2 responses from Dr Andrew Catley (Individual)
1. Dr Andrew Catley (Individual) : 5 Apr 2012 12:00:00
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
Policy/Site No.
LA1.3 Housing Allocations - RN213-mod BRIGSTEER LAND OPPOSITE THE WHEATSHEAF
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Proposed site RN213 in Brigsteer should be removed from the DPD.
The Guidance Notes for Making Representations on Development Plan Documents advise that for the DPD to be sound, it should be:
“Justified
This means that the DPD should be founded on a robust and credible evidence base involving:
- Evidence of participation of the local community and others having a stake in the area
- Research/fact finding: the choices made in the plan are backed up by facts
The DPD should also provide the most appropriate strategy when considered against reasonable alternatives. These alternatives should be realistic and subject to sustainability appraisal. The DPD should show how the policies and proposals help to ensure that the social, environmental, economic and resource use objectives of sustainability will be achieved.”
My proposed change to the PDP regarding site RN213 is based on:
- Limited evidence of representative local community participation in the selection of the site, or in analysis of alternative sites
- Evidence from a survey indicating low community support for development of the site
- Limited research or fact finding to support the development of the site.
These issues are described in further detail below.
In paragraph 3.150 the DPD notes that no development land allocation proposals are being considered in small village and hamlets, with the exception of site RN-213 in Brigsteer. This exception is attributed to the apparent degree of community involvement and support for this specific proposal. The DPD further notes the involvement of the local Community Land Trust, with the implication that this involvement reflects community support.
Regarding community involvement in developing the RN-213 site, an important starting point for this appears to be the Helsington Parish Housing Needs Survey report of April 2008 produced by the Cumbria Rural Housing Trust. However,
• Although the survey response rate of 62.6% may be viewed as high relative to comparable surveys in Cumbria, this level of response is still low when viewed against good survey design and analysis more generally, and indicates systematic errors and/or biases in the survey design and administration. Clearly, the design and results of a survey need to be interpreted against the objectives of the organization which conducts the survey, and the risk of limited objectivity.
• When considering specific sites for development in the parish, only 35 survey responses were received. Of these, only 3 respondents suggested developing land near the village hall. In other words, from the total of 122 households who responded to the overall survey, only 2.5% identified this site as appropriate; of the 35 households who responded specifically to the question of suitable sites, only 8.6% identified the site as appropriate. These figures indicate low community support for developing the land opposite the Wheatsheaf.
The selection of site RN213 as the most appropriate site for development appears to be based on the views of the local Community Land Trust, with very limited wider community involvement. Points to consider are:
• The trust comprises self-nominated individuals, some of whom do not live in Brigsteer.
• Some trust members have family members who might benefit from the development of low-cost housing, indicating that the trust’s activities are not entirely altruistic.
• While the trust has analyzed the various sites in Brigsteer for potential development, their analysis is an internal qualitative/subjective analysis and is not evidence-based.
• New houses on site RN213 would be largely isolated and hidden from most of Brigsteer, and curiously, hidden from those Community Land Trust members who reside in Brigsteer. This again indicates that the process for selecting site RN213 by the trust, reflects self-interests. Strong cases could be made for developing other potential sites, such as areas to the south of the village.
• I have consulted residents opposite and adjacent to the proposed RN213 site. There is strong opposition to the development, which could be validated by independent survey or poll.
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
I do not support the DPD in relation to the development of site RN213, for the reasons described in section 2.3.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
The Guidance Notes for Making Representations on Development Plan Documents do not mention an oral examination.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
2. Dr Andrew Catley (Individual) : 17 Apr 2012 07:41:00
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
Policy/Site No.
LA1.3 Housing Allocations - RN213-mod BRIGSTEER LAND OPPOSITE THE WHEATSHEAF
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
On 10th April 2012 a Helsington Parish Meeting was held to discuss the proposed development of site RN213. There were 31 votes against the development and 20 votes in favour, confirming that a majority of local people are against the development. I was unable to attend the meeting, but add a further vote against the development.
The Parish Meeting also led to a large majority of 55 votes for the Parish Council to respond to the SLDC in accordance with results of the meeting. However, the Parish Council have disregarded this position and have voted 4-2 in favour of the development of site RN213. Notably, 5 out of 7 Parish Councillors are also directors of the Helsington Community Land Trust, as a group of self-appointed individuals with interests in housing development.
The Parish Meeting vote against the development and the clear conflict of interest among Parish Councillors demonstrates that meaningful local community support for the development is not evident, in contrast to the DPD paragraph 3.150. Therefore, the proposed development of site RN213 is not sound.
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
I do not support the DPD in relation to the development of site RN213 for the reasons described above.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
