Local Development Framework Consultation

I have read the guidance notes

LA1.3 Housing Allocations - M41M ENDMOOR NORTH OF SYCAMORE DRIVE

Yes

Yes

Land North of Sycamore Close, Endmoor (Site Ref: M41M-mod)

Story Homes, in conjunction with the land owners, fully support, in principle, the allocation of land to the north of Sycamore Close, Endmoor (Site Ref: M41M-mod) for residential development. In this regard, the statement confirms, first, the continued support by Story Homes and the land owners for this residential allocation and, secondly, that the site is fully deliverable. In light of this, it is argued that the development should fall within Phases 1 and 2 of the Land Allocations DPD. In order to inform Story Homes’ support for the allocation an indicative masterplan has been prepared and submitted with this representation (Plan Ref: 01-01) to demonstrate the suitability of the site for residential development, which has been formulated with reference to Policy LA2.14 of the Land Allocations DPD.
Site Description
The site extends to approximately 4.64 hectares in size, is broadly rectangular in shape and is immediately adjacent to and extends northwards from the existing northern boundary to Endmoor. The southern boundary of the site adjoins existing residential properties at Sycamore Close and also St Patrick’s Primary School, the eastern boundary abuts the rear gardens of residential properties fronting onto Gatebeck Road, the western boundary is formed by the A65 whilst the northern boundary is defined by dry stone walls which separate the site from further agricultural grazing fields to the north. A public footpath runs parallel to the northern boundary of the site extending from Gatebeck Road to the A65.
Policy Context
The National Planning Policy Framework (NPPF) was published on 27th March 2012. Paragraph 182 of the NPPF requires that a local plan has been prepared in accordance with a duty to cooperate, legal and procedural requirements, and whether it is sound. In light of this, the local planning authority are required to submit a plan for examination which it considers to be sound, which requires the plan to be assessed against the following:

• Positively prepared – the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development;

• Justified – the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence;

• Effective – the plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priority;

• Consistent with national policy – the plan should enable the delivery of sustainable development in accordance with the policies in the framework.

1. Positively Prepared – Story Homes consider that South Lakeland’s Housing Strategy, as laid out in their Land Allocations DPD has been positively prepared, following a full appraisal of designated strategic objectives, which were formulated in line with the key aims of sustainable development;

2. Justified – The residential allocation of land to the north of Sycamore Close, Endmoor was arrived at through the evolution and appraisal of almost 1,000 potential site options with a formulation of a sustainability appraisal framework providing the basis for appraising, analysing and preparing the relative sustainability effects of all the alternative site options. In light of this Story Homes considered that the proposed allocation is justified in terms of it being an appropriate site for housing considered against the alternatives assessed and on the basis of the Council’s comprehensive evidence base.

3. Effective – The NPPF requires that the Housing Strategy outlined in the Land Allocations DPD is fully deliverable over the designated plan period. In this regard, Story Homes agree with the conclusions drawn from the report prepared, and submitted, by Garner Planning Associates, on behalf of the Cumbria House Builders Group, of which Story Homes are part, that the Land Allocations DPD Housing Strategy is to under provide for housing in the period up to 2017 – 2022, but seek to make up the shortfalls in the last 3 years of the plan period. In so doing, the authority relies on broad locations being brought forward in the context of a plan review and for those sites, and others, to contribute to housing completions at unrealistic development rates. In addition, it is evident with reference to the SLDC Annual Monitoring Reports (AMR) from 2003/2004 onwards, that the Council has persistently under delivered housing against their annual requirement. However, there is no provision for a 20% buffer (housing moved forward from later in the plan period) to provide a realistic prospect of achieving the planned supply, in accordance with paragraph 47 of the NPPF. Tables confirming this under provision are attached to this representation. In light of this, it is Story Homes’ view that the Land Allocations DPD needs, first, to release sites earlier in the plan period and, secondly increase housing density and so housing yield on appropriate sites, particularly given the Council’s aspiration in Core Strategy Policy CS6.6 to achieve an average housing density of 30 dwellings per hectare.

In terms of Local Service Centres, of which Endmoor is one, Table 5 of the Garner Report also highlights that there is a shortfall of 222 dwellings in Local Service Centres to the meet the Core Strategy requirements. In light of this the deliverability of the allocated site on land north of Sycamore Close, Endmoor is important in terms of delivering the housing requirement for the Local Service Centres, and indeed the District as a whole, in terms of both housing numbers and also their deliverability early in the plan period.

In terms of the deliverability of the site, paragraph 47 of the NPPF confirms that the site should be:

i) Available now;

ii) Offer a suitable location for development;

iii) Be achievable with a realistic prospect that housing will be delivered on the site within 5 years and, in particular, that development of the site is viable.


i) Availability
Story Homes have a legal agreement with the land owners, Mr and Mrs Hodgson, to seek a formal allocation on their land with a view to bringing forward a development scheme as soon as possible. In light of this, it is considered that the site is available now.

ii) Suitability
A detailed Sustainability Appraisal was carried out by SLDC to identify Local Service Centres considered suitable to accommodate additional housing, in accordance with Core Strategy Policy CS1.2. This identified Endmoor as providing an appropriate level of services and facilities to support additional residential development. In light of this, a detailed analysis was undertaken by the Council of Endmoor in order to identify land most suitable for accommodating the residential development required. A total of 15 sites were initially put forward for consideration for further development at Endmoor, of which 12 were proposed for residential development and one for mixed use.

As part of the consultation exercise on the Emerging Option sites, 8 further new and alternative sites were identified and considered. Based on further evidence collated by the Council and more detailed site assessment a total of 3 sites were put forward as ‘Emerging Options’ for consultation in Endmoor, of which 2 were proposed for residential development and 1 proposed for mixed use. The land north of Sycamore Close, Endmoor, at that stage of the Land Allocations DPD consultation, was proposed for mixed use. In addition, 5 further new and alternative sites were identified and these were also subject to public consultation at this options stage.

As a result of further assessment work on the part of the Council a total of 4 sites were put forward for allocation. This includes Site Ref: M41M-MOD. This land north of Sycamore Close was originally allocated for a mixed use comprising residential and employment use. However, both the Parish Council and other residents of Endmoor considered that there was no identified need for employment development in the village and, in light of this, the employment element of the land allocation was removed with the proposed allocation now comprising residential development only.

The process of allocation, as highlighted above, demonstrates that the allocation of land to the north of Sycamore Close was made following detailed assessment of the suitability of this land for residential development and Story Homes are in agreement with the Council’s conclusions, for the following reasons:

a. There are no restrictive planning policy designations across the site which would preclude development;

b. The site was identified in both the SHLAA and the Employment and Housing Search Study as a Category 1 and Category 2 site respectively;

c. Endmoor scored well against the Council’s full Sustainability Appraisal in terms of the level of services and facilities available to support additional development;

d. The County Highways Authority has confirmed that the proposed access is acceptable to the site from the A65. In this regard, Story Homes commissioned White Young Green to formulate an appropriate access to the site, in conjunction with the County Highways Authority. Plan Reference: C-001 Rev B attached to this representation confirms the access configuration which has been agreed with the County Highways Authority as suitable to service the proposed residential development.

e. The Environment Agency has confirmed that the site is located in Flood Risk Zone 1 and is therefore at little or no risk of flooding from river, tidal and coastal sources. However, development that increases the amount of any impermeable surfaces can result in an increase in surface water run-off, which could result in flooding on site or elsewhere in the catchment. Any future scheme will be designed to ensure the management of surface water disposal does not cause flooding on site or elsewhere in the catchment and this will be illustrated through a Flood Risk Assessment which will accompany any future planning application. A number of options exist for surface water disposal and these will be investigated in greater detail as and when the detailed scheme design is progressed. These options include the use of sustainable drainage systems where ground conditions and topography permit and discharging surface water to a nearby watercourse attenuated to greenfield run-off rates.

f. In respect of foul water drainage, United Utilities have advised Story Homes that the existing waste water treatment works (WWtW) is at, or near to capacity, and investment is required to up-grade the works to facilitate the development of the site. United Utilities have also advised that an application can be made within the next round of OFWAT funding in 2014 to enable the works to be upgraded during the period 2015-2020. As a result the site has been placed within Phase 2 (2015-2020) of the Land Allocations DPD. Story Homes’ recognises and acknowledges this situation, and appreciates that new infrastructure will be required to accommodate the development of this site. However, it is Story Homes’ firm belief that a range of options currently exist to deliver the required infrastructure within Phase 1 of the Allocations DPD and these include:

o Story Homes working with United Utilities and contributing towards any specific up-grade works to increase the capacity of the treatment works;
o Exploring surface water removal from the existing combined sewer to generate spare capacity at the main waste water treatment works;
o Providing a package treatment plant on site which treats any foul drainage on site rather than transferring it to main waste water treatment plant.

Therefore, Story Homes object to the current phasing as set out in Policy LA1.3 and consider that to ensure ‘effectiveness’ some flexibility should be built into Policy LA2.14 which enables the early release of the site if the foul drainage proposals have been agreed to the satisfaction of the South Lakeland District Council.

g. Story Homes has undertaken an assessment of the services and facilities required to serve the site including water, gas, electricity and telecoms. Following investigations Story Homes can confirm there are no utilities and servicing constraints that affect the proposed development.

h. Cumbria Wildlife Trust do not object to residential development on the site although a full ecological assessment will be carried out in support of any future planning application.

i. In order to inform Story Homes’ support for a residential allocation on this site an indicative masterplan has been prepared to demonstrate how a suitable residential scheme could be achieved. Whilst a more detailed scheme will be formulated to support any planning application this indicative layout has taken account of the characteristics of the site itself and also the respective setting in which the site is located. It also acknowledges the provisions of Policy LA2.14 of the Land Allocations DPD, which makes specific reference to the requirement for a landscape and green infrastructure framework incorporating open space, strong landscaping and tree planting along the northern boundary and retention of hedgerow and trees and also the retention and enhancement of public rights of way across the site and the provision of pedestrian and cycle links to the main road and adjoining housing areas. In addition, the lower density of the indicative masterplan reflects both the existing built form of Endmoor at its northern edge and also views of the site from the north, with the latter also accounted for through the significant structural planting proposed along the site’s northern boundary and the provision of a linear park which allows for views through the site both from Endmoor to the south and also from land to the north. It has also been acknowledged by the Council as part of their ‘South Lakeland Employment and Housing Land Search Study’ that, due to the steeply undulating topography with areas of wood and tall hedgerows Endmoor is broadly enclosed with views restricted.

iii) Achievability
Story Homes can confirm the economic viability of the site taking into consideration all known costs, including foul water drainage, as well as meeting the policy requirements of the SLDC Core Strategy and Policy LA2.14 of the Land Allocations DPD. Story Homes have taken into account market, cost and delivery factors as well as residual evaluation calculations in their consideration.

The proposed site is 4.64 hectares in area and, at a density of 30 dwellings per hectare as advocated within the Land Allocations DPD, would produce a yield of approximately 120 dwellings. However, given the relatively low density of the existing built fabric of Endmoor it is considered by Story Homes that a lower density of between 22 – 25 dwellings per hectare would be more appropriate on this particular site, as demonstrated by the indicative masterplan submitted with this representation, generating a yield of around 100-105 dwellings.
Conclusion
Story Homes, in conjunction with the land owner of the land at Sycamore Close, Endmoor (Site Ref: M41M-mod), fully supports the allocation of land for residential development. In doing so, Story Homes have taken full cognisance of paragraph 182 of the NPPF in terms of demonstrating the soundness of this particular allocation. In this regard, Story Homes supports the submission by Garner Planning Associates, on behalf of the Cumbria House Builders Group, in terms of highlighting both the shortfall in housing numbers proposed by the Council over the plan period and also the need to bring forward the development of housing sites to earlier in the plan period
Story Homes, through this statement, also confirms that the site is fully deliverable in the context of paragraph 47 of the NPPF and that the allocation of the site is fully in accordance with the aims of the NPPF of delivering sustainable development in accordance with the SLDC Core Strategy.

In light of the above it is respectfully requested by Story Homes that the Inspector, first, endorses the Council’s allocation of this site for housing and, secondly, includes it for development within Phases 1 and 2.

YES, I wish to participate at the oral examination

Representations submitted on behalf of Story Homes deal with both site-specific and District-wide housing issues.

LA1.3 Housing Allocations - M41M ENDMOOR NORTH OF SYCAMORE DRIVE

Yes

No

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

The DPD is not consistent with national policy.

Land North of Sycamore Close, Endmoor (Site Ref: M41M-mod)

Story Homes, in conjunction with the land owners, fully support, in principle, the allocation of land to the north of Sycamore Close, Endmoor (Site Ref: M41M-mod) for residential development. In this regard, the statement confirms, first, the continued support by Story Homes and the land owners for this residential allocation and, secondly, that the site is fully deliverable. In light of this, it is argued that the development should fall within Phases 1 and 2 of the Land Allocations DPD. In order to inform Story Homes’ support for the allocation an indicative masterplan has been prepared and submitted with this representation (Plan Ref: 01-01) to demonstrate the suitability of the site for residential development, which has been formulated with reference to Policy LA2.14 of the Land Allocations DPD.
f. In respect of foul water drainage, United Utilities have advised Story Homes that the existing waste water treatment works (WWtW) is at, or near to capacity, and investment is required to up-grade the works to facilitate the development of the site. United Utilities have also advised that an application can be made within the next round of OFWAT funding in 2014 to enable the works to be upgraded during the period 2015-2020. As a result the site has been placed within Phase 2 (2015-2020) of the Land Allocations DPD. Story Homes’ recognises and acknowledges this situation, and appreciates that new infrastructure will be required to accommodate the development of this site. However, it is Story Homes’ firm belief that a range of options currently exist to deliver the required infrastructure within Phase 1 of the Allocations DPD and these include:

o Story Homes working with United Utilities and contributing towards any specific up-grade works to increase the capacity of the treatment works;
o Exploring surface water removal from the existing combined sewer to generate spare capacity at the main waste water treatment works;
o Providing a package treatment plant on site which treats any foul drainage on site rather than transferring it to main waste water treatment plant.

Therefore, Story Homes object to the current phasing as set out in Policy LA1.3 and consider that to ensure ‘effectiveness’ some flexibility should be built into Policy LA2.14 which enables the early release of the site if the foul drainage proposals have been agreed to the satisfaction of the South Lakeland District Council.
Following an assessment of the local market and based upon the experience of Story Homes it is considered that the site will take around 5 years to deliver. This would include a year to prepare and obtain the necessary planning permission, a year to undertake initial site infrastructure works and commence construction of housing and subsequent 3 years to build and sell the 100-105 dwellings. As the site is fully deliverable, in accordance with paragraph 47 of the NPPF, Story Homes consider that the development of the site should be brought forward to Phases 1 and 2 of the Land Allocations DPD in order that it contributes to meeting the housing requirements set out within the Core Strategy.

iv) Consistent with National Policy
Story Homes considers that, although the Council’s overall phasing is not currently consistent with the NPPF, the allocation of land to the north of Sycamore Close, Endmoor (Site Ref: M41M-mod) is fully consistent with national policy. The Sustainability Appraisal carried out by the Council in relation to each proposed housing allocation assessed the allocation against delivering the economic, social and environmental dimensions to sustainable development, as required by paragraph 7 of the NPPF. This proposed allocation will enable, in full, these 3 key aims of sustainable development to be met.
In light of the above it is respectfully requested by Story Homes that the Inspector, first, endorses the Council’s allocation of this site for housing and, secondly, includes it for development within Phases 1 and 2.

YES, I wish to participate at the oral examination

Representations submitted on behalf of Story Homes deal with both site-specific and District-wide housing issues

I have read the guidance notes

LA2.14 Land North of Sycamore Drive, Endmoor

Yes

Yes

Land North of Sycamore Close, Endmoor (Site Ref: M41M-mod)

Story Homes, in conjunction with the land owners, fully support, in principle, the allocation of land to the north of Sycamore Close, Endmoor (Site Ref: M41M-mod) for residential development. In this regard, the statement confirms, first, the continued support by Story Homes and the land owners for this residential allocation and, secondly, that the site is fully deliverable. In light of this, it is argued that the development should fall within Phases 1 and 2 of the Land Allocations DPD. In order to inform Story Homes’ support for the allocation an indicative masterplan has been prepared and submitted with this representation (Plan Ref: 01-01) to demonstrate the suitability of the site for residential development, which has been formulated with reference to Policy LA2.14 of the Land Allocations DPD.

Site Description
The site extends to approximately 4.64 hectares in size, is broadly rectangular in shape and is immediately adjacent to and extends northwards from the existing northern boundary to Endmoor. The southern boundary of the site adjoins existing residential properties at Sycamore Close and also St Patrick’s Primary School, the eastern boundary abuts the rear gardens of residential properties fronting onto Gatebeck Road, the western boundary is formed by the A65 whilst the northern boundary is defined by dry stone walls which separate the site from further agricultural grazing fields to the north. A public footpath runs parallel to the northern boundary of the site extending from Gatebeck Road to the A65.

Policy Context
The National Planning Policy Framework (NPPF) was published on 27th March 2012. Paragraph 182 of the NPPF requires that a local plan has been prepared in accordance with a duty to cooperate, legal and procedural requirements, and whether it is sound. In light of this, the local planning authority are required to submit a plan for examination which it considers to be sound, which requires the plan to be assessed against the following:

• Positively prepared – the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development;

• Justified – the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence;

• Effective – the plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priority;

• Consistent with national policy – the plan should enable the delivery of sustainable development in accordance with the policies in the framework.

1. Positively Prepared – Story Homes consider that South Lakeland’s Housing Strategy, as laid out in their Land Allocations DPD has been positively prepared, following a full appraisal of designated strategic objectives, which were formulated in line with the key aims of sustainable development;

2. Justified – The residential allocation of land to the north of Sycamore Close, Endmoor was arrived at through the evolution and appraisal of almost 1,000 potential site options with a formulation of a sustainability appraisal framework providing the basis for appraising, analysing and preparing the relative sustainability effects of all the alternative site options. In light of this Story Homes considered that the proposed allocation is justified in terms of it being an appropriate site for housing considered against the alternatives assessed and on the basis of the Council’s comprehensive evidence base.

3. Effective – The NPPF requires that the Housing Strategy outlined in the Land Allocations DPD is fully deliverable over the designated plan period. In this regard, Story Homes agree with the conclusions drawn from the report prepared, and submitted, by Garner Planning Associates, on behalf of the Cumbria House Builders Group, of which Story Homes are part, that the Land Allocations DPD Housing Strategy is to under provide for housing in the period up to 2017 – 2022, but seek to make up the shortfalls in the last 3 years of the plan period. In so doing, the authority relies on broad locations being brought forward in the context of a plan review and for those sites, and others, to contribute to housing completions at unrealistic development rates. In addition, it is evident with reference to the SLDC Annual Monitoring Reports (AMR) from 2003/2004 onwards, that the Council has persistently under delivered housing against their annual requirement. However, there is no provision for a 20% buffer (housing moved forward from later in the plan period) to provide a realistic prospect of achieving the planned supply, in accordance with paragraph 47 of the NPPF. Tables confirming this under provision are attached to this representation. In light of this, it is Story Homes’ view that the Land Allocations DPD needs, first, to release sites earlier in the plan period and, secondly increase housing density and so housing yield on appropriate sites, particularly given the Council’s aspiration in Core Strategy Policy CS6.6 to achieve an average housing density of 30 dwellings per hectare.

In terms of Local Service Centres, of which Endmoor is one, Table 5 of the Garner Report also highlights that there is a shortfall of 222 dwellings in Local Service Centres to the meet the Core Strategy requirements. In light of this the deliverability of the allocated site on land north of Sycamore Close, Endmoor is important in terms of delivering the housing requirement for the Local Service Centres, and indeed the District as a whole, in terms of both housing numbers and also their deliverability early in the plan period.

In terms of the deliverability of the site, paragraph 47 of the NPPF confirms that the site should be:

i) Available now;

ii) Offer a suitable location for development;

iii) Be achievable with a realistic prospect that housing will be delivered on the site within 5 years and, in particular, that development of the site is viable.


i) Availability
Story Homes have a legal agreement with the land owners, Mr and Mrs Hodgson, to seek a formal allocation on their land with a view to bringing forward a development scheme as soon as possible. In light of this, it is considered that the site is available now.

ii) Suitability
A detailed Sustainability Appraisal was carried out by SLDC to identify Local Service Centres considered suitable to accommodate additional housing, in accordance with Core Strategy Policy CS1.2. This identified Endmoor as providing an appropriate level of services and facilities to support additional residential development. In light of this, a detailed analysis was undertaken by the Council of Endmoor in order to identify land most suitable for accommodating the residential development required. A total of 15 sites were initially put forward for consideration for further development at Endmoor, of which 12 were proposed for residential development and one for mixed use.

As part of the consultation exercise on the Emerging Option sites, 8 further new and alternative sites were identified and considered. Based on further evidence collated by the Council and more detailed site assessment a total of 3 sites were put forward as ‘Emerging Options’ for consultation in Endmoor, of which 2 were proposed for residential development and 1 proposed for mixed use. The land north of Sycamore Close, Endmoor, at that stage of the Land Allocations DPD consultation, was proposed for mixed use. In addition, 5 further new and alternative sites were identified and these were also subject to public consultation at this options stage.

As a result of further assessment work on the part of the Council a total of 4 sites were put forward for allocation. This includes Site Ref: M41M-MOD. This land north of Sycamore Close was originally allocated for a mixed use comprising residential and employment use. However, both the Parish Council and other residents of Endmoor considered that there was no identified need for employment development in the village and, in light of this, the employment element of the land allocation was removed with the proposed allocation now comprising residential development only.

The process of allocation, as highlighted above, demonstrates that the allocation of land to the north of Sycamore Close was made following detailed assessment of the suitability of this land for residential development and Story Homes are in agreement with the Council’s conclusions, for the following reasons:

a. There are no restrictive planning policy designations across the site which would preclude development;

b. The site was identified in both the SHLAA and the Employment and Housing Search Study as a Category 1 and Category 2 site respectively;

c. Endmoor scored well against the Council’s full Sustainability Appraisal in terms of the level of services and facilities available to support additional development;

d. The County Highways Authority has confirmed that the proposed access is acceptable to the site from the A65. In this regard, Story Homes commissioned White Young Green to formulate an appropriate access to the site, in conjunction with the County Highways Authority. Plan Reference: C-001 Rev B attached to this representation confirms the access configuration which has been agreed with the County Highways Authority as suitable to service the proposed residential development.

e. The Environment Agency has confirmed that the site is located in Flood Risk Zone 1 and is therefore at little or no risk of flooding from river, tidal and coastal sources. However, development that increases the amount of any impermeable surfaces can result in an increase in surface water run-off, which could result in flooding on site or elsewhere in the catchment. Any future scheme will be designed to ensure the management of surface water disposal does not cause flooding on site or elsewhere in the catchment and this will be illustrated through a Flood Risk Assessment which will accompany any future planning application. A number of options exist for surface water disposal and these will be investigated in greater detail as and when the detailed scheme design is progressed. These options include the use of sustainable drainage systems where ground conditions and topography permit and discharging surface water to a nearby watercourse attenuated to greenfield run-off rates.

g. Story Homes has undertaken an assessment of the services and facilities required to serve the site including water, gas, electricity and telecoms. Following investigations Story Homes can confirm there are no utilities and servicing constraints that affect the proposed development.

h. Cumbria Wildlife Trust do not object to residential development on the site although a full ecological assessment will be carried out in support of any future planning application.

i. In order to inform Story Homes’ support for a residential allocation on this site an indicative masterplan has been prepared to demonstrate how a suitable residential scheme could be achieved. Whilst a more detailed scheme will be formulated to support any planning application this indicative layout has taken account of the characteristics of the site itself and also the respective setting in which the site is located. It also acknowledges the provisions of Policy LA2.14 of the Land Allocations DPD, which makes specific reference to the requirement for a landscape and green infrastructure framework incorporating open space, strong landscaping and tree planting along the northern boundary and retention of hedgerow and trees and also the retention and enhancement of public rights of way across the site and the provision of pedestrian and cycle links to the main road and adjoining housing areas. In addition, the lower density of the indicative masterplan reflects both the existing built form of Endmoor at its northern edge and also views of the site from the north, with the latter also accounted for through the significant structural planting proposed along the site’s northern boundary and the provision of a linear park which allows for views through the site both from Endmoor to the south and also from land to the north. It has also been acknowledged by the Council as part of their ‘South Lakeland Employment and Housing Land Search Study’ that, due to the steeply undulating topography with areas of wood and tall hedgerows Endmoor is broadly enclosed with views restricted.

iii) Achievability
Story Homes can confirm the economic viability of the site taking into consideration all known costs, including foul water drainage, as well as meeting the policy requirements of the SLDC Core Strategy and Policy LA2.14 of the Land Allocations DPD. Story Homes have taken into account market, cost and delivery factors as well as residual evaluation calculations in their consideration.

The proposed site is 4.64 hectares in area and, at a density of 30 dwellings per hectare as advocated within the Land Allocations DPD, would produce a yield of approximately 120 dwellings. However, given the relatively low density of the existing built fabric of Endmoor it is considered by Story Homes that a lower density of between 22 – 25 dwellings per hectare would be more appropriate on this particular site, as demonstrated by the indicative masterplan submitted with this representation, generating a yield of around 100-105 dwellings.

YES, I wish to participate at the oral examination

Representations submitted on behalf of Story Homes deal with both site-specific and District-wide housing issues

I have read the guidance notes

2.18

Yes

No

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

The DPD is not consistent with national policy.

Story Homes – Draft Housing Land Supply Representation
Story Homes forms part of the Cumbria House Builders’ Group which instructed Garner Planning Associates to examine the Core Strategy housing requirements compared to proposed housing provision within the Land Allocations DPD at district-wide level and then in each of the settlement hierarchies referred to in CS1.2 namely, Kendal and Ulverston separately as Principal Service Centres, Key Service Centres, Local Service Centres and Small Villages and Hamlets. The Garner Planning Associates report and appendices have been appended to this Statement for reference.

The purpose of the report was to establish if sufficient land has been identified to deliver the Core Strategy housing requirement. Based upon the findings of the attached report we consider that further housing provision is required to ensure that the housing requirement set out within the adopted Core Strategy is met within the plan period (2010-2025). It should be stressed that the housing requirement adopted within the Core Strategy was found to be “sound” by an independent Planning Inspector, and we also consider the Council’s extensive housing needs evidence base continues to support this level of housing.

Findings of the Garner Planning Associates Report

In summary, the House Builders do not agree with the authority’s assessment of net dwelling requirements or the likely level of housing completions from both identified and unidentified sites. Detailed reasoning is provided in Appendix D of the report. In brief:-

• for planning permissions - only net increases should be counted not gross figures;
• small site contributions should not be included, but a contribution from windfalls in the first 5 years would be appropriate but this element is included in the planning permissions in any case;
• development rates for any one site or sites should only be at a maximum of 30 dwellings per annum, as a result, if phased release remains as suggested a significant number of completions would be beyond the plan period;
• if the Broad Locations are only to come forward post 2022, then the maximum each site could contribute in the three year period to 2025 is 90 dwellings each (i.e. 30 dwellings per annum multiplied by 3 years), with the remainder beyond the plan period;
• the Land Allocations document assumes a contribution from small villages and hamlets, but there is a concern that housing completions from this source will be limited; and
• there is a need to provide for an element of slippage in relation to all sites to ensure the housing requirement is met.

Appended at C of the report is the House Builders’ assessment of the housing and mixed use allocations. Large sites are phased at a maximum of 30 dwellings per annum. Applying this annual rate results in some sites contributing in either a later phase or beyond the end of the plan period. In preparing this assessment it is not suggested that completions on large sites be held back by phasing, but that completions will naturally ‘spill over’ into later phases.

As can be seen, the House Builders consider there is a higher net requirement and assume housing completions from specifically allocated sites and broad locations to be 4,727 dwellings in the plan period compared to the planning authority’s assumption of 5,563 dwellings.

Taking all assumptions made by both the planning authority and housebuilders (as adjusted in Appendix B), the respective positions are set out in the table below.


An explanation for the principle of slippage can be found in Section 7 of Appendix D. For the table above the slippage at 10% is calculated by adding the slippage at 10% from each of the tables 2-5 plus the net requirement of the small villages and hamlets (574 dwellings). The revised figure of 6849 dwellings is then assessed against the total provision which suggests under provision of 1,891 dwellings across the District.

As can be seen from Table 1 whilst the planning authority consider sufficient housing provision has been identified to meet Core Strategy requirements, the House Builders consider there to be a shortfall at district-wide level. The shortfall can be further broken down by spatial distribution:

• Kendal – shortfall of 856 dwellings;
• Ulverston – shortfall of 324 dwellings;
• Key Service Centres – shortfall of 175 dwellings;
• Local Service Centres – shortfall of 222 dwellings;
• Villages and Hamlets – shortfall of 314 dwellings.

Summary and Conclusions

In summary, and based upon the above findings contained within the Garner Planning Associates report, it is considered that the Land Allocations DPD will under provide for housing in the period up to 2017 and 2022, and seeks to make up the shortfall in the last three years of the plan period. In so doing the authority rely on Broad Locations to be brought forward in the context of a plan review and for those sites, and others, to contribute housing completions at unrealistic development rates.

The Allocations document does not identify sufficient housing provision to meet Core Strategy housing requirements in the period 2003-2025 at district-wide level or within individual settlement categories, with an anticipated shortfall of 1,891 across the District. Based upon this evidence it is suggested that the document, as currently drafted, will not be “effective” in meeting the Core Strategy’s housing requirement and is therefore not “sound”.

Whilst Story Homes consider that the Land Allocations DPD, as drafted, to be “unsound”, we do consider that the document can be made “sound” by increasing the housing provision across the District within the plan period. Story Homes considers that there are a number of options available to the Council to increase the housing provision, not all of which require any additional deliverable or developable land. These options could include:

1. Re-examine the phasing and delivery of some of the proposed allocations and broad locations to ensure they are delivered in their entirety within the plan period;
2. Re-examine the capacity and proposed site densities of some of the proposed allocations and broad locations;
3. Following the above exercises, and if required, identify further deliverable and developable site specific housing allocations within or on the edge of Principle, Key and Local Service Centres and Villages and Hamlets;
4. Allow a degree of flexibility to the percentage spatial distribution requirements for each settlement categories to compensate for shortfalls elsewhere.

Considering some of the above suggestions in greater detail, and with reference to Appendix C of the Garner Planning Associates report, it is considered that 836 dwellings will not be delivered within the plan period due to being phased too late in the plan period. It is suggested that consideration is given to releasing these sites earlier in the plan period, to ensure that sufficient time is allowed for planning permission to be achieved, initial site construction and infrastructure provision and a build and selling period of circa 30 dwellings per annum. It is Story Homes’ view that all of these dwellings could be delivered within the plan period if the phasing is re-examined and the sites are released earlier within the plan period. Story Homes have also made site-specific comments in respect to the proposed phasing within their site specific representations in relation to sites that they have an interest in.

Story Homes are also of the view that the Council should re-examine the proposed site capacities to ensure the proposed allocations maximise housing delivery, match market requirements and accord with the density requirements set out within the Core Strategy. It is Story Homes’ view that the proposed capacities and densities within the consultation document appear to be very low, often less than 20 dwellings per hectare. For example:

• Land at Stainbank Green, Kendal – The site area is 10.8 hectares and the proposed yield is 189 dwellings. This equates to 17.5 dwellings per hectare;
• Land at Kendal Parks, Kendal – The site area is 10.1 hectares and the proposed yield is 200 dwellings. This equates to 19.8 dwellings per hectare.
• Across the whole of Kendal 67.3 hectares of land has been provisionally allocated to deliver 1,388 dwellings. This equates to an overall density of 20.5 dwellings per hectare.

Whilst it is appreciated that each site needs to be looked at on its own merits in the context of topography, public open space provision and landscape provision, it is considered that there is considerable scope to increase the site capacities whilst adequately addressing the site-specific policy requirements of each site. Using Kendal as an example, if the site capacities were increased to an average of 25 dwellings per hectare, an additional 337 dwellings could be delivered in Kendal alone.

Story Homes have made separate representations within their site-specific statements regarding the proposed site capacities in relation to the sites which they have an interest in. These are supported within indicative concept masterplans which illustrate that in some cases higher site capacities are acceptable and deliverable whilst meeting the wider policy aims for the respective allocations.

Finally, Story Homes would like to stress that, whilst they consider the draft document to be “unsound” in its current form, they consider it can be made sound by following the suggested actions above. Story Homes remain supportive of the land allocation process and are keen to work with the Council to ensure the plan is found to be sound at the forthcoming examination. Please refer to the site-specific statements for further information relating to the sites being promoted by Story Homes.


TEXT FROM OTHER REPS


Policy Context
The National Planning Policy Framework (NPPF) was published on 27th March 2012. Paragraph 182 of the NPPF requires that a Local Plan has been prepared in accordance with the duty to co-operate, legal and procedural requirements, and whether it is sound. In light of this, the local planning authority are required to submit a plan for examination which it considers to be sound, which requires the plan to be assessed against the following:

• Positively prepared – the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development;

• Justified – the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence;

• Effective – the plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priority;

• Consistent with national policy – the plan should enable the delivery of sustainable development in accordance with the policies in the framework.

1. Positively Prepared – Story Homes considered that South Lakeland’s Housing Strategy, as laid out in their Land Allocations DPD has been positively prepared, following a full appraisal of designated strategic objectives, which were formulated in line with the key aims of sustainable development;

2. Justified - The residential allocation of land at Brigsteer Road was made through the evolution and appraisal of almost 1,000 potential site options with the formulation of a sustainability appraisal framework to provide the basis for appraising, analysing and preparing the sustainability effects of all the alternative site options. In light of this Story Homes considers that the proposed allocation is justified in terms of it being an appropriate site for housing considered against the alternatives assessed and on the basis of the Council’s comprehensive evidence base;

1. Effective – The NPPF requires that the housing strategy outlined in the Land Allocations DPD is fully deliverable over the designated plan period. In this regard, Story Homes agree with the conclusions drawn from the report prepared and submitted by Garner Planning Associates, on behalf of the Cumbria House Builders Group, of which Story Homes are part, that the Land Allocations DPD Housing Strategy is to under provide for housing in the period up to 2017 – 2022, but seek to make up the shortfalls in the last 3 years of the plan period. In so doing, the Authority rely on broad locations being brought forward in the context of plan review and for those sites, and others, to contribute to housing completions at unrealistic development rates. In addition it is evident, with reference to the SLDC Annual Monitoring Reports (AMR) from 2003/2004 onwards, that the Council has persistently under delivered housing, year on year, against their annual requirement. However, there is currently no provision for a 20% buffer (housing numbers moved forward from later in the plan period) to provide a realistic prospect of achieving the planned supply, in accordance with paragraph 47 of the NPPF. Tables confirming this under provision are attached to this representation. In light of this, it is Story Homes’ view that the Land Allocations DPD needs to, first, release sites earlier in the plan period and, secondly, increase the density and, therefore, housing yield, on appropriate sites, particularly given the Council’s aspiration in Core Strategy Policy CS6.6 to achieve an average housing density of 30 dwellings per hectare. However, even adopting the latter two measures, it is clear that there will remain a shortfall of housing proposed across the District, with reference to the Garner planning Associates’ Report and, in particular, for Kendal. In order to address this, at least in part, it is Story Homes’ view that the ‘Broad Location’ identified in the Land Allocations DPD, that lies adjacent to the land in Story Homes’ control, should either be considered as an allocation within the DPD or Policy LA1.4 be amended first to allow the site to come forward prior to 2022 and, secondly, make specific reference to the trigger point at which the site will be developed. Leaving this site within the last phase means that, first, it will not be developed fully within the Plan Period and, secondly, it cannot contribute to a shortfall of housing prior to 2022. In addition, bringing the site forward by way of a separate DPD is not effective, in the view of Story Homes.

iv) Consistent with National Policy
Story Homes considers that, although the Council’s overall phasing is not currently consistent with the NPPF, the allocation of land under their ownership, which forms part of a larger site allocation Reference R103M-mod, is fully consistent with national policy. The detailed Sustainability Appraisal carried out by the Council in relation to each proposed housing allocation assessed the allocation against delivering the economic, social and environmental dimensions to sustainable development, as required by paragraph 7 of the NPPF. This proposed allocation will enable, in full, the 3 key aims of sustainable development to me bet.

Conclusion
Story Homes, in conjunction with the land owners, fully support the allocation of land under their control forming the northern extent of housing allocation R103M/mod for residential development, subject to the increase in density proposed by Story Homes. In doing so, Story Homes have taken full cognisance of paragraph 182 of the NPPF in terms of demonstrating the soundness of this particular allocation. This statement confirms that the site is fully deliverable in the context of paragraph 47 of the NPPF and that the allocation of the site is fully in accordance with the key aims of the NPPF of delivering sustainable development in accordance with SLDC Core Strategy. Story Homes are also in agreement with the Council that development of the site should take place within Phase 1 of the Council Housing Strategy, in accordance with Policy LA1.3 of the Land Allocations DPD. However, it is Story Homes’ view that the density should be increased to around 24 dwellings per hectare, generating a yield of 264 dwellings which will contribute to the housing shortfall of 1891 units identified in the Garner Report. In light of the above it is respectfully requested by Story Homes that the Inspector endorses, in the first instance, the Council’s allocation of the land under control of Story Homes extending southwards from Brigsteer Road at an increased yield across the whole site of 264 dwellings, secondly, the allocation in its entirety (Site Ref: 103M-mod) for residential development.

In terms of Local Service Centres, of which Endmoor is one, Table 5 of the Garner Report also highlights that there is a shortfall of 222 dwellings in Local Service Centres to the meet the Core Strategy requirements. In light of this the deliverability of the allocated site on land north of Sycamore Close, Endmoor is important in terms of delivering the housing requirement for the Local Service Centres, and indeed the District as a whole, in terms of both housing numbers and also their deliverability early in the plan period.
Story Homes are also of the view that, due to the persistent record of failure to deliver the annual housing requirement, a 20% buffer should be allowed for early on in the plan period, in accordance with NPPF guidance.

YES, I wish to participate at the oral examination

see other reps

I have read the guidance notes

LA1.3 Housing Allocations - R107M mod and R150M KENDAL KENDAL PARKS

Yes

Yes

Land at Kendal Parks, Kendal (Site Refs: R107M and R150M)

Introduction
Story Homes fully supports, in principle, the allocation of land at Kendal Parks for residential development within the South Lakeland Land Allocations DPD. Whilst Story Homes support the allocation of both sites (Site Refs: R107M and R150M) for residential development, this statement only relates to the land under the control of Story Homes which comprises Site R107M Kendal Parks and the northern field of Site R150M Kendal Parks. Plan reference L000139.LP (Location Plan) attached to this representation clarifies the boundary to the land in question. For clarification references to ‘the site’ relate to this land within the control of Story Homes.

This statement confirms, first, both Story Homes’ and the land owners’ continued support for this residential allocation and, secondly, that the site is fully deliverable. As a consequence, the statement emphasises that the development should commence in Phase 1 of the plan. In order to inform Story Homes support for the allocation an indicative masterplan (Plan Ref: 01-01) has been prepared to demonstrate the acceptability of development on the site.

Site Description
The site is located on the south-eastern edge of Kendal, the eastern-most extent of Kendal Parks Road. The land under control of Story Homes comprises agricultural grazing land which forms a relatively narrow rectangular parcel bounded to the west by established residential areas and to the east by the Kendal to Windermere Railway with the land rising up to the railway from west to east. To the south of the site lies further agricultural grazing fields which comprise the remainder of allocated site R150M. Bounding the north of the site is a mature woodland amenity area whilst Natland Mill Beck dissects this site east to west with the river flowing in a westerly direction into the River Kent. The public right of way also runs through the site in an easterly direction from Kendal Parks Road and underneath the railway towards Kendal Parks Farm. A central woodland area is located between Natland Mill Beck and the public footpath – however, this area is excluded from the allocated site.

Policy Context
The National Planning Policy Framework (NPPF) was published on 27th March 2012. Paragraph 182 of the NPPF requires that a Local Plan has been prepared in accordance with the duty to co-operate, legal and procedural requirements, and whether it is sound. In light of this, the local planning authority are required to submit a plan for examination which it considers to be sound, which requires the plan to be assessed against the following:

• Positively prepared – the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development;

• Justified – the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence;

• Effective – the plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priority;

• Consistent with national policy – the plan should enable the delivery of sustainable development in accordance with the policies in the framework.

1. Positively Prepared – Story Homes considered that South Lakeland’s Housing Strategy, as laid out in their Land Allocations DPD has been positively prepared, following a full appraisal of designated strategic objectives, which were formulated in line with the key aims of sustainable development;

2. Justified - The residential allocation of land at Kendal Parks was made through the evolution and appraisal of almost 1,000 potential site options with the formulation of a sustainability appraisal framework to provide the basis for appraising, analysing and preparing the sustainability effects of all the alternative site options. In light of this Story Homes considers that the proposed allocation is justified in terms of it being an appropriate site for housing considered against the alternatives assessed and on the basis of the Council’s comprehensive evidence base;

3. Effective – The NPPF requires that the housing strategy outlined in the Land Allocations DPD is fully deliverable over the designated plan period. In this regard, Story Homes agree with the conclusions drawn from the report prepared and submitted by Garner Planning Associates, on behalf of the Cumbria House Builders Group, of which Story Homes are part, that the Land Allocations DPD Housing Strategy is to under provide for housing in the period up to 2017 – 2022, but seek to make up the shortfalls in the last 3 years of the plan period. In so doing, the Authority rely on broad locations being brought forward in the context of plan review and for those sites, and others, to contribute to housing completions at unrealistic development rates. In addition it is evident, with reference to the SLDC Annual Monitoring Reports (AMR) from 2003/2004 onwards, that the Council has persistently under delivered housing, year on year, against their annual requirement. However, there is currently no provision for a 20% buffer (housing moved forward from later in the plan period) to provide a realistic prospect of achieving the planned supply, in accordance with paragraph 47 of the NPPF. Tables confirming this under provision are attached to this representation. In light of this, it is Story Homes’ view that the Land Allocations DPD needs to, first, release sites earlier in the plan period and, secondly, seek to ensure, wherever possible, that housing numbers proposed on each respective site accords better with the Council’s aspiration in Core Strategy Policy CS6.6 of seeking an average density of 30 dwellings per hectare.

i) Availability
Story Homes have control of the land by way of a legal agreement with the Westbury family, the owners of the site who reside at Kendal Parks Farm. Story Homes have been instructed to seek a formal allocation on the land with a view to bringing forward a development scheme as soon as possible. In light of this, it is considered that the site is available now.


ii) Suitability
Core Strategy Policy CS1.2 (the Development Strategy) confirms that development will be concentrated in the towns on Kendal and Ulverston, which are defined as Principal Service Centres. In this regard, Policy CS1.2 allocates approximately 35% of new housing in and around Kendal. This equates to a requirement for 3,080 dwellings for Kendal across the plan period. In light of this a detailed analysis and assessment was undertaken by the Council as part of the emerging Land Allocations Development Plan Document to identify sites considered suitable to accommodate the housing numbers required by SDLCs Housing Strategy, as highlighted in Core Strategy Policy CS1.2. In this regard, a total of 149 sites were put forward initially for consideration for further development in Kendal. This included the allocated site the subject of this representation. The Development Strategy Team created a further 19 modified sites as part of the process to identify ‘Emerging Option’ sites in January 2011. As part of the consultation exercise on the ‘Emerging Option’ sites a further 30 new and alternatives sites were identified. Based on the comprehensive evidence base formulated by SDLC and detailed site assessments conducted as part of the emerging Land Allocations Development Plan Document, a total of 25 sites were put forward as ‘Emerging Options’. These included both land under the control of Story Homes and the land extending southwards from this, both of which were the subject of a housing allocation. Utilising the evidence base, and with the benefit of further assessment, a total of 21 sites and 2 broad locations were included for allocation. The land the subject of this representation, together with the land extending southwards, were both allocated for housing under Site Refs: R107M and R150M.

It is clear, therefore, that the allocation of the subject site for housing has been a consequence of a continuing process of detailed assessment by the Council against its comprehensive evidence base. In light of this, SLDC consider that the site is suitable to accommodate residential development with Story Homes in full agreement with the Council for the following reasons:

a) There are no restrictive planning policy designations across the site which would preclude development;

b) The site is located within the settlement limit for Kendal, with Site Allocation R107M identified in the SHLAA as a Category 2 site with the field immediately south of Site R107M, also under the control of Story Homes, identified as Category 3 within the SHLAA. This key evidence base study has clearly established the suitability of the site for residential purposes;

c) The site was assessed as part of the Kendal Transport Plan (June 2009) in terms of identifying a satisfactory site access and also impact on highways capacity. This confirmed that the site could be satisfactorily accessed from the eastern end of Kendal Parks Road. In addition, the study confirmed that, on the basis of the scale of development proposed within the SHLAA, there was sufficient capacity at the signalised junction between Kendal Parks Road and Oxenholme Road to accommodate the additional traffic generated by the proposed site. In addition, Story Homes has consulted with the County Highways Authority in relation to a proposed priority junction to access the site. The Highways Authority has confirmed that this is acceptable, in principle.

d) The site is highly sustainable in that it benefits from good accessibility to public transport, with the whole site located within 400m of a bus stop and lying within easy reach of Oxenholme Railway Station, together with employment, shopping and school services;

e) The Environment Agency has confirmed that the site is located in Flood Risk Zone 1 and is, therefore, at little or no risk of flooding. Natland Mill Beck runs through the site and therefore a Flood Risk Assessment will be required to accompany any future planning application to ensure the appropriate management of surface water disposal does not cause flooding on site or elsewhere in the catchment.

f) In relation to foul drainage, United Utilities have advised that the most suitable connection point for foul flows will be the existing adopted foul sewer located in Kendal Parks Road and that there is sufficient capacity in the existing network to accommodate the extra flows.

g) In terms of services and facilities, Story Homes have undertaken an assessment of the required services and utilities required to serve the site including water, gas, electric and telecoms. Following investigations, Story Homes can confirm there are no utilities and servicing constraints that effect the proposed development.

h) The majority of the site is improved agricultural land. However, Natland Mill Beck flows through the site and is a tributary of the River Kent and, therefore part of a Special Area of Conservation (SAC). In light of this, prior to the detailed design of the site a full ecological survey will be undertaken to fully evaluate the ecological and biodiversity of the site, including Natland Mill Beck. As part of this study a thorough assessment of the impact of the proposed development upon the features of the SAC will be undertaken to ensure no adverse impact upon water quality and flow of the water course. In addition, as part of any future development proposals for the site, and in accordance with the requirements of Natural England, a permanent fence will be erected in order to create a 10m wide no-working buffer zone adjacent to the watercourse with any development located at least 15m from it. This buffer zone will then be landscaped with no local native trees. In conjunction with these measures survey work will identify opportunities to enhance the ecological and biodiversity value of the site.

i) The Kendal to Windermere railway line runs along the eastern boundary of the site and is a potential generator of noise. However, the railway line is a less used line in comparison to the West Coast Main Line trains speeds are significantly reduced due to the proximity of Oxenholme Station. Notwithstanding this, a Noise Survey has been carried out by Story Homes which confirms that, given the moderate noise levels generated, appropriate attenuation measures can be incorporated within those dwellings closet to the railway line with this principally comprising ‘acoustic’ double glazing and fencing;

j) From a landscape and visual impact perspective the development of this site for housing would occur entirely within the existing development limits for Kendal and would form a logical and sustainable extension of the town up to the natural boundary to development provided by the Kendal to Windermere Railway, without harming the character of the area. Landscape and visual impact can be further mitigated with a comprehensive landscape strategy, focusing on the eastern and southern boundaries which are elevated within the wider landscape. The indicative masterplan submitted with this representation illustrates how a scheme for residential development could work on the site in the context of ensuring that landscape and visual impact issues play a major part in the scheme’s evolution. This illustrates the retention and enhancement of the landscaped buffer between the railway line and proposed development to the west together with the landscaped buffer to the south, although this also shows that a potential access, if required, can be provided to the remainder of housing allocation R150M. The indicative masterplan also shows a landscaped buffer zone around Natland Mill Beck with an area of POS also proposed to ensure a suitable buffer between the SAC and any new housing. This also ensures the creation of a linear green infrastructure corridor traversing east-west which also provides pedestrian/cycle access through the site with the links to neighbouring residential areas and open spaces as well as Oxenholme Road. It should also be noted that the proposed residential development is shown at a density of approximately 25 dwellings per hectare, reflecting the nature of the site, existing form, scale and character of the established residential areas to the west and also the provision made within the site for high quality, effective landscaping. This density does, however, accord more fully with the provisions of Core Strategy Policy CS6.6 in terms of achieving an appropriate density across all allocated sites rather than the density currently proposed across this proposed site. Policy LA1.3 of the Land Allocations DPD proposes a yield of 200 dwellings on this site of 10.1 hectares. This equates to a density of only 20 dwellings per hectare which is significantly below both the aspirational average density of 30 dwellings per hectare and the density proposed by Story Homes of 23 dwellings per hectare. It is proposed, in light of this, that the latter density of 23 dwellings per hectare be applied across the whole of the allocated site in order to contribute, in part, to the shortfall of housing (1891 units) identified by the Garner Report across the plan period through an increase in yield to 230 units.

iii) Achievability
Story Homes can confirm the economic viability of the site taking into consideration all known costs as well as meeting the policy requirements of the SLDC Core Strategy and also Policy LA2.4 of the Land Allocations DPD. Story Homes have taken into account market, cost and delivery factors as well as residual evaluation calculations in arriving at this conclusion. Based upon the experience of Story Homes, and an assessment of the local market and economy, it is predicted the site would take in the region of 6 years to deliver. This assumes 2 years to obtain the relevant planning permission and commencement development on the site and approximately 4 years to complete and sell the proposed dwellings. This is based upon the site area of 5 hectares and a total of 115 units at an average selling rate of 30 dwellings per annum which presently may be optimistic, but could be achieved over the lifetime of the site if economic circumstances improve.

In light of this, Story Homes welcomes the inclusion of the site within Phases 1 and 2 of the Council’s proposed housing strategy. As the primary access route serving the Kendal Parks site will be Kendal Parks Road it is the view of Story Homes that the enlarged site R107M should be allocated in Phases 1 and 2 and the remaining site R150M be allocated in Phases 2 and 3. This would enable the natural development of the wider site to evolve, starting from the northern part of the site which is better related to the existing settlement and principal access route.

iv) Consistent with National Policy
Story Homes considers that, although the Council’s phasing does not currently accord with the NPPF, the allocation of the site under the control of Story Homes and indeed the remainder of Site Allocation R150M, is fully consistent with national policy. The Sustainability Appraisal carried out by the Council in relation to each proposed housing allocation assessed the allocation against delivering the economic social and environmental dimensions to sustainable development, as required by paragraph 7 of the NPPF. This proposed allocation will enable, in full, the 3 key aims of sustainable development to be met.

Conclusion
Story Homes, in conjunction with the land owners of the site in the ownership of Story Homes, fully supports the allocation of this land for residential development. In doing so, Story Homes have taken full cognisance of paragraph 182 of the NPPF in terms of demonstrating the soundness of this particular allocation. In this regard, Story Homes supports the submission by Garner Planning Associates, on behalf of the Cumbria House Builders Group, in terms of highlighting both a shortfall in housing numbers proposed by the Council over the plan period and also the need to bring forward the development of housing sites to earlier in the plan period. Story Homes are also of the view that, due to the persistent record of failure to deliver the annual housing requirement, a 20% buffer is to be allowed for early on in the plan period, in accordance with NPPF guidance.

Story Homes, through this statement, also confirms that the site is fully deliverable in the context of paragraph 47 of the NPPF and that the allocation of the site is fully in accordance with the aims of the NPPF of delivering sustainable development in accordance with the SLDC Core Strategy. Whilst Story Homes do not control the land forming the remainder of housing allocation R150M they are, none the less, of the view that this land should also be brought forward for housing. It is also Story Homes’ view that a realistic density of 23 dwellings per hectare can be achieved on both the land in Story Homes’ ownership and also the wider allocation, rather than the 20 dwellings per hectare proposed in Core Strategy CS6.6 and so contribute to the housing shortfall identified in the Garner Report.

In light of the above it is respectfully requested by Story Homes that the Inspector, first, endorses the Council’s allocation of this site for housing and, secondly, includes it for development within Phases 1 and 2 of the Council’s Housing Strategy.

YES, I wish to participate at the oral examination

Representations submitted on behalf of Story Homes deal with both site-specific and District-wide housing issues

LA1.3 Housing Allocations - R107M mod and R150M KENDAL KENDAL PARKS

Yes

No

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

The DPD is not consistent with national policy.

It should also be noted that the proposed residential development is shown at a density of approximately 25 dwellings per hectare, reflecting the nature of the site, existing form, scale and character of the established residential areas to the west and also the provision made within the site for high quality, effective landscaping. This density does, however, accord more fully with the provisions of Core Strategy Policy CS6.6 in terms of achieving an appropriate density across all allocated sites rather than the density currently proposed across this proposed site. Policy LA1.3 of the Land Allocations DPD proposes a yield of 200 dwellings on this site of 10.1 hectares. This equates to a density of only 20 dwellings per hectare which is significantly below both the aspirational average density of 30 dwellings per hectare and the density proposed by Story Homes of 23 dwellings per hectare. It is proposed, in light of this, that the latter density of 23 dwellings per hectare be applied across the whole of the allocated site in order to contribute, in part, to the shortfall of housing (1891 units) identified by the Garner Report across the plan period through an increase in yield to 230 units.

Story Homes, through this statement, also confirms that the site is fully deliverable in the context of paragraph 47 of the NPPF and that the allocation of the site is fully in accordance with the aims of the NPPF of delivering sustainable development in accordance with the SLDC Core Strategy. Whilst Story Homes do not control the land forming the remainder of housing allocation R150M they are, none the less, of the view that this land should also be brought forward for housing. It is also Story Homes’ view that a realistic density of 23 dwellings per hectare can be achieved on both the land in Story Homes’ ownership and also the wider allocation, rather than the 20 dwellings per hectare proposed in Core Strategy CS6.6 and so contribute to the housing shortfall identified in the Garner Report.

YES, I wish to participate at the oral examination

Representations submitted on behalf of Story Homes deal with both site-specific and District-wide housing issues

I have read the guidance notes

LA1.3 Housing Allocations - R97 /MN34# KENDAL SOUTH OF NATLAND BECK FARM

Yes

Yes

Introduction
Story Homes fully supports the allocation of land South of Natland Mill Beck Farm, Kendal (Site Ref: R97M-mod and part of MN34#-mod) for residential development and has prepared and submitted this representation on behalf of the land owners. This statement confirms, first, both Story Homes’ and the land owners’ continued support for this residential allocation and, secondly, that this site is fully deliverable. As such, Story Homes fully supports the proposed development of land south of Natland Mill Beck Farm within Phases 1 and 2 of the Land Allocations DPD. In order to inform Story Homes support for the allocation an indicative masterplan is being prepared to demonstrate the acceptability of development on this allocated site.

Site Description
The site is located on the southern edge of Kendal, forming a broadly triangular shaped piece of land extending to approximately 3.97 hectares. The site is generally flat and bounded to the north by Natland Mill Beck Lane and Natland Mill Beck Farm and associated outbuildings, to the south-east by the road providing access to Helme Lodge, together with agricultural grazing fields beyond this to the south and south-east, and to the west by a mature tree belt which lines Natland Road passing north-south at this point. Natland Mill Beck farmhouse is a Grade II listed building, which is accessed from Natland Mill Beck Lane, beyond which is an area of open space adjoining an existing residential area. Helme Lodge to the south of the site is also a Grade II listed building and is heavily screened from the site by mature trees and vegetation. The most eastward point of the site extends to the junction between Natland Mill Beck Lane and Burdon Road to the east, beyond which is an Asda Superstore.

Policy Context
The National Planning Policy Framework (NPPF) was published on 27th March 2012. Paragraph 182 of the NPPF requires that a Local Plan has been prepared in accordance with the duty to co-operate, legal and procedural requirements, and whether it is sound. In light of this, the local planning authority are required to submit a plan for examination which it considers to be sound, which requires the plan to be assessed against the following:

• Positively prepared – the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development;

• Justified – the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence;

• Effective – the plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priority;

• Consistent with national policy – the plan should enable the delivery of sustainable development in accordance with the policies in the framework.

1. Positively Prepared – Story Homes considered that South Lakeland’s Housing Strategy, as laid out in their Land Allocations DPD has been positively prepared, following a full appraisal of designated strategic objectives, which were formulated in line with the key aims of sustainable development;

2. Justified - The residential allocation of land at Brigsteer Road was made through the evolution and appraisal of almost 1,000 potential site options with the formulation of a sustainability appraisal framework to provide the basis for appraising, analysing and preparing the sustainability effects of all the alternative site options. In light of this Story Homes considers that the proposed allocation is justified in terms of it being an appropriate site for housing considered against the alternatives assessed and on the basis of the Council’s comprehensive evidence base;

3. Effective – The NPPF requires that the housing strategy outlined in the Land Allocations DPD is fully deliverable over the designated plan period. In this regard, Story Homes agree with the conclusions drawn from the report prepared and submitted by Garner Planning Associates, on behalf of the Cumbria House Builders Group, of which Story Homes are part, that the Land Allocations DPD Housing Strategy is to under provide for housing in the period up to 2017 – 2022, but seek to make up the shortfalls in the last 3 years of the plan period. In so doing, the Authority rely on broad locations being brought forward in the context of plan review and for those sites, and others, to contribute to housing completions at unrealistic development rates. In addition it is evident, with reference to the SLDC Annual Monitoring Reports (AMR) from 2003/2004 onwards, that the Council has persistently under delivered housing, year on year, against their annual requirement. However, there is currently no provision for a 20% buffer (housing numbers moved forward from later in the plan period) to provide a realistic prospect of achieving the planned supply, in accordance with paragraph 47 of the NPPF. Tables confirming this under provision are attached to this representation. In light of this, it is Story Homes’ view that the Land Allocations DPD needs to, first, release sites earlier in the plan period and, secondly, increase the density and, therefore, housing yield, on appropriate sites, particularly given the Council’s aspiration in Core Strategy Policy CS6.6 to achieve an average housing density of 30 dwellings per hectare. However, even adopting the latter two measures, it is clear that there will remain a shortfall of housing proposed across the District, with reference to the Garner planning Associates’ Report and, in particular, for Kendal. In order to address this, at least in part, it is Story Homes’ view that the ‘Broad Location’ identified in the Land Allocations DPD, that lies adjacent to the land in Story Homes’ control, should either be considered as an allocation within the DPD or Policy LA1.4 be amended first to allow the site to come forward prior to 2022 and, secondly, make specific reference to the trigger point at which the site will be developed. Leaving this site within the last phase means that, first, it will not be developed fully within the Plan Period and, secondly, it cannot contribute to a shortfall of housing prior to 2022. In addition, bringing the site forward by way of a separate DPD is not effective, in the view of Story Homes.

ii) Suitability
Core Strategy Policy CS1.2 (the Development Strategy) confirms that development will be concentrated in the towns on Kendal and Ulverston, which are defined as Principal Service Centres. In this regard, Policy CS1.2 allocates approximately 35% of new housing to around Kendal. This equates to a requirement for 3,080 dwellings for Kendal across the plan period. In light of this a detailed analysis and assessment was undertaken by the Council as part of the emerging Land Allocations Development Plan Document to identify sites considered suitable to accommodate the housing numbers required by the Council’s Housing Strategy, as highlighted in Core Strategy Policy CS1.2. In this regard, a total of 149 sites were put forward initially for consideration for further development in Kendal. This included the allocated site the subject of this representation.

The Development Strategy Team created a further 19 modified sites as part of the process to identify ‘Emerging Option’ sites in January 2011. As part of the consultation exercise on the ‘Emerging Option’ sites a further 30 new and alternatives sites were identified.

Based on the comprehensive evidence base formulated by SDLC and detailed site assessments conducted as part of the emerging Land Allocations Development Plan Document, a total of 25 sites were put forward as ‘Emerging Options’. These included the land in the control of Story Homes which, earlier on in the assessment process, were two separate sites (R97M and R104). Utilising the evidence base, and with the benefit of further assessment, a total of 21 sites and 2 broad locations were included for allocation. The site the subject of this representation was included as a formal allocation.

It is, therefore, clear that the allocation of the subject site for housing has been a consequence of a continuing process of detailed assessment by the Council against its comprehensive evidence base. In light of this, SLDC considered that the site is suitable to accommodate residential development with Story Homes agreeing with the Council for the following reasons:

a) There are no restrictive planning policy designations across the site which would preclude development;

b) The site was identified in the SHLAA as a Category 3 site and therefore as a potentially suitable housing site within the District.

c) The site is in a highly sustainable location, with good pedestrian and cycle links to existing facilities and services together with good access to public transport, particularly Oxenholme railway station. Pedestrian/cycle links with the surrounding area will be maintained and enhanced as part of any development on the site with a particular emphasis on linking the site with the Canal Cycle Path.

d) The Environment Agency has confirmed that the site falls within Flood Zone 1 and, therefore, represents a low risk of flooding from tidal river sources. United Utilities have also confirmed that there are no records for localised surface water flooding issues.

e) Surface water drainage will be fully considered as part of the future submission of a planning application. However, there are options for the treatment of surface water, the choices of which will be largely dependent upon ground conditions which may enable the use of SUDS or, if ground conditions are not suitable, surface water discharge to a watercourse (likely to be Natland Mill Beck) attenuated to greenfield run-off rates will be considered. There is also the further option of discharging the surface water to an adopted sewer (subject to the approval of United Utilities).

f) Given that the boundary to the housing allocation extends to both Natland Mill Beck Lane and Natland Road, there are various potential options to access the site. Story Homes has discussed the proposed access arrangements with Cumbria Highways Authority and agreement was reached in principle for a primary two way access serving the site via Natland Road utilising the existing access arrangements, and that access via Natland Mill Beck Lane will be investigated in greater detail to determine if a safe two way or single access (entry only) could be achieved. Alternatively, this access could be utilised as a pedestrian, cycle and emergency vehicle access only. In terms of traffic generation the Kendal Transport Study has confirmed that there is sufficient capacity within the existing highway network to accommodate development on the proposed site. A full Transport Assessment will be prepared to accompany any future planning application.

g) Given the proximity of the allocated site to the Grade II listed Natland Mill Beck Farmhouse and Helme Lodge to the south respectively, any scheme proposed by Story Homes will ensure that there will be no impact from new development on the setting of either listed building. Indeed, in terms of Helme Lodge there is already an existing mature tree belt between the site and Helme Lodge which will ensure that the setting of the Lodge will remain unaffected, whilst in the case of the setting of Natland Mill Beck farmhouse this will be significantly improved due to the farm outbuildings and slurry pit, which currently detract from the setting of the farmhouse, being replaced by appropriate structural planting and landscaping. As a matter of course, a Heritage Statement will be submitted in support of any planning application on the site.

h) In terms of ecology and biodiversity a full ecological assessment will be carried out to accompany any future planning application on the site. This will be used to inform the precise form and layout of any new development with particular emphasis on the retention of trees and hedgerows, in particular the existing mature tree belt bounding the western part of the site.

i) Whilst the site is not visually prominent, due principally to its topography and the existing level of screening afforded to the site, particularly from views from the west and south-east, together with the existing development either adjacent or close to the site boundary in its entirety which will serve to further diminish any new development on this area of land, development of the site provides an opportunity to further strengthen the structural landscaping, with the use of native tree and shrub species which will not only reduce further any visual impact from new development, but will also enhance the biodiversity and ecology of the site.

iii) Achievability
Story Homes can confirm the economic viability of the site accounting for all known costs as well as meeting the policy requirements of the SLDC Core Strategy. Based upon the current market conditions, and the experience of Story Homes, it is likely that it would take approximately 4 years to build and sell the 73 units proposed. This comprises a year to prepare and obtain the necessary planning permission, a year to undertake initial site infrastructure works and approximately 2 years to build and sell the new units. This is based upon an envisaged selling rate of 30 dwellings per year. Given that it has been demonstrated that the site is fully deliverable it can contribute to the development required within Phases 1 and 2 in order that it can contribute to meeting the aims of the Core Strategy.

i) Consistent with National Policy
Story Homes considers that, whilst the Council’s phasing is not currently consistent with the NPPF, the allocation of the site under the control of Story Homes and indeed the remainder of Site Allocation R150M, is fully consistent with national policy. The Sustainability Appraisal carried out by the Council in relation to each proposed housing allocation assessed the allocation against delivering the economic social and environmental dimensions to sustainable development, as required by paragraph 7 of the NPPF. This proposed allocation will enable, in full, the 3 key aims of sustainable development to be met.

Conclusion
Story Homes, in conjunction with the land owners of Site Ref: R97M-mod and Part MN34#-mod, fully support the allocation of land south of Natland Beck Mill Farm, Kendal for residential development. In doing so, Story Homes have taken full cognisance of paragraph 182 of the NPPF in terms of demonstrating the soundness of this particular allocation. In this regard, Story Homes support the submission of Garner Planning Associates, on behalf of the Cumbria House Builders Group, in terms of highlighting both the shortfall in housing numbers proposed by the Council over the plan period and also the need to bring forward the development of housing sites earlier in the plan period. Story Homes are also of the view that, due to the persistent record of failure to deliver the annual housing requirement, there should be reference to a 20% buffer early on in the plan period, in accordance with NPPF guidance.

Story Homes also confirm within this statement that the site is fully deliverable, in the context of paragraph 47 of the NPPF, and that the allocation of the site is fully in accordance with the key aims of the NPPF of delivering sustainable development in accordance with SLDC Core Strategy. In light of the above it is respectfully requested by Story Homes that the Inspector endorses the Council’s allocation of this land to the south of Natland Mill Beck Farm for residential development.

YES, I wish to participate at the oral examination

Representations submitted on behalf of Story Homes deal with both site-specific and District-wide housing issues

I have read the guidance notes

LA1.4 Broad Locations for New Housing - BURTON ROAD, KENDAL

Yes

No

The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.

Story Homes are also of the view that, in order to address the shortfall of housing numbers in the District as highlighted below, and in particular the shortfall of 856 units for Kendal, the ‘Broad Location’ identified immediately south of Natland Mill Beck Farm should be either considered as an allocation within the Land Allocations DPD, or Policy LA1.4 be amended to first allow Broad Locations to come forward before 2022 and, secondly, to make explicit reference to the trigger point at which sites are to be released.

3. Effective – The NPPF requires that the housing strategy outlined in the Land Allocations DPD is fully deliverable over the designated plan period. In this regard, Story Homes agree with the conclusions drawn from the report prepared and submitted by Garner Planning Associates, on behalf of the Cumbria House Builders Group, of which Story Homes are part, that the Land Allocations DPD Housing Strategy is to under provide for housing in the period up to 2017 – 2022, but seek to make up the shortfalls in the last 3 years of the plan period. In so doing, the Authority rely on broad locations being brought forward in the context of plan review and for those sites, and others, to contribute to housing completions at unrealistic development rates. In addition it is evident, with reference to the SLDC Annual Monitoring Reports (AMR) from 2003/2004 onwards, that the Council has persistently under delivered housing, year on year, against their annual requirement. However, there is currently no provision for a 20% buffer (housing numbers moved forward from later in the plan period) to provide a realistic prospect of achieving the planned supply, in accordance with paragraph 47 of the NPPF. Tables confirming this under provision are attached to this representation. In light of this, it is Story Homes’ view that the Land Allocations DPD needs to, first, release sites earlier in the plan period and, secondly, increase the density and, therefore, housing yield, on appropriate sites, particularly given the Council’s aspiration in Core Strategy Policy CS6.6 to achieve an average housing density of 30 dwellings per hectare. However, even adopting the latter two measures, it is clear that there will remain a shortfall of housing proposed across the District, with reference to the Garner planning Associates’ Report and, in particular, for Kendal. In order to address this, at least in part, it is Story Homes’ view that the ‘Broad Location’ identified in the Land Allocations DPD, that lies adjacent to the land in Story Homes’ control, should either be considered as an allocation within the DPD or Policy LA1.4 be amended first to allow the site to come forward prior to 2022 and, secondly, make specific reference to the trigger point at which the site will be developed. Leaving this site within the last phase means that, first, it will not be developed fully within the Plan Period and, secondly, it cannot contribute to a shortfall of housing prior to 2022. In addition, bringing the site forward by way of a separate DPD is not effective, in the view of Story Homes.

The site extends to approximately 15 hectares and has been assessed as suitable to accommodate residential development by the Council as part of the formulation of their evidence base. The principal constraint on development identified by the Council is the presence of numbers of mature trees. However, even setting aside 25 percent of the area to accommodate existing trees and additional landscape, a potential yield of 280 – 340 dwellings would be achievable at a density of 25 – 30 dwellings per hectare. This would contribute significantly to addressing the housing shortfall and would represent a logical extension of the Natland Mill Beck Farm allocation on this southern extent of Kendal.

In terms of the allocated site’s contribution to housing numbers in Phase 1 Story Homes can confirm that the site is fully deliverable. This is demonstrated by applying the definition of deliverability in the footnote to paragraph 47 of the NPPF, which requires the site to be available, suitable and achievable with a realistic prospect of housing being delivered on the site within 5 years.

i) Availability
Story Homes has been instructed by the landowners, Messrs Gardner, to seek a formal allocation on the land with a view to bringing forward a development scheme as soon as possible. The site is available now for residential development and there are no legal or land ownership issues preventing development coming forward. In addition, Story Homes have been instructed to promote the identified ‘Broad Location’ immediately adjacent to the site for development within the Plan period, rather than being subject to a separate DPD (or iteration of this one).

Story Homes also request that the ‘Broad Location’ identified in the Land Allocations DPD be either considered as an allocation with the DPD or that Policy LA1.4 be amended to first allow the site to come forward before 2022 and, secondly, that specific reference is made to the trigger point at which the site will be considered for release.

YES, I wish to participate at the oral examination

Representations submitted on behalf of Story Homes deal with both site-specific and District-wide housing issues

I have read the guidance notes

LA1.3 Housing Allocations - R103M-mod KENDAL STAINBANK GREEN

Yes

Yes

Introduction
Story Homes fully support, in principle, the allocation of land at Stainbank Green, Kendal (overall allocated Site Ref: R103M-mod) for residential development and has prepared and submitted this representation on behalf of the land owners. Whilst Story Homes support the allocation of the entire site for residential purposes, this statement relates to land under the control of Story Homes which comprises the northern section of the site (previously Site Ref: M39) and confirmed on Plan Ref: L000283.LP attached. This statement confirms, first, both Story Homes’ and the land owners’ continued support for this residential allocation, and in particular the northern section under the control of Story Homes and, secondly, that this northern site is fully deliverable. In light of this the statement emphasises that the development of this land should take place within Phase 1 of the Land Allocations DPD.

In order to inform Story Homes’ support for the allocation an indicative masterplan (Plan Ref: 01-01) has been prepared and attached to this representation to demonstrate the acceptability of development on the land under Story Homes’ control.

Site Description
The site extends to approximately 2.1 hectares in size and is located on the western edge of Kendal. It immediately abuts the western extent of the town and comprises 3 grazing fields forming the northern section of allocated site R103M-mod. The site is bounded to the north by Brigsteer Road, existing residential properties to the east, grazing land to the south which comprises the remainder of Site Allocation 103M-mod, and to the west is further grazing land beyond which is the A591, which runs north/south to the west of Kendall.

The site itself is predominantly level except for the north-east corner of the site which falls steeply towards Brigsteer Road. The boundaries of the site are heavily wooded, offering good existing structural screening into and out of the site. Existing public footpaths run along the southern and eastern boundaries which are to be retained in order to provide links between the proposed residential development and surrounding residential neighbourhoods.

Policy Context
The National Planning Policy Framework (NPPF) was published on 27th March 2012. Paragraph 182 of the NPPF requires that a Local Plan has been prepared in accordance with the duty to co-operate, legal and procedural requirements, and whether it is sound. In light of this, the local planning authority are required to submit a plan for examination which it considers to be sound, which requires the plan to be assessed against the following:

• Positively prepared – the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development;

• Justified – the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence;

• Effective – the plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priority;

• Consistent with national policy – the plan should enable the delivery of sustainable development in accordance with the policies in the framework.

1. Positively Prepared – Story Homes considered that South Lakeland’s Housing Strategy, as laid out in their Land Allocations DPD has been positively prepared, following a full appraisal of designated strategic objectives, which were formulated in line with the key aims of sustainable development;

2. Justified - The residential allocation of land at Brigsteer Road was made through the evolution and appraisal of almost 1,000 potential site options with the formulation of a sustainability appraisal framework to provide the basis for appraising, analysing and preparing the sustainability effects of all the alternative site options. In light of this Story Homes considers that the proposed allocation is justified in terms of it being an appropriate site for housing considered against the alternatives assessed and on the basis of the Council’s comprehensive evidence base;

3. Effective – The NPPF requires that the housing strategy outlined in the Land Allocations DPD is fully deliverable over the designated plan period. In this regard, Story Homes agree with the conclusions drawn from the report prepared and submitted by Garner Planning Associates, on behalf of the Cumbria House Builders Group, of which Story Homes are part, that the Land Allocations DPD Housing Strategy is to under provide for housing in the period up to 2017 – 2022, but seek to make up the shortfalls in the last 3 years of the plan period. In so doing, the Authority rely on broad locations being brought forward in the context of plan review and for those sites, and others, to contribute to housing completions at unrealistic development rates. In addition it is evident, with reference to the SLDC Annual Monitoring Reports (AMR) from 2003/2004 onwards, that the Council has persistently under delivered housing, year on year, against their annual requirement. However, there is currently no provision for a 20% buffer (housing numbers moved forward from later in the plan period) to provide a realistic prospect of achieving the planned supply, in accordance with paragraph 47 of the NPPF. Tables confirming this under provision are attached to this representation. In light of this, it is Story Homes’ view that the Land Allocations DPD needs to, first, release sites earlier in the plan period and, secondly, seek to ensure, wherever possible, that housing numbers proposed on each respective site accords with the Council’s aspiration in Core Strategy Policy CS6.6 for an average density of 30 dwellings per hectare.

In terms of the allocated site’s contribution to housing numbers in Phase 1 Story Homes can confirm that the site is fully deliverable. This is demonstrated by applying the definition of deliverability in the footnote to paragraph 47 of the NPPF which requires the site to be available, suitable and achievable with a realistic prospect of housing being delivered on the site within 5 years.

i) Availability
Story Homes has entered into a legal agreement with the land owner to seek a formal allocation on the land with a view to bringing forward a development scheme as soon as possible. As such the site is available now for residential development and there are no legal or land ownership issues preventing development coming forward.

ii) Suitability
Core Strategy Policy CS1.2 (the Development Strategy) confirms that development will be concentrated in the towns on Kendal and Ulverston, which are defined as Principal Service Centres. In this regard, Policy CS1.2 allocates approximately 35% of new housing to around Kendal. This equates to a requirement for 3,080 dwellings for Kendal across the plan period. In light of this a detailed analysis and assessment was undertaken by the Council as part of the emerging Land Allocations Development Plan Document to identify sites considered suitable to accommodate the housing numbers required by the Council’s Housing Strategy, as highlighted in Core Strategy Policy CS1.2. In this regard, a total of 149 sites were put forward initially for consideration for further development in Kendal. This included the allocated site the subject of this representation.

The Development Strategy Team created a further 19 modified sites as part of the process to identify ‘Emerging Option’ sites in January 2011. As part of the consultation exercise on the ‘Emerging Option’ sites a further 30 new and alternatives sites were identified.

Based on the comprehensive evidence base formulated by SDLC and detailed site assessments conducted as part of the emerging Land Allocations Development Plan Document, a total of 25 sites were put forward as ‘Emerging Options’. These included both land under the control of Story Homes immediately south of Brigsteer Road and the land extending southwards from this site also the subject of a housing allocation. Utilising the evidence base, and with the benefit of further assessment, a total of 21 sites and 2 broad locations were included for allocation. The land the subject of this representation, together with the land to the south form a single allocation within the final version of the Land Allocations DPD as Site Ref: R103M-mod.

It is, therefore, clear that the allocation of the subject site for housing has been a consequence of a continuing process of detailed assessment by the Council against its comprehensive evidence base. In light of this, SLDC considered that the site is suitable to accommodate residential development with Story Homes agreeing with the Council for the following reasons:

a. There are no restrictive planning policy designations across the site which would preclude development;

b. The Environment Agency has confirmed that the site is located in Flood Risk Zone 1 and is therefore at little or no risk of flooding from river, tidal and coastal sources. However, development that increases the amount of any impermeable surfaces can result in an increase in surface water run-off, which could result in flooding on site or elsewhere in the catchment. Any future scheme will be designed to ensure the management of surface water disposal which does not cause flooding on site or elsewhere in the catchment and which will be confirmed through the preparation of a Flood Risk Assessment which will accompany any future planning application;

c. The northern section of Allocation R103M-mod (previously Site Allocation M39) was identified as a suitable site for residential development within Category 1 of the SHLAA. The site was also identified within the Employment and Housing Land Search Study (February 2009) as a Category 3 site;

d. Cumbria County Council Highways are in agreement with Story Homes that an appropriate access to the site can be taken from Brigsteer Road close to the north-eastern corner of the site;

e. The site offers good access on foot and cycle to a range of services including public transport, the town centre, schools and employment opportunities. Opportunities also exist to improve the connectivity of the site by linking into the footpath network which surrounds the site and links into the neighbouring residential areas, whilst also improving footpath links along Brigsteer Road;

f. In terms of the cumulative impact of the traffic generated in Kendal any submission of a future planning application on this site will be supported by a full Transport Assessment, Travel Plan and Road Safety Audit to ensure that the proposed scheme is acceptable in highways terms;

g. Cumbria Wildlife Trust have confirmed that the development of this site is feasible, although any development would need to avoid harm to any Meadow Saxifrage which could be located towards the north east corner of the site. Meadow Saxifrage is not a statutory protected species and a number of mitigation measures could be undertaken to ensure no net loss of habitat, including transplanting the species to more suitable locations within the site, the site boundaries and potentially alternative sites. We therefore object to the wording of Policy LA2.7, as we consider it is not justified. We consider the following policy wording would be more appropriate in accordance with national planning policy set out within the NPPF ‘Undertake a detailed ecological survey to determine the presence of Meadow Saxifrage within the NE corner of the site and if required ensure acceptable mitigation measures are undertaken to ensure no significant harm to this habitat’. This would accord with the approach advocated in paragraph 118 of the NPPF. Notwithstanding this, the indicative masterplan submitted in support of this representation confirms that the area in question will be retained as public open space, to safeguard and enhance the ecological habitat;

h. In relation to foul and surface water drainage, Story Homes has consulted with United Utilities, the Environment Agency and also instructed Integra Consulting to undertake a Desk Top Drainage Assessment. In relation to foul drainage, United Utilities have advised that foul flows can be discharged to the combined sewer in Brigsteer Road. In terms of surface water drainage a range of options exist, with the final scheme confirmed as part of any future planning application. The options include SUDS, depending on ground conditions, discharge of surface water into Blind Beck or establish a connection to the combined sewer system in Brigsteer Road appropriately attenuated to greenfield run-off rates;

i. In terms of services and utilities, Story Homes has undertaken an assessment of the required services and utilities to serve the site including water, gas, electric and telecoms. Following their investigations, Story Homes can confirm that there are no utilities and servicing constraints that affect the proposed development.

j. In terms of landscape and visual impact, it is considered that the site benefits from good levels of existing screening through the presence of mature trees bounding the site on 3 sides. Existing trees and hedgerows will be retained as part of any development on the site, which is illustrated in the indicative masterplan submitted in support of this representation. This illustrates that, whilst access to the remainder of Allocation R103M-mod is provided along the site’s southern boundary, due to the existing screening along this southern extent the site could be developed out in its own right. It should also be noted from the indicative masterplan that the proposed density has been kept relatively low, in this case around 24 dwellings per hectare, in order to reflect and respect the existing character, form and layout of housing to the east. This density does, however, accord more fully with the provisions of Core Strategy Policy CS6.6 in terms of achieving an average of 30 dph across all allocated sites than the density currently proposed across this proposed site. Policy LA1.3 of the Land Allocations DPD proposes a yield of 189 dwellings on this site of 10.8 hectares. This equates to a density of first over 17 dwellings per hectare which is significantly below both the aspirational average density of 30 dwellings per hectare and the density proposed by Story Homes of 24 dwellings per hectare. It is proposed, in light of this, that the latter density of 24 dwellings per hectare be applied across the whole of the allocated site in order to contribute, in part, to the shortfall of housing (1891 units) identified by the Garner Report across the plan period through an increase in yield of 264 units and Policy LA1.3 should be amended accordingly. The indicative masterplan also confirms that connectivity via existing footpath networks are to be retained as part of any residential development which allows permeation through from the adjoining residential area and also onto Brigsteer Road. It is clear that residential development on the site, of the form, scale and nature proposed within the indicative masterplan, reflects the setting of both the site and the surrounding area and, in doing so, ensure that the development requirements (to form an overall development brief) outlined in Policy LA2.7 of the Land Allocations DPD is fully addressed.

iii) Achievability
Story Homes can confirm the economic viability of the site taking into consideration all known costs as well as meeting the policy requirements of the SLDC Core Strategy and the Development Brief contained within Policy LA2.7 of the Land Allocations DPD. The site is within the control of Story Homes and extends to approximately 2.1 hectares in area. Following an assessment of the local market and based upon the experience of Story Homes it is considered that the site would deliver approximately 50 units, as proposed within the indicative masterplan, at a density of approximately 24 dwellings per hectare. It would therefore take in the region of 3 - 4 years to deliver which would comprise a year to obtain the necessary planning permission, a year to undertake initial site infrastructure works and construct the development and up to 2 years to sell the 50 units.

Whilst the land under the control of Story Homes could be developed in its own right, the allocation in its entirety, extending to approximately 10.8 hectares, should be earmarked for around 264 dwellings (at a density of 24 dwellings per hectare). Of this, 60 units should be retained within Phase 1, with the balance of 204 proposed within Phase 2 of the Council’s Housing Strategy. In light of this, whether the site under the ownership of Story Homes is developed out on its own or in conjunction with the allocation in its entirety, the 50 units proposed will need to be constructed within Phase 1, particularly in light of the need for a 20% buffer at the front end of the plan period.

iv) Consistent with National Policy
Story Homes considers that, although the Council’s overall phasing is not currently consistent with the NPPF, the allocation of land under their ownership, which forms part of a larger site allocation Reference R103M-mod, is fully consistent with national policy. The detailed Sustainability Appraisal carried out by the Council in relation to each proposed housing allocation assessed the allocation against delivering the economic, social and environmental dimensions to sustainable development, as required by paragraph 7 of the NPPF. This proposed allocation will enable, in full, the 3 key aims of sustainable development to me bet.

Conclusion
Story Homes, in conjunction with the land owners, fully support the allocation of land under their control forming the northern extent of housing allocation R103M/mod for residential development, subject to the increase in density proposed by Story Homes. In doing so, Story Homes have taken full cognisance of paragraph 182 of the NPPF in terms of demonstrating the soundness of this particular allocation. This statement confirms that the site is fully deliverable in the context of paragraph 47 of the NPPF and that the allocation of the site is fully in accordance with the key aims of the NPPF of delivering sustainable development in accordance with SLDC Core Strategy. Story Homes are also in agreement with the Council that development of the site should take place within Phase 1 of the Council Housing Strategy, in accordance with Policy LA1.3 of the Land Allocations DPD. However, it is Story Homes’ view that the density should be increased to around 24 dwellings per hectare, generating a yield of 264 dwellings which will contribute to the housing shortfall of 1891 units identified in the Garner Report. In light of the above it is respectfully requested by Story Homes that the Inspector endorses, in the first instance, the Council’s allocation of the land under control of Story Homes extending southwards from Brigsteer Road at an increased yield across the whole site of 264 dwellings, secondly, the allocation in its entirety (Site Ref: 103M-mod) for residential development.

YES, I wish to participate at the oral examination

Representations submitted on behalf of Story Homes deal with both site-specific and District-wide housing issues

I have read the guidance notes

2.7

Yes

No

The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.

g. Cumbria Wildlife Trust have confirmed that the development of this site is feasible, although any development would need to avoid harm to any Meadow Saxifrage which could be located towards the north east corner of the site. Meadow Saxifrage is not a statutory protected species and a number of mitigation measures could be undertaken to ensure no net loss of habitat, including transplanting the species to more suitable locations within the site, the site boundaries and potentially alternative sites. We therefore object to the wording of Policy LA2.7, as we consider it is not justified. We consider the following policy wording would be more appropriate in accordance with national planning policy set out within the NPPF ‘Undertake a detailed ecological survey to determine the presence of Meadow Saxifrage within the NE corner of the site and if required ensure acceptable mitigation measures are undertaken to ensure no significant harm to this habitat’. This would accord with the approach advocated in paragraph 118 of the NPPF. Notwithstanding this, the indicative masterplan submitted in support of this representation confirms that the area in question will be retained as public open space, to safeguard and enhance the ecological habitat;

j. In terms of landscape and visual impact, it is considered that the site benefits from good levels of existing screening through the presence of mature trees bounding the site on 3 sides. Existing trees and hedgerows will be retained as part of any development on the site, which is illustrated in the indicative masterplan submitted in support of this representation. This illustrates that, whilst access to the remainder of Allocation R103M-mod is provided along the site’s southern boundary, due to the existing screening along this southern extent the site could be developed out in its own right. It should also be noted from the indicative masterplan that the proposed density has been kept relatively low, in this case around 24 dwellings per hectare, in order to reflect and respect the existing character, form and layout of housing to the east. This density does, however, accord more fully with the provisions of Core Strategy Policy CS6.6 in terms of achieving an average of 30 dph across all allocated sites than the density currently proposed across this proposed site. Policy LA1.3 of the Land Allocations DPD proposes a yield of 189 dwellings on this site of 10.8 hectares. This equates to a density of first over 17 dwellings per hectare which is significantly below both the aspirational average density of 30 dwellings per hectare and the density proposed by Story Homes of 24 dwellings per hectare. It is proposed, in light of this, that the latter density of 24 dwellings per hectare be applied across the whole of the allocated site in order to contribute, in part, to the shortfall of housing (1891 units) identified by the Garner Report across the plan period through an increase in yield of 264 units and Policy LA1.3 should be amended accordingly. The indicative masterplan also confirms that connectivity via existing footpath networks are to be retained as part of any residential development which allows permeation through from the adjoining residential area and also onto Brigsteer Road. It is clear that residential development on the site, of the form, scale and nature proposed within the indicative masterplan, reflects the setting of both the site and the surrounding area and, in doing so, ensure that the development requirements (to form an overall development brief) outlined in Policy LA2.7 of the Land Allocations DPD is fully addressed.

iii) Achievability
Story Homes can confirm the economic viability of the site taking into consideration all known costs as well as meeting the policy requirements of the SLDC Core Strategy and the Development Brief contained within Policy LA2.7 of the Land Allocations DPD. The site is within the control of Story Homes and extends to approximately 2.1 hectares in area. Following an assessment of the local market and based upon the experience of Story Homes it is considered that the site would deliver approximately 50 units, as proposed within the indicative masterplan, at a density of approximately 24 dwellings per hectare. It would therefore take in the region of 3 - 4 years to deliver which would comprise a year to obtain the necessary planning permission, a year to undertake initial site infrastructure works and construct the development and up to 2 years to sell the 50 units.

Whilst the land under the control of Story Homes could be developed in its own right, the allocation in its entirety, extending to approximately 10.8 hectares, should be earmarked for around 264 dwellings (at a density of 24 dwellings per hectare). Of this, 60 units should be retained within Phase 1, with the balance of 204 proposed within Phase 2 of the Council’s Housing Strategy. In light of this, whether the site under the ownership of Story Homes is developed out on its own or in conjunction with the allocation in its entirety, the 50 units proposed will need to be constructed within Phase 1, particularly in light of the need for a 20% buffer at the front end of the plan period.

YES, I wish to participate at the oral examination

Representations submitted on behalf of Story Homes deal with both site-specific and District-wide housing issues

I have read the guidance notes

LA1.3 Housing Allocations - R103M-mod KENDAL STAINBANK GREEN

Yes

No

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

The DPD is not consistent with national policy.

j. In terms of landscape and visual impact, it is considered that the site benefits from good levels of existing screening through the presence of mature trees bounding the site on 3 sides. Existing trees and hedgerows will be retained as part of any development on the site, which is illustrated in the indicative masterplan submitted in support of this representation. This illustrates that, whilst access to the remainder of Allocation R103M-mod is provided along the site’s southern boundary, due to the existing screening along this southern extent the site could be developed out in its own right. It should also be noted from the indicative masterplan that the proposed density has been kept relatively low, in this case around 24 dwellings per hectare, in order to reflect and respect the existing character, form and layout of housing to the east. This density does, however, accord more fully with the provisions of Core Strategy Policy CS6.6 in terms of achieving an average of 30 dph across all allocated sites than the density currently proposed across this proposed site. Policy LA1.3 of the Land Allocations DPD proposes a yield of 189 dwellings on this site of 10.8 hectares. This equates to a density of first over 17 dwellings per hectare which is significantly below both the aspirational average density of 30 dwellings per hectare and the density proposed by Story Homes of 24 dwellings per hectare. It is proposed, in light of this, that the latter density of 24 dwellings per hectare be applied across the whole of the allocated site in order to contribute, in part, to the shortfall of housing (1891 units) identified by the Garner Report across the plan period through an increase in yield of 264 units and Policy LA1.3 should be amended accordingly. The indicative masterplan also confirms that connectivity via existing footpath networks are to be retained as part of any residential development which allows permeation through from the adjoining residential area and also onto Brigsteer Road. It is clear that residential development on the site, of the form, scale and nature proposed within the indicative masterplan, reflects the setting of both the site and the surrounding area and, in doing so, ensure that the development requirements (to form an overall development brief) outlined in Policy LA2.7 of the Land Allocations DPD is fully addressed.

iii) Achievability
Story Homes can confirm the economic viability of the site taking into consideration all known costs as well as meeting the policy requirements of the SLDC Core Strategy and the Development Brief contained within Policy LA2.7 of the Land Allocations DPD. The site is within the control of Story Homes and extends to approximately 2.1 hectares in area. Following an assessment of the local market and based upon the experience of Story Homes it is considered that the site would deliver approximately 50 units, as proposed within the indicative masterplan, at a density of approximately 24 dwellings per hectare. It would therefore take in the region of 3 - 4 years to deliver which would comprise a year to obtain the necessary planning permission, a year to undertake initial site infrastructure works and construct the development and up to 2 years to sell the 50 units.

Whilst the land under the control of Story Homes could be developed in its own right, the allocation in its entirety, extending to approximately 10.8 hectares, should be earmarked for around 264 dwellings (at a density of 24 dwellings per hectare). Of this, 60 units should be retained within Phase 1, with the balance of 204 proposed within Phase 2 of the Council’s Housing Strategy. In light of this, whether the site under the ownership of Story Homes is developed out on its own or in conjunction with the allocation in its entirety, the 50 units proposed will need to be constructed within Phase 1, particularly in light of the need for a 20% buffer at the front end of the plan period.

Conclusion
Story Homes, in conjunction with the land owners, fully support the allocation of land under their control forming the northern extent of housing allocation R103M/mod for residential development, subject to the increase in density proposed by Story Homes. In doing so, Story Homes have taken full cognisance of paragraph 182 of the NPPF in terms of demonstrating the soundness of this particular allocation. This statement confirms that the site is fully deliverable in the context of paragraph 47 of the NPPF and that the allocation of the site is fully in accordance with the key aims of the NPPF of delivering sustainable development in accordance with SLDC Core Strategy. Story Homes are also in agreement with the Council that development of the site should take place within Phase 1 of the Council Housing Strategy, in accordance with Policy LA1.3 of the Land Allocations DPD. However, it is Story Homes’ view that the density should be increased to around 24 dwellings per hectare, generating a yield of 264 dwellings which will contribute to the housing shortfall of 1891 units identified in the Garner Report. In light of the above it is respectfully requested by Story Homes that the Inspector endorses, in the first instance, the Council’s allocation of the land under control of Story Homes extending southwards from Brigsteer Road at an increased yield across the whole site of 264 dwellings, secondly, the allocation in its entirety (Site Ref: 103M-mod) for residential development.

YES, I wish to participate at the oral examination

Representations submitted on behalf of Story Homes deal with both site-specific and District-wide housing issues

I have read the guidance notes

LA1.3 Housing Allocations - RN109M RN315# SWARTHMOOR OFF CROSS-a-MOOR

Yes

Yes

Land Off Cross a Moor, Swarthmoor (Site Refs: RN315# and RN109M)

Introduction
Story Homes fully supports, in principle, the allocation of land off Cross a Moor, Swarthmoor (Site Refs: RN315# and RN109M) for residential development and has prepared and submitted this representation on behalf of the land owners, Messrs Towers and Hodgson respectively. This statement confirms first, both Story Homes’ and the landowners’ continued support for this residential allocation and, secondly, that the site is fully deliverable. As a consequence, the statement emphasises that the development should be allocated across Phases 1 and 2 of the Land Allocations DPD. In order to inform Story Homes’ support for the allocation an indicative masterplan is attached (Plan Ref: 01-01) to demonstrate the acceptability of development on the site.

Site Description
The site extends to approximately 8.26 hectares in size and it bounds directly the existing western edge of Swarthmoor. The south-eastern boundary to the proposed site is formed by existing residential development and the A590 respectively. The south-western extent is defined by a minor road off the A590 serving existing residential development to the north-west of the site whilst beyond the northern boundary is further grazing land.

Policy Context
The National Planning Policy Framework (NPPF) was published on 27th March 2012. Paragraph 182 of the NPPF requires that a Local Plan has been prepared in accordance with the duty to co-operate, legal and procedural requirements, and whether it is sound. In light of this, the local planning authority are required to submit a plan for examination which it considers to be sound, which requires the plan to be assessed against the following:

• Positively prepared – the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development;

• Justified – the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence;

• Effective – the plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priority;

• Consistent with national policy – the plan should enable the delivery of sustainable development in accordance with the policies in the framework.

1. Positively Prepared – Story Homes considered that South Lakeland’s Housing Strategy, as laid out in their Land Allocations DPD has been positively prepared, following a full appraisal of designated strategic objectives, which were formulated in line with the key aims of sustainable development;

2. Justified - The residential allocation of land at Cross a Moor, Swarthmoor, was made through the evolution and appraisal of almost 1,000 potential site options with the formulation of a sustainability appraisal framework to provide the basis for appraising, analysing and preparing the sustainability effects of all the alternative site options. In light of this Story Homes considers that the proposed allocation is justified in terms of it being an appropriate site for housing considered against the alternatives assessed and on the basis of the Council’s comprehensive evidence base;

In terms of the deliverability of the site, paragraph 47 of the NPPF confirms that the site should be:

i) Available now;

ii) Offer a suitable location for development;

iii) Be achievable with a realistic prospect that housing will be delivered on the site within 5 years and, in particular, that development of the site is viable.

i) Availability
The land is owned by Messrs Towers and Hodgson respectively. They jointly have instructed Story Homes to seek a formal allocation on their land with a view to bringing forward a development scheme as soon as possible. In light of this, it is considered that the site is available now.

ii) Suitability
A detailed Sustainability Appraisal was carried out by South Lakeland District Council (SLDC) to identify Local Service Centres considered suitable to accommodate additional housing, in accordance with Core Strategy Policy CS1.2. This identified Swarthmoor as providing an appropriate level of services and facilities to support some additional residential development. In light of this, a detailed analysis was undertaken by the Council of Swarthmoor in terms of identifying land most suitable for accommodating the residential development required. A total of 20 sites were initially considered with a further 8 sites identified as part of the ongoing consultation exercise. Following detailed assessments of each of these, 2 sites have been included within the Land Allocations DPD, including the land at Cross a Moor. This site is considered by Story Homes, and the Council, to be suitable for the following reasons:

a) There are no restrictive planning policy designations across the site which would preclude development;

b) The site lies within Flood Zone 1 and the EA has confirmed that it has no knowledge of flooding on the site;

c) Swarthmoor scores well against the Council’s full Sustainability Appraisal in terms of the level of services and facilities to support additional development;

d) United Utilities has confirmed that development is feasible and there are no known constraints in relation to drainage;

e) Cumbria Wildlife Trust have advised that development is feasible, although ecology surveys will need to support any planning application on the site;

f) Cumbria County Council Highways Department and the Highways Agency have confirmed within the Council’s ‘Traffic Study to Inform Land Allocations DPD for Ulverston and Swarthmoor’ (February 2012) that development will not adversely impact upon the capacity, operation and safety of the strategic road network. In addition, the site can be accessed either by Cross a Moor Lane, which leads to an existing junction onto the A590, as well as a new access directly into the site with a new junction directly from the A590 subject to approval from the Highways Agency;

g) The landscape and visual impact of the proposed development will be limited. The site is well related to the existing settlement and would offer an opportunity to soften the impact of the western settlement boundary with appropriate structural planting, in accordance with Policy 5.6 of the Land Allocations DPD.

iii) Achievability
Story Homes can confirm the economic viability of the site taking into consideration all known costs, in addition to meeting the policy requirements of the SLDC Core Strategy and also the provisions of Policy 5.6 of the Land Allocations DPD.

iv) Consistent with National Policy
Story Homes consider that, although the Council’s overall phasing of housing is not currently consistent with the NPPF, the allocation of land off Cross a Moor, Swarthmoor (Site Refs: RN315# and RN109M) is fully consistent with national policy. The Sustainability Appraisal carried out by the Council in relation to each proposed housing allocation assessed the allocation against delivering the economic, social and environmental dimensions to sustainable development, as required by paragraph 7 of the NPPF. This proposed allocation will enable, in full, these 3 key aims of sustainable development to be met.

Conclusion
Story Homes, in conjunction with the land owners of Site Refs: RN315# and RN109M, fully support the allocation of land off Cross a Moor, Swarthmoor for residential development. In doing so, Story Homes have taken full cognisance of paragraph 182 of the NPPF in terms of demonstrating the soundness of this particular allocation. In this regard, Story Homes support the submission by Garner Planning Associates, on behalf of the Cumbria House Builders Group, in terms of highlighting both a shortfall in housing numbers proposed by the Council over the plan period and also the need to bring forward the development of housing sites to earlier in the plan period. The shortfall in housing numbers can be addressed, in part, by increasing housing yields on allocated sites with the land at Swarthmoor able to generate a housing yield of around 160-170 dwellings at a density of 20 dwellings per hectare, an increase of 34-44 over the proposed allocation in Housing Allocations DPD Policy LA1.3. Story Homes are also of the view that, due to the persistent record of failure to deliver the annual housing requirement, there should be reference to a 20% buffer early on in the plan period, in accordance with NPPF guidance.

Story Homes, through this representation, also confirm that the site is fully deliverable in the context of paragraph 47 of the NPPF and that the allocation of the site is fully in accordance with the key aims of the NPPF of delivering sustainable development in accordance with SLDC Core Strategy. In light of the above it is respectfully requested by Story Homes that the Inspector, first, endorses the Council’s allocation of land off Cross a Moor, Swarthmoor for residential development and, secondly, includes it for development within Phases 1 and 2 for a housing yield of 160-170 dwellings.

YES, I wish to participate at the oral examination

Representations submitted on behalf of Story Homes deal with both site-specific and District-wide housing issues

I have read the guidance notes

LA1.3 Housing Allocations - RN109M RN315# SWARTHMOOR OFF CROSS-a-MOOR

Yes

No

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

The DPD is not consistent with national policy.

As a consequence, the statement emphasises that the development should be allocated across Phases 1 and 2 of the Land Allocations DPD. In order to inform Story Homes’ support for the allocation an indicative masterplan is attached (Plan Ref: 01-01) to demonstrate the acceptability of development on the site.

Site R684SWM, on land adjacent to Kingsley Avenue, Swarthmoor has been provisionally allocated within Phase 1 of the Land Allocations DPD. However, it is highly unlikely that this site will be delivered in its totality within Phase 1 given the timescales highlighted for developing out and subsequently selling individual units which, in the case of Site R684SWM, would take approximately 3 – 4 years to deliver based upon obtaining the necessary planning permission, delivering initial site infrastructure and then constructing and selling 35 dwellings. In light of this, the predicted shortfall in unit numbers highlighted by the Garner Report, particularly in the early phases, and the 20% buffer required by the NPPF, and on the basis that Story Homes have confirmed that land at Cross a Moor is fully deliverable, it is recommended that the development of the site is brought forward to Phases 1 and 2 in order that it can be delivered in tandem with Site R684SWM at the earliest opportunity, to meet the aims of the Core Strategy.

iv) Consistent with National Policy
Story Homes consider that, although the Council’s overall phasing of housing is not currently consistent with the NPPF, the allocation of land off Cross a Moor, Swarthmoor (Site Refs: RN315# and RN109M) is fully consistent with national policy. The Sustainability Appraisal carried out by the Council in relation to each proposed housing allocation assessed the allocation against delivering the economic, social and environmental dimensions to sustainable development, as required by paragraph 7 of the NPPF. This proposed allocation will enable, in full, these 3 key aims of sustainable development to be met.

Conclusion
Story Homes, in conjunction with the land owners of Site Refs: RN315# and RN109M, fully support the allocation of land off Cross a Moor, Swarthmoor for residential development. In doing so, Story Homes have taken full cognisance of paragraph 182 of the NPPF in terms of demonstrating the soundness of this particular allocation. In this regard, Story Homes support the submission by Garner Planning Associates, on behalf of the Cumbria House Builders Group, in terms of highlighting both a shortfall in housing numbers proposed by the Council over the plan period and also the need to bring forward the development of housing sites to earlier in the plan period. The shortfall in housing numbers can be addressed, in part, by increasing housing yields on allocated sites with the land at Swarthmoor able to generate a housing yield of around 160-170 dwellings at a density of 20 dwellings per hectare, an increase of 34-44 over the proposed allocation in Housing Allocations DPD Policy LA1.3. Story Homes are also of the view that, due to the persistent record of failure to deliver the annual housing requirement, there should be reference to a 20% buffer early on in the plan period, in accordance with NPPF guidance.

Story Homes, through this representation, also confirm that the site is fully deliverable in the context of paragraph 47 of the NPPF and that the allocation of the site is fully in accordance with the key aims of the NPPF of delivering sustainable development in accordance with SLDC Core Strategy. In light of the above it is respectfully requested by Story Homes that the Inspector, first, endorses the Council’s allocation of land off Cross a Moor, Swarthmoor for residential development and, secondly, includes it for development within Phases 1 and 2 for a housing yield of 160-170 dwellings.

support consider that the site is deliverable and DPD is in line with national Policy NPPF

YES, I wish to participate at the oral examination

Representations submitted on behalf of Story Homes deal with both site-specific and District-wide housing issues

I have read the guidance notes

2.18

Yes

No

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

The DPD is not consistent with national policy.

3. Effective – The NPPF requires that the housing strategy outlined in the Land Allocations DPD is fully deliverable over the designated plan period. In this regard, Story Homes agree with the conclusions drawn from the report prepared and submitted by Garner Planning Associates, on behalf of the Cumbria House Builders Group, of which Story Homes are part, that the Land Allocations DPD Housing Strategy is to under provide for housing in the period up to 2017 – 2022, but seek to make up the shortfalls in the last 3 years of the plan period. In so doing, the Authority rely on broad locations being brought forward in the context of plan review and for those sites, and others, to contribute to housing completions at unrealistic development rates. In addition it is evident, with reference to the SLDC Annual Monitoring Reports (AMR) from 2003/2004 onwards, that the Council has persistently under delivered housing, year on year, against their annual requirement. However, there is currently no provision for a 20% buffer (housing moved forward from later in the plan period) to provide a realistic prospect of achieving the planned supply, in accordance with paragraph 47 of the NPPF. Tables confirming this under provision are attached to this representation. In light of this, it is Story Homes’ view that the Land Allocations DPD needs to, first, release sites earlier in the plan period and, secondly, increase housing yields from allocated sites by increasing housing density in order to achieve the average density of 30 dwellings per hectare, as advocated in Core Strategy Policy CS6.6.

In terms of Local Service Centres, of which Swarthmoor is one, Table 5 of the Garner Report also highlights that there is a shortfall of 222 dwellings in Local Service Centres to meet the Core Strategy requirements. In light of this the deliverability of the allocated site on land at Cross a Moor, Swarthmoor is important in terms of delivering the housing requirement for the Local Service Centres, and indeed the District as a whole, in terms of both housing numbers and also their deliverability early in the plan period.

Indeed, Story Homes are of the view that the site can realistically accommodate a higher density than the 16 dwellings per hectare proposed with Land Allocations DPD Policy LA1.3. In this regard, the indicative masterplan submitted with this representation shows that an appropriate density for the site is around 20 dwellings per hectare which would realise a housing yield of approximately 160-170 dwellings. This additional yield would contribute to addressing the shortfall identified by the Garner Report not only across the District (1891 units), but also in the Local Service Centres (245 units). It would also, importantly, contribute to addressing the shortfall of 640 affordable housing units across the District, as identified within the Council’s SHMA (2011), with a recognised total annual affordable need of 170 units for Ulverston and Furness. Based upon the current market conditions a build out and sales period of approximately 7 – 8 years for all 165 units would be necessary. For clarification this would comprise a year to obtain the necessary planning permission, a year to undertake the initial site infrastructure works and commence construction of the dwellings, and a further 5 – 6 years to build and sell the remaining units based upon a predicted sales rate of 30 dwellings per year.

Conclusion
Story Homes, in conjunction with the land owners of Site Refs: RN315# and RN109M, fully support the allocation of land off Cross a Moor, Swarthmoor for residential development. In doing so, Story Homes have taken full cognisance of paragraph 182 of the NPPF in terms of demonstrating the soundness of this particular allocation. In this regard, Story Homes support the submission by Garner Planning Associates, on behalf of the Cumbria House Builders Group, in terms of highlighting both a shortfall in housing numbers proposed by the Council over the plan period and also the need to bring forward the development of housing sites to earlier in the plan period. The shortfall in housing numbers can be addressed, in part, by increasing housing yields on allocated sites with the land at Swarthmoor able to generate a housing yield of around 160-170 dwellings at a density of 20 dwellings per hectare, an increase of 34-44 over the proposed allocation in Housing Allocations DPD Policy LA1.3. Story Homes are also of the view that, due to the persistent record of failure to deliver the annual housing requirement, there should be reference to a 20% buffer early on in the plan period, in accordance with NPPF guidance.

Story Homes, through this representation, also confirm that the site is fully deliverable in the context of paragraph 47 of the NPPF and that the allocation of the site is fully in accordance with the key aims of the NPPF of delivering sustainable development in accordance with SLDC Core Strategy. In light of the above it is respectfully requested by Story Homes that the Inspector, first, endorses the Council’s allocation of land off Cross a Moor, Swarthmoor for residential development and, secondly, includes it for development within Phases 1 and 2 for a housing yield of 160-170 dwellings.

YES, I wish to participate at the oral examination

Representations submitted on behalf of Story Homes deal with both site-specific and District-wide housing issues

LA5.6 Land at Cross-a-Moor, Swarthmoor

Yes

Yes

Story Homes can confirm the economic viability of the site taking into consideration all known costs, in addition to meeting the policy requirements of the SLDC Core Strategy and also the provisions of Policy 5.6 of the Land Allocations DPD

Conclusion
Story Homes, in conjunction with the land owners of Site Refs: RN315# and RN109M, fully support the allocation of land off Cross a Moor, Swarthmoor for residential development. In doing so, Story Homes have taken full cognisance of paragraph 182 of the NPPF in terms of demonstrating the soundness of this particular allocation. In this regard, Story Homes support the submission by Garner Planning Associates, on behalf of the Cumbria House Builders Group, in terms of highlighting both a shortfall in housing numbers proposed by the Council over the plan period and also the need to bring forward the development of housing sites to earlier in the plan period. The shortfall in housing numbers can be addressed, in part, by increasing housing yields on allocated sites with the land at Swarthmoor able to generate a housing yield of around 160-170 dwellings at a density of 20 dwellings per hectare, an increase of 34-44 over the proposed allocation in Housing Allocations DPD Policy LA1.3. Story Homes are also of the view that, due to the persistent record of failure to deliver the annual housing requirement, there should be reference to a 20% buffer early on in the plan period, in accordance with NPPF guidance.

Story Homes, through this representation, also confirm that the site is fully deliverable in the context of paragraph 47 of the NPPF and that the allocation of the site is fully in accordance with the key aims of the NPPF of delivering sustainable development in accordance with SLDC Core Strategy. In light of the above it is respectfully requested by Story Homes that the Inspector, first, endorses the Council’s allocation of land off Cross a Moor, Swarthmoor for residential development and, secondly, includes it for development within Phases 1 and 2 for a housing yield of 160-170 dwellings.

YES, I wish to participate at the oral examination

Representations submitted on behalf of Story Homes deal with both site-specific and District-wide housing issues

I have read the guidance notes

LA1.3 Housing Allocations - RN684 SWM SWARTHMOOR ADJACENT TO KINGSLEY AVENUE

Yes

No

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

The DPD is not consistent with national policy.

Site R684SWM, on land adjacent to Kingsley Avenue, Swarthmoor has been provisionally allocated within Phase 1 of the Land Allocations DPD. However, it is highly unlikely that this site will be delivered in its totality within Phase 1 given the timescales highlighted for developing out and subsequently selling individual units which, in the case of Site R684SWM, would take approximately 3 – 4 years to deliver based upon obtaining the necessary planning permission, delivering initial site infrastructure and then constructing and selling 35 dwellings. In light of this, the predicted shortfall in unit numbers highlighted by the Garner Report, particularly in the early phases, and the 20% buffer required by the NPPF, and on the basis that Story Homes have confirmed that land at Cross a Moor is fully deliverable, it is recommended that the development of the site is brought forward to Phases 1 and 2 in order that it can be delivered in tandem with Site R684SWM at the earliest opportunity, to meet the aims of the Core Strategy.

Conclusion
Story Homes, in conjunction with the land owners of Site Refs: RN315# and RN109M, fully support the allocation of land off Cross a Moor, Swarthmoor for residential development. In doing so, Story Homes have taken full cognisance of paragraph 182 of the NPPF in terms of demonstrating the soundness of this particular allocation. In this regard, Story Homes support the submission by Garner Planning Associates, on behalf of the Cumbria House Builders Group, in terms of highlighting both a shortfall in housing numbers proposed by the Council over the plan period and also the need to bring forward the development of housing sites to earlier in the plan period. The shortfall in housing numbers can be addressed, in part, by increasing housing yields on allocated sites with the land at Swarthmoor able to generate a housing yield of around 160-170 dwellings at a density of 20 dwellings per hectare, an increase of 34-44 over the proposed allocation in Housing Allocations DPD Policy LA1.3. Story Homes are also of the view that, due to the persistent record of failure to deliver the annual housing requirement, there should be reference to a 20% buffer early on in the plan period, in accordance with NPPF guidance.

Story Homes, through this representation, also confirm that the site is fully deliverable in the context of paragraph 47 of the NPPF and that the allocation of the site is fully in accordance with the key aims of the NPPF of delivering sustainable development in accordance with SLDC Core Strategy. In light of the above it is respectfully requested by Story Homes that the Inspector, first, endorses the Council’s allocation of land off Cross a Moor, Swarthmoor for residential development and, secondly, includes it for development within Phases 1 and 2 for a housing yield of 160-170 dwellings.

YES, I wish to participate at the oral examination

Representations submitted on behalf of Story Homes deal with both site-specific and District-wide housing issues