Local Development Framework Consultation

7.1 General Comment

No

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. SLDC should not include Grange-over-Sands as one of its Key Service Centres because it does not meet the criteria in CS1.2 The development strategy for Principal Service Centres, Key Service Centres and Local Service Centres. This would mean that the number of proposed developments in Grange-over-Sands and district should be reduced and all proposed development sites should be reassessed. Development of brown field sites, such as Berners, should be prioritised and SLDC should take account of the views of local residents and Grange-over-Sands Town Council.
2. SLDC have not followed Government guidance about the use and interpretation of household surveys. They have not provided objective evidence to justify ‘housing need for Grange-over-Sands and District.
3. SLDC should be required to produce objective evidence to justify their plans to allow Grange-over-Sands to develop into a coastal urban sprawl incorporating Kents Bank.
4. SLDC should be required to remove sites MN25N, R672 and R79# from their Land Development DPD because development of these sites will lead to coalescence between the communities of Kents Bank and Allithwaite.
5. SLDC should be required to remove sites R449, R74 and R110 from their Land Development DPD because development of these sites will lead to further coalescence between the communities of Grange-over-Sands and Kents Bank.
6. SLDC should be required to produce clear evidence about how their proposed developments will enhance tourism in Grange-over-Sands and district.
7. SLDC should be required to explain why they have ignored recommendations made about green field sites and tourism in the Grange-over-Sands Regeneration Study (Douglas Wheeler Associates, November 2007), that they claim has informed SLDC's Core Strategy.
8. SLDC should be required to provide objective evidence that the local roads are adequate to support the proposed increase in population and traffic in Grange-over-Sands especially for known bottle-necks in Main Street and on Risedale Hill.
9. SLDC should not allow any development on prime green field land between Kents Bank and Allithwaite because it will lead to coalescence between these two separate communities.

I do not support SLDC’s Land Allocations DPD because it is based on spurious ‘housing need’ targets, has unnecessarily ear-marked important green field sites for development, encourages coalescence between Kents Bank and Allithwaite and does not meet the criteria of important Core Strategy policies.

No

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 following text of response 11287 includes the introduction and summary of the main conclusions from my response to SLDC’s Land Allocation Development DPD consultation that was submitted as a report entitled: ‘Soundness’ response to SLDC’s Land Allocation Development Plan (DPD, Jan 2012) focussing on SLDC’s ‘housing need’ predictions & SLDC’s vision for Grange-over-Sands and District.
My report included photographs and maps to illustrate comments that were made in the report.
I have requested that a copy of my full report is made available to the Planning Inspector.
[A copy of the full report is attached]

Introduction
During SLDC’s two Land Development consultations (2011) I submitted forms for
nine proposed land development sites in Kents Bank and Allithwaite raising a number
of serious problems that would arise if these sites were included in SLDC’s final Land
Allocation Development Plan document.
None of these problems have been satisfactorily resolved; one was made even
worse by nearly doubling the size of the proposed development.
After the close of SLDC’s first 2011 Land Development consultation I submitted a
form querying the way that SLDC’s Core Strategy had been applied when proposing
land development throughout the district with particular reference to Grange-over-
Sands.
I queried the basis of SLDC’s housing need projections, the lack of baseline data on
sustainability and environmental impacts, the vested interests of land owners
suggesting development land etc… (Appendix 1)
None of these problems have been addressed adequately.
I have invested a substantial amount of time in preparing these submissions because
it is important the unique heritages of Grange-over-Sands, Kents Bank and
Allithwaite are preserved for future generations, and, that this delightful part of the
Morecambe Bay coast is not allowed to evolve into an urban coastal sprawl.
Friends, relatives and environmental research workers visiting me from Canada, New
Zealand, Brazil, Greece, Italy, Spain, Scandinavia and even the south of England are
always impressed by Victorian/Edwardian heritage of Grange-over-Sands town
centre and are attracted by its back-drop of undulating rough pastureland, dry stone
walls and narrow lanes linking its local communities.
This is why they come to visit us!
Please include my submission with the papers submitted to the Government
Inspector.
I would also like to participate in the oral public examination into the soundness of the
SLDC Land Allocation Development Plan by the Inspector.


SUMMARY
Proposals in the SLDC Land Allocations Development Plan Document are
NOT JUSTIFIED because:
-The large error bars associated with the average and median values of
the four scenarios used to predict SLDC’s ‘housing need’ demonstrate
the variability of the underlying data and the need for careful
interpretation of the results.
- SLDC have not provided selecting objective evidence to support the
selection of the highest ‘housing need’ prediction scenario of 640
dwellings per annum.
- SLDC’s ‘housing need’ data indicates that its ‘building needs targets
should be reduced to the median value of 347 dwellings per annum.
- SLDC’s councillors appear to have been given incomplete advice by
their expert advisers before adopting the highest ‘housing need’
prediction from the four scenarios tested by the POPGROUP model.
- SLDC have not provided objective evidence to support their proposed
development of housing and employment units on important green field
sites.
- SLDC have not provided objective evidence for the level of ‘affordable
housing’ need in South Lakeland.
- SLDC have not provided objective evidence to support the use of one
funding model for ‘affordable housing’: making developers subsidise
35% affordable dwellings on all sites.
- Grange-over-Sands does not meet the SLDC Core Strategy criteria
required for designation as a Key Service Centre.
- SLDC have ignored key recommendations in the Grange-over-Sands
Regeneration Study 2007 that they claim had informed their
development proposals for Grange-over-Sands and district.
- Grange-over-Sands does not have appropriate facilities, roads or
infrastructure to cope with 500 additional dwellings.
- SLDC’s proposals will undermine the tourist industry that is the life
blood of the Grange-over-Sands and the Cartmel peninsula.
- SLDC have ignored the historical heritage of Kents Bank as a separate
community; it is not a suburb of Grange-over-Sands; it has a historical
heritage dating back to Mediaeval times.
- SLDC’s development proposals fail to protect the boundaries between
Kents Bank and Allithwaite from coalescence.
- SLDC’s development proposals erode the remaining green gaps
between Grange-over-Sands and Kents Bank.
- The Cartmel peninsula road system is already inadequate and cannot
absorb the extra traffic generated 734 new dwellings and an
unspecified number of additional employment units.
- It would be expensive and difficult to agree a route for a new trunk road
to the A590 that by-passed Grange-over-Sands.
- SLDC has a duty to ensure that the communities of Kents Bank and
Allithwaite retain their integrity and do not become part of a urban n
coastal sprawl that destroys the unique characteristics of Grange-over-
Sands and its surrounding area.
- The proposals for Grange-over-Sands and district are not sustainable
because they will destroy the town’s attraction as a unique coastal town
where tourists exploring the Cartmel peninsula will want to stay.
- SLDC’s consultation process has not been fair to local residents.
- Developers have been allowed to appoint Land Agents to lobby for
particularly desirable green field sites to be included in SLDC’s Land
Allocation DPD.
- SLDC’s consultation process has not been fair to local residents.

Proposals in the SLDC Land Allocations Development Plan Document are
NOT DELIVERABLE because:
- SLDC have provided no objective evidence that developers will be
prepared to develop prime sites on the basis of 35% affordable housing
in Grange-over-Sands and District.
- SLDC have made no provision for infrastructure development such as
upgrading roads, resolving water run-off drainage problems, utility
capacity etc...
- SLDC have made no provision for resolving two known traffic
bottlenecks on Risedale Hill and Main Street, Grange-over-Sands; key
sections of the B2577, the road that links Grange-over-Sands, Kents
Bank, Allithwaite and Flookburgh to the A590, Kendal, Lancaster and
the M6.

I do not support SLDC’s Land Allocation DPD

YES, I wish to participate at the oral examination

I wish to take part in the oral examination because SLDC have not made an adequate response to significant planning concerns, raised by local residents, during earlier consultation phases, particularly those relating to:
1. ‘Housing need’ in the Grange-over-Sands area.
2. Proposed green field site land allocations for the Grange-over-Sands area.
3. The adverse impact of the proposed developments on tourism, the life-blood of Grange-over-Sands and the Cartmel Peninsula.
4. The inadequate road system that links Grange-over-Sands to other SLDC Service Centres.
In addition, SLDC have not provided objective evidence that justifies their classification of Grange-over-Sands as an SLDC Key Service Centre. Grange-over-Sands does not meet SLDC’s Core Strategy Document definition of Key Service Centre: it does not have a secondary school and it is not directly linked to other SLDC Service Centres by a main trunk road.
Nor does the SLDC Land Allocation DPD take account of local residents’ wishes about how their community should be developed, or the views of Grange-over-Sands Town Council.

Please notify me

0.0 Whole Document

No

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. SLDC should not include Grange-over-Sands as one of its Key Service Centres because it does not meet the criteria in CS1.2 The development strategy for Principal Service Centres, Key Service Centres and Local Service Centres. This would mean that the number of proposed developments in Grange-over-Sands and district should be reduced and all proposed development sites should be reassessed. Development of brown field sites, such as Berners, should be prioritised and SLDC should take account of the views of local residents and Grange-over-Sands Town Council.
2. SLDC have not followed Government guidance about the use and interpretation of household surveys. They have not provided objective evidence to justify ‘housing need for Grange-over-Sands and District.
3. SLDC should be required to produce objective evidence to justify their plans to allow Grange-over-Sands to develop into a coastal urban sprawl incorporating Kents Bank.
4. SLDC should be required to remove sites MN25N, R672 and R79# from their Land Development DPD because development of these sites will lead to coalescence between the communities of Kents Bank and Allithwaite.
5. SLDC should be required to remove sites R449, R74 and R110 from their Land Development DPD because development of these sites will lead to further coalescence between the communities of Grange-over-Sands and Kents Bank.
6. SLDC should be required to produce clear evidence about how their proposed developments will enhance tourism in Grange-over-Sands and district.
7. SLDC should be required to explain why they have ignored recommendations made about green field sites and tourism in the Grange-over-Sands Regeneration Study (Douglas Wheeler Associates, November 2007), that they claim has informed SLDC's Core Strategy.
8. SLDC should be required to provide objective evidence that the local roads are adequate to support the proposed increase in population and traffic in Grange-over-Sands especially for known bottle-necks in Main Street and on Risedale Hill.
9. SLDC should not allow any development on prime green field land between Kents Bank and Allithwaite because it will lead to coalescence between these two separate communities.

I do not support SLDC’s Land Allocations DPD because it is based on spurious ‘housing need’ targets and has unnecessarily ear-marked important greenfield sites for development.

No

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.

Mrs Kennedy wishes to emphasise that the submitted response relates to all of the following:
LA1.1 Development boundaries: to ensure that new homes and workplaces are delivered in sustainable locations and to protect the character of the surrounding landscape.
LA1.2 Town centre boundaries: to maintain and enhance the vitality, viability and sustainability of the District’s town centres.
LA1.3 Housing allocations: to allocate available, deliverable and sustainable sites for a range of types and sizes of new housing to meet the needs of all sectors of the community.
LA1.9 Green gaps: to provide a framework for maintaining the framework of separate identities of communities in the District by maintaining visual and functional separation. (refers to Grange-over-Sands/Allithwaite boundary; ignores Grange-over-Sands/Kents Bank and Kents Bank/Allithwaite boundaries)
LA1.10 Existing green infrastructure purpose: to ensure that new development safe guards and where possible enhances the District’s green infrastructure.
LA3.2: Mixed use allocation at land south of Allithwaite Road, Kents Bank Grange-over-Sands:
LA3.3: Mixed use allocation at Guides Lot, Grange-over-Sands
And Core Strategy policies:
CS1.1 Sustainable development principles
CS1.2 The development strategy for Principal Service Centres, Key Service Centres and Local Service Centres
CS6.1 Meeting the housing requirement especially
CS6.2 Dwelling mix and type
CS6.3 Provision of affordable housing
CS7.1 Meeting the employment requirement
CS7.2 Type of employment land required and sectoral split
CS7.5 Town Centre and retail strategy – support will be given to maintaining the vitality and viability of town and local centres
CS7.6 Tourist development
CS8.1 Green infrastructure
CS8.2 Protection and enhancement of landscape and settlement
Especially site numbers:
Grange-over-Sands/Kents Bank: R449, R74 and R110
Kents Bank/Allithwaite: MN25N, R672, R79# and R89



The following text of response 11288 is taken from sections 1, 2 and 3 of my response to SLDC’s Land Allocation Development DPD consultation, in a report: ‘Soundness’ response to SLDC’s Land Allocation Development Plan (DPD, Jan 2012) focussing on SLDC’s ‘housing need’ predictions & SLDC’s vision for Grange-over-Sands and District.
My report included photographs, maps and tables to support comments that were made in the report. I have requested that this report be made available to the Planning Inspector.
The sections featured in response 11288 are:
1. Is SLDC’s interpretation of the Strategic Housing Market Assessment ‘sound’ in terms of the number of dwellings needed over the next 15 years?
2. Is SLDC’s policy for financing ‘affordable housing’ ‘sound’ and sustainable?
3. Does Grange-over-Sands meet SLDC’s Core Strategy criteria for a Key Service Centre?
The tables that were included with the text in the report have been stored elsewhere, formatting that clarified the text has been removed and spurious question marks have appeared that are not in the original text.
[The full report is attached]

1 Is SLDC’s interpretation of the Strategic Housing Market Assessment
‘sound’ in terms of the number of dwellings needed over the next 15 years?

1.1 The South Lakeland District 2011, Strategic Housing Market Assessment: Main Report
(October 2011) ARC4 states that a multi-method approach was used to model SLDC’s
‘housing need’ for the next 15 years including:
- A household survey.
- Interviews with key stakeholders.
- A review of relevant secondary data.

1.2 All four of the POPGROUP SLDC model predictions in ARC4 ‘s report rely heavily on
data from household surveys but, UK guidance* for Local Authorities states:
“…Throughout the guide there is an assumption that secondary data (ie data from local
administrative or national data collection exercises rather than specially commissioned
surveys or interviews) should be used where appropriate and feasible…” (page 16) and
*Strategic Housing Market Assessments: Practice Guidance Version 2, Department for Communities and Local Government. August 2007 (see Government web site)

1.3 The SLDC SHMA Report 2011 states that there was an overall 26% response rate to the
June 2011 household survey.

1.4 This is disingenuous. The response rate quoted is a percentage return of the number of
surveys sent out but, only 36.6% of SLDC occupied households were sent surveys.

1.5 Of those 37% households surveyed only 26% of households replied.

1.6 Therefore the survey information used was provided by 9.2% of the occupied
households on SLDC’s 2011 Council Tax register; this is not a representative sample.

1.7 In addition, only 67% of the households who replied are covered by the SLDC Land
Allocation Plan because the rest live in National Park areas that are outside the scope of
SLDC’s Land Allocation Development Plan.

1.8 The SLDC SHMA Report 2011 states that the total response rate was well in excess of
the 1,500 specified in Government guidance but gives no reference to the source of this
information.

1.9 If the aim was for at least 1,500 responses this is 8.9% of the surveys sent out or 3.3%
of occupied households on SLDC’s 2011 Council Tax register; neither are representative
samples therefore the information provided by the survey will include unquantifiable bias
as well as being impossible to verify.

1.10 Nor do these survey returns comply with recommendations in Annex C in the
Government Guidance on use of surveys which states:
“…Thirty per cent should be considered as an absolute minimum response rate. Fifty per
cent would be a good target, and in many areas, with the methods suggested above, it
should be achievable…” (page 23).

1.11 Even though the Government Guidance recommends that a 30% response rate should
be considered as an absolute minimum the SLDC SHMA report states that:
“…the survey element of the assessment is sufficiently statistically robust to undertake
detailed analysis and underpin core outputs of the study…”

1.12 This cannot be justified when the overall response rate to the surveys sent out was 26% and the response rate relative to occupied dwellings in South Lakeland was 9.2%.

1.13 The POPGROUP model used by ARC4 to project ‘housing need’ relies heavily on
information from a survey that was provided by 9’2% of the occupied households on
SLDC’s 2011 Council Tax register, and only 6.4% of the households who are covered by
the SLDC Land Allocation Plan.

1.14 The UK Government Guidance* also states:
“…Traditionally local surveys have been used although these can be costly to
administer and difficult to interpret…” (page 43)

1.15 It is not ‘sound’ to claim that the survey information is representative of the population
covered by SLDC’s Land Allocation document when it has been provided by only 9.2%
of SLDC’s occupied households.

1.16 There is no way to verify the accuracy of the information provided on the survey forms.

1.17 There is no reliable way of assessing the demographic bias of the survey information
relative to the households in SLDC. 2001 census information has been used in an
attempt to eliminate potential bias, but this is 11 years out-of-date!

1.18 The SLDC SHMA Report 2011 states that due to the demographic bias in the of the type of households replying to the survey the survey data for each sub-area was weighted by
comparison with 2001 census information on:

i. Tenure data: the proportion of affordable (social, rented and intermediate tenure)
and open market dwellings and

ii. Age of household reference person: under 60 and over 60 living in each of the
dwelling types.

1.19 SLDC’s Council Tax Database contains reliable, objective data that should have been
used as a source of information about changes in the number of occupied SLDC
households over the last ten years.

1.20 Information from SLDC’s Council Tax Database for 2001 to 2011 could have been
extracted and tabulated to provide information on: number of occupied households,
empty dwellings and second homes etc… for each of the last ten years.

1.21 The actual rate of growth in occupied households over the last ten years could then have been compared with the predicted growth from the four scenarios used for the
POPGROUP model.

1.22 The UK Government Guidance* also emphasises that the advantages of using
‘secondary data’ such as the Council Tax Database are that they:

i. Encourage consistency of approach between different authorities and housing
market areas.

ii. Reflect actual behaviour and events rather than aspirations.

iii. Often cheaper to obtain than primary data.

iv. Allows the monitoring of trends usually on an annual basis.

v. Can provide a picture of market conditions, based on small areas, which
identifies locational differences within housing market areas and

vi. The data are less affected by methodological problems of bias than surveys.

1.23 Table 1 below lists the main sources of data fed into the POPGROOUP model for
analysis as given in Appendix A of SLDC SHMA Report 2011.

1.24 It clearly demonstrates that the POPGROUP model relies heavily on information from
the SLDC household survey (2011; largely subjective and likely to be inaccurate for
questions on topics such as income) and Office for National Statistics (ONS) data
(based on national and regional trends).

1.25 ONS cautions on its website that:
“…Population estimates are calculated using a ‘top down’ approach. The national estimates for England and Wales are produced first; estimates for subnational areas are then produced and constrained to the national estimates. …” and
“…The data sources used are the best available on a nationally consistent basis. Information from administrative registers such as the numbers of births and deaths is reliable. However, estimates of international migration are largely derived from the International Passenger Survey (IPS) and are subject to sampling and non-sampling error…”

SEE TABLE 1 IN ATTACHED DOCUMENT

1.26 ONS warns on its website that:
“…Projections are uncertain and become increasingly uncertain the further they are carried
forward in time…

1.27 ONS population models are trend based with considerable uncertainties therefore
estimates for the future SLDC population and household characteristics derived from this
data should be interpreted with care because data used for SLDC projections may
include urban bias that is introduced because the NW region includes large urban
populations such as Liverpool and Manchester.

SEE TABLE 2 IN ATTACHED DOCUMENT

1.28 The POPGROUP demographic forecasting model is also trend based and uses a range of assumptions about natural change (births and deaths), migration and employment.

1.29 The ‘housing need’ predictions, per annum, for the whole of SLDC (including the Nation Park areas), from the four scenarios, range from 205 to 694 (Table 2, and Strategic
Housing Market Assessment report, Appendix C, page 49)

1.30 The mean of the four predictions is: 398 with a potential error of ± 296 dwellings per
annum, from the mean of the four predictions.

1.31 The median of the four predictions is: 347 with a potential error of +347 dwellings per
annum or -142 dwellings per annum, from the median of the four predictions.

1.32 The Strategic Housing Market Assessment report states many times that there is an
annual housing need of 640 per annum for SLDC (230: Lake District National Park; 9:
Yorkshire Dales and 402: SLDC), but the report does not explain how they have
selected these figures from the POPGROUP model predictions (Table 2).

1.33 ARC4’s proposed annual figure of 640 dwellings per annum is closest to the prediction of the labour force led POPGROUP scenario of 694 dwellings per annum: that is 240 more dwellings per annum than the average of the four scenarios, and, 293 more than the median of the four mode predictions.

1.34 The labour force led scenario is almost certainly an over estimate in terms of housing
need because it is be biased by information about National Insurance registrations for
overseas nationals applying for work during the period 2005/06 to 2009/10 (five years).

1.35 The five years selected will have a positive bias because the figures have been distorted by three years of exceptionally intensive cockling activity (when the price of cockles
rocketed in Europe), so that the Morecambe Bay cockle beds were fished out and
subsequently closed.

1.36 The figures for the labour force led scenario also include a high proportion of migrant
workers who come to the area for two or three years to improve their English and learn
Tourist industry service skills. They have no intention of living permanently in the area
and are frequently provided with accommodation by their employers. For example: The
Netherwood Hotel, Grange-over-Sands, Aynsome Manor Hotel, Cartmel, The Swan
Hotel, Newby Bridge etc…

1.37 The large error bars associated with the average and median values of the four
scenarios used to predict SLDC’s ‘housing need’ demonstrate the variability of the
underlying data and the need for careful interpretation of the results.

1.38 The average ‘housing need’ prediction has a positive bias because of weaknesses in the underlying employment data (see 1.35 and 1.36 above).

1.39 Given the uncertainties and weaknesses of the modelling data it would be more realistic to plan for a housing need using the median value of the four scenarios tested of: 347 dwellings per annum to determine ‘housing need’ throughput South Lakeland until 2025.

1.40 The selection of 640 dwellings per annum as SLDC’s housing need is not justified and is not supported by clear objective evidence.

1.41 Nor is it sustainable because the Land Allocation DPD does not make any provision for capital expenditure on infrastructure and services.

1.42 This would have the added advantage that it would not then be necessary to develop
important green field sites that should be part of the local heritage passed on to future
generations.

1.43 SLDC’s elected councillors cannot be expected to have the time and skills to read
through and understand the avalanche of documentation provided to support of the
housing need allocations; they therefore rely heavily of SLDC’s expert advisers.

1.44 It would appear that SLDC’s expert advisers gave incomplete information to councillors
about how the annual housing need figures were derived when councillors were asked
to approve SLDC’s Core Strategy document stating that there was an annual housing
requirement of 640 dwellings per annum.

1.45 Is it possible that SLDC selected a high housing need target because they have been
tempted by the UK Government’s offer of matched funding equivalent to the new build
Council Tax paid, for six years, for new build dwellings?

1.46 If so, SLDC have allowed a perceived short-term financial boost to cloud their judgement about the additional long-term costs of providing services to support their proposed housing need.

Section 1 Main Conclusions

SLDC’s annual ‘housing need’ targets are not sound because:
- The large error bars associated with the average and median values of
the four scenarios used to predict SLDC’s ‘housing need’ demonstrate
the variability of the underlying data and the need for careful
interpretation of the results.
- SLDC’s councillors appear to have been given incomplete advice by
their expert advisers before adopting the highest ‘housing need’
prediction from the four scenarios tested by the POPGROUP model
- SLDC’s ‘housing need’ data indicates that its ‘housing needs’ targets
should be reduced to the median value of 347 dwellings per annum.
- SLDC have selected the highest annual housing need prediction from
the four POPGROUP models tested.
- SLDC have not justified their ‘housing need’ selection of 640 dwellings
per annum with objective evidence.
- UK Government recommendations to Local Authorities recommend that
‘housing need’ prediction should not rely heavily on information supplied
by household surveys returned by a minority of households
- SLDC’s housing need predictions do rely heavily on information
provided from household surveys submitted by 6.4% of households
covered by SLDC’s Land Allocation Plan.
- SLDC may have selected a high annual housing need so that they
qualify for new build matched Council Tax funding from the UK
Government.

2 Is SLDC’s policy for financing ‘affordable housing’ ‘sound’ and sustainable?

2.1 SLDC defines Affordable housing as:
“…housing whether for rent, shared ownership or outright purchase, provided at cost
considered affordable in relation to income that are average, or in relation to the price of
general market housing…” (Source: glossary to the Allocations of Land Development
Plan Document, Emerging Site Options, Spring 2011).

2.2 This definition lacks clarity and is open to a wide range of interpretations.

2.3 ARC4’s SLDC Strategic Housing Market Assessment report relies heavily on survey
information which cannot be verified and needs to be interpreted with care (see
discussion in section1).

2.4 Survey information provided about the standard of accommodation and overcrowding
may be exaggerated by respondents who want to be re-housed.

2.5 The ‘housing need’ aspirations of some respondents may not be achievable for a wide
variety of reasons that are outside the control of SLDC.

2.6 SLDC’s Land Allocation DPD does not provide clear information about the number and
type of affordable dwellings that have been allocated to specific development sites eg
social, handicapped, sheltered, affordable rents for those who do not qualify for benefits,
shared ownership schemes, reduced price for affordable mortgages etc….

2.7 SLDC state that ‘affordable housing’ is divided into a range of categories but they do not
provide information about which categories are needed for specific development sites
supported by objective information justifying the use of sites selected those categories.

2.8 As part of the 2011 consultation exercise Cumbria County Council recommended that
MN25N, the important green gap site separating Kents Bank and Allithwaite, should only
be developed “…if a strategic housing allocation is required in the area…” but SLDC
have provided no evidence about the type of ‘affordable housing’ needed on this site and
no evidence to justify the need for 71 affordable dwellings at this specific location.

2.9 SLDC estimates for the number of ‘affordable houses’ needed throughout the district
cannot justified because they have not provided objective information about the number
of households on the waiting list for ‘affordable housing’ by SLDC service area, or by
type eg Kendal, Grange-over-Sands, single person, disabled, sheltered housing need,
family etc…

2.10 According to UK Government Advice to Local Authorities they should hold reliable data
about: “…the number of homeless families, those in temporary accommodation and the
extent of overcrowding…”

SEE TABLE 3 IN ATTACHED DOCUMENT

2.11 Table 3 summarises information about SLDC’s ‘affordable housing’ stock in the Cartmel peninsula provided on South Lakes Housing’s web pages. South Lakes Housing also provides information about their ‘affordable housing’ stock for the whole of South
Lakeland.

2.12 SLDC should therefore also have access up-to-date information about the number of
people on waiting lists for these of dwellings, the length of time that they have been on
the waiting list and the areas where they need accommodation that could have been
used to produce more accurate predictions about ‘affordable housing need’.

2.13 But, SLDC have provided no factual information about the number of households on
their waiting lists for affordable housing between 2002 and 2012 for each SLDC area
(Kendal, Ulverston, Grange-over-Sands etc…) showing type required (single person,
family, sheltered, disabled etc…) and typical waiting times. Why not?

2.14 The different terms and conditions for each ‘affordable housing’ development do not
preclude SLDC establishing a ‘master affordable housing list’, with information about the
geographical areas, the type of need (handicapped, sheltered housing, family housing,
retirement housing, ‘average income’ housing to rent or buy etc…) so that there is more
reliable data for the future modelling of local housing need.

2.15 The UK Government guidance also states that Cenus information should be used to
extract information about overcrowding and ‘hidden’ households, and, if this information
is out-of-date it can be compared with data from the Survey of English Housing (SHE) at
a regional level.

2.16 Reliable data from the National Census of 2011 will be released in July 2012; why hasn’t SLDC waited until this is available so that their estimates of affordable housing need are more reliable?

2.17 SLDC’s projected ‘affordable housing’ requirement for the Cartmel peninsula area is not based on objective data either in terms of numbers, or, areas of the District with a
particular ‘affordable housing’ need it is largely based on returns from survey
questionnaires (see Appendix 2).

2.18 SLDC has stated that the Grange-over-Sands area has an ‘affordable housing’ need of
35% of all new builds; their projected ‘new-build’ need of 501 (between 2010 and 2025)
equates to 175 ‘affordable’ residential units. But, the number of houses allocated to
Grange-over-Sands and district is an apparently arbitrary percent of SLDC’s projected
‘housing need’ assessment and is not allocated on evidenced need.

2.19 ‘Affordable housing’ is needed on the Cartmel Peninsula (including Grange-over-Sands and district) but, SLDC have not justified a specific need for 175 ‘affordable dwellings’ for the Cartmel peninsula based on objective evidence.

2.20 Nor have SLDC provided evidence that their overall ‘housing need’ policies, based on
the provision of 35% ‘affordable housing’, financed by subsidies from large development
projects requiring the use of swathes of ‘green gap’ land, are viable (see section 4).

2.21 The Conservative/Liberal Democrat Coalition Government has stated that it plans to
devolve more power to local councils for local planning decisions.

2.22 SLDC has completely ignored Grange-over-Sands Town Council submission to the 2011 consultation exercise as well as informed submissions from local residents. This attitude cannot be justified.

2.23 Recommendations by local councils about suitable development sites, local ‘affordable housing’ need and local infrastructure needs should be incorporated into the SLDC’s Land Allocation DPD to comply with Coalition Government policy.

2.24 SLDC’s ‘affordable housing’ policy depends on developers being forced to subsidise
‘affordable housing’ by allocating 35% of any dwellings built as ‘affordable houses’ but
they provide no objective evidence that this is feasible.

2.25 No examples are given of developers who have successfully developed sites on this
basis in the Cartmel peninsula. Are there any?

2.26 The more likely scenario is that developers will get planning permission and then claim that it is not financially viable for them to proceed on the 35% ‘affordable housing’ basis and then negotiate a reduced percentage of ‘affordable housing’ or, for the price of the ‘affordable housing’ to be raised.

2.27 In addition SLDC have not justified their selection of specific sites for ‘affordable housing’ with an objective evaluation of whether or not land proposed for development is in a suitable location for people who need affordable housing.

2.28 SLDC have not justified their reasons for ignoring other ways of financing ‘affordable
housing’ such as:
i. Using the Council Tax from second homes and holiday lets to set up a fund to
finance grants to local housing associations for new build affordable housing.
ii. Using funds from the SLSC reserve to make relatively low interest loans to local
residents who qualify for ‘affordable housing’ and who can prove that they have
paid their rent regularly for at least three years.
iii. Providing incentives for private owners to rent out empty properties as ‘affordable
housing’ eg grants to modernise properties that are made available for three years
or more, arrange for housing association to administer property (including
maintenance) at no extra cost to owner etc...
iv. Providing incentives for long-term residents of ‘family council houses’ to move to
smaller properties.
v. Developing a more effective system to ensure that housing association properties
are not sub-let by people moving away from the area due to changing their job; this
has happened and there do not appear to be effective systems to prevent it.

Section 2: Summary of main ‘affordable housing’ conclusions
SLDC’s annual ‘affordable housing need’ targets are NOT JUSIFIED because:
- Their definition of ‘affordable housing’ lacks clarity and is open to wide
interpretation.
- They are not based on objective evidence such as area waiting lists.
- They have not provided objective evidence that it is viable for developers to
develop site with a 35% ‘affordable housing’ requirement.
- They have not provided evidence that specific sites are suitable for the type of
‘affordable housing’ proposed.
- They have not considered alternative ways of financing ‘affordable housing’.

3 Does Grange-over-Sands meet SLDC’s Core Strategy criteria for a Key
Service Centre?

3.1 SLDC’s Land Allocation Plan states that Grange-over-Sands meets the criteria for
consideration as a Key Service Centre.

3.2 Section 2.10 of SLDC’s Core Strategy document justifies including Grange-over Sands
as a Key Service Centre because: “…
- It has good public transport links to outlying settlements.
- A primary school, a secondary school, library, doctor’s surgery, and a town centre
function providing at least a post office and 2,000 sq m of retail floorspace;
- A population of more than 1,500…”

3.3 Key Service Centre status is not justified because Grange-over-Sands does not meet
the public transport criteria for links to the outlying settlements. It is covered by the 532
Grange Area Bus Service:
- On Mondays to Saturdays the first circular bus leaves Grange station at 0800 hours
and the last bus leaves Grange station at 17.00.
- There are no buses linking the outlying villages in the evening.
- There are no buses linking the outlying villages on Bank Holidays or Sundays.

3.4 This means that residents of the Cartmel peninsula, including Grange-over-Sands and
district, are not able to use public transport if they wish to attend evening classes or
attend events organised at local community centres and village halls.

3.5 Key Service Centre status is not justified because Grange-over-Sands does not have a
secondary school which is listed as a requirement for Key Service Centres.

3.6 All children between the ages of 11 and 16 have to be bussed to Cartmel Priory school;
the local roads have no pavements and it would be dangerous for them to walk.

3.7 All children over 16 years old, living in Grange-over-Sands and district, have to travel by
bus or train to Kendal (15 miles), Milthorpe (12 miles), Ulverston (18 miles), Lancaster
(27 miles) or Barrow-in-Furness (27 miles) for sixth form and further education.

3.8 The introduction to SLDC’s Core Strategy document states: “ …Key Service Centres of
Grange-over-Sands, Milnthorpe,… are the main centres of provision of services and
employment for their hinterlands…” (page 10)

3.9 This is not justified because Grange-over-Sands is not the main centre of employment
for the Cartmel peninsula. Many workers living in this area commute to Kendal,
Lancaster, Ulverston and Barrow-in-Furness some also travel further afield to Sellafield
and Preston.

3.10 In most cases small business units would not provide these commuters with an
equivalent income to the one that they already have.

3.11 In 2003, when my workplace was transferred from Merlewood Research Station to
Lancaster University campus, no local employer would have paid me a salary that would
have made it worth changing jobs, even though I had considerably increased travel
costs at the new location and a 70 mile a day round trip to work.

3.12 Apart from retail shops and other tourist related businesses, such as hotels, most small businesses are based in Flookburgh with some in Cartmel, Allithwaite and Lindale, and a few in Grange-over-Sands.

3.13 There have been no large employers in Grange-over-Sands since the Natural
Environment Research Council’s Centre for Ecology and Hydrology was re-located from
Merlewood Research Station to the University of Lancaster Campus in October 2003
(80-90 staff). This property is now owned by the Holiday Bond Company. It has been
converted to luxury self-catering holiday apartments and currently has about six
employees.

3.14 SLDC’s Core Strategy document states that the Regional Spatial Strategy recommends:
“…that development in rural areas should be concentrated in these Key Service Centres
and should be of a scale and nature appropriate to fulfil the needs of local communities
in terms of housing, employment and services, and to enhance the quality of rural life…”

3.15 The development proposed for Grange-over-Sands and district is not appropriate in
terms of proposed housing, employment, services or quality of rural life (see section 4).

3.16 Grange-over-Sands does not have a hospital. All patients needing minor hospital
treatment have to travel to Kendal (30 mile round trip); those needing more specialist
treatment have to travel to Barrow-in-Furness or Lancaster (both approximately 54 mile
round trips).

3.17 Given the inadequacy of local roads trips to local hospitals are already time consuming; this will be considerably worse if 735 additional dwellings and an unspecified number of employment units are built in Grange-over-Sands and district before upgrading local roads (see also section 7).

3.18 A few days ago the family of a man in Grange-over-Sands who was assessed as
needing urgent medical treatment was told that there would be at least a four hour wait
for an ambulance and were recommended to find an alternative method of getting him to
hospital. Unfortunately this is not an isolated example.

3.19 This is evidence that Grange-over-Sands does not have the capacity to act as a Key
Service Centre for existing households.

3.20 How is the University of Morecambe Bay NHS Trust going to cope with the increased
number of households proposed by SLDC?

3.21 The ‘main’ road to Grange-over-Sands, from the A590 Meathop roundabout, is the
B5277 that also links Grange-over-Sands to Kents Bank, Allithwaite, Flookburgh, Cark
and Holker. Other villages in the Grange-over-Sands hinterland are linked by C roads.

3.22 Milnthorpe (A6) and Kirbky Lonsdale (A65), the other towns that SLDC has identified as
Key Service Centres, are linked directly to other towns and to the M6 by A roads making
them easily accessible.

3.23 Grange-over-Sands is not directly linked to SLDC Principal Service Centres, to other
Key Service Centres or to the M6 by a trunk road therefore SLDC cannot justify
identifying Grange-over-Sands as a Key Service Centre.

3.24 Grange-over-Sands is primarily a small coastal town that relies on tourism.

3.25 Tourists are attracted to Grange-over-Sands because of its unique heritage as a
Victorian coastal town surrounded by gentle limestone hills with traditional fell pastures
therefore it would be detrimental to Grange-over-Sands’ attraction as a tourist
destination if these pastures are built over as proposed in SLDC’s Land Allocation
document.

3.26 Grange-over-Sands does not meet the criteria of a Key Service Centre defined in
SLDC’s Core Strategy document SLDC are not justified proposing large-scale housing
and employment developments in Grange-over-Sands and District.

3.27 Section 2.20 of SLDC’s Core Strategy document states:”… the amount of land allocated in each Key Service Centre will have regard to: the capacity of existing services to
accommodate development; critical thresholds for new service investment; the size,
character and environmental capacity of the existing settlement; and the need to secure
regeneration and/or investor confidence…”

3.28 Again SLDC appear to have ignored their own criteria when defining Grange-over-Sands as a Key Service Centre suitable for large scale housing and employment developments because:
- The Grange-over-Sands and district road system is already inadequate (mainly C
roads; linked to A590 by B5277).
- Utility provision in Grange-over-Sands is inadequate and would need major capital
investment to sustain the proposed developments.
- The topography and environmental value of green spaces in Grange-over-Sands and
district will be destroyed along with tourism, the ‘life blood’ of the Cartmel peninsula if
development on the scale proposed is permitted.

3.29 It would appear that SLDC councillors were given inadequate information when they
voted to accept Planning Department recommendations, in SLDC’s Core Strategy
document, to classify Grange-over-Sands as a Key Service Centre.

3.30 There are only two SLDC District councillors for Grange-over-Sands so that their
representations on behalf of Grange-over-Sands and District are easily over-ridden by
the majority of councillors from Kendal and Ulverston.

3.31 Historically SLDC has also ignored representations from Grange-over-Sands Town
Council even though they are elected representatives of the local community. Why?
SLDC have ignored their stated objective of ensuring:
“…the adequate provision of additional housing…in a way that gives priority to the
housing needs of the town…”

Section 3: Should Grange-over-Sands be a Key Service Centre:
Summary of main conclusions
- Grange-over-Sands does not meet SLDC’s criteria for a Key Service
Centre therefore it should not have been classified as an SLDC Key
Service Centre.
- Grange-over-Sands should be treated as a small coastal town that is
dependent on the tourist industry and has unique development needs.
- Grange-over-Sands is not suitable for large scale development because
of its topographical location; the surrounding rough pasture lands are
part of its attraction.
- All proposed development should be considered in this context and
should be concentrated on brown field sites.
- Grange-over-Sands’ proximity of other local communities means that it
is inappropriate allow green field developments that will lead to Grange-over-
Sands absorbing other settlements.

I do not support SLDC’s Land Allocations DPD because it is based on spurious ‘housing need’ targets and has unnecessarily ear-marked important greenfield sites for development.

YES, I wish to participate at the oral examination

I wish to take part in the oral examination because SLDC have not made an adequate response to significant planning concerns, raised by local residents, during earlier consultation phases, particularly those relating to:
1. ‘Housing need’ in the Grange-over-Sands area.
2. Proposed green field site land allocations for the Grange-over-Sands area.
3. The adverse impact of the proposed developments on tourism, the life-blood of Grange-over-Sands and the Cartmel Peninsula.
4. The inadequate road system that links Grange-over-Sands to other SLDC Service Centres.
In addition, SLDC have not provided objective evidence that justifies their classification of Grange-over-Sands as an SLDC Key Service Centre. Grange-over-Sands does not meet SLDC’s Core Strategy Document definition of Key Service Centre: it does not have a secondary school and it is not directly linked to other SLDC Service Centres by a main trunk road.
Nor does the SLDC Land Allocation DPD take account of local residents’ wishes about how their community should be developed, or the views of Grange-over-Sands Town Council.

Please notify me

LA1.3 Housing Allocations - All Grange-over-Sands sites

No

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. SLDC should not include Grange-over-Sands as one of its Key Service Centres because it does not meet the criteria in CS1.2 The development strategy for Principal Service Centres, Key Service Centres and Local Service Centres. This would mean that the number of proposed developments in Grange-over-Sands and district should be reduced and all proposed development sites should be reassessed. Development of brown field sites, such as Berners, should be prioritised and SLDC should take account of the views of local residents and Grange-over-Sands Town Council.
2. SLDC have not followed Government guidance about the use and interpretation of household surveys. They have not provided objective evidence to justify ‘housing need for Grange-over-Sands and District.
3. SLDC should be required to produce objective evidence to justify their plans to allow Grange-over-Sands to develop into a coastal urban sprawl incorporating Kents Bank.
4. SLDC should be required to remove sites MN25N, R672 and R79# from their Land Development DPD because development of these sites will lead to coalescence between the communities of Kents Bank and Allithwaite.
5. SLDC should be required to remove sites R449, R74 and R110 from their Land Development DPD because development of these sites will lead to further coalescence between the communities of Grange-over-Sands and Kents Bank.
6. SLDC should be required to produce clear evidence about how their proposed developments will enhance tourism in Grange-over-Sands and district.
7. SLDC should be required to explain why they have ignored recommendations made about green field sites and tourism in the Grange-over-Sands Regeneration Study (Douglas Wheeler Associates, November 2007), that they claim has informed SLDC's Core Strategy.
8. SLDC should be required to provide objective evidence that the local roads are adequate to support the proposed increase in population and traffic in Grange-over-Sands especially for known bottle-necks in Main Street and on Risedale Hill.
9. SLDC should not allow any development on prime green field land between Kents Bank and Allithwaite because it will lead to coalescence between these two separate communities.

I do not support SLDC’s Land Allocations DPD because it is based on spurious ‘housing need’ targets and has unnecessarily ear-marked important greenfield sites for development.

No

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 following text of response 11289 is taken from sections 4 and 7 of my SLDC LDF consultation submission entitled: ‘Soundness’ response to SLDC’s Land Allocation Development Plan (DPD, Jan 2012) focussing on SLDC’s ‘housing need’ predictions & SLDC’s vision for Grange-over-Sands and District.
My report included photographs, maps and tables to support comments that were made in the report. I have requested that this report be made available to the Planning Inspector.
The sections featured in response 11289 are:
4. (Does SLDC's Land Allocation Document protect the needs of Grange-over-Sands as a unique coastal tourist destination?
7. Does SLDC's Land Allocation Document make adequate provision for capital expenditure to upgrade local roads?
Photographs that were included with the text in the report have been stored elsewhere, formatting that clarified the text has been removed and spurious question marks have appeared that are not in the original text.
[The full report is attached]


4 Does SLDC’s Land Allocation Document protect the needs of Grange-over-
Sands as a unique coastal tourist destination?

4.1 SLDC’s Land Allocation Plan states that the Grange-over-Sands Regeneration Study
(November 2007), Douglas Wheeler Associates, has informed SLDC’s Core Strategy.

4.2 The Grange-over-Sands Regeneration Study states that Grange-over-Sands is:

i. North West England’s most distinctive, contemporary coastal resort town that has
used its Edwardian heritage as a strong asset in its regeneration.

ii. An exceptionally pleasant, very well maintained and friendly town with:
- An impressive promenade and superb views across Morecambe Bay.
- Excellent parks and garden.
- A well connected rail station.
- A strong community of established and new residents.
- A great place to live, work and visit.

iii. Has a strong convenience retailing and service orientated focus.

4.3 SLDC’s Core Strategy document states that:
"...We aim to achieve a balanced housing market by securing the provision of a range of
housing types and sizes to meet the needs of all sectors…” and
“…The exact scale and level of development supported will be dependent on individual
character, the impact on environmental capacity and infrastructure provision, and the
desire to meet the need for affordable housing as locally as possible…”

4.4 The proposed developments in SLDC’s Land Allocation document for Grange-over-
Sands and district have not achieved this objective because:
- They will increase the number of households by 25%.
- Local roads do not have the capacity to absorb the extra traffic that will be
generated.
- They will allow building on important green field sites.
- They will lead to the coalescence of Grange-over-Sands with adjacent
communities.

4.5 The questionable SLDC ‘new build’ target has been arbitrarily divided between defined
areas of South Lakeland district, on a percentage basis, between the Principal Service
Centres, Key Service Centres and rural areas.

4.6 The housing allocation made for Grange-over-Sands was based on its classification as a Key Service Centre but, as it does not meet the SLDC’s stated criteria for a Key Service
Centre (see Section 3), the housing allocation is not compatible with its needs as a
unique coastal tourist destination.

4.7 The allocation of new build’ for Grange-over-Sands, Kents Bank, Allithwaite and Cartmel
peninsula area does not appear to have factored in:
- The high percentage of retired people living in the area: a proportionally higher
amount of the existing housing stock will be available for ‘new’ households, on a
regular basis, due to the higher mortality.
- The high percentage of dwellings that are ‘second homes’ and ‘holiday lets’ some of
which are likely revert to normal residential use over time eg eight apartments in
Kents Bank were converted from ‘holiday apartments’ to ‘normal residential’
apartments in 2010.

4.8 SLDC has not justified the need for a massive ‘new build’ requirement in Grange-over-
Sands and district with objective evidence.

4.9 There is a need for ‘affordable housing’ but even that need has not been quantified
objectively.

4.10 The overall ‘new build’ housing figures have been inflated because of the policy of
requiring developers to subsidise ‘affordable housing’ (see section 2).

4.11 SLDC’s proposals will lead to a 25% increase in the number of households in Grangeover-Sands and Kents Bank without any provision for improvements to the local road
system or car parking facilities or utilities; this will be detrimental to the tourist industry.

4.12 Section 4.4 of SLDC’s Land Allocation document states:
“…Douglas Wheeler Associates prepared a Regeneration Study for Grange-over-
Sands in 2007. This carried out a detailed assessment of Grange as a Key
Service Centre that formed the basis of Core Strategy policies for the town…”

4.13 The independent Grange-over-Sands Regeneration Study 2007 found:
“…Around 7.5% of properties are second homes and clearly Grange should not become
dominated by second homes and retirement homes…”

4.14 If SLDC’s proposal to build 500 dwellings in Grange-over-Sands and district is realised the likely outcome will be to increase in the number of ‘second homes’, ‘holiday homes’, and ‘in-coming’ pensioners in order to subsidise 175 ‘affordable homes’; SLDC have not provided evidence to justify this need.

4.15 Building on this scale will not benefit the local community because it will lead to an
increased pressure on the NHS, local roads, public transport, utilities etc… and have an
adverse effect on local tourism.

4.16 There are currently 129 dwellings on the market in Grange-over-Sands and district
ranging from one and two bed-roomed apartments to large detached houses and
everything in between. Many of these properties have been on the market for over two
years; many others have been taken off the market and turned into private rented
accommodation. So, how can SLDC justify the need for 325 more new dwellings on the
open market?

4.17 The Grange-over-Sands Regeneration Study 2007 also stated that:
“…Additional housing will be provided to meet the needs of local people without
damaging the sensitive setting and character of the town…” and
“…the key to the success or failure of Grange-over-Sands…will be to invest in the
unique quality of the built and natural environment, infrastructure and public facilities
alongside promoting enterprise and business development…” and
“…It only requires one element to be below standard to reduce the overall appeal of the
place…”

4.18 Residents of Grange-over-Sands and district would agree with all the above objectives
but feel that SLDC’s Land Allocation DPD proposals do not match this expectation. For
instance, the study looked at Grange-over-Sands land development options in detail. It
recommended that land ‘north of playing field’ (R110: Trickett’s field) should not be
developed because: “…loss of open views from street is negative…”

4.19 This site is also important because it is one of the few remaining green gaps between
Grange-over-Sands and Kents Bank (see section 5).

4.20 The Grange-over-Sands Regeneration Study 2007 also stated that it was important to:
“…protect the network of green spaces and important environmental characteristics of
the town and its setting…” and
“…protect the network of green spaces and important characteristics of the town…give
priority to the use of previously developed land for development…”

4.21 Brown field sites such as Berners, the former candle factory and Bateman’s garage
should be developed for housing and employment before any green field sites are
considered; sensitive development of brown field sites will not destroy the rural
ambience of the area that is so attractive to tourists.

4.22 Tourism is the life-blood of Grange-over-Sands’ economy. SLDC is not justified in
proposing large scale developments on green field sites before undertaking a feasibility
study assessing the impact of the proposed developments on tourism. They have not
done this. Such arrogance is negligent given the potential impact on the local tourist
industry.

4.23 It is unlikely that tourists will want visit the Grange-over-Sands area during the
construction phases due to the impact on the already inadequate road system (see
section 7); post construction, who wants to visit a coastal urban sprawl?

4.24 Investment in basic infrastructure is needed before any major increase in housing but
the SLDC Land Allocation Development Plan does include any provision for solving the
known traffic bottle-necks of Risedale Hill and Main Street Grange-over-Sands (see
section 7). Why not?

4.25 Section 4.2 of the SLDC Land Allocation DPD states:
“…The Core Strategy (Policy CS4) sets the overall context for development in Grangeover-
Sands. This seeks to make provision for moderate housing development and
employment development, regenerate the Berners site, improve public transport, reinstate
footbridges and protect the network of Green Infrastructure as well as promoting
the vitality of Grange town Centre and promoting tourism…”

4.26 Local residents support all these objectives, but, the land development proposals that
SLDC have proposed for Grange-over-Sands and district contradict these objectives;
they have not protected the network Green infrastructure (see sections 5, 6 and 7) and
they have not promoted tourism, nor have they justified proposing to development of
green field sites with objective evidence.

4.27 As the Grange-over-Sands Regeneration Study 2007 said of Grange-over-Sands it is
important to:
- Maintain and enhance the viability of the town centre.
- Promote…appropriate development at the Berners Pool/BernersClose car
park/nursery/lido site to create a new focus.
- Promote the vitality and viability of Grange-over-Sands town centre.
- Promote the reintroduction of the Berners Close railway bridge.
- Focus on renovation rather than demolition.
- Minimise the impact on the environment and improve biodiversity

Unfortunately SLDC’s Land Allocation DPD appears to have lost sight of these
objectives.

Section 4: Grange-over-Sands, a unique coastal town;
summary of main conclusions
- Grange-over-Sands is a unique coastal town that is dependent on the tourist
industry and has unique development needs.
- Grange-over-Sands is not suitable for large scale development because of its
tourist needs; the surrounding rough pasture lands are part of its attraction.
- All proposed development should be considered in this context and should be
concentrated on brown field sites as recommended in the Grange-over-Sands
Regeneration Study 2007.
- The local road system, utilities and community support systems are already
inadequate; they are not robust enough to support 500 more households.
- The surrounding topography and proximity of other local communities means
that it is inappropriate allow large scale developments to extend into Kents
Bank or onto peripheral rough pasture land.

7 Does SLDC’s Land Allocation Document make adequate provision for
capital expenditure to upgrade local roads?

7.1 Allithwaite Road (B5277) is already inadequate for the amount of traffic regularly
travelling between Grange-over-Sands, Allithwaite, Flookburgh, Holker Hall, Kendal,
Lancaster and the M6.

7.2 The traffic problem is exacerbated when regular events such as Cartmel Races and
the Holker Garden Festival attract large crowds.

7.3 The stretch of Allithwaite Road between Kents Bank and Allithwaite from the top of
Risedale Hill is a fast stretch of undulating road that poses sight line problems for
drivers (see picture 3, section 6.15).

7.4 Developers would be forced to create new roads for development area MN25M linking
onto Allithwaite Road; this would increase traffic hazards on Allithwaite Road, or, lead
to the creation of an intrusive roundabout system that would destroy the rural nature
of this road and area

7.5 Greaves Wood Road bridleway forms the eastern, and southern, boundaries of
MN25M; it could not be used as access to MN25M development area because of a)
the Protected Limestone Pavement in Greaves Wood and b) it is a popular pedestrian
route for local residents, especially dog walkers (see Map 1, section 5.7 and Map 3,
section 6.4).

7.6 Access from Kirkhead Road to the MN25M development area is not practical; there
are no suitable gaps between the houses whose back gardens form the western
boundary of MN25M.

7.7 Industrial development and 202 residential units will generate a large amount of extra
traffic in Kents Bank that will all need to drive through Grange-over-Sands to reach the
A590 for access to Kendal, Lancaster and the M6; the local road system is not
suitable for this.

7.8 Local roads are not adequate to accommodate service vehicles for industrial
development.

PICTURES - see attached document

7.9 SLDC are also proposing to build dwellings on the land behind the lorry on Allithwaite
Road (picture 6) and on the left hand side of Allithwaite Road beyond the junction of
Allithwaite Road with Jack Hill (junction to the left of Kirkhead Road; picture 6); access to both these sites is constrained by their location and will cause road safety
problems.

7.10 Picture 5 clearly shows that it is not possible to widen or straighten Risedale Hill
without major road works involving compulsory purchase orders, demolition of walls
and completely altering the character of this part of Kents Bank and that the road is
not suitable for large volumes of traffic.

7.11 Traffic from three other nearby proposed residential developments in Kents Bank,
R672M: 36 residential units & R89: 45 residential units, R350M: 17 houses, also link
to Allithwaite Road, near the top of Risedale Hill therefore they should also be taken
into account when undertaking an area traffic impact study (see Map 1, section 5.7);
as should traffic generated by all residential and employment developments west of
Risedale Hill in Allithwaite and Flookburgh.

7.12 Once the traffic has negotiated Risedale Hill it then has to negotiate Main Street hill in
Grange-over-Sands another bottleneck that is often made worse by delivery vehicles
for the local shops because none of the shops on this part of Main Street have rear
access,

7.13 The local roads are in a poor state of repair and are not suitable for this level of traffic
increase.

7.14 SLDC have made no provision for improving these roads and have not justified a
need for developments that will make the traffic conditions considerably worse and
deter tourists.

7.15 There is no viable route for a Grange-over-Sands by-pass. A new trunk road to the
A590 would have to be routed across rough pastureland to the north of Grange-over-
Sands and would impinge on classic views of Cartmel and Cartmel Priory.

7.16 Car parking in Grange-over-Sands is already inadequate for local residents shopping
and tourists and again, no provision has been made in SLDC’s Land Allocation DPD
to improve local car parking facilities.

Section 7: Inadequate local roads in Grange-over-Sands and District;
summary of main conclusions
- The roads in Grange-over-Sands and district are already inadequate for the
traffic that they carry.
- There are two major bottlenecks: Risedale Hill and Main Street Hill that
cannot be widened due to their location.
- It would be expensive and difficult to agree a route for a new trunk road to the
A590 that by-passed Grange-over-Sands.
- SLDC have not made any provision to upgrade roads in Grange-over-Sands
and district.
- SLDC have not provided objective evidence to justify proposing large
development to the west of Grange-over-Sands given the already inadequate
road system.

SEE ALSO ALL APPENDICES on attached document

I do not support SLDC’s Land Allocation DPD

YES, I wish to participate at the oral examination

I wish to take part in the oral examination because SLDC have not made an adequate response to significant planning concerns, raised by local residents, during earlier consultation phases, particularly those relating to:
1. ‘Housing need’ in the Grange-over-Sands area.
2. Proposed green field site land allocations for the Grange-over-Sands area.
3. The adverse impact of the proposed developments on tourism, the life-blood of Grange-over-Sands and the Cartmel Peninsula.
4. The inadequate road system that links Grange-over-Sands to other SLDC Service Centres.
In addition, SLDC have not provided objective evidence that justifies their classification of Grange-over-Sands as an SLDC Key Service Centre. Grange-over-Sands does not meet SLDC’s Core Strategy Document definition of Key Service Centre: it does not have a secondary school and it is not directly linked to other SLDC Service Centres by a main trunk road.
Nor does the SLDC Land Allocation DPD take account of local residents’ wishes about how their community should be developed, or the views of Grange-over-Sands Town Council.

Please notify me

LA3.1 Mixed Use Allocation at Berners Pool, Grange-over-Sands

No

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. SLDC should not include Grange-over-Sands as one of its Key Service Centres because it does not meet the criteria in CS1.2 The development strategy for Principal Service Centres, Key Service Centres and Local Service Centres. This would mean that the number of proposed developments in Grange-over-Sands and district should be reduced and all proposed development sites should be reassessed. Development of brown field sites, such as Berners, should be prioritised and SLDC should take account of the views of local residents and Grange-over-Sands Town Council.
2. SLDC have not followed Government guidance about the use and interpretation of household surveys. They have not provided objective evidence to justify ‘housing need for Grange-over-Sands and District.
3. SLDC should be required to produce objective evidence to justify their plans to allow Grange-over-Sands to develop into a coastal urban sprawl incorporating Kents Bank.
4. SLDC should be required to remove sites MN25N, R672 and R79# from their Land Development DPD because development of these sites will lead to coalescence between the communities of Kents Bank and Allithwaite.
5. SLDC should be required to remove sites R449, R74 and R110 from their Land Development DPD because development of these sites will lead to further coalescence between the communities of Grange-over-Sands and Kents Bank.
6. SLDC should be required to produce clear evidence about how their proposed developments will enhance tourism in Grange-over-Sands and district.
7. SLDC should be required to explain why they have ignored recommendations made about green field sites and tourism in the Grange-over-Sands Regeneration Study (Douglas Wheeler Associates, November 2007), that they claim has informed SLDC's Core Strategy.
8. SLDC should be required to provide objective evidence that the local roads are adequate to support the proposed increase in population and traffic in Grange-over-Sands especially for known bottle-necks in Main Street and on Risedale Hill.
9. SLDC should not allow any development on prime green field land between Kents Bank and Allithwaite because it will lead to coalescence between these two separate communities.

I do not support SLDC’s Land Allocations DPD because it is based on spurious ‘housing need’ targets and has unnecessarily ear-marked important greenfield sites for development.

No

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 following text of response 11291 is taken from sections 4 and 7 of my SLDC LDF consultation submission entitled: ‘Soundness’ response to SLDC’s Land Allocation Development Plan (DPD, Jan 2012) focussing on SLDC’s ‘housing need’ predictions & SLDC’s vision for Grange-over-Sands and District.
My report included photographs, maps and tables to support comments that were made in the report. I have requested that this report be made available to the Planning Inspector.
The sections featured in response 11291 are:
4. Does SLDC's Land Allocation Document protect the needs of Grange-over-Sands as a unique coastal tourist destination?
7. Does SLDC's Land Allocation Document make adequate provision for capital expenditure to upgrade local roads?
Photographs that were included with the text in the report have been stored elsewhere, formatting that clarified the text has been removed and spurious question marks have appeared that are not in the original text.
[The full report is attached]



4 Does SLDC’s Land Allocation Document protect the needs of Grange-over-
Sands as a unique coastal tourist destination?

4.1 SLDC’s Land Allocation Plan states that the Grange-over-Sands Regeneration Study
(November 2007), Douglas Wheeler Associates, has informed SLDC’s Core Strategy.
4.2 The Grange-over-Sands Regeneration Study states that Grange-over-Sands is:
i. North West England’s most distinctive, contemporary coastal resort town that has
used its Edwardian heritage as a strong asset in its regeneration.

ii. An exceptionally pleasant, very well maintained and friendly town with:
- An impressive promenade and superb views across Morecambe Bay.
- Excellent parks and garden.
- A well connected rail station.
- A strong community of established and new residents.
- A great place to live, work and visit.

iii. Has a strong convenience retailing and service orientated focus.

4.3 SLDC’s Core Strategy document states that:
"...We aim to achieve a balanced housing market by securing the provision of a range of
housing types and sizes to meet the needs of all sectors…” and
“…The exact scale and level of development supported will be dependent on individual
character, the impact on environmental capacity and infrastructure provision, and the
desire to meet the need for affordable housing as locally as possible…”

4.4 The proposed developments in SLDC’s Land Allocation document for Grange-over-
Sands and district have not achieved this objective because:
- They will increase the number of households by 25%.
- Local roads do not have the capacity to absorb the extra traffic that will be
generated.
- They will allow building on important green field sites.
- They will lead to the coalescence of Grange-over-Sands with adjacent
communities.

4.5 The questionable SLDC ‘new build’ target has been arbitrarily divided between defined
areas of South Lakeland district, on a percentage basis, between the Principal Service
Centres, Key Service Centres and rural areas.

4.6 The housing allocation made for Grange-over-Sands was based on its classification as a Key Service Centre but, as it does not meet the SLDC’s stated criteria for a Key Service
Centre (see Section 3), the housing allocation is not compatible with its needs as a
unique coastal tourist destination.

4.7 The allocation of new build’ for Grange-over-Sands, Kents Bank, Allithwaite and Cartmel
peninsula area does not appear to have factored in:
- The high percentage of retired people living in the area: a proportionally higher
amount of the existing housing stock will be available for ‘new’ households, on a
regular basis, due to the higher mortality.
- The high percentage of dwellings that are ‘second homes’ and ‘holiday lets’ some of
which are likely revert to normal residential use over time eg eight apartments in
Kents Bank were converted from ‘holiday apartments’ to ‘normal residential’
apartments in 2010.

4.8 SLDC has not justified the need for a massive ‘new build’ requirement in Grange-over-
Sands and district with objective evidence.

4.9 There is a need for ‘affordable housing’ but even that need has not been quantified
objectively.

4.10 The overall ‘new build’ housing figures have been inflated because of the policy of
requiring developers to subsidise ‘affordable housing’ (see section 2).

4.11 SLDC’s proposals will lead to a 25% increase in the number of households in Grange-over-Sands and Kents Bank without any provision for improvements to the local road system or car parking facilities or utilities; this will be detrimental to the tourist industry.

4.12 Section 4.4 of SLDC’s Land Allocation document states:
“…Douglas Wheeler Associates prepared a Regeneration Study for Grange-over-
Sands in 2007. This carried out a detailed assessment of Grange as a Key
Service Centre that formed the basis of Core Strategy policies for the town…”

4.13 The independent Grange-over-Sands Regeneration Study 2007 found:
“…Around 7.5% of properties are second homes and clearly Grange should not become
dominated by second homes and retirement homes…”

4.14 If SLDC’s proposal to build 500 dwellings in Grange-over-Sands and district is realised the likely outcome will be to increase in the number of ‘second homes’, ‘holiday homes’, and ‘in-coming’ pensioners in order to subsidise 175 ‘affordable homes’; SLDC have not provided evidence to justify this need.

4.15 Building on this scale will not benefit the local community because it will lead to an
increased pressure on the NHS, local roads, public transport, utilities etc… and have an
adverse effect on local tourism.

4.16 There are currently 129 dwellings on the market in Grange-over-Sands and district
ranging from one and two bed-roomed apartments to large detached houses and
everything in between. Many of these properties have been on the market for over two
years; many others have been taken off the market and turned into private rented
accommodation. So, how can SLDC justify the need for 325 more new dwellings on the
open market?

4.17 The Grange-over-Sands Regeneration Study 2007 also stated that:
“…Additional housing will be provided to meet the needs of local people without
damaging the sensitive setting and character of the town…” and
“…the key to the success or failure of Grange-over-Sands…will be to invest in the
unique quality of the built and natural environment, infrastructure and public facilities
alongside promoting enterprise and business development…” and
“…It only requires one element to be below standard to reduce the overall appeal of the
place…”

4.18 Residents of Grange-over-Sands and district would agree with all the above objectives
but feel that SLDC’s Land Allocation DPD proposals do not match this expectation. For
instance, the study looked at Grange-over-Sands land development options in detail. It
recommended that land ‘north of playing field’ (R110: Trickett’s field) should not be
developed because: “…loss of open views from street is negative…”

4.19 This site is also important because it is one of the few remaining green gaps between
Grange-over-Sands and Kents Bank (see section 5).

4.20 The Grange-over-Sands Regeneration Study 2007 also stated that it was important to:
“…protect the network of green spaces and important environmental characteristics of
the town and its setting…” and
“…protect the network of green spaces and important characteristics of the town…give
priority to the use of previously developed land for development…”

4.21 Brown field sites such as Berners, the former candle factory and Bateman’s garage
should be developed for housing and employment before any green field sites are
considered; sensitive development of brown field sites will not destroy the rural
ambience of the area that is so attractive to tourists.

4.22 Tourism is the life-blood of Grange-over-Sands’ economy. SLDC is not justified in
proposing large scale developments on green field sites before undertaking a feasibility
study assessing the impact of the proposed developments on tourism. They have not
done this. Such arrogance is negligent given the potential impact on the local tourist
industry.

4.23 It is unlikely that tourists will want visit the Grange-over-Sands area during the
construction phases due to the impact on the already inadequate road system (see
section 7); post construction, who wants to visit a coastal urban sprawl?

4.24 Investment in basic infrastructure is needed before any major increase in housing but
the SLDC Land Allocation Development Plan does include any provision for solving the
known traffic bottle-necks of Risedale Hill and Main Street Grange-over-Sands (see
section 7). Why not?

4.25 Section 4.2 of the SLDC Land Allocation DPD states:
“…The Core Strategy (Policy CS4) sets the overall context for development in Grangeover-
Sands. This seeks to make provision for moderate housing development and
employment development, regenerate the Berners site, improve public transport, reinstate
footbridges and protect the network of Green Infrastructure as well as promoting
the vitality of Grange town Centre and promoting tourism…”

4.26 Local residents support all these objectives, but, the land development proposals that
SLDC have proposed for Grange-over-Sands and district contradict these objectives;
they have not protected the network Green infrastructure (see sections 5, 6 and 7) and
they have not promoted tourism, nor have they justified proposing to development of
green field sites with objective evidence.

4.27 As the Grange-over-Sands Regeneration Study 2007 said of Grange-over-Sands it is
important to:
- Maintain and enhance the viability of the town centre.
- Promote…appropriate development at the Berners Pool/BernersClose car
park/nursery/lido site to create a new focus.
- Promote the vitality and viability of Grange-over-Sands town centre.
- Promote the reintroduction of the Berners Close railway bridge.
- Focus on renovation rather than demolition.
- Minimise the impact on the environment and improve biodiversity

Unfortunately SLDC’s Land Allocation DPD appears to have lost sight of these
objectives.

Section 4: Grange-over-Sands, a unique coastal town;
summary of main conclusions
- Grange-over-Sands is a unique coastal town that is dependent on the tourist
industry and has unique development needs.
- Grange-over-Sands is not suitable for large scale development because of its
tourist needs; the surrounding rough pasture lands are part of its attraction.
- All proposed development should be considered in this context and should be
concentrated on brown field sites as recommended in the Grange-over-Sands
Regeneration Study 2007.
- The local road system, utilities and community support systems are already
inadequate; they are not robust enough to support 500 more households.
- The surrounding topography and proximity of other local communities means
that it is inappropriate allow large scale developments to extend into Kents
Bank or onto peripheral rough pasture land.

7 Does SLDC’s Land Allocation Document make adequate provision for
capital expenditure to upgrade local roads?

7.1 Allithwaite Road (B5277) is already inadequate for the amount of traffic regularly
travelling between Grange-over-Sands, Allithwaite, Flookburgh, Holker Hall, Kendal,
Lancaster and the M6.

7.2 The traffic problem is exacerbated when regular events such as Cartmel Races and
the Holker Garden Festival attract large crowds.

7.3 The stretch of Allithwaite Road between Kents Bank and Allithwaite from the top of
Risedale Hill is a fast stretch of undulating road that poses sight line problems for
drivers (see picture 3, section 6.15).

7.4 Developers would be forced to create new roads for development area MN25M linking
onto Allithwaite Road; this would increase traffic hazards on Allithwaite Road, or, lead
to the creation of an intrusive roundabout system that would destroy the rural nature
of this road and area

7.5 Greaves Wood Road bridleway forms the eastern, and southern, boundaries of
MN25M; it could not be used as access to MN25M development area because of a)
the Protected Limestone Pavement in Greaves Wood and b) it is a popular pedestrian
route for local residents, especially dog walkers (see Map 1, section 5.7 and Map 3,
section 6.4).

7.6 Access from Kirkhead Road to the MN25M development area is not practical; there
are no suitable gaps between the houses whose back gardens form the western
boundary of MN25M.

7.7 Industrial development and 202 residential units will generate a large amount of extra
traffic in Kents Bank that will all need to drive through Grange-over-Sands to reach the
A590 for access to Kendal, Lancaster and the M6; the local road system is not
suitable for this.

7.8 Local roads are not adequate to accommodate service vehicles for industrial
development.

SEE PICTURES ON ATTACHED DOCUMENT

7.9 SLDC are also proposing to build dwellings on the land behind the lorry on Allithwaite
Road (picture 6) and on the left hand side of Allithwaite Road beyond the junction of
Allithwaite Road with Jack Hill (junction to the left of Kirkhead Road; picture 6); access
to both these sites is constrained by their location and will cause road safety
problems.

7.10 Picture 5 clearly shows that it is not possible to widen or straighten Risedale Hill
without major road works involving compulsory purchase orders, demolition of walls
and completely altering the character of this part of Kents Bank and that the road is
not suitable for large volumes of traffic.

7.11 Traffic from three other nearby proposed residential developments in Kents Bank,
R672M: 36 residential units & R89: 45 residential units, R350M: 17 houses, also link
to Allithwaite Road, near the top of Risedale Hill therefore they should also be taken
into account when undertaking an area traffic impact study (see Map 1, section 5.7);
as should traffic generated by all residential and employment developments west of
Risedale Hill in Allithwaite and Flookburgh.

7.12 Once the traffic has negotiated Risedale Hill it then has to negotiate Main Street hill in
Grange-over-Sands another bottleneck that is often made worse by delivery vehicles
for the local shops because none of the shops on this part of Main Street have rear
access,

7.13 The local roads are in a poor state of repair and are not suitable for this level of traffic
increase.

7.14 SLDC have made no provision for improving these roads and have not justified a
need for developments that will make the traffic conditions considerably worse and
deter tourists.

7.15 There is no viable route for a Grange-over-Sands by-pass. A new trunk road to the
A590 would have to be routed across rough pastureland to the north of Grange-over-
Sands and would impinge on classic views of Cartmel and Cartmel Priory.

7.16 Car parking in Grange-over-Sands is already inadequate for local residents shopping
and tourists and again, no provision has been made in SLDC’s Land Allocation DPD
to improve local car parking facilities.

Section 7: Inadequate local roads in Grange-over-Sands and District;
summary of main conclusions
- The roads in Grange-over-Sands and district are already inadequate for the
traffic that they carry.
- There are two major bottlenecks: Risedale Hill and Main Street Hill that
cannot be widened due to their location.
- It would be expensive and difficult to agree a route for a new trunk road to the
A590 that by-passed Grange-over-Sands.
- SLDC have not made any provision to upgrade roads in Grange-over-Sands
and district.
- SLDC have not provided objective evidence to justify proposing large
development to the west of Grange-over-Sands given the already inadequate
road system.

I do not support SLDC’s Land Allocation DPD

YES, I wish to participate at the oral examination

I wish to take part in the oral examination because SLDC have not made an adequate response to significant planning concerns, raised by local residents, during earlier consultation phases, particularly those relating to:
1. ‘Housing need’ in the Grange-over-Sands area.
2. Proposed green field site land allocations for the Grange-over-Sands area.
3. The adverse impact of the proposed developments on tourism, the life-blood of Grange-over-Sands and the Cartmel Peninsula.
4. The inadequate road system that links Grange-over-Sands to other SLDC Service Centres.
In addition, SLDC have not provided objective evidence that justifies their classification of Grange-over-Sands as an SLDC Key Service Centre. Grange-over-Sands does not meet SLDC’s Core Strategy Document definition of Key Service Centre: it does not have a secondary school and it is not directly linked to other SLDC Service Centres by a main trunk road.
Nor does the SLDC Land Allocation DPD take account of local residents’ wishes about how their community should be developed, or the views of Grange-over-Sands Town Council.

Please notify me

LA3.2 Mixed Use Allocation at Land South of Allithwaite Road, Kent's Bank, Grange-over-Sands

No

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. SLDC should not include Grange-over-Sands as one of its Key Service Centres because it does not meet the criteria in CS1.2 The development strategy for Principal Service Centres, Key Service Centres and Local Service Centres. This would mean that the number of proposed developments in Grange-over-Sands and district should be reduced and all proposed development sites should be reassessed. Development of brown field sites, such as Berners, should be prioritised and SLDC should take account of the views of local residents and Grange-over-Sands Town Council.
2. SLDC have not followed Government guidance about the use and interpretation of household surveys. They have not provided objective evidence to justify ‘housing need for Grange-over-Sands and District.
3. SLDC should be required to produce objective evidence to justify their plans to allow Grange-over-Sands to develop into a coastal urban sprawl incorporating Kents Bank.
4. SLDC should be required to remove sites MN25N, R672 and R79# from their Land Development DPD because development of these sites will lead to coalescence between the communities of Kents Bank and Allithwaite.
5. SLDC should be required to remove sites R449, R74 and R110 from their Land Development DPD because development of these sites will lead to further coalescence between the communities of Grange-over-Sands and Kents Bank.
6. SLDC should be required to produce clear evidence about how their proposed developments will enhance tourism in Grange-over-Sands and district.
7. SLDC should be required to explain why they have ignored recommendations made about green field sites and tourism in the Grange-over-Sands Regeneration Study (Douglas Wheeler Associates, November 2007), that they claim has informed SLDC's Core Strategy.
8. SLDC should be required to provide objective evidence that the local roads are adequate to support the proposed increase in population and traffic in Grange-over-Sands especially for known bottle-necks in Main Street and on Risedale Hill.
9. SLDC should not allow any development on prime green field land between Kents Bank and Allithwaite because it will lead to coalescence between these two separate communities.

I do not support SLDC’s Land Allocations DPD because it is based on spurious ‘housing need’ targets and has unnecessarily ear-marked important greenfield sites for development.

No

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 following text of response 11292 is taken from sections 4, 5, 6 and 7 of my SLDC LDF consultation submission entitled: ‘Soundness’ response to SLDC’s Land Allocation Development Plan (DPD, Jan 2012) focussing on SLDC’s ‘housing need’ predictions & SLDC’s vision for Grange-over-Sands and District.
My report included photographs, maps and tables to support comments that were made in the report. I have requested that this report be made available to the Planning Inspector.
The sections featured in response 11292 are:
4. Does SLDC's Land Allocation Document protect the needs of Grange-over-Sands as a unique coastal tourist destination?
5 . Does SLDC’s Land Allocation Document attempt to ‘air-brush’ Kents Bank out of existence as a separate community?
6. Does SLDC’s Land Allocation Document protect against coalescence between Kents Bank and Allithwaite?
7. Does SLDC's Land Allocation Document make adequate provision for capital expenditure to upgrade local roads?
The tables that were included with the text in the report have been stored elsewhere, formatting that clarified the text has been removed and spurious question marks have appeared that are not in the original text.
[The full report is attached]

4 Does SLDC’s Land Allocation Document protect the needs of Grange-over-
Sands as a unique coastal tourist destination?

4.1 SLDC’s Land Allocation Plan states that the Grange-over-Sands Regeneration Study
(November 2007), Douglas Wheeler Associates, has informed SLDC’s Core Strategy.

4.2 The Grange-over-Sands Regeneration Study states that Grange-over-Sands is:

i. North West England’s most distinctive, contemporary coastal resort town that has
used its Edwardian heritage as a strong asset in its regeneration.

ii. An exceptionally pleasant, very well maintained and friendly town with:
- An impressive promenade and superb views across Morecambe Bay.
- Excellent parks and garden.
- A well connected rail station.
- A strong community of established and new residents.
- A great place to live, work and visit.

iii. Has a strong convenience retailing and service orientated focus.

4.3 SLDC’s Core Strategy document states that:
"...We aim to achieve a balanced housing market by securing the provision of a range of
housing types and sizes to meet the needs of all sectors…” and
“…The exact scale and level of development supported will be dependent on individual
character, the impact on environmental capacity and infrastructure provision, and the
desire to meet the need for affordable housing as locally as possible…”

4.4 The proposed developments in SLDC’s Land Allocation document for Grange-over-
Sands and district have not achieved this objective because:
- They will increase the number of households by 25%.
- Local roads do not have the capacity to absorb the extra traffic that will be
generated.
- They will allow building on important green field sites.
- They will lead to the coalescence of Grange-over-Sands with adjacent
communities.

4.5 The questionable SLDC ‘new build’ target has been arbitrarily divided between defined
areas of South Lakeland district, on a percentage basis, between the Principal Service
Centres, Key Service Centres and rural areas.

4.6 The housing allocation made for Grange-over-Sands was based on its classification as a Key Service Centre but, as it does not meet the SLDC’s stated criteria for a Key Service
Centre (see Section 3), the housing allocation is not compatible with its needs as a
unique coastal tourist destination.

4.7 The allocation of new build’ for Grange-over-Sands, Kents Bank, Allithwaite and Cartmel
peninsula area does not appear to have factored in:

- The high percentage of retired people living in the area: a proportionally higher
amount of the existing housing stock will be available for ‘new’ households, on a
regular basis, due to the higher mortality.
- The high percentage of dwellings that are ‘second homes’ and ‘holiday lets’ some of
which are likely revert to normal residential use over time eg eight apartments in
Kents Bank were converted from ‘holiday apartments’ to ‘normal residential’
apartments in 2010.

4.8 SLDC has not justified the need for a massive ‘new build’ requirement in Grange-over-
Sands and district with objective evidence.

4.9 There is a need for ‘affordable housing’ but even that need has not been quantified
objectively.

4.10 The overall ‘new build’ housing figures have been inflated because of the policy of
requiring developers to subsidise ‘affordable housing’ (see section 2).

4.11 SLDC’s proposals will lead to a 25% increase in the number of households in Grange-over-Sands and Kents Bank without any provision for improvements to the local road system or car parking facilities or utilities; this will be detrimental to the tourist industry.

4.12 Section 4.4 of SLDC’s Land Allocation document states:
“…Douglas Wheeler Associates prepared a Regeneration Study for Grange-over-
Sands in 2007. This carried out a detailed assessment of Grange as a Key
Service Centre that formed the basis of Core Strategy policies for the town…”

4.13 The independent Grange-over-Sands Regeneration Study 2007 found:
“…Around 7.5% of properties are second homes and clearly Grange should not become
dominated by second homes and retirement homes…”

4.14 If SLDC’s proposal to build 500 dwellings in Grange-over-Sands and district is realised the likely outcome will be to increase in the number of ‘second homes’, ‘holiday homes’,and ‘in-coming’ pensioners in order to subsidise 175 ‘affordable homes’; SLDC have not provided evidence to justify this need.

4.15 Building on this scale will not benefit the local community because it will lead to an
increased pressure on the NHS, local roads, public transport, utilities etc… and have an
adverse effect on local tourism.

4.16 There are currently 129 dwellings on the market in Grange-over-Sands and district
ranging from one and two bed-roomed apartments to large detached houses and
everything in between. Many of these properties have been on the market for over two
years; many others have been taken off the market and turned into private rented
accommodation. So, how can SLDC justify the need for 325 more new dwellings on the
open market?

4.17 The Grange-over-Sands Regeneration Study 2007 also stated that:
“…Additional housing will be provided to meet the needs of local people without
damaging the sensitive setting and character of the town…” and
“…the key to the success or failure of Grange-over-Sands…will be to invest in the
unique quality of the built and natural environment, infrastructure and public facilities
alongside promoting enterprise and business development…” and
“…It only requires one element to be below standard to reduce the overall appeal of the
place…”

4.18 Residents of Grange-over-Sands and district would agree with all the above objectives
but feel that SLDC’s Land Allocation DPD proposals do not match this expectation. For
instance, the study looked at Grange-over-Sands land development options in detail. It
recommended that land ‘north of playing field’ (R110: Trickett’s field) should not be
developed because: “…loss of open views from street is negative…”

4.19 This site is also important because it is one of the few remaining green gaps between
Grange-over-Sands and Kents Bank (see section 5).

4.20 The Grange-over-Sands Regeneration Study 2007 also stated that it was important to:
“…protect the network of green spaces and important environmental characteristics of
the town and its setting…” and
“…protect the network of green spaces and important characteristics of the town…give
priority to the use of previously developed land for development…”

4.21 Brown field sites such as Berners, the former candle factory and Bateman’s garage
should be developed for housing and employment before any green field sites are
considered; sensitive development of brown field sites will not destroy the rural
ambience of the area that is so attractive to tourists.

4.22 Tourism is the life-blood of Grange-over-Sands’ economy. SLDC is not justified in
proposing large scale developments on green field sites before undertaking a feasibility
study assessing the impact of the proposed developments on tourism. They have not
done this. Such arrogance is negligent given the potential impact on the local tourist
industry.

4.23 It is unlikely that tourists will want visit the Grange-over-Sands area during the
construction phases due to the impact on the already inadequate road system (see
section 7); post construction, who wants to visit a coastal urban sprawl?

4.24 Investment in basic infrastructure is needed before any major increase in housing but
the SLDC Land Allocation Development Plan does include any provision for solving the
known traffic bottle-necks of Risedale Hill and Main Street Grange-over-Sands (see
section 7). Why not?

4.25 Section 4.2 of the SLDC Land Allocation DPD states:
“…The Core Strategy (Policy CS4) sets the overall context for development in Grangeover-
Sands. This seeks to make provision for moderate housing development and
employment development, regenerate the Berners site, improve public transport, reinstate
footbridges and protect the network of Green Infrastructure as well as promoting
the vitality of Grange town Centre and promoting tourism…”

4.26 Local residents support all these objectives, but, the land development proposals that
SLDC have proposed for Grange-over-Sands and district contradict these objectives;
they have not protected the network Green infrastructure (see sections 5, 6 and 7) and
they have not promoted tourism, nor have they justified proposing to development of
green field sites with objective evidence.

4.27 As the Grange-over-Sands Regeneration Study 2007 said of Grange-over-Sands it is
important to:
- Maintain and enhance the viability of the town centre.
- Promote…appropriate development at the Berners Pool/BernersClose car
park/nursery/lido site to create a new focus.
- Promote the vitality and viability of Grange-over-Sands town centre.
- Promote the reintroduction of the Berners Close railway bridge.
- Focus on renovation rather than demolition.
- Minimise the impact on the environment and improve biodiversity

Unfortunately SLDC’s Land Allocation DPD appears to have lost sight of these
objectives.

Section 4: Grange-over-Sands, a unique coastal town;
summary of main conclusions
- Grange-over-Sands is a unique coastal town that is dependent on the tourist
industry and has unique development needs.
- Grange-over-Sands is not suitable for large scale development because of its
tourist needs; the surrounding rough pasture lands are part of its attraction.
- All proposed development should be considered in this context and should be
concentrated on brown field sites as recommended in the Grange-over-Sands
Regeneration Study 2007.
- The local road system, utilities and community support systems are already
inadequate; they are not robust enough to support 500 more households.
- The surrounding topography and proximity of other local communities means
that it is inappropriate allow large scale developments to extend into Kents
Bank or onto peripheral rough pasture land.

5 Does SLDC’s Land Allocation Document attempt to ‘air-brush’ Kents
Bank out of existence as a separate community?

5.1 SLDC’s Planning Department currently treats Kents Bank as a suburb of Grange-over-
Sands even though Kents Bank can trace its existence back to Mediaeval times when
monks from Cartmel lodged at Abbot Hall, Kents Bank, when ‘crossing the sands’
whereas Grange-over-Sands developed as a tourist resort in Victorian times after the
‘coming of the railway.

5.2 Kents Bank has its own station, Post Office, shop, Art Gallery, Abbot Hall Hotel and
Guide’s Farm. The post of Guide dates back to at least 1501 according to records of
Cartmel Priory.

5.3 During the past 20-25 years SLDC’s Planning Department have permitted infilling
development on many Kents Bank green field sites; they have allowed infilling on green
gaps between Kents Bank and Grange-over-Sands on the east, and, Kents Bank and
Allithwaite on the west.

5.4 Why is SLDC treating Kents Bank as a suburb of Grange-over-Sands? Residents of
Kents Bank do not support this view; they value their community and do not want to see
Kents Bank absorbed into Grange-over-Sands or Allithwaite. Kents Bank was
established hundreds of years before Grange-over-Sands.

5.5 This unsound approach has been perpetuated in SLDC’s Land Allocation DPD. Section
4.2 of the document is headed Grange-over-Sands and Kents Bank whereas Allithwaite
is considered as a separate community.

5.6 Subsequent text in SLDC’s Land Allocation DPD uses the name Grange-over-Sands
when it is actually referring to Kents Bank. For example paragraph 4.12 states:
“…The second major allocation is a large site on Allithwaite Road west of Kents Bank.
This is the only large site available in Grange-over-Sands…”

5.7 This is nonsense. The site referred to is MN25M; it is west of Kents Bank; it will
significantly extend Kents Bank’s western boundary and will lead to coalescence
between Kents Bank and Allithwaite if it is developed (see Map 1 and section 6).

SEE MAP 1 & 2 IN ATTACHED DOCUMENT

5.8 SLDC’s Land Allocation DPD gives Kents Bank similar problems with its Grange-over-
Sands boundaries; the green spaces between Grange-over-Sands and Kents Bank have
been gradually eroded over the years. If more green spaces between the two
communities are developed it will be the ‘death knell’ of Kents Bank as a separate
community (see Map 2)

5.9 It is clear from Map 2 that building on sites R110 (Trickett’s field) and R449/R74 will
erode the sense of separation between Grange-over-Sands and Kents Bank when
driving on the main road, the B5227 and that they will increase coalescence between
Grange-over-Sands and Kents Bank.

5.10 The Grange-over-Sands Regeneration Study 2007 considered site R110 (Trickett’s
field). They concluded that it should not be developed because:
“…loss of open views from street is negative…”

5.11 R449/R74 was not considered by the Grange-over-Sands Regeneration Study 2007 and its importance as a green field site has not been independently assessed. It is clear from Map 2 that development of these two sites will increase coalescence between Grangeover-Sands and Kents Bank. SLDC has provided no objective evidence to support the development of either of these green field sites.

5.12 The only green field site in Kents Bank that was considered by the Grange-over-Sands
Regeneration Study 2007 was site R89 (the Carter Road site, Berry Bank, Map 1 and
Map 2) and the report did not recommend development of R89 because of:
“…the loss of open area will be an issue…” and they concluded that
“…that residential development of the Allithwaite Road/Carter Road site is likely to be
controversial because of the ‘green field’ nature of the site…”

5.13 None of the development sites proposed for Kents Bank (Map 1), except R89, were
considered by the Grange-over-Sands Regeneration Study 2007; they have not been
independently assessed before inclusion in SLDC’s Land Allocation DPD.

SEE TABLE 4 in ATTACHED DOCUMENT

5.14 Table 4 clearly shows that a disproportionate amount of the unsustainable housing
allocation for Grange-over-Sands has been allocated to Kents Bank (58%)

5.15 The proposed development will increase the size of Kents Bank by 40% and extend its
boundaries towards Allithwaite causing coalescence between Kents Bank and
Allithwaite; SLDC have provided no objective evidence to justify increasing the size of
Kents Bank on this scale.

5.16 All the proposed housing development sites in Kents Bank have been allocated to
desirable green field sites except for Guides Lot (17 dwellings plus employment units)
but even this site includes a small additional green field and the site is adjacent to land
on Wart Barrow that is covered by a Limestone Pavement Order.

5.17 The proposed site MN25M is particularly contentious (see section 6).

5.18 Development of all the proposed sites near Risedale Hill and in Kents Bank will have an adverse effect on local drainage in areas that are already prone to flooding after heavy
rainfall eg Allithwaite Road beyond the top of Risedale Hill, Greaves Wood Road
(Bridleway) and Kirkhead Road.

5.19 The SLDC’s Land Allocation DPD has not taken account of problems highlighted by
Kents Bank residents in the 2011 consultation exercises. For example response forms
that I submitted for sites: MN25M, R672, 350M, R79#, R82#/R347# (see Appendices 3
to 7).

5.20 Many other residents also highlighted significant problems associated with the proposed land allocations for Kents Bank. All appear to have been ignored and lumped together in groups with a comment such as ‘noted’ beside them (see section 8). Why?

Section 5: Kents Bank as a separate community;
summary of main conclusions
- Kents Bank has been a separate community since Mediaeval times.
- SLDC have provided no clear evidence to justify increasing the size of Kents
Bank by 40%.
- SLDC have provided no clear evidence to justify sanctioning developments
that will increase coalescence between Grange-over-Sands and Kents Bank.
- SLDC have provided no clear evidence to justify sanctioning developments
that will increase coalescence between Kents Bank and Allithwaite.
- The local road system, utilities and community support systems are already
inadequate; they are not robust enough to support 298 more households in
Kents Bank.

6 Does SLDC’s Land Allocation Document protect against coalescence
between Kents Bank and Allithwaite?

6.1 To be sound SLDC need to show that they have considered potential coalescence
problems between communities. SLDC’s Core Strategy states:
CS1.2 states: “…Exceptionally, new development will be permitted in the open
countryside where it has an essential requirement for a rural location, is needed to
sustain existing businesses, provides for exceptional needs for affordable housing…”

6.2 According to SLDC’s Land Allocation DPD policy Green Gap Policy LA1.9 provides:
“…A framework for maintaining the separate identities of communities by maintaining
visual and functional separation…”
The green gap between Grange-over-Sands (not Kents Bank!) and Allithwaite is
identified as one of these important green gaps (see Map 1 and Map 3). Therefore, how
can they justify building on the site south of Allithwaite Road between Kents Bank and
Allithwaite ( MN25M)without clear objective evidence that there is a genuine need for
such development?

6.3 When SLDC prepared maps in support of their Land Allocation DPD the maps were split between Allithwaite and Kents Bank so that the dramatic reduction in the green gap
between Kents Bank and Allithwaite was not immediately obvious.

6.4 The impact of the proposed development sites for Kents Bank on coalescence between
Kents Bank and Allithwaite is clearly shown on Map 1 (section 5.7) and Map 3.

SEE MAP 3 IN ATTACHED DOCUMENT

6.5 Map 3 clearly illustrates the importance of the triangular piece of land as a green gap
between Kents Bank and Allithwaite. It also demonstrates SLDC’s poor understanding of
the boundaries between Kents Bank and Allithwaite. Currently there is only minimal
coalescence between Kents Bank and Allithwaite about a third of the way down
Kirkhead Road (see Map 3). Coalescence between the two communities will be
considerably increased if SLDC’s development proposals west of Kents Bank and south
of Allithwaite are permitted (see Map 1, section 5.7)

6.6 Appendix 5 of the Grange Fact File states:
“…Coalescence has already taken place to some degree as Kentsford Road joins Kents
Bank/Grange to the SE corner of Allithwaite…

6.7 This is nonsense! Kirkhead Road joins the south east corner of Allithwaite and the
houses at the top of Kirkhead Road are in Allithwaite (see Map 3, section 5.7). Kentsford
Road is adjacent to the railway and links Kirkhead Road and Carter; it does not form a
junction with Allithwaite Road.

6.8 The minimal coalescence between Kents Bank and Allithwaite on Kirkhead Road at
Laneside Farm is due to ribbon development in the 1930s (see Map 3, section 5.7).

6.9 The value of MN25N (the large site south of Allithwaite Road) as an important green gap
has never been independently assessed. It was not included in the Grange-over-Sands
Regenertion Study 2007 (which is supposed to have informed SLDC’s proposals for this
area) and Berry Bank (which was included was ruled out because “…loss of open area
will be an issue…” (see Map 1, section 5.7)

6.10 During the original consultation exercise SLDC was proposing an inappropriate
development of 120 residential units, plus employment units for MN25M. In spite of
widespread opposition proposals in the SLDC Land Allocation DPD nearly doubled the
number of dwellings for this site from 120 to 202 and had retained the employment units
with no objective evidence to support these proposals.

6.11 If MN25M is developed it will reduce the green gap between the communities of Kents
Bank and Allithwaite to 220 metres (site MN25M and R672) even though Section 4.22
of the SLDC Land Allocation (DPD) 2012 highlights: “…Key issues affecting
development in Allithwaite…The need to avoid coalescence with Kents Bank/Grange…”
How can SLDC justify their claim that a 220 metre gap is sufficient to avoid coalescence
between these two communities?

6.12 A significant number of local residents raised concerns about coalescence between
Kents Bank and Allithwaite during the 2011 consultation period their comments were
responded to with phrases such as “…Disagree, no proposed change it is considered
that the land does not perform a visual or functional separation and therefore does not
warrant green gap designation…” This is an outrageous description of a delightful
undulating green field site with wonderful views of Morecambe Bay that forms an
important green gap between the communities of Kents Bank and Allithwaite (see
Pictures 1 to 4).

6.13 Nor does it follow recommendations in the Grange-over-Sands Regeneration Study
2007 which stated that it was important to:
“…protect the network of green spaces and important environmental characteristics of
the town and its setting…” and
“…give priority to the use of previously developed land for development and focus on
renovation rather than demolition and new build and minimise the impact on the
environment and improve biodiversity…”

6.14 It may be significant that the land owners and developers are keen to develop this site.
On a clear day it has magnificent views of Morecambe Bay to the south and of Kirkhead
Tower to the southwest (see pictures in Table 4 below).

6.15 The land owners are so keen to see this MN25M developed that they appointed Land
Agents to liaise with SLDC Planning Department before the 2011 consultation exercise.

SEE PICTURES IN ATTACHED DOCUMENT

6.16 The complex topography of site MN25M (see Map 3) also means that drainage problems in Kents Bank will be exacerbated; a major development is likely to cause flooding in the troughs of natural undulations, as well as lower down, in southern areas of Kents Bank.

6.17 Kirkhead Road already becomes a stream bed during heavy rain; the southern end of
Greaves Wood bridleway floods during heavy rain.

6.18 Site MN25M is also an important local area for absorbing water runoff; the local drainage system does not have any ‘spare’ capacity and would need major capital investment to cope with a large-scale building development; there is no provision for this in the proposed SLDC’s land Allocation DPD.

6.19 Even a small industrial estate on this Greenfield site would have an adverse impact on
Kents Bank village, local wildlife and tourism potential.

6.20 It is inappropriate to encourage industrial development on a rural site that has been
farmed for centuries. Farming is an important local industry and part of the vernacular
landscape; this local industry should be retained for area MN25M to encourage a local
sustainable food supply and tourism.

6.21 Grange-over-Sands and the surrounding areas depend on tourism and farming;
changing the character of Kents Bank, in the way proposed, will have an adverse impact
on the tourism potential of Kents Bank.

6.22 Site MN25M is an open area that enhances the view east from Kirkhead Tower (an
ancient monument; see Picture 4) towards Grange-over-Sands; a view much admired by
visitors to the area.

6.23 MN25N is also an important wildlife corridor between Kirkhead, Greaves Wood and Wart Barrow that are all covered by Limestone Protection Orders; buzzards, kestrels and
sparrow hawks regularly hunt across this land and the woodland in the centre of the site
is a wildlife refuge.

6.24 SLDC’s response to all these adverse effects has been to state that a Development Brief will be prepared to guide development of this site even though they have not provided
clear objective evidence to show that development of this desirable and important green
field site is justified. A Development Brief will not solve the problems outlined above.

6.25 During the last 25 years SLDC have permitted:

i. Extensive infilling of green field sites in the Risedale Hill and Cardronna Road areas
of Kents Bank.

ii. The extension Kents Bank’s boundary westwards towards Allithwaite with a large
development north of Priory Lane.

iii. Extensive infilling along Priory Lane.

iv. Extensive infilling in the grounds of Kilmidyke House and Kentsford Road House.

v. Conversion of large Victorian buildings in the Kents Bank Conservation Area to
apartment blocks eg Kilmidyke House, Kentsford House, Kents Bank House and the
Kents Bank Hotel.

6.26 SLDC’s Land Allocation DPD has not justified perpetuating this policy of development
creep along the Cumbrian coast. It is time to call a halt to ensure that the communities of
Kents Bank and Allithwaite retain their integrity and do not become part of a coastal
urban sprawl that destroys the unique characteristics of Grange-over-Sands and its
surrounding area.

6.27 SLDC have provided no objective evidence to justify the need to build an additional 202
dwellings plus an unspecified number of employment units on the important green field
site between Kents Bank and Allithwaite.

Section 6: Coalescence between Kents Bank and Allithwaite;
summary of main conclusions
- SLDC have not justified reducing the boundary between Kents Bank and
Allithwaite to 220 metres.
- Development of sites MN25M and R672 will extend the boundaries of Kents
Bank towards Allithwaite; both will encroach onto open fell pastures that are
an important back-drop to Grange-over-Sands and district.
- SLDC has provided no clear evidence to justify building on these important
green field site between Kents Bank and Allithwaite.
- SLDC have not taken account of the impact of their land development
proposals on the natural drainage problems in Kents Bank.
- Such intensive development will disrupt an important wildlife corridor linking
Kirkhead, Greaves Wood and Wart Barrow; all areas of land that are covered
by Limestone Pavement Orders.
- A development Brief for MN25M will not be able to solve the fundamental
problem of coalescence between Kents Bank and Allithwaite caused by
development of this site.
- SLDC has a duty to ensure that the communities of Kents Bank and
Allithwaite retain their integrity and do not become part of a coastal urban
sprawl that destroys the unique characteristics of Grange-over-Sands and its
surrounding area.

7 Does SLDC’s Land Allocation Document make adequate provision for
capital expenditure to upgrade local roads?

7.1 Allithwaite Road (B5277) is already inadequate for the amount of traffic regularly
travelling between Grange-over-Sands, Allithwaite, Flookburgh, Holker Hall, Kendal,
Lancaster and the M6.

7.2 The traffic problem is exacerbated when regular events such as Cartmel Races and
the Holker Garden Festival attract large crowds.

7.3 The stretch of Allithwaite Road between Kents Bank and Allithwaite from the top of
Risedale Hill is a fast stretch of undulating road that poses sight line problems for
drivers (see picture 3, section 6.15).

7.4 Developers would be forced to create new roads for development area MN25M linking
onto Allithwaite Road; this would increase traffic hazards on Allithwaite Road, or, lead
to the creation of an intrusive roundabout system that would destroy the rural nature
of this road and area

7.5 Greaves Wood Road bridleway forms the eastern, and southern, boundaries of
MN25M; it could not be used as access to MN25M development area because of a)
the Protected Limestone Pavement in Greaves Wood and b) it is a popular pedestrian
route for local residents, especially dog walkers (see Map 1, section 5.7 and Map 3,
section 6.4).

7.6 Access from Kirkhead Road to the MN25M development area is not practical; there
are no suitable gaps between the houses whose back gardens form the western
boundary of MN25M.

7.7 Industrial development and 202 residential units will generate a large amount of extra
traffic in Kents Bank that will all need to drive through Grange-over-Sands to reach the
A590 for access to Kendal, Lancaster and the M6; the local road system is not
suitable for this.

7.8 Local roads are not adequate to accommodate service vehicles for industrial
development.

SEE PICTURES IN ATTACHED DOCUMENT

7.9 SLDC are also proposing to build dwellings on the land behind the lorry on Allithwaite
Road (picture 6) and on the left hand side of Allithwaite Road beyond the junction of
Allithwaite Road with Jack Hill (junction to the left of Kirkhead Road; picture 6); access
to both these sites is constrained by their location and will cause road safety
problems.

7.10 Picture 5 clearly shows that it is not possible to widen or straighten Risedale Hill
without major road works involving compulsory purchase orders, demolition of walls
and completely altering the character of this part of Kents Bank and that the road is
not suitable for large volumes of traffic.

7.11 Traffic from three other nearby proposed residential developments in Kents Bank,
R672M: 36 residential units & R89: 45 residential units, R350M: 17 houses, also link
to Allithwaite Road, near the top of Risedale Hill therefore they should also be taken
into account when undertaking an area traffic impact study (see Map 1, section 5.7);
as should traffic generated by all residential and employment developments west of
Risedale Hill in Allithwaite and Flookburgh.

7.12 Once the traffic has negotiated Risedale Hill it then has to negotiate Main Street hill in
Grange-over-Sands another bottleneck that is often made worse by delivery vehicles
for the local shops because none of the shops on this part of Main Street have rear
access,

7.13 The local roads are in a poor state of repair and are not suitable for this level of traffic
increase.

7.14 SLDC have made no provision for improving these roads and have not justified a
need for developments that will make the traffic conditions considerably worse and
deter tourists.

7.15 There is no viable route for a Grange-over-Sands by-pass. A new trunk road to the
A590 would have to be routed across rough pastureland to the north of Grange-over-
Sands and would impinge on classic views of Cartmel and Cartmel Priory.

7.16 Car parking in Grange-over-Sands is already inadequate for local residents shopping
and tourists and again, no provision has been made in SLDC’s Land Allocation DPD
to improve local car parking facilities.

Section 7: Inadequate local roads in Grange-over-Sands and District;
summary of main conclusions
- The roads in Grange-over-Sands and district are already inadequate for the
traffic that they carry.
- There are two major bottlenecks: Risedale Hill and Main Street Hill that
cannot be widened due to their location.
- It would be expensive and difficult to agree a route for a new trunk road to the
A590 that by-passed Grange-over-Sands.
- SLDC have not made any provision to upgrade roads in Grange-over-Sands
and district.
- SLDC have not provided objective evidence to justify proposing large
development to the west of Grange-over-Sands given the already inadequate
road system.

I do not support SLDC’s Land Allocation DPD

YES, I wish to participate at the oral examination

I wish to take part in the oral examination because SLDC have not made an adequate response to significant planning concerns, raised by local residents, during earlier consultation phases, particularly those relating to:
1. ‘Housing need’ in the Grange-over-Sands area.
2. Proposed green field site land allocations for the Grange-over-Sands area.
3. The adverse impact of the proposed developments on tourism, the life-blood of Grange-over-Sands and the Cartmel Peninsula.
4. The inadequate road system that links Grange-over-Sands to other SLDC Service Centres.
In addition, SLDC have not provided objective evidence that justifies their classification of Grange-over-Sands as an SLDC Key Service Centre. Grange-over-Sands does not meet SLDC’s Core Strategy Document definition of Key Service Centre: it does not have a secondary school and it is not directly linked to other SLDC Service Centres by a main trunk road.
Nor does the SLDC Land Allocation DPD take account of local residents’ wishes about how their community should be developed, or the views of Grange-over-Sands Town Council.

Please notify me

LA3.3 Mixed Use Allocation at Guide's Lot, Grange-over-Sands

No

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. SLDC should not include Grange-over-Sands as one of its Key Service Centres because it does not meet the criteria in CS1.2 The development strategy for Principal Service Centres, Key Service Centres and Local Service Centres. This would mean that the number of proposed developments in Grange-over-Sands and district should be reduced and all proposed development sites should be reassessed. Development of brown field sites, such as Berners, should be prioritised and SLDC should take account of the views of local residents and Grange-over-Sands Town Council.
2. SLDC have not followed Government guidance about the use and interpretation of household surveys. They have not provided objective evidence to justify ‘housing need for Grange-over-Sands and District.
3. SLDC should be required to produce objective evidence to justify their plans to allow Grange-over-Sands to develop into a coastal urban sprawl incorporating Kents Bank.
4. SLDC should be required to remove sites MN25N, R672 and R79# from their Land Development DPD because development of these sites will lead to coalescence between the communities of Kents Bank and Allithwaite.
5. SLDC should be required to remove sites R449, R74 and R110 from their Land Development DPD because development of these sites will lead to further coalescence between the communities of Grange-over-Sands and Kents Bank.
6. SLDC should be required to produce clear evidence about how their proposed developments will enhance tourism in Grange-over-Sands and district.
7. SLDC should be required to explain why they have ignored recommendations made about green field sites and tourism in the Grange-over-Sands Regeneration Study (Douglas Wheeler Associates, November 2007), that they claim has informed SLDC's Core Strategy.
8. SLDC should be required to provide objective evidence that the local roads are adequate to support the proposed increase in population and traffic in Grange-over-Sands especially for known bottle-necks in Main Street and on Risedale Hill.
9. SLDC should not allow any development on prime green field land between Kents Bank and Allithwaite because it will lead to coalescence between these two separate communities.

I do not support SLDC’s Land Allocations DPD because it is based on spurious ‘housing need’ targets and has unnecessarily ear-marked important greenfield sites for development.

No

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 following text of response 11293 is taken from sections 4, 5 and 7 of my SLDC LDF consultation submission entitled: ‘Soundness’ response to SLDC’s Land Allocation Development Plan (DPD, Jan 2012) focussing on SLDC’s ‘housing need’ predictions & SLDC’s vision for Grange-over-Sands and District.
My report included photographs, maps and tables to support comments that were made in the report. I have requested that this report be made available to the Planning Inspector.
The sections featured in response 11293 are:
4. Does SLDC's Land Allocation Document protect the needs of Grange-over-Sands as a unique coastal tourist destination?
5 . Does SLDC’s Land Allocation Document attempt to ‘air-brush’ Kents Bank out of existence as a separate community?
7. Does SLDC's Land Allocation Document make adequate provision for capital expenditure to upgrade local roads?
Photographs, tables and maps that were included with the text in the report have been stored elsewhere, formatting that clarified the text has been removed and spurious question marks have appeared that are not in the original text.
[The full report is attached]

4 Does SLDC’s Land Allocation Document protect the needs of Grange-over-
Sands as a unique coastal tourist destination?

4.1 SLDC’s Land Allocation Plan states that the Grange-over-Sands Regeneration Study
(November 2007), Douglas Wheeler Associates, has informed SLDC’s Core Strategy.

4.2 The Grange-over-Sands Regeneration Study states that Grange-over-Sands is:

i. North West England’s most distinctive, contemporary coastal resort town that has
used its Edwardian heritage as a strong asset in its regeneration.

ii. An exceptionally pleasant, very well maintained and friendly town with:
- An impressive promenade and superb views across Morecambe Bay.
- Excellent parks and garden.
- A well connected rail station.
- A strong community of established and new residents.
- A great place to live, work and visit.

iii. Has a strong convenience retailing and service orientated focus.

4.3 SLDC’s Core Strategy document states that:
"...We aim to achieve a balanced housing market by securing the provision of a range of
housing types and sizes to meet the needs of all sectors…” and
“…The exact scale and level of development supported will be dependent on individual
character, the impact on environmental capacity and infrastructure provision, and the
desire to meet the need for affordable housing as locally as possible…”

4.4 The proposed developments in SLDC’s Land Allocation document for Grange-over-
Sands and district have not achieved this objective because:
- They will increase the number of households by 25%.
- Local roads do not have the capacity to absorb the extra traffic that will be
generated.
- They will allow building on important green field sites.
- They will lead to the coalescence of Grange-over-Sands with adjacent
communities.

4.5 The questionable SLDC ‘new build’ target has been arbitrarily divided between defined
areas of South Lakeland district, on a percentage basis, between the Principal Service
Centres, Key Service Centres and rural areas.

4.6 The housing allocation made for Grange-over-Sands was based on its classification as a Key Service Centre but, as it does not meet the SLDC’s stated criteria for a Key Service
Centre (see Section 3), the housing allocation is not compatible with its needs as a
unique coastal tourist destination.

4.7 The allocation of new build’ for Grange-over-Sands, Kents Bank, Allithwaite and Cartmel
peninsula area does not appear to have factored in:
- The high percentage of retired people living in the area: a proportionally higher
amount of the existing housing stock will be available for ‘new’ households, on a
regular basis, due to the higher mortality.
- The high percentage of dwellings that are ‘second homes’ and ‘holiday lets’ some of
which are likely revert to normal residential use over time eg eight apartments in
Kents Bank were converted from ‘holiday apartments’ to ‘normal residential’
apartments in 2010.

4.8 SLDC has not justified the need for a massive ‘new build’ requirement in Grange-over-
Sands and district with objective evidence.

4.9 There is a need for ‘affordable housing’ but even that need has not been quantified
objectively.

4.10 The overall ‘new build’ housing figures have been inflated because of the policy of
requiring developers to subsidise ‘affordable housing’ (see section 2).

4.11 SLDC’s proposals will lead to a 25% increase in the number of households in Grangeover-Sands and Kents Bank without any provision for improvements to the local road
system or car parking facilities or utilities; this will be detrimental to the tourist industry.

4.12 Section 4.4 of SLDC’s Land Allocation document states:
“…Douglas Wheeler Associates prepared a Regeneration Study for Grange-over-
Sands in 2007. This carried out a detailed assessment of Grange as a Key
Service Centre that formed the basis of Core Strategy policies for the town…”

4.13 The independent Grange-over-Sands Regeneration Study 2007 found:
“…Around 7.5% of properties are second homes and clearly Grange should not become
dominated by second homes and retirement homes…”

4.14 If SLDC’s proposal to build 500 dwellings in Grange-over-Sands and district is realised the likely outcome will be to increase in the number of ‘second homes’, ‘holiday homes’, and ‘in-coming’ pensioners in order to subsidise 175 ‘affordable homes’; SLDC have not provided evidence to justify this need.

4.15 Building on this scale will not benefit the local community because it will lead to an
increased pressure on the NHS, local roads, public transport, utilities etc… and have an
adverse effect on local tourism.

4.16 There are currently 129 dwellings on the market in Grange-over-Sands and district
ranging from one and two bed-roomed apartments to large detached houses and
everything in between. Many of these properties have been on the market for over two
years; many others have been taken off the market and turned into private rented
accommodation. So, how can SLDC justify the need for 325 more new dwellings on the
open market?

4.17 The Grange-over-Sands Regeneration Study 2007 also stated that:
“…Additional housing will be provided to meet the needs of local people without
damaging the sensitive setting and character of the town…” and
“…the key to the success or failure of Grange-over-Sands…will be to invest in the
unique quality of the built and natural environment, infrastructure and public facilities
alongside promoting enterprise and business development…” and
“…It only requires one element to be below standard to reduce the overall appeal of the
place…”

4.18 Residents of Grange-over-Sands and district would agree with all the above objectives
but feel that SLDC’s Land Allocation DPD proposals do not match this expectation. For
instance, the study looked at Grange-over-Sands land development options in detail. It
recommended that land ‘north of playing field’ (R110: Trickett’s field) should not be
developed because: “…loss of open views from street is negative…”

4.19 This site is also important because it is one of the few remaining green gaps between
Grange-over-Sands and Kents Bank (see section 5).

4.20 The Grange-over-Sands Regeneration Study 2007 also stated that it was important to:
“…protect the network of green spaces and important environmental characteristics of
the town and its setting…” and
“…protect the network of green spaces and important characteristics of the town…give
priority to the use of previously developed land for development…”

4.21 Brown field sites such as Berners, the former candle factory and Bateman’s garage
should be developed for housing and employment before any green field sites are
considered; sensitive development of brown field sites will not destroy the rural
ambience of the area that is so attractive to tourists.

4.22 Tourism is the life-blood of Grange-over-Sands’ economy. SLDC is not justified in
proposing large scale developments on green field sites before undertaking a feasibility
study assessing the impact of the proposed developments on tourism. They have not
done this. Such arrogance is negligent given the potential impact on the local tourist
industry.

4.23 It is unlikely that tourists will want visit the Grange-over-Sands area during the
construction phases due to the impact on the already inadequate road system (see
section 7); post construction, who wants to visit a coastal urban sprawl?

4.24 Investment in basic infrastructure is needed before any major increase in housing but
the SLDC Land Allocation Development Plan does include any provision for solving the
known traffic bottle-necks of Risedale Hill and Main Street Grange-over-Sands (see
section 7). Why not?

4.25 Section 4.2 of the SLDC Land Allocation DPD states:
“…The Core Strategy (Policy CS4) sets the overall context for development in Grangeover-
Sands. This seeks to make provision for moderate housing development and
employment development, regenerate the Berners site, improve public transport, reinstate
footbridges and protect the network of Green Infrastructure as well as promoting
the vitality of Grange town Centre and promoting tourism…”

4.26 Local residents support all these objectives, but, the land development proposals that
SLDC have proposed for Grange-over-Sands and district contradict these objectives;
they have not protected the network Green infrastructure (see sections 5, 6 and 7) and
they have not promoted tourism, nor have they justified proposing to development of
green field sites with objective evidence.

4.27 As the Grange-over-Sands Regeneration Study 2007 said of Grange-over-Sands it is
important to:
- Maintain and enhance the viability of the town centre.
- Promote…appropriate development at the Berners Pool/BernersClose car
park/nursery/lido site to create a new focus.
- Promote the vitality and viability of Grange-over-Sands town centre.
- Promote the reintroduction of the Berners Close railway bridge.
- Focus on renovation rather than demolition.
- Minimise the impact on the environment and improve biodiversity
Unfortunately SLDC’s Land Allocation DPD appears to have lost sight of these
objectives.

Section 4: Grange-over-Sands, a unique coastal town;
summary of main conclusions
- Grange-over-Sands is a unique coastal town that is dependent on the tourist
industry and has unique development needs.
- Grange-over-Sands is not suitable for large scale development because of its
tourist needs; the surrounding rough pasture lands are part of its attraction.
- All proposed development should be considered in this context and should be
concentrated on brown field sites as recommended in the Grange-over-Sands
Regeneration Study 2007.
- The local road system, utilities and community support systems are already
inadequate; they are not robust enough to support 500 more households.
- The surrounding topography and proximity of other local communities means
that it is inappropriate allow large scale developments to extend into Kents
Bank or onto peripheral rough pasture land.

5 Does SLDC’s Land Allocation Document attempt to ‘air-brush’ Kents
Bank out of existence as a separate community?

5.1 SLDC’s Planning Department currently treats Kents Bank as a suburb of Grange-over-
Sands even though Kents Bank can trace its existence back to Mediaeval times when
monks from Cartmel lodged at Abbot Hall, Kents Bank, when ‘crossing the sands’
whereas Grange-over-Sands developed as a tourist resort in Victorian times after the
‘coming of the railway.

5.2 Kents Bank has its own station, Post Office, shop, Art Gallery, Abbot Hall Hotel and
Guide’s Farm. The post of Guide dates back to at least 1501 according to records of
Cartmel Priory.

5.3 During the past 20-25 years SLDC’s Planning Department have permitted infilling
development on many Kents Bank green field sites; they have allowed infilling on green
gaps between Kents Bank and Grange-over-Sands on the east, and, Kents Bank and
Allithwaite on the west.

5.4 Why is SLDC treating Kents Bank as a suburb of Grange-over-Sands? Residents of
Kents Bank do not support this view; they value their community and do not want to see
Kents Bank absorbed into Grange-over-Sands or Allithwaite. Kents Bank was
established hundreds of years before Grange-over-Sands.

5.5 This unsound approach has been perpetuated in SLDC’s Land Allocation DPD. Section
4.2 of the document is headed Grange-over-Sands and Kents Bank whereas Allithwaite
is considered as a separate community.

5.6 Subsequent text in SLDC’s Land Allocation DPD uses the name Grange-over-Sands
when it is actually referring to Kents Bank. For example paragraph 4.12 states:
“…The second major allocation is a large site on Allithwaite Road west of Kents Bank.
This is the only large site available in Grange-over-Sands…”

5.7 This is nonsense. The site referred to is MN25M; it is west of Kents Bank; it will
significantly extend Kents Bank’s western boundary and will lead to coalescence
between Kents Bank and Allithwaite if it is developed (see Map 1 and section 6).

REFER TO MAP 1 & 2 IN ATTACHED DOCUMENT

5.8 SLDC’s Land Allocation DPD gives Kents Bank similar problems with its Grange-over-
Sands boundaries; the green spaces between Grange-over-Sands and Kents Bank have
been gradually eroded over the years. If more green spaces between the two
communities are developed it will be the ‘death knell’ of Kents Bank as a separate
community (see Map 2)

5.9 It is clear from Map 2 that building on sites R110 (Trickett’s field) and R449/R74 will
erode the sense of separation between Grange-over-Sands and Kents Bank when
driving on the main road, the B5227 and that they will increase coalescence between
Grange-over-Sands and Kents Bank.

5.10 The Grange-over-Sands Regeneration Study 2007 considered site R110 (Trickett’s
field). They concluded that it should not be developed because:
“…loss of open views from street is negative…”

5.11 R449/R74 was not considered by the Grange-over-Sands Regeneration Study 2007 and its importance as a green field site has not been independently assessed. It is clear from Map 2 that development of these two sites will increase coalescence between Grangeover-Sands and Kents Bank. SLDC has provided no objective evidence to support the development of either of these green field sites.

5.12 The only green field site in Kents Bank that was considered by the Grange-over-Sands
Regeneration Study 2007 was site R89 (the Carter Road site, Berry Bank, Map 1 and
Map 2) and the report did not recommend development of R89 because of:
“…the loss of open area will be an issue…” and they concluded that
“…that residential development of the Allithwaite Road/Carter Road site is likely to be
controversial because of the ‘green field’ nature of the site…”

5.13 None of the development sites proposed for Kents Bank (Map 1), except R89, were
considered by the Grange-over-Sands Regeneration Study 2007; they have not been
independently assessed before inclusion in SLDC’s Land Allocation DPD.

REFER TO TABLE 4 in ATTACHED DOCUMENT

5.14 Table 4 clearly shows that a disproportionate amount of the unsustainable housing
allocation for Grange-over-Sands has been allocated to Kents Bank (58%)

5.15 The proposed development will increase the size of Kents Bank by 40% and extend its
boundaries towards Allithwaite causing coalescence between Kents Bank and
Allithwaite; SLDC have provided no objective evidence to justify increasing the size of
Kents Bank on this scale.

5.16 All the proposed housing development sites in Kents Bank have been allocated to
desirable green field sites except for Guides Lot (17 dwellings plus employment units)
but even this site includes a small additional green field and the site is adjacent to land
on Wart Barrow that is covered by a Limestone Pavement Order.

5.17 The proposed site MN25M is particularly contentious (see section 6).

5.18 Development of all the proposed sites near Risedale Hill and in Kents Bank will have an adverse effect on local drainage in areas that are already prone to flooding after heavy
rainfall eg Allithwaite Road beyond the top of Risedale Hill, Greaves Wood Road
(Bridleway) and Kirkhead Road.

5.19 The SLDC’s Land Allocation DPD has not taken account of problems highlighted by
Kents Bank residents in the 2011 consultation exercises. For example response forms
that I submitted for sites: MN25M, R672, 350M, R79#, R82#/R347# (see Appendices 3
to 7).

5.20 Many other residents also highlighted significant problems associated with the proposed land allocations for Kents Bank. All appear to have been ignored and lumped together in groups with a comment such as ‘noted’ beside them (see section 8). Why?

Section 5: Kents Bank as a separate community;
summary of main conclusions
- Kents Bank has been a separate community since Mediaeval times.
- SLDC have provided no clear evidence to justify increasing the size of Kents
Bank by 40%.
- SLDC have provided no clear evidence to justify sanctioning developments
that will increase coalescence between Grange-over-Sands and Kents Bank.
- SLDC have provided no clear evidence to justify sanctioning developments
that will increase coalescence between Kents Bank and Allithwaite.
- The local road system, utilities and community support systems are already
inadequate; they are not robust enough to support 298 more households in
Kents Bank.

7 Does SLDC’s Land Allocation Document make adequate provision for
capital expenditure to upgrade local roads?

7.1 Allithwaite Road (B5277) is already inadequate for the amount of traffic regularly
travelling between Grange-over-Sands, Allithwaite, Flookburgh, Holker Hall, Kendal,
Lancaster and the M6.

7.2 The traffic problem is exacerbated when regular events such as Cartmel Races and
the Holker Garden Festival attract large crowds.

7.3 The stretch of Allithwaite Road between Kents Bank and Allithwaite from the top of
Risedale Hill is a fast stretch of undulating road that poses sight line problems for
drivers (see picture 3, section 6.15).

7.4 Developers would be forced to create new roads for development area MN25M linking
onto Allithwaite Road; this would increase traffic hazards on Allithwaite Road, or, lead
to the creation of an intrusive roundabout system that would destroy the rural nature
of this road and area

7.5 Greaves Wood Road bridleway forms the eastern, and southern, boundaries of
MN25M; it could not be used as access to MN25M development area because of a)
the Protected Limestone Pavement in Greaves Wood and b) it is a popular pedestrian
route for local residents, especially dog walkers (see Map 1, section 5.7 and Map 3,
section 6.4).

7.6 Access from Kirkhead Road to the MN25M development area is not practical; there
are no suitable gaps between the houses whose back gardens form the western
boundary of MN25M.

7.7 Industrial development and 202 residential units will generate a large amount of extra
traffic in Kents Bank that will all need to drive through Grange-over-Sands to reach the
A590 for access to Kendal, Lancaster and the M6; the local road system is not
suitable for this.

7.8 Local roads are not adequate to accommodate service vehicles for industrial
development.

REFER TO PICTURES IN ATTACHED DOCUMENT

7.9 SLDC are also proposing to build dwellings on the land behind the lorry on Allithwaite
Road (picture 6) and on the left hand side of Allithwaite Road beyond the junction of
Allithwaite Road with Jack Hill (junction to the left of Kirkhead Road; picture 6); access
to both these sites is constrained by their location and will cause road safety
problems.

7.10 Picture 5 clearly shows that it is not possible to widen or straighten Risedale Hill
without major road works involving compulsory purchase orders, demolition of walls
and completely altering the character of this part of Kents Bank and that the road is
not suitable for large volumes of traffic.

7.11 Traffic from three other nearby proposed residential developments in Kents Bank,
R672M: 36 residential units & R89: 45 residential units, R350M: 17 houses, also link
to Allithwaite Road, near the top of Risedale Hill therefore they should also be taken
into account when undertaking an area traffic impact study (see Map 1, section 5.7);
as should traffic generated by all residential and employment developments west of
Risedale Hill in Allithwaite and Flookburgh.

7.12 Once the traffic has negotiated Risedale Hill it then has to negotiate Main Street hill in
Grange-over-Sands another bottleneck that is often made worse by delivery vehicles
for the local shops because none of the shops on this part of Main Street have rear
access,

7.13 The local roads are in a poor state of repair and are not suitable for this level of traffic
increase.

7.14 SLDC have made no provision for improving these roads and have not justified a
need for developments that will make the traffic conditions considerably worse and
deter tourists.

7.15 There is no viable route for a Grange-over-Sands by-pass. A new trunk road to the
A590 would have to be routed across rough pastureland to the north of Grange-over-
Sands and would impinge on classic views of Cartmel and Cartmel Priory.

7.16 Car parking in Grange-over-Sands is already inadequate for local residents shopping
and tourists and again, no provision has been made in SLDC’s Land Allocation DPD
to improve local car parking facilities.

Section 7: Inadequate local roads in Grange-over-Sands and District;
summary of main conclusions
- The roads in Grange-over-Sands and district are already inadequate for the
traffic that they carry.
- There are two major bottlenecks: Risedale Hill and Main Street Hill that
cannot be widened due to their location.
- It would be expensive and difficult to agree a route for a new trunk road to the
A590 that by-passed Grange-over-Sands.
- SLDC have not made any provision to upgrade roads in Grange-over-Sands
and district.
- SLDC have not provided objective evidence to justify proposing large
development to the west of Grange-over-Sands given the already inadequate
road system.

I do not support SLDC’s Land Allocation DPD

YES, I wish to participate at the oral examination

I wish to take part in the oral examination because SLDC have not made an adequate response to significant planning concerns, raised by local residents, during earlier consultation phases, particularly those relating to:
1. ‘Housing need’ in the Grange-over-Sands area.
2. Proposed green field site land allocations for the Grange-over-Sands area.
3. The adverse impact of the proposed developments on tourism, the life-blood of Grange-over-Sands and the Cartmel Peninsula.
4. The inadequate road system that links Grange-over-Sands to other SLDC Service Centres.
In addition, SLDC have not provided objective evidence that justifies their classification of Grange-over-Sands as an SLDC Key Service Centre. Grange-over-Sands does not meet SLDC’s Core Strategy Document definition of Key Service Centre: it does not have a secondary school and it is not directly linked to other SLDC Service Centres by a main trunk road.
Nor does the SLDC Land Allocation DPD take account of local residents’ wishes about how their community should be developed, or the views of Grange-over-Sands Town Council.

Please notify me

LA1.3 Housing Allocations - R449/R74 GRANGE-OVER-SANDS OPPOSITE LITTLE FELL GATE FARM

No

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. SLDC should not include Grange-over-Sands as one of its Key Service Centres because it does not meet the criteria in CS1.2 The development strategy for Principal Service Centres, Key Service Centres and Local Service Centres. This would mean that the number of proposed developments in Grange-over-Sands and district should be reduced and all proposed development sites should be reassessed. Development of brown field sites, such as Berners, should be prioritised and SLDC should take account of the views of local residents and Grange-over-Sands Town Council.
2. SLDC have not followed Government guidance about the use and interpretation of household surveys. They have not provided objective evidence to justify ‘housing need for Grange-over-Sands and District.
3. SLDC should be required to produce objective evidence to justify their plans to allow Grange-over-Sands to develop into a coastal urban sprawl incorporating Kents Bank.
4. SLDC should be required to remove sites MN25N, R672 and R79# from their Land Development DPD because development of these sites will lead to coalescence between the communities of Kents Bank and Allithwaite.
5. SLDC should be required to remove sites R449, R74 and R110 from their Land Development DPD because development of these sites will lead to further coalescence between the communities of Grange-over-Sands and Kents Bank.
6. SLDC should be required to produce clear evidence about how their proposed developments will enhance tourism in Grange-over-Sands and district.
7. SLDC should be required to explain why they have ignored recommendations made about green field sites and tourism in the Grange-over-Sands Regeneration Study (Douglas Wheeler Associates, November 2007), that they claim has informed SLDC's Core Strategy.
8. SLDC should be required to provide objective evidence that the local roads are adequate to support the proposed increase in population and traffic in Grange-over-Sands especially for known bottle-necks in Main Street and on Risedale Hill.
9. SLDC should not allow any development on prime green field land between Kents Bank and Allithwaite because it will lead to coalescence between these two separate communities.

I do not support SLDC’s Land Allocations DPD because it is based on spurious ‘housing need’ targets and has unnecessarily ear-marked important greenfield sites for development.

No

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 following text of response 11295 is taken from section 5, my SLDC LDF consultation submission entitled: ‘Soundness’ response to SLDC’s Land Allocation Development Plan (DPD, Jan 2012) focussing on SLDC’s ‘housing need’ predictions & SLDC’s vision for Grange-over-Sands and District.
My report included photographs, maps and tables to support comments that were made in the report. I have requested that this report be made available to the Planning Inspector.
The section featured in response 11295 is:
5. Does SLDC’s Land Allocation Document attempt to ‘air-brush’ Kents Bank out of existence as a separate community?
Tables and maps that were included with the text in the report have been stored elsewhere, formatting that clarified the text has been removed and spurious question marks have appeared that are not in the original text.
[The full report is attached]

5 Does SLDC’s Land Allocation Document attempt to ‘air-brush’ Kents
Bank out of existence as a separate community?

5.1 SLDC’s Planning Department currently treats Kents Bank as a suburb of Grange-over-
Sands even though Kents Bank can trace its existence back to Mediaeval times when
monks from Cartmel lodged at Abbot Hall, Kents Bank, when ‘crossing the sands’
whereas Grange-over-Sands developed as a tourist resort in Victorian times after the
‘coming of the railway.

5.2 Kents Bank has its own station, Post Office, shop, Art Gallery, Abbot Hall Hotel and
Guide’s Farm. The post of Guide dates back to at least 1501 according to records of
Cartmel Priory.

5.3 During the past 20-25 years SLDC’s Planning Department have permitted infilling
development on many Kents Bank green field sites; they have allowed infilling on green
gaps between Kents Bank and Grange-over-Sands on the east, and, Kents Bank and
Allithwaite on the west.

5.4 Why is SLDC treating Kents Bank as a suburb of Grange-over-Sands? Residents of
Kents Bank do not support this view; they value their community and do not want to see
Kents Bank absorbed into Grange-over-Sands or Allithwaite. Kents Bank was
established hundreds of years before Grange-over-Sands.

5.5 This unsound approach has been perpetuated in SLDC’s Land Allocation DPD. Section
4.2 of the document is headed Grange-over-Sands and Kents Bank whereas Allithwaite
is considered as a separate community.

5.6 Subsequent text in SLDC’s Land Allocation DPD uses the name Grange-over-Sands
when it is actually referring to Kents Bank. For example paragraph 4.12 states:
“…The second major allocation is a large site on Allithwaite Road west of Kents Bank.
This is the only large site available in Grange-over-Sands…”

5.7 This is nonsense. The site referred to is MN25M; it is west of Kents Bank; it will
significantly extend Kents Bank’s western boundary and will lead to coalescence
between Kents Bank and Allithwaite if it is developed (see Map 1 and section 6).

REFER TO MAP 1 & 2 IN ATTACHED DOCUMENT

5.8 SLDC’s Land Allocation DPD gives Kents Bank similar problems with its Grange-over-
Sands boundaries; the green spaces between Grange-over-Sands and Kents Bank have
been gradually eroded over the years. If more green spaces between the two
communities are developed it will be the ‘death knell’ of Kents Bank as a separate
community (see Map 2)

5.9 It is clear from Map 2 that building on sites R110 (Trickett’s field) and R449/R74 will
erode the sense of separation between Grange-over-Sands and Kents Bank when
driving on the main road, the B5227 and that they will increase coalescence between
Grange-over-Sands and Kents Bank.

5.10 The Grange-over-Sands Regeneration Study 2007 considered site R110 (Trickett’s
field). They concluded that it should not be developed because:
“…loss of open views from street is negative…”

5.11 R449/R74 was not considered by the Grange-over-Sands Regeneration Study 2007 and its importance as a green field site has not been independently assessed. It is clear from Map 2 that development of these two sites will increase coalescence between Grangeover-Sands and Kents Bank. SLDC has provided no objective evidence to support the development of either of these green field sites.

5.12 The only green field site in Kents Bank that was considered by the Grange-over-Sands
Regeneration Study 2007 was site R89 (the Carter Road site, Berry Bank, Map 1 and
Map 2) and the report did not recommend development of R89 because of:
“…the loss of open area will be an issue…” and they concluded that
“…that residential development of the Allithwaite Road/Carter Road site is likely to be
controversial because of the ‘green field’ nature of the site…”

5.13 None of the development sites proposed for Kents Bank (Map 1), except R89, were
considered by the Grange-over-Sands Regeneration Study 2007; they have not been
independently assessed before inclusion in SLDC’s Land Allocation DPD.

SEE TABLE 4 IN ATTACHED DOCUMENT

5.14 Table 4 clearly shows that a disproportionate amount of the unsustainable housing
allocation for Grange-over-Sands has been allocated to Kents Bank (58%)

5.15 The proposed development will increase the size of Kents Bank by 40% and extend its
boundaries towards Allithwaite causing coalescence between Kents Bank and
Allithwaite; SLDC have provided no objective evidence to justify increasing the size of
Kents Bank on this scale.

5.16 All the proposed housing development sites in Kents Bank have been allocated to
desirable green field sites except for Guides Lot (17 dwellings plus employment units)
but even this site includes a small additional green field and the site is adjacent to land
on Wart Barrow that is covered by a Limestone Pavement Order.

5.17 The proposed site MN25M is particularly contentious (see section 6).

5.18 Development of all the proposed sites near Risedale Hill and in Kents Bank will have an adverse effect on local drainage in areas that are already prone to flooding after heavy
rainfall eg Allithwaite Road beyond the top of Risedale Hill, Greaves Wood Road
(Bridleway) and Kirkhead Road.

5.19 The SLDC’s Land Allocation DPD has not taken account of problems highlighted by
Kents Bank residents in the 2011 consultation exercises. For example response forms
that I submitted for sites: MN25M, R672, 350M, R79#, R82#/R347# (see Appendices 3
to 7).

5.20 Many other residents also highlighted significant problems associated with the proposed land allocations for Kents Bank. All appear to have been ignored and lumped together in groups with a comment such as ‘noted’ beside them (see section 8). Why?

Section 5: Kents Bank as a separate community;
summary of main conclusions
- Kents Bank has been a separate community since Mediaeval times.
- SLDC have provided no clear evidence to justify increasing the size of Kents
Bank by 40%.
- SLDC have provided no clear evidence to justify sanctioning developments
that will increase coalescence between Grange-over-Sands and Kents Bank.
- SLDC have provided no clear evidence to justify sanctioning developments
that will increase coalescence between Kents Bank and Allithwaite.
- The local road system, utilities and community support systems are already
inadequate; they are not robust enough to support 298 more households in
Kents Bank.

I do not support SLDC’s Land Allocation DPD

YES, I wish to participate at the oral examination

I wish to take part in the oral examination because SLDC have not made an adequate response to significant planning concerns, raised by local residents, during earlier consultation phases, particularly those relating to:
1. ‘Housing need’ in the Grange-over-Sands area.
2. Proposed green field site land allocations for the Grange-over-Sands area.
3. The adverse impact of the proposed developments on tourism, the life-blood of Grange-over-Sands and the Cartmel Peninsula.
4. The inadequate road system that links Grange-over-Sands to other SLDC Service Centres.
In addition, SLDC have not provided objective evidence that justifies their classification of Grange-over-Sands as an SLDC Key Service Centre. Grange-over-Sands does not meet SLDC’s Core Strategy Document definition of Key Service Centre: it does not have a secondary school and it is not directly linked to other SLDC Service Centres by a main trunk road.
Nor does the SLDC Land Allocation DPD take account of local residents’ wishes about how their community should be developed, or the views of Grange-over-Sands Town Council.

Please notify me

LA1.3 Housing Allocations - R89 GRANGE-OVER-SANDS NORTH OF CARTER ROAD

No

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. SLDC should not include Grange-over-Sands as one of its Key Service Centres because it does not meet the criteria in CS1.2 The development strategy for Principal Service Centres, Key Service Centres and Local Service Centres. This would mean that the number of proposed developments in Grange-over-Sands and district should be reduced and all proposed development sites should be reassessed. Development of brown field sites, such as Berners, should be prioritised and SLDC should take account of the views of local residents and Grange-over-Sands Town Council.
2. SLDC have not followed Government guidance about the use and interpretation of household surveys. They have not provided objective evidence to justify ‘housing need for Grange-over-Sands and District.
3. SLDC should be required to produce objective evidence to justify their plans to allow Grange-over-Sands to develop into a coastal urban sprawl incorporating Kents Bank.
4. SLDC should be required to remove sites MN25N, R672 and R79# from their Land Development DPD because development of these sites will lead to coalescence between the communities of Kents Bank and Allithwaite.
5. SLDC should be required to remove sites R449, R74 and R110 from their Land Development DPD because development of these sites will lead to further coalescence between the communities of Grange-over-Sands and Kents Bank.
6. SLDC should be required to produce clear evidence about how their proposed developments will enhance tourism in Grange-over-Sands and district.
7. SLDC should be required to explain why they have ignored recommendations made about green field sites and tourism in the Grange-over-Sands Regeneration Study (Douglas Wheeler Associates, November 2007), that they claim has informed SLDC's Core Strategy.
8. SLDC should be required to provide objective evidence that the local roads are adequate to support the proposed increase in population and traffic in Grange-over-Sands especially for known bottle-necks in Main Street and on Risedale Hill.
9. SLDC should not allow any development on prime green field land between Kents Bank and Allithwaite because it will lead to coalescence between these two separate communities.

I do not support SLDC’s Land Allocations DPD because it is based on spurious ‘housing need’ targets and has unnecessarily ear-marked important greenfield sites for development.

No

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 following text of response 11296 is taken from sections 5 and 7 of my SLDC LDF consultation submission entitled: ‘Soundness’ response to SLDC’s Land Allocation Development Plan (DPD, Jan 2012) focussing on SLDC’s ‘housing need’ predictions & SLDC’s vision for Grange-over-Sands and District.
My report included photographs, maps and tables to support comments that were made in the report. I have requested that this report be made available to the Planning Inspector.
The sections featured in response 11296 are:
5 . Does SLDC’s Land Allocation Document attempt to ‘air-brush’ Kents Bank out of existence as a separate community?
7. Does SLDC's Land Allocation Document make adequate provision for capital expenditure to upgrade local roads?
Photographs, tables and maps that were included with the text in the report have been stored elsewhere, formatting that clarified the text has been removed and spurious question marks have appeared that are not in the original text.
[Full report is attached]

5 Does SLDC’s Land Allocation Document attempt to ‘air-brush’ Kents
Bank out of existence as a separate community?

5.1 SLDC’s Planning Department currently treats Kents Bank as a suburb of Grange-over-
Sands even though Kents Bank can trace its existence back to Mediaeval times when
monks from Cartmel lodged at Abbot Hall, Kents Bank, when ‘crossing the sands’
whereas Grange-over-Sands developed as a tourist resort in Victorian times after the
‘coming of the railway.

5.2 Kents Bank has its own station, Post Office, shop, Art Gallery, Abbot Hall Hotel and
Guide’s Farm. The post of Guide dates back to at least 1501 according to records of
Cartmel Priory.

5.3 During the past 20-25 years SLDC’s Planning Department have permitted infilling
development on many Kents Bank green field sites; they have allowed infilling on green
gaps between Kents Bank and Grange-over-Sands on the east, and, Kents Bank and
Allithwaite on the west.

5.4 Why is SLDC treating Kents Bank as a suburb of Grange-over-Sands? Residents of
Kents Bank do not support this view; they value their community and do not want to see
Kents Bank absorbed into Grange-over-Sands or Allithwaite. Kents Bank was
established hundreds of years before Grange-over-Sands.

5.5 This unsound approach has been perpetuated in SLDC’s Land Allocation DPD. Section
4.2 of the document is headed Grange-over-Sands and Kents Bank whereas Allithwaite
is considered as a separate community.

5.6 Subsequent text in SLDC’s Land Allocation DPD uses the name Grange-over-Sands
when it is actually referring to Kents Bank. For example paragraph 4.12 states:
“…The second major allocation is a large site on Allithwaite Road west of Kents Bank.
This is the only large site available in Grange-over-Sands…”

5.7 This is nonsense. The site referred to is MN25M; it is west of Kents Bank; it will
significantly extend Kents Bank’s western boundary and will lead to coalescence
between Kents Bank and Allithwaite if it is developed (see Map 1 and section 6).

REFER TO MAP 1 & 2 IN ATTACHED DOCUMENT

5.8 SLDC’s Land Allocation DPD gives Kents Bank similar problems with its Grange-over-
Sands boundaries; the green spaces between Grange-over-Sands and Kents Bank have
been gradually eroded over the years. If more green spaces between the two
communities are developed it will be the ‘death knell’ of Kents Bank as a separate
community (see Map 2)

5.9 It is clear from Map 2 that building on sites R110 (Trickett’s field) and R449/R74 will
erode the sense of separation between Grange-over-Sands and Kents Bank when
driving on the main road, the B5227 and that they will increase coalescence between
Grange-over-Sands and Kents Bank.

5.10 The Grange-over-Sands Regeneration Study 2007 considered site R110 (Trickett’s
field). They concluded that it should not be developed because:
“…loss of open views from street is negative…”

5.11 R449/R74 was not considered by the Grange-over-Sands Regeneration Study 2007 and its importance as a green field site has not been independently assessed. It is clear from Map 2 that development of these two sites will increase coalescence between Grangeover-Sands and Kents Bank. SLDC has provided no objective evidence to support the development of either of these green field sites.

5.12 The only green field site in Kents Bank that was considered by the Grange-over-Sands
Regeneration Study 2007 was site R89 (the Carter Road site, Berry Bank, Map 1 and
Map 2) and the report did not recommend development of R89 because of:
“…the loss of open area will be an issue…” and they concluded that
“…that residential development of the Allithwaite Road/Carter Road site is likely to be
controversial because of the ‘green field’ nature of the site…”

5.13 None of the development sites proposed for Kents Bank (Map 1), except R89, were
considered by the Grange-over-Sands Regeneration Study 2007; they have not been
independently assessed before inclusion in SLDC’s Land Allocation DPD.

SEE TABLE 4 IN ATTACHED DOCUMENT

5.14 Table 4 clearly shows that a disproportionate amount of the unsustainable housing
allocation for Grange-over-Sands has been allocated to Kents Bank (58%)

5.15 The proposed development will increase the size of Kents Bank by 40% and extend its
boundaries towards Allithwaite causing coalescence between Kents Bank and
Allithwaite; SLDC have provided no objective evidence to justify increasing the size of
Kents Bank on this scale.

5.16 All the proposed housing development sites in Kents Bank have been allocated to
desirable green field sites except for Guides Lot (17 dwellings plus employment units)
but even this site includes a small additional green field and the site is adjacent to land
on Wart Barrow that is covered by a Limestone Pavement Order.

5.17 The proposed site MN25M is particularly contentious (see section 6).

5.18 Development of all the proposed sites near Risedale Hill and in Kents Bank will have an adverse effect on local drainage in areas that are already prone to flooding after heavy
rainfall eg Allithwaite Road beyond the top of Risedale Hill, Greaves Wood Road
(Bridleway) and Kirkhead Road.

5.19 The SLDC’s Land Allocation DPD has not taken account of problems highlighted by
Kents Bank residents in the 2011 consultation exercises. For example response forms
that I submitted for sites: MN25M, R672, 350M, R79#, R82#/R347# (see Appendices 3
to 7).

5.20 Many other residents also highlighted significant problems associated with the proposed land allocations for Kents Bank. All appear to have been ignored and lumped together in groups with a comment such as ‘noted’ beside them (see section 8). Why?

Section 5: Kents Bank as a separate community;
summary of main conclusions
- Kents Bank has been a separate community since Mediaeval times.
- SLDC have provided no clear evidence to justify increasing the size of Kents
Bank by 40%.
- SLDC have provided no clear evidence to justify sanctioning developments
that will increase coalescence between Grange-over-Sands and Kents Bank.
- SLDC have provided no clear evidence to justify sanctioning developments
that will increase coalescence between Kents Bank and Allithwaite.
- The local road system, utilities and community support systems are already
inadequate; they are not robust enough to support 298 more households in
Kents Bank.

7 Does SLDC’s Land Allocation Document make adequate provision for
capital expenditure to upgrade local roads?

7.1 Allithwaite Road (B5277) is already inadequate for the amount of traffic regularly
travelling between Grange-over-Sands, Allithwaite, Flookburgh, Holker Hall, Kendal,
Lancaster and the M6.

7.2 The traffic problem is exacerbated when regular events such as Cartmel Races and
the Holker Garden Festival attract large crowds.

7.3 The stretch of Allithwaite Road between Kents Bank and Allithwaite from the top of
Risedale Hill is a fast stretch of undulating road that poses sight line problems for
drivers (see picture 3, section 6.15).

7.4 Developers would be forced to create new roads for development area MN25M linking
onto Allithwaite Road; this would increase traffic hazards on Allithwaite Road, or, lead
to the creation of an intrusive roundabout system that would destroy the rural nature
of this road and area

7.5 Greaves Wood Road bridleway forms the eastern, and southern, boundaries of
MN25M; it could not be used as access to MN25M development area because of a)
the Protected Limestone Pavement in Greaves Wood and b) it is a popular pedestrian
route for local residents, especially dog walkers (see Map 1, section 5.7 and Map 3,
section 6.4).

7.6 Access from Kirkhead Road to the MN25M development area is not practical; there
are no suitable gaps between the houses whose back gardens form the western
boundary of MN25M.

7.7 Industrial development and 202 residential units will generate a large amount of extra
traffic in Kents Bank that will all need to drive through Grange-over-Sands to reach the
A590 for access to Kendal, Lancaster and the M6; the local road system is not
suitable for this.

7.8 Local roads are not adequate to accommodate service vehicles for industrial
development.

SEE PICTURES IN ATTACHED DOCUMENT

7.9 SLDC are also proposing to build dwellings on the land behind the lorry on Allithwaite
Road (picture 6) and on the left hand side of Allithwaite Road beyond the junction of
Allithwaite Road with Jack Hill (junction to the left of Kirkhead Road; picture 6); access
to both these sites is constrained by their location and will cause road safety
problems.

7.10 Picture 5 clearly shows that it is not possible to widen or straighten Risedale Hill
without major road works involving compulsory purchase orders, demolition of walls
and completely altering the character of this part of Kents Bank and that the road is
not suitable for large volumes of traffic.

7.11 Traffic from three other nearby proposed residential developments in Kents Bank,
R672M: 36 residential units & R89: 45 residential units, R350M: 17 houses, also link
to Allithwaite Road, near the top of Risedale Hill therefore they should also be taken
into account when undertaking an area traffic impact study (see Map 1, section 5.7);
as should traffic generated by all residential and employment developments west of
Risedale Hill in Allithwaite and Flookburgh.

7.12 Once the traffic has negotiated Risedale Hill it then has to negotiate Main Street hill in
Grange-over-Sands another bottleneck that is often made worse by delivery vehicles
for the local shops because none of the shops on this part of Main Street have rear
access,

7.13 The local roads are in a poor state of repair and are not suitable for this level of traffic
increase.

7.14 SLDC have made no provision for improving these roads and have not justified a
need for developments that will make the traffic conditions considerably worse and
deter tourists.

7.15 There is no viable route for a Grange-over-Sands by-pass. A new trunk road to the
A590 would have to be routed across rough pastureland to the north of Grange-over-
Sands and would impinge on classic views of Cartmel and Cartmel Priory.

7.16 Car parking in Grange-over-Sands is already inadequate for local residents shopping
and tourists and again, no provision has been made in SLDC’s Land Allocation DPD
to improve local car parking facilities.

Section 7: Inadequate local roads in Grange-over-Sands and District;
summary of main conclusions
- The roads in Grange-over-Sands and district are already inadequate for the
traffic that they carry.
- There are two major bottlenecks: Risedale Hill and Main Street Hill that
cannot be widened due to their location.
- It would be expensive and difficult to agree a route for a new trunk road to the
A590 that by-passed Grange-over-Sands.
- SLDC have not made any provision to upgrade roads in Grange-over-Sands
and district.
- SLDC have not provided objective evidence to justify proposing large
development to the west of Grange-over-Sands given the already inadequate
road system.

I do not support SLDC’s Land Allocation DPD

YES, I wish to participate at the oral examination

I wish to take part in the oral examination because SLDC have not made an adequate response to significant planning concerns, raised by local residents, during earlier consultation phases, particularly those relating to:
1. ‘Housing need’ in the Grange-over-Sands area.
2. Proposed green field site land allocations for the Grange-over-Sands area.
3. The adverse impact of the proposed developments on tourism, the life-blood of Grange-over-Sands and the Cartmel Peninsula.
4. The inadequate road system that links Grange-over-Sands to other SLDC Service Centres.
In addition, SLDC have not provided objective evidence that justifies their classification of Grange-over-Sands as an SLDC Key Service Centre. Grange-over-Sands does not meet SLDC’s Core Strategy Document definition of Key Service Centre: it does not have a secondary school and it is not directly linked to other SLDC Service Centres by a main trunk road.
Nor does the SLDC Land Allocation DPD take account of local residents’ wishes about how their community should be developed, or the views of Grange-over-Sands Town Council.

Please notify me

LA1.3 Housing Allocations - R672M GRANGE-OVER-SANDS WEST OF CARDRONA ROAD

No

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. SLDC should not include Grange-over-Sands as one of its Key Service Centres because it does not meet the criteria in CS1.2 The development strategy for Principal Service Centres, Key Service Centres and Local Service Centres. This would mean that the number of proposed developments in Grange-over-Sands and district should be reduced and all proposed development sites should be reassessed. Development of brown field sites, such as Berners, should be prioritised and SLDC should take account of the views of local residents and Grange-over-Sands Town Council.
2. SLDC have not followed Government guidance about the use and interpretation of household surveys. They have not provided objective evidence to justify ‘housing need for Grange-over-Sands and District.
3. SLDC should be required to produce objective evidence to justify their plans to allow Grange-over-Sands to develop into a coastal urban sprawl incorporating Kents Bank.
4. SLDC should be required to remove sites MN25N, R672 and R79# from their Land Development DPD because development of these sites will lead to coalescence between the communities of Kents Bank and Allithwaite.
5. SLDC should be required to remove sites R449, R74 and R110 from their Land Development DPD because development of these sites will lead to further coalescence between the communities of Grange-over-Sands and Kents Bank.
6. SLDC should be required to produce clear evidence about how their proposed developments will enhance tourism in Grange-over-Sands and district.
7. SLDC should be required to explain why they have ignored recommendations made about green field sites and tourism in the Grange-over-Sands Regeneration Study (Douglas Wheeler Associates, November 2007), that they claim has informed SLDC's Core Strategy.
8. SLDC should be required to provide objective evidence that the local roads are adequate to support the proposed increase in population and traffic in Grange-over-Sands especially for known bottle-necks in Main Street and on Risedale Hill.
9. SLDC should not allow any development on prime green field land between Kents Bank and Allithwaite because it will lead to coalescence between these two separate communities.

I do not support SLDC’s Land Allocations DPD because it is based on spurious ‘housing need’ targets and has unnecessarily ear-marked important greenfield sites for development.

No

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 following text of response 11297 is taken from sections 5, 6 and 7 of my SLDC LDF consultation submission entitled: ‘Soundness’ response to SLDC’s Land Allocation Development Plan (DPD, Jan 2012) focussing on SLDC’s ‘housing need’ predictions & SLDC’s vision for Grange-over-Sands and District.
My report included photographs, maps and tables to support comments that were made in the report. I have requested that this report be made available to the Planning Inspector.
The sections featured in response 11297 are:
5 . Does SLDC’s Land Allocation Document attempt to ‘air-brush’ Kents Bank out of existence as a separate community?
6. Does SLDC’s Land Allocation Document protect against coalescence between Kents Bank and Allithwaite?
7. Does SLDC's Land Allocation Document make adequate provision for capital expenditure to upgrade local roads?
Photographs, tables and maps that were included with the text in the report have been stored elsewhere, formatting that clarified the text has been removed and spurious question marks have appeared that are not in the original text.
[The full report is attached]


5 Does SLDC’s Land Allocation Document attempt to ‘air-brush’ Kents
Bank out of existence as a separate community?

5.1 SLDC’s Planning Department currently treats Kents Bank as a suburb of Grange-over-
Sands even though Kents Bank can trace its existence back to Mediaeval times when
monks from Cartmel lodged at Abbot Hall, Kents Bank, when ‘crossing the sands’
whereas Grange-over-Sands developed as a tourist resort in Victorian times after the
‘coming of the railway.

5.2 Kents Bank has its own station, Post Office, shop, Art Gallery, Abbot Hall Hotel and
Guide’s Farm. The post of Guide dates back to at least 1501 according to records of
Cartmel Priory.

5.3 During the past 20-25 years SLDC’s Planning Department have permitted infilling
development on many Kents Bank green field sites; they have allowed infilling on green
gaps between Kents Bank and Grange-over-Sands on the east, and, Kents Bank and
Allithwaite on the west.

5.4 Why is SLDC treating Kents Bank as a suburb of Grange-over-Sands? Residents of
Kents Bank do not support this view; they value their community and do not want to see
Kents Bank absorbed into Grange-over-Sands or Allithwaite. Kents Bank was
established hundreds of years before Grange-over-Sands.

5.5 This unsound approach has been perpetuated in SLDC’s Land Allocation DPD. Section
4.2 of the document is headed Grange-over-Sands and Kents Bank whereas Allithwaite
is considered as a separate community.

5.6 Subsequent text in SLDC’s Land Allocation DPD uses the name Grange-over-Sands
when it is actually referring to Kents Bank. For example paragraph 4.12 states:
“…The second major allocation is a large site on Allithwaite Road west of Kents Bank.
This is the only large site available in Grange-over-Sands…”

5.7 This is nonsense. The site referred to is MN25M; it is west of Kents Bank; it will
significantly extend Kents Bank’s western boundary and will lead to coalescence
between Kents Bank and Allithwaite if it is developed (see Map 1 and section 6).

REFER TO MAP 1 & 2 IN ATTACHED DOCUMENT

5.8 SLDC’s Land Allocation DPD gives Kents Bank similar problems with its Grange-over-
Sands boundaries; the green spaces between Grange-over-Sands and Kents Bank have
been gradually eroded over the years. If more green spaces between the two
communities are developed it will be the ‘death knell’ of Kents Bank as a separate
community (see Map 2)

5.9 It is clear from Map 2 that building on sites R110 (Trickett’s field) and R449/R74 will
erode the sense of separation between Grange-over-Sands and Kents Bank when
driving on the main road, the B5227 and that they will increase coalescence between
Grange-over-Sands and Kents Bank.

5.10 The Grange-over-Sands Regeneration Study 2007 considered site R110 (Trickett’s
field). They concluded that it should not be developed because:
“…loss of open views from street is negative…”

5.11 R449/R74 was not considered by the Grange-over-Sands Regeneration Study 2007 and its importance as a green field site has not been independently assessed. It is clear from Map 2 that development of these two sites will increase coalescence between Grangeover-Sands and Kents Bank. SLDC has provided no objective evidence to support the development of either of these green field sites.

5.12 The only green field site in Kents Bank that was considered by the Grange-over-Sands
Regeneration Study 2007 was site R89 (the Carter Road site, Berry Bank, Map 1 and
Map 2) and the report did not recommend development of R89 because of:
“…the loss of open area will be an issue…” and they concluded that
“…that residential development of the Allithwaite Road/Carter Road site is likely to be
controversial because of the ‘green field’ nature of the site…”

5.13 None of the development sites proposed for Kents Bank (Map 1), except R89, were
considered by the Grange-over-Sands Regeneration Study 2007; they have not been
independently assessed before inclusion in SLDC’s Land Allocation DPD.

SEE TABLE 4 IN ATTACHED DOCUMENT

5.14 Table 4 clearly shows that a disproportionate amount of the unsustainable housing
allocation for Grange-over-Sands has been allocated to Kents Bank (58%)

5.15 The proposed development will increase the size of Kents Bank by 40% and extend its
boundaries towards Allithwaite causing coalescence between Kents Bank and
Allithwaite; SLDC have provided no objective evidence to justify increasing the size of
Kents Bank on this scale.

5.16 All the proposed housing development sites in Kents Bank have been allocated to
desirable green field sites except for Guides Lot (17 dwellings plus employment units)
but even this site includes a small additional green field and the site is adjacent to land
on Wart Barrow that is covered by a Limestone Pavement Order.

5.17 The proposed site MN25M is particularly contentious (see section 6).

5.18 Development of all the proposed sites near Risedale Hill and in Kents Bank will have an adverse effect on local drainage in areas that are already prone to flooding after heavy
rainfall eg Allithwaite Road beyond the top of Risedale Hill, Greaves Wood Road
(Bridleway) and Kirkhead Road.

5.19 The SLDC’s Land Allocation DPD has not taken account of problems highlighted by
Kents Bank residents in the 2011 consultation exercises. For example response forms
that I submitted for sites: MN25M, R672, 350M, R79#, R82#/R347# (see Appendices 3
to 7).

5.20 Many other residents also highlighted significant problems associated with the proposed land allocations for Kents Bank. All appear to have been ignored and lumped together in groups with a comment such as ‘noted’ beside them (see section 8). Why?

Section 5: Kents Bank as a separate community;
summary of main conclusions
- Kents Bank has been a separate community since Mediaeval times.
- SLDC have provided no clear evidence to justify increasing the size of Kents
Bank by 40%.
- SLDC have provided no clear evidence to justify sanctioning developments
that will increase coalescence between Grange-over-Sands and Kents Bank.
- SLDC have provided no clear evidence to justify sanctioning developments
that will increase coalescence between Kents Bank and Allithwaite.
- The local road system, utilities and community support systems are already
inadequate; they are not robust enough to support 298 more households in
Kents Bank.

6 Does SLDC’s Land Allocation Document protect against coalescence
between Kents Bank and Allithwaite?

6.1 To be sound SLDC need to show that they have considered potential coalescence
problems between communities. SLDC’s Core Strategy states:
CS1.2 states: “…Exceptionally, new development will be permitted in the open
countryside where it has an essential requirement for a rural location, is needed to
sustain existing businesses, provides for exceptional needs for affordable housing…”

6.2 According to SLDC’s Land Allocation DPD policy Green Gap Policy LA1.9 provides:
“…A framework for maintaining the separate identities of communities by maintaining
visual and functional separation…”
The green gap between Grange-over-Sands (not Kents Bank!) and Allithwaite is
identified as one of these important green gaps (see Map 1 and Map 3). Therefore, how
can they justify building on the site south of Allithwaite Road between Kents Bank and
Allithwaite ( MN25M)without clear objective evidence that there is a genuine need for
such development?

6.3 When SLDC prepared maps in support of their Land Allocation DPD the maps were split between Allithwaite and Kents Bank so that the dramatic reduction in the green gap
between Kents Bank and Allithwaite was not immediately obvious.

6.4 The impact of the proposed development sites for Kents Bank on coalescence between
Kents Bank and Allithwaite is clearly shown on Map 1 (section 5.7) and Map 3.

SEE MAP ON ATTACHED DOCUMENT

6.5 Map 3 clearly illustrates the importance of the triangular piece of land as a green gap
between Kents Bank and Allithwaite. It also demonstrates SLDC’s poor understanding of
the boundaries between Kents Bank and Allithwaite. Currently there is only minimal
coalescence between Kents Bank and Allithwaite about a third of the way down
Kirkhead Road (see Map 3). Coalescence between the two communities will be
considerably increased if SLDC’s development proposals west of Kents Bank and south
of Allithwaite are permitted (see Map 1, section 5.7)

6.6 Appendix 5 of the Grange Fact File states:
“…Coalescence has already taken place to some degree as Kentsford Road joins Kents
Bank/Grange to the SE corner of Allithwaite…

6.7 This is nonsense! Kirkhead Road joins the south east corner of Allithwaite and the
houses at the top of Kirkhead Road are in Allithwaite (see Map 3, section 5.7). Kentsford
Road is adjacent to the railway and links Kirkhead Road and Carter; it does not form a
junction with Allithwaite Road.

6.8 The minimal coalescence between Kents Bank and Allithwaite on Kirkhead Road at
Laneside Farm is due to ribbon development in the 1930s (see Map 3, section 5.7).

6.9 The value of MN25N (the large site south of Allithwaite Road) as an important green gap
has never been independently assessed. It was not included in the Grange-over-Sands
Regenertion Study 2007 (which is supposed to have informed SLDC’s proposals for this
area) and Berry Bank (which was included was ruled out because “…loss of open area
will be an issue…” (see Map 1, section 5.7)

6.10 During the original consultation exercise SLDC was proposing an inappropriate
development of 120 residential units, plus employment units for MN25M. In spite of
widespread opposition proposals in the SLDC Land Allocation DPD nearly doubled the
number of dwellings for this site from 120 to 202 and had retained the employment units
with no objective evidence to support these proposals.

6.11 If MN25M is developed it will reduce the green gap between the communities of Kents
Bank and Allithwaite to 220 metres (site MN25M and R672) even though Section 4.22
of the SLDC Land Allocation (DPD) 2012 highlights: “…Key issues affecting
development in Allithwaite…The need to avoid coalescence with Kents Bank/Grange…”
How can SLDC justify their claim that a 220 metre gap is sufficient to avoid coalescence
between these two communities?

6.12 A significant number of local residents raised concerns about coalescence between
Kents Bank and Allithwaite during the 2011 consultation period their comments were
responded to with phrases such as “…Disagree, no proposed change it is considered
that the land does not perform a visual or functional separation and therefore does not
warrant green gap designation…” This is an outrageous description of a delightful
undulating green field site with wonderful views of Morecambe Bay that forms an
important green gap between the communities of Kents Bank and Allithwaite (see
Pictures 1 to 4).

6.13 Nor does it follow recommendations in the Grange-over-Sands Regeneration Study
2007 which stated that it was important to:
“…protect the network of green spaces and important environmental characteristics of
the town and its setting…” and
“…give priority to the use of previously developed land for development and focus on
renovation rather than demolition and new build and minimise the impact on the
environment and improve biodiversity…”

6.14 It may be significant that the land owners and developers are keen to develop this site.
On a clear day it has magnificent views of Morecambe Bay to the south and of Kirkhead
Tower to the southwest (see pictures in Table 4 below).

6.15 The land owners are so keen to see this MN25M developed that they appointed Land
Agents to liaise with SLDC Planning Department before the 2011 consultation exercise.

SEE PICTURES ON ATTACHED DOCUMENT

6.16 The complex topography of site MN25M (see Map 3) also means that drainage problems in Kents Bank will be exacerbated; a major development is likely to cause flooding in the troughs of natural undulations, as well as lower down, in southern areas of Kents Bank.

6.17 Kirkhead Road already becomes a stream bed during heavy rain; the southern end of
Greaves Wood bridleway floods during heavy rain.

6.18 Site MN25M is also an important local area for absorbing water runoff; the local drainage system does not have any ‘spare’ capacity and would need major capital investment to cope with a large-scale building development; there is no provision for this in the proposed SLDC’s land Allocation DPD.

6.19 Even a small industrial estate on this Greenfield site would have an adverse impact on
Kents Bank village, local wildlife and tourism potential.

6.20 It is inappropriate to encourage industrial development on a rural site that has been
farmed for centuries. Farming is an important local industry and part of the vernacular
landscape; this local industry should be retained for area MN25M to encourage a local
sustainable food supply and tourism.

6.21 Grange-over-Sands and the surrounding areas depend on tourism and farming;
changing the character of Kents Bank, in the way proposed, will have an adverse impact
on the tourism potential of Kents Bank.

6.22 Site MN25M is an open area that enhances the view east from Kirkhead Tower (an
ancient monument; see Picture 4) towards Grange-over-Sands; a view much admired by
visitors to the area.

6.23 MN25N is also an important wildlife corridor between Kirkhead, Greaves Wood and Wart Barrow that are all covered by Limestone Protection Orders; buzzards, kestrels and
sparrow hawks regularly hunt across this land and the woodland in the centre of the site
is a wildlife refuge.

6.24 SLDC’s response to all these adverse effects has been to state that a Development Brief will be prepared to guide development of this site even though they have not provided
clear objective evidence to show that development of this desirable and important green
field site is justified. A Development Brief will not solve the problems outlined above.

6.25 During the last 25 years SLDC have permitted:

i. Extensive infilling of green field sites in the Risedale Hill and Cardronna Road areas
of Kents Bank.

ii. The extension Kents Bank’s boundary westwards towards Allithwaite with a large
development north of Priory Lane.

iii. Extensive infilling along Priory Lane.

iv. Extensive infilling in the grounds of Kilmidyke House and Kentsford Road House.

v. Conversion of large Victorian buildings in the Kents Bank Conservation Area to
apartment blocks eg Kilmidyke House, Kentsford House, Kents Bank House and the
Kents Bank Hotel.

6.26 SLDC’s Land Allocation DPD has not justified perpetuating this policy of development
creep along the Cumbrian coast. It is time to call a halt to ensure that the communities of
Kents Bank and Allithwaite retain their integrity and do not become part of a coastal
urban sprawl that destroys the unique characteristics of Grange-over-Sands and its
surrounding area.

6.27 SLDC have provided no objective evidence to justify the need to build an additional 202
dwellings plus an unspecified number of employment units on the important green field
site between Kents Bank and Allithwaite.

Section 6: Coalescence between Kents Bank and Allithwaite;
summary of main conclusions
- SLDC have not justified reducing the boundary between Kents Bank and
Allithwaite to 220 metres.
- Development of sites MN25M and R672 will extend the boundaries of Kents
Bank towards Allithwaite; both will encroach onto open fell pastures that are
an important back-drop to Grange-over-Sands and district.
- SLDC has provided no clear evidence to justify building on these important
green field site between Kents Bank and Allithwaite.
- SLDC have not taken account of the impact of their land development
proposals on the natural drainage problems in Kents Bank.
- Such intensive development will disrupt an important wildlife corridor linking
Kirkhead, Greaves Wood and Wart Barrow; all areas of land that are covered
by Limestone Pavement Orders.
- A development Brief for MN25M will not be able to solve the fundamental
problem of coalescence between Kents Bank and Allithwaite caused by
development of this site.
- SLDC has a duty to ensure that the communities of Kents Bank and
Allithwaite retain their integrity and do not become part of a coastal urban
sprawl that destroys the unique characteristics of Grange-over-Sands and its
surrounding area.


7 Does SLDC’s Land Allocation Document make adequate provision for
capital expenditure to upgrade local roads?

7.1 Allithwaite Road (B5277) is already inadequate for the amount of traffic regularly
travelling between Grange-over-Sands, Allithwaite, Flookburgh, Holker Hall, Kendal,
Lancaster and the M6.

7.2 The traffic problem is exacerbated when regular events such as Cartmel Races and
the Holker Garden Festival attract large crowds.

7.3 The stretch of Allithwaite Road between Kents Bank and Allithwaite from the top of
Risedale Hill is a fast stretch of undulating road that poses sight line problems for
drivers (see picture 3, section 6.15).

7.4 Developers would be forced to create new roads for development area MN25M linking
onto Allithwaite Road; this would increase traffic hazards on Allithwaite Road, or, lead
to the creation of an intrusive roundabout system that would destroy the rural nature
of this road and area

7.5 Greaves Wood Road bridleway forms the eastern, and southern, boundaries of
MN25M; it could not be used as access to MN25M development area because of a)
the Protected Limestone Pavement in Greaves Wood and b) it is a popular pedestrian
route for local residents, especially dog walkers (see Map 1, section 5.7 and Map 3,
section 6.4).

7.6 Access from Kirkhead Road to the MN25M development area is not practical; there
are no suitable gaps between the houses whose back gardens form the western
boundary of MN25M.

7.7 Industrial development and 202 residential units will generate a large amount of extra
traffic in Kents Bank that will all need to drive through Grange-over-Sands to reach the
A590 for access to Kendal, Lancaster and the M6; the local road system is not
suitable for this.

7.8 Local roads are not adequate to accommodate service vehicles for industrial
development.

SEE PICTURES IN ATTACHED DOCUMENT

7.9 SLDC are also proposing to build dwellings on the land behind the lorry on Allithwaite
Road (picture 6) and on the left hand side of Allithwaite Road beyond the junction of
Allithwaite Road with Jack Hill (junction to the left of Kirkhead Road; picture 6); access
to both these sites is constrained by their location and will cause road safety
problems.

7.10 Picture 5 clearly shows that it is not possible to widen or straighten Risedale Hill
without major road works involving compulsory purchase orders, demolition of walls
and completely altering the character of this part of Kents Bank and that the road is
not suitable for large volumes of traffic.

7.11 Traffic from three other nearby proposed residential developments in Kents Bank,
R672M: 36 residential units & R89: 45 residential units, R350M: 17 houses, also link
to Allithwaite Road, near the top of Risedale Hill therefore they should also be taken
into account when undertaking an area traffic impact study (see Map 1, section 5.7);
as should traffic generated by all residential and employment developments west of
Risedale Hill in Allithwaite and Flookburgh.

7.12 Once the traffic has negotiated Risedale Hill it then has to negotiate Main Street hill in
Grange-over-Sands another bottleneck that is often made worse by delivery vehicles
for the local shops because none of the shops on this part of Main Street have rear
access,

7.13 The local roads are in a poor state of repair and are not suitable for this level of traffic
increase.

7.14 SLDC have made no provision for improving these roads and have not justified a
need for developments that will make the traffic conditions considerably worse and
deter tourists.

7.15 There is no viable route for a Grange-over-Sands by-pass. A new trunk road to the
A590 would have to be routed across rough pastureland to the north of Grange-over-
Sands and would impinge on classic views of Cartmel and Cartmel Priory.

7.16 Car parking in Grange-over-Sands is already inadequate for local residents shopping
and tourists and again, no provision has been made in SLDC’s Land Allocation DPD
to improve local car parking facilities.

Section 7: Inadequate local roads in Grange-over-Sands and District;
summary of main conclusions
- The roads in Grange-over-Sands and district are already inadequate for the
traffic that they carry.
- There are two major bottlenecks: Risedale Hill and Main Street Hill that
cannot be widened due to their location.
- It would be expensive and difficult to agree a route for a new trunk road to the
A590 that by-passed Grange-over-Sands.
- SLDC have not made any provision to upgrade roads in Grange-over-Sands
and district.
- SLDC have not provided objective evidence to justify proposing large
development to the west of Grange-over-Sands given the already inadequate
road system.

I do not support SLDC’s Land Allocation DPD

YES, I wish to participate at the oral examination

I wish to take part in the oral examination because SLDC have not made an adequate response to significant planning concerns, raised by local residents, during earlier consultation phases, particularly those relating to:
1. ‘Housing need’ in the Grange-over-Sands area.
2. Proposed green field site land allocations for the Grange-over-Sands area.
3. The adverse impact of the proposed developments on tourism, the life-blood of Grange-over-Sands and the Cartmel Peninsula.
4. The inadequate road system that links Grange-over-Sands to other SLDC Service Centres.
In addition, SLDC have not provided objective evidence that justifies their classification of Grange-over-Sands as an SLDC Key Service Centre. Grange-over-Sands does not meet SLDC’s Core Strategy Document definition of Key Service Centre: it does not have a secondary school and it is not directly linked to other SLDC Service Centres by a main trunk road.
Nor does the SLDC Land Allocation DPD take account of local residents’ wishes about how their community should be developed, or the views of Grange-over-Sands Town Council.

Please notify me

LA1.3 Housing Allocations - RN79#-mod ALLITHWAITE LAND NORTH OF JACK HILL

No

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. SLDC should not include Grange-over-Sands as one of its Key Service Centres because it does not meet the criteria in CS1.2 The development strategy for Principal Service Centres, Key Service Centres and Local Service Centres. This would mean that the number of proposed developments in Grange-over-Sands and district should be reduced and all proposed development sites should be reassessed. Development of brown field sites, such as Berners, should be prioritised and SLDC should take account of the views of local residents and Grange-over-Sands Town Council.
2. SLDC have not followed Government guidance about the use and interpretation of household surveys. They have not provided objective evidence to justify ‘housing need for Grange-over-Sands and District.
3. SLDC should be required to produce objective evidence to justify their plans to allow Grange-over-Sands to develop into a coastal urban sprawl incorporating Kents Bank.
4. SLDC should be required to remove sites MN25N, R672 and R79# from their Land Development DPD because development of these sites will lead to coalescence between the communities of Kents Bank and Allithwaite.
5. SLDC should be required to remove sites R449, R74 and R110 from their Land Development DPD because development of these sites will lead to further coalescence between the communities of Grange-over-Sands and Kents Bank.
6. SLDC should be required to produce clear evidence about how their proposed developments will enhance tourism in Grange-over-Sands and district.
7. SLDC should be required to explain why they have ignored recommendations made about green field sites and tourism in the Grange-over-Sands Regeneration Study (Douglas Wheeler Associates, November 2007), that they claim has informed SLDC's Core Strategy.
8. SLDC should be required to provide objective evidence that the local roads are adequate to support the proposed increase in population and traffic in Grange-over-Sands especially for known bottle-necks in Main Street and on Risedale Hill.
9. SLDC should not allow any development on prime green field land between Kents Bank and Allithwaite because it will lead to coalescence between these two separate communities.

I do not support SLDC’s Land Allocations DPD because it is based on spurious ‘housing need’ targets and has unnecessarily ear-marked important greenfield sites for development.

No

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 following text of response 11298 is taken from sections 5 and 7 of my SLDC LDF consultation submission entitled: ‘Soundness’ response to SLDC’s Land Allocation Development Plan (DPD, Jan 2012) focussing on SLDC’s ‘housing need’ predictions & SLDC’s vision for Grange-over-Sands and District.
My report included photographs, maps and tables to support comments that were made in the report. I have requested that this report be made available to the Planning Inspector.
The sections featured in response 11298 are:
5 . Does SLDC’s Land Allocation Document attempt to ‘air-brush’ Kents Bank out of existence as a separate community?
7. Does SLDC's Land Allocation Document make adequate provision for capital expenditure to upgrade local roads?
Photographs, tables and maps that were included with the text in the report have been stored elsewhere, formatting that clarified the text has been removed and spurious question marks have appeared that are not in the original text
[The full report is attached]

5 Does SLDC’s Land Allocation Document attempt to ‘air-brush’ Kents
Bank out of existence as a separate community?

5.1 SLDC’s Planning Department currently treats Kents Bank as a suburb of Grange-over-
Sands even though Kents Bank can trace its existence back to Mediaeval times when
monks from Cartmel lodged at Abbot Hall, Kents Bank, when ‘crossing the sands’
whereas Grange-over-Sands developed as a tourist resort in Victorian times after the
‘coming of the railway.

5.2 Kents Bank has its own station, Post Office, shop, Art Gallery, Abbot Hall Hotel and
Guide’s Farm. The post of Guide dates back to at least 1501 according to records of
Cartmel Priory.

5.3 During the past 20-25 years SLDC’s Planning Department have permitted infilling
development on many Kents Bank green field sites; they have allowed infilling on green
gaps between Kents Bank and Grange-over-Sands on the east, and, Kents Bank and
Allithwaite on the west.

5.4 Why is SLDC treating Kents Bank as a suburb of Grange-over-Sands? Residents of
Kents Bank do not support this view; they value their community and do not want to see
Kents Bank absorbed into Grange-over-Sands or Allithwaite. Kents Bank was
established hundreds of years before Grange-over-Sands.

5.5 This unsound approach has been perpetuated in SLDC’s Land Allocation DPD. Section
4.2 of the document is headed Grange-over-Sands and Kents Bank whereas Allithwaite
is considered as a separate community.

5.6 Subsequent text in SLDC’s Land Allocation DPD uses the name Grange-over-Sands
when it is actually referring to Kents Bank. For example paragraph 4.12 states:
“…The second major allocation is a large site on Allithwaite Road west of Kents Bank.
This is the only large site available in Grange-over-Sands…”

5.7 This is nonsense. The site referred to is MN25M; it is west of Kents Bank; it will
significantly extend Kents Bank’s western boundary and will lead to coalescence
between Kents Bank and Allithwaite if it is developed (see Map 1 and section 6).

REFER TO MAP 1 & 2 IN ATTACHED DOCUMENT

5.8 SLDC’s Land Allocation DPD gives Kents Bank similar problems with its Grange-over-
Sands boundaries; the green spaces between Grange-over-Sands and Kents Bank have
been gradually eroded over the years. If more green spaces between the two
communities are developed it will be the ‘death knell’ of Kents Bank as a separate
community (see Map 2)

5.9 It is clear from Map 2 that building on sites R110 (Trickett’s field) and R449/R74 will
erode the sense of separation between Grange-over-Sands and Kents Bank when
driving on the main road, the B5227 and that they will increase coalescence between
Grange-over-Sands and Kents Bank.

5.10 The Grange-over-Sands Regeneration Study 2007 considered site R110 (Trickett’s
field). They concluded that it should not be developed because:
“…loss of open views from street is negative…”

5.11 R449/R74 was not considered by the Grange-over-Sands Regeneration Study 2007 and its importance as a green field site has not been independently assessed. It is clear from Map 2 that development of these two sites will increase coalescence between Grangeover-Sands and Kents Bank. SLDC has provided no objective evidence to support the development of either of these green field sites.

5.12 The only green field site in Kents Bank that was considered by the Grange-over-Sands
Regeneration Study 2007 was site R89 (the Carter Road site, Berry Bank, Map 1 and
Map 2) and the report did not recommend development of R89 because of:
“…the loss of open area will be an issue…” and they concluded that
“…that residential development of the Allithwaite Road/Carter Road site is likely to be
controversial because of the ‘green field’ nature of the site…”

5.13 None of the development sites proposed for Kents Bank (Map 1), except R89, were
considered by the Grange-over-Sands Regeneration Study 2007; they have not been
independently assessed before inclusion in SLDC’s Land Allocation DPD.

SEE TABLE 4 IN ATTACHED DOCUMENT

5.14 Table 4 clearly shows that a disproportionate amount of the unsustainable housing
allocation for Grange-over-Sands has been allocated to Kents Bank (58%)

5.15 The proposed development will increase the size of Kents Bank by 40% and extend its
boundaries towards Allithwaite causing coalescence between Kents Bank and
Allithwaite; SLDC have provided no objective evidence to justify increasing the size of
Kents Bank on this scale.

5.16 All the proposed housing development sites in Kents Bank have been allocated to
desirable green field sites except for Guides Lot (17 dwellings plus employment units)
but even this site includes a small additional green field and the site is adjacent to land
on Wart Barrow that is covered by a Limestone Pavement Order.

5.17 The proposed site MN25M is particularly contentious (see section 6).

5.18 Development of all the proposed sites near Risedale Hill and in Kents Bank will have an adverse effect on local drainage in areas that are already prone to flooding after heavy
rainfall eg Allithwaite Road beyond the top of Risedale Hill, Greaves Wood Road
(Bridleway) and Kirkhead Road.

5.19 The SLDC’s Land Allocation DPD has not taken account of problems highlighted by
Kents Bank residents in the 2011 consultation exercises. For example response forms
that I submitted for sites: MN25M, R672, 350M, R79#, R82#/R347# (see Appendices 3
to 7).

5.20 Many other residents also highlighted significant problems associated with the proposed land allocations for Kents Bank. All appear to have been ignored and lumped together in groups with a comment such as ‘noted’ beside them (see section 8). Why?

Section 5: Kents Bank as a separate community;
summary of main conclusions
- Kents Bank has been a separate community since Mediaeval times.
- SLDC have provided no clear evidence to justify increasing the size of Kents
Bank by 40%.
- SLDC have provided no clear evidence to justify sanctioning developments
that will increase coalescence between Grange-over-Sands and Kents Bank.
- SLDC have provided no clear evidence to justify sanctioning developments
that will increase coalescence between Kents Bank and Allithwaite.
- The local road system, utilities and community support systems are already
inadequate; they are not robust enough to support 298 more households in
Kents Bank.

7 Does SLDC’s Land Allocation Document make adequate provision for
capital expenditure to upgrade local roads?

7.1 Allithwaite Road (B5277) is already inadequate for the amount of traffic regularly
travelling between Grange-over-Sands, Allithwaite, Flookburgh, Holker Hall, Kendal,
Lancaster and the M6.

7.2 The traffic problem is exacerbated when regular events such as Cartmel Races and
the Holker Garden Festival attract large crowds.

7.3 The stretch of Allithwaite Road between Kents Bank and Allithwaite from the top of
Risedale Hill is a fast stretch of undulating road that poses sight line problems for
drivers (see picture 3, section 6.15).

7.4 Developers would be forced to create new roads for development area MN25M linking
onto Allithwaite Road; this would increase traffic hazards on Allithwaite Road, or, lead
to the creation of an intrusive roundabout system that would destroy the rural nature
of this road and area

7.5 Greaves Wood Road bridleway forms the eastern, and southern, boundaries of
MN25M; it could not be used as access to MN25M development area because of a)
the Protected Limestone Pavement in Greaves Wood and b) it is a popular pedestrian
route for local residents, especially dog walkers (see Map 1, section 5.7 and Map 3,
section 6.4).

7.6 Access from Kirkhead Road to the MN25M development area is not practical; there
are no suitable gaps between the houses whose back gardens form the western
boundary of MN25M.

7.7 Industrial development and 202 residential units will generate a large amount of extra
traffic in Kents Bank that will all need to drive through Grange-over-Sands to reach the
A590 for access to Kendal, Lancaster and the M6; the local road system is not
suitable for this.

7.8 Local roads are not adequate to accommodate service vehicles for industrial
development.

SEE PICTURES IN ATTACHED DOCUMENT

7.9 SLDC are also proposing to build dwellings on the land behind the lorry on Allithwaite
Road (picture 6) and on the left hand side of Allithwaite Road beyond the junction of
Allithwaite Road with Jack Hill (junction to the left of Kirkhead Road; picture 6); access
to both these sites is constrained by their location and will cause road safety
problems.

7.10 Picture 5 clearly shows that it is not possible to widen or straighten Risedale Hill
without major road works involving compulsory purchase orders, demolition of walls
and completely altering the character of this part of Kents Bank and that the road is
not suitable for large volumes of traffic.

7.11 Traffic from three other nearby proposed residential developments in Kents Bank,
R672M: 36 residential units & R89: 45 residential units, R350M: 17 houses, also link
to Allithwaite Road, near the top of Risedale Hill therefore they should also be taken
into account when undertaking an area traffic impact study (see Map 1, section 5.7);
as should traffic generated by all residential and employment developments west of
Risedale Hill in Allithwaite and Flookburgh.

7.12 Once the traffic has negotiated Risedale Hill it then has to negotiate Main Street hill in
Grange-over-Sands another bottleneck that is often made worse by delivery vehicles
for the local shops because none of the shops on this part of Main Street have rear
access,

7.13 The local roads are in a poor state of repair and are not suitable for this level of traffic
increase.

7.14 SLDC have made no provision for improving these roads and have not justified a
need for developments that will make the traffic conditions considerably worse and
deter tourists.

7.15 There is no viable route for a Grange-over-Sands by-pass. A new trunk road to the
A590 would have to be routed across rough pastureland to the north of Grange-over-
Sands and would impinge on classic views of Cartmel and Cartmel Priory.

7.16 Car parking in Grange-over-Sands is already inadequate for local residents shopping
and tourists and again, no provision has been made in SLDC’s Land Allocation DPD
to improve local car parking facilities.

Section 7: Inadequate local roads in Grange-over-Sands and District;
summary of main conclusions
- The roads in Grange-over-Sands and district are already inadequate for the
traffic that they carry.
- There are two major bottlenecks: Risedale Hill and Main Street Hill that
cannot be widened due to their location.
- It would be expensive and difficult to agree a route for a new trunk road to the
A590 that by-passed Grange-over-Sands.
- SLDC have not made any provision to upgrade roads in Grange-over-Sands
and district.
- SLDC have not provided objective evidence to justify proposing large
development to the west of Grange-over-Sands given the already inadequate
road system.

I do not support SLDC’s Land Allocation DPD

YES, I wish to participate at the oral examination

I wish to take part in the oral examination because SLDC have not made an adequate response to significant planning concerns, raised by local residents, during earlier consultation phases, particularly those relating to:
1. ‘Housing need’ in the Grange-over-Sands area.
2. Proposed green field site land allocations for the Grange-over-Sands area.
3. The adverse impact of the proposed developments on tourism, the life-blood of Grange-over-Sands and the Cartmel Peninsula.
4. The inadequate road system that links Grange-over-Sands to other SLDC Service Centres.
In addition, SLDC have not provided objective evidence that justifies their classification of Grange-over-Sands as an SLDC Key Service Centre. Grange-over-Sands does not meet SLDC’s Core Strategy Document definition of Key Service Centre: it does not have a secondary school and it is not directly linked to other SLDC Service Centres by a main trunk road.
Nor does the SLDC Land Allocation DPD take account of local residents’ wishes about how their community should be developed, or the views of Grange-over-Sands Town Council.

Please notify me

LA1.3 Housing Allocations - R347# ALLITHWAITE LAND REAR OF BANKFIELD

No

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. SLDC should not include Grange-over-Sands as one of its Key Service Centres because it does not meet the criteria in CS1.2 The development strategy for Principal Service Centres, Key Service Centres and Local Service Centres. This would mean that the number of proposed developments in Grange-over-Sands and district should be reduced and all proposed development sites should be reassessed. Development of brown field sites, such as Berners, should be prioritised and SLDC should take account of the views of local residents and Grange-over-Sands Town Council.
2. SLDC have not followed Government guidance about the use and interpretation of household surveys. They have not provided objective evidence to justify ‘housing need for Grange-over-Sands and District.
3. SLDC should be required to produce objective evidence to justify their plans to allow Grange-over-Sands to develop into a coastal urban sprawl incorporating Kents Bank.
4. SLDC should be required to remove sites MN25N, R672 and R79# from their Land Development DPD because development of these sites will lead to coalescence between the communities of Kents Bank and Allithwaite.
5. SLDC should be required to remove sites R449, R74 and R110 from their Land Development DPD because development of these sites will lead to further coalescence between the communities of Grange-over-Sands and Kents Bank.
6. SLDC should be required to produce clear evidence about how their proposed developments will enhance tourism in Grange-over-Sands and district.
7. SLDC should be required to explain why they have ignored recommendations made about green field sites and tourism in the Grange-over-Sands Regeneration Study (Douglas Wheeler Associates, November 2007), that they claim has informed SLDC's Core Strategy.
8. SLDC should be required to provide objective evidence that the local roads are adequate to support the proposed increase in population and traffic in Grange-over-Sands especially for known bottle-necks in Main Street and on Risedale Hill.
9. SLDC should not allow any development on prime green field land between Kents Bank and Allithwaite because it will lead to coalescence between these two separate communities.

I do not support SLDC’s Land Allocations DPD because it is based on spurious ‘housing need’ targets and has unnecessarily ear-marked important greenfield sites for development.

No

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 following text of response 11292 is taken from sections 4, 5, 6 and 7 of my SLDC LDF consultation submission entitled: ‘Soundness’ response to SLDC’s Land Allocation Development Plan (DPD, Jan 2012) focussing on SLDC’s ‘housing need’ predictions & SLDC’s vision for Grange-over-Sands and District.
My report included photographs, maps and tables to support comments that were made in the report. I have requested that this report be made available to the Planning Inspector.
The sections featured in response 11292 are:
5 . Does SLDC’s Land Allocation Document attempt to ‘air-brush’ Kents Bank out of existence as a separate community?
Photographs, tables and maps that were included with the text in the report have been stored elsewhere, formatting that clarified the text has been removed and spurious question marks have appeared that are not in the original text.
[The full report is attached]

5 Does SLDC’s Land Allocation Document attempt to ‘air-brush’ Kents
Bank out of existence as a separate community?

5.1 SLDC’s Planning Department currently treats Kents Bank as a suburb of Grange-over-
Sands even though Kents Bank can trace its existence back to Mediaeval times when
monks from Cartmel lodged at Abbot Hall, Kents Bank, when ‘crossing the sands’
whereas Grange-over-Sands developed as a tourist resort in Victorian times after the
‘coming of the railway.

5.2 Kents Bank has its own station, Post Office, shop, Art Gallery, Abbot Hall Hotel and
Guide’s Farm. The post of Guide dates back to at least 1501 according to records of
Cartmel Priory.

5.3 During the past 20-25 years SLDC’s Planning Department have permitted infilling
development on many Kents Bank green field sites; they have allowed infilling on green
gaps between Kents Bank and Grange-over-Sands on the east, and, Kents Bank and
Allithwaite on the west.

5.4 Why is SLDC treating Kents Bank as a suburb of Grange-over-Sands? Residents of
Kents Bank do not support this view; they value their community and do not want to see
Kents Bank absorbed into Grange-over-Sands or Allithwaite. Kents Bank was
established hundreds of years before Grange-over-Sands.

5.5 This unsound approach has been perpetuated in SLDC’s Land Allocation DPD. Section
4.2 of the document is headed Grange-over-Sands and Kents Bank whereas Allithwaite
is considered as a separate community.

5.6 Subsequent text in SLDC’s Land Allocation DPD uses the name Grange-over-Sands
when it is actually referring to Kents Bank. For example paragraph 4.12 states:
“…The second major allocation is a large site on Allithwaite Road west of Kents Bank.
This is the only large site available in Grange-over-Sands…”

5.7 This is nonsense. The site referred to is MN25M; it is west of Kents Bank; it will
significantly extend Kents Bank’s western boundary and will lead to coalescence
between Kents Bank and Allithwaite if it is developed (see Map 1 and section 6).

REFER TO MAP 1 & 2 IN ATTACHED DOCUMENT

5.8 SLDC’s Land Allocation DPD gives Kents Bank similar problems with its Grange-over-
Sands boundaries; the green spaces between Grange-over-Sands and Kents Bank have
been gradually eroded over the years. If more green spaces between the two
communities are developed it will be the ‘death knell’ of Kents Bank as a separate
community (see Map 2)

5.9 It is clear from Map 2 that building on sites R110 (Trickett’s field) and R449/R74 will
erode the sense of separation between Grange-over-Sands and Kents Bank when
driving on the main road, the B5227 and that they will increase coalescence between
Grange-over-Sands and Kents Bank.

5.10 The Grange-over-Sands Regeneration Study 2007 considered site R110 (Trickett’s
field). They concluded that it should not be developed because:
“…loss of open views from street is negative…”

5.11 R449/R74 was not considered by the Grange-over-Sands Regeneration Study 2007 and its importance as a green field site has not been independently assessed. It is clear from Map 2 that development of these two sites will increase coalescence between Grangeover-Sands and Kents Bank. SLDC has provided no objective evidence to support the development of either of these green field sites.

5.12 The only green field site in Kents Bank that was considered by the Grange-over-Sands
Regeneration Study 2007 was site R89 (the Carter Road site, Berry Bank, Map 1 and
Map 2) and the report did not recommend development of R89 because of:
“…the loss of open area will be an issue…” and they concluded that
“…that residential development of the Allithwaite Road/Carter Road site is likely to be
controversial because of the ‘green field’ nature of the site…”

5.13 None of the development sites proposed for Kents Bank (Map 1), except R89, were
considered by the Grange-over-Sands Regeneration Study 2007; they have not been
independently assessed before inclusion in SLDC’s Land Allocation DPD.

SEE TABLE 4 IN ATTACHED DOCUMENT

5.14 Table 4 clearly shows that a disproportionate amount of the unsustainable housing
allocation for Grange-over-Sands has been allocated to Kents Bank (58%)

5.15 The proposed development will increase the size of Kents Bank by 40% and extend its
boundaries towards Allithwaite causing coalescence between Kents Bank and
Allithwaite; SLDC have provided no objective evidence to justify increasing the size of
Kents Bank on this scale.

5.16 All the proposed housing development sites in Kents Bank have been allocated to
desirable green field sites except for Guides Lot (17 dwellings plus employment units)
but even this site includes a small additional green field and the site is adjacent to land
on Wart Barrow that is covered by a Limestone Pavement Order.

5.17 The proposed site MN25M is particularly contentious (see section 6).

5.18 Development of all the proposed sites near Risedale Hill and in Kents Bank will have an adverse effect on local drainage in areas that are already prone to flooding after heavy
rainfall eg Allithwaite Road beyond the top of Risedale Hill, Greaves Wood Road
(Bridleway) and Kirkhead Road.

5.19 The SLDC’s Land Allocation DPD has not taken account of problems highlighted by
Kents Bank residents in the 2011 consultation exercises. For example response forms
that I submitted for sites: MN25M, R672, 350M, R79#, R82#/R347# (see Appendices 3
to 7).

5.20 Many other residents also highlighted significant problems associated with the proposed land allocations for Kents Bank. All appear to have been ignored and lumped together in groups with a comment such as ‘noted’ beside them (see section 8). Why?

Section 5: Kents Bank as a separate community;
summary of main conclusions
- Kents Bank has been a separate community since Mediaeval times.
- SLDC have provided no clear evidence to justify increasing the size of Kents
Bank by 40%.
- SLDC have provided no clear evidence to justify sanctioning developments
that will increase coalescence between Grange-over-Sands and Kents Bank.
- SLDC have provided no clear evidence to justify sanctioning developments
that will increase coalescence between Kents Bank and Allithwaite.
- The local road system, utilities and community support systems are already
inadequate; they are not robust enough to support 298 more households in
Kents Bank.

I do not support SLDC’s Land Allocation DPD

YES, I wish to participate at the oral examination

I wish to take part in the oral examination because SLDC have not made an adequate response to significant planning concerns, raised by local residents, during earlier consultation phases, particularly those relating to:
1. ‘Housing need’ in the Grange-over-Sands area.
2. Proposed green field site land allocations for the Grange-over-Sands area.
3. The adverse impact of the proposed developments on tourism, the life-blood of Grange-over-Sands and the Cartmel Peninsula.
4. The inadequate road system that links Grange-over-Sands to other SLDC Service Centres.
In addition, SLDC have not provided objective evidence that justifies their classification of Grange-over-Sands as an SLDC Key Service Centre. Grange-over-Sands does not meet SLDC’s Core Strategy Document definition of Key Service Centre: it does not have a secondary school and it is not directly linked to other SLDC Service Centres by a main trunk road.
Nor does the SLDC Land Allocation DPD take account of local residents’ wishes about how their community should be developed, or the views of Grange-over-Sands Town Council.

Please notify me

LA1.3 Housing Allocations - RN265# ALLITHWAITE LAND WEST OF BRACKEN EDGE

No

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. SLDC should not include Grange-over-Sands as one of its Key Service Centres because it does not meet the criteria in CS1.2 The development strategy for Principal Service Centres, Key Service Centres and Local Service Centres. This would mean that the number of proposed developments in Grange-over-Sands and district should be reduced and all proposed development sites should be reassessed. Development of brown field sites, such as Berners, should be prioritised and SLDC should take account of the views of local residents and Grange-over-Sands Town Council.
2. SLDC have not followed Government guidance about the use and interpretation of household surveys. They have not provided objective evidence to justify ‘housing need for Grange-over-Sands and District.
3. SLDC should be required to produce objective evidence to justify their plans to allow Grange-over-Sands to develop into a coastal urban sprawl incorporating Kents Bank.
4. SLDC should be required to remove sites MN25N, R672 and R79# from their Land Development DPD because development of these sites will lead to coalescence between the communities of Kents Bank and Allithwaite.
5. SLDC should be required to remove sites R449, R74 and R110 from their Land Development DPD because development of these sites will lead to further coalescence between the communities of Grange-over-Sands and Kents Bank.
6. SLDC should be required to produce clear evidence about how their proposed developments will enhance tourism in Grange-over-Sands and district.
7. SLDC should be required to explain why they have ignored recommendations made about green field sites and tourism in the Grange-over-Sands Regeneration Study (Douglas Wheeler Associates, November 2007), that they claim has informed SLDC's Core Strategy.
8. SLDC should be required to provide objective evidence that the local roads are adequate to support the proposed increase in population and traffic in Grange-over-Sands especially for known bottle-necks in Main Street and on Risedale Hill.
9. SLDC should not allow any development on prime green field land between Kents Bank and Allithwaite because it will lead to coalescence between these two separate communities.

I do not support SLDC’s Land Allocations DPD because it is based on spurious ‘housing need’ targets and has unnecessarily ear-marked important greenfield sites for development.

No

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 following text of response 11301 is taken from sections 5 of my SLDC LDF consultation submission entitled: ‘Soundness’ response to SLDC’s Land Allocation Development Plan (DPD, Jan 2012) focussing on SLDC’s ‘housing need’ predictions & SLDC’s vision for Grange-over-Sands and District.
My report included photographs, maps and tables to support comments that were made in the report. I have requested that this report be made available to the Planning Inspector.
The section featured in response 11301 is:
5 . Does SLDC’s Land Allocation Document attempt to ‘air-brush’ Kents Bank out of existence as a separate community?

Photographs, tables and maps that were included with the text in the report have been stored elsewhere, formatting that clarified the text has been removed and spurious question marks have appeared that are not in the original text
[The full report is attached]


5 Does SLDC’s Land Allocation Document attempt to ‘air-brush’ Kents
Bank out of existence as a separate community?

5.1 SLDC’s Planning Department currently treats Kents Bank as a suburb of Grange-over-
Sands even though Kents Bank can trace its existence back to Mediaeval times when
monks from Cartmel lodged at Abbot Hall, Kents Bank, when ‘crossing the sands’
whereas Grange-over-Sands developed as a tourist resort in Victorian times after the
‘coming of the railway.

5.2 Kents Bank has its own station, Post Office, shop, Art Gallery, Abbot Hall Hotel and
Guide’s Farm. The post of Guide dates back to at least 1501 according to records of
Cartmel Priory.

5.3 During the past 20-25 years SLDC’s Planning Department have permitted infilling
development on many Kents Bank green field sites; they have allowed infilling on green
gaps between Kents Bank and Grange-over-Sands on the east, and, Kents Bank and
Allithwaite on the west.

5.4 Why is SLDC treating Kents Bank as a suburb of Grange-over-Sands? Residents of
Kents Bank do not support this view; they value their community and do not want to see
Kents Bank absorbed into Grange-over-Sands or Allithwaite. Kents Bank was
established hundreds of years before Grange-over-Sands.

5.5 This unsound approach has been perpetuated in SLDC’s Land Allocation DPD. Section
4.2 of the document is headed Grange-over-Sands and Kents Bank whereas Allithwaite
is considered as a separate community.

5.6 Subsequent text in SLDC’s Land Allocation DPD uses the name Grange-over-Sands
when it is actually referring to Kents Bank. For example paragraph 4.12 states:
“…The second major allocation is a large site on Allithwaite Road west of Kents Bank.
This is the only large site available in Grange-over-Sands…”

5.7 This is nonsense. The site referred to is MN25M; it is west of Kents Bank; it will
significantly extend Kents Bank’s western boundary and will lead to coalescence
between Kents Bank and Allithwaite if it is developed (see Map 1 and section 6).

REFER TO MAP 1 & 2 IN ATTACHED DOCUMENT

5.8 SLDC’s Land Allocation DPD gives Kents Bank similar problems with its Grange-over-
Sands boundaries; the green spaces between Grange-over-Sands and Kents Bank have
been gradually eroded over the years. If more green spaces between the two
communities are developed it will be the ‘death knell’ of Kents Bank as a separate
community (see Map 2)

5.9 It is clear from Map 2 that building on sites R110 (Trickett’s field) and R449/R74 will
erode the sense of separation between Grange-over-Sands and Kents Bank when
driving on the main road, the B5227 and that they will increase coalescence between
Grange-over-Sands and Kents Bank.

5.10 The Grange-over-Sands Regeneration Study 2007 considered site R110 (Trickett’s
field). They concluded that it should not be developed because:
“…loss of open views from street is negative…”

5.11 R449/R74 was not considered by the Grange-over-Sands Regeneration Study 2007 and its importance as a green field site has not been independently assessed. It is clear from Map 2 that development of these two sites will increase coalescence between Grangeover-Sands and Kents Bank. SLDC has provided no objective evidence to support the development of either of these green field sites.

5.12 The only green field site in Kents Bank that was considered by the Grange-over-Sands
Regeneration Study 2007 was site R89 (the Carter Road site, Berry Bank, Map 1 and
Map 2) and the report did not recommend development of R89 because of:
“…the loss of open area will be an issue…” and they concluded that
“…that residential development of the Allithwaite Road/Carter Road site is likely to be
controversial because of the ‘green field’ nature of the site…”

5.13 None of the development sites proposed for Kents Bank (Map 1), except R89, were
considered by the Grange-over-Sands Regeneration Study 2007; they have not been
independently assessed before inclusion in SLDC’s Land Allocation DPD.

SEE TABLE 4 IN ATTACHED DOCUMENT

5.14 Table 4 clearly shows that a disproportionate amount of the unsustainable housing
allocation for Grange-over-Sands has been allocated to Kents Bank (58%)

5.15 The proposed development will increase the size of Kents Bank by 40% and extend its
boundaries towards Allithwaite causing coalescence between Kents Bank and
Allithwaite; SLDC have provided no objective evidence to justify increasing the size of
Kents Bank on this scale.

5.16 All the proposed housing development sites in Kents Bank have been allocated to
desirable green field sites except for Guides Lot (17 dwellings plus employment units)
but even this site includes a small additional green field and the site is adjacent to land
on Wart Barrow that is covered by a Limestone Pavement Order.

5.17 The proposed site MN25M is particularly contentious (see section 6).

5.18 Development of all the proposed sites near Risedale Hill and in Kents Bank will have an adverse effect on local drainage in areas that are already prone to flooding after heavy
rainfall eg Allithwaite Road beyond the top of Risedale Hill, Greaves Wood Road
(Bridleway) and Kirkhead Road.

5.19 The SLDC’s Land Allocation DPD has not taken account of problems highlighted by
Kents Bank residents in the 2011 consultation exercises. For example response forms
that I submitted for sites: MN25M, R672, 350M, R79#, R82#/R347# (see Appendices 3
to 7).

5.20 Many other residents also highlighted significant problems associated with the proposed land allocations for Kents Bank. All appear to have been ignored and lumped together in groups with a comment such as ‘noted’ beside them (see section 8). Why?

Section 5: Kents Bank as a separate community;
summary of main conclusions
- Kents Bank has been a separate community since Mediaeval times.
- SLDC have provided no clear evidence to justify increasing the size of Kents
Bank by 40%.
- SLDC have provided no clear evidence to justify sanctioning developments
that will increase coalescence between Grange-over-Sands and Kents Bank.
- SLDC have provided no clear evidence to justify sanctioning developments
that will increase coalescence between Kents Bank and Allithwaite.
- The local road system, utilities and community support systems are already
inadequate; they are not robust enough to support 298 more households in
Kents Bank.

I do not support SLDC’s Land Allocation DPD

YES, I wish to participate at the oral examination

I wish to take part in the oral examination because SLDC have not made an adequate response to significant planning concerns, raised by local residents, during earlier consultation phases, particularly those relating to:
1. ‘Housing need’ in the Grange-over-Sands area.
2. Proposed green field site land allocations for the Grange-over-Sands area.
3. The adverse impact of the proposed developments on tourism, the life-blood of Grange-over-Sands and the Cartmel Peninsula.
4. The inadequate road system that links Grange-over-Sands to other SLDC Service Centres.
In addition, SLDC have not provided objective evidence that justifies their classification of Grange-over-Sands as an SLDC Key Service Centre. Grange-over-Sands does not meet SLDC’s Core Strategy Document definition of Key Service Centre: it does not have a secondary school and it is not directly linked to other SLDC Service Centres by a main trunk road.
Nor does the SLDC Land Allocation DPD take account of local residents’ wishes about how their community should be developed, or the views of Grange-over-Sands Town Council.

Please notify me

LA1.3 Housing Allocations - R110 GRANGE-OVER-SANDS SOUTH OF THORNFIELD ROAD

No

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. SLDC should not include Grange-over-Sands as one of its Key Service Centres because it does not meet the criteria in CS1.2 The development strategy for Principal Service Centres, Key Service Centres and Local Service Centres. This would mean that the number of proposed developments in Grange-over-Sands and district should be reduced and all proposed development sites should be reassessed. Development of brown field sites, such as Berners, should be prioritised and SLDC should take account of the views of local residents and Grange-over-Sands Town Council.
2. SLDC have not followed Government guidance about the use and interpretation of household surveys. They have not provided objective evidence to justify ‘housing need for Grange-over-Sands and District.
3. SLDC should be required to produce objective evidence to justify their plans to allow Grange-over-Sands to develop into a coastal urban sprawl incorporating Kents Bank.
4. SLDC should be required to remove sites MN25N, R672 and R79# from their Land Development DPD because development of these sites will lead to coalescence between the communities of Kents Bank and Allithwaite.
5. SLDC should be required to remove sites R449, R74 and R110 from their Land Development DPD because development of these sites will lead to further coalescence between the communities of Grange-over-Sands and Kents Bank.
6. SLDC should be required to produce clear evidence about how their proposed developments will enhance tourism in Grange-over-Sands and district.
7. SLDC should be required to explain why they have ignored recommendations made about green field sites and tourism in the Grange-over-Sands Regeneration Study (Douglas Wheeler Associates, November 2007), that they claim has informed SLDC's Core Strategy.
8. SLDC should be required to provide objective evidence that the local roads are adequate to support the proposed increase in population and traffic in Grange-over-Sands especially for known bottle-necks in Main Street and on Risedale Hill.
9. SLDC should not allow any development on prime green field land between Kents Bank and Allithwaite because it will lead to coalescence between these two separate communities.

I do not support SLDC’s Land Allocations DPD because it is based on spurious ‘housing need’ targets and has unnecessarily ear-marked important greenfield sites for development.

No

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 following text of response 11292 is taken from sections 4, 5, 6 and 7 of my SLDC LDF consultation submission entitled: ‘Soundness’ response to SLDC’s Land Allocation Development Plan (DPD, Jan 2012) focussing on SLDC’s ‘housing need’ predictions & SLDC’s vision for Grange-over-Sands and District.
My report included photographs, maps and tables to support comments that were made in the report. I have requested that this report be made available to the Planning Inspector.
The sections featured in response 11292 are:
5 . Does SLDC’s Land Allocation Document attempt to ‘air-brush’ Kents Bank out of existence as a separate community?
Photographs, tables and maps that were included with the text in the report have been stored elsewhere, formatting that clarified the text has been removed and spurious question marks have appeared that are not in the original text.
[The full report is attached]


5 Does SLDC’s Land Allocation Document attempt to ‘air-brush’ Kents
Bank out of existence as a separate community?

5.1 SLDC’s Planning Department currently treats Kents Bank as a suburb of Grange-over-
Sands even though Kents Bank can trace its existence back to Mediaeval times when
monks from Cartmel lodged at Abbot Hall, Kents Bank, when ‘crossing the sands’
whereas Grange-over-Sands developed as a tourist resort in Victorian times after the
‘coming of the railway.

5.2 Kents Bank has its own station, Post Office, shop, Art Gallery, Abbot Hall Hotel and
Guide’s Farm. The post of Guide dates back to at least 1501 according to records of
Cartmel Priory.

5.3 During the past 20-25 years SLDC’s Planning Department have permitted infilling
development on many Kents Bank green field sites; they have allowed infilling on green
gaps between Kents Bank and Grange-over-Sands on the east, and, Kents Bank and
Allithwaite on the west.

5.4 Why is SLDC treating Kents Bank as a suburb of Grange-over-Sands? Residents of
Kents Bank do not support this view; they value their community and do not want to see
Kents Bank absorbed into Grange-over-Sands or Allithwaite. Kents Bank was
established hundreds of years before Grange-over-Sands.

5.5 This unsound approach has been perpetuated in SLDC’s Land Allocation DPD. Section
4.2 of the document is headed Grange-over-Sands and Kents Bank whereas Allithwaite
is considered as a separate community.

5.6 Subsequent text in SLDC’s Land Allocation DPD uses the name Grange-over-Sands
when it is actually referring to Kents Bank. For example paragraph 4.12 states:
“…The second major allocation is a large site on Allithwaite Road west of Kents Bank.
This is the only large site available in Grange-over-Sands…”

5.7 This is nonsense. The site referred to is MN25M; it is west of Kents Bank; it will
significantly extend Kents Bank’s western boundary and will lead to coalescence
between Kents Bank and Allithwaite if it is developed (see Map 1 and section 6).

REFER TO MAP 1 & 2 IN ATTACHED DOCUMENT

5.8 SLDC’s Land Allocation DPD gives Kents Bank similar problems with its Grange-over-
Sands boundaries; the green spaces between Grange-over-Sands and Kents Bank have
been gradually eroded over the years. If more green spaces between the two
communities are developed it will be the ‘death knell’ of Kents Bank as a separate
community (see Map 2)

5.9 It is clear from Map 2 that building on sites R110 (Trickett’s field) and R449/R74 will
erode the sense of separation between Grange-over-Sands and Kents Bank when
driving on the main road, the B5227 and that they will increase coalescence between
Grange-over-Sands and Kents Bank.

5.10 The Grange-over-Sands Regeneration Study 2007 considered site R110 (Trickett’s
field). They concluded that it should not be developed because:
“…loss of open views from street is negative…”

5.11 R449/R74 was not considered by the Grange-over-Sands Regeneration Study 2007 and its importance as a green field site has not been independently assessed. It is clear from Map 2 that development of these two sites will increase coalescence between Grangeover-Sands and Kents Bank. SLDC has provided no objective evidence to support the development of either of these green field sites.

5.12 The only green field site in Kents Bank that was considered by the Grange-over-Sands
Regeneration Study 2007 was site R89 (the Carter Road site, Berry Bank, Map 1 and
Map 2) and the report did not recommend development of R89 because of:
“…the loss of open area will be an issue…” and they concluded that
“…that residential development of the Allithwaite Road/Carter Road site is likely to be
controversial because of the ‘green field’ nature of the site…”

5.13 None of the development sites proposed for Kents Bank (Map 1), except R89, were
considered by the Grange-over-Sands Regeneration Study 2007; they have not been
independently assessed before inclusion in SLDC’s Land Allocation DPD.

SEE TABLE 4 IN ATTACHED DOCUMENT

5.14 Table 4 clearly shows that a disproportionate amount of the unsustainable housing
allocation for Grange-over-Sands has been allocated to Kents Bank (58%)

5.15 The proposed development will increase the size of Kents Bank by 40% and extend its
boundaries towards Allithwaite causing coalescence between Kents Bank and
Allithwaite; SLDC have provided no objective evidence to justify increasing the size of
Kents Bank on this scale.

5.16 All the proposed housing development sites in Kents Bank have been allocated to
desirable green field sites except for Guides Lot (17 dwellings plus employment units)
but even this site includes a small additional green field and the site is adjacent to land
on Wart Barrow that is covered by a Limestone Pavement Order.

5.17 The proposed site MN25M is particularly contentious (see section 6).

5.18 Development of all the proposed sites near Risedale Hill and in Kents Bank will have an adverse effect on local drainage in areas that are already prone to flooding after heavy
rainfall eg Allithwaite Road beyond the top of Risedale Hill, Greaves Wood Road
(Bridleway) and Kirkhead Road.

5.19 The SLDC’s Land Allocation DPD has not taken account of problems highlighted by
Kents Bank residents in the 2011 consultation exercises. For example response forms
that I submitted for sites: MN25M, R672, 350M, R79#, R82#/R347# (see Appendices 3
to 7).

5.20 Many other residents also highlighted significant problems associated with the proposed land allocations for Kents Bank. All appear to have been ignored and lumped together in groups with a comment such as ‘noted’ beside them (see section 8). Why?

Section 5: Kents Bank as a separate community;
summary of main conclusions
- Kents Bank has been a separate community since Mediaeval times.
- SLDC have provided no clear evidence to justify increasing the size of Kents
Bank by 40%.
- SLDC have provided no clear evidence to justify sanctioning developments
that will increase coalescence between Grange-over-Sands and Kents Bank.
- SLDC have provided no clear evidence to justify sanctioning developments
that will increase coalescence between Kents Bank and Allithwaite.
- The local road system, utilities and community support systems are already
inadequate; they are not robust enough to support 298 more households in
Kents Bank.

I do not support SLDC’s Land Allocation DPD

YES, I wish to participate at the oral examination

I wish to take part in the oral examination because SLDC have not made an adequate response to significant planning concerns, raised by local residents, during earlier consultation phases, particularly those relating to:
1. ‘Housing need’ in the Grange-over-Sands area.
2. Proposed green field site land allocations for the Grange-over-Sands area.
3. The adverse impact of the proposed developments on tourism, the life-blood of Grange-over-Sands and the Cartmel Peninsula.
4. The inadequate road system that links Grange-over-Sands to other SLDC Service Centres.
In addition, SLDC have not provided objective evidence that justifies their classification of Grange-over-Sands as an SLDC Key Service Centre. Grange-over-Sands does not meet SLDC’s Core Strategy Document definition of Key Service Centre: it does not have a secondary school and it is not directly linked to other SLDC Service Centres by a main trunk road.
Nor does the SLDC Land Allocation DPD take account of local residents’ wishes about how their community should be developed, or the views of Grange-over-Sands Town Council.

Please notify me

LA1.3 Housing Allocations - All Flookburgh sites

No

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. SLDC should not include Grange-over-Sands as one of its Key Service Centres because it does not meet the criteria in CS1.2 The development strategy for Principal Service Centres, Key Service Centres and Local Service Centres. This would mean that the number of proposed developments in Grange-over-Sands and district should be reduced and all proposed development sites should be reassessed. Development of brown field sites, such as Berners, should be prioritised and SLDC should take account of the views of local residents and Grange-over-Sands Town Council.
2. SLDC have not followed Government guidance about the use and interpretation of household surveys. They have not provided objective evidence to justify ‘housing need for Grange-over-Sands and District.
3. SLDC should be required to produce objective evidence to justify their plans to allow Grange-over-Sands to develop into a coastal urban sprawl incorporating Kents Bank.
4. SLDC should be required to remove sites MN25N, R672 and R79# from their Land Development DPD because development of these sites will lead to coalescence between the communities of Kents Bank and Allithwaite.
5. SLDC should be required to remove sites R449, R74 and R110 from their Land Development DPD because development of these sites will lead to further coalescence between the communities of Grange-over-Sands and Kents Bank.
6. SLDC should be required to produce clear evidence about how their proposed developments will enhance tourism in Grange-over-Sands and district.
7. SLDC should be required to explain why they have ignored recommendations made about green field sites and tourism in the Grange-over-Sands Regeneration Study (Douglas Wheeler Associates, November 2007), that they claim has informed SLDC's Core Strategy.
8. SLDC should be required to provide objective evidence that the local roads are adequate to support the proposed increase in population and traffic in Grange-over-Sands especially for known bottle-necks in Main Street and on Risedale Hill.
9. SLDC should not allow any development on prime green field land between Kents Bank and Allithwaite because it will lead to coalescence between these two separate communities.

I do not support SLDC’s Land Allocations DPD because it is based on spurious ‘housing need’ targets and has unnecessarily ear-marked important greenfield sites for development.

No

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 following text of response 11303 is taken from sections 7 of my SLDC LDF consultation submission entitled: ‘Soundness’ response to SLDC’s Land Allocation Development Plan (DPD, Jan 2012) focussing on SLDC’s ‘housing need’ predictions & SLDC’s vision for Grange-over-Sands and District.
My report included photographs, maps and tables to support comments that were made in the report. I have requested that this report be made available to the Planning Inspector.
The sections featured in response 11303 are:
7. Does SLDC's Land Allocation Document make adequate provision for capital expenditure to upgrade local roads?
Photographs, tables and maps that were included with the text in the report have been stored elsewhere, formatting that clarified the text has been removed and spurious question marks have appeared that are not in the original text.
[The full report is attached]


7 Does SLDC’s Land Allocation Document make adequate provision for
capital expenditure to upgrade local roads?

7.1 Allithwaite Road (B5277) is already inadequate for the amount of traffic regularly
travelling between Grange-over-Sands, Allithwaite, Flookburgh, Holker Hall, Kendal,
Lancaster and the M6.

7.2 The traffic problem is exacerbated when regular events such as Cartmel Races and
the Holker Garden Festival attract large crowds.

7.3 The stretch of Allithwaite Road between Kents Bank and Allithwaite from the top of
Risedale Hill is a fast stretch of undulating road that poses sight line problems for
drivers (see picture 3, section 6.15).

7.4 Developers would be forced to create new roads for development area MN25M linking
onto Allithwaite Road; this would increase traffic hazards on Allithwaite Road, or, lead
to the creation of an intrusive roundabout system that would destroy the rural nature
of this road and area

7.5 Greaves Wood Road bridleway forms the eastern, and southern, boundaries of
MN25M; it could not be used as access to MN25M development area because of a)
the Protected Limestone Pavement in Greaves Wood and b) it is a popular pedestrian
route for local residents, especially dog walkers (see Map 1, section 5.7 and Map 3,
section 6.4).

7.6 Access from Kirkhead Road to the MN25M development area is not practical; there
are no suitable gaps between the houses whose back gardens form the western
boundary of MN25M.

7.7 Industrial development and 202 residential units will generate a large amount of extra
traffic in Kents Bank that will all need to drive through Grange-over-Sands to reach the
A590 for access to Kendal, Lancaster and the M6; the local road system is not
suitable for this.

7.8 Local roads are not adequate to accommodate service vehicles for industrial
development.

SEE PICTURES IN ATTACHED DOCUMENT

7.9 SLDC are also proposing to build dwellings on the land behind the lorry on Allithwaite
Road (picture 6) and on the left hand side of Allithwaite Road beyond the junction of
Allithwaite Road with Jack Hill (junction to the left of Kirkhead Road; picture 6); access
to both these sites is constrained by their location and will cause road safety
problems.

7.10 Picture 5 clearly shows that it is not possible to widen or straighten Risedale Hill
without major road works involving compulsory purchase orders, demolition of walls
and completely altering the character of this part of Kents Bank and that the road is
not suitable for large volumes of traffic.

7.11 Traffic from three other nearby proposed residential developments in Kents Bank,
R672M: 36 residential units & R89: 45 residential units, R350M: 17 houses, also link
to Allithwaite Road, near the top of Risedale Hill therefore they should also be taken
into account when undertaking an area traffic impact study (see Map 1, section 5.7);
as should traffic generated by all residential and employment developments west of
Risedale Hill in Allithwaite and Flookburgh.

7.12 Once the traffic has negotiated Risedale Hill it then has to negotiate Main Street hill in
Grange-over-Sands another bottleneck that is often made worse by delivery vehicles
for the local shops because none of the shops on this part of Main Street have rear
access,

7.13 The local roads are in a poor state of repair and are not suitable for this level of traffic
increase.

7.14 SLDC have made no provision for improving these roads and have not justified a
need for developments that will make the traffic conditions considerably worse and
deter tourists.

7.15 There is no viable route for a Grange-over-Sands by-pass. A new trunk road to the
A590 would have to be routed across rough pastureland to the north of Grange-over-
Sands and would impinge on classic views of Cartmel and Cartmel Priory.

7.16 Car parking in Grange-over-Sands is already inadequate for local residents shopping
and tourists and again, no provision has been made in SLDC’s Land Allocation DPD
to improve local car parking facilities.

Section 7: Inadequate local roads in Grange-over-Sands and District;
summary of main conclusions
- The roads in Grange-over-Sands and district are already inadequate for the
traffic that they carry.
- There are two major bottlenecks: Risedale Hill and Main Street Hill that
cannot be widened due to their location.
- It would be expensive and difficult to agree a route for a new trunk road to the
A590 that by-passed Grange-over-Sands.
- SLDC have not made any provision to upgrade roads in Grange-over-Sands
and district.
- SLDC have not provided objective evidence to justify proposing large
development to the west of Grange-over-Sands given the already inadequate
road system.

I do not support SLDC’s Land Allocation DPD

YES, I wish to participate at the oral examination

I wish to take part in the oral examination because SLDC have not made an adequate response to significant planning concerns, raised by local residents, during earlier consultation phases, particularly those relating to:
1. ‘Housing need’ in the Grange-over-Sands area.
2. Proposed green field site land allocations for the Grange-over-Sands area.
3. The adverse impact of the proposed developments on tourism, the life-blood of Grange-over-Sands and the Cartmel Peninsula.
4. The inadequate road system that links Grange-over-Sands to other SLDC Service Centres.
In addition, SLDC have not provided objective evidence that justifies their classification of Grange-over-Sands as an SLDC Key Service Centre. Grange-over-Sands does not meet SLDC’s Core Strategy Document definition of Key Service Centre: it does not have a secondary school and it is not directly linked to other SLDC Service Centres by a main trunk road.
Nor does the SLDC Land Allocation DPD take account of local residents’ wishes about how their community should be developed, or the views of Grange-over-Sands Town Council.

Please notify me

1.9

No

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. SLDC should not include Grange-over-Sands as one of its Key Service Centres because it does not meet the criteria in CS1.2 The development strategy for Principal Service Centres, Key Service Centres and Local Service Centres. This would mean that the number of proposed developments in Grange-over-Sands and district should be reduced and all proposed development sites should be reassessed. Development of brown field sites, such as Berners, should be prioritised and SLDC should take account of the views of local residents and Grange-over-Sands Town Council.
2. SLDC have not followed Government guidance about the use and interpretation of household surveys. They have not provided objective evidence to justify ‘housing need for Grange-over-Sands and District.
3. SLDC should be required to produce objective evidence to justify their plans to allow Grange-over-Sands to develop into a coastal urban sprawl incorporating Kents Bank.
4. SLDC should be required to remove sites MN25N, R672 and R79# from their Land Development DPD because development of these sites will lead to coalescence between the communities of Kents Bank and Allithwaite.
5. SLDC should be required to remove sites R449, R74 and R110 from their Land Development DPD because development of these sites will lead to further coalescence between the communities of Grange-over-Sands and Kents Bank.
6. SLDC should be required to produce clear evidence about how their proposed developments will enhance tourism in Grange-over-Sands and district.
7. SLDC should be required to explain why they have ignored recommendations made about green field sites and tourism in the Grange-over-Sands Regeneration Study (Douglas Wheeler Associates, November 2007), that they claim has informed SLDC's Core Strategy.
8. SLDC should be required to provide objective evidence that the local roads are adequate to support the proposed increase in population and traffic in Grange-over-Sands especially for known bottle-necks in Main Street and on Risedale Hill.
9. SLDC should not allow any development on prime green field land between Kents Bank and Allithwaite because it will lead to coalescence between these two separate communities.

I do not support SLDC’s Land Allocations DPD because it is based on spurious ‘housing need’ targets and has unnecessarily ear-marked important greenfield sites for development.

No

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 following text of response 11304 is taken from sections 8 of my SLDC LDF consultation submission entitled: ‘Soundness’ response to SLDC’s Land Allocation Development Plan (DPD, Jan 2012) focussing on SLDC’s ‘housing need’ predictions & SLDC’s vision for Grange-over-Sands and District.
My report included photographs, maps, tables and Appendices to support comments that were made in the report. I have requested that this report be made available to the Planning Inspector.
The sections featured in response 11304 are:
8. Was SLDC’s consultation process sound?
Photographs, tables, maps and Appendices that were included with the text in the report have been stored elsewhere and formatting that clarified the text has been removed
[The full report is attached]


8 Was SLDC’s consultation process ‘sound’?

8.1 SLDC’s consultation process appears to have been flawed.

8.2 Members of the public were offered a chance to make comments on SLDC’s Land
Development proposals in 2011 but the system for assessing these submissions lacks
clarity and objectivity.

8.3 The SLDC Planning Department:

i. Prepared the Land Allocation DPD.

ii. Assessed responses from local residents with phrases such as ‘noted’ or ‘taken into
account’.

iii. Ignored factual evidence submitted.

8.4 There has been no independent scrutiny of submissions made during the consultation
process.

8.5 There has been no open discussion about alternative options for the provision of
‘affordable housing’ and the majority Liberal Democrat Council have been under a ‘three
line whip’ to support the proposals.

8.6 In addition developers have been allowed to appoint Land Agents to lobby for
particularly desirable green field sites to be included in SLDC’s Land Allocation DP.

8.7 This can hardly be described as a fair process.

8.8 The reality is that many of the proposals in SLDC’s Land Allocation DPD do not ‘live up
to their SLDC ‘billing’ in the plan. A prime example of this being the claim that a 220
metre gap on the B5227 between Kents Bank and Allithwaite is sufficient to avoid
coalescence between the two communities.

8.9 SLDC’s ‘soundness consultation period’ has been the minimum allowed (six weeks) and has included the Easter holiday fortnight. Again, this puts local residents at a
disadvantage.

I do not support SLDC’s Land Allocation DPD

YES, I wish to participate at the oral examination

I wish to take part in the oral examination because SLDC have not made an adequate response to significant planning concerns, raised by local residents, during earlier consultation phases, particularly those relating to:
1. ‘Housing need’ in the Grange-over-Sands area.
2. Proposed green field site land allocations for the Grange-over-Sands area.
3. The adverse impact of the proposed developments on tourism, the life-blood of Grange-over-Sands and the Cartmel Peninsula.
4. The inadequate road system that links Grange-over-Sands to other SLDC Service Centres.
In addition, SLDC have not provided objective evidence that justifies their classification of Grange-over-Sands as an SLDC Key Service Centre. Grange-over-Sands does not meet SLDC’s Core Strategy Document definition of Key Service Centre: it does not have a secondary school and it is not directly linked to other SLDC Service Centres by a main trunk road.
Nor does the SLDC Land Allocation DPD take account of local residents’ wishes about how their community should be developed, or the views of Grange-over-Sands Town Council.

Please notify me

1.10

No

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. SLDC should not include Grange-over-Sands as one of its Key Service Centres because it does not meet the criteria in CS1.2 The development strategy for Principal Service Centres, Key Service Centres and Local Service Centres. This would mean that the number of proposed developments in Grange-over-Sands and district should be reduced and all proposed development sites should be reassessed. Development of brown field sites, such as Berners, should be prioritised and SLDC should take account of the views of local residents and Grange-over-Sands Town Council.
2. SLDC have not followed Government guidance about the use and interpretation of household surveys. They have not provided objective evidence to justify ‘housing need for Grange-over-Sands and District.
3. SLDC should be required to produce objective evidence to justify their plans to allow Grange-over-Sands to develop into a coastal urban sprawl incorporating Kents Bank.
4. SLDC should be required to remove sites MN25N, R672 and R79# from their Land Development DPD because development of these sites will lead to coalescence between the communities of Kents Bank and Allithwaite.
5. SLDC should be required to remove sites R449, R74 and R110 from their Land Development DPD because development of these sites will lead to further coalescence between the communities of Grange-over-Sands and Kents Bank.
6. SLDC should be required to produce clear evidence about how their proposed developments will enhance tourism in Grange-over-Sands and district.
7. SLDC should be required to explain why they have ignored recommendations made about green field sites and tourism in the Grange-over-Sands Regeneration Study (Douglas Wheeler Associates, November 2007), that they claim has informed SLDC's Core Strategy.
8. SLDC should be required to provide objective evidence that the local roads are adequate to support the proposed increase in population and traffic in Grange-over-Sands especially for known bottle-necks in Main Street and on Risedale Hill.
9. SLDC should not allow any development on prime green field land between Kents Bank and Allithwaite because it will lead to coalescence between these two separate communities.

I do not support SLDC’s Land Allocations DPD because it is based on spurious ‘housing need’ targets and has unnecessarily ear-marked important greenfield sites for development.

No

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 following text of response 11305 is taken from section 8 of my SLDC LDF consultation submission entitled: ‘Soundness’ response to SLDC’s Land Allocation Development Plan (DPD, Jan 2012) focussing on SLDC’s ‘housing need’ predictions & SLDC’s vision for Grange-over-Sands and District.
My report included photographs, maps, tables and Appendices to support comments that were made in the report. I have requested that this report be made available to the Planning Inspector.
The section featured in response 11305 is:
8. Was SLDC's consultation process sound?
Photographs, tables and maps that were included with the text in the report have been stored elsewhere and formatting that clarified the text has been removed.
[The full report is attached]

8 Was SLDC’s consultation process ‘sound’?

8.1 SLDC’s consultation process appears to have been flawed.

8.2 Members of the public were offered a chance to make comments on SLDC’s Land
Development proposals in 2011 but the system for assessing these submissions lacks
clarity and objectivity.

8.3 The SLDC Planning Department:

i. Prepared the Land Allocation DPD.

ii. Assessed responses from local residents with phrases such as ‘noted’ or ‘taken into
account’.

iii. Ignored factual evidence submitted.

8.4 There has been no independent scrutiny of submissions made during the consultation
process.

8.5 There has been no open discussion about alternative options for the provision of
‘affordable housing’ and the majority Liberal Democrat Council have been under a ‘three
line whip’ to support the proposals.

8.6 In addition developers have been allowed to appoint Land Agents to lobby for
particularly desirable green field sites to be included in SLDC’s Land Allocation DP.

8.7 This can hardly be described as a fair process.

8.8 The reality is that many of the proposals in SLDC’s Land Allocation DPD do not ‘live up
to their SLDC ‘billing’ in the plan. A prime example of this being the claim that a 220
metre gap on the B5227 between Kents Bank and Allithwaite is sufficient to avoid
coalescence between the two communities.

8.9 SLDC’s ‘soundness consultation period’ has been the minimum allowed (six weeks) and has included the Easter holiday fortnight. Again, this puts local residents at a
disadvantage.

I do not support SLDC’s Land Allocation DPD

YES, I wish to participate at the oral examination

I wish to take part in the oral examination because SLDC have not made an adequate response to significant planning concerns, raised by local residents, during earlier consultation phases, particularly those relating to:
1. ‘Housing need’ in the Grange-over-Sands area.
2. Proposed green field site land allocations for the Grange-over-Sands area.
3. The adverse impact of the proposed developments on tourism, the life-blood of Grange-over-Sands and the Cartmel Peninsula.
4. The inadequate road system that links Grange-over-Sands to other SLDC Service Centres.
In addition, SLDC have not provided objective evidence that justifies their classification of Grange-over-Sands as an SLDC Key Service Centre. Grange-over-Sands does not meet SLDC’s Core Strategy Document definition of Key Service Centre: it does not have a secondary school and it is not directly linked to other SLDC Service Centres by a main trunk road.
Nor does the SLDC Land Allocation DPD take account of local residents’ wishes about how their community should be developed, or the views of Grange-over-Sands Town Council.

Please notify me