Response from E H Booths , c/o Steven Abbott Associates (Mr Lester)
1. E H Booths , c/o Steven Abbott Associates (Mr Lester) : 17 Apr 2012 14:44:00
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Policy/Site No.
LA5.3 Mixed Use Allocation, Ulverston, Canal Head
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.
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.
We seek the following changes to the proposed submission edition of the Land Allocations Development Plan Document (DPD).
Proposed site allocation MN31 is not included within the wider allocation for Site M28/Policy 5.3 Mixed Use Allocation, Ulverston Canal Head. We seek the inclusion of this area within the plan area and associated policy.
After positive discussions regarding this site with South Lakeland District Council in the context of the Canal Head area we were encouraged to submit representations in support of identifying the site as part of the wider redevelopment of the area. At the present time we do not consider that the strategic importance on the Booths site to the redevelopment of the Canal Head has been considered fully by Planning Policy. We would therefore request that South Lakeland reconsider their strategy for this area.
The South Lakeland Employment Review (February 2012) prepared by Lambert Smith Hampton, considered the site within section 9.20 of their report. However, Lambert Smith Hampton has failed to understand the reason for suggesting the allocation and its potential to assist in the development of surrounding sites. It is certainly not the case that Booths seek to increase the size of their existing store or relocated elsewhere, Booths simply seek to assist in the regeneration of the Canal Head area.
We reiterate our previous representation that was submitted, which we consider relevant in this situation and sets out our case. We have updated the references to taken into account the most up to date Land Allocations Development Plan Document.
1. Booths store in Ulverston, associated buildings (including Cumbria Crystal and the former Heron Glass building) and car park, sit next to the proposed Strategic Employment Sites (M26/E30) and (M28) Land at Ulverston Canal Head. There is a clear and longstanding objective to regenerate the Canal Head area and development which will take place in this area will be complementary to the Strategic Employment sites E30 and M26 in terms of the mix of land uses which are capable of being delivered. The relationship between Booths and the Canal Head offers great potential to create a very high quality built environment with the Canal at its heart and Booths as the anchor food store.
2. Our client thus supports the principle of the regeneration of the Canal Head which offers an exceptional and unique opportunity for Ulverston. Booths also support the proposed employment areas which make sensible use of a high quality strategic and sustainable location. Unfortunately, as proposed the DPD ignores the potential benefits of integrating the Canal Head area with Booths premises. The latter already contains a highly successful and very attractive high quality food store. Their other buildings have the potential to enhance the quality of that site in a way which would help to stimulate the wider Canal Head location. Seen from the other direction, the Canal head has great heritage value and potential which would be complementary to Booths quality offer.
3. The two areas – Booths premises and the Canal head should be linked so that there is a flow of pedestrians and cyclists between the two areas. To enhance the profile of The Canal Head, Booths store and the other buildings should be seen as part of the regeneration area and will help attract investment into the Canal head proper.
4. In spatial terms the aim should be to make Booths store accessible by foot from the Town Centre by walking through the proposed mixed use Canal Head area. This will enhance Booths site, the Canal Head and the Town Centre by breaking down ‘barriers’such that the wider area is permeable and performs as a whole rather than disjointed, unconnected elements.
5. In terms of the strategic employment area the spatial relationship between that and Booths premises should also be recognised given that access into it crosses Booths land. And the need to connect the two areas together. The key change we suggest to the DPD on this is that Site reference M28 should be extended to envelope all of Booths holding. At the same time the policy should be amended along the lines shown below. Central to that is a broadening of the land uses acceptable within the wider Canal Head location we propose. More particularly, it needs to include Class A (town centre) uses to take account of Booths premises AND to promote more of that type of use in the Canal Head as a whole alongside the other uses proposed by the Council.
For the Canal Head ‘project’ to be viable it is essential that Class A uses are accepted in principle to act as the lead use and catalyse the rest. It follows that Booths premises beyond the food store should enjoy a more relaxed approach than the fettered uses approved in their buildings in the past. These units have under achieved (one is empty)and currently do nothing to enhance the vitality of this key gateway and potential Canal Head related site. They do not represent Ulverston’s image well as the first port of call for many visitors. With a town centre mix of uses and connectivity with the Canal Head they will materially enhance its prospects of investment. We set out below some suggestions for how Policy 5.3 (site M28) could be reworded.
6. On a related matter we note that the term ‘employment’ is used. Given NPPF and the Minister for Decentralisation’s written statement (‘Planning for Growth’) we suggest that the term be replaced by ‘economic development’ albeit we accept that this would need to be qualified so that retail development is not accidentally promoted in unsustainable or otherwise inappropriate locations.
7. Finally, Booths are happy to assist the Council as a landowner with a major stake in Ulverston’s future and the subject area in particular. We would be happy to discuss the above matters further.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
To ensure that the interests of our client are represented at the examination.
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