2 responses from Mrs E McCallum, c/o Garner Planning Associates
1. Mrs E McCallum, c/o Garner Planning Associates : 25 May 2012 15:05:00
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I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - Site Omission
If you have selected a ‘Site omission’ please enter the site reference or location and relevant policy below
R124 Land East of Ullswater Road, Kendal
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
1. INTRODUCTION
1.1 These representations relate to land to the east of Ullswater Road (R124).
1.2 It is considered that the site is suitable and deliverable for residential development and should therefore be identified as a housing allocation under Policy LA1.3.
2. SITE DESCRIPTION
2.1 The site is located on the north east side of Kendal, to the east of Ullswater Road with potential access from Peat Lane, Whitbarrow Close, Grizedale Avenue and from Sedbergh Road.
2.2 The site is in agricultural use and comprises 3.47 ha.
2.3 The eastern and northern boundaries of the site are defined by stone walls.
3. LOCAL PLAN DESIGNATION
3.1 The land is identified in the South Lakeland Local Plan 2006 Kendal Proposals Map as outside the Development Boundary.
3.2 The site is specifically excluded from the County Landscape Area which is evident to the north and east of the site.
3.3 There are only a limited number of areas immediately outside the Local Plan Development boundary and on the edge of Kendal that the Local Plan does not designate as either County Landscape Area or Green Barrier.
3.4 There are only two areas, without the above designations, on the edge of Kendal that are not proposed for development in the Draft Allocations document. One being a large area on the north side of Kendal between Burneside Road and Gilthwaitrigg Lane which lies within the Functional Floodplain (see the South Lakeland Flood Risk Assessment October 2007) and therefore not suitable for development and the other the Objection Site which is considered suitable by the Objector for development.
4. HOUSING REQUIREMENTS
4.1 It is considered there is a significant shortfall of housing provision in the District and in Kendal to meet Core Strategy requirements. A detailed explanation of the extent of housing shortfalls can be provided at any Planning Hearing. In brief the shortfall in Kendal is considered to be 643 dwellings and 856 dwellings if one assumes a 10% slippage.
4.2 There is a need to provide for additional housing provision in Kendal and the allocation of the Objection site can, in part, address the shortfall.
4.3 The background to the consideration of this site in evidence base documents is set out below.
5. EVIDENCE BASE DOCUMENTS CONFIRM THE OBJECTION SITE’S SUITABILITY FOR RESIDENTIAL DEVELOPMENT
5.1 South Lakeland Housing and Employment Land Search Study
5.1.1 The Housing and Employment Land Search Study, produced in February 2009 for SLDC by Gillespie’s, forms part of the evidence base prepared to focus on potential urban extensions around key settlements in the District, including Kendal.
5.1.2 The Study identifies 9 sites on the edge of Kendal considered suitable for residential development and one site suitable for a mixed development including residential. The Objection Site is the only site capable of accommodating over 50 dwellings not subsequently identified as a housing allocation.
5.1.3 The Objection Site is described as “Site 9 South of Peat Lane”, with a site area of 3.47ha and capacity of 139 dwellings.
5.1.4 In appraising each site the authority considered environmental context, including wider landscape and visual impact, accessibility, proximity to community facilities, shops, services and employment, utility services and feasibility including development costs, topography, ownership and viability.
5.1.5 The report indicates that the planning authority considered the site to be highly sustainable but with only moderate deliverability. Of the 9 sites only one site was considered to have high deliverability.
5.1.6 The combination of these Study’s findings on sustainability and deliverability resulted in the site being categorised as a Category 2 site, with 7 categories identified in total. Clearly the site was considered to perform highly in planning terms.
5.1.7 In concluding the site was highly sustainable the Study indicates the Objection Site to have:-
• “Local visual impact
• Good access to buses
• Good access to services including schools and employment”
5.1.8 In considering the deliverability, the Study indicates the Objection Site to have the following potential issues:-
• “Off site water mains works required
• Land assembly issues
• Potential site drainage issues.”
5.1.9 Off site water main issues is mentioned in relation to all the sites considered and was not considered at the time of the Study to preclude any of the sites coming forward.
5.1.10 The Study refers only to “potential drainage issues” and does not confirm that such issues preclude the site from coming forward for residential development. Indeed 113 dwellings are identified on the site east of Appleby Road (M35KM) with reference on the Kendal Main Proposals Map as a “Long-term development site subject to surface water drainage issues investigation. Potential 25% residential in the shorter term.” Clearly “potential drainage issues” are not considered a reason to preclude the allocation of housing sites.
5.2 Strategic Housing Land Availability Assessment (March 2009)
5.2.1 The SHLAA produced by Roger Tym & Partners in March 2009 identifies the Objection Site in the highest category i.e. a Category 1 Deliverable Sites.
5.2.3 The Gross Area is stated as being 3.4ha, the net area 2.55ha and the site capacity 77 dwellings. The site boundary is slightly different from the Housing and Employment Land Search Study, with a small triangle of land excluded at the northern end of the site.
5.2.4 The site area is similar to the Study referred to in Section 6.1 above, but the capacity is considerably lower. It is the Objector’s view that the SHLAA provides a more realistic assessment of the site’s capacity.
5.2.6 Whilst the SHLAA considers the Objection Site to be in the highest category in terms of deliverability the Allocations document excludes the site.
5.3 Sustainability Appraisal
5.3.1 The planning authority’s Sustainability Appraisal of the site indicates the Objection Site has good access to community facilities, primary and secondary schools, education and training facilities, jobs, transport, open space, culture and leisure and its development would not cause coalescence.
5.3.2 The Sustainability Appraisal indicates a neutral impact on landscape character and the built environment, but suggests the negative aspects of the site’s development would be an impact upon air quality and the fact the site is greenfield.
5.3.4 It is not clear why the development of the site for housing development is considered more likely to detrimentally impact on air quality than other edge of urban sites. The close relationship between the site and various services and facilities at least provides prospective residents with the opportunity to reach these facilities without needing to use a car. It is not clear why the development of the site would impact upon air quality more than other allocations.
5.3.5 The site is greenfield like all housing allocations on the edge of Kendal, so the site cannot be ruled out for consideration on these grounds.
5.3.6 The reference “no surface water to foul sewer – UU” is one made in relation to several sites that have been allocated so again this does not seem a reason to rule out potential development of the site for residential purposes.
5.3.7
The Environment Agency indicate “any further increase in surface water runoff as a result of development in this area could (our emphasis) compromise the storage capacity of the Stock Beck Detention Basin downstream.” At this point in time the Environment Agency is not certain that Stock Beck cannot accommodate more surface water. Further it is possible that an attenuation scheme restricting surface water runoff to greenfield rates would be a solution to avoid downstream issues.
5.3.8 Issues associated with the Stock Beck catchment area are referred to in the context of other proposed allocations. In the context of other proposed allocations the Environment Agency make reference to Natland Beck and Blind Beck. There may be technical issues that need further investigation but given the Objection Site’s suitability in sustainability and landscape terms, these issues simply require further investigation and should not rule out the allocation of the site for housing development.
6. DELIVERABILITY
6.1 As is indicated above it is the Objector’s view that the Allocations document does not identify sufficient housing land in total, or more specifically of relevance to this submission, in Kendal.
6.2 The National Planning Framework indicates that planning authorities should:-
47...identify and update annually a supply of specific deliverable sites...”
Footnote 11 indicates that:-
“To be considered deliverable, sites should be available now, offer a suitable location for development now, and be achievable with a realistic prospect that housing will be delivered on the site within five years and in particular development of the site is viable...”
6.3 The site is available now, is in a suitable location for housing development being located on the edge of a Principal Service Centre and there is a reasonable prospect of the site being delivered within five years.
7. CONCLUSIONS
7.1 The Allocations document does not provide for sufficient housing to meet Core Strategy housing requirements in the period 2003-2025 at district wide level or in Kendal.
7.2 The allocation of the Objection site could partly meet this shortfall.
7.3 As several studies have demonstrated, the Objection Site scores highly in sustainability terms. The site is well related to the built-up area of Kendal and would not have an adverse impact upon the landscape. Access is available and the landowner is willing to release the site for housing development.
7.4 The site should be identified in Policy LA1.3 as a site capable of accommodating approximately 80 dwellings in Phase 1.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
To discuss the housing supply position and the wider context for Kendal and the district.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
2. Mrs E McCallum, c/o Garner Planning Associates : 25 May 2012 15:18:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
2.18
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
1. INTRODUCTION
1.1 These representations relate to land to the east of Ullswater Road (R124).
1.2 It is considered that the site is suitable and deliverable for residential development and should therefore be identified as a housing allocation under Policy LA1.3.
2. SITE DESCRIPTION
2.1 The site is located on the north east side of Kendal, to the east of Ullswater Road with potential access from Peat Lane, Whitbarrow Close, Grizedale Avenue and from Sedbergh Road.
2.2 The site is in agricultural use and comprises 3.47 ha.
2.3 The eastern and northern boundaries of the site are defined by stone walls.
3. LOCAL PLAN DESIGNATION
3.1 The land is identified in the South Lakeland Local Plan 2006 Kendal Proposals Map as outside the Development Boundary.
3.2 The site is specifically excluded from the County Landscape Area which is evident to the north and east of the site.
3.3 There are only a limited number of areas immediately outside the Local Plan Development boundary and on the edge of Kendal that the Local Plan does not designate as either County Landscape Area or Green Barrier.
3.4 There are only two areas, without the above designations, on the edge of Kendal that are not proposed for development in the Draft Allocations document. One being a large area on the north side of Kendal between Burneside Road and Gilthwaitrigg Lane which lies within the Functional Floodplain (see the South Lakeland Flood Risk Assessment October 2007) and therefore not suitable for development and the other the Objection Site which is considered suitable by the Objector for development.
4. HOUSING REQUIREMENTS
4.1 It is considered there is a significant shortfall of housing provision in the District and in Kendal to meet Core Strategy requirements. A detailed explanation of the extent of housing shortfalls can be provided at any Planning Hearing. In brief the shortfall in Kendal is considered to be 643 dwellings and 856 dwellings if one assumes a 10% slippage.
4.2 There is a need to provide for additional housing provision in Kendal and the allocation of the Objection site can, in part, address the shortfall.
4.3 The background to the consideration of this site in evidence base documents is set out below.
5. EVIDENCE BASE DOCUMENTS CONFIRM THE OBJECTION SITE’S SUITABILITY FOR RESIDENTIAL DEVELOPMENT
5.1 South Lakeland Housing and Employment Land Search Study
5.1.1 The Housing and Employment Land Search Study, produced in February 2009 for SLDC by Gillespie’s, forms part of the evidence base prepared to focus on potential urban extensions around key settlements in the District, including Kendal.
5.1.2 The Study identifies 9 sites on the edge of Kendal considered suitable for residential development and one site suitable for a mixed development including residential. The Objection Site is the only site capable of accommodating over 50 dwellings not subsequently identified as a housing allocation.
5.1.3 The Objection Site is described as “Site 9 South of Peat Lane”, with a site area of 3.47ha and capacity of 139 dwellings.
5.1.4 In appraising each site the authority considered environmental context, including wider landscape and visual impact, accessibility, proximity to community facilities, shops, services and employment, utility services and feasibility including development costs, topography, ownership and viability.
5.1.5 The report indicates that the planning authority considered the site to be highly sustainable but with only moderate deliverability. Of the 9 sites only one site was considered to have high deliverability.
5.1.6 The combination of these Study’s findings on sustainability and deliverability resulted in the site being categorised as a Category 2 site, with 7 categories identified in total. Clearly the site was considered to perform highly in planning terms.
5.1.7 In concluding the site was highly sustainable the Study indicates the Objection Site to have:-
• “Local visual impact
• Good access to buses
• Good access to services including schools and employment”
5.1.8 In considering the deliverability, the Study indicates the Objection Site to have the following potential issues:-
• “Off site water mains works required
• Land assembly issues
• Potential site drainage issues.”
5.1.9 Off site water main issues is mentioned in relation to all the sites considered and was not considered at the time of the Study to preclude any of the sites coming forward.
5.1.10 The Study refers only to “potential drainage issues” and does not confirm that such issues preclude the site from coming forward for residential development. Indeed 113 dwellings are identified on the site east of Appleby Road (M35KM) with reference on the Kendal Main Proposals Map as a “Long-term development site subject to surface water drainage issues investigation. Potential 25% residential in the shorter term.” Clearly “potential drainage issues” are not considered a reason to preclude the allocation of housing sites.
5.2 Strategic Housing Land Availability Assessment (March 2009)
5.2.1 The SHLAA produced by Roger Tym & Partners in March 2009 identifies the Objection Site in the highest category i.e. a Category 1 Deliverable Sites.
5.2.3 The Gross Area is stated as being 3.4ha, the net area 2.55ha and the site capacity 77 dwellings. The site boundary is slightly different from the Housing and Employment Land Search Study, with a small triangle of land excluded at the northern end of the site.
5.2.4 The site area is similar to the Study referred to in Section 6.1 above, but the capacity is considerably lower. It is the Objector’s view that the SHLAA provides a more realistic assessment of the site’s capacity.
5.2.6 Whilst the SHLAA considers the Objection Site to be in the highest category in terms of deliverability the Allocations document excludes the site.
5.3 Sustainability Appraisal
5.3.1 The planning authority’s Sustainability Appraisal of the site indicates the Objection Site has good access to community facilities, primary and secondary schools, education and training facilities, jobs, transport, open space, culture and leisure and its development would not cause coalescence.
5.3.2 The Sustainability Appraisal indicates a neutral impact on landscape character and the built environment, but suggests the negative aspects of the site’s development would be an impact upon air quality and the fact the site is greenfield.
5.3.4 It is not clear why the development of the site for housing development is considered more likely to detrimentally impact on air quality than other edge of urban sites. The close relationship between the site and various services and facilities at least provides prospective residents with the opportunity to reach these facilities without needing to use a car. It is not clear why the development of the site would impact upon air quality more than other allocations.
5.3.5 The site is greenfield like all housing allocations on the edge of Kendal, so the site cannot be ruled out for consideration on these grounds.
5.3.6 The reference “no surface water to foul sewer – UU” is one made in relation to several sites that have been allocated so again this does not seem a reason to rule out potential development of the site for residential purposes.
5.3.7
The Environment Agency indicate “any further increase in surface water runoff as a result of development in this area could (our emphasis) compromise the storage capacity of the Stock Beck Detention Basin downstream.” At this point in time the Environment Agency is not certain that Stock Beck cannot accommodate more surface water. Further it is possible that an attenuation scheme restricting surface water runoff to greenfield rates would be a solution to avoid downstream issues.
5.3.8 Issues associated with the Stock Beck catchment area are referred to in the context of other proposed allocations. In the context of other proposed allocations the Environment Agency make reference to Natland Beck and Blind Beck. There may be technical issues that need further investigation but given the Objection Site’s suitability in sustainability and landscape terms, these issues simply require further investigation and should not rule out the allocation of the site for housing development.
6. DELIVERABILITY
6.1 As is indicated above it is the Objector’s view that the Allocations document does not identify sufficient housing land in total, or more specifically of relevance to this submission, in Kendal.
6.2 The National Planning Framework indicates that planning authorities should:-
47...identify and update annually a supply of specific deliverable sites...”
Footnote 11 indicates that:-
“To be considered deliverable, sites should be available now, offer a suitable location for development now, and be achievable with a realistic prospect that housing will be delivered on the site within five years and in particular development of the site is viable...”
6.3 The site is available now, is in a suitable location for housing development being located on the edge of a Principal Service Centre and there is a reasonable prospect of the site being delivered within five years.
7. CONCLUSIONS
7.1 The Allocations document does not provide for sufficient housing to meet Core Strategy housing requirements in the period 2003-2025 at district wide level or in Kendal.
7.2 The allocation of the Objection site could partly meet this shortfall.
7.3 As several studies have demonstrated, the Objection Site scores highly in sustainability terms. The site is well related to the built-up area of Kendal and would not have an adverse impact upon the landscape. Access is available and the landowner is willing to release the site for housing development.
7.4 The site should be identified in Policy LA1.3 as a site capable of accommodating approximately 80 dwellings in Phase 1.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
To discuss the housing supply position and the wider context for Kendal and the district.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me