3 responses from Cumbria House Builders Group , c/o Garner Planning Associates
1. Cumbria House Builders Group , c/o Garner Planning Associates : 15 May 2012 07:56:00
A typed or handwritten document was submitted. This has been scanned and can be downloaded below:
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
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 effective in that the document is not deliverable, flexible or capable of being monitored.
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.
Please refer to attached documents - submitted on behalf of Cumbria House Builders Group
1. INTRODUCTION
1.1
These representations are submitted on behalf of the Cumbria House Builders Group including the following companies:- Applethwaite, Briery Homes, Cumbrian Homes, Holbeck Homes, Russell Armer and Story Homes.
1.2
Analysis is undertaken comparing Core Strategy housing requirements compared to proposed provision at district wide level and then in each of the settlement hierarchies referred to in CS1.2 namely, Kendal and Ulverston separately as Principal Service Centres, Key Service Centres collectively, Local Service Centres collectively and Small Villages and Hamlets collectively.
1.3
Phasing of provision is analysed at district wide level only.
1.4
In the analysis of the settlements or settlement hierarchy categories, the ‘approximate’ percentage of gross requirements referred to in Core Strategy policy is applied.
1.5
No comment is made upon the appropriateness of any of the housing allocations, the proposed phasing or capacity of individual sites. This report simply analyses the implications of the Land Allocations document for housing land provision in the District as currently proposed.
2. DISTRICTWIDE HOUSING REQUIREMENTS
2.1 THE PLANNING AUTHORITY’S POSITION
2.1.1
The Land Allocations document sets out dwellings required in a table on page 16 of that document. One can see from the TOTAL row at the bottom of the table that the planning authority assume the following:- Completions to date 1690 dwellings; Planning permissions 1042 dwellings; Small identified sites 289 dwellings; and A total net requirement by 2025 of 5778 dwellings.
2.1.2
Table 1A: Overall Housing Requirement and Balance between Settlements on page 17 of the Land Allocations document indicates how the authority intends to meet the requirement.
2.1.3
Elements of the two tables are brought together in Appendix A which compares cumulative requirements with cumulative provision in each of the phases. It is clear that the Land Allocation’s strategy to meet housing requirements is to under provide for housing in the period up to 2017 and 2022 and only seek to make up the shortfall in the third phase. As a result the planning authority is in danger of not being able to identify a five year land supply soon after the Land Allocations document is adopted.
2.1.4
More detailed analysis of intended housing provision is set out in Appendix B which brings together all the housing allocations and mixed use sites referred to in policy and text within each of the relevant settlements and hierarchies. There is an element of interpretation of what is understood to be the planning authority’s position in Appendix B and in the tables below.
2.1.5
It is apparent that housing provision is dependent upon several large sites delivering significant housing completions in Phase 3, (a three year period) including two sites which are identified as Broad Locations for New Housing in the context of draft Policy LA1.4. The Milnthorpe Broad Location does not appear to be taken into account in the authority’s assessment of provision.
2.2 THE HOUSE BUILDERS’ASSESSMENT
2.2.1
The House Builders do not agree with the authority’s assessment of net dwelling requirements or the likely level of housing completions from both identified and unidentified sites. Detailed reasoning is provided in Appendix D.
2.2.2
In brief:- for planning permissions only net increases should be counted not gross figures; small site contributions should not be included, but a contribution from windfalls in the first 5 years would be appropriate but this element is included in the planning permissions in any case; development rates for any one site or sites should only be at a maximum of 30 dwellings per annum, as a result, if phased release remains as suggested a significant number of completions would be beyond the plan period; if the Broad Locations are only to come forward post 2022, then the maximum each site could contribute in the three year period to 2025 is 90 dwellings each (i.e. 30 dwellings per annum multiplied by 3 years), with the remainder beyond the plan period; the Land Allocations document assumes a contribution from small villages and hamlets, but there is a concern that housing completions from this source will be limited; and there is a need to provide for an element of slippage in relation to all sites to ensure the housing requirement is met.
2.2.3
Appended at C is the House Builder’s assessment of the housing and mixed use allocations. Large sites are phased at a maximum of 30 dwellings per annum based upon the Land Allocations reference to this annual yield in a footnote to Table 1A. Applying this annual rate results in some sites contributing in either a later phase or beyond the end of the plan period. In preparing this assessment it is not suggested that completions on large sites be held back by phasing, but that completions will naturally ‘spill over’ into later phases.
2.2.4
As can be seen, the House Builders consider there is a higher net requirement and assume housing completions from specifically allocated sites and broad locations to be 4727 dwellings in the plan period compared to the planning authority’s assumption of 5563 dwellings.
2.2.5
Taking all assumptions made by both the planning authority (as adjusted in Appendix B), the respective positions are set out in the table below
See attachment for Table 1
2.2.7
An explanation for the principle of slippage can be found in Section 7 of Appendix D. For the table above the slippage at 10% is calculated by adding the slippage at 10% from each of the tables 2-5 plus the net requirement of the small villages and hamlets (574 dwellings). The revised figure of 6849 dwellings is then assessed against the total provision which suggests under provision of 1891 dwellings.
2.2.8
As can be seen from Table 1 whilst the planning authority consider sufficient housing provision has been identified to meet Core Strategy requirements, the House Builders consider there to be a significant shortfall at district wide level.
3. KENDAL
3.1
Based upon the approach adopted above, the comparative positions in relation to Kendal can be summarised in Table 2.
See attachment for Table 2
3.3
The slippage at 10% is calculated by net requirement multiplied by 110% (i.e. 2134 x 110% = 2347) and then deducting 2347 from the allocations figure of 1491 dwellings to produce an overall shortfall of 856 dwellings.
3.4
The House Builders consider there is a significant shortfall of housing provision in Kendal to meet Core Strategy requirements.
4. ULVERSTON
4.1
The comparative positions in relation to Ulverston are summarised in Table 3.
See attachment for table 3
4.3
The House Builders consider there is a shortfall of housing provision in Ulverston to meet Core Strategy requirements.
5. KEY SERVICE CENTRES
5.1
The comparative positions in relation to the Key Service Centres are summarised in Table 4.
See attachment for table 4
5.3
The House Builders consider there is a shortfall of housing provision in the Key Service Centres to meet Core Strategy requirements.
6. LOCAL SERVICE CENTRES
6.1
The comparative positions in relation to Local Service Centres are summarised in Table 5.
See attachment for table 5
6.3
The Objector considers there is a shortfall of housing provision in the Local Service Centres to meet Core Strategy requirements.
7. SMALL VILLAGES AND HAMLETS
7.1
The comparative positions in relation to Local Service Centres are summarised in Table 6.
See attachment for table 6
7.3
The authority count small site contributions to determine the net requirement and then assume an anticipated rate to meet the net requirement. There is a small element of double counting here.
7.4
Table 6 includes all completions from the small villages and hamlets and the open countryside unrelated to any small settlement. However, it is apparent there is a clear policy contradiction between CS1.2 that requires approximately 11% of the 8800 new dwelling requirement to be provided for in the network of smaller villages and hamlets and CS6.1 which refers to a Housing Split 2003-2025 table that counts all completions in the small villages and hamlets and open countryside in a category entitled “All Other Areas”. Completions in the small villages and hamlets is in fact only 83 dwellings and therefore the level of under provision against the 11% requirement would be significantly higher than is indicated in the above table, if assessed on the basis of only 83 dwelling completions.
7.6
The reasoning behind a total anticipated contribution of 260 dwellings is set out in Appendix D. The House Builders consider there is likely to be a shortfall of housing provision in the Small Villages and Hamlets to meet Core Strategy requirements.
8. CONCLUSIONS
8.1
The Land Allocations document’s strategy is to under provide for housing in the period up to 2017 and 2022, but seek to make up the shortfalls in the last three years of the plan period. In so doing the authority rely on Broad Locations to be brought forward in the context of a plan review and for those sites, and others, to contribute housing completions at unrealistic development rates.
8.2
The Allocations document does not identify sufficient housing provision to meet Core Strategy housing requirements in the period 2003-2025 at district wide level or within individual settlement categories.
8.3
To be made sound the Land Allocations document needs to provide for significantly more housing.
8.4
To make the document easier to read all mixed use allocations with a housing element should be referred to in Policy LA1.3.
8.5
The Cumbria House Builders are keen to work with the planning authority to make the document sound. Individual house builders will make separate representations to demonstrate specific ways in which the document can be made sound.
See attachment for appendices
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I 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.
Technical nature of submissions
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
2. Cumbria House Builders Group , c/o Garner Planning Associates : 15 May 2012 08:00:00
A typed or handwritten document was submitted. This has been scanned and can be downloaded below:
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.
LA1.4 Broad Locations for New Housing
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 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.
Please refer to attached document on behalf of Cumbria House Builders Group
Please refer to attached documents - submitted on behalf of Cumbria House Builders Group
1. INTRODUCTION
1.1
These representations are submitted on behalf of the Cumbria House Builders Group including the following companies:- Applethwaite, Briery Homes, Cumbrian Homes, Holbeck Homes, Russell Armer and Story Homes.
1.2
Analysis is undertaken comparing Core Strategy housing requirements compared to proposed provision at district wide level and then in each of the settlement hierarchies referred to in CS1.2 namely, Kendal and Ulverston separately as Principal Service Centres, Key Service Centres collectively, Local Service Centres collectively and Small Villages and Hamlets collectively.
1.3
Phasing of provision is analysed at district wide level only.
1.4
In the analysis of the settlements or settlement hierarchy categories, the ‘approximate’ percentage of gross requirements referred to in Core Strategy policy is applied.
1.5
No comment is made upon the appropriateness of any of the housing allocations, the proposed phasing or capacity of individual sites. This report simply analyses the implications of the Land Allocations document for housing land provision in the District as currently proposed.
2. DISTRICTWIDE HOUSING REQUIREMENTS
2.1 THE PLANNING AUTHORITY’S POSITION
2.1.1
The Land Allocations document sets out dwellings required in a table on page 16 of that document. One can see from the TOTAL row at the bottom of the table that the planning authority assume the following:- Completions to date 1690 dwellings; Planning permissions 1042 dwellings; Small identified sites 289 dwellings; and A total net requirement by 2025 of 5778 dwellings.
2.1.2
Table 1A: Overall Housing Requirement and Balance between Settlements on page 17 of the Land Allocations document indicates how the authority intends to meet the requirement.
2.1.3
Elements of the two tables are brought together in Appendix A which compares cumulative requirements with cumulative provision in each of the phases. It is clear that the Land Allocation’s strategy to meet housing requirements is to under provide for housing in the period up to 2017 and 2022 and only seek to make up the shortfall in the third phase. As a result the planning authority is in danger of not being able to identify a five year land supply soon after the Land Allocations document is adopted.
2.1.4
More detailed analysis of intended housing provision is set out in Appendix B which brings together all the housing allocations and mixed use sites referred to in policy and text within each of the relevant settlements and hierarchies. There is an element of interpretation of what is understood to be the planning authority’s position in Appendix B and in the tables below.
2.1.5
It is apparent that housing provision is dependent upon several large sites delivering significant housing completions in Phase 3, (a three year period) including two sites which are identified as Broad Locations for New Housing in the context of draft Policy LA1.4. The Milnthorpe Broad Location does not appear to be taken into account in the authority’s assessment of provision.
2.2 THE HOUSE BUILDERS’ASSESSMENT
2.2.1
The House Builders do not agree with the authority’s assessment of net dwelling requirements or the likely level of housing completions from both identified and unidentified sites. Detailed reasoning is provided in Appendix D.
2.2.2
In brief:- for planning permissions only net increases should be counted not gross figures; small site contributions should not be included, but a contribution from windfalls in the first 5 years would be appropriate but this element is included in the planning permissions in any case; development rates for any one site or sites should only be at a maximum of 30 dwellings per annum, as a result, if phased release remains as suggested a significant number of completions would be beyond the plan period; if the Broad Locations are only to come forward post 2022, then the maximum each site could contribute in the three year period to 2025 is 90 dwellings each (i.e. 30 dwellings per annum multiplied by 3 years), with the remainder beyond the plan period; the Land Allocations document assumes a contribution from small villages and hamlets, but there is a concern that housing completions from this source will be limited; and there is a need to provide for an element of slippage in relation to all sites to ensure the housing requirement is met.
2.2.3
Appended at C is the House Builder’s assessment of the housing and mixed use allocations. Large sites are phased at a maximum of 30 dwellings per annum based upon the Land Allocations reference to this annual yield in a footnote to Table 1A. Applying this annual rate results in some sites contributing in either a later phase or beyond the end of the plan period. In preparing this assessment it is not suggested that completions on large sites be held back by phasing, but that completions will naturally ‘spill over’ into later phases.
2.2.4
As can be seen, the House Builders consider there is a higher net requirement and assume housing completions from specifically allocated sites and broad locations to be 4727 dwellings in the plan period compared to the planning authority’s assumption of 5563 dwellings.
2.2.5
Taking all assumptions made by both the planning authority (as adjusted in Appendix B), the respective positions are set out in the table below
See attachment for Table 1
2.2.7
An explanation for the principle of slippage can be found in Section 7 of Appendix D. For the table above the slippage at 10% is calculated by adding the slippage at 10% from each of the tables 2-5 plus the net requirement of the small villages and hamlets (574 dwellings). The revised figure of 6849 dwellings is then assessed against the total provision which suggests under provision of 1891 dwellings.
2.2.8
As can be seen from Table 1 whilst the planning authority consider sufficient housing provision has been identified to meet Core Strategy requirements, the House Builders consider there to be a significant shortfall at district wide level.
3. KENDAL
3.1
Based upon the approach adopted above, the comparative positions in relation to Kendal can be summarised in Table 2.
See attachment for Table 2
3.3
The slippage at 10% is calculated by net requirement multiplied by 110% (i.e. 2134 x 110% = 2347) and then deducting 2347 from the allocations figure of 1491 dwellings to produce an overall shortfall of 856 dwellings.
3.4
The House Builders consider there is a significant shortfall of housing provision in Kendal to meet Core Strategy requirements.
4. ULVERSTON
4.1
The comparative positions in relation to Ulverston are summarised in Table 3.
See attachment for table 3
4.3
The House Builders consider there is a shortfall of housing provision in Ulverston to meet Core Strategy requirements.
5. KEY SERVICE CENTRES
5.1
The comparative positions in relation to the Key Service Centres are summarised in Table 4.
See attachment for table 4
5.3
The House Builders consider there is a shortfall of housing provision in the Key Service Centres to meet Core Strategy requirements.
6. LOCAL SERVICE CENTRES
6.1
The comparative positions in relation to Local Service Centres are summarised in Table 5.
See attachment for table 5
6.3
The Objector considers there is a shortfall of housing provision in the Local Service Centres to meet Core Strategy requirements.
7. SMALL VILLAGES AND HAMLETS
7.1
The comparative positions in relation to Local Service Centres are summarised in Table 6.
See attachment for table 6
7.3
The authority count small site contributions to determine the net requirement and then assume an anticipated rate to meet the net requirement. There is a small element of double counting here.
7.4
Table 6 includes all completions from the small villages and hamlets and the open countryside unrelated to any small settlement. However, it is apparent there is a clear policy contradiction between CS1.2 that requires approximately 11% of the 8800 new dwelling requirement to be provided for in the network of smaller villages and hamlets and CS6.1 which refers to a Housing Split 2003-2025 table that counts all completions in the small villages and hamlets and open countryside in a category entitled “All Other Areas”. Completions in the small villages and hamlets is in fact only 83 dwellings and therefore the level of under provision against the 11% requirement would be significantly higher than is indicated in the above table, if assessed on the basis of only 83 dwelling completions.
7.6
The reasoning behind a total anticipated contribution of 260 dwellings is set out in Appendix D. The House Builders consider there is likely to be a shortfall of housing provision in the Small Villages and Hamlets to meet Core Strategy requirements.
8. CONCLUSIONS
8.1
The Land Allocations document’s strategy is to under provide for housing in the period up to 2017 and 2022, but seek to make up the shortfalls in the last three years of the plan period. In so doing the authority rely on Broad Locations to be brought forward in the context of a plan review and for those sites, and others, to contribute housing completions at unrealistic development rates.
8.2
The Allocations document does not identify sufficient housing provision to meet Core Strategy housing requirements in the period 2003-2025 at district wide level or within individual settlement categories.
8.3
To be made sound the Land Allocations document needs to provide for significantly more housing.
8.4
To make the document easier to read all mixed use allocations with a housing element should be referred to in Policy LA1.3.
8.5
The Cumbria House Builders are keen to work with the planning authority to make the document sound. Individual house builders will make separate representations to demonstrate specific ways in which the document can be made sound.
See attachment for appendices
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I 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.
Technical nature of submissions
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
3. Cumbria House Builders Group , c/o Garner Planning Associates : 15 May 2012 08:05:00
A typed or handwritten document was submitted. This has been scanned and can be downloaded below:
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.
2.18
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 effective in that the document is not deliverable, flexible or capable of being monitored.
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.
Please refer to attached document on behalf of Cumbria House Builders Group
Please refer to attached documents - submitted on behalf of Cumbria House Builders Group
1. INTRODUCTION
1.1
These representations are submitted on behalf of the Cumbria House Builders Group including the following companies:- Applethwaite, Briery Homes, Cumbrian Homes, Holbeck Homes, Russell Armer and Story Homes.
1.2
Analysis is undertaken comparing Core Strategy housing requirements compared to proposed provision at district wide level and then in each of the settlement hierarchies referred to in CS1.2 namely, Kendal and Ulverston separately as Principal Service Centres, Key Service Centres collectively, Local Service Centres collectively and Small Villages and Hamlets collectively.
1.3
Phasing of provision is analysed at district wide level only.
1.4
In the analysis of the settlements or settlement hierarchy categories, the ‘approximate’ percentage of gross requirements referred to in Core Strategy policy is applied.
1.5
No comment is made upon the appropriateness of any of the housing allocations, the proposed phasing or capacity of individual sites. This report simply analyses the implications of the Land Allocations document for housing land provision in the District as currently proposed.
2. DISTRICTWIDE HOUSING REQUIREMENTS
2.1 THE PLANNING AUTHORITY’S POSITION
2.1.1
The Land Allocations document sets out dwellings required in a table on page 16 of that document. One can see from the TOTAL row at the bottom of the table that the planning authority assume the following:- Completions to date 1690 dwellings; Planning permissions 1042 dwellings; Small identified sites 289 dwellings; and A total net requirement by 2025 of 5778 dwellings.
2.1.2
Table 1A: Overall Housing Requirement and Balance between Settlements on page 17 of the Land Allocations document indicates how the authority intends to meet the requirement.
2.1.3
Elements of the two tables are brought together in Appendix A which compares cumulative requirements with cumulative provision in each of the phases. It is clear that the Land Allocation’s strategy to meet housing requirements is to under provide for housing in the period up to 2017 and 2022 and only seek to make up the shortfall in the third phase. As a result the planning authority is in danger of not being able to identify a five year land supply soon after the Land Allocations document is adopted.
2.1.4
More detailed analysis of intended housing provision is set out in Appendix B which brings together all the housing allocations and mixed use sites referred to in policy and text within each of the relevant settlements and hierarchies. There is an element of interpretation of what is understood to be the planning authority’s position in Appendix B and in the tables below.
2.1.5
It is apparent that housing provision is dependent upon several large sites delivering significant housing completions in Phase 3, (a three year period) including two sites which are identified as Broad Locations for New Housing in the context of draft Policy LA1.4. The Milnthorpe Broad Location does not appear to be taken into account in the authority’s assessment of provision.
2.2 THE HOUSE BUILDERS’ASSESSMENT
2.2.1
The House Builders do not agree with the authority’s assessment of net dwelling requirements or the likely level of housing completions from both identified and unidentified sites. Detailed reasoning is provided in Appendix D.
2.2.2
In brief:- for planning permissions only net increases should be counted not gross figures; small site contributions should not be included, but a contribution from windfalls in the first 5 years would be appropriate but this element is included in the planning permissions in any case; development rates for any one site or sites should only be at a maximum of 30 dwellings per annum, as a result, if phased release remains as suggested a significant number of completions would be beyond the plan period; if the Broad Locations are only to come forward post 2022, then the maximum each site could contribute in the three year period to 2025 is 90 dwellings each (i.e. 30 dwellings per annum multiplied by 3 years), with the remainder beyond the plan period; the Land Allocations document assumes a contribution from small villages and hamlets, but there is a concern that housing completions from this source will be limited; and there is a need to provide for an element of slippage in relation to all sites to ensure the housing requirement is met.
2.2.3
Appended at C is the House Builder’s assessment of the housing and mixed use allocations. Large sites are phased at a maximum of 30 dwellings per annum based upon the Land Allocations reference to this annual yield in a footnote to Table 1A. Applying this annual rate results in some sites contributing in either a later phase or beyond the end of the plan period. In preparing this assessment it is not suggested that completions on large sites be held back by phasing, but that completions will naturally ‘spill over’ into later phases.
2.2.4
As can be seen, the House Builders consider there is a higher net requirement and assume housing completions from specifically allocated sites and broad locations to be 4727 dwellings in the plan period compared to the planning authority’s assumption of 5563 dwellings.
2.2.5
Taking all assumptions made by both the planning authority (as adjusted in Appendix B), the respective positions are set out in the table below
See attachment for Table 1
2.2.7
An explanation for the principle of slippage can be found in Section 7 of Appendix D. For the table above the slippage at 10% is calculated by adding the slippage at 10% from each of the tables 2-5 plus the net requirement of the small villages and hamlets (574 dwellings). The revised figure of 6849 dwellings is then assessed against the total provision which suggests under provision of 1891 dwellings.
2.2.8
As can be seen from Table 1 whilst the planning authority consider sufficient housing provision has been identified to meet Core Strategy requirements, the House Builders consider there to be a significant shortfall at district wide level.
3. KENDAL
3.1
Based upon the approach adopted above, the comparative positions in relation to Kendal can be summarised in Table 2.
See attachment for Table 2
3.3
The slippage at 10% is calculated by net requirement multiplied by 110% (i.e. 2134 x 110% = 2347) and then deducting 2347 from the allocations figure of 1491 dwellings to produce an overall shortfall of 856 dwellings.
3.4
The House Builders consider there is a significant shortfall of housing provision in Kendal to meet Core Strategy requirements.
4. ULVERSTON
4.1
The comparative positions in relation to Ulverston are summarised in Table 3.
See attachment for table 3
4.3
The House Builders consider there is a shortfall of housing provision in Ulverston to meet Core Strategy requirements.
5. KEY SERVICE CENTRES
5.1
The comparative positions in relation to the Key Service Centres are summarised in Table 4.
See attachment for table 4
5.3
The House Builders consider there is a shortfall of housing provision in the Key Service Centres to meet Core Strategy requirements.
6. LOCAL SERVICE CENTRES
6.1
The comparative positions in relation to Local Service Centres are summarised in Table 5.
See attachment for table 5
6.3
The Objector considers there is a shortfall of housing provision in the Local Service Centres to meet Core Strategy requirements.
7. SMALL VILLAGES AND HAMLETS
7.1
The comparative positions in relation to Local Service Centres are summarised in Table 6.
See attachment for table 6
7.3
The authority count small site contributions to determine the net requirement and then assume an anticipated rate to meet the net requirement. There is a small element of double counting here.
7.4
Table 6 includes all completions from the small villages and hamlets and the open countryside unrelated to any small settlement. However, it is apparent there is a clear policy contradiction between CS1.2 that requires approximately 11% of the 8800 new dwelling requirement to be provided for in the network of smaller villages and hamlets and CS6.1 which refers to a Housing Split 2003-2025 table that counts all completions in the small villages and hamlets and open countryside in a category entitled “All Other Areas”. Completions in the small villages and hamlets is in fact only 83 dwellings and therefore the level of under provision against the 11% requirement would be significantly higher than is indicated in the above table, if assessed on the basis of only 83 dwelling completions.
7.6
The reasoning behind a total anticipated contribution of 260 dwellings is set out in Appendix D. The House Builders consider there is likely to be a shortfall of housing provision in the Small Villages and Hamlets to meet Core Strategy requirements.
8. CONCLUSIONS
8.1
The Land Allocations document’s strategy is to under provide for housing in the period up to 2017 and 2022, but seek to make up the shortfalls in the last three years of the plan period. In so doing the authority rely on Broad Locations to be brought forward in the context of a plan review and for those sites, and others, to contribute housing completions at unrealistic development rates.
8.2
The Allocations document does not identify sufficient housing provision to meet Core Strategy housing requirements in the period 2003-2025 at district wide level or within individual settlement categories.
8.3
To be made sound the Land Allocations document needs to provide for significantly more housing.
8.4
To make the document easier to read all mixed use allocations with a housing element should be referred to in Policy LA1.3.
8.5
The Cumbria House Builders are keen to work with the planning authority to make the document sound. Individual house builders will make separate representations to demonstrate specific ways in which the document can be made sound.
See attachment for appendices
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I 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.
Technical nature of submission
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
