5 responses from Mr Andrew Mortimer (Individual)
1. Mr Andrew Mortimer (Individual) : 15 Apr 2012 16:43:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
0.0 Whole Document
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I do not believe that South Lakeland District Council’s Land Allocation Development Plan Document (DPD) should be adopted in relation to planning for Grange-over-Sands and District because it is not sound.
It is not founded on robust and credible evidence, it makes assumptions that are based on out-of-date and poor research and, most importantly, it contains significant inconsistencies across the collection of ‘Local Development Framework’ (LDF) documents and, in particular, discrepancies and contradictions with the Core Strategy.
My principal objections are made on the grounds of:
1. site selection,
2. density
3. impact on transport infrastructure
4. failure to comply with core strategy methodology
1. Site Selection
I do not believe that the sites in Grange-over-Sands, identified for development in this plan, take sufficient account of the “detailed criteria” set out in DPD para 2.23 namely:
“General criteria such as the capacity of the site, the appropriate density at which it could be developed, the ease of accessing the site, the impact of topography and relief and the scope to meet identified needs …”
“Landscape and Settlement considerations including the potential impact of development on landscape and views, the scale of development relative to the settlement size, whether the site preserves the separate identity of settlements and the impact of development on site features such as trees, watercourses and buildings”
I also believe that some development would compromise an identified Green Gap.
For example, this would be the case if development were allowed on the scale proposed on site MN25M which would both visually and effectively join together the settlements of Grange-over-Sands, Kents Bank and Allithwaite.
Proposed development R110 would also compromise an important recreational open space. This is land “which is not accessible to the public but which nonetheless has amenity value because of its openness, appearance or landscape quality.” Using such sites for the density of development proposed contradicts the criteria for preserving Amenity Open Space, suggested in DPD para 2.63. It would also compromise the important recreational open space immediately next to it, turning it into little more than an urban playground.
Further, recommendations in the Grange Regeneration Study (which has informed the Core Strategy) about building a sense of place, business and tourist development etc would also be threatened by the DPD. Currently, as one walks or drives through Grange-over-Sands on the B5277, clear views across Morecambe Bay open out to give the visual and environmental qualities that make Grange unique and which attract visitors. The proposed developments would change those, often tree-lined, views into an unattractive urban ribbon development.
If the objective is “to deliver the vision and objectives set out in the Council’s adopted Core Strategy and help to make South Lakeland the best place to live, work and visit”(DPD 1.5), then the DPD choice of development sites in Grange-over-Sands must be considered more carefully.
2. Density
The DPD has not taken notice of the Core Strategy’s overarching development strategy (CS1.2), with regard to the impact that the suggested density of housing development in Grange-over-Sands would have in general on the landscape, historic setting, and the environment. Under the DPD proposals, between Grange Station and Kents Bank, all but one “greenfield” site would disappear.
The volume of housing development proposed is out of character and will change the unique and special nature of the area. It is not “moderate” as the Core Strategy would claim (Policy CS4).
500 dwellings in Grange-over-Sands would increase the current population by at least 25%.
I do not believe that an increase in population of a quarter could be considered “moderate”. Even the Local Transport Plan for South Lakeland (CCC Local Transport Plan 3, “Moving Cumbria Forward”, 2011 – 2016) describes this as “substantial housing allocation”.
In addition, some of the individual sites challenge the Core Strategy with regard to density of housing. “Core Strategy Policy CS6.6 seeks an average density of 30 dwellings per hectare, with higher densities in town centres and locations with good public transport and lower densities in areas where there are environmental constraints.”
There is a clear breach of this policy in regard to site R110, south of Thornfield Road, where the DPD recommends building 66 dwellings on only 1.83 ha. This is not a town centre site and is not a location with good public transport.
3. Impact on Transport Infrastructure
The DPD, by placing all the emphasis on development in Grange South, ignores the Core Strategy’s warning (CS5.32) 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”.
An increase in population, on the scale proposed in the plan, would certainly result in at least 25% more traffic which would challenge its ambition of
“promoting the vitality of Grange Town Centre and promoting tourism”. (DPD 4.2)
The final plan seems to ignore the fact that,
“The main B5277 road runs through the heart of Grange over Sands … In places this road narrows and on some stretches, there is a feeling of car domination.”
(SLDC Framework Land Allocations Development Plan Document Consultation on emerging site options – Grange over Sands)
The Core Strategy also suggests that,
“Access into the peninsula is poor, limited mainly to the B5277/8 looping off the A590 to run through Grange, Allithwaite and Cark, the B6271 from Lindale and minor roads north of Cartmel.” (CS5.12)
Statistics from “count points” on the A590 show that between the Meathop Roundabout and Newby Bridge over 5000 vehicles joined or left the A590 per day in 2010. (Highways Agency Cumbria AADF statistics 2011) This confirms that there is already an extremely high volume of traffic coming in and out of the Cartmel Peninsula on unsuitable roads. Even The Development Plan itself admits,
“Elsewhere in the peninsula … the road network … is constrained in places.” (DPD 4.1)
It is likely to become very much more “constrained” if the volume of traffic grows by almost 25% in line with the proposed population increase in Grange-over-Sands, not forgetting the fact that,
“Car ownership levels in Grange … are high, with 80.7% of households having access to a car or van (compared to a Cumbria average of 75.6%)”.
(SLDC Framework Land Allocations Development Plan Document Consultation on emerging site options – Grange over Sands)
Even more significant is the apparent failure of SLDC to consider the impact of its plans for Grange-over-Sands, the Cartmel Peninsula and Ulverston together, on the wider transport infrastructure and especially the increase in volume of traffic on the A590. Whatever the discussions SLDC have had with The Highways Agency, the latter have no plans for improvements to the A590 before 2025 except a possible roundabout construction at Greenodd. A spokesman has told me that “Our current major scheme programme does not include any schemes on the A590”.
The most recent average annual daily flow (AADF) figures for the A590 show a steady increase of traffic on this road over the last 10 years, with almost 4000 more vehicles travelling daily in 2010 than in 2009. (Highways Agency Cumbria AADF statistics 2011)
This volume of traffic would be increased significantly by the proposals in the DPD for housing and industrial development in Cartmel Peninsula and Ulverston.
In the Cumbria County Council Local Transport Plan 2006 – 2011, it was noted that,
"The A590 between the Furness peninsula and the M6 motorway has several constrictions, including passing through Ulverston and ... long single carriageway sections with unimproved alignments. This causes unreliable and extended journey times between Furness and the rest of the region and UK, impeding economic development. The worsening position regarding average journey times on A590 has already been noted in the context of road safety”
What this means, according to provisional data published by the Highways Agency, is that on average only about 65% of journeys undertaken on A590 in 2011 were ‘on time’.(The national average for ‘on-time’ journeys was approximately 85%)(Journey Reliability Data to November 2011 – data.gov.uk)
In addition, Cumbria Constabulary has unofficially acknowledged that there were 3 fatalities and 6 serious injuries as a result of accidents in 2011 on the A590, making it the worst road in Cumbria for fatal accidents over the past 10 years.
If the potential increase in traffic as a result of DPD is added to the Department of Transport's own national statistical projections for 2025 of a 25% increase in volume of all traffic, and an increase in car ownership of 30% (Table TRA 9905), I believe that the actual increase in traffic on this dangerous road is likely to be at least 50% by 2025.
4. Failure to Comply with Core Strategy Methodology
Core Strategy clearly lays out a sequence for the planning process.
CS1.1 sets out “Sustainable Development Principles” including
“Development should accord with the following sequential approach:
• first, using existing buildings (including conversion) within settlements, and previously
developed land within settlements;
• second, using other suitable infill opportunities within settlements;
• third, the development of other land where this is well located in relation to housing, jobs, other services and infrastructure.”
CS1.2 states “Priority will be given to the reuse of existing buildings and previously developed land for all new housing development”
The question is now raised as to whether, in the light of the withdrawal of the Berner’s site proposals in Grange-over-Sands (25/01/12), these DPD plans might no longer be seen as having a ‘sequential’ approach –
“A sequential approach which looks first at previously used land and buildings within settlements” (2.22) before any ‘greenfield’ sites are developed.
The current land allocation plans for Grange need to be looked at again in the light of these principles and the recent failure of proposed schemes.
No ‘greenfield’ site should be earmarked for development until the use of ‘brownfield’ sites is resolved.
I believe that any one of these 4 issues renders the Land Allocation Proposals unsound but together they demand a radical reappraisal by South Lakes District Council as to how it develops land usage in Grange-over-Sands and District.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
2. Mr Andrew Mortimer (Individual) : 15 May 2012 11:58:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - All Grange-over-Sands sites
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I do not believe that South Lakeland District Council’s Land Allocation Development Plan Document (DPD) should be adopted in relation to planning for Grange-over-Sands and District because it is not sound.
It is not founded on robust and credible evidence, it makes assumptions that are based on out-of-date and poor research and, most importantly, it contains significant inconsistencies across the collection of ‘Local Development Framework’ (LDF) documents and, in particular, discrepancies and contradictions with the Core Strategy.
My principal objections are made on the grounds of:
1. site selection,
2. density
3. impact on transport infrastructure
4. failure to comply with core strategy methodology
1. Site Selection
I do not believe that the sites in Grange-over-Sands, identified for development in this plan, take sufficient account of the “detailed criteria” set out in DPD para 2.23 namely:
“General criteria such as the capacity of the site, the appropriate density at which it could be developed, the ease of accessing the site, the impact of topography and relief and the scope to meet identified needs …”
“Landscape and Settlement considerations including the potential impact of development on landscape and views, the scale of development relative to the settlement size, whether the site preserves the separate identity of settlements and the impact of development on site features such as trees, watercourses and buildings”
I also believe that some development would compromise an identified Green Gap.
For example, this would be the case if development were allowed on the scale proposed on site MN25M which would both visually and effectively join together the settlements of Grange-over-Sands, Kents Bank and Allithwaite.
Proposed development R110 would also compromise an important recreational open space. This is land “which is not accessible to the public but which nonetheless has amenity value because of its openness, appearance or landscape quality.” Using such sites for the density of development proposed contradicts the criteria for preserving Amenity Open Space, suggested in DPD para 2.63. It would also compromise the important recreational open space immediately next to it, turning it into little more than an urban playground.
Further, recommendations in the Grange Regeneration Study (which has informed the Core Strategy) about building a sense of place, business and tourist development etc would also be threatened by the DPD. Currently, as one walks or drives through Grange-over-Sands on the B5277, clear views across Morecambe Bay open out to give the visual and environmental qualities that make Grange unique and which attract visitors. The proposed developments would change those, often tree-lined, views into an unattractive urban ribbon development.
If the objective is “to deliver the vision and objectives set out in the Council’s adopted Core Strategy and help to make South Lakeland the best place to live, work and visit”(DPD 1.5), then the DPD choice of development sites in Grange-over-Sands must be considered more carefully.
2. Density
The DPD has not taken notice of the Core Strategy’s overarching development strategy (CS1.2), with regard to the impact that the suggested density of housing development in Grange-over-Sands would have in general on the landscape, historic setting, and the environment. Under the DPD proposals, between Grange Station and Kents Bank, all but one “greenfield” site would disappear.
The volume of housing development proposed is out of character and will change the unique and special nature of the area. It is not “moderate” as the Core Strategy would claim (Policy CS4).
500 dwellings in Grange-over-Sands would increase the current population by at least 25%.
I do not believe that an increase in population of a quarter could be considered “moderate”. Even the Local Transport Plan for South Lakeland (CCC Local Transport Plan 3, “Moving Cumbria Forward”, 2011 – 2016) describes this as “substantial housing allocation”.
In addition, some of the individual sites challenge the Core Strategy with regard to density of housing. “Core Strategy Policy CS6.6 seeks an average density of 30 dwellings per hectare, with higher densities in town centres and locations with good public transport and lower densities in areas where there are environmental constraints.”
There is a clear breach of this policy in regard to site R110, south of Thornfield Road, where the DPD recommends building 66 dwellings on only 1.83 ha. This is not a town centre site and is not a location with good public transport.
3. Impact on Transport Infrastructure
The DPD, by placing all the emphasis on development in Grange South, ignores the Core Strategy’s warning (CS5.32) 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”.
An increase in population, on the scale proposed in the plan, would certainly result in at least 25% more traffic which would challenge its ambition of
“promoting the vitality of Grange Town Centre and promoting tourism”. (DPD 4.2)
The final plan seems to ignore the fact that,
“The main B5277 road runs through the heart of Grange over Sands … In places this road narrows and on some stretches, there is a feeling of car domination.”
(SLDC Framework Land Allocations Development Plan Document Consultation on emerging site options – Grange over Sands)
The Core Strategy also suggests that,
“Access into the peninsula is poor, limited mainly to the B5277/8 looping off the A590 to run through Grange, Allithwaite and Cark, the B6271 from Lindale and minor roads north of Cartmel.” (CS5.12)
Statistics from “count points” on the A590 show that between the Meathop Roundabout and Newby Bridge over 5000 vehicles joined or left the A590 per day in 2010. (Highways Agency Cumbria AADF statistics 2011) This confirms that there is already an extremely high volume of traffic coming in and out of the Cartmel Peninsula on unsuitable roads. Even The Development Plan itself admits,
“Elsewhere in the peninsula … the road network … is constrained in places.” (DPD 4.1)
It is likely to become very much more “constrained” if the volume of traffic grows by almost 25% in line with the proposed population increase in Grange-over-Sands, not forgetting the fact that,
“Car ownership levels in Grange … are high, with 80.7% of households having access to a car or van (compared to a Cumbria average of 75.6%)”.
(SLDC Framework Land Allocations Development Plan Document Consultation on emerging site options – Grange over Sands)
Even more significant is the apparent failure of SLDC to consider the impact of its plans for Grange-over-Sands, the Cartmel Peninsula and Ulverston together, on the wider transport infrastructure and especially the increase in volume of traffic on the A590. Whatever the discussions SLDC have had with The Highways Agency, the latter have no plans for improvements to the A590 before 2025 except a possible roundabout construction at Greenodd. A spokesman has told me that “Our current major scheme programme does not include any schemes on the A590”.
The most recent average annual daily flow (AADF) figures for the A590 show a steady increase of traffic on this road over the last 10 years, with almost 4000 more vehicles travelling daily in 2010 than in 2009. (Highways Agency Cumbria AADF statistics 2011)
This volume of traffic would be increased significantly by the proposals in the DPD for housing and industrial development in Cartmel Peninsula and Ulverston.
In the Cumbria County Council Local Transport Plan 2006 – 2011, it was noted that,
"The A590 between the Furness peninsula and the M6 motorway has several constrictions, including passing through Ulverston and ... long single carriageway sections with unimproved alignments. This causes unreliable and extended journey times between Furness and the rest of the region and UK, impeding economic development. The worsening position regarding average journey times on A590 has already been noted in the context of road safety”
What this means, according to provisional data published by the Highways Agency, is that on average only about 65% of journeys undertaken on A590 in 2011 were ‘on time’.(The national average for ‘on-time’ journeys was approximately 85%)(Journey Reliability Data to November 2011 – data.gov.uk)
In addition, Cumbria Constabulary has unofficially acknowledged that there were 3 fatalities and 6 serious injuries as a result of accidents in 2011 on the A590, making it the worst road in Cumbria for fatal accidents over the past 10 years.
If the potential increase in traffic as a result of DPD is added to the Department of Transport's own national statistical projections for 2025 of a 25% increase in volume of all traffic, and an increase in car ownership of 30% (Table TRA 9905), I believe that the actual increase in traffic on this dangerous road is likely to be at least 50% by 2025.
4. Failure to Comply with Core Strategy Methodology
Core Strategy clearly lays out a sequence for the planning process.
CS1.1 sets out “Sustainable Development Principles” including
“Development should accord with the following sequential approach:
• first, using existing buildings (including conversion) within settlements, and previously
developed land within settlements;
• second, using other suitable infill opportunities within settlements;
• third, the development of other land where this is well located in relation to housing, jobs, other services and infrastructure.”
CS1.2 states “Priority will be given to the reuse of existing buildings and previously developed land for all new housing development”
The question is now raised as to whether, in the light of the withdrawal of the Berner’s site proposals in Grange-over-Sands (25/01/12), these DPD plans might no longer be seen as having a ‘sequential’ approach –
“A sequential approach which looks first at previously used land and buildings within settlements” (2.22) before any ‘greenfield’ sites are developed.
The current land allocation plans for Grange need to be looked at again in the light of these principles and the recent failure of proposed schemes.
No ‘greenfield’ site should be earmarked for development until the use of ‘brownfield’ sites is resolved.
I believe that any one of these 4 issues renders the Land Allocation Proposals unsound but together they demand a radical reappraisal by South Lakes District Council as to how it develops land usage in Grange-over-Sands and District.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
3. Mr Andrew Mortimer (Individual) : 15 May 2012 12:01:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA3.1 Mixed Use Allocation at Berners Pool, Grange-over-Sands
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I do not believe that South Lakeland District Council’s Land Allocation Development Plan Document (DPD) should be adopted in relation to planning for Grange-over-Sands and District because it is not sound.
It is not founded on robust and credible evidence, it makes assumptions that are based on out-of-date and poor research and, most importantly, it contains significant inconsistencies across the collection of ‘Local Development Framework’ (LDF) documents and, in particular, discrepancies and contradictions with the Core Strategy.
My principal objections are made on the grounds of:
1. site selection,
2. density
3. impact on transport infrastructure
4. failure to comply with core strategy methodology
1. Site Selection
I do not believe that the sites in Grange-over-Sands, identified for development in this plan, take sufficient account of the “detailed criteria” set out in DPD para 2.23 namely:
“General criteria such as the capacity of the site, the appropriate density at which it could be developed, the ease of accessing the site, the impact of topography and relief and the scope to meet identified needs …”
“Landscape and Settlement considerations including the potential impact of development on landscape and views, the scale of development relative to the settlement size, whether the site preserves the separate identity of settlements and the impact of development on site features such as trees, watercourses and buildings”
I also believe that some development would compromise an identified Green Gap.
For example, this would be the case if development were allowed on the scale proposed on site MN25M which would both visually and effectively join together the settlements of Grange-over-Sands, Kents Bank and Allithwaite.
Proposed development R110 would also compromise an important recreational open space. This is land “which is not accessible to the public but which nonetheless has amenity value because of its openness, appearance or landscape quality.” Using such sites for the density of development proposed contradicts the criteria for preserving Amenity Open Space, suggested in DPD para 2.63. It would also compromise the important recreational open space immediately next to it, turning it into little more than an urban playground.
Further, recommendations in the Grange Regeneration Study (which has informed the Core Strategy) about building a sense of place, business and tourist development etc would also be threatened by the DPD. Currently, as one walks or drives through Grange-over-Sands on the B5277, clear views across Morecambe Bay open out to give the visual and environmental qualities that make Grange unique and which attract visitors. The proposed developments would change those, often tree-lined, views into an unattractive urban ribbon development.
If the objective is “to deliver the vision and objectives set out in the Council’s adopted Core Strategy and help to make South Lakeland the best place to live, work and visit”(DPD 1.5), then the DPD choice of development sites in Grange-over-Sands must be considered more carefully.
2. Density
The DPD has not taken notice of the Core Strategy’s overarching development strategy (CS1.2), with regard to the impact that the suggested density of housing development in Grange-over-Sands would have in general on the landscape, historic setting, and the environment. Under the DPD proposals, between Grange Station and Kents Bank, all but one “greenfield” site would disappear.
The volume of housing development proposed is out of character and will change the unique and special nature of the area. It is not “moderate” as the Core Strategy would claim (Policy CS4).
500 dwellings in Grange-over-Sands would increase the current population by at least 25%.
I do not believe that an increase in population of a quarter could be considered “moderate”. Even the Local Transport Plan for South Lakeland (CCC Local Transport Plan 3, “Moving Cumbria Forward”, 2011 – 2016) describes this as “substantial housing allocation”.
In addition, some of the individual sites challenge the Core Strategy with regard to density of housing. “Core Strategy Policy CS6.6 seeks an average density of 30 dwellings per hectare, with higher densities in town centres and locations with good public transport and lower densities in areas where there are environmental constraints.”
There is a clear breach of this policy in regard to site R110, south of Thornfield Road, where the DPD recommends building 66 dwellings on only 1.83 ha. This is not a town centre site and is not a location with good public transport.
3. Impact on Transport Infrastructure
The DPD, by placing all the emphasis on development in Grange South, ignores the Core Strategy’s warning (CS5.32) 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”.
An increase in population, on the scale proposed in the plan, would certainly result in at least 25% more traffic which would challenge its ambition of
“promoting the vitality of Grange Town Centre and promoting tourism”. (DPD 4.2)
The final plan seems to ignore the fact that,
“The main B5277 road runs through the heart of Grange over Sands … In places this road narrows and on some stretches, there is a feeling of car domination.”
(SLDC Framework Land Allocations Development Plan Document Consultation on emerging site options – Grange over Sands)
The Core Strategy also suggests that,
“Access into the peninsula is poor, limited mainly to the B5277/8 looping off the A590 to run through Grange, Allithwaite and Cark, the B6271 from Lindale and minor roads north of Cartmel.” (CS5.12)
Statistics from “count points” on the A590 show that between the Meathop Roundabout and Newby Bridge over 5000 vehicles joined or left the A590 per day in 2010. (Highways Agency Cumbria AADF statistics 2011) This confirms that there is already an extremely high volume of traffic coming in and out of the Cartmel Peninsula on unsuitable roads. Even The Development Plan itself admits,
“Elsewhere in the peninsula … the road network … is constrained in places.” (DPD 4.1)
It is likely to become very much more “constrained” if the volume of traffic grows by almost 25% in line with the proposed population increase in Grange-over-Sands, not forgetting the fact that,
“Car ownership levels in Grange … are high, with 80.7% of households having access to a car or van (compared to a Cumbria average of 75.6%)”.
(SLDC Framework Land Allocations Development Plan Document Consultation on emerging site options – Grange over Sands)
Even more significant is the apparent failure of SLDC to consider the impact of its plans for Grange-over-Sands, the Cartmel Peninsula and Ulverston together, on the wider transport infrastructure and especially the increase in volume of traffic on the A590. Whatever the discussions SLDC have had with The Highways Agency, the latter have no plans for improvements to the A590 before 2025 except a possible roundabout construction at Greenodd. A spokesman has told me that “Our current major scheme programme does not include any schemes on the A590”.
The most recent average annual daily flow (AADF) figures for the A590 show a steady increase of traffic on this road over the last 10 years, with almost 4000 more vehicles travelling daily in 2010 than in 2009. (Highways Agency Cumbria AADF statistics 2011)
This volume of traffic would be increased significantly by the proposals in the DPD for housing and industrial development in Cartmel Peninsula and Ulverston.
In the Cumbria County Council Local Transport Plan 2006 – 2011, it was noted that,
"The A590 between the Furness peninsula and the M6 motorway has several constrictions, including passing through Ulverston and ... long single carriageway sections with unimproved alignments. This causes unreliable and extended journey times between Furness and the rest of the region and UK, impeding economic development. The worsening position regarding average journey times on A590 has already been noted in the context of road safety”
What this means, according to provisional data published by the Highways Agency, is that on average only about 65% of journeys undertaken on A590 in 2011 were ‘on time’.(The national average for ‘on-time’ journeys was approximately 85%)(Journey Reliability Data to November 2011 – data.gov.uk)
In addition, Cumbria Constabulary has unofficially acknowledged that there were 3 fatalities and 6 serious injuries as a result of accidents in 2011 on the A590, making it the worst road in Cumbria for fatal accidents over the past 10 years.
If the potential increase in traffic as a result of DPD is added to the Department of Transport's own national statistical projections for 2025 of a 25% increase in volume of all traffic, and an increase in car ownership of 30% (Table TRA 9905), I believe that the actual increase in traffic on this dangerous road is likely to be at least 50% by 2025.
4. Failure to Comply with Core Strategy Methodology
Core Strategy clearly lays out a sequence for the planning process.
CS1.1 sets out “Sustainable Development Principles” including
“Development should accord with the following sequential approach:
• first, using existing buildings (including conversion) within settlements, and previously
developed land within settlements;
• second, using other suitable infill opportunities within settlements;
• third, the development of other land where this is well located in relation to housing, jobs, other services and infrastructure.”
CS1.2 states “Priority will be given to the reuse of existing buildings and previously developed land for all new housing development”
The question is now raised as to whether, in the light of the withdrawal of the Berner’s site proposals in Grange-over-Sands (25/01/12), these DPD plans might no longer be seen as having a ‘sequential’ approach –
“A sequential approach which looks first at previously used land and buildings within settlements” (2.22) before any ‘greenfield’ sites are developed.
The current land allocation plans for Grange need to be looked at again in the light of these principles and the recent failure of proposed schemes.
No ‘greenfield’ site should be earmarked for development until the use of ‘brownfield’ sites is resolved.
I believe that any one of these 4 issues renders the Land Allocation Proposals unsound but together they demand a radical reappraisal by South Lakes District Council as to how it develops land usage in Grange-over-Sands and District.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
4. Mr Andrew Mortimer (Individual) : 15 May 2012 12:04:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA3.2 Mixed Use Allocation at Land South of Allithwaite Road, Kent's Bank, Grange-over-Sands
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I do not believe that South Lakeland District Council’s Land Allocation Development Plan Document (DPD) should be adopted in relation to planning for Grange-over-Sands and District because it is not sound.
It is not founded on robust and credible evidence, it makes assumptions that are based on out-of-date and poor research and, most importantly, it contains significant inconsistencies across the collection of ‘Local Development Framework’ (LDF) documents and, in particular, discrepancies and contradictions with the Core Strategy.
My principal objections are made on the grounds of:
1. site selection,
2. density
3. impact on transport infrastructure
4. failure to comply with core strategy methodology
1. Site Selection
I do not believe that the sites in Grange-over-Sands, identified for development in this plan, take sufficient account of the “detailed criteria” set out in DPD para 2.23 namely:
“General criteria such as the capacity of the site, the appropriate density at which it could be developed, the ease of accessing the site, the impact of topography and relief and the scope to meet identified needs …”
“Landscape and Settlement considerations including the potential impact of development on landscape and views, the scale of development relative to the settlement size, whether the site preserves the separate identity of settlements and the impact of development on site features such as trees, watercourses and buildings”
I also believe that some development would compromise an identified Green Gap.
For example, this would be the case if development were allowed on the scale proposed on site MN25M which would both visually and effectively join together the settlements of Grange-over-Sands, Kents Bank and Allithwaite.
Proposed development R110 would also compromise an important recreational open space. This is land “which is not accessible to the public but which nonetheless has amenity value because of its openness, appearance or landscape quality.” Using such sites for the density of development proposed contradicts the criteria for preserving Amenity Open Space, suggested in DPD para 2.63. It would also compromise the important recreational open space immediately next to it, turning it into little more than an urban playground.
Further, recommendations in the Grange Regeneration Study (which has informed the Core Strategy) about building a sense of place, business and tourist development etc would also be threatened by the DPD. Currently, as one walks or drives through Grange-over-Sands on the B5277, clear views across Morecambe Bay open out to give the visual and environmental qualities that make Grange unique and which attract visitors. The proposed developments would change those, often tree-lined, views into an unattractive urban ribbon development.
If the objective is “to deliver the vision and objectives set out in the Council’s adopted Core Strategy and help to make South Lakeland the best place to live, work and visit”(DPD 1.5), then the DPD choice of development sites in Grange-over-Sands must be considered more carefully.
2. Density
The DPD has not taken notice of the Core Strategy’s overarching development strategy (CS1.2), with regard to the impact that the suggested density of housing development in Grange-over-Sands would have in general on the landscape, historic setting, and the environment. Under the DPD proposals, between Grange Station and Kents Bank, all but one “greenfield” site would disappear.
The volume of housing development proposed is out of character and will change the unique and special nature of the area. It is not “moderate” as the Core Strategy would claim (Policy CS4).
500 dwellings in Grange-over-Sands would increase the current population by at least 25%.
I do not believe that an increase in population of a quarter could be considered “moderate”. Even the Local Transport Plan for South Lakeland (CCC Local Transport Plan 3, “Moving Cumbria Forward”, 2011 – 2016) describes this as “substantial housing allocation”.
In addition, some of the individual sites challenge the Core Strategy with regard to density of housing. “Core Strategy Policy CS6.6 seeks an average density of 30 dwellings per hectare, with higher densities in town centres and locations with good public transport and lower densities in areas where there are environmental constraints.”
There is a clear breach of this policy in regard to site R110, south of Thornfield Road, where the DPD recommends building 66 dwellings on only 1.83 ha. This is not a town centre site and is not a location with good public transport.
3. Impact on Transport Infrastructure
The DPD, by placing all the emphasis on development in Grange South, ignores the Core Strategy’s warning (CS5.32) 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”.
An increase in population, on the scale proposed in the plan, would certainly result in at least 25% more traffic which would challenge its ambition of
“promoting the vitality of Grange Town Centre and promoting tourism”. (DPD 4.2)
The final plan seems to ignore the fact that,
“The main B5277 road runs through the heart of Grange over Sands … In places this road narrows and on some stretches, there is a feeling of car domination.”
(SLDC Framework Land Allocations Development Plan Document Consultation on emerging site options – Grange over Sands)
The Core Strategy also suggests that,
“Access into the peninsula is poor, limited mainly to the B5277/8 looping off the A590 to run through Grange, Allithwaite and Cark, the B6271 from Lindale and minor roads north of Cartmel.” (CS5.12)
Statistics from “count points” on the A590 show that between the Meathop Roundabout and Newby Bridge over 5000 vehicles joined or left the A590 per day in 2010. (Highways Agency Cumbria AADF statistics 2011) This confirms that there is already an extremely high volume of traffic coming in and out of the Cartmel Peninsula on unsuitable roads. Even The Development Plan itself admits,
“Elsewhere in the peninsula … the road network … is constrained in places.” (DPD 4.1)
It is likely to become very much more “constrained” if the volume of traffic grows by almost 25% in line with the proposed population increase in Grange-over-Sands, not forgetting the fact that,
“Car ownership levels in Grange … are high, with 80.7% of households having access to a car or van (compared to a Cumbria average of 75.6%)”.
(SLDC Framework Land Allocations Development Plan Document Consultation on emerging site options – Grange over Sands)
Even more significant is the apparent failure of SLDC to consider the impact of its plans for Grange-over-Sands, the Cartmel Peninsula and Ulverston together, on the wider transport infrastructure and especially the increase in volume of traffic on the A590. Whatever the discussions SLDC have had with The Highways Agency, the latter have no plans for improvements to the A590 before 2025 except a possible roundabout construction at Greenodd. A spokesman has told me that “Our current major scheme programme does not include any schemes on the A590”.
The most recent average annual daily flow (AADF) figures for the A590 show a steady increase of traffic on this road over the last 10 years, with almost 4000 more vehicles travelling daily in 2010 than in 2009. (Highways Agency Cumbria AADF statistics 2011)
This volume of traffic would be increased significantly by the proposals in the DPD for housing and industrial development in Cartmel Peninsula and Ulverston.
In the Cumbria County Council Local Transport Plan 2006 – 2011, it was noted that,
"The A590 between the Furness peninsula and the M6 motorway has several constrictions, including passing through Ulverston and ... long single carriageway sections with unimproved alignments. This causes unreliable and extended journey times between Furness and the rest of the region and UK, impeding economic development. The worsening position regarding average journey times on A590 has already been noted in the context of road safety”
What this means, according to provisional data published by the Highways Agency, is that on average only about 65% of journeys undertaken on A590 in 2011 were ‘on time’.(The national average for ‘on-time’ journeys was approximately 85%)(Journey Reliability Data to November 2011 – data.gov.uk)
In addition, Cumbria Constabulary has unofficially acknowledged that there were 3 fatalities and 6 serious injuries as a result of accidents in 2011 on the A590, making it the worst road in Cumbria for fatal accidents over the past 10 years.
If the potential increase in traffic as a result of DPD is added to the Department of Transport's own national statistical projections for 2025 of a 25% increase in volume of all traffic, and an increase in car ownership of 30% (Table TRA 9905), I believe that the actual increase in traffic on this dangerous road is likely to be at least 50% by 2025.
4. Failure to Comply with Core Strategy Methodology
Core Strategy clearly lays out a sequence for the planning process.
CS1.1 sets out “Sustainable Development Principles” including
“Development should accord with the following sequential approach:
• first, using existing buildings (including conversion) within settlements, and previously
developed land within settlements;
• second, using other suitable infill opportunities within settlements;
• third, the development of other land where this is well located in relation to housing, jobs, other services and infrastructure.”
CS1.2 states “Priority will be given to the reuse of existing buildings and previously developed land for all new housing development”
The question is now raised as to whether, in the light of the withdrawal of the Berner’s site proposals in Grange-over-Sands (25/01/12), these DPD plans might no longer be seen as having a ‘sequential’ approach –
“A sequential approach which looks first at previously used land and buildings within settlements” (2.22) before any ‘greenfield’ sites are developed.
The current land allocation plans for Grange need to be looked at again in the light of these principles and the recent failure of proposed schemes.
No ‘greenfield’ site should be earmarked for development until the use of ‘brownfield’ sites is resolved.
I believe that any one of these 4 issues renders the Land Allocation Proposals unsound but together they demand a radical reappraisal by South Lakes District Council as to how it develops land usage in Grange-over-Sands and District.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
5. Mr Andrew Mortimer (Individual) : 15 May 2012 12:05:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA3.3 Mixed Use Allocation at Guide's Lot, Grange-over-Sands
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I do not believe that South Lakeland District Council’s Land Allocation Development Plan Document (DPD) should be adopted in relation to planning for Grange-over-Sands and District because it is not sound.
It is not founded on robust and credible evidence, it makes assumptions that are based on out-of-date and poor research and, most importantly, it contains significant inconsistencies across the collection of ‘Local Development Framework’ (LDF) documents and, in particular, discrepancies and contradictions with the Core Strategy.
My principal objections are made on the grounds of:
1. site selection,
2. density
3. impact on transport infrastructure
4. failure to comply with core strategy methodology
1. Site Selection
I do not believe that the sites in Grange-over-Sands, identified for development in this plan, take sufficient account of the “detailed criteria” set out in DPD para 2.23 namely:
“General criteria such as the capacity of the site, the appropriate density at which it could be developed, the ease of accessing the site, the impact of topography and relief and the scope to meet identified needs …”
“Landscape and Settlement considerations including the potential impact of development on landscape and views, the scale of development relative to the settlement size, whether the site preserves the separate identity of settlements and the impact of development on site features such as trees, watercourses and buildings”
I also believe that some development would compromise an identified Green Gap.
For example, this would be the case if development were allowed on the scale proposed on site MN25M which would both visually and effectively join together the settlements of Grange-over-Sands, Kents Bank and Allithwaite.
Proposed development R110 would also compromise an important recreational open space. This is land “which is not accessible to the public but which nonetheless has amenity value because of its openness, appearance or landscape quality.” Using such sites for the density of development proposed contradicts the criteria for preserving Amenity Open Space, suggested in DPD para 2.63. It would also compromise the important recreational open space immediately next to it, turning it into little more than an urban playground.
Further, recommendations in the Grange Regeneration Study (which has informed the Core Strategy) about building a sense of place, business and tourist development etc would also be threatened by the DPD. Currently, as one walks or drives through Grange-over-Sands on the B5277, clear views across Morecambe Bay open out to give the visual and environmental qualities that make Grange unique and which attract visitors. The proposed developments would change those, often tree-lined, views into an unattractive urban ribbon development.
If the objective is “to deliver the vision and objectives set out in the Council’s adopted Core Strategy and help to make South Lakeland the best place to live, work and visit”(DPD 1.5), then the DPD choice of development sites in Grange-over-Sands must be considered more carefully.
2. Density
The DPD has not taken notice of the Core Strategy’s overarching development strategy (CS1.2), with regard to the impact that the suggested density of housing development in Grange-over-Sands would have in general on the landscape, historic setting, and the environment. Under the DPD proposals, between Grange Station and Kents Bank, all but one “greenfield” site would disappear.
The volume of housing development proposed is out of character and will change the unique and special nature of the area. It is not “moderate” as the Core Strategy would claim (Policy CS4).
500 dwellings in Grange-over-Sands would increase the current population by at least 25%.
I do not believe that an increase in population of a quarter could be considered “moderate”. Even the Local Transport Plan for South Lakeland (CCC Local Transport Plan 3, “Moving Cumbria Forward”, 2011 – 2016) describes this as “substantial housing allocation”.
In addition, some of the individual sites challenge the Core Strategy with regard to density of housing. “Core Strategy Policy CS6.6 seeks an average density of 30 dwellings per hectare, with higher densities in town centres and locations with good public transport and lower densities in areas where there are environmental constraints.”
There is a clear breach of this policy in regard to site R110, south of Thornfield Road, where the DPD recommends building 66 dwellings on only 1.83 ha. This is not a town centre site and is not a location with good public transport.
3. Impact on Transport Infrastructure
The DPD, by placing all the emphasis on development in Grange South, ignores the Core Strategy’s warning (CS5.32) 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”.
An increase in population, on the scale proposed in the plan, would certainly result in at least 25% more traffic which would challenge its ambition of
“promoting the vitality of Grange Town Centre and promoting tourism”. (DPD 4.2)
The final plan seems to ignore the fact that,
“The main B5277 road runs through the heart of Grange over Sands … In places this road narrows and on some stretches, there is a feeling of car domination.”
(SLDC Framework Land Allocations Development Plan Document Consultation on emerging site options – Grange over Sands)
The Core Strategy also suggests that,
“Access into the peninsula is poor, limited mainly to the B5277/8 looping off the A590 to run through Grange, Allithwaite and Cark, the B6271 from Lindale and minor roads north of Cartmel.” (CS5.12)
Statistics from “count points” on the A590 show that between the Meathop Roundabout and Newby Bridge over 5000 vehicles joined or left the A590 per day in 2010. (Highways Agency Cumbria AADF statistics 2011) This confirms that there is already an extremely high volume of traffic coming in and out of the Cartmel Peninsula on unsuitable roads. Even The Development Plan itself admits,
“Elsewhere in the peninsula … the road network … is constrained in places.” (DPD 4.1)
It is likely to become very much more “constrained” if the volume of traffic grows by almost 25% in line with the proposed population increase in Grange-over-Sands, not forgetting the fact that,
“Car ownership levels in Grange … are high, with 80.7% of households having access to a car or van (compared to a Cumbria average of 75.6%)”.
(SLDC Framework Land Allocations Development Plan Document Consultation on emerging site options – Grange over Sands)
Even more significant is the apparent failure of SLDC to consider the impact of its plans for Grange-over-Sands, the Cartmel Peninsula and Ulverston together, on the wider transport infrastructure and especially the increase in volume of traffic on the A590. Whatever the discussions SLDC have had with The Highways Agency, the latter have no plans for improvements to the A590 before 2025 except a possible roundabout construction at Greenodd. A spokesman has told me that “Our current major scheme programme does not include any schemes on the A590”.
The most recent average annual daily flow (AADF) figures for the A590 show a steady increase of traffic on this road over the last 10 years, with almost 4000 more vehicles travelling daily in 2010 than in 2009. (Highways Agency Cumbria AADF statistics 2011)
This volume of traffic would be increased significantly by the proposals in the DPD for housing and industrial development in Cartmel Peninsula and Ulverston.
In the Cumbria County Council Local Transport Plan 2006 – 2011, it was noted that,
"The A590 between the Furness peninsula and the M6 motorway has several constrictions, including passing through Ulverston and ... long single carriageway sections with unimproved alignments. This causes unreliable and extended journey times between Furness and the rest of the region and UK, impeding economic development. The worsening position regarding average journey times on A590 has already been noted in the context of road safety”
What this means, according to provisional data published by the Highways Agency, is that on average only about 65% of journeys undertaken on A590 in 2011 were ‘on time’.(The national average for ‘on-time’ journeys was approximately 85%)(Journey Reliability Data to November 2011 – data.gov.uk)
In addition, Cumbria Constabulary has unofficially acknowledged that there were 3 fatalities and 6 serious injuries as a result of accidents in 2011 on the A590, making it the worst road in Cumbria for fatal accidents over the past 10 years.
If the potential increase in traffic as a result of DPD is added to the Department of Transport's own national statistical projections for 2025 of a 25% increase in volume of all traffic, and an increase in car ownership of 30% (Table TRA 9905), I believe that the actual increase in traffic on this dangerous road is likely to be at least 50% by 2025.
4. Failure to Comply with Core Strategy Methodology
Core Strategy clearly lays out a sequence for the planning process.
CS1.1 sets out “Sustainable Development Principles” including
“Development should accord with the following sequential approach:
• first, using existing buildings (including conversion) within settlements, and previously
developed land within settlements;
• second, using other suitable infill opportunities within settlements;
• third, the development of other land where this is well located in relation to housing, jobs, other services and infrastructure.”
CS1.2 states “Priority will be given to the reuse of existing buildings and previously developed land for all new housing development”
The question is now raised as to whether, in the light of the withdrawal of the Berner’s site proposals in Grange-over-Sands (25/01/12), these DPD plans might no longer be seen as having a ‘sequential’ approach –
“A sequential approach which looks first at previously used land and buildings within settlements” (2.22) before any ‘greenfield’ sites are developed.
The current land allocation plans for Grange need to be looked at again in the light of these principles and the recent failure of proposed schemes.
No ‘greenfield’ site should be earmarked for development until the use of ‘brownfield’ sites is resolved.
I believe that any one of these 4 issues renders the Land Allocation Proposals unsound but together they demand a radical reappraisal by South Lakes District Council as to how it develops land usage in Grange-over-Sands and District.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
