Local Development Framework Consultation

0.0 Whole Document

Please find the response to the proposed submission document . The Agency acknowledges the work carried out so far and would wish to continue to work with Southlake land District Council as the plan progresses.

Many of the comments raised have already been highlighted in our meeting with yoursevles on the 7th February and should therefore be of no surprise to you . The Agency still has some concerns with regard to a number of the larger sites and would wisht o ensure any mitigation measures or issues are addressed.

The Highways Agency [the Agency] has undertaken a review of the proposed submission version Land Allocations Development Plan Document [DPD] recently released by South Lakeland District Council [SLDC] as part of their emerging Local Development Framework [LDF].
As you aware, the Agency has already had input into the development of the LDF through previous reviews, and most recently, from involvement in the development and review of the South Lakeland Transport Study, the outputs from which we believe should inform the DPD.
This letter reviews the document; comments on the proposed allocations contained within it, and considers the likelihood for negative material impacts upon the SRN as a result of the allocations coming forward.
For ease of reading, this letter generally addresses issues as they arise in the order of the DPD itself......

Summary:

From the review of the proposed submission Land Allocations DPD, the HA conclude that the only sites of real concern to the Agency are those in Ulverston and Swarthmoor. These sites are all deliverable within the LDF period, and as such, the Agencydoes not object to their inclusion within the DPD, but would want to continue to undertake joint-working with SLDC to establish how these sites can be delivered within the LDF period.
The other proposed allocations should be able to be delivered sustainably through the planning process. However the Agency would wish to work with SLDC in the preparation of Development Briefs for those sites identified as requiring one. In addition to those stated in the DPD, the HA would recommend the following sites also have Development Briefs prepared:
• Site E13M at Milnthorpe;
• Site M9M2-mod at Milnthorpe; and
• Site R675M-mod at Holme.
Agency has worked closely with SLDC regarding the emergence of their LDF, and the recent review of the South Lakeland Transport Study has allowed the trip generation characteristics of each site to be understood, reviewed, and commented upon. This has allowed the Agency to understand the implications of each site, as well as their deliverability and infrastructure requirements. These issues were raised at the 7th February meeting, and these issues remain valid when considering the implication of the DPD.
By continuing this joint-working through the emergence of the Development Briefs for the key land allocations, the Agency will be able to inform their deliverability and infrastructure requirements, as well as ensuring that they emerge within the context of the wider A590 Route Management Strategy. Such joint-working will ensure that houses and jobs coming forward within the District, but to the detriment to the operation of the A590.

[see also additional report attached]

0.2 Section 2

Yes

The HA is generally supportive of the content of this section, and the approach and methodologies used. The settlement hierarchy used is appropriate and the intention to prioritise development within existing settlement boundaries is welcomed.

2.67

No

It is our understanding that Development Briefs will be issued as Supplementary Planning Documents for major, complex or sensitive sites. The Agency welcomes this approach and will continue the joint-working with SLDC in the production of the Briefs, so that the impact upon the SRN can be managed at the earliest opportunity. Notwithstanding, the Agency recommends that Development Briefs should be prepared for the following developments in addition to the ones presented:

• Site E13M at Milnthorpe;
• Site M9M2-mod at Milnthorpe; and
• Site R675M-mod at Holme.
Any issues arising from other sites in the area can be considered on a case-by-case basis through the planning process. The Agency requests that Development Briefs be prepared for the M9M2-mod site at Milnthorpe as it is of a larger size and closer to the SRN than other sites nearby which will have Development Briefs prepared. Similarly, site R675M-mod at Holme should have a Development Brief prepared as per the other, smaller housing site at Holme; R653M-mod............

A Development Brief should also be prepared for Site E13M at Milnthorpe as this is a sizable employment site, which whilst adjacent to existing employment land is poorly served by public transport and is remote from any settlement.............

Summary
From the review of the proposed submission Land Allocations DPD, the HA conclude that the only sites of real concern to the Agency are those in Ulverston and Swarthmoor. These sites are all deliverable within the LDF period, and as such, the Agencydoes not object to their inclusion within the DPD, but would want to continue to undertake joint-working with SLDC to establish how these sites can be delivered within the LDF period.
The other proposed allocations should be able to be delivered sustainably through the planning process. However the Agency would wish to work with SLDC in the preparation of Development Briefs for those sites identified as requiring one. In addition to those stated in the DPD, the HA would recommend the following sites also have Development Briefs prepared:
• Site E13M at Milnthorpe;
• Site M9M2-mod at Milnthorpe; and
• Site R675M-mod at Holme.

2.70

No

The boxes below Paragraph 2.70 detail the thresholds at which various assessments would need to be made for each type of allocation, including transport statements/assessments and travel plans. The Highways Agency advise that the values in these boxes are amended to the following to be in line with the thresholds in DfT’s Guidance on Transport Assessments.

Table 1 Thresholds for Transport Statement/Assessment & Travel Plan

Development Type Size No Assessment Transport Statement Transport Assessment & Travel Plan
Housing (Land Use Class C3) Unit <50 units 50 < 80 units >80 units
Employment (B1) GFA <1,500 sqm 1,500 < 2,500 sqm > 2,500 sqm
Employment (B2) GFA <2,500 sqm 2,500 < 4,000 sqm > 4,000 sqm
Employment (B8) GFA <3,000 sqm 3,000 < 5,000 sqm > 5,000 sqm

0.3 Section 3

Yes

Kendal & Surrounding Area
The Allocations DPD seeks to accommodate around 60% of new housing and employment in Kendal and its surrounding area. This totals approximately 2,000 homes in Kendal, 300 each in Kirkby Lonsdale and Milnthorpe, and 800 spread around other local service centres.
An allocation of 20 hectares of employment land is to be provided over the LDF period which will be focused on Kendal itself. It is stated that industrial and distribution uses will seek to locate where they are accessible via a range of means and there they can be connected to the Strategic Road Network without detrimental impact upon the town centre network and such development will be acceptable to the Agency provided it can be demonstrated that the SRN will be “no worse off” as a result.
In general, the Agency would have no issues with any one site in the Kendal area provided it inputs and works with SLDC as part of the work into the emerging Development Briefs for the larger sites, particularly the Strategic Site at Scroggs Wood and proposed business park at Burton Road.
Any issues arising from other sites in the area can be considered on a case-by-case basis through the planning process. The Agency requests that Development Briefs be prepared for the M9M2-mod site at Milnthorpe as it is of a larger size and closer to the SRN than other sites nearby which will have Development Briefs prepared. Similarly, site R675M-mod at Holme should have a Development Brief prepared as per the other, smaller housing site at Holme; R653M-mod.

3.3

Yes

It is noted that the Land Allocations DPD does not apply to proposals for the Canal Head scheme at Kendal, which will be subject to a separate DPD. The Agency will continue to work with SLDC on the development of planning documentation at this location to ensure the site comes forward sustainably.
The Agency welcomes the focus of development to be on the main service centre in the area, as it is the most sustainable location within the District. However, with so much development being focused on one area, there is potential for cumulative impacts over the course of the LDF period.

0.4 Section 4

Yes

Grange-over-Sands & Surrounding Area
The majority of sites within this area are small in size and whilst the Agency will monitor the potential for cumulative impacts arising from development, there is no one significant generator of traffic which would impact upon the SRN.

0.5 Section 5

Yes

Ulverston and Furness
This section covers the sites to be allocated primarily in the key service centre of Ulverston, but also the surrounding settlements of Kirkby-in-Furness, Broughton-in-Furness, Great and Little Urswick, Swarthmoor, Greenodd and Penny Bridge. Ulverston is of particular interest to the Agency as the A590 bi-sects the town, as well as providing the strategic link to Barrow-in-Furness, and therefore it is crucial that its operation is not compromised by development.....

Furness
Other sites in Furness are generally small and located within existing settlements. In addition they are generally remote from the SRN. It is therefore the HA impression that these sites can be delivered through the planning process and no one site will impact unacceptably upon the operation of the A590.

5.7

Yes

As mentioned previously, the A590 around Ulverston was subject to a Transport Study undertaken by KR Synergy. The sites considered in the Allocations DPD are the same as those considered in the Study and therefore the Agency will already be aware of these proposals and the concerns raised through the review process and at the subsequent 7th February meeting with SLDC remain the same.

LA1.3 Housing Allocations - RN684 SWM SWARTHMOOR ADJACENT TO KINGSLEY AVENUE

Swarthmoor
The two housing sites - RN109M & RN315# - in Swarthmoor propose 161 dwellings. Whilst it is appreciated that this is an appropriate location to locate new housing development, in accordance with the Core Strategy, it is not appropriate for an increase in vehicles to use the A590 / Main Road junction, due to the safety concerns as raised at the 7th February meeting with SLDC. In addition, it is not considered appropriate for the smaller residential site – R684SW to use Rufus Lane as a means of accessing the A590 due to visibility constraints.
However, these issues are not necessarily a barrier to development, and access arrangements, suitable to all parties, will be sought, following liaison with Cumbria County Council Highways. It may be more suitable for any access arrangements to be considered in terms of wider Agency aspirations at this location, to ensure consistency in approach, and this will be able to inform any Development Briefs that are produced as a consequence of the Land Allocations DPD consultation.

LA1.3 Housing Allocations - RN109M RN315# SWARTHMOOR OFF CROSS-a-MOOR

Swarthmoor
The two housing sites - RN109M & RN315# - in Swarthmoor propose 161 dwellings. Whilst it is appreciated that this is an appropriate location to locate new housing development, in accordance with the Core Strategy, it is not appropriate for an increase in vehicles to use the A590 / Main Road junction, due to the safety concerns as raised at the 7th February meeting with SLDC. In addition, it is not considered appropriate for the smaller residential site – R684SW to use Rufus Lane as a means of accessing the A590 due to visibility constraints.
However, these issues are not necessarily a barrier to development, and access arrangements, suitable to all parties, will be sought, following liaison with Cumbria County Council Highways. It may be more suitable for any access arrangements to be considered in terms of wider Agency aspirations at this location, to ensure consistency in approach, and this will be able to inform any Development Briefs that are produced as a consequence of the Land Allocations DPD consultation.

LA1.3 Housing Allocations - R697 & part R242 ULVERSTON CROFTLANDS EAST

‘South Ulverston Urban Extension’
The group of residential land allocations which form a band around the south of the Town propose a total of 984 dwellings. It is accepted that this cluster of sites are not located directly by the A590, however, the limited route choices within Ulverston mean that a high proportion of trips from these housing sites will use the A590 in the AM and PM peak periods to access employment opportunities.
It is accepted that a certain proportion of trips will dissipate via Mountbarrow Road and Priory Road to access Barrow-in-Furness and the settlements to the south of Ulverston, but the principal route choice will be the A590. Notwithstanding, locating residential development within an existing urban area is the most appropriate location, providing it is supported by the appropriate infrastructure.
Due to the number of dwellings being proposed in this location, any Development Brief produced should include the requirement for complimentary services which will help reduce the need for travel, such as local retail, medical facilities and associated services. In addition, public transport routes should be rerouted to penetrate the new residential areas, and these routes’ timings should be linked into the ‘express’ services to Barrow, as well as to national rail timetables, and the working hours of employment sites within Ulverston.

LA1.3 Housing Allocations - RN131M,RN141#, RN321# &RN284# Ulverston - Gascow Farm

‘South Ulverston Urban Extension’
The group of residential land allocations which form a band around the south of the Town propose a total of 984 dwellings. It is accepted that this cluster of sites are not located directly by the A590, however, the limited route choices within Ulverston mean that a high proportion of trips from these housing sites will use the A590 in the AM and PM peak periods to access employment opportunities.
It is accepted that a certain proportion of trips will dissipate via Mountbarrow Road and Priory Road to access Barrow-in-Furness and the settlements to the south of Ulverston, but the principal route choice will be the A590. Notwithstanding, locating residential development within an existing urban area is the most appropriate location, providing it is supported by the appropriate infrastructure.
Due to the number of dwellings being proposed in this location, any Development Brief produced should include the requirement for complimentary services which will help reduce the need for travel, such as local retail, medical facilities and associated services. In addition, public transport routes should be rerouted to penetrate the new residential areas, and these routes’ timings should be linked into the ‘express’ services to Barrow, as well as to national rail timetables, and the working hours of employment sites within Ulverston.

LA1.3 Housing Allocations - R690ulv, R691ULV, R126M, RN184, RN234# & part R242 ULVERSTON CROFTLANDS WEST - NOOK FARM

‘South Ulverston Urban Extension’
The group of residential land allocations which form a band around the south of the Town propose a total of 984 dwellings. It is accepted that this cluster of sites are not located directly by the A590, however, the limited route choices within Ulverston mean that a high proportion of trips from these housing sites will use the A590 in the AM and PM peak periods to access employment opportunities.
It is accepted that a certain proportion of trips will dissipate via Mountbarrow Road and Priory Road to access Barrow-in-Furness and the settlements to the south of Ulverston, but the principal route choice will be the A590. Notwithstanding, locating residential development within an existing urban area is the most appropriate location, providing it is supported by the appropriate infrastructure.
Due to the number of dwellings being proposed in this location, any Development Brief produced should include the requirement for complimentary services which will help reduce the need for travel, such as local retail, medical facilities and associated services. In addition, public transport routes should be rerouted to penetrate the new residential areas, and these routes’ timings should be linked into the ‘express’ services to Barrow, as well as to national rail timetables, and the working hours of employment sites within Ulverston.

LA1.3 Housing Allocations - RN250 ULVERSTON STONE CROSS MANSION

Daltongate
Two sites are proposed at Daltongate; one residential site comprising approximately 50 dwellings and an employment site comprising 3.1ha of B1 floorspace. Following discussions with SLDC, it is apparent that the Daltongate employment site is key for delivering employment in Ulverston within the LDF period.
In order for the employment site to be deliverable, direct access will be required from the A590, as the site cannot be accessed from other any part of the highway network. Whilst, the proposed residential site has access from Daltongate, the A590 / Daltongate junction is directly opposite the employment site, and as such, provides an opportunity for this junction to be improved to allow access to the proposed allocated employment site.
It was discussed at the 7th February meeting that the most appropriate solution at this location would be a roundabout, which would allow all movements, as well as providing a natural entry feature into Ulverston for traffic entering on the A590 from the west. It was discussed that the introduction of such a junction may provide the opportunity to provide a location to change the speed limit on the A590 at this point.
The Agency recommends that further discussions are held with Cumbria County Council to discuss potential highway improvements at this location, and should a proposal be agreed, then it could be included within the Development Brief for the site.

LA1.7 Business and Science Park Sites - M11M - Mod ULVERSTON LAND AT LIGHTBURN ROAD

Daltongate
Two sites are proposed at Daltongate; one residential site comprising approximately 50 dwellings and an employment site comprising 3.1ha of B1 floorspace. Following discussions with SLDC, it is apparent that the Daltongate employment site is key for delivering employment in Ulverston within the LDF period.
In order for the employment site to be deliverable, direct access will be required from the A590, as the site cannot be accessed from other any part of the highway network. Whilst, the proposed residential site has access from Daltongate, the A590 / Daltongate junction is directly opposite the employment site, and as such, provides an opportunity for this junction to be improved to allow access to the proposed allocated employment site.
It was discussed at the 7th February meeting that the most appropriate solution at this location would be a roundabout, which would allow all movements, as well as providing a natural entry feature into Ulverston for traffic entering on the A590 from the west. It was discussed that the introduction of such a junction may provide the opportunity to provide a location to change the speed limit on the A590 at this point.
The Agency recommends that further discussions are held with Cumbria County Council to discuss potential highway improvements at this location, and should a proposal be agreed, then it could be included within the Development Brief for the site.

5.3

Canal Head
The two sites at Canal Head – one a mixed use (heritage, tourism, leisure and residential), the other an employment site (B1, B2, B8) – will both require access from the A590 in order to be delivered. Within the Study it is shown that the Booths roundabout is over capacity in the 2025 future year assessment, and this is exacerbated when the development traffic (LDF allocations) is added.
It is worth noting that a significant proportion of the development traffic, which exacerbates the capacity issues at the Booths roundabout, will be the trips to and from the proposed Canal Head development. Discussions at the 7th February meeting failed to identify an appropriate point of access from either the SRN or local road network to unlock these sites.
It is suggested that the Agency inputs, where necessary, into any access proposals at this location, to ensure that no abortive work is undertaken.

LA1.6 Strategic Employment Sites - E30-M26 ULVERSTON LAND AT CANAL HEAD

Canal Head
The two sites at Canal Head – one a mixed use (heritage, tourism, leisure and residential), the other an employment site (B1, B2, B8) – will both require access from the A590 in order to be delivered. Within the Study it is shown that the Booths roundabout is over capacity in the 2025 future year assessment, and this is exacerbated when the development traffic (LDF allocations) is added.
It is worth noting that a significant proportion of the development traffic, which exacerbates the capacity issues at the Booths roundabout, will be the trips to and from the proposed Canal Head development. Discussions at the 7th February meeting failed to identify an appropriate point of access from either the SRN or local road network to unlock these sites.
It is suggested that the Agency inputs, where necessary, into any access proposals at this location, to ensure that no abortive work is undertaken.