3 responses from Ms Susan Teper and Mr M Ferguson (Individual)
1. Ms Susan Teper and Mr M Ferguson (Individual) : 13 Apr 2012 16:48:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
0.0 Whole Document
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
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.
The DPD is not consistent with national policy.
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.
I believe SLDC have used outdated statistics and business plans to calculate housing needs, which do not reflect the current economic climate. Current figures would reduce projected needs resulting in them being more in line with what local communities feel appropriate. They would also be more in line with recent changes in Government strategy. Local Town councils and Parish Councils throughout the SLDC area have objected strongly to the DPD. Several have stated that they want housing needs to be managed under the Localism Act, as many residents feel SLDC are not responding adequately to concerns, not just about individual sites but also the scale of the increase and the general impact on the green space around our towns and villages and how this affects their character. A high proportion of residents strongly value the rural nature of the areas where they live.
The Government has stated that as part of its National Planning Policy Framework it wants to create a new designation to protect green areas of particular importance to local communities, that it wants to safeguard and enhance the environment, and that it wants to greatly increase the consultation period on such large-scale developments. SLDC seem to have largely ignored this. A huge percentage of people have objected to the proposed building on green sites, agricultural land and open countryside. SLDC's standard response to this seems to be "The Council looked first at previously used land ... secondly at suitable infill sites ... thirdly at other land which is well located...". This still does not conclude that they can justify any green site they propose.
In some cases a resident has opposed a "green gap" or "green belt" site, when perhaps they simply meant a green area and have used the wrong terminology - SLDC's "the land does not have a green belt allocation" seems more like an arrogant put-down than a valid response to a concern. Several responses to concerns are "Noted" or "have been taken into account", giving no justification or explanation.
For the DPD to be sound it must be justified - there must be evidence of participation of the local community and others having a stake in the area - the choices made in the plan must be backed up by facts. Several residents have written to the SLDC saying that facts have not been taken into account (for example on site visits). Countryside views valued by locals have been mentioned on some site visit reports but omitted on others (eg for site R692ULVM). Hedgerows are mentioned as valuable on some sites but not their existance mentioned on others (eg MN29).
Many residents feel the consultation with the public has been flawed. An SLDC representative confirmed to me that a leaflet drop should have taken place but never happened. A recent leaflet drop by locals has proved that many residents were still unaware of the exact nature of the DPD and are alarmed at the scale of it. A drop-in session in Ulverston's Coronation Hall had a small poorly written board on the pavement outside to alert passers-by which wasn't even in place on the morning of the event. I received an email notification of a consultation meeting only a few hours before the event. Actual consultation and response has been difficult and confusing for those who are not fully computer literate. Drop-in sessions proved frustrating as residents often could not get an informative answer to questions - many questions were merely answered with "that will be dealt with". A question as to how affordable housing would be maintained as affordable wasn't answered at all - this was raised by a resident who has evidence that rules regarding "affordable housing" in Swarthmoor have not been followed.
Government policy states that building in flood risk areas should be avoided, but the DPD includes several areas liable to flooding. SLDC states that one of the mitigation measures for this is to build with raised floor levels. However this does not address the problem of streets and gardens being flooded and the difficulty in obtaining home insurance. When one resident challenged SLDC that the current flooding problems in Ulverston have never been resolved as promised, he was told that new development would bring in money which would allow them to address it. When several residents said that the council currently didn't maintain the current infrastructure (roads, parks, allotments etc), they were told that funding from the new development would ensure infrastructure would be taken care of, but it was not answered as to how long this funding would last and if it would cover the existing problems. SLDC seemed to suggest that if we got behind the DPD then a lot of our current problems could be tackled, which angered many residents. Unfortunately, based on past performance, SLDC often do not follow through, or state there is insufficient budget, which is why so many residents are asking for more specific answers.
With regard to site reports and conclusions, these are inconsistent. For site RN131M (land at Gascow Farm), Cumbria County Council Highways Agency states that this would require "removal of a number of substantial trees". Cumbria Wildlife Trust states "Mature trees and hedgerows surrounding the site should be retained" and that they have "concerns about the felling of trees along Priory Rd ... these should be retained". The SLDC Arboriculturist Officer (Trees) states "Major constraint. TPO on site". However SLDC proposes the site for development, and as mitigation states "Retention of mature trees on the boundary where possible", and retention of apparently only some of the hedgerow. Surely "where possible" indicates that they will go against the recommendations. Consulting with agencies does not validate the DPD if they're prepared to do this. For site R692ULVM Cumbria Wildlife Trust states "hedgerows and mature trees surrounding the site should be retained", and the SLDC Arboriculturalist Officer(Trees) states "Major constraint. TPO on site". SLDC respond that mitigation measures will be needed, but does not state what they are, as it does with other sites (for example MN29), so it is unclear whether or not the Trust's recommendation will be followed.
Returning to general aspects of the DPD, I do not believe that Ulverston's current facilities can cope with such an increase in the size of the town. This concern has been raised by many residents and SLDC's response is that planning and consulting the relevant agencies will allow this to be catered for. However, land does not appear to have been allocated for additional schooling, medical and leisure facilities etc, so the public are unable to comment as to whether they will be located in the right places and whether they will be sufficient. The school serving Swarthmoor is apparently at capacity, but no answers have been given as to whether it is possible to expand that school or if young children would need to travel to a school elsewhere.
All in all, when looking at the concerns raised across the district, they seem to echo the same theme - that residents do not want such a large expansion, that they do not want their green spaces destroyed, and that SLDC are not consulting or responding adequately.
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
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
2. Ms Susan Teper and Mr M Ferguson (Individual) : 15 May 2012 14:48:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
1.10
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
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.
The DPD is not consistent with national policy.
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.
I believe SLDC have used outdated statistics and business plans to calculate housing needs, which do not reflect the current economic climate. Current figures would reduce projected needs resulting in them being more in line with what local communities feel appropriate. They would also be more in line with recent changes in Government strategy. Local Town councils and Parish Councils throughout the SLDC area have objected strongly to the DPD. Several have stated that they want housing needs to be managed under the Localism Act, as many residents feel SLDC are not responding adequately to concerns, not just about individual sites but also the scale of the increase and the general impact on the green space around our towns and villages and how this affects their character. A high proportion of residents strongly value the rural nature of the areas where they live.
The Government has stated that as part of its National Planning Policy Framework it wants to create a new designation to protect green areas of particular importance to local communities, that it wants to safeguard and enhance the environment, and that it wants to greatly increase the consultation period on such large-scale developments. SLDC seem to have largely ignored this. A huge percentage of people have objected to the proposed building on green sites, agricultural land and open countryside. SLDC's standard response to this seems to be "The Council looked first at previously used land ... secondly at suitable infill sites ... thirdly at other land which is well located...". This still does not conclude that they can justify any green site they propose.
In some cases a resident has opposed a "green gap" or "green belt" site, when perhaps they simply meant a green area and have used the wrong terminology - SLDC's "the land does not have a green belt allocation" seems more like an arrogant put-down than a valid response to a concern. Several responses to concerns are "Noted" or "have been taken into account", giving no justification or explanation.
For the DPD to be sound it must be justified - there must be evidence of participation of the local community and others having a stake in the area - the choices made in the plan must be backed up by facts. Several residents have written to the SLDC saying that facts have not been taken into account (for example on site visits). Countryside views valued by locals have been mentioned on some site visit reports but omitted on others (eg for site R692ULVM). Hedgerows are mentioned as valuable on some sites but not their existance mentioned on others (eg MN29).
Many residents feel the consultation with the public has been flawed. An SLDC representative confirmed to me that a leaflet drop should have taken place but never happened. A recent leaflet drop by locals has proved that many residents were still unaware of the exact nature of the DPD and are alarmed at the scale of it. A drop-in session in Ulverston's Coronation Hall had a small poorly written board on the pavement outside to alert passers-by which wasn't even in place on the morning of the event. I received an email notification of a consultation meeting only a few hours before the event. Actual consultation and response has been difficult and confusing for those who are not fully computer literate. Drop-in sessions proved frustrating as residents often could not get an informative answer to questions - many questions were merely answered with "that will be dealt with". A question as to how affordable housing would be maintained as affordable wasn't answered at all - this was raised by a resident who has evidence that rules regarding "affordable housing" in Swarthmoor have not been followed.
Government policy states that building in flood risk areas should be avoided, but the DPD includes several areas liable to flooding. SLDC states that one of the mitigation measures for this is to build with raised floor levels. However this does not address the problem of streets and gardens being flooded and the difficulty in obtaining home insurance. When one resident challenged SLDC that the current flooding problems in Ulverston have never been resolved as promised, he was told that new development would bring in money which would allow them to address it. When several residents said that the council currently didn't maintain the current infrastructure (roads, parks, allotments etc), they were told that funding from the new development would ensure infrastructure would be taken care of, but it was not answered as to how long this funding would last and if it would cover the existing problems. SLDC seemed to suggest that if we got behind the DPD then a lot of our current problems could be tackled, which angered many residents. Unfortunately, based on past performance, SLDC often do not follow through, or state there is insufficient budget, which is why so many residents are asking for more specific answers.
With regard to site reports and conclusions, these are inconsistent. For site RN131M (land at Gascow Farm), Cumbria County Council Highways Agency states that this would require "removal of a number of substantial trees". Cumbria Wildlife Trust states "Mature trees and hedgerows surrounding the site should be retained" and that they have "concerns about the felling of trees along Priory Rd ... these should be retained". The SLDC Arboriculturist Officer (Trees) states "Major constraint. TPO on site". However SLDC proposes the site for development, and as mitigation states "Retention of mature trees on the boundary where possible", and retention of apparently only some of the hedgerow. Surely "where possible" indicates that they will go against the recommendations. Consulting with agencies does not validate the DPD if they're prepared to do this. For site R692ULVM Cumbria Wildlife Trust states "hedgerows and mature trees surrounding the site should be retained", and the SLDC Arboriculturalist Officer(Trees) states "Major constraint. TPO on site". SLDC respond that mitigation measures will be needed, but does not state what they are, as it does with other sites (for example MN29), so it is unclear whether or not the Trust's recommendation will be followed.
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
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
3. Ms Susan Teper and Mr M Ferguson (Individual) : 15 May 2012 14:50:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - All Ulverston sites
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
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.
The DPD is not consistent with national policy.
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.
I believe SLDC have used outdated statistics and business plans to calculate housing needs, which do not reflect the current economic climate. Current figures would reduce projected needs resulting in them being more in line with what local communities feel appropriate. They would also be more in line with recent changes in Government strategy. Local Town councils and Parish Councils throughout the SLDC area have objected strongly to the DPD. Several have stated that they want housing needs to be managed under the Localism Act, as many residents feel SLDC are not responding adequately to concerns, not just about individual sites but also the scale of the increase and the general impact on the green space around our towns and villages and how this affects their character. A high proportion of residents strongly value the rural nature of the areas where they live.
The Government has stated that as part of its National Planning Policy Framework it wants to create a new designation to protect green areas of particular importance to local communities, that it wants to safeguard and enhance the environment, and that it wants to greatly increase the consultation period on such large-scale developments. SLDC seem to have largely ignored this. A huge percentage of people have objected to the proposed building on green sites, agricultural land and open countryside. SLDC's standard response to this seems to be "The Council looked first at previously used land ... secondly at suitable infill sites ... thirdly at other land which is well located...". This still does not conclude that they can justify any green site they propose.
In some cases a resident has opposed a "green gap" or "green belt" site, when perhaps they simply meant a green area and have used the wrong terminology - SLDC's "the land does not have a green belt allocation" seems more like an arrogant put-down than a valid response to a concern. Several responses to concerns are "Noted" or "have been taken into account", giving no justification or explanation.
For the DPD to be sound it must be justified - there must be evidence of participation of the local community and others having a stake in the area - the choices made in the plan must be backed up by facts. Several residents have written to the SLDC saying that facts have not been taken into account (for example on site visits). Countryside views valued by locals have been mentioned on some site visit reports but omitted on others (eg for site R692ULVM). Hedgerows are mentioned as valuable on some sites but not their existance mentioned on others (eg MN29).
Many residents feel the consultation with the public has been flawed. An SLDC representative confirmed to me that a leaflet drop should have taken place but never happened. A recent leaflet drop by locals has proved that many residents were still unaware of the exact nature of the DPD and are alarmed at the scale of it. A drop-in session in Ulverston's Coronation Hall had a small poorly written board on the pavement outside to alert passers-by which wasn't even in place on the morning of the event. I received an email notification of a consultation meeting only a few hours before the event. Actual consultation and response has been difficult and confusing for those who are not fully computer literate. Drop-in sessions proved frustrating as residents often could not get an informative answer to questions - many questions were merely answered with "that will be dealt with". A question as to how affordable housing would be maintained as affordable wasn't answered at all - this was raised by a resident who has evidence that rules regarding "affordable housing" in Swarthmoor have not been followed.
Government policy states that building in flood risk areas should be avoided, but the DPD includes several areas liable to flooding. SLDC states that one of the mitigation measures for this is to build with raised floor levels. However this does not address the problem of streets and gardens being flooded and the difficulty in obtaining home insurance. When one resident challenged SLDC that the current flooding problems in Ulverston have never been resolved as promised, he was told that new development would bring in money which would allow them to address it. When several residents said that the council currently didn't maintain the current infrastructure (roads, parks, allotments etc), they were told that funding from the new development would ensure infrastructure would be taken care of, but it was not answered as to how long this funding would last and if it would cover the existing problems. SLDC seemed to suggest that if we got behind the DPD then a lot of our current problems could be tackled, which angered many residents. Unfortunately, based on past performance, SLDC often do not follow through, or state there is insufficient budget, which is why so many residents are asking for more specific answers.
With regard to site reports and conclusions, these are inconsistent. For site RN131M (land at Gascow Farm), Cumbria County Council Highways Agency states that this would require "removal of a number of substantial trees". Cumbria Wildlife Trust states "Mature trees and hedgerows surrounding the site should be retained" and that they have "concerns about the felling of trees along Priory Rd ... these should be retained". The SLDC Arboriculturist Officer (Trees) states "Major constraint. TPO on site". However SLDC proposes the site for development, and as mitigation states "Retention of mature trees on the boundary where possible", and retention of apparently only some of the hedgerow. Surely "where possible" indicates that they will go against the recommendations. Consulting with agencies does not validate the DPD if they're prepared to do this. For site R692ULVM Cumbria Wildlife Trust states "hedgerows and mature trees surrounding the site should be retained", and the SLDC Arboriculturalist Officer(Trees) states "Major constraint. TPO on site". SLDC respond that mitigation measures will be needed, but does not state what they are, as it does with other sites (for example MN29), so it is unclear whether or not the Trust's recommendation will be followed.
Returning to general aspects of the DPD, I do not believe that Ulverston's current facilities can cope with such an increase in the size of the town. This concern has been raised by many residents and SLDC's response is that planning and consulting the relevant agencies will allow this to be catered for. However, land does not appear to have been allocated for additional schooling, medical and leisure facilities etc, so the public are unable to comment as to whether they will be located in the right places and whether they will be sufficient. The school serving Swarthmoor is apparently at capacity, but no answers have been given as to whether it is possible to expand that school or if young children would need to travel to a school elsewhere.
All in all, when looking at the concerns raised across the district, they seem to echo the same theme - that residents do not want such a large expansion, that they do not want their green spaces destroyed, and that SLDC are not consulting or responding adequately.
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
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
