”), and did not inform the debate.
2 The SHMA takes no account of the empty housing stock in South Lakeland in calculating housing requirement. The exact number of empty houses does not appear to have been calculated; SHMA = 1,024, SLDC 18th Jan. 2012 Council meeting = 1,500, Conservative local election leaflet April 2012 = 2,039.
3 There is no evidence that those in need of affordable housing are able to afford to buy or rent the planned “affordable” homes. Recent Westmorland Gazette articles report slow take-up on new developments suggesting that they would not. No evidence has been put forward to demonstrate where increased levels of employment, with secure, long-term, and adequate wage/salary levels, might come from to enable an uptake of such homes
4 The 2006 Housing Needs Survey concluded the area needed “416 affordable new homes every year for the following five years.” There is no evidence to link this statement to the number of people on the Housing List, or the stated target of 8800 houses.
5 The policy for building affordable new homes is entirely dependent on how many open-market houses developers will be allowed in the proposed scheme, creating an unsustainable, and probably unenforceable, “one for three” approach. The policy must demonstrate a robust exploration of all possible methods for constructing affordable homes. Overall forecasts of the need for new housing (open- market & affordable) do not appear to take into account the current economic conditions in Britain let alone in South Lakeland, (very low growth in the economy, generally stagnant personal incomes, average incomes insufficient to meet current mortgage lenders’ criteria).
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
I hereby register a request to make representations at the future public hearings of the Land Allocation DPD procedure. However, I will withdraw this request if Levens Residents Group is allowed to make representations.
2. Mr Stephen Reed (Individual) : 24 Apr 2012 16:47:00
Policy/Site No.
LA1.3 Housing Allocations - All Levens sites
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
6 The consultation documents are so complex that it is almost impossible for the average council tax payer to make a response to the soundness of the Plan, and those without access to the Internet are at an even greater disadvantage given the difficulties in obtaining printed copies of the relevant documents.
7 SLDC have a Statement of Community Involvement yet it appears they have not given full weight to the available Community documents for Levens; the 2008 Levens Village Plan and the 2008 Rural Housing Needs Survey, nor to the views expressed through the Levens Residents Association’s responses throughout the consultation process.
8 Since the consultation commenced the bus service into Levens village has been curtailed such that it is of no use for commuting for employment.The 555 bus services to Kendal & Lancaster do not enter the village and pedestrian access to them is not safe owing to the need to walk along busy roads without footpaths or street lighting. They are also too far away for pedestrian access other than by fit & active people, thereby discriminating against the elderly and disabled. The Rural Wheels scheme does not assist those going to and from work. The inevitable conclusion is that virtually all commuting to Levens by those in the newly planned houses would be by car. How does this meet any reasonable definition of “sustainable”?
9 Levens is designated a Local Service Centre. A criteria of status as a Local Service Centre is “accessibility by public transport to a GP, a hospital, a primary school, a secondary school, areas of employment and a major retail centre....within a 30-minute public transport journey..” Such public transport is no longer available to Levens Residents. In addition, the village Post Office has been lost although a part-time (three afternoons per week) service comes from Grange-over-Sands.
10 The proposed development in Levens will add estates of houses which cannot add to the sustainable community described in Core Strategy section 1.39.
11 Given the history of development in Levens, and the manner in which SLDC have dealt with the Parish Council and individual objections and comments in the past, any further development must only be allowed subject to a Development Brief.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
I hereby register a request to make representations at the future public hearings of the Land Allocation DPD procedure. However, I will withdraw this request if Levens Residents Group is allowed to make representations.