5 responses from Miss Camilla James, Planning Branch Ltd
1. Miss Camilla James, Planning Branch Ltd : 30 Mar 2012 11:34:00
A typed or handwritten document was submitted. This has been scanned and can be downloaded below:
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Policy/Site No.
SO Site Omission
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RN35 Cartmel
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.
1.0 Introduction
The following document provides a representation on the soundness of the South Lakeland Land Allocations Development Plan Document (DPD); commenting on its justification, with regard to research / fact finding, and the decisions / conclusions which are made in the plan. The focal point for this representation is concerned with the following site:
1. The submission of SHLAA site RN35 - Land adjacent Cartmel Old Grammar, Cartmel, Grange-Over-Sands
This assessment aims to call into question the robust and credible evidence base upon which the DPD is founded.
2.0 Purpose of this Document
This document has been produced in response to the exclusion of SHLAA site RN35. The justification received for the sites removal is as follows:
‘The Council has decided not to allocate sites for residential development outside of Principle, Key or Local Service Centres i.e. the Council will not be allocating sites in small villages and hamlets or in the open countryside as part of the Land Allocations process.’
Map Extract of Site:
Site Details: Gross/Net Area (hectares): 0.49/0.44
Possible yield: 13 (30dph)
Brownfield or Greenfield: Greenfield
3.0 Justification for Site Inclusion
Planning Branch has undertaken an assessment of SHLAA site RN35 and is of the opinion that there is justification for its inclusion based on the following criteria:
a) Character of Settlement
b) Site Location
c) Sequential Analysis
Character of Settlement
The settlement has no rigid developed form and development pattern, comprising somewhat unrelated dense linear forms developed adjacent to the highway infrastructure serving the settlement. This ribbon form of development is a consequence of constraint by the existing settlement form, community open spaces and flood areas within the confines of the settlement. The infill development of the identified site would act to emulate and reinforce this type of development to the northern extent of the settlement and would act to prevent any adverse detraction resulting from an over concentration of development within the central element of the settlement as would result from the development of the extensive site existing to the east of the settlement. As is illustrated on figure
It can be argued that the current development boundaries for Cartmel, as identified by the Land Allocations DPD are unduly restrictive to the development pattern of the settlement, and as a result detrimental to the preservation of the settlement pattern. As can be interpreted from figure 3.2, development of SHLAA site RN35 would be in conformity with the existing settlement, and relate well to the centre of Cartmel.
Site Location
The site is located to the north of the settlement of Cartmel approximately 430m north of the defined settlement boundary. Although outside the settlement boundary, the site is located on a bus route. Per the justification for the location of the residential care facilities adjacent to the application site, under planning application reference 5980488, the site is located within walking distance of the central village facilities (c.570m), Cartmel Church (c.670m) and Cartmel School (c.1.1km) utilising the existing highway and pedestrian infrastructure, reducing the reliance upon private care usage to access the key services located within the settlement of Cartmel.
At a normal pace it takes 7 minutes to walk from the site to the shop and pub in the village of Cartmel.
In addition to the information relating to the general level of overall need for residential accommodation in this location. Specific need for older persons one and two bedroom accommodation is identified within the SHMA.
Older 1 Bedroom 8% (6 dwellings x 74.1% = 4 per annum)
Older 2 Bedroom 7% (5 dwellings x 74.1% = 4 per annum)
Given the relationship to the existing care facilities the development site offers a primary opportunity to procure an inclusive mixed community incorporating independent and sheltered elderly people’s accommodation to meet this overarching need within this retirement settlement. The proximity to the facility would offer significant potential for social interaction to the benefit of the occupant’s mental health and quality of life.
Sequential Analysis
As previously discussed, given the character of the settlement and its site location, the interpretation given by map 34 of the Land Allocations Emerging Options Consultation (see appendix 1) can be deemed unjustifiable. Site RN35 should not be classified as a site within the open countryside as it relates well to the adjacent settlement of Cartmel, it is therefore inaccurate to classify the site as being removed from a settlement.
On this reasoning the council’s decision not to allocate the site for residential development due simply to the fact it is outside a key, principle, or local service centre is unsound. As a result of which a sequential analysis has been carried out to consider how the site performs in comparison to the other suitable sites within Cartmel.
Sites R112 & ON17
Although within the development boundary, the land area does not relate well to the character of the settlement within Cartmel. Over development of this site would result in an over concentration of dwellings to the east dramatically and irreversibly altering the development pattern of the settlement and therefore serving to erode the character and organic expansion of Cartmel.
Access may also be a concern, with only one point of entry/exit serving the development and feeding onto the highway.
Site RN14
Despite being within flood risk zone 2 site RN14 does respect the existing development pattern of Cartmel, and unlike sites R112 & ON17 it is of a modest scale as to prevent the over concentration of development within the central element of the settlement.
It is proposed a phased development of sites RN14 and RN35 could occur, thereby ensuring that that RN35 relates well to the settlement of Cartmel in terms of its proximity to the central element without detracting from the existing development pattern of the settlement as would occur if sites R112 & ON17 are to be included.
The phased development of sites RN14 and RN35 would safeguard the settlements character and organic ribbon form of expansion whilst taking advantage of infill sites with strong access points, and together would provide the housing need for Cartmel.
4.0 Conclusion
From the assessment carried out by Planning Brach it is evident there are strong grounds for SHLAA site RN35’s inclusion within the Land Allocations DPD. This report brings into question the robust and sound basis on which site selection has taken place; bringing into contention the credibility of the document.
- When assessing site RN35‘s potential for inclusion within the DPD the character of the settlement of Cartmel was overlooked, and as a result the site was misidentified as being within the open countryside.
- When considered as a site within the Cartmel settlement RN35 together with RN14 sequentially outperform included sites R112 & ON17.
Appendix 1
Extract from the Land Allocations Emerging Options Consultation
By South Lakeland District Council
Map 34: Open Countryside sites in Cartmel Peninsula
For Maps and figures please refer to attached document
2. Miss Camilla James, Planning Branch Ltd : 11 Apr 2012 15:02:00
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Paragraph No.
2.62
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.
Justification for Change of Land Allocation
a) Insufficient Evidence Base for the allocation of site AS100 as an Amenity Open Space
The Land Allocations Document states that the Open Space, Sport and Recreation Assessment commissioned by the council in 2007, provides the evidence base upon which sites were allocated for urban greenspace and public open space. However, site AS100 does not appear to have been included within this assessment and no other sources of evidence are provided for its allocation as an amenity open space. No evidence of consultation with parish and town councils regarding the sites allocation is included.
On this basis, it is considered that the allocation of site AS100 as amenity open space is not justified. The DPD does not demonstrate a sufficient degree of evidence of participation of the local community in relation to this site, and as such, the decision made in the document to allocate the site as amenity open space is not backed up by facts.
b) Low Amenity Value of the site
From an assessment of the site AS100 it is considered the amenity value and visual quality of site are very low. Despite the fact, there are trees on the site; the area is heavily brambled, not accessible to the public, unsafe and not of a quality to be deemed a valuable visual amenity.
The site is not a valuable open space and should not have scored sufficiently within an assessment to support its designation within the Land Allocations.
c) Reclassification of site to housing
Site AS100 was identified within the SHLAA (as site 787) although its justification for reclassification to Amenity Open Space is not disclosed within the DPD. The adjacent land, which engulfs the site, has been identified as a housing site (R107M & R150M). It was established in the Councils SHLAA that site AS100 has a housing yield potential of 14, the landowner is willing to develop the site for housing. The most effective use of the land would be its residential development in association with sites R107M & R150M.
Proposed change of Land Allocation
This representation puts forward a change in the land allocation of site AS100 from that of Amenity Open Space to that of a housing site; with the intention of its development in association with immediately adjacent sites R107M and R150M. It is considered this change of allocation will improve the yield and appearance of the identified site, allowing the residential development to uphold a structured settlement pattern.
The reclassification of site AS100 to that of housing is considered the most appropriate strategy in terms of the council meeting its future housing targets. Neighbouring Public Open Space sites (PS225, PS257, and PS61) that are of a higher amenity value than AS100, will ensure that if the site is reclassified as a housing site, the surrounding area is still served adequately and sufficiently to meet the required open space needs.
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. Miss Camilla James, Planning Branch Ltd : 15 May 2012 15:48:00
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 - R107M mod and R150M KENDAL KENDAL PARKS
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.
Justification for Change of Land Allocation
a) Insufficient Evidence Base for the allocation of site AS100 as an Amenity Open Space
The Land Allocations Document states that the Open Space, Sport and Recreation Assessment commissioned by the council in 2007, provides the evidence base upon which sites were allocated for urban greenspace and public open space. However, site AS100 does not appear to have been included within this assessment and no other sources of evidence are provided for its allocation as an amenity open space. No evidence of consultation with parish and town councils regarding the sites allocation is included.
On this basis, it is considered that the allocation of site AS100 as amenity open space is not justified. The DPD does not demonstrate a sufficient degree of evidence of participation of the local community in relation to this site, and as such, the decision made in the document to allocate the site as amenity open space is not backed up by facts.
b) Low Amenity Value of the site
From an assessment of the site AS100 it is considered the amenity value and visual quality of site are very low. Despite the fact, there are trees on the site; the area is heavily brambled, not accessible to the public, unsafe and not of a quality to be deemed a valuable visual amenity.
The site is not a valuable open space and should not have scored sufficiently within an assessment to support its designation within the Land Allocations.
c) Reclassification of site to housing
Site AS100 was identified within the SHLAA (as site 787) although its justification for reclassification to Amenity Open Space is not disclosed within the DPD. The adjacent land, which engulfs the site, has been identified as a housing site (R107M & R150M). It was established in the Councils SHLAA that site AS100 has a housing yield potential of 14, the landowner is willing to develop the site for housing. The most effective use of the land would be its residential development in association with sites R107M & R150M.
Proposed change of Land Allocation
This representation puts forward a change in the land allocation of site AS100 from that of Amenity Open Space to that of a housing site; with the intention of its development in association with immediately adjacent sites R107M and R150M. It is considered this change of allocation will improve the yield and appearance of the identified site, allowing the residential development to uphold a structured settlement pattern.
The reclassification of site AS100 to that of housing is considered the most appropriate strategy in terms of the council meeting its future housing targets. Neighbouring Public Open Space sites (PS225, PS257, and PS61) that are of a higher amenity value than AS100, will ensure that if the site is reclassified as a housing site, the surrounding area is still served adequately and sufficiently to meet the required open space needs.
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. Miss Camilla James, Planning Branch Ltd : 15 May 2012 15:52:00
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.
LA1.10 Existing Green Infrastructure
If you have selected a ‘Site omission’ please enter the site reference or location and relevant policy below
AS100 (not omission, objection)
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.
Justification for Change of Land Allocation
a) Insufficient Evidence Base for the allocation of site AS100 as an Amenity Open Space
The Land Allocations Document states that the Open Space, Sport and Recreation Assessment commissioned by the council in 2007, provides the evidence base upon which sites were allocated for urban greenspace and public open space. However, site AS100 does not appear to have been included within this assessment and no other sources of evidence are provided for its allocation as an amenity open space. No evidence of consultation with parish and town councils regarding the sites allocation is included.
On this basis, it is considered that the allocation of site AS100 as amenity open space is not justified. The DPD does not demonstrate a sufficient degree of evidence of participation of the local community in relation to this site, and as such, the decision made in the document to allocate the site as amenity open space is not backed up by facts.
b) Low Amenity Value of the site
From an assessment of the site AS100 it is considered the amenity value and visual quality of site are very low. Despite the fact, there are trees on the site; the area is heavily brambled, not accessible to the public, unsafe and not of a quality to be deemed a valuable visual amenity.
The site is not a valuable open space and should not have scored sufficiently within an assessment to support its designation within the Land Allocations.
c) Reclassification of site to housing
Site AS100 was identified within the SHLAA (as site 787) although its justification for reclassification to Amenity Open Space is not disclosed within the DPD. The adjacent land, which engulfs the site, has been identified as a housing site (R107M & R150M). It was established in the Councils SHLAA that site AS100 has a housing yield potential of 14, the landowner is willing to develop the site for housing. The most effective use of the land would be its residential development in association with sites R107M & R150M.
Proposed change of Land Allocation
This representation puts forward a change in the land allocation of site AS100 from that of Amenity Open Space to that of a housing site; with the intention of its development in association with immediately adjacent sites R107M and R150M. It is considered this change of allocation will improve the yield and appearance of the identified site, allowing the residential development to uphold a structured settlement pattern.
The reclassification of site AS100 to that of housing is considered the most appropriate strategy in terms of the council meeting its future housing targets. Neighbouring Public Open Space sites (PS225, PS257, and PS61) that are of a higher amenity value than AS100, will ensure that if the site is reclassified as a housing site, the surrounding area is still served adequately and sufficiently to meet the required open space needs.
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. Miss Camilla James, Planning Branch Ltd : 15 May 2012 15:54:00
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 - Site Omission
If you have selected a ‘Site omission’ please enter the site reference or location and relevant policy below
R34
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.
Justification for Change of Land Allocation
a) Insufficient Evidence Base for the allocation of site AS100 as an Amenity Open Space
The Land Allocations Document states that the Open Space, Sport and Recreation Assessment commissioned by the council in 2007, provides the evidence base upon which sites were allocated for urban greenspace and public open space. However, site AS100 does not appear to have been included within this assessment and no other sources of evidence are provided for its allocation as an amenity open space. No evidence of consultation with parish and town councils regarding the sites allocation is included.
On this basis, it is considered that the allocation of site AS100 as amenity open space is not justified. The DPD does not demonstrate a sufficient degree of evidence of participation of the local community in relation to this site, and as such, the decision made in the document to allocate the site as amenity open space is not backed up by facts.
b) Low Amenity Value of the site
From an assessment of the site AS100 it is considered the amenity value and visual quality of site are very low. Despite the fact, there are trees on the site; the area is heavily brambled, not accessible to the public, unsafe and not of a quality to be deemed a valuable visual amenity.
The site is not a valuable open space and should not have scored sufficiently within an assessment to support its designation within the Land Allocations.
c) Reclassification of site to housing
Site AS100 was identified within the SHLAA (as site 787) although its justification for reclassification to Amenity Open Space is not disclosed within the DPD. The adjacent land, which engulfs the site, has been identified as a housing site (R107M & R150M). It was established in the Councils SHLAA that site AS100 has a housing yield potential of 14, the landowner is willing to develop the site for housing. The most effective use of the land would be its residential development in association with sites R107M & R150M.
Proposed change of Land Allocation
This representation puts forward a change in the land allocation of site AS100 from that of Amenity Open Space to that of a housing site; with the intention of its development in association with immediately adjacent sites R107M and R150M. It is considered this change of allocation will improve the yield and appearance of the identified site, allowing the residential development to uphold a structured settlement pattern.
The reclassification of site AS100 to that of housing is considered the most appropriate strategy in terms of the council meeting its future housing targets. Neighbouring Public Open Space sites (PS225, PS257, and PS61) that are of a higher amenity value than AS100, will ensure that if the site is reclassified as a housing site, the surrounding area is still served adequately and sufficiently to meet the required open space needs.
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
