5 responses from Mr Robinson , c/o Indigo Planning
1. Mr Robinson , c/o Indigo Planning : 5 Apr 2012 11:47:00
A typed or handwritten document was submitted. This has been scanned and can be downloaded below:
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
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Policy/Site No.
LA1.3 Housing Allocations - All Kirkby-in-Furness sites
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
1.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
The continued inclusion within Policy LA1.3: Housing Allocations of site R29m (Four Lane Ends, Kirkby In Furness) is supported.
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.
We seek the following changes to the emerging Land Allocation Development Plan Document (DPD) Policy LA1.3: Housing Allocations, as representing a more sustainable and sound approach the planning and development of Kirkby in Furness:
(a) The reinstatement of the allocation of Site R189M for residential development - as detailed on Map 40 of the Land Allocations Proposal Map published on 29 July 2011. Proposal R189M is not included on Map 17 of the Land Allocations Proposal Map published on 2 March 2012, which is the subject of the current consultation.
(b) The removal of the allocation Site RN11 for residential development as detailed on Map 17 of the Land Allocations Proposal Map published on 2 March 2012.
Our reasoned justification for the above outcome is provided below:
1. The allocation of R189M as oppose RN11 represents a more sustainable approach to the development of Kirkby on Furness. It better accords with the sequential approach to the location of new housing development identified in the adopted South Lakeland Local Development Framework – Core Strategy 2010.
Policy CS6.1 – Meeting the housing requirement - contained in the adopted South Lakeland Local Development Framework – Core Strategy 2010 states that sites will be allocated in the Land Allocation DPD using the sequential approach to housing development identified in PPS 3 (now replaced) and Spatial Strategy Policies CS1.1.
Policy CS1.1 referred to above states:
‘8. 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’.
It is submitted that the development of Site R189M as oppose RN11 better accords with this adopted sequential approach to the location of new residential development for the following reasons:
• It is located closer to the core of the existing settlement and is bounded by development on three sides. It will also occupy the only significant remaining undeveloped road frontage within the settlement, on the southern side of Side Sands Road. It is submitted that this is more sustainable than the development of Site RN11, which will result in the physical extension of the settlement to the north along the A595.
• Site 189M is better located in relation to services and infrastructure in the settlement including the village post office, pub and railway station.
Site R189M therefore performs better than RN11 in terms of the sequential approach to the location of new residential development.
2. The allocation of Site R189M as oppose RN11 accords with the identification of the lands incorporating R189M in Employment and Housing Land Search Study (EHLSS). It will also be preferable in terms of settlement character, visual impact and traffic impacts.
Site R189M was identified for residential development in the earlier draft of the Land Allocations DPD (Map 40). Site R189M (which incorporates R29, R189 and part of RN170) forms Site 2 (Side Sands) identified in the Employment and Housing Land Search Study (EHLSS). It is one of only two potential residential development sites identified in Kirkby in Furness.
The site identified as a Category 2 Site in the EHLSS. This is described as a site having a high degree of sustainability and a medium degree of deliverability.
The identification of the lands incorporating Site R189M in the EHLSS is significant. The land has therefore been the subject of strategic analysis and their identification for residential development can be seen to have a rational planning basis.
It is also important to note that Site RN11 was not identified in the EHLSS. Furthermore, the Kirkby in Furness (including Sand Site and Beck Side) Fact File - February 2012 states:
‘The EHLSS states that development to the north of the Kirkby in Furness is not recommended. It states that development would impact on the extensive views of the Duddon Estuary and impact on coalescence between Wall End and Kirkby. It does not recommend development in this area.’
This is a clear rationale why the allocation of the RN11 lands for residential development is unsustainable and at odds with the proper planning of the area. The proposal to allocate the land for residential development is therefore unsound – particularly when Site R189M is available and preferable in terms of overall sustainability, settlement character, visual impact and traffic impacts.
3. The appropriate development of Site R189M as oppose RN11 will make a positive contribution to settlement structure and actively support consolidation of the settlement in accordance with its prevailing character.
Site R189M performs well in the Sustainability Appraisal provided at Appendix 3 of the Kirkby in Furness (including Sand Site and Beck Side) Fact File - February 2012. The site performs well in terms of access to primary school, health services, avoidance of coalescence and access to public transport. It is also located within short walking distance of other key amenities / services including the railway station, village pub and post office.
The Fact File also recognises that the site is centrally located within the settlement, has the potential to provide a stronger development boundary and improve the visual approach to Kirkby from the south.
The development of Site R189M will also have a consolidating effect in the settlement. It will complete a prevailing pattern of development in the settlement, in which development is located on both sides of the A595 and Sand Side Road. Site R189 is currently the only road frontage within the existing settlement boundary which is undeveloped land. The development of this land would have a significant positive consolidating effect on the settlement streetscape - completing the prevailing form of development within the existing settlement envelope.
This contrasts with the potential impact of the allocation of the RN11 lands. This would result in an extension of the settlement boundary in a northern direction and would exacerbate an unsustainable linear form of development along the A595. This would also have a negative impact on coalescence and result in reduced undeveloped break between Kirkby and Wall End of only c. 280 metres. This potential negative impact was noted in the Sustainability Appraisal contained in the Fact File which identifies that the Site RN11 performs poorly in terms of coalescence.
4. The appropriate development of Site R189M will have limited visual impact. This is due to its relatively flat topography and existing screening resulting from the central location of the site within the settlement; surrounded by existing development. The development of RN11 is potentially more problematic due to the sloping nature of the site and its peripheral location. The EHLSS specifically recommends against development of the lands incorporating Site RN11 on visual impact grounds.
The appropriate development of Site R189M has the potential to achieve positive visual impacts in terms of strengthening the development boundary of Kirkby in this area of the settlement and improving the visual approach to Kirkby from the south. These potential positives are identified in the Fact File
Any potential longer range visual impact will be mitigated by existing surrounding development. This includes the village pub, existing residential development to the north and south of Sand Side Road and the terrace of houses to the east of the A585 and south of Beck Side Road.
Site R189M is identified as being located in Landscape Character Area 2c Coastal Plain in the Cumbria Landscape Character Guidance and Toolkit. This is the same designation as afforded to the bulk of the settlement. This contrasts with the designation of the RN11 Site as Area 9d Ridges. This is the prevailing designation of the upland areas to the east of Kirkby which are predominately undeveloped in character.
The upward sloping nature of Site RN11 from the A595 is such that development on these lands may have a significant negative visual impact on views from Kirkby towards the upland areas to the north east. Furthermore, the EHLSS identifies that development to the north of Kirkby in Furness is not recommended. It states that development would impact upon the extensive views of the Duddon Estuary. It does not recommend development in this area.
These factors combine to mean there are significantly more potential negative visual impacts associated with development of Site RN11 than R189M.
5. The appropriate development of allocation of R189M as oppose RN11 has the potential to make a significant positive contribution to the highway and pedestrian network in Kirkby in Furness. It will facilitate the improvement of the existing STOP junction and improve pedestrian access to the adjacent railway station and local services.
A comprehensive Highway and Transport Report has been prepared in support of the allocation of R189M by VTC (Highway and Transport Consultants). This document is included with this submission.
The report identifies that there are a number of deficiencies in the highway network in the settlement including the STOP junction at the intersection of Sand Side Road and the A595, the restricted width of Sand Side Road and the lack of pedestrian footpaths on a stretch of Sand Side Road.
These deficiencies could be alleviated by the allocation of R189M. Any future development of the lands would facilitate the widening of Sand Side Road and the provision of appropriate pedestrian footpaths. Significantly, the development of R189M would facilitate the provision of a new road linking from the western end of Sand Side Road to the A595 and forming a new junction onto the A595 approximately 80 metres south of the existing junction with Sand Side Road. This in turn could facilitate the designation of Sand Side Road as a one way only road (east to west) and thereby remove issues with the existing STOP junction and the width of Sand Side Road. These measures would be subject to agreement with the Highways Authority, however the Highway and Transport Report identifies that this new road has been recommended by the Highways Authority (Paragraph 4.5).
While the allocation of Site R189M provides these significant potential improvements to the road network in Kirkby, no such benefits would be associated with the allocation of RN11. Furthermore, we note that the development of these lands likely require a new access to the A595 at a location adjacent to the existing primary school.
Summary / Conclusions
Table 1.1 below summarises the characteristic of both R189M and RN11 and should be considered with the following conclusions.
• The allocation of R189M as oppose RN11 represents a more sustainable approach to the development of Kirkby on Furness. It better accords with the sequential approach to the location of new housing development identified in the adopted South Lakeland Local Development Framework – Core Strategy 2010.
• The allocation of Site R189M as oppose RN11 accords with the identification of the lands incorporating R189M in Employment and Housing Land Search Study (EHLSS). It will also be preferable in terms of settlement character, visual impact and traffic impacts.
• The appropriate development of Site R189M as oppose RN11 will make a positive contribution to settlement structure and actively support consolidation of the settlement in accordance with its prevailing character.
• The appropriate development of Site R189M will have limited visual impact. This is due to its relatively flat topography and existing screening resulting from the central location of the site within the settlement; surrounded by existing development. The development of RN11 is potentially more problematic due to the sloping nature of the site and its peripheral location. The EHLSS specifically recommends against development of the lands incorporating Site RN11 on visual impact grounds.
• The appropriate development of allocation of R189M as oppose RN11 has the potential to make a significant positive contribution to the highway and pedestrian network in Kirkby in Furness. It will facilitate the improvement of the existing STOP junction and improve pedestrian access to the adjacent railway station and local services.
For the above reasons - the reinstatement of the allocation for residential development of Site R189M and removal of the allocation Site RN11 is considered a more sound approach to the emerging Land Allocation Development Plan Document (DPD) and is sought as an outcome of this submission.
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
The continued inclusion within Policy LA1.3: Housing Allocations of site R29m (Four Lane Ends, Kirkby In Furness) is supported.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
To ensure my client is best represented as it is probable that the land owner of RN11 will be represented 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 Robinson , c/o Indigo Planning : 15 May 2012 10:14:00
A typed or handwritten document was submitted. This has been scanned and can be downloaded below:
Policy/Site No.
LA1.3 Housing Allocations - R29M KIRKBY-in- FURNESS FOUR LANE ENDS
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.
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
Firstly we wish to submit our support for the continued inclusion of allocation R29 within the DPD
1. The allocation of R189M as oppose RN11 represents a more sustainable approach to the development of Kirkby on Furness. It better accords with the sequential approach to the location of new housing development identified in the adopted South Lakeland Local Development Framework – Core Strategy 2010.
Policy CS6.1 – Meeting the housing requirement - contained in the adopted South Lakeland Local Development Framework – Core Strategy 2010 states that sites will be allocated in the Land Allocation DPD using the sequential approach to housing development identified in PPS 3 (now replaced) and Spatial Strategy Policies CS1.1.
Policy CS1.1 referred to above states:
‘8. 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’.
It is submitted that the development of Site R189M as oppose RN11 better accords with this adopted sequential approach to the location of new residential development for the following reasons:
• It is located closer to the core of the existing settlement and is bounded by development on three sides. It will also occupy the only significant remaining undeveloped road frontage within the settlement, on the southern side of Side Sands Road. It is submitted that this is more sustainable than the development of Site RN11, which will result in the physical extension of the settlement to the north along the A595.
• Site 189M is better located in relation to services and infrastructure in the settlement including the village post office, pub and railway station.
A highway and Transport report has been prepared in support of allocation
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
To ensure my client is best represented as it is probable that the land owner of RN11 will be represented 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 Robinson , c/o Indigo Planning : 15 May 2012 10:29:00
A typed or handwritten document was submitted. This has been scanned and can be downloaded below:
Policy/Site No.
LA1.3 Housing Allocations - RN11# KIRKBY-in- FURNESS LAND ADJACENT TO BURLINGTON C OF E SCHOOL
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.
We seek the following changes to the emerging Land Allocation Development Plan Document (DPD) Policy LA1.3: Housing Allocations, as representing a more sustainable and sound approach the planning and development of Kirkby in Furness:
(a) The reinstatement of the allocation of Site R189M for residential development - as detailed on Map 40 of the Land Allocations Proposal Map published on 29 July 2011. Proposal R189M is not included on Map 17 of the Land Allocations Proposal Map published on 2 March 2012, which is the subject of the current consultation.
1. The allocation of R189M as oppose RN11 represents a more sustainable approach to the development of Kirkby on Furness. It better accords with the sequential approach to the location of new housing development identified in the adopted South Lakeland Local Development Framework – Core Strategy 2010.
Policy CS6.1 – Meeting the housing requirement - contained in the adopted South Lakeland Local Development Framework – Core Strategy 2010 states that sites will be allocated in the Land Allocation DPD using the sequential approach to housing development identified in PPS 3 (now replaced) and Spatial Strategy Policies CS1.1.
Policy CS1.1 referred to above states:
‘8. 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’.
It is submitted that the development of Site R189M as oppose RN11 better accords with this adopted sequential approach to the location of new residential development for the following reasons:
• It is located closer to the core of the existing settlement and is bounded by development on three sides. It will also occupy the only significant remaining undeveloped road frontage within the settlement, on the southern side of Side Sands Road. It is submitted that this is more sustainable than the development of Site RN11, which will result in the physical extension of the settlement to the north along the A595.
• Site 189M is better located in relation to services and infrastructure in the settlement including the village post office, pub and railway station.
Site R189M therefore performs better than RN11 in terms of the sequential approach to the location of new residential development.
2. The allocation of Site R189M as oppose RN11 accords with the identification of the lands incorporating R189M in Employment and Housing Land Search Study (EHLSS). It will also be preferable in terms of settlement character, visual impact and traffic impacts.
Site R189M was identified for residential development in the earlier draft of the Land Allocations DPD (Map 40). Site R189M (which incorporates R29, R189 and part of RN170) forms Site 2 (Side Sands) identified in the Employment and Housing Land Search Study (EHLSS). It is one of only two potential residential development sites identified in Kirkby in Furness.
The site identified as a Category 2 Site in the EHLSS. This is described as a site having a high degree of sustainability and a medium degree of deliverability.
3. The appropriate development of Site R189M as oppose RN11 will make a positive contribution to settlement structure and actively support consolidation of the settlement in accordance with its prevailing character.
Site R189M performs well in the Sustainability Appraisal provided at Appendix 3 of the Kirkby in Furness (including Sand Site and Beck Side) Fact File - February 2012. The site performs well in terms of access to primary school, health services, avoidance of coalescence and access to public transport. It is also located within short walking distance of other key amenities / services including the railway station, village pub and post office.
The Fact File also recognises that the site is centrally located within the settlement, has the potential to provide a stronger development boundary and improve the visual approach to Kirkby from the south.
The development of Site R189M will also have a consolidating effect in the settlement. It will complete a prevailing pattern of development in the settlement, in which development is located on both sides of the A595 and Sand Side Road. Site R189 is currently the only road frontage within the existing settlement boundary which is undeveloped land. The development of this land would have a significant positive consolidating effect on the settlement streetscape - completing the prevailing form of development within the existing settlement envelope.
4. The appropriate development of Site R189M will have limited visual impact. This is due to its relatively flat topography and existing screening resulting from the central location of the site within the settlement; surrounded by existing development. The development of RN11 is potentially more problematic due to the sloping nature of the site and its peripheral location. The EHLSS specifically recommends against development of the lands incorporating Site RN11 on visual impact grounds.
The appropriate development of Site R189M has the potential to achieve positive visual impacts in terms of strengthening the development boundary of Kirkby in this area of the settlement and improving the visual approach to Kirkby from the south. These potential positives are identified in the Fact File
Any potential longer range visual impact will be mitigated by existing surrounding development. This includes the village pub, existing residential development to the north and south of Sand Side Road and the terrace of houses to the east of the A585 and south of Beck Side Road.
Site R189M is identified as being located in Landscape Character Area 2c Coastal Plain in the Cumbria Landscape Character Guidance and Toolkit. This is the same designation as afforded to the bulk of the settlement. This contrasts with the designation of the RN11 Site as Area 9d Ridges. This is the prevailing designation of the upland areas to the east of Kirkby which are predominately undeveloped in character.
5. The appropriate development of allocation of R189M as oppose RN11 has the potential to make a significant positive contribution to the highway and pedestrian network in Kirkby in Furness. It will facilitate the improvement of the existing STOP junction and improve pedestrian access to the adjacent railway station and local services.
A comprehensive Highway and Transport Report has been prepared in support of the allocation of R189M by VTC (Highway and Transport Consultants). This document is included with this submission.
The report identifies that there are a number of deficiencies in the highway network in the settlement including the STOP junction at the intersection of Sand Side Road and the A595, the restricted width of Sand Side Road and the lack of pedestrian footpaths on a stretch of Sand Side Road.
These deficiencies could be alleviated by the allocation of R189M. Any future development of the lands would facilitate the widening of Sand Side Road and the provision of appropriate pedestrian footpaths. Significantly, the development of R189M would facilitate the provision of a new road linking from the western end of Sand Side Road to the A595 and forming a new junction onto the A595 approximately 80 metres south of the existing junction with Sand Side Road. This in turn could facilitate the designation of Sand Side Road as a one way only road (east to west) and thereby remove issues with the existing STOP junction and the width of Sand Side Road. These measures would be subject to agreement with the Highways Authority, however the Highway and Transport Report identifies that this new road has been recommended by the Highways Authority (Paragraph 4.5).
While the allocation of Site R189M provides these significant potential improvements to the road network in Kirkby, no such benefits would be associated with the allocation of RN11. Furthermore, we note that the development of these lands likely require a new access to the A595 at a location adjacent to the existing primary school.
Summary / Conclusions
Table 1.1 below summarises the characteristic of both R189M and RN11 and should be considered with the following conclusions.
• The allocation of R189M as oppose RN11 represents a more sustainable approach to the development of Kirkby on Furness. It better accords with the sequential approach to the location of new housing development identified in the adopted South Lakeland Local Development Framework – Core Strategy 2010.
• The allocation of Site R189M as oppose RN11 accords with the identification of the lands incorporating R189M in Employment and Housing Land Search Study (EHLSS). It will also be preferable in terms of settlement character, visual impact and traffic impacts.
• The appropriate development of Site R189M as oppose RN11 will make a positive contribution to settlement structure and actively support consolidation of the settlement in accordance with its prevailing character.
• The appropriate development of Site R189M will have limited visual impact. This is due to its relatively flat topography and existing screening resulting from the central location of the site within the settlement; surrounded by existing development. The development of RN11 is potentially more problematic due to the sloping nature of the site and its peripheral location. The EHLSS specifically recommends against development of the lands incorporating Site RN11 on visual impact grounds.
• The appropriate development of allocation of R189M as oppose RN11 has the potential to make a significant positive contribution to the highway and pedestrian network in Kirkby in Furness. It will facilitate the improvement of the existing STOP junction and improve pedestrian access to the adjacent railway station and local services.
For the above reasons - the reinstatement of the allocation for residential development of Site R189M and removal of the allocation Site RN11 is considered a more sound approach to the emerging Land Allocation Development Plan Document (DPD) and is sought as an outcome of this submission.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
To ensure my client is best represented as it is probable that the land owner of RN11 will be represented at the oral examination
4. Mr Robinson , c/o Indigo Planning : 15 May 2012 10:34:00
Policy/Site No.
LA1.3 Housing Allocations - RN11# KIRKBY-in- FURNESS LAND ADJACENT TO BURLINGTON C OF E SCHOOL
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.
We seek the following changes to the emerging Land Allocation Development Plan Document (DPD) Policy LA1.3: Housing Allocations, as representing a more sustainable and sound approach the planning and development of Kirkby in Furness:
(b) The removal of the allocation Site RN11 for residential development as detailed on Map 17 of the Land Allocations Proposal Map published on 2 March 2012.
It is also important to note that Site RN11 was not identified in the EHLSS. Furthermore, the Kirkby in Furness (including Sand Site and Beck Side) Fact File - February 2012 states:
‘The EHLSS states that development to the north of the Kirkby in Furness is not recommended. It states that development would impact on the extensive views of the Duddon Estuary and impact on coalescence between Wall End and Kirkby. It does not recommend development in this area.’
This is a clear rationale why the allocation of the RN11 lands for residential development is unsustainable and at odds with the proper planning of the area. The proposal to allocate the land for residential development is therefore unsound – particularly when Site R189M is available and preferable in terms of overall sustainability, settlement character, visual impact and traffic impacts.
This contrasts with the potential impact of the allocation of the RN11 lands. This would result in an extension of the settlement boundary in a northern direction and would exacerbate an unsustainable linear form of development along the A595. This would also have a negative impact on coalescence and result in reduced undeveloped break between Kirkby and Wall End of only c. 280 metres. This potential negative impact was noted in the Sustainability Appraisal contained in the Fact File which identifies that the Site RN11 performs poorly in terms of coalescence.
The upward sloping nature of Site RN11 from the A595 is such that development on these lands may have a significant negative visual impact on views from Kirkby towards the upland areas to the north east. Furthermore, the EHLSS identifies that development to the north of Kirkby in Furness is not recommended. It states that development would impact upon the extensive views of the Duddon Estuary. It does not recommend development in this area.
These factors combine to mean there are significantly more potential negative visual impacts associated with development of Site RN11 than R189M.
Summary / Conclusions
Table 1.1 below summarises the characteristic of both R189M and RN11 and should be considered with the following conclusions.
• The allocation of R189M as oppose RN11 represents a more sustainable approach to the development of Kirkby on Furness. It better accords with the sequential approach to the location of new housing development identified in the adopted South Lakeland Local Development Framework – Core Strategy 2010.
• The allocation of Site R189M as oppose RN11 accords with the identification of the lands incorporating R189M in Employment and Housing Land Search Study (EHLSS). It will also be preferable in terms of settlement character, visual impact and traffic impacts.
• The appropriate development of Site R189M as oppose RN11 will make a positive contribution to settlement structure and actively support consolidation of the settlement in accordance with its prevailing character.
• The appropriate development of Site R189M will have limited visual impact. This is due to its relatively flat topography and existing screening resulting from the central location of the site within the settlement; surrounded by existing development. The development of RN11 is potentially more problematic due to the sloping nature of the site and its peripheral location. The EHLSS specifically recommends against development of the lands incorporating Site RN11 on visual impact grounds.
• The appropriate development of allocation of R189M as oppose RN11 has the potential to make a significant positive contribution to the highway and pedestrian network in Kirkby in Furness. It will facilitate the improvement of the existing STOP junction and improve pedestrian access to the adjacent railway station and local services.
For the above reasons - the reinstatement of the allocation for residential development of Site R189M and removal of the allocation Site RN11 is considered a more sound approach to the emerging Land Allocation Development Plan Document (DPD) and is sought as an outcome of this submission.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
To ensure my client is best represented as it is probable that the land owner of RN11 will be represented at the oral examination
development here is not in line with the ELHSS or SA there is a potentiaslly more suitable avalaible and deliverable site in the centre of the settlement
5. Mr Robinson , c/o Indigo Planning : 28 May 2012 14:26:00
A typed or handwritten document was submitted. This has been scanned and can be downloaded below:
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
R189M
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.
We seek the following changes to the emerging Land Allocation Development Plan Document (DPD) Policy LA1.3: Housing Allocations, as representing a more sustainable and sound approach the planning and development of Kirkby in Furness:
(a) The reinstatement of the allocation of Site R189M for residential development - as detailed on Map 40 of the Land Allocations Proposal Map published on 29 July 2011. Proposal R189M is not included on Map 17 of the Land Allocations Proposal Map published on 2 March 2012, which is the subject of the current consultation.
(b) The removal of the allocation Site RN11 for residential development as detailed on Map 17 of the Land Allocations Proposal Map published on 2 March 2012.
Our reasoned justification for the above outcome is provided below:
1. The allocation of R189M as oppose RN11 represents a more sustainable approach to the development of Kirkby on Furness. It better accords with the sequential approach to the location of new housing development identified in the adopted South Lakeland Local Development Framework – Core Strategy 2010.
Policy CS6.1 – Meeting the housing requirement - contained in the adopted South Lakeland Local Development Framework – Core Strategy 2010 states that sites will be allocated in the Land Allocation DPD using the sequential approach to housing development identified in PPS 3 (now replaced) and Spatial Strategy Policies CS1.1.
Policy CS1.1 referred to above states:
‘8. 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’.
It is submitted that the development of Site R189M as oppose RN11 better accords with this adopted sequential approach to the location of new residential development for the following reasons:
• It is located closer to the core of the existing settlement and is bounded by development on three sides. It will also occupy the only significant remaining undeveloped road frontage within the settlement, on the southern side of Side Sands Road. It is submitted that this is more sustainable than the development of Site RN11, which will result in the physical extension of the settlement to the north along the A595.
• Site 189M is better located in relation to services and infrastructure in the settlement including the village post office, pub and railway station.
Site R189M therefore performs better than RN11 in terms of the sequential approach to the location of new residential development.
2. The allocation of Site R189M as oppose RN11 accords with the identification of the lands incorporating R189M in Employment and Housing Land Search Study (EHLSS). It will also be preferable in terms of settlement character, visual impact and traffic impacts.
Site R189M was identified for residential development in the earlier draft of the Land Allocations DPD (Map 40). Site R189M (which incorporates R29, R189 and part of RN170) forms Site 2 (Side Sands) identified in the Employment and Housing Land Search Study (EHLSS). It is one of only two potential residential development sites identified in Kirkby in Furness.
The site identified as a Category 2 Site in the EHLSS. This is described as a site having a high degree of sustainability and a medium degree of deliverability.
The identification of the lands incorporating Site R189M in the EHLSS is significant. The land has therefore been the subject of strategic analysis and their identification for residential development can be seen to have a rational planning basis.
It is also important to note that Site RN11 was not identified in the EHLSS. Furthermore, the Kirkby in Furness (including Sand Site and Beck Side) Fact File - February 2012 states:
‘The EHLSS states that development to the north of the Kirkby in Furness is not recommended. It states that development would impact on the extensive views of the Duddon Estuary and impact on coalescence between Wall End and Kirkby. It does not recommend development in this area.’
This is a clear rationale why the allocation of the RN11 lands for residential development is unsustainable and at odds with the proper planning of the area. The proposal to allocate the land for residential development is therefore unsound – particularly when Site R189M is available and preferable in terms of overall sustainability, settlement character, visual impact and traffic impacts.
3. The appropriate development of Site R189M as oppose RN11 will make a positive contribution to settlement structure and actively support consolidation of the settlement in accordance with its prevailing character.
Site R189M performs well in the Sustainability Appraisal provided at Appendix 3 of the Kirkby in Furness (including Sand Site and Beck Side) Fact File - February 2012. The site performs well in terms of access to primary school, health services, avoidance of coalescence and access to public transport. It is also located within short walking distance of other key amenities / services including the railway station, village pub and post office.
The Fact File also recognises that the site is centrally located within the settlement, has the potential to provide a stronger development boundary and improve the visual approach to Kirkby from the south.
The development of Site R189M will also have a consolidating effect in the settlement. It will complete a prevailing pattern of development in the settlement, in which development is located on both sides of the A595 and Sand Side Road. Site R189 is currently the only road frontage within the existing settlement boundary which is undeveloped land. The development of this land would have a significant positive consolidating effect on the settlement streetscape - completing the prevailing form of development within the existing settlement envelope.
This contrasts with the potential impact of the allocation of the RN11 lands. This would result in an extension of the settlement boundary in a northern direction and would exacerbate an unsustainable linear form of development along the A595. This would also have a negative impact on coalescence and result in reduced undeveloped break between Kirkby and Wall End of only c. 280 metres. This potential negative impact was noted in the Sustainability Appraisal contained in the Fact File which identifies that the Site RN11 performs poorly in terms of coalescence.
4. The appropriate development of Site R189M will have limited visual impact. This is due to its relatively flat topography and existing screening resulting from the central location of the site within the settlement; surrounded by existing development. The development of RN11 is potentially more problematic due to the sloping nature of the site and its peripheral location. The EHLSS specifically recommends against development of the lands incorporating Site RN11 on visual impact grounds.
The appropriate development of Site R189M has the potential to achieve positive visual impacts in terms of strengthening the development boundary of Kirkby in this area of the settlement and improving the visual approach to Kirkby from the south. These potential positives are identified in the Fact File
Any potential longer range visual impact will be mitigated by existing surrounding development. This includes the village pub, existing residential development to the north and south of Sand Side Road and the terrace of houses to the east of the A585 and south of Beck Side Road.
Site R189M is identified as being located in Landscape Character Area 2c Coastal Plain in the Cumbria Landscape Character Guidance and Toolkit. This is the same designation as afforded to the bulk of the settlement. This contrasts with the designation of the RN11 Site as Area 9d Ridges. This is the prevailing designation of the upland areas to the east of Kirkby which are predominately undeveloped in character.
The upward sloping nature of Site RN11 from the A595 is such that development on these lands may have a significant negative visual impact on views from Kirkby towards the upland areas to the north east. Furthermore, the EHLSS identifies that development to the north of Kirkby in Furness is not recommended. It states that development would impact upon the extensive views of the Duddon Estuary. It does not recommend development in this area.
These factors combine to mean there are significantly more potential negative visual impacts associated with development of Site RN11 than R189M.
5. The appropriate development of allocation of R189M as oppose RN11 has the potential to make a significant positive contribution to the highway and pedestrian network in Kirkby in Furness. It will facilitate the improvement of the existing STOP junction and improve pedestrian access to the adjacent railway station and local services.
A comprehensive Highway and Transport Report has been prepared in support of the allocation of R189M by VTC (Highway and Transport Consultants). This document is included with this submission.
The report identifies that there are a number of deficiencies in the highway network in the settlement including the STOP junction at the intersection of Sand Side Road and the A595, the restricted width of Sand Side Road and the lack of pedestrian footpaths on a stretch of Sand Side Road.
These deficiencies could be alleviated by the allocation of R189M. Any future development of the lands would facilitate the widening of Sand Side Road and the provision of appropriate pedestrian footpaths. Significantly, the development of R189M would facilitate the provision of a new road linking from the western end of Sand Side Road to the A595 and forming a new junction onto the A595 approximately 80 metres south of the existing junction with Sand Side Road. This in turn could facilitate the designation of Sand Side Road as a one way only road (east to west) and thereby remove issues with the existing STOP junction and the width of Sand Side Road. These measures would be subject to agreement with the Highways Authority, however the Highway and Transport Report identifies that this new road has been recommended by the Highways Authority (Paragraph 4.5).
While the allocation of Site R189M provides these significant potential improvements to the road network in Kirkby, no such benefits would be associated with the allocation of RN11. Furthermore, we note that the development of these lands likely require a new access to the A595 at a location adjacent to the existing primary school.
Summary / Conclusions
Table 1.1 below summarises the characteristic of both R189M and RN11 and should be considered with the following conclusions.
• The allocation of R189M as oppose RN11 represents a more sustainable approach to the development of Kirkby on Furness. It better accords with the sequential approach to the location of new housing development identified in the adopted South Lakeland Local Development Framework – Core Strategy 2010.
• The allocation of Site R189M as oppose RN11 accords with the identification of the lands incorporating R189M in Employment and Housing Land Search Study (EHLSS). It will also be preferable in terms of settlement character, visual impact and traffic impacts.
• The appropriate development of Site R189M as oppose RN11 will make a positive contribution to settlement structure and actively support consolidation of the settlement in accordance with its prevailing character.
• The appropriate development of Site R189M will have limited visual impact. This is due to its relatively flat topography and existing screening resulting from the central location of the site within the settlement; surrounded by existing development. The development of RN11 is potentially more problematic due to the sloping nature of the site and its peripheral location. The EHLSS specifically recommends against development of the lands incorporating Site RN11 on visual impact grounds.
• The appropriate development of allocation of R189M as oppose RN11 has the potential to make a significant positive contribution to the highway and pedestrian network in Kirkby in Furness. It will facilitate the improvement of the existing STOP junction and improve pedestrian access to the adjacent railway station and local services.
For the above reasons - the reinstatement of the allocation for residential development of Site R189M and removal of the allocation Site RN11 is considered a more sound approach to the emerging Land Allocation Development Plan Document (DPD) and is sought as an outcome of this submission.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
To ensure my client is best represented as it is probable that the land owner of RN11 will be represented at the oral examination.
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