Local Development Framework Consultation

I have read the guidance notes

0.0 Whole Document

No

The Land Allocations Document (DPD) is not within the Local Development Scheme and the key stages have not been followed

The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)

The DPD has not been prepared in accordance with the Town & County Planning Regulations 2004 (as amended)

Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD

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

The DPD has not had regard to the Sustainable Community Strategy

Paper submission and confirmation of support from 110 members hand delivered to SLDC Kendal Office on 17/04/12.
Please reference this document, see below

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 DPD is not consistent with national policy.

Paper submission and confirmation of support from 110 members hand delivered to SLDC Kendal Office on 17/04/12.
Please reference this document;

Submission Overview

This statement has been prepared on behalf of Grange and District Action Group (GADAG), representing members who are residents of Grange over Sands and of the Cartmel Peninsular in Cumbria.

The objective of GADAG is to promote sustainable community-led planning in response to Land Allocation proposals by the Local Planning Authority (LPA), South Lakeland District Council (SLDC) which we believe to be unsound and unsustainable in its current format.

GADAG is affiliated to a regional coalition of resident groups across South Lakeland, The Green Spaces Group, who campaign to promote better consultation between the LPA and the communities it represents, where this has been deemed to be so far ineffective.

GADAG / Green Spaces Group consult with Town and Parish Councils representing Principal and Key Service Centres who are opposed to the existing land allocation plan. In addition, consultation is made with district councillors at SLDC who support neighbourhoods in their opposition to the soundness of the current DPD and who are in favour of neighbourhood-led planning to promote inclusion, acceptance and ownership by the community.

There are sufficient areas of doubt across a range of criteria used to assess the soundness of the DPD. GADAG considers the Land Allocation Development Plan Document (DPD) to be unsound for the reasons outlined below.

If adopted, the Land allocation DPD would over-prescribe for the inclusion of green-field sites throughout South Lakeland within revised development boundaries for settlements over the lifetime of the plan.

This would provide ‘tacit’ planning approval for such sites which have on the whole been speculatively offered-up for disposal by landowners under the ‘land allocation’ process.

We are concerned that SLDC policy to adopt over-inflated targets for house building continues to be informed by the misconception that increasing the supply of new houses improves the level of affordability across all housing stock. We would assert that the stated aim of the current portfolio holder for housing and development at SLDC to reduce house prices across South Lakeland by around 20% through the implementation of an aggressive house building strategy (per the current local plan) to be wholly misinformed and contrary to the findings of national case studies. In fact where evidence shows the converse to be true, the delivery of the local plan is likely to increase affordability issues across the private sector housing market which accounts for the majority of housing stock. This will have the unintended consequence of increasing the perceived need for affordable housing, thereby perpetuating the requirement rather than addressing it.

It is not at all evident that SLDC have meaningfully cooperated with neighbouring authorities in the preparation of their local plan. Over prescribed for house building targets in South Lakeland create regional instabilities and imbalance where they undermine efforts to attract private funding to regenerate depressed areas or allow other districts to maintain viable rural communities where planning restrictions are greater. Consequently, no net gain would be derived from the planning process to the greater benefit of the regional community.

We would consider these objections, together with those submitted by others could form the basis of a community-led legal challenge by resident groups to the soundness of the DPD.

We welcome Lord Justice Keene’s ruling that there can be no assumption that a local authority plan is sound, even in the absence of evidence from objectors.

In registering our objections we confirm that Grange and District Action Group would like to participate in the oral public examination by the Inspector into the soundness of the Land Allocation DPD presented for consideration by SLDC.

Summary of objections to soundness

1. The Land Allocation DPD is based on the highest estimates for population and household growth, where no consideration has been given to the numerous and credible alternatives.

2. Public consultation has failed to deliver appropriate, sufficient and effective methods of engagement.

3. The plan has not adequately explored alternative options for the appropriate and suitable delivery of affordable housing other than by private sector development ‘gains’.

4. The plan fails to consider adequately the balance between settlements or the sustainability of site options across key service centres.

5. The plan fails to conduct adequate sustainability analysis for preferred site options at Grange over Sands and allocations are not in accordance with stated policy.

6. The plan does not consider the impact to the tourism-based economy of Grange over Sands.

7. The plan fails to show adequate coherence and collaboration with the plans and strategies of neighbouring authorities.

1.0 The Land Allocation DPD is based on the highest estimates for population and household growth, where no consideration has been given to numerous and credible alternatives.

1.1 Tests of Soundness failed:
Justified
• Research / fact finding – The choices made in the plan are not backed by up-to-date facts / credible evidence base.
• Assumptions are not reasonable and justified.
• The LPA’s chosen approach is not the most appropriate given the reasonable alternatives. There is no clear audit trail to show how the preferred strategy/approach was arrived at.

1.2 The Land Allocation DPD is based purely upon growth targets from the revoked Regional Spatial Strategy (RSS) as per the core strategy e.g. CS6 (p75). Even though SLDC acknowledges that RSS targets no longer form part of the development plan, it fails to reference credible and up-to-date sources or provide a clear audit trail to inform why it believes the RSS targets are still the most appropriate in informing the level of dwellings scoped for in the Land allocation DPD where alternative and more current projections form part of the evidence base. The Strategic Housing Market Assessment (2011) suggests a variety of average annualised dwelling requirements using 2011 POPGROUP modelling ranging between 205 and 367 units per year up to 2029 (forecasts provided by the Cumbria Intelligence Observatory). Where the Land Allocation DPD plans to deliver 444 dwellings per annum up to 2025, it can be seen that this would over-prescribe for the number of dwellings in comparison to POPGROUP forecasts by between 1001 and 3107 dwellings between 2012 and 2025. We would conclude that SLDC have placed undue weight to the targets set in the RSS and have failed to give sufficient consideration to a more up-to-date evidence base. At such time that the RSS is abolished by order we would assert that both the Core Strategy and the Land Allocation document could be considered to be unsound on this basis.

1.3 There are further issues in relation to using RSS targets in relation to the Land allocation DPD. The RSS spans from 2003 to 2021. SLDC have further extended this to 2025 to ensure plans adopted since 2010 accord to a 15 year time span. The result is that the Land Allocation plan is based on targets set over a much longer and un-prescribed for plan period of 22 years. It could be reasonably expected that had the RSS not been revoked, it would have been subject to at least one review up to 2012. Given this fact and in light of prevailing economic conditions it is surprising SLDC have not sought to act more realistically in setting lower dwelling targets which would be more achievable instead of wholly aspirational.

1.4 We would propose that provision should not be made for housing shortfalls between 2003 and 2009 in the Land Allocation DPD where this is beyond the scope of a 15 year plan to 2025. There is no requirement for this in national policy and there are examples locally where LPA’s such as Allerdale Borough Council explicitly exclude shortfalls since 2003 where this would be deemed to set unrealistic targets, especially in the context of prevailing economic conditions. It would be more realistic for dwelling requirements in the land allocation DPD to commence at a date more consistent with the prescribed maximum time span of 15 years. Given the plan runs to 2025, this would suggest 2010 as a more appropriate baseline.

1.5 The Land allocation DPD is inconsistent and misleading where Para 1.2 states “the ambition is to deliver 400 dwellings...each year until 2025”. This fails to make clear that housing shortfalls will be rolled forward from 2003 until the end of the plan so that the actual target for each year will be significantly higher than 400.

1.6 The land allocation DPD is informed by a core strategy for which fundamental planning assumptions relating to population growth are inconsistent and irreconcilable with up-to-date and localised data. SLDC core strategy 2010 Para CS 1.4 states “The total population of the area of South Lakeland District is around 105,000...The population (of South Lakeland) is projected to grow to around 117,000 by 2026”. However, three POPGROUP scenarios by the Cumbria Intelligence Observatory (2011 refresh) quoted as part of the evidence base for the land allocation DPD (SHMA 2011) estimate the population by 2029 to be between 99,500 and 106,003.

2.0 Public consultation has failed to deliver appropriate, sufficient and effective methods of engagement.

2.1 Tests of Soundness failed:
Justified
• Participation. The consultation process has not allowed for effective engagement of all interested parties.

2.2 SLDC has failed to deliver against the criteria set out in its Statement of Community Involvement (SCI) and has not complied with the wider requirements for public participation set out in:
• PPS12 (and the National Planning Policy Framework which replaces it)
• UNECE Convention on Access to Information, Public Participation in Decision-Making and Access to Justice in Environmental Matters.
• Community involvement in planning: The Government’s objectives.

2.3 Specifically, SLDC has failed to deliver appropriate, sufficient and effective methods of engagement in response to the needs of our community, not least for the under-represented or vulnerable elements of the community such as the young, the disabled and the elderly.

2.4 The presentation of the Land Allocation DPD and the supporting evidence base has not been made in such a way as to allow scrutiny by all groups in the community. The public have been asked to submit to the soundness of a DPD comprising approximately 460 technical documents covering 14,500 pages (visually, this would represent a stack of A4 paper approx. 1.5 metres tall). SLDC chose only to allow for the minimally prescribed consultation period of six weeks.

2.5 Residents who are less inclined or able to read through a complex set of documents containing thousands of pages of text, tables, maps and appendices (either in paper form or via the SLDC website) have therefore been broadly excluded from making any substantial comments or submissions which are deemed to be ‘viable’ by SLDC.

2.6 Any critical study into the quality, depth and range of public responses to the consultations will evidence that the poor presentation of data by SLDC has been a significant barrier to effective democratic scrutiny and a broad-based consultation.

2.7 The thematic presentation of evidence by SLDC across documents and archives has severely limited the efficient study of the DPD on a settlement by settlement basis. In general this has meant members of the public have had to ‘sift’ through a far greater volume of documents in order to assess the whole DPD from the perspective of their own community. This could have been remedied by the creation of complimentary, ‘settlement-based’ presentations.

2.8 As it has failed to be creative in the way it reaches out to all parts of the community, participation has been limited to the usual ‘informed and active minority’.

2.8 Crucially, the disenfranchisement of the older generation from the consultation process has meant that a significant percentage of the population has been under-represented (where currently 29% of the population of South Lakeland is over 60).

2.9 There is little or no evidence that the council has taken advantage of innovative and relevant channels of participation for younger members of the community such as through the use of social media sites like Facebook or Twitter, or through short message service (SMS) alerts and updates.

2.10 Where SLDC have engaged with the public in face to face meetings in the community, it has been with a “presentational style” of plans to be delivered, rather than of options for consultation. Witnesses attest that in response to challenges, SLDC have been overtly confrontational at public meetings. For example at the Milnthorpe Parish Council consultation on 14th March 2011, senior SLDC representatives advised that the plans will be delivered ‘regardless of opposition’. Similar responses have been noted elsewhere such as at Ulverston. Therefore, despite an outward impression of a robust consultation process, it could be said this has simply been a ‘tick-the-box’ exercise.

2.11 There is no evidence that public submissions to the earlier consultations have been taken into consideration in any meaningful way when preparing the final land allocation document. To the contrary, there are instances where additional sites have been added or numbers of dwellings increased in areas where submissions were made opposing original plans.

2.12 It is clear from analysis into the replies provided by SLDC to the submissions made to previous land allocation consultations that responses have been on the whole formulaic and could in no way be deemed to be considered or have sufficient depth to render them objective or useful.

2.13 The SCI also outlines the use of real-time 3D computer modelling to assist communities with visualising the potential impact of SLDC proposals. However, there is no evidence that this has been effectively delivered at any part of the process.

2.14 The SLDC have failed to provide appropriate and relevant supporting information in conjunction with the DPD for respondents to consider its soundness in the context of wider regional and sub-regional groups, strategies, policies and initiatives such as the Cumbria Economic Strategy, Cumbria Local Investment Plan, the Cumbria Local Enterprise Partnership, the Eden and South Lakeland Forward Delivery Plan, Cumbria Sub Regional Housing Group or the Third Local Transport Plan for Cumbria (LPT3).

2.15 The delivery of the consultation by SLDC has resulted in a sense of detachment from the planning process as many residents feel marginalised by an ‘indifferent approach’ to their opinions and aspirations for their neighbourhoods. Communities have not been treated as stake-holders in the future success of their towns and villages. This is contrary to current and evolving national policy regarding localism and ‘big society’.


3.0 The plan has not adequately explored alternative options for the appropriate and suitable delivery of affordable housing other than by private sector development ‘gains’.

3.1 Tests of Soundness failed:
Justified
• Research / fact finding – The choices made in the plan are not backed by facts / credible evidence base.
• Assumptions are not reasonable and justified.
• The LPA’s chosen approach is not the most appropriate given the reasonable alternatives.
Effective
• Not Deliverable – Evidence does not show how policies will meet the objectives.
• Timescales are not realistic with regard to the delivery of affordable housing.

3.2 It is not clear from the SHMA how it derives a recommended percentage split between affordable and open market dwellings of 35% / 65%.

3.3 It is highly questionable whether the SHMA household survey of housing need which forms part of the evidence base could be found to be robust or legally defensible. The survey which helps to inform the level of affordable need returned a response rate of 4363 which represents less than 10% of the total number of dwellings in the survey area. Given the margin of error which could be applied to the utilised technique of ‘weighted and grossed responses’, any adopted policy based on this survey could be found to be ‘unsound’.

3.4 It would seem incongruous that Milnthorpe as a designated key service centre only has an identified need for 2 affordable dwellings per annum in comparison to other KSC’s and settlements. This would cast further doubt on the accuracy of the SHMA.

3.5 The evidence base supporting the land allocation DPD fails to make explicit or compare and contrast alternative mechanisms for the delivery of affordable housing other than by private sector development ‘gains’. Therefore we would find that assumptions which are used to justify the ‘scale’ of proposed private sector development in the land allocation DPD as the preferred or only method of delivering affordable housing not to be reasonable or justified. In fact housing market studies would suggest that this approach could further exacerbate the need for affordable dwellings where an influx of development schemes leads to a generalised increase in private sector house prices.

3.7 We would not consider that the over-reliance on private sector development ‘gains’ for the provision of affordable housing could be deemed to be effective, in that the economic outlook in the short to medium term would render this policy undeliverable within a realistic timeframe.

4.0 The plan fails to consider adequately the balance between settlements or the sustainability of site options across key service centres.

4.1 Tests of Soundness failed:
Justified
• Research / fact finding – The choices made in the plan are not backed by facts / credible evidence base.
• Assumptions are not reasonable and justified.
• The LPA’s chosen approach is not the most appropriate given the reasonable alternatives.
• The sustainability appraisal does not show how the different options perform and is it not clear that sustainability considerations informed the content of the DPD from the start.
• The strategy does not take forward the regional context reflecting local issues and objectives.
• The plan does not adequately reflect the concept of spatial planning.

4.2 We would firstly highlight that there are unexplained inconsistencies between data sets utilised in DPD’s and supporting documentation for existing housing stock in key service centres. This is important where they are used to pro-rata allocations between the key service centres of Grange over Sands, Milnthorpe and Kirkby Lonsdale. For example, the Land Allocation DPD advises there are 738 dwellings in Kirkby Lonsdale (Land Allocation DPD p16). However, the SHMA uses a figure of 1268 (SHMA Oct 2011 Appendix A Table A2). Similar discrepancies have been recorded for Milnthorpe. Where these anomalies have not been explained it is not clear that any policies in the land allocation DPD based on analysis of settlement size are credible.

4.3 The plan does not provide for the adequate or relative comparison of sustainability criteria between or across key service centres (KSC’s) and therefore it is not clear that sustainability considerations have informed the content of the DPD. Where some sites and KSC characteristics mean some are inherently more sustainable than others, strategy has not allowed for an objective appraisal of sustainability in a localised context across this settlement grouping.

4.4 In the Inspector’s report of the core strategy, it is stated that “more detailed work at balancing local needs and environmental capacities outside the principal service centres can properly be conducted as part of the Allocation of Land DPD process”. Also that in respect to Grange and the Cartmel peninsular, that “further detail will be necessary to firm up specific plans but in my mind the level of further detail necessary is more appropriate to the forthcoming allocation of land DPD”. It is clear that the land allocation DPD or supporting documentation fails to adequately provide for the level of required analysis in this regard and as such does not adequately reflect local issues and objectives.

4.5 It can be seen that relative to Milnthorpe and Kirkby Lonsdale, Grange over Sands is less favourably positioned to accept significant and sustainable development due to current infrastructure and environmental constraints peculiar to its situation on the Cartmel peninsular. It also fails to meet all the criteria of a key service centre which further detracts from its ability to accommodate large scale expansion. Where SLDC refer to development proposals at Grange over Sands as “moderate” this is clearly not the case where this represents an approximate 25% increase in the number of dwellings.

4.6 The town is less well serviced in relation to its proximity and ease of access to a trunk road or the motorway network. This is especially the case for the west of Grange where the majority of proposed sites are located. It can also be evidenced that the bulk of traffic accessing services to the east of Grange via the major road network would pass through the narrow thoroughfare of the town centre (Main Street). The core strategy which is used to inform the land allocation DPD recognises that “access to the peninsular is poor, limited to the B5277/8 looping off the A590 to run through Grange, Allithwaite and Cark, the B6271 (sic - should read B5271) from Lindale and minor roads north of Cartmel” (CS5.12). Road infrastructure in Grange cannot be easily improved due to the restrictions imposed across the town by the built environment and other constraints. Contrary to requirements of the core strategy (CS10.2 Transport impact of new development) SLDC have confirmed (March 2012) that no traffic surveys have been carried out by Cumbria County Council to inform the land allocations process in Grange, and that they (Cumbria County Council) advise that significant development in Grange may increase parking and traffic pressures. Conversely, the core strategy notes that the East (including Kirkby Lonsdale and Milnthorpe) “benefits from excellent strategic transport links. The M6 passes directly through the area” and “are easy accessible by road, Milnthorpe being situated on the junction of the A6...and Kirkby Lonsdale being situated on the A65.” (CS6.11). Where the land allocation DPD fails to provide for the level of analysis per Para 4.4 above, we would request that the inspector calls upon SLDC to ensure traffic surveys are carried out prior to adopting the proposals of the Land Allocation DPD for Grange and the Cartmel Peninsular so that the cumulative impacts of all proposed development sites on the road network can be been properly assessed and planned for.

4.7 Grange over Sands is further away from the principal service centre at Kendal relative to the other KSC’s, and it has poor access to Ulverston (using the B5278 to reach the A590 north of Haverthwaite). It is also further away from the nearest city of Lancaster.

4.8 Unlike Milnthorpe and Kirkby Lonsdale, Grange over Sands does not have a Secondary School, which is one of the key criterions for a KSC. The nearest secondary school is in the village of Cartmel. This is two miles from Grange and cannot be practically accessed by foot or by bicycle. It therefore creates a dependency on motor vehicles for pupils from Grange. School transport is provided free of charge as an exception to the LEA ‘3-mile’ policy in recognition of this fact. Children do not enjoy easy and fair access to after school activities where school transport is not provided for.

4.9 Both Milnthorpe and Kirkby Lonsdale also benefit from further education facilities which are not available to pupils in Grange. Students from Grange have to travel to Milnthorpe, Ulverston, Lancaster, Kirkby Lonsdale, Kendal or Barrow which inevitably means an increased dependency on car travel as well as a requirement for adequate public transport links which cannot be assured where service providers are under increased pressure to ensure services are economically viable.

5.0 The plan fails to conduct adequate sustainability analysis for preferred site options at Grange over Sands and allocations are not in accordance with stated policy.

5.1 Tests of Soundness failed:
Justified
• Research / fact finding – The choices made in the plan are not backed by facts / credible evidence base.
• Assumptions are not reasonable and justified.
• The LPA’s chosen approach is not the most appropriate given the reasonable alternatives.
• The sustainability appraisal does not show how the different options perform and is it not clear that sustainability considerations informed the content of the DPD from the start.
Effective
• The plan is not holistic.
• Implications for infrastructure have not been clearly identified.
• There is insufficient detail to evidence that plans are deliverable.
• It is not clear that there is the necessary commitment from external agencies to the local planning authority.

5.2 A holistic approach with respect to the selection of sustainable site options could not take place where the process of land allocation was driven by the initial invitation to landowners by SLDC to submit plots for development. This may ensure sites are deliverable but the process has necessarily precluded some options which may have scored more highly in terms of sustainability. It could be asserted that the process has been ‘reverse-engineered’ where sustainability analysis has been used to justify the inclusion of sites offered up for development, rather than to consider the merits of all sites against a set of objective criteria. We would question for instance whether the process has identified eminently sustainable sites which would need to be secured by negotiation or compulsory purchase. To this end we would ask the inspector to seek clarification from SLDC regarding the availability of all sites considered since the start of the process, and compare this to the availability of sites within the final allocation.

5.3 It is questionable whether “Accession” computer modelling techniques or other studies have correctly informed analysis of topographical and infrastructure constraints relating to proposed development sites on the western side of Grange over Sands. Doubts are raised whether it has factored features such as the gradient at Risedale Hill which provides the main link to access services in the centre of town. These considerations severely question the viability of providing pedestrian or cycle links in to town which is contrary to core strategy and national policy in promoting a reduced reliance on car use and climate change. Similarly, that the nearest secondary school is at Cartmel, which is only accessible by car or bus due to the rural nature of the road network. Both of these examples detract considerably from the sustainability of sites such as MN25M, R672M, R89 and R350M but appear not to have been factored suitably into the sustainability assessment.

5.4 SLDC has only identified one ‘key’ brown field site in Grange over Sands at Berners Pool in their final assessment of allocations. Core strategy policy CS1.1 states that development should accord to a sequential approach, first using “previously developed land within settlements”. However the land allocation DPD (4.11) states that Berners will be developed in two phases, which indicates that development across Grange will not be in accordance with the sequential policy in the CS where green field sites are developed ahead of the final phase at M378M / R381 / R383.

5.5 It is not entirely clear that sustainability criteria informed the decision to remove emerging site RN34 (land North of Grange Fell Road) from the final land allocations process. This is also supported by the fact that SLDC did not highlight any successful objections in response to the allocations consultation which forms part of the evidence base. Therefore it cannot be shown that the exclusion of this site has demonstrated a uniform and consistent approach with respect to the consideration of site allocations in Grange. Further concerns relating to the objectivity of this decision were raised when the cabinet member responsible for housing and development intimated that site RN34 could be reconsidered for inclusion in response to opposition requests to reconsider the extent of all allocations at the full council meeting on 18th January 2012. Without prejudice to the decision to remove it from consideration, we would request that the inspector investigates this matter to ensure procedures and policy were followed correctly and that this process was “sound”.

5.6 We would question whether existing planning policy has been applied consistently by SLDC with respect to the final allocations at Grange over Sands. With respect to site R672M, respondents to the allocations consultation process raised the point that development here would effectively create a precedent for continued development westwards along the north side of Allithwaite Road and towards the village of Allithwaite. It is quite clear from the SLDC map (Grange South) that in conjunction with MN25M, that neither site could be considered to be either infill or rounding off where they are extensions into open countryside. It can be seen that the existing boundary either side of Allithwaite Road currently provides for a distinct edge to the settlement of Grange along Allithwaite Road. In fact the two proposed sites would inevitably make it more difficult for SLDC to resist future development westwards on green gap sites adjacent to R672M, up to and including the new boundary described by MN25M on the south of Allithwaite Road.

5.7 It can be seen that current development plans on the western edge of Grange over Sands and on the eastern edge of Allithwaite will lead to the significant and critical erosion of an existing green gap where this currently serves the purpose of preventing further coalescence between the two settlements. This is contrary to SLDC core strategy CS8.2 regarding the protection and enhancement of landscape and settlement character and to Land Allocation DPD 4.22 which describes the need to avoid coalescence between Allithwaite and Kent’s Bank / Grange. The development of sites RN79# - mod (Allithwaite) and MN25M / R672M (Grange over Sands) will erode the green gap along Allithwaite Road to approximately 220 metres which will increase perceived and visual coalescence between the two. Critically, It will also cause an incursion of Kent’s Bank / Grange over Sands westwards between the limits of the Allithwaite parish boundary which is described to the North of Allithwaite Road and to the south of Kirkhead Road, either side of MN25M. Given the importance of maintaining the integrity of this green gap in avoiding further coalescence between Grange and Allithwaite, we would request that SLDC remove MN25M and R672M from the land allocation DPD.

5.8 Where the majority of development sites in Grange over Sands lie to the West of town (MN25M / R672M / R89 / R350M) the land allocation DPD fails to describe how safe, convenient and attractive access to the town centre by foot or cycle is provided for. The main route into town is along the B5277 where footpath provision is restricted to one narrow path along the steep and twisting incline of Risedale Hill. When describing the perceived sustainability of site MN25M, the land allocation DPD document 4.12 states that “The promenade footpath offers the opportunity to provide improved pedestrian and cycle access to the town centre.” However it fails to describe the limitations imposed on this route by the adjacent railway line which creates a significant barrier to free and unimpeded travel by foot or by cycle. Where this route is restricted by steep and narrow access points and pathways, and where it necessarily crosses under or over the railway line before reaching the town centre by underpass, a single bridge or unmanned level crossings, this route can hardly be seen to be one that would give encouragement to non-vehicular journeys between the western outskirts and the centre of town. A crucial underpass is also too low with no line of site on either side to allow for safe use by cyclists, especially in conjunction with pedestrians. We would consider there to be parallels with the planning inspectorate’s recommendation to dismiss the appeal by Harbour Castle Limited against Wycombe District Council, 14 February 2012 in relation to inadequate (unsustainable) provision of non-vehicular travel between proposed developments and the town centre. This decision was subsequently upheld by the secretary of state.

5.9 SLDC recognises that the pedestrian environment in Grange over Sands is already poor. The core strategy states “…it suffers from problems associated with the impact of the private car on the built environment. For pedestrians, the Grange over Sands environment is noticeably poor. In general terms, footpaths are narrow and there is a strong sense that the car is the dominant feature on Kents Bank Road and Main Street. Improving linkages, infrastructure and the quality of the pedestrian environment are key priorities”. However the land allocation DPD fails to make clear any coherent or detailed strategy to improve the situation in conjunction with the estimated 25% increase in the size of the town.

5.10 With regard to site R89, it can be seen that as well as being subject to the sustainability constraints already outlined for sites to the west of Grange over Sands, it is not clear that other sustainability criteria have been applied consistently or objectively. SHLAA 2009 describes the site as a “category three” site, performing least well against assessment criteria with regard to its suitability for development. However it has since been described as having met all necessary requirements and is now deemed to be eminently suitable for development. In addition, SLDC have chosen to exclude from their evidence base previous independent development studies for Grange over Sands where they do not support the findings proposed by the current land allocation DPD. With regard to site R89 both the Gillespies and Douglas Wheeler reports exclude this site from consideration for development, not least in recognition of the fact that it provides for an important open space in an otherwise built-up and now suburban landscape. The local community would look to consider this land as a ‘local green space’ under provisions afforded by the National Planning Policy Framework. Therefore we would request that R89 is not included in the land allocation DPD whilst consideration is given to this.

5.11 Site R110 is one of the last open spaces in the Grange over Sands conservation area. It has high amenity value where it provides for views across the bay and has enjoyed protection from development for this reason. Planning permission has been refused previously by SLDC who cited road infrastructure issues where there were concerns over traffic (application No. 5/91/2372). It would not therefore be consistent to allow development on this site where the only material change since refusal would have been an increase in general traffic volumes across the district. As per Para 4.6 above, no traffic surveys have been carried out to inform the land allocation process and so SLDC cannot have said to have objectively reconsidered their previous decision to refuse permission. We would request that SLDC consider the results of a detailed traffic survey before proceeding with consideration of this and other sites in the town.

5.12 Given the proximity of sites R74 and R449 to R110, it would seem logical to extend the comments made in Para 5.10 to these sites also.

5.13 We would have concern that lack of adequate environmental surveys across all sites in Grange over Sands and district have not allowed for the site selection process to be compliant with CS8.4. We are particularly concerned that protected species and those included in the Cumbria Biodiversity Action Plan have not been afforded sufficient consideration. Furthermore, detailed assessment at the site selection stage is required to determine the potential impact of proposed development on the west side of Grange at sites which are adjacent to or between internationally rare and nationally protected areas of limestone pavement. It would not be appropriate to carry out this work once a site has been ‘allocated’ as it makes it less likely that sufficient objectivity and weight would be given to findings where they recommend a site to be ‘de-allocated’.

5.14 Where it should be recognised that the development of site options in Grange over Sands pose significant issues with respect to managing surface water runoff (a good example being R89) it is clear that insufficient consideration has been given to how this significant issue would be addressed at each of the locations. We would highlight the fact that United Utilities will not make provision for accepting surface water runoff into the sewerage network and that no credible alternatives have been detailed by SLDC in the land allocation DPD where it simply expresses the need to provide remediation for the issue.

5.15 It is not evident that there is sufficient existing capacity or the financial commitment from the LEA to expand the provision of primary and secondary school places within the Grange over Sands catchment in line with the projected requirements of the land allocation DPD.

5.16 It is not evident that Cumbria County Council or the Highways Authority have given sufficient consideration to or have sufficient funds to mitigate the collective impact of development proposals across the minor and major road networks.

6. The plan does not consider the impact to the tourism-based economy of Grange over Sands
.1 Tests of Soundness failed:
Effective
• Policies are not internally consistent.

6.2 The core strategy widely refers to the importance of the tourism sector and the role it plays in maintaining the viability and vitality of towns and villages in South Lakeland. SLDC estimate that nearly a million visitors per year are attracted to the area outside the national parks, providing revenue in excess of £130 million to local businesses (2008). The Core Strategy warns that “given the problem of town centre congestion in Grange at peak times...Significantly higher traffic levels could well threaten the core economic activity of the town, namely tourism” (CS5.32).

6.3 We would not see the promotion and growth of tourism in Grange and the Cartmel Peninsular as being consistent with the scale of development plans currently described by the land allocation DPD. We would expect particular conflict to occur where continual, prolonged and intensive levels of construction activity are required to deliver the unrealistic levels of development contained in the plan. This would be particularly apparent if SLDC continue to revise upwards their annual dwelling targets to make up for previous shortfalls against already unrealistic requirements.

6.4 We would expect a gradual but long term decline in the tourist offering at Grange over sands and the surrounding district. This would inevitably have a detrimental impact on businesses and jobs as the area loses its appeal to tourists seeking respite from the traditional and busy tourist centres within the National park, or for those just seeking the elegant and quiet charm of a traditional Victorian/Edwardian seaside resort. We would assert that further, significant urbanisation of Grange would take the town beyond its environmental capacity for sustainable development and its innate charm and attractiveness as a tourist destination outside the national parks would suffer irreversible damage. This is in contravention to SLDC Policy which states the ambition of “promoting the vitality of Grange Town Centre and promoting tourism” (LADPD 4.2).

6.5 We would draw parallels to consideration given by the Planning Inspectorate when refusing planning permission at Princes Risborough (February 2012). Para 130 states “Tourism relies much on the attractiveness of the town and its setting and the development risks adversely affecting both”.

7. The plan fails to show adequate coherence and collaboration with the plans and strategies of neighbouring authorities.
7.1 Tests of Soundness failed:
Effective
• The plan does not show coherence and collaboration with the plans and strategies of neighbouring authorities.
National Policy
• The DPD contains proposals which are not consistent with national policy.

7.2 It is not apparent that SLDC have properly consulted with neighbouring authorities to ensure coherence and collaboration since the revocation of regional spatial strategies (RSS). This is in direct contravention to the requirements of national policy for a duty to cooperate on strategic priorities.

7.3 Where for instance there is a particular need for sustained private sector investment inflows into the Borough of Barrow to facilitate regeneration requirements, it is not at all clear that SLDC policy complements this requirement. In fact the setting of aggressive, unfounded and unrealistic housing targets in South Lakeland fails to show a balanced regional approach and is likely to undermine neighbouring areas particularly where it could be said that South Lakeland has an advantage in relation to its environmental setting and economic vitality derived from tourism.

7.4 Furthermore, it could be said that SLDC planning targets have taken advantage of traditional restrictions and reluctances to perpetuate a lower housing provision in the adjacent National Parks. It could be seen that this policy is in detriment to the vitality and continued viability of settlements in these areas and would ensure this situation is entrenched where they do not attract private investment or a fair proportion of the new homes bonus.

YES, I wish to participate at the oral examination

As part of its submission, Grange and District Action Group (GADAG) have provided written confirmation to SLDC from 110 members that GADAG should represent them at the oral examination.

Please notify me

I have read the guidance notes

1.9

No

The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.

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.

Submission Overview....

It is not at all evident that SLDC have meaningfully cooperated with neighbouring authorities in the preparation of their local plan. .....

Summary of objections to soundness

2. Public consultation has failed to deliver appropriate, sufficient and effective methods of engagement.

Public consultation has failed to deliver appropriate, sufficient and effective methods of engagement

2.1 Tests of Soundness failed:
Justified
• Participation. The consultation process has not allowed for effective engagement of all interested parties.

2.2 SLDC has failed to deliver against the criteria set out in its Statement of Community Involvement (SCI) and has not complied with the wider requirements for public participation set out in:
• PPS12 (and the National Planning Policy Framework which replaces it)
• UNECE Convention on Access to Information, Public Participation in Decision-Making and Access to Justice in Environmental Matters.
• Community involvement in planning: The Government’s objectives.

2.3 Specifically, SLDC has failed to deliver appropriate, sufficient and effective methods of engagement in response to the needs of our community, not least for the under-represented or vulnerable elements of the community such as the young, the disabled and the elderly.

2.4 The presentation of the Land Allocation DPD and the supporting evidence base has not been made in such a way as to allow scrutiny by all groups in the community. The public have been asked to submit to the soundness of a DPD comprising approximately 460 technical documents covering 14,500 pages (visually, this would represent a stack of A4 paper approx. 1.5 metres tall). SLDC chose only to allow for the minimally prescribed consultation period of six weeks.

2.5 Residents who are less inclined or able to read through a complex set of documents containing thousands of pages of text, tables, maps and appendices (either in paper form or via the SLDC website) have therefore been broadly excluded from making any substantial comments or submissions which are deemed to be ‘viable’ by SLDC.

2.6 Any critical study into the quality, depth and range of public responses to the consultations will evidence that the poor presentation of data by SLDC has been a significant barrier to effective democratic scrutiny and a broad-based consultation.

2.7 The thematic presentation of evidence by SLDC across documents and archives has severely limited the efficient study of the DPD on a settlement by settlement basis. In general this has meant members of the public have had to ‘sift’ through a far greater volume of documents in order to assess the whole DPD from the perspective of their own community. This could have been remedied by the creation of complimentary, ‘settlement-based’ presentations.

2.8 As it has failed to be creative in the way it reaches out to all parts of the community, participation has been limited to the usual ‘informed and active minority’.

2.8 Crucially, the disenfranchisement of the older generation from the consultation process has meant that a significant percentage of the population has been under-represented (where currently 29% of the population of South Lakeland is over 60).

2.9 There is little or no evidence that the council has taken advantage of innovative and relevant channels of participation for younger members of the community such as through the use of social media sites like Facebook or Twitter, or through short message service (SMS) alerts and updates.

2.10 Where SLDC have engaged with the public in face to face meetings in the community, it has been with a “presentational style” of plans to be delivered, rather than of options for consultation. Witnesses attest that in response to challenges, SLDC have been overtly confrontational at public meetings. For example at the Milnthorpe Parish Council consultation on 14th March 2011, senior SLDC representatives advised that the plans will be delivered ‘regardless of opposition’. Similar responses have been noted elsewhere such as at Ulverston. Therefore, despite an outward impression of a robust consultation process, it could be said this has simply been a ‘tick-the-box’ exercise.......

2.13 The SCI also outlines the use of real-time 3D computer modelling to assist communities with visualising the potential impact of SLDC proposals. However, there is no evidence that this has been effectively delivered at any part of the process.

2.14 The SLDC have failed to provide appropriate and relevant supporting information in conjunction with the DPD for respondents to consider its soundness in the context of wider regional and sub-regional groups, strategies, policies and initiatives such as the Cumbria Economic Strategy, Cumbria Local Investment Plan, the Cumbria Local Enterprise Partnership, the Eden and South Lakeland Forward Delivery Plan, Cumbria Sub Regional Housing Group or the Third Local Transport Plan for Cumbria (LPT3).

2.15 The delivery of the consultation by SLDC has resulted in a sense of detachment from the planning process as many residents feel marginalised by an ‘indifferent approach’ to their opinions and aspirations for their neighbourhoods. Communities have not been treated as stake-holders in the future success of their towns and villages. This is contrary to current and evolving national policy regarding localism and ‘big society’.

YES, I wish to participate at the oral examination

As part of its submission, Grange and District Action Group (GADAG) have provided written confirmation to SLDC from 110 members that GADAG should represent them at the oral examination.

Please notify me

I have read the guidance notes

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

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 DPD is not consistent with national policy.

Summary of objections to soundness

5. The plan fails to conduct adequate sustainability analysis for preferred site options at Grange over Sands and allocations are not in accordance with stated policy

5.0 The plan fails to conduct adequate sustainability analysis for preferred site options at Grange over Sands and allocations are not in accordance with stated policy.

5.1 Tests of Soundness failed:
Justified
• Research / fact finding – The choices made in the plan are not backed by facts / credible evidence base.
• Assumptions are not reasonable and justified.
• The LPA’s chosen approach is not the most appropriate given the reasonable alternatives.
• The sustainability appraisal does not show how the different options perform and is it not clear that sustainability considerations informed the content of the DPD from the start.
Effective
• The plan is not holistic.
• Implications for infrastructure have not been clearly identified.
• There is insufficient detail to evidence that plans are deliverable.
• It is not clear that there is the necessary commitment from external agencies to the local planning authority......

5.4 SLDC has only identified one ‘key’ brown field site in Grange over Sands at Berners Pool in their final assessment of allocations. Core strategy policy CS1.1 states that development should accord to a sequential approach, first using “previously developed land within settlements”. However the land allocation DPD (4.11) states that Berners will be developed in two phases, which indicates that development across Grange will not be in accordance with the sequential policy in the CS where green field sites are developed ahead of the final phase at M378M / R381 / R383......

5.6 We would question whether existing planning policy has been applied consistently by SLDC with respect to the final allocations at Grange over Sands. With respect to site R672M, respondents to the allocations consultation process raised the point that development here would effectively create a precedent for continued development westwards along the north side of Allithwaite Road and towards the village of Allithwaite. It is quite clear from the SLDC map (Grange South) that in conjunction with MN25M, that neither site could be considered to be either infill or rounding off where they are extensions into open countryside. It can be seen that the existing boundary either side of Allithwaite Road currently provides for a distinct edge to the settlement of Grange along Allithwaite Road. In fact the two proposed sites would inevitably make it more difficult for SLDC to resist future development westwards on green gap sites adjacent to R672M, up to and including the new boundary described by MN25M on the south of Allithwaite Road....

5.7 It can be seen that current development plans on the western edge of Grange over Sands and on the eastern edge of Allithwaite will lead to the significant and critical erosion of an existing green gap where this currently serves the purpose of preventing further coalescence between the two settlements. This is contrary to SLDC core strategy CS8.2 regarding the protection and enhancement of landscape and settlement character and to Land Allocation DPD 4.22 which describes the need to avoid coalescence between Allithwaite and Kent’s Bank / Grange. .....

5.9 SLDC recognises that the pedestrian environment in Grange over Sands is already poor. The core strategy states “…it suffers from problems associated with the impact of the private car on the built environment. For pedestrians, the Grange over Sands environment is noticeably poor. In general terms, footpaths are narrow and there is a strong sense that the car is the dominant feature on Kents Bank Road and Main Street. Improving linkages, infrastructure and the quality of the pedestrian environment are key priorities”. However the land allocation DPD fails to make clear any coherent or detailed strategy to improve the situation in conjunction with the estimated 25% increase in the size of the town.....

5.11 ............ As per Para 4.6 above, no traffic surveys have been carried out to inform the land allocation process and so SLDC cannot have said to have objectively reconsidered their previous decision to refuse permission. We would request that SLDC consider the results of a detailed traffic survey before proceeding with consideration of this and other sites in the town.....

5.13 We would have concern that lack of adequate environmental surveys across all sites in Grange over Sands and district have not allowed for the site selection process to be compliant with CS8.4. We are particularly concerned that protected species and those included in the Cumbria Biodiversity Action Plan have not been afforded sufficient consideration. Furthermore, detailed assessment at the site selection stage is required to determine the potential impact of proposed development on the west side of Grange at sites which are adjacent to or between internationally rare and nationally protected areas of limestone pavement. It would not be appropriate to carry out this work once a site has been ‘allocated’ as it makes it less likely that sufficient objectivity and weight would be given to findings where they recommend a site to be ‘de-allocated’.

5.14 Where it should be recognised that the development of site options in Grange over Sands pose significant issues with respect to managing surface water runoff (a good example being R89) it is clear that insufficient consideration has been given to how this significant issue would be addressed at each of the locations. We would highlight the fact that United Utilities will not make provision for accepting surface water runoff into the sewerage network and that no credible alternatives have been detailed by SLDC in the land allocation DPD where it simply expresses the need to provide remediation for the issue.....

5.15 It is not evident that there is sufficient existing capacity or the financial commitment from the LEA to expand the provision of primary and secondary school places within the Grange over Sands catchment in line with the projected requirements of the land allocation DPD.

5.16 It is not evident that Cumbria County Council or the Highways Authority have given sufficient consideration to or have sufficient funds to mitigate the collective impact of development proposals across the minor and major road networks.

6. The plan does not consider the impact to the tourism-based economy of Grange over Sands

6.1 Tests of Soundness failed:
Effective
• Policies are not internally consistent.

6.2 The core strategy widely refers to the importance of the tourism sector and the role it plays in maintaining the viability and vitality of towns and villages in South Lakeland. SLDC estimate that nearly a million visitors per year are attracted to the area outside the national parks, providing revenue in excess of £130 million to local businesses (2008). The Core Strategy warns that “given the problem of town centre congestion in Grange at peak times...Significantly higher traffic levels could well threaten the core economic activity of the town, namely tourism” (CS5.32).

6.3 We would not see the promotion and growth of tourism in Grange and the Cartmel Peninsular as being consistent with the scale of development plans currently described by the land allocation DPD. We would expect particular conflict to occur where continual, prolonged and intensive levels of construction activity are required to deliver the unrealistic levels of development contained in the plan. This would be particularly apparent if SLDC continue to revise upwards their annual dwelling targets to make up for previous shortfalls against already unrealistic requirements.

6.4 We would expect a gradual but long term decline in the tourist offering at Grange over sands and the surrounding district. This would inevitably have a detrimental impact on businesses and jobs as the area loses its appeal to tourists seeking respite from the traditional and busy tourist centres within the National park, or for those just seeking the elegant and quiet charm of a traditional Victorian/Edwardian seaside resort. We would assert that further, significant urbanisation of Grange would take the town beyond its environmental capacity for sustainable development and its innate charm and attractiveness as a tourist destination outside the national parks would suffer irreversible damage. This is in contravention to SLDC Policy which states the ambition of “promoting the vitality of Grange Town Centre and promoting tourism” (LADPD 4.2).

6.5 We would draw parallels to consideration given by the Planning Inspectorate when refusing planning permission at Princes Risborough (February 2012). Para 130 states “Tourism relies much on the attractiveness of the town and its setting and the development risks adversely affecting both”.

YES, I wish to participate at the oral examination

As part of its submission, Grange and District Action Group (GADAG) have provided written confirmation to SLDC from 110 members that GADAG should represent them at the oral examination.

Please notify me

I have read the guidance notes

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

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 DPD is not consistent with national policy.

5.0 The plan fails to conduct adequate sustainability analysis for preferred site options at Grange over Sands and allocations are not in accordance with stated policy.

5.1 Tests of Soundness failed:
Justified
• Research / fact finding – The choices made in the plan are not backed by facts / credible evidence base.
• Assumptions are not reasonable and justified.
• The LPA’s chosen approach is not the most appropriate given the reasonable alternatives.
• The sustainability appraisal does not show how the different options perform and is it not clear that sustainability considerations informed the content of the DPD from the start.
Effective
• The plan is not holistic.
• Implications for infrastructure have not been clearly identified.
• There is insufficient detail to evidence that plans are deliverable.
• It is not clear that there is the necessary commitment from external agencies to the local planning authority......

5.4 SLDC has only identified one ‘key’ brown field site in Grange over Sands at Berners Pool in their final assessment of allocations. Core strategy policy CS1.1 states that development should accord to a sequential approach, first using “previously developed land within settlements”. However the land allocation DPD (4.11) states that Berners will be developed in two phases, which indicates that development across Grange will not be in accordance with the sequential policy in the CS where green field sites are developed ahead of the final phase at M378M / R381 / R383........

5.9 SLDC recognises that the pedestrian environment in Grange over Sands is already poor. The core strategy states “…it suffers from problems associated with the impact of the private car on the built environment. For pedestrians, the Grange over Sands environment is noticeably poor. In general terms, footpaths are narrow and there is a strong sense that the car is the dominant feature on Kents Bank Road and Main Street. Improving linkages, infrastructure and the quality of the pedestrian environment are key priorities”. However the land allocation DPD fails to make clear any coherent or detailed strategy to improve the situation in conjunction with the estimated 25% increase in the size of the town.....

5.11 ...........As per Para 4.6 (see rep 8), no traffic surveys have been carried out to inform the land allocation process and so SLDC cannot have said to have objectively reconsidered their previous decision to refuse permission. We would request that SLDC consider the results of a detailed traffic survey before proceeding with consideration of this and other sites in the town.....

5.13 We would have concern that lack of adequate environmental surveys across all sites in Grange over Sands and district have not allowed for the site selection process to be compliant with CS8.4. We are particularly concerned that protected species and those included in the Cumbria Biodiversity Action Plan have not been afforded sufficient consideration. Furthermore, detailed assessment at the site selection stage is required to determine the potential impact of proposed development on the west side of Grange at sites which are adjacent to or between internationally rare and nationally protected areas of limestone pavement. It would not be appropriate to carry out this work once a site has been ‘allocated’ as it makes it less likely that sufficient objectivity and weight would be given to findings where they recommend a site to be ‘de-allocated’.

5.14 Where it should be recognised that the development of site options in Grange over Sands pose significant issues with respect to managing surface water runoff (a good example being R89) it is clear that insufficient consideration has been given to how this significant issue would be addressed at each of the locations. We would highlight the fact that United Utilities will not make provision for accepting surface water runoff into the sewerage network and that no credible alternatives have been detailed by SLDC in the land allocation DPD where it simply expresses the need to provide remediation for the issue.

5.15 It is not evident that there is sufficient existing capacity or the financial commitment from the LEA to expand the provision of primary and secondary school places within the Grange over Sands catchment in line with the projected requirements of the land allocation DPD.

5.16 It is not evident that Cumbria County Council or the Highways Authority have given sufficient consideration to or have sufficient funds to mitigate the collective impact of development proposals across the minor and major road networks.

6. The plan does not consider the impact to the tourism-based economy of Grange over Sands

6.1 Tests of Soundness failed:
Effective
• Policies are not internally consistent.

6.2 The core strategy widely refers to the importance of the tourism sector and the role it plays in maintaining the viability and vitality of towns and villages in South Lakeland. SLDC estimate that nearly a million visitors per year are attracted to the area outside the national parks, providing revenue in excess of £130 million to local businesses (2008). The Core Strategy warns that “given the problem of town centre congestion in Grange at peak times...Significantly higher traffic levels could well threaten the core economic activity of the town, namely tourism” (CS5.32).

6.3 We would not see the promotion and growth of tourism in Grange and the Cartmel Peninsular as being consistent with the scale of development plans currently described by the land allocation DPD. We would expect particular conflict to occur where continual, prolonged and intensive levels of construction activity are required to deliver the unrealistic levels of development contained in the plan. This would be particularly apparent if SLDC continue to revise upwards their annual dwelling targets to make up for previous shortfalls against already unrealistic requirements.

6.4 We would expect a gradual but long term decline in the tourist offering at Grange over sands and the surrounding district. This would inevitably have a detrimental impact on businesses and jobs as the area loses its appeal to tourists seeking respite from the traditional and busy tourist centres within the National park, or for those just seeking the elegant and quiet charm of a traditional Victorian/Edwardian seaside resort. We would assert that further, significant urbanisation of Grange would take the town beyond its environmental capacity for sustainable development and its innate charm and attractiveness as a tourist destination outside the national parks would suffer irreversible damage. This is in contravention to SLDC Policy which states the ambition of “promoting the vitality of Grange Town Centre and promoting tourism” (LADPD 4.2).

6.5 We would draw parallels to consideration given by the Planning Inspectorate when refusing planning permission at Princes Risborough (February 2012). Para 130 states “Tourism relies much on the attractiveness of the town and its setting and the development risks adversely affecting both”.

YES, I wish to participate at the oral examination

As part of its submission, Grange and District Action Group (GADAG) have provided written confirmation to SLDC from 110 members that GADAG should represent them at the oral examination.

Please notify me

I have read the guidance notes

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

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 DPD is not consistent with national policy.

Summary of objections to soundness

5. The plan fails to conduct adequate sustainability analysis for preferred site options at Grange over Sands and allocations are not in accordance with stated policy.

6. The plan does not consider the impact to the tourism-based economy of Grange over Sands........

5.1 Tests of Soundness failed:
Justified
• Research / fact finding – The choices made in the plan are not backed by facts / credible evidence base.
• Assumptions are not reasonable and justified.
• The LPA’s chosen approach is not the most appropriate given the reasonable alternatives.
• The sustainability appraisal does not show how the different options perform and is it not clear that sustainability considerations informed the content of the DPD from the start.
Effective
• The plan is not holistic.
• Implications for infrastructure have not been clearly identified.
• There is insufficient detail to evidence that plans are deliverable.
• It is not clear that there is the necessary commitment from external agencies to the local planning authority.


5.6 We would question whether existing planning policy has been applied consistently by SLDC with respect to the final allocations at Grange over Sands. With respect to site R672M, respondents to the allocations consultation process raised the point that development here would effectively create a precedent for continued development westwards along the north side of Allithwaite Road and towards the village of Allithwaite. It is quite clear from the SLDC map (Grange South) that in conjunction with MN25M, that neither site could be considered to be either infill or rounding off where they are extensions into open countryside. It can be seen that the existing boundary either side of Allithwaite Road currently provides for a distinct edge to the settlement of Grange along Allithwaite Road. In fact the two proposed sites would inevitably make it more difficult for SLDC to resist future development westwards on green gap sites adjacent to R672M, up to and including the new boundary described by MN25M on the south of Allithwaite Road.

5.7 It can be seen that current development plans on the western edge of Grange over Sands and on the eastern edge of Allithwaite will lead to the significant and critical erosion of an existing green gap where this currently serves the purpose of preventing further coalescence between the two settlements. This is contrary to SLDC core strategy CS8.2 regarding the protection and enhancement of landscape and settlement character and to Land Allocation DPD 4.22 which describes the need to avoid coalescence between Allithwaite and Kent’s Bank / Grange. The development of sites RN79# - mod (Allithwaite) and MN25M / R672M (Grange over Sands) will erode the green gap along Allithwaite Road to approximately 220 metres which will increase perceived and visual coalescence between the two. Critically, It will also cause an incursion of Kent’s Bank / Grange over Sands westwards between the limits of the Allithwaite parish boundary which is described to the North of Allithwaite Road and to the south of Kirkhead Road, either side of MN25M. Given the importance of maintaining the integrity of this green gap in avoiding further coalescence between Grange and Allithwaite, we would request that SLDC remove MN25M and R672M from the land allocation DPD.

5.8 Where the majority of development sites in Grange over Sands lie to the West of town (MN25M / R672M / R89 / R350M) the land allocation DPD fails to describe how safe, convenient and attractive access to the town centre by foot or cycle is provided for. The main route into town is along the B5277 where footpath provision is restricted to one narrow path along the steep and twisting incline of Risedale Hill. When describing the perceived sustainability of site MN25M, the land allocation DPD document 4.12 states that “The promenade footpath offers the opportunity to provide improved pedestrian and cycle access to the town centre.” However it fails to describe the limitations imposed on this route by the adjacent railway line which creates a significant barrier to free and unimpeded travel by foot or by cycle. Where this route is restricted by steep and narrow access points and pathways, and where it necessarily crosses under or over the railway line before reaching the town centre by underpass, a single bridge or unmanned level crossings, this route can hardly be seen to be one that would give encouragement to non-vehicular journeys between the western outskirts and the centre of town. A crucial underpass is also too low with no line of site on either side to allow for safe use by cyclists, especially in conjunction with pedestrians. We would consider there to be parallels with the planning inspectorate’s recommendation to dismiss the appeal by Harbour Castle Limited against Wycombe District Council, 14 February 2012 in relation to inadequate (unsustainable) provision of non-vehicular travel between proposed developments and the town centre. This decision was subsequently upheld by the secretary of state.

5.9 SLDC recognises that the pedestrian environment in Grange over Sands is already poor. The core strategy states “…it suffers from problems associated with the impact of the private car on the built environment. For pedestrians, the Grange over Sands environment is noticeably poor. In general terms, footpaths are narrow and there is a strong sense that the car is the dominant feature on Kents Bank Road and Main Street. Improving linkages, infrastructure and the quality of the pedestrian environment are key priorities”. However the land allocation DPD fails to make clear any coherent or detailed strategy to improve the situation in conjunction with the estimated 25% increase in the size of the town...........

5.11 ....... As per Para 4.6 (Rep 8), no traffic surveys have been carried out to inform the land allocation process and so SLDC cannot have said to have objectively reconsidered their previous decision to refuse permission. We would request that SLDC consider the results of a detailed traffic survey before proceeding with consideration of this and other sites in the town....

5.13 We would have concern that lack of adequate environmental surveys across all sites in Grange over Sands and district have not allowed for the site selection process to be compliant with CS8.4. We are particularly concerned that protected species and those included in the Cumbria Biodiversity Action Plan have not been afforded sufficient consideration. Furthermore, detailed assessment at the site selection stage is required to determine the potential impact of proposed development on the west side of Grange at sites which are adjacent to or between internationally rare and nationally protected areas of limestone pavement. It would not be appropriate to carry out this work once a site has been ‘allocated’ as it makes it less likely that sufficient objectivity and weight would be given to findings where they recommend a site to be ‘de-allocated’.
5.14 Where it should be recognised that the development of site options in Grange over Sands pose significant issues with respect to managing surface water runoff (a good example being R89) it is clear that insufficient consideration has been given to how this significant issue would be addressed at each of the locations. We would highlight the fact that United Utilities will not make provision for accepting surface water runoff into the sewerage network and that no credible alternatives have been detailed by SLDC in the land allocation DPD where it simply expresses the need to provide remediation for the issue.
5.15 It is not evident that there is sufficient existing capacity or the financial commitment from the LEA to expand the provision of primary and secondary school places within the Grange over Sands catchment in line with the projected requirements of the land allocation DPD.
5.16 It is not evident that Cumbria County Council or the Highways Authority have given sufficient consideration to or have sufficient funds to mitigate the collective impact of development proposals across the minor and major road networks.

6. The plan does not consider the impact to the tourism-based economy of Grange over Sands

6.1 Tests of Soundness failed:
Effective
• Policies are not internally consistent.

6.2 The core strategy widely refers to the importance of the tourism sector and the role it plays in maintaining the viability and vitality of towns and villages in South Lakeland. SLDC estimate that nearly a million visitors per year are attracted to the area outside the national parks, providing revenue in excess of £130 million to local businesses (2008). The Core Strategy warns that “given the problem of town centre congestion in Grange at peak times...Significantly higher traffic levels could well threaten the core economic activity of the town, namely tourism” (CS5.32).

6.3 We would not see the promotion and growth of tourism in Grange and the Cartmel Peninsular as being consistent with the scale of development plans currently described by the land allocation DPD. We would expect particular conflict to occur where continual, prolonged and intensive levels of construction activity are required to deliver the unrealistic levels of development contained in the plan. This would be particularly apparent if SLDC continue to revise upwards their annual dwelling targets to make up for previous shortfalls against already unrealistic requirements.

6.4 We would expect a gradual but long term decline in the tourist offering at Grange over sands and the surrounding district. This would inevitably have a detrimental impact on businesses and jobs as the area loses its appeal to tourists seeking respite from the traditional and busy tourist centres within the National park, or for those just seeking the elegant and quiet charm of a traditional Victorian/Edwardian seaside resort. We would assert that further, significant urbanisation of Grange would take the town beyond its environmental capacity for sustainable development and its innate charm and attractiveness as a tourist destination outside the national parks would suffer irreversible damage. This is in contravention to SLDC Policy which states the ambition of “promoting the vitality of Grange Town Centre and promoting tourism” (LADPD 4.2).

6.5 We would draw parallels to consideration given by the Planning Inspectorate when refusing planning permission at Princes Risborough (February 2012). Para 130 states “Tourism relies much on the attractiveness of the town and its setting and the development risks adversely affecting both”.

YES, I wish to participate at the oral examination

As part of its submission, Grange and District Action Group (GADAG) have provided written confirmation to SLDC from 110 members that GADAG should represent them at the oral examination.

Please notify me

I have read the guidance notes

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

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 DPD is not consistent with national policy.

Summary of objections to soundness

5. The plan fails to conduct adequate sustainability analysis for preferred site options at Grange over Sands and allocations are not in accordance with stated policy.

6. The plan does not consider the impact to the tourism-based economy of Grange over Sands..............


5.1 Tests of Soundness failed:
Justified
• Research / fact finding – The choices made in the plan are not backed by facts / credible evidence base.
• Assumptions are not reasonable and justified.
• The LPA’s chosen approach is not the most appropriate given the reasonable alternatives.
• The sustainability appraisal does not show how the different options perform and is it not clear that sustainability considerations informed the content of the DPD from the start.
Effective
• The plan is not holistic.
• Implications for infrastructure have not been clearly identified.
• There is insufficient detail to evidence that plans are deliverable.
• It is not clear that there is the necessary commitment from external agencies to the local planning authority..........

5.8 Where the majority of development sites in Grange over Sands lie to the West of town (MN25M / R672M / R89 / R350M) the land allocation DPD fails to describe how safe, convenient and attractive access to the town centre by foot or cycle is provided for. The main route into town is along the B5277 where footpath provision is restricted to one narrow path along the steep and twisting incline of Risedale Hill. When describing the perceived sustainability of site MN25M, the land allocation DPD document 4.12 states that “The promenade footpath offers the opportunity to provide improved pedestrian and cycle access to the town centre.” However it fails to describe the limitations imposed on this route by the adjacent railway line which creates a significant barrier to free and unimpeded travel by foot or by cycle. Where this route is restricted by steep and narrow access points and pathways, and where it necessarily crosses under or over the railway line before reaching the town centre by underpass, a single bridge or unmanned level crossings, this route can hardly be seen to be one that would give encouragement to non-vehicular journeys between the western outskirts and the centre of town. A crucial underpass is also too low with no line of site on either side to allow for safe use by cyclists, especially in conjunction with pedestrians. We would consider there to be parallels with the planning inspectorate’s recommendation to dismiss the appeal by Harbour Castle Limited against Wycombe District Council, 14 February 2012 in relation to inadequate (unsustainable) provision of non-vehicular travel between proposed developments and the town centre. This decision was subsequently upheld by the secretary of state.

5.9 SLDC recognises that the pedestrian environment in Grange over Sands is already poor. The core strategy states “…it suffers from problems associated with the impact of the private car on the built environment. For pedestrians, the Grange over Sands environment is noticeably poor. In general terms, footpaths are narrow and there is a strong sense that the car is the dominant feature on Kents Bank Road and Main Street. Improving linkages, infrastructure and the quality of the pedestrian environment are key priorities”. However the land allocation DPD fails to make clear any coherent or detailed strategy to improve the situation in conjunction with the estimated 25% increase in the size of the town.

5.11................As per Para 4.6 (Rep 8), no traffic surveys have been carried out to inform the land allocation process and so SLDC cannot have said to have objectively reconsidered their previous decision to refuse permission. We would request that SLDC consider the results of a detailed traffic survey before proceeding with consideration of this and other sites in the town............

5.13 We would have concern that lack of adequate environmental surveys across all sites in Grange over Sands and district have not allowed for the site selection process to be compliant with CS8.4. We are particularly concerned that protected species and those included in the Cumbria Biodiversity Action Plan have not been afforded sufficient consideration. Furthermore, detailed assessment at the site selection stage is required to determine the potential impact of proposed development on the west side of Grange at sites which are adjacent to or between internationally rare and nationally protected areas of limestone pavement. It would not be appropriate to carry out this work once a site has been ‘allocated’ as it makes it less likely that sufficient objectivity and weight would be given to findings where they recommend a site to be ‘de-allocated’.
5.14 Where it should be recognised that the development of site options in Grange over Sands pose significant issues with respect to managing surface water runoff (a good example being R89) it is clear that insufficient consideration has been given to how this significant issue would be addressed at each of the locations. We would highlight the fact that United Utilities will not make provision for accepting surface water runoff into the sewerage network and that no credible alternatives have been detailed by SLDC in the land allocation DPD where it simply expresses the need to provide remediation for the issue.
5.15 It is not evident that there is sufficient existing capacity or the financial commitment from the LEA to expand the provision of primary and secondary school places within the Grange over Sands catchment in line with the projected requirements of the land allocation DPD.
5.16 It is not evident that Cumbria County Council or the Highways Authority have given sufficient consideration to or have sufficient funds to mitigate the collective impact of development proposals across the minor and major road networks.

6. The plan does not consider the impact to the tourism-based economy of Grange over Sands

6.1 Tests of Soundness failed:
Effective
• Policies are not internally consistent.

6.2 The core strategy widely refers to the importance of the tourism sector and the role it plays in maintaining the viability and vitality of towns and villages in South Lakeland. SLDC estimate that nearly a million visitors per year are attracted to the area outside the national parks, providing revenue in excess of £130 million to local businesses (2008). The Core Strategy warns that “given the problem of town centre congestion in Grange at peak times...Significantly higher traffic levels could well threaten the core economic activity of the town, namely tourism” (CS5.32).
6.3 We would not see the promotion and growth of tourism in Grange and the Cartmel Peninsular as being consistent with the scale of development plans currently described by the land allocation DPD. We would expect particular conflict to occur where continual, prolonged and intensive levels of construction activity are required to deliver the unrealistic levels of development contained in the plan. This would be particularly apparent if SLDC continue to revise upwards their annual dwelling targets to make up for previous shortfalls against already unrealistic requirements.
6.4 We would expect a gradual but long term decline in the tourist offering at Grange over sands and the surrounding district. This would inevitably have a detrimental impact on businesses and jobs as the area loses its appeal to tourists seeking respite from the traditional and busy tourist centres within the National park, or for those just seeking the elegant and quiet charm of a traditional Victorian/Edwardian seaside resort. We would assert that further, significant urbanisation of Grange would take the town beyond its environmental capacity for sustainable development and its innate charm and attractiveness as a tourist destination outside the national parks would suffer irreversible damage. This is in contravention to SLDC Policy which states the ambition of “promoting the vitality of Grange Town Centre and promoting tourism” (LADPD 4.2).
6.5 We would draw parallels to consideration given by the Planning Inspectorate when refusing planning permission at Princes Risborough (February 2012). Para 130 states “Tourism relies much on the attractiveness of the town and its setting and the development risks adversely affecting both”.

YES, I wish to participate at the oral examination

As part of its submission, Grange and District Action Group (GADAG) have provided written confirmation to SLDC from 110 members that GADAG should represent them at the oral examination.

Please notify me

I have read the guidance notes

1.10

No

Summary of objections to soundness

2. Public consultation has failed to deliver appropriate, sufficient and effective methods of engagement.

2.1 Tests of Soundness failed:
Justified
• Participation. The consultation process has not allowed for effective engagement of all interested parties.

YES, I wish to participate at the oral examination

As part of its submission, Grange and District Action Group (GADAG) have provided written confirmation to SLDC from 110 members that GADAG should represent them at the oral examination.

Please notify me

I have read the guidance notes

2.8

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.

Summary of objections to soundness

4. The plan fails to consider adequately the balance between settlements or the sustainability of site options across key service centres.

4.1 Tests of Soundness failed:
Justified
• Research / fact finding – The choices made in the plan are not backed by facts / credible evidence base.
• Assumptions are not reasonable and justified.
• The LPA’s chosen approach is not the most appropriate given the reasonable alternatives.
• The sustainability appraisal does not show how the different options perform and is it not clear that sustainability considerations informed the content of the DPD from the start.
• The strategy does not take forward the regional context reflecting local issues and objectives.
• The plan does not adequately reflect the concept of spatial planning.


4.2 We would firstly highlight that there are unexplained inconsistencies between data sets utilised in DPD’s and supporting documentation for existing housing stock in key service centres. This is important where they are used to pro-rata allocations between the key service centres of Grange over Sands, Milnthorpe and Kirkby Lonsdale. For example, the Land Allocation DPD advises there are 738 dwellings in Kirkby Lonsdale (Land Allocation DPD p16). However, the SHMA uses a figure of 1268 (SHMA Oct 2011 Appendix A Table A2). Similar discrepancies have been recorded for Milnthorpe. Where these anomalies have not been explained it is not clear that any policies in the land allocation DPD based on analysis of settlement size are credible.
4.3 The plan does not provide for the adequate or relative comparison of sustainability criteria between or across key service centres (KSC’s) and therefore it is not clear that sustainability considerations have informed the content of the DPD. Where some sites and KSC characteristics mean some are inherently more sustainable than others, strategy has not allowed for an objective appraisal of sustainability in a localised context across this settlement grouping.
4.4 In the Inspector’s report of the core strategy, it is stated that “more detailed work at balancing local needs and environmental capacities outside the principal service centres can properly be conducted as part of the Allocation of Land DPD process”. Also that in respect to Grange and the Cartmel peninsular, that “further detail will be necessary to firm up specific plans but in my mind the level of further detail necessary is more appropriate to the forthcoming allocation of land DPD”. It is clear that the land allocation DPD or supporting documentation fails to adequately provide for the level of required analysis in this regard and as such does not adequately reflect local issues and objectives.
4.5 It can be seen that relative to Milnthorpe and Kirkby Lonsdale, Grange over Sands is less favourably positioned to accept significant and sustainable development due to current infrastructure and environmental constraints peculiar to its situation on the Cartmel peninsular. It also fails to meet all the criteria of a key service centre which further detracts from its ability to accommodate large scale expansion. Where SLDC refer to development proposals at Grange over Sands as “moderate” this is clearly not the case where this represents an approximate 25% increase in the number of dwellings.
4.6 The town is less well serviced in relation to its proximity and ease of access to a trunk road or the motorway network. This is especially the case for the west of Grange where the majority of proposed sites are located. It can also be evidenced that the bulk of traffic accessing services to the east of Grange via the major road network would pass through the narrow thoroughfare of the town centre (Main Street). The core strategy which is used to inform the land allocation DPD recognises that “access to the peninsular is poor, limited to the B5277/8 looping off the A590 to run through Grange, Allithwaite and Cark, the B6271 (sic - should read B5271) from Lindale and minor roads north of Cartmel” (CS5.12). Road infrastructure in Grange cannot be easily improved due to the restrictions imposed across the town by the built environment and other constraints. Contrary to requirements of the core strategy (CS10.2 Transport impact of new development) SLDC have confirmed (March 2012) that no traffic surveys have been carried out by Cumbria County Council to inform the land allocations process in Grange, and that they (Cumbria County Council) advise that significant development in Grange may increase parking and traffic pressures. Conversely, the core strategy notes that the East (including Kirkby Lonsdale and Milnthorpe) “benefits from excellent strategic transport links. The M6 passes directly through the area” and “are easy accessible by road, Milnthorpe being situated on the junction of the A6...and Kirkby Lonsdale being situated on the A65.” (CS6.11). Where the land allocation DPD fails to provide for the level of analysis per Para 4.4 above, we would request that the inspector calls upon SLDC to ensure traffic surveys are carried out prior to adopting the proposals of the Land Allocation DPD for Grange and the Cartmel Peninsular so that the cumulative impacts of all proposed development sites on the road network can be been properly assessed and planned for.
4.7 Grange over Sands is further away from the principal service centre at Kendal relative to the other KSC’s, and it has poor access to Ulverston (using the B5278 to reach the A590 north of Haverthwaite). It is also further away from the nearest city of Lancaster.
4.8 Unlike Milnthorpe and Kirkby Lonsdale, Grange over Sands does not have a Secondary School, which is one of the key criterions for a KSC. The nearest secondary school is in the village of Cartmel. This is two miles from Grange and cannot be practically accessed by foot or by bicycle. It therefore creates a dependency on motor vehicles for pupils from Grange. School transport is provided free of charge as an exception to the LEA ‘3-mile’ policy in recognition of this fact. Children do not enjoy easy and fair access to after school activities where school transport is not provided for.
4.9 Both Milnthorpe and Kirkby Lonsdale also benefit from further education facilities which are not available to pupils in Grange. Students from Grange have to travel to Milnthorpe, Ulverston, Lancaster, Kirkby Lonsdale, Kendal or Barrow which inevitably means an increased dependency on car travel as well as a requirement for adequate public transport links which cannot be assured where service providers are under increased pressure to ensure services are economically viable.

YES, I wish to participate at the oral examination

As part of its submission, Grange and District Action Group (GADAG) have provided written confirmation to SLDC from 110 members that GADAG should represent them at the oral examination.

Please notify me

I have read the guidance notes

1.12

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.

5.0 The plan fails to conduct adequate sustainability analysis for preferred site options at Grange over Sands and allocations are not in accordance with stated policy.

5.1 Tests of Soundness failed:
Justified
• Research / fact finding – The choices made in the plan are not backed by facts / credible evidence base.
• Assumptions are not reasonable and justified.
• The LPA’s chosen approach is not the most appropriate given the reasonable alternatives.
• The sustainability appraisal does not show how the different options perform and is it not clear that sustainability considerations informed the content of the DPD from the start.
Effective
• The plan is not holistic.
• Implications for infrastructure have not been clearly identified.
• There is insufficient detail to evidence that plans are deliverable.
• It is not clear that there is the necessary commitment from external agencies to the local planning authority...........


5.3 It is questionable whether “Accession” computer modelling techniques or other studies have correctly informed analysis of topographical and infrastructure constraints relating to proposed development sites on the western side of Grange over Sands. Doubts are raised whether it has factored features such as the gradient at Risedale Hill which provides the main link to access services in the centre of town. These considerations severely question the viability of providing pedestrian or cycle links in to town which is contrary to core strategy and national policy in promoting a reduced reliance on car use and climate change. Similarly, that the nearest secondary school is at Cartmel, which is only accessible by car or bus due to the rural nature of the road network. Both of these examples detract considerably from the sustainability of sites such as MN25M, R672M, R89 and R350M but appear not to have been factored suitably into the sustainability assessment..........

5.5 It is not entirely clear that sustainability criteria informed the decision to remove emerging site RN34 (land North of Grange Fell Road) from the final land allocations process. This is also supported by the fact that SLDC did not highlight any successful objections in response to the allocations consultation which forms part of the evidence base. Therefore it cannot be shown that the exclusion of this site has demonstrated a uniform and consistent approach with respect to the consideration of site allocations in Grange. Further concerns relating to the objectivity of this decision were raised when the cabinet member responsible for housing and development intimated that site RN34 could be reconsidered for inclusion in response to opposition requests to reconsider the extent of all allocations at the full council meeting on 18th January 2012. Without prejudice to the decision to remove it from consideration, we would request that the inspector investigates this matter to ensure procedures and policy were followed correctly and that this process was “sound”.

YES, I wish to participate at the oral examination

As part of its submission, Grange and District Action Group (GADAG) have provided written confirmation to SLDC from 110 members that GADAG should represent them at the oral examination.

I have read the guidance notes

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

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.

5.0 The plan fails to conduct adequate sustainability analysis for preferred site options at Grange over Sands and allocations are not in accordance with stated policy.

5.1 Tests of Soundness failed:
Justified
• Research / fact finding – The choices made in the plan are not backed by facts / credible evidence base.
• Assumptions are not reasonable and justified.
• The LPA’s chosen approach is not the most appropriate given the reasonable alternatives.
• The sustainability appraisal does not show how the different options perform and is it not clear that sustainability considerations informed the content of the DPD from the start.
Effective
• The plan is not holistic.
• Implications for infrastructure have not been clearly identified.
• There is insufficient detail to evidence that plans are deliverable.
• It is not clear that there is the necessary commitment from external agencies to the local planning authority.................

With respect to site R672M, respondents to the allocations consultation process raised the point that development here would effectively create a precedent for continued development westwards along the north side of Allithwaite Road and towards the village of Allithwaite. It is quite clear from the SLDC map (Grange South) that in conjunction with MN25M, that neither site could be considered to be either infill or rounding off where they are extensions into open countryside. It can be seen that the existing boundary either side of Allithwaite Road currently provides for a distinct edge to the settlement of Grange along Allithwaite Road. In fact the two proposed sites would inevitably make it more difficult for SLDC to resist future development westwards on green gap sites adjacent to R672M, up to and including the new boundary described by MN25M on the south of Allithwaite Road.

5.7 It can be seen that current development plans on the western edge of Grange over Sands and on the eastern edge of Allithwaite will lead to the significant and critical erosion of an existing green gap where this currently serves the purpose of preventing further coalescence between the two settlements. This is contrary to SLDC core strategy CS8.2 regarding the protection and enhancement of landscape and settlement character and to Land Allocation DPD 4.22 which describes the need to avoid coalescence between Allithwaite and Kent’s Bank / Grange. The development of sites RN79# - mod (Allithwaite) and MN25M / R672M (Grange over Sands) will erode the green gap along Allithwaite Road to approximately 220 metres which will increase perceived and visual coalescence between the two. Critically, It will also cause an incursion of Kent’s Bank / Grange over Sands westwards between the limits of the Allithwaite parish boundary which is described to the North of Allithwaite Road and to the south of Kirkhead Road, either side of MN25M. Given the importance of maintaining the integrity of this green gap in avoiding further coalescence between Grange and Allithwaite, we would request that SLDC remove MN25M and R672M from the land allocation DPD.

.8 Where the majority of development sites in Grange over Sands lie to the West of town (MN25M / R672M / R89 / R350M) the land allocation DPD fails to describe how safe, convenient and attractive access to the town centre by foot or cycle is provided for. The main route into town is along the B5277 where footpath provision is restricted to one narrow path along the steep and twisting incline of Risedale Hill.

YES, I wish to participate at the oral examination

As part of its submission, Grange and District Action Group (GADAG) have provided written confirmation to SLDC from 110 members that GADAG should represent them at the oral examination.

Please notify me

I have read the guidance notes

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

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.

5.0 The plan fails to conduct adequate sustainability analysis for preferred site options at Grange over Sands and allocations are not in accordance with stated policy.

5.1 Tests of Soundness failed:
Justified
• Research / fact finding – The choices made in the plan are not backed by facts / credible evidence base.
• Assumptions are not reasonable and justified.
• The LPA’s chosen approach is not the most appropriate given the reasonable alternatives.
• The sustainability appraisal does not show how the different options perform and is it not clear that sustainability considerations informed the content of the DPD from the start.
Effective
• The plan is not holistic.
• Implications for infrastructure have not been clearly identified.
• There is insufficient detail to evidence that plans are deliverable.
• It is not clear that there is the necessary commitment from external agencies to the local planning authority.


The development of sites RN79# - mod (Allithwaite) and MN25M / R672M (Grange over Sands) will erode the green gap along Allithwaite Road to approximately 220 metres which will increase perceived and visual coalescence between the two. Critically, It will also cause an incursion of Kent’s Bank / Grange over Sands westwards between the limits of the Allithwaite parish boundary which is described to the North of Allithwaite Road and to the south of Kirkhead Road, either side of MN25M. Given the importance of maintaining the integrity of this green gap in avoiding further coalescence between Grange and Allithwaite, we would request that SLDC remove MN25M and R672M from the land allocation DPD.

YES, I wish to participate at the oral examination

As part of its submission, Grange and District Action Group (GADAG) have provided written confirmation to SLDC from 110 members that GADAG should represent them at the oral examination.

Please notify me

I have read the guidance notes

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

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.

5.0 The plan fails to conduct adequate sustainability analysis for preferred site options at Grange over Sands and allocations are not in accordance with stated policy.

5.1 Tests of Soundness failed:
Justified
• Research / fact finding – The choices made in the plan are not backed by facts / credible evidence base.
• Assumptions are not reasonable and justified.
• The LPA’s chosen approach is not the most appropriate given the reasonable alternatives.
• The sustainability appraisal does not show how the different options perform and is it not clear that sustainability considerations informed the content of the DPD from the start.
Effective
• The plan is not holistic.
• Implications for infrastructure have not been clearly identified.
• There is insufficient detail to evidence that plans are deliverable.
• It is not clear that there is the necessary commitment from external agencies to the local planning authority..........

5.8 Where the majority of development sites in Grange over Sands lie to the West of town (MN25M / R672M / R89 / R350M) the land allocation DPD fails to describe how safe, convenient and attractive access to the town centre by foot or cycle is provided for. The main route into town is along the B5277 where footpath provision is restricted to one narrow path along the steep and twisting incline of Risedale Hill............

5.10 With regard to site R89, it can be seen that as well as being subject to the sustainability constraints already outlined for sites to the west of Grange over Sands, it is not clear that other sustainability criteria have been applied consistently or objectively. SHLAA 2009 describes the site as a “category three” site, performing least well against assessment criteria with regard to its suitability for development. However it has since been described as having met all necessary requirements and is now deemed to be eminently suitable for development. In addition, SLDC have chosen to exclude from their evidence base previous independent development studies for Grange over Sands where they do not support the findings proposed by the current land allocation DPD. With regard to site R89 both the Gillespies and Douglas Wheeler reports exclude this site from consideration for development, not least in recognition of the fact that it provides for an important open space in an otherwise built-up and now suburban landscape. The local community would look to consider this land as a ‘local green space’ under provisions afforded by the National Planning Policy Framework. Therefore we would request that R89 is not included in the land allocation DPD whilst consideration is given to this...........

5.12 Given the proximity of sites R74 and R449 to R110, it would seem logical to extend the comments made in Para 5.10 to these sites also.

YES, I wish to participate at the oral examination

As part of its submission, Grange and District Action Group (GADAG) have provided written confirmation to SLDC from 110 members that GADAG should represent them at the oral examination.

Please notify me

I have read the guidance notes

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

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.

5.0 The plan fails to conduct adequate sustainability analysis for preferred site options at Grange over Sands and allocations are not in accordance with stated policy.

5.1 Tests of Soundness failed:
Justified
• Research / fact finding – The choices made in the plan are not backed by facts / credible evidence base.
• Assumptions are not reasonable and justified.
• The LPA’s chosen approach is not the most appropriate given the reasonable alternatives.
• The sustainability appraisal does not show how the different options perform and is it not clear that sustainability considerations informed the content of the DPD from the start.
Effective
• The plan is not holistic.
• Implications for infrastructure have not been clearly identified.
• There is insufficient detail to evidence that plans are deliverable.
• It is not clear that there is the necessary commitment from external agencies to the local planning authority.

.11 Site R110 is one of the last open spaces in the Grange over Sands conservation area. It has high amenity value where it provides for views across the bay and has enjoyed protection from development for this reason. Planning permission has been refused previously by SLDC who cited road infrastructure issues where there were concerns over traffic (application No. 5/91/2372). It would not therefore be consistent to allow development on this site where the only material change since refusal would have been an increase in general traffic volumes across the district.

YES, I wish to participate at the oral examination

As part of its submission, Grange and District Action Group (GADAG) have provided written confirmation to SLDC from 110 members that GADAG should represent them at the oral examination.

Please notify me