Response from Mr Rodney Sayers (Individual)
1. Mr Rodney Sayers (Individual) : 24 Apr 2012 14:33:00
Paragraph No.
0.0 Whole Document
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 DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
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.
On 18'h January 2012, the full Council of the SLDC approved the land Allocations Development Plan Document (DPD), despite the overwhelming opposition of the majority of persons who have taken part in consultations since its inception in 2005.
Please make clear, to the Inspector to be appointed as judge of the 'soundness' of the proposals, my opposition to the proposals. I believe that the process is flawed for the following reasons:
1) The proposals for the allocation of housing land do not reflect the split in the increase in
population as set out in the Core Document.
2) The proposals do not follow the guidelines set out in the Core Document.
3) The proposals are reliant on the fact that all of the approximately 6,000 proposed dwellings need to be built before the target of approximately 2,000 affordable dwellings is achieved and that there is no plan 'B' to accommodate any shortfall.
4) If all 6.000 dwellings are needed then the Council/Officers have not adequately considered alternatives to allocating land in places closer to proposed Industrial Units.
In detail:
1) Councillor Peter Thornton, who is the Portfolio holder for Housing and Development on the SlDC, stated in the Westmorland Gazette of 27'h January 2011, referring to the Land
Allocations Exercise, I quote ' If we don't do this then our young people will continue to
leave, replaced by a continued influx of retirees. Ultimately we will end up with the
equivalent of a huge residential home, but with no one to care for the residents.
a. Howeverthe Core Document clearly shows that the population of the South Lakes is
estimated to increase by 12,000 persons between 2006 and 2026 (From 105,000 to
117,000).
b. Of these 12,000, page 78 of the Core Document shows an estimated increase of
8,000 retirees. If it is assumed that these persons already live in the district, then
they will probably own their homes. If not, then it must be assumed that around
4,000 new homes will be required for the incomers. I.e. Councillor Thornton's
prophecy is self-fulfilled. The proposals should concentrate on the 4,000 remaining
persons in the Core document. These are the young persons and families that we
must retain in the district and who need the 2,000 affordable or low cost
dwellings.
c. The means of building and funding this affordable housing need to be addressed, but
the only method offunding suggested in the exercise seems to be by making the
developers foot the bill. The developers are expected, not only to subsidise the
affordable element but also many of the necessary infrastructure projects.
d. This will have two effects: 1) There is a strong possibility that all 6,000 dwelling will
not be developed due to the cost structure and 2) The mixed dwellings will become
more expensive which, in turn, will lead to problems of young people moving up the
housing ladder. In any case, if the mixed dwellings are required, they must be
suitable for the older persons as set out in the Core Document. This type of dwelling
is not necessarily the same as that required for younger persons.
e. If all 6,000 new homes are not built, then there will be a shortfall in the 2,000
required for the affordable/low cost section. There is no plan 'B' to make up this
shortfall.
2) The proposals in the final land allocation document do not meet the criteria as set out in the Core Document. The document sets out relatively clear guidelines on the amount of land to be set aside for housing and Industrial development and the criteria to be used in proposing developments on this land. However, despite claiming green and 'sustainable' credentials, there are many incidences where allocations appear to be contrary to the guidelines.
a. The relationship between the allocation of new land for new housing and Industry
does not appear to have been addressed. Housing seems to have been allocated
away from industrial sites. This will lead to more traffic between homes and places
of work.
b. If all6,000 new homes are required, then alternative options should have been
considered. For example, a new Auction Mart development is currently being built at
Crooklands, which could grow over the next few years as the site has easy access to
the M6 motorway. There is also a proposal to extend the Main line industrial estate
on the Crooklands to Milnthorpe road. There is little housing around this area, so
virtually all personnel will have to travel to the site. Surely it makes more sense to
create a completely new village to service these sites, which would be large enough
to support its own local services. A similar village could be created between
Ulverston and Barrow to service those industrial hubs.
c. This would leave towns and villages such as Kendal, Grange and Milnthorpe, which
all currently have their own traffic problems to provide some extra housing through
infill and existing sites.
d. A further alternative, would be to create larger 'hubs, just outside the larger towns
with their own services and good infrastructure to provide easy access to the places
of employment
e. The document does not appear to have considered any alternative options
other than increasing the size of already crowded towns and villages through
developments around their fringes.
There are other anomalies In the final proposals which go against the principles of the Core
Document. Together with the main reasons given above, I believe that the proposals are flawed and should be rejected.
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 effective in that the document is not deliverable, flexible or capable of being monitored.
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.
On 18'h January 2012, the full Council of the SLDC approved the land Allocations Development Plan
Document (DPD), despite the overwhelming opposition of the majority of persons who have taken
part in consultations since its inception in 2005.
Please make clear, to the Inspector to be appointed as judge of the 'soundness' of the proposals, my
opposition to the proposals. I believe that the process is flawed for the following reasons:
1) The proposals for the allocation of housing land do not reflect the split in the increase in
population as set out in the Core Document.
2) The proposals do not follow the guidelines set out in the Core Document.
3) The proposals are reliant on the fact that all of the approximately 6,000 proposed dwellings
need to be built before the target of approximately 2,000 affordable dwellings is achieved
and that there is no plan 'B' to accommodate any shortfall.
4) If all 6.000 dwellings are needed then the Council/Officers have not adequately considered
alternatives to allocating land in places closer to proposed Industrial Units.
In detail:
1) Councillor Peter Thornton, who is the Portfolio holder for Housing and Development on the
SlDC, stated in the Westmorland Gazette of 27'h January 2011, referring to the Land
Allocations Exercise, I quote ' If we don't do this then our young people will continue to
leave, replaced by a continued influx of retirees. Ultimately we will end up with the
equivalent of a huge residential home, but with no one to care for the residents.
a. Howeverthe Core Document clearly shows that the population of the South Lakes is
estimated to increase by 12,000 persons between 2006 and 2026 (From 105,000 to
117,000).
b. Of these 12,000, page 78 of the Core Document shows an estimated increase of
8,000 retirees. If it is assumed that these persons already live in the district, then
they will probably own their homes. If not, then it must be assumed that around
4,000 new homes will be required for the incomers. I.e. Councillor Thornton's
prophecy is self-fulfilled. The proposals should concentrate on the 4,000 remaining
persons in the Core document. These are the young persons and families that we
must retain in the district and who need the 2,000 affordable or low cost
dwellings.
c. The means of building and funding this affordable housing need to be addressed, but
the only method offunding suggested in the exercise seems to be by making the
developers foot the bill. The developers are expected, not only to subsidise the
affordable element but also many of the necessary infrastructure projects.
d. This will have two effects: 1) There is a strong possibility that all 6,000 dwelling will
not be developed due to the cost structure and 2) The mixed dwellings will become
more expensive which, in turn, will lead to problems of young people moving up the
housing ladder. In any case, if the mixed dwellings are required, they must be
suitable for the older persons as set out in the Core Document. This type of dwelling
is not necessarily the same as that required for younger persons.
e. If all 6,000 new homes are not built, then there will be a shortfall in the 2,000
required for the affordable/low cost section. There is no plan 'B' to make up this
shortfall.
2) The proposals in the final land allocation document do not meet the criteria as set out in the
Core Document. The document sets out relatively clear guidelines on the amount of land to
be set aside for housing and Industrial development and the criteria to be used in proposing
developments on this land. However, despite claiming green and 'sustainable' credentials,
there are many incidences where allocations appear to be contrary to the guidelines.
a. The relationship between the allocation of new land for new housing and Industry
does not appear to have been addressed. Housing seems to have been allocated
away from industrial sites. This will lead to more traffic between homes and places
of work.
b. If all6,000 new homes are required, then alternative options should have been
considered. For example, a new Auction Mart development is currently being built at
Crooklands, which could grow over the next few years as the site has easy access to
the M6 motorway. There is also a proposal to extend the Main line industrial estate
on the Crooklands to Milnthorpe road. There is little housing around this area, so
virtually all personnel will have to travel to the site. Surely it makes more sense to
create a completely new village to service these sites, which would be large enough
to support its own local services. A similar village could be created between
Ulverston and Barrow to service those industrial hubs.
c. This would leave towns and villages such as Kendal, Grange and Milnthorpe, which
all currently have their own traffic problems to provide some extra housing through
infill and existing sites.
d. A further alternative, would be to create larger 'hubs, just outside the larger towns
with their own services and good infrastructure to provide easy access to the places
of employment
e. The document does not appear to have considered any alternative options
other than increasing the size of already crowded towns and villages through
developments around their fringes.
There are other anomalies In the final proposals which go against the principles of the Core
Document. Together with the main reasons given above, I believe that the proposals are flawed
and should be rejected.
