Local Development Framework Consultation

0.0 Whole Document

No

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

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.

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.

Response to Land Allocations Development Plan Document (DPD) consultation – April 2012

Grange-over-Sands Town Council considers the Land Development Framework in its current form as being unsound, unfair and lacking transparency. This Council questions the need for 6000 new homes in South Lakeland now the Regional Spatial Strategy has been removed by the current Government. We ask that SLDC halts the publication of the LDF, pending implementation of the localism bill and introduction of neighbourhood planning.

Our response must relate to the soundness of the documents and process – as described below.
1. Legal compliance; (process etc.).
2. Soundness.
a. Justified (DPD should be based on a robust and credible evidence base, involving community participation, and with choices based on research and facts. The DPD should show how the policies and proposals help to ensure that the social, environmental, economic and resource use objectives of sustainability will be achieved.)
b. Effective; (DPD should be deliverable; with sound infrastructure planning, no regulatory or planning barriers, flexible, and with committed delivery partners.)
c. Consistent with national policy.
Our comments mainly fall under the soundness heading.
1. Affordable Housing
1.1 Grange Town Council has serious reservations about the evidence base for the conclusions reached by SLDC in its decision to allocate over 500 new houses to the town and almost 800 for the area as a whole.

1.2 In the consultation documents for the allocations SLDC itself identified (5.10) that the lack of affordable housing is the main housing issue for this area, with a particular need for smaller accommodation, social rented, intermediate and local’s only housing. 5.30 of the consultation document states that based on need, 100% of additional dwellings should be affordable. The Grange Fact File states: “The lack of affordable housing is the main issue for the housing market area. There is a particular need for smaller accommodation and a need for social rented and intermediate housing. The average selling prices in Grange (based on ward profile from Cumbria Observatory, derived from CACI) are higher than both the District and Cumbrian average selling prices.”

1.3 There is no identified need for more high-end, high-value private housing or holiday homes within the Grange area.

1.4 However, the DPD includes a target of merely 35% of new dwellings being affordable – based on an assumption that developers will not be interested in a greater percentage. There is no evidence base to show how, or why, this figure has been set as a target – other than that it ‘is in the core strategy’ (non-evidenced in itself). As mentioned by Arnside Parish Council in their response: SLDC has not provided any data to demonstrate that this policy is viable and will succeed in the current economy and in future commercial development markets. Because this is such a critical and fundamental assumption underlying the whole of SLDC’s Land Allocations, and because the future supply of affordable housing appears to depend entirely on it operating effectively, it is essential that robust and “bankable” evidence is provided by SLDC. Without it, the current Land Allocations cannot pass the deliverability test for the supply of local affordable housing and is therefore not sound.

1.5 This means that 65% of the proposed new dwellings are not needed and will merely flood the high end of the market – which is already well provided for. It also means that three times as much land will be needed, impacting upon the feel of the town and the existing views of Morecambe Bay –the town’s most important features...........

1.7 Sites of less than 0.3ha have been excluded from the land allocations – which have meant that only large scale developments have been allocated. However, the number of smaller sites within Grange could actually provide a good proportion of the required housing need – especially if developed by housing associations or similar bodies (as happened at Higher Grange in 2010-11).

1.8 The Core Strategy (p170) states that one of the aims for Grange is to “incorporate moderate new housing development”. We do not consider that an increase of housing provision by the amounts proposed (around 30% of the existing housing stock) can be described as ‘moderate’.

2. Deliverability
2.1 There are also serious doubts about the deliverability of the plan. For example, R110 has been allocated for 66 dwellings (35% of which should be affordable housing). However, the recent proposals on display by a developer in the Victoria Hall (late 2011) only made room for 55 dwellings, and the developers were vague when pressed as to how many of these would be affordable. This shows what developers consider appropriate and would imply that there will be difficulties in delivering the plans. It also raises questions about the strength of the relationships with delivery partners required for the plan to be considered sound.........

The evidence base (transport) provided by SLDC within its documents refers to “significant housing allocations” proposed for Ulverston & Grange, but only identifies transport improvement schemes for Kirkby Lonsdale and Milnthorpe.

There is no evidence of the ‘detailed work looking at balancing local needs and environmental capacities outside the Principal Service Centres’, which the Core Strategy inspector stated should be conducted as part of the Allocations of Land DPD process. The information in the ‘Settlement Fact Files’ is insufficient, and takes no account of the cumulative impact of development on infrastructure............

6. Contradictions and inadequate assessments
6.1 The assessments, in some cases, contradict themselves. Which reflects the lack of justification and credibility of a number of the allocations and the plan as a whole....

7. Key Service Centres
7.1 One of the fundamental flaws is that Grange has been identified as a ‘Key Service Centre’ (KSC) and considered to be alike to the other KSCs.

7.2 However, Grange does not meet some of the important criteria for a KSC – for example; good public transport links to outlying settlements, a secondary school, and so on.

7.2 Grange-over-Sands is not well placed to meet all the criteria for a Key Service Centre (e.g. restrictive and isolated location, topography and sustainability of sites proposed, poor proximity to trunk roads and motorway, no secondary school or Further Education College, increased reliance on car usage).

7.3 A pro rata development for Grange, Milnthorpe and Kirkby Lonsdale is therefore fundamentally flawed, as Grange’s infrastructure (especially the road network and access to services) is less able to cope with additional development than the other two towns.....

8. Summary
8.1 The land allocation process has, in our view, been gone about the wrong way around. We consider that instead of allocating land for development and then looking at the issues the matter should have been addressed the other way around.

The current transport issues, pedestrian facilities, cycling facilities should have been mapped;

Proposed improvements to the above should have been mapped;

Public transport routes should have been mapped – along with potential changes or improvements;

The Environment Agency and United Utilities information on their infrastructure and capacity should have been mapped;

The green gaps should have been expanded and mapped;

Other public open space should have been considered and mapped – even down to fairly small scale;

The importance of existing views should have been considered, and important views mapped and protected.

Only then should the suitable sites for development have been identified. It appears that the opposite has happened – which we consider to be unsustainable and not evidence based – thereby not meeting the requirements of the DPD process.

8.2 The Grange Fact File states “The small dispersed settlement pattern could be sensitive to unsympathetic village expansion. The openness in higher parts and long uninterrupted views to the Lakeland Fells and across Morecambe Bay are sensitive to large scale and infrastructure development.” Yet an excessive level of development is proposed – an increase of 23% in housing units between 2009 and 2025, characterised in the Core Strategy as ‘moderate’. This cannot be justified as being based on robust or credible evidence, and contradicts the very points identified by SLDC as being important and of concern.

8.3 There has been a lack of effective community participation and support. A number of the allocations have been consistently opposed by the local community, for valid reasons – as acknowledged by SLDC. However, there are no attempts within the DPD to overcome this opposition or mitigate the reasons for it. The question of inadequate infrastructure has been raised time and again, and effectively just put to one side and not addressed.

8.4 The sheer scale of development and the acknowledged inadequate existing infrastructure is incompatible. There is no indication as to how the acknowledged infrastructure problems will be solved and funded from the potential development sites in the Allocations of Land documentation. There must be policies in place to deal with these major issues, before land is allocated for development. Otherwise, the result will be piecemeal development putting ever increasing strain on the community environment, with no financial means of alleviating the damage. The inability to improve much of this (highway, cycling and pedestrian links), and the total lack of any proposals within the DPD to improve the infrastructure means that the allocations plan does not show proposals help to ensure that the social, environmental, economic and resource use objectives of sustainability will be achieved. A key and necessary feature required.

8.5 The Local Development Framework is designed to be a local framework for local needs. The current proposals are far wider than this, and do not address the specific local needs and issues for Grange-over-Sands.

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

No

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

No

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

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

The DPD is not consistent with national policy.

1.6 Given that three of the sites allocated (Berners car park, Berners swimming pool, Guides Lot) are all owned by SLDC or Cumbria County Council there is no overriding need to maximise profit – and these sites could all be developed for purely affordable housing if required....

2.2 The Berners areas have been allocated for mixed use, with quite specific developments. However, this appears to be have been predicated on what SLDC’s preferred developer had already put forward proposals for – rather than based on an actual need assessment. This development has now collapsed and SLDC has said (February 2012) that any proposals will again be considered.

This contradicts the DPD before it has even been published – as the DPD will set a type of allocation that the owner and proposed (both SLDC) have effectively dismissed as being 2.2 irrelevant. There is therefore no credible evidence base for this (and some other) allocations.

3. Infrastructure
3.1 Insufficient weight is given to the problem of the inadequate main road system through Grange, which already has to cope with commercial and tourism demands from Flookburgh, Cark, Holker, and Cartmel, in addition to traffic bound for Grange.

3.2 5.32 of the consultation documents (and elsewhere) identifies the problems of town centre congestion. The Core Strategy (CS4) refers to improved cycle and pedestrian provision, and CS10.2 gives the criteria to be considered when assessing the transport impact of new development.

3.3 The Grange Fact File states that “the main B5277 road runs through the heart of Grange over Sands linking it to the A590 trunk road and connecting the town with Barrow and Ulverston and the M6 motorway. In places this road narrows and on some stretches, there is a feeling of car domination.”

3.4 The Core Strategy document (5.12) also identifies that “Access into the peninsula is poor, limited mainly to the B5277/8 looping off the A590 to run through Grange, Allithwaite and Cark, the B6271 from Lindale and minor roads north of Cartmel.” And adds (5.13) that Grange “suffers from problems associated with the impact of the private car on the built environment. For pedestrians, the Grange-over-Sands environment is noticeably poor. In general terms, footpaths are narrow and there is a strong sense that the car is the dominant feature on Kents Bank Road and Main Street. Improving linkages, infrastructure and the quality of the pedestrian environment are key priorities.”

3.5 It has already been acknowledged that the recent planning permission granted for a supermarket at the Bateman’s site will have a detrimental effect on the existing traffic issues – before any further development has begun.

3.6 None of the following aspects raised with SLDC have been addressed:

Given the identified issues with transport, developments to the south of the town will only make existing problems worse. No proposals have been put forward together with the allocations. For example – MN25M (Kent’s Bank) there are no concurrent plans to improve the already overloaded transport network to accommodate such a development, or anything to actually improve the cycling and pedestrian facilities. The topography and gradients mean that it is extremely unlikely that new residents on most of the proposed sites will be able to walk or cycle into the Town Centre, or to the new supermarket.

There is no evidence of how SLDC and its partners will ‘improve the pedestrian experience of Grange Town Centre, as stated in paragraph CS4 of the Core Strategy. Bearing in mind the topography of Grange, it is hard to see how paragraph CS10.1 can be achieved, which states that ‘the Council will work with partners to improve accessibility …….promoting a network of safe cycle and walking routes linking residential areas with employment areas, town and local centres, schools…… The only feasible route from Grange to the secondary school in Cartmel is along Haggs Lane, a steep and narrow road with an unrestricted speed limit and blind corners. It is not possible to create a safe cycling and walking route to the school from Grange. Grange’s topography imposes severe restrictions on the viability of cycle routes from the town centre to either Windermere Road or upper Grange Fell Road. The recent development of 59 apartments at Merlewood included no proposals for safe cycling and pedestrian routes (and none are being delivered), and is therefore likely to add to the traffic congestion in the town centre. And this is indicative of the doubts we have over the sustainable deliverability of the whole plan.

Paragraph CS10.2 of the Core Strategy states that development proposals will be considered against criteria, including whether the expected nature and volume of traffic generated by the proposal could be accommodated by the existing road network without detriment to the amenity and character of the surrounding area. This assessment has not visibly been carried out.

The responses to the consultations raised the issue repeatedly. The reply by DLDC has been formulaic “The Council has liaised with the Local Highways Authority and Highways Agency to identify the likely impacts of new development for the local and strategic road network in terms of highways safety, congestion and access arrangements. Mitigation measures will be a requirement to offset any potential adverse impact.”

In meetings with the Town Council, SLDC have confirmed that there are few viable improvements that can be made to the highway infrastructure, either road based or for cyclists and pedestrians – given the topography and existing town layout. So the replies given to the consultation responses by SLDC are meaningless, as they require mitigation measures that SLDC themselves accept are not possible.

In these same meetings the Town Council have repeatedly asked for the traffic surveys and modelling on which the assumption that the infrastructure will cope have been based. These have been promised, but not delivered. SLDC have recently (7 March 2012) confirmed to the Mayor that such modelling has not actually taken place: “We are not aware of any recent traffic modelling in Grange undertaken by CCC. We have consulted with CCC’s Highways department throughout the process of preparing the Land Allocations DPD. The department has commented on all the sites in Grange that we propose to put forward for allocation and none of their comments express concerns about individual sites. The department has however made the same generic statement for many towns and villages across the LDF area, including Grange, highlighting that significant development may increase traffic and parking pressures.....

3.7 In summary - no infrastructure plans have been devised for Grange-over-Sands or the surrounding area to deal with the proposed level of development. The Highway Authority’s consultation responses have been site specific rather than looking at the impact of the whole proposal – which is far greater.

3.8 The Core Strategy warns (CS5.32) that “Given the problem of town centre congestion in Grange at peak times, it is imperative that improvements are made to reduce dependency on private car use. Significantly higher traffic levels could well threaten the core economic activity of the town, namely tourism.” The combination of the following means that there is an obvious contradiction to the requirement for the DPD to show how the policies and proposals help to ensure that the social, environmental, economic and resource use objectives of sustainability will be achieved:

If housing is increased by 30% in Grange, then immediately local traffic will almost certainly increase by about 30% as well;

Additional traffic will be generated by developments in Allithwaite, Flookburgh, Cartmel, and elsewhere that will all have to pass through Grange;

The new supermarket at Batemans will generate further traffic at an existing congestion point;
No plans have been developed to improve the pedestrian or traffic experience;
There are no stated plans to improve public transport links;
There is an acceptance that the topography and layout of the town means that there are no obvious mitigation measures that can actually be put into place.....

6.3 The Core Strategy (CS4) identifies as key aim for Grange as being to: “Maintain and enhance the strength of tourism across the area”. For modern tourism, it is unfortunately necessary to provide adequate car parking facilities. Grange currently has four main car parks. Under the allocation proposals two of the largest will be unavailable for tourists (Windermere Road is to become a supermarket car park, and Berners is allocated for mixed residential, leisure, and so on). This will restrict the car parking capacity for tourists to Main Street, Hampsfell and Kents Bank car parks – both of which are often already very busy. In addition, it is likely that some on-road parking will be removed as part of any mitigation measures to cope with the additional traffic. This double whammy will reduce the tourism potential, and also reduce the vitality of the town centre as locals will not be able to park either.

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

No

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

No

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

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

The DPD is not consistent with national policy.

1.6 Given that three of the sites allocated (Berners car park, Berners swimming pool, Guides Lot) are all owned by SLDC or Cumbria County Council there is no overriding need to maximise profit – and these sites could all be developed for purely affordable housing if required....

3. Infrastructure
3.1 Insufficient weight is given to the problem of the inadequate main road system through Grange, which already has to cope with commercial and tourism demands from Flookburgh, Cark, Holker, and Cartmel, in addition to traffic bound for Grange.

3.2 5.32 of the consultation documents (and elsewhere) identifies the problems of town centre congestion. The Core Strategy (CS4) refers to improved cycle and pedestrian provision, and CS10.2 gives the criteria to be considered when assessing the transport impact of new development.

3.3 The Grange Fact File states that “the main B5277 road runs through the heart of Grange over Sands linking it to the A590 trunk road and connecting the town with Barrow and Ulverston and the M6 motorway. In places this road narrows and on some stretches, there is a feeling of car domination.”

3.4 The Core Strategy document (5.12) also identifies that “Access into the peninsula is poor, limited mainly to the B5277/8 looping off the A590 to run through Grange, Allithwaite and Cark, the B6271 from Lindale and minor roads north of Cartmel.” And adds (5.13) that Grange “suffers from problems associated with the impact of the private car on the built environment. For pedestrians, the Grange-over-Sands environment is noticeably poor. In general terms, footpaths are narrow and there is a strong sense that the car is the dominant feature on Kents Bank Road and Main Street. Improving linkages, infrastructure and the quality of the pedestrian environment are key priorities.”

3.5 It has already been acknowledged that the recent planning permission granted for a supermarket at the Bateman’s site will have a detrimental effect on the existing traffic issues – before any further development has begun.

3.6 None of the following aspects raised with SLDC have been addressed:

Given the identified issues with transport, developments to the south of the town will only make existing problems worse. No proposals have been put forward together with the allocations. For example – MN25M (Kent’s Bank) there are no concurrent plans to improve the already overloaded transport network to accommodate such a development, or anything to actually improve the cycling and pedestrian facilities. The topography and gradients mean that it is extremely unlikely that new residents on most of the proposed sites will be able to walk or cycle into the Town Centre, or to the new supermarket.

There is no evidence of how SLDC and its partners will ‘improve the pedestrian experience of Grange Town Centre, as stated in paragraph CS4 of the Core Strategy. Bearing in mind the topography of Grange, it is hard to see how paragraph CS10.1 can be achieved, which states that ‘the Council will work with partners to improve accessibility …….promoting a network of safe cycle and walking routes linking residential areas with employment areas, town and local centres, schools…… The only feasible route from Grange to the secondary school in Cartmel is along Haggs Lane, a steep and narrow road with an unrestricted speed limit and blind corners. It is not possible to create a safe cycling and walking route to the school from Grange. Grange’s topography imposes severe restrictions on the viability of cycle routes from the town centre to either Windermere Road or upper Grange Fell Road. The recent development of 59 apartments at Merlewood included no proposals for safe cycling and pedestrian routes (and none are being delivered), and is therefore likely to add to the traffic congestion in the town centre. And this is indicative of the doubts we have over the sustainable deliverability of the whole plan.
Paragraph CS10.2 of the Core Strategy states that development proposals will be considered against criteria, including whether the expected nature and volume of traffic generated by the proposal could be accommodated by the existing road network without detriment to the amenity and character of the surrounding area. This assessment has not visibly been carried out.
The responses to the consultations raised the issue repeatedly. The reply by DLDC has been formulaic “The Council has liaised with the Local Highways Authority and Highways Agency to identify the likely impacts of new development for the local and strategic road network in terms of highways safety, congestion and access arrangements. Mitigation measures will be a requirement to offset any potential adverse impact.”
In meetings with the Town Council, SLDC have confirmed that there are few viable improvements that can be made to the highway infrastructure, either road based or for cyclists and pedestrians – given the topography and existing town layout. So the replies given to the consultation responses by SLDC are meaningless, as they require mitigation measures that SLDC themselves accept are not possible.
In these same meetings the Town Council have repeatedly asked for the traffic surveys and modelling on which the assumption that the infrastructure will cope have been based. These have been promised, but not delivered. SLDC have recently (7 March 2012) confirmed to the Mayor that such modelling has not actually taken place: “We are not aware of any recent traffic modelling in Grange undertaken by CCC. We have consulted with CCC’s Highways department throughout the process of preparing the Land Allocations DPD. The department has commented on all the sites in Grange that we propose to put forward for allocation and none of their comments express concerns about individual sites. The department has however made the same generic statement for many towns and villages across the LDF area, including Grange, highlighting that significant development may increase traffic and parking pressures.”.............

3.7 In summary - no infrastructure plans have been devised for Grange-over-Sands or the surrounding area to deal with the proposed level of development. The Highway Authority’s consultation responses have been site specific rather than looking at the impact of the whole proposal – which is far greater.
3.8 The Core Strategy warns (CS5.32) that “Given the problem of town centre congestion in Grange at peak times, it is imperative that improvements are made to reduce dependency on private car use. Significantly higher traffic levels could well threaten the core economic activity of the town, namely tourism.” The combination of the following means that there is an obvious contradiction to the requirement for the DPD to show how the policies and proposals help to ensure that the social, environmental, economic and resource use objectives of sustainability will be achieved:
If housing is increased by 30% in Grange, then immediately local traffic will almost certainly increase by about 30% as well;
Additional traffic will be generated by developments in Allithwaite, Flookburgh, Cartmel, and elsewhere that will all have to pass through Grange;
The new supermarket at Batemans will generate further traffic at an existing congestion point;
No plans have been developed to improve the pedestrian or traffic experience;
There are no stated plans to improve public transport links;
There is an acceptance that the topography and layout of the town means that there are no obvious mitigation measures that can actually be put into place............

6.3 The Core Strategy (CS4) identifies as key aim for Grange as being to: “Maintain and enhance the strength of tourism across the area”. For modern tourism, it is unfortunately necessary to provide adequate car parking facilities. Grange currently has four main car parks. Under the allocation proposals two of the largest will be unavailable for tourists (Windermere Road is to become a supermarket car park, and Berners is allocated for mixed residential, leisure, and so on). This will restrict the car parking capacity for tourists to Main Street, Hampsfell and Kents Bank car parks – both of which are often already very busy. In addition, it is likely that some on-road parking will be removed as part of any mitigation measures to cope with the additional traffic. This double whammy will reduce the tourism potential, and also reduce the vitality of the town centre as locals will not be able to park either.

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

No

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

No

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

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

The DPD is not consistent with national policy.

1.7 Sites of less than 0.3ha have been excluded from the land allocations – which have meant that only large scale developments have been allocated. However, the number of smaller sites within Grange could actually provide a good proportion of the required housing need – especially if developed by housing associations or similar bodies (as happened at Higher Grange in 2010-11)...........

3. Infrastructure
3.1 Insufficient weight is given to the problem of the inadequate main road system through Grange, which already has to cope with commercial and tourism demands from Flookburgh, Cark, Holker, and Cartmel, in addition to traffic bound for Grange.

3.2 5.32 of the consultation documents (and elsewhere) identifies the problems of town centre congestion. The Core Strategy (CS4) refers to improved cycle and pedestrian provision, and CS10.2 gives the criteria to be considered when assessing the transport impact of new development.

3.3 The Grange Fact File states that “the main B5277 road runs through the heart of Grange over Sands linking it to the A590 trunk road and connecting the town with Barrow and Ulverston and the M6 motorway. In places this road narrows and on some stretches, there is a feeling of car domination.”

3.4 The Core Strategy document (5.12) also identifies that “Access into the peninsula is poor, limited mainly to the B5277/8 looping off the A590 to run through Grange, Allithwaite and Cark, the B6271 from Lindale and minor roads north of Cartmel.” And adds (5.13) that Grange “suffers from problems associated with the impact of the private car on the built environment. For pedestrians, the Grange-over-Sands environment is noticeably poor. In general terms, footpaths are narrow and there is a strong sense that the car is the dominant feature on Kents Bank Road and Main Street. Improving linkages, infrastructure and the quality of the pedestrian environment are key priorities.”

3.5 It has already been acknowledged that the recent planning permission granted for a supermarket at the Bateman’s site will have a detrimental effect on the existing traffic issues – before any further development has begun.

3.6 None of the following aspects raised with SLDC have been addressed:
Given the identified issues with transport, developments to the south of the town will only make existing problems worse. No proposals have been put forward together with the allocations. For example – MN25M (Kent’s Bank) there are no concurrent plans to improve the already overloaded transport network to accommodate such a development, or anything to actually improve the cycling and pedestrian facilities. The topography and gradients mean that it is extremely unlikely that new residents on most of the proposed sites will be able to walk or cycle into the Town Centre, or to the new supermarket.

There is no evidence of how SLDC and its partners will ‘improve the pedestrian experience of Grange Town Centre, as stated in paragraph CS4 of the Core Strategy. Bearing in mind the topography of Grange, it is hard to see how paragraph CS10.1 can be achieved, which states that ‘the Council will work with partners to improve accessibility …….promoting a network of safe cycle and walking routes linking residential areas with employment areas, town and local centres, schools…… The only feasible route from Grange to the secondary school in Cartmel is along Haggs Lane, a steep and narrow road with an unrestricted speed limit and blind corners. It is not possible to create a safe cycling and walking route to the school from Grange. Grange’s topography imposes severe restrictions on the viability of cycle routes from the town centre to either Windermere Road or upper Grange Fell Road. The recent development of 59 apartments at Merlewood included no proposals for safe cycling and pedestrian routes (and none are being delivered), and is therefore likely to add to the traffic congestion in the town centre. And this is indicative of the doubts we have over the sustainable deliverability of the whole plan.
Paragraph CS10.2 of the Core Strategy states that development proposals will be considered against criteria, including whether the expected nature and volume of traffic generated by the proposal could be accommodated by the existing road network without detriment to the amenity and character of the surrounding area. This assessment has not visibly been carried out.
The responses to the consultations raised the issue repeatedly. The reply by DLDC has been formulaic “The Council has liaised with the Local Highways Authority and Highways Agency to identify the likely impacts of new development for the local and strategic road network in terms of highways safety, congestion and access arrangements. Mitigation measures will be a requirement to offset any potential adverse impact.”

In meetings with the Town Council, SLDC have confirmed that there are few viable improvements that can be made to the highway infrastructure, either road based or for cyclists and pedestrians – given the topography and existing town layout. So the replies given to the consultation responses by SLDC are meaningless, as they require mitigation measures that SLDC themselves accept are not possible.
In these same meetings the Town Council have repeatedly asked for the traffic surveys and modelling on which the assumption that the infrastructure will cope have been based. These have been promised, but not delivered. SLDC have recently (7 March 2012) confirmed to the Mayor that such modelling has not actually taken place: “We are not aware of any recent traffic modelling in Grange undertaken by CCC. We have consulted with CCC’s Highways department throughout the process of preparing the Land Allocations DPD. The department has commented on all the sites in Grange that we propose to put forward for allocation and none of their comments express concerns about individual sites. The department has however made the same generic statement for many towns and villages across the LDF area, including Grange, highlighting that significant development may increase traffic and parking pressures.”........

3.7 In summary - no infrastructure plans have been devised for Grange-over-Sands or the surrounding area to deal with the proposed level of development. The Highway Authority’s consultation responses have been site specific rather than looking at the impact of the whole proposal – which is far greater.

3.8 The Core Strategy warns (CS5.32) that “Given the problem of town centre congestion in Grange at peak times, it is imperative that improvements are made to reduce dependency on private car use. Significantly higher traffic levels could well threaten the core economic activity of the town, namely tourism.” The combination of the following means that there is an obvious contradiction to the requirement for the DPD to show how the policies and proposals help to ensure that the social, environmental, economic and resource use objectives of sustainability will be achieved:

If housing is increased by 30% in Grange, then immediately local traffic will almost certainly increase by about 30% as well;
Additional traffic will be generated by developments in Allithwaite, Flookburgh, Cartmel, and elsewhere that will all have to pass through Grange;
The new supermarket at Batemans will generate further traffic at an existing congestion point;
No plans have been developed to improve the pedestrian or traffic experience;
There are no stated plans to improve public transport links;
There is an acceptance that the topography and layout of the town means that there are no obvious mitigation measures that can actually be put into place............





5.5 There is no evidence in the local community to support the proposed number of new houses. The allocation appears to have been made based on the erroneous categorisation of Grange as a key service centre. The target for the three KSCs (Grange, Milnthorpe and Kirkby Lonsdale) is a pro rata split based on current numbers of dwellings. Grange’s poor road infrastructure, the cumulative effect of development across the Cartmel Peninsula on traffic flows in Grange town centre and the distance from Grange to the secondary school in Cartmel make Grange the least able of the three KSCs to cope with development on a sustainable basis.

6.3 The Core Strategy (CS4) identifies as key aim for Grange as being to: “Maintain and enhance the strength of tourism across the area”. For modern tourism, it is unfortunately necessary to provide adequate car parking facilities. Grange currently has four main car parks. Under the allocation proposals two of the largest will be unavailable for tourists (Windermere Road is to become a supermarket car park, and Berners is allocated for mixed residential, leisure, and so on). This will restrict the car parking capacity for tourists to Main Street, Hampsfell and Kents Bank car parks – both of which are often already very busy. In addition, it is likely that some on-road parking will be removed as part of any mitigation measures to cope with the additional traffic. This double whammy will reduce the tourism potential, and also reduce the vitality of the town centre as locals will not be able to park either.

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

No

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

No

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

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

The DPD is not consistent with national policy.

3. Infrastructure
3.1 Insufficient weight is given to the problem of the inadequate main road system through Grange, which already has to cope with commercial and tourism demands from Flookburgh, Cark, Holker, and Cartmel, in addition to traffic bound for Grange.
3.2 5.32 of the consultation documents (and elsewhere) identifies the problems of town centre congestion. The Core Strategy (CS4) refers to improved cycle and pedestrian provision, and CS10.2 gives the criteria to be considered when assessing the transport impact of new development.
3.3 The Grange Fact File states that “the main B5277 road runs through the heart of Grange over Sands linking it to the A590 trunk road and connecting the town with Barrow and Ulverston and the M6 motorway. In places this road narrows and on some stretches, there is a feeling of car domination.”
3.4 The Core Strategy document (5.12) also identifies that “Access into the peninsula is poor, limited mainly to the B5277/8 looping off the A590 to run through Grange, Allithwaite and Cark, the B6271 from Lindale and minor roads north of Cartmel.” And adds (5.13) that Grange “suffers from problems associated with the impact of the private car on the built environment. For pedestrians, the Grange-over-Sands environment is noticeably poor. In general terms, footpaths are narrow and there is a strong sense that the car is the dominant feature on Kents Bank Road and Main Street. Improving linkages, infrastructure and the quality of the pedestrian environment are key priorities.”
3.5 It has already been acknowledged that the recent planning permission granted for a supermarket at the Bateman’s site will have a detrimental effect on the existing traffic issues – before any further development has begun.
3.6 None of the following aspects raised with SLDC have been addressed:
Given the identified issues with transport, developments to the south of the town will only make existing problems worse. No proposals have been put forward together with the allocations. For example – MN25M (Kent’s Bank) there are no concurrent plans to improve the already overloaded transport network to accommodate such a development, or anything to actually improve the cycling and pedestrian facilities. The topography and gradients mean that it is extremely unlikely that new residents on most of the proposed sites will be able to walk or cycle into the Town Centre, or to the new supermarket.

There is no evidence of how SLDC and its partners will ‘improve the pedestrian experience of Grange Town Centre, as stated in paragraph CS4 of the Core Strategy. Bearing in mind the topography of Grange, it is hard to see how paragraph CS10.1 can be achieved, which states that ‘the Council will work with partners to improve accessibility …….promoting a network of safe cycle and walking routes linking residential areas with employment areas, town and local centres, schools…… The only feasible route from Grange to the secondary school in Cartmel is along Haggs Lane, a steep and narrow road with an unrestricted speed limit and blind corners. It is not possible to create a safe cycling and walking route to the school from Grange. Grange’s topography imposes severe restrictions on the viability of cycle routes from the town centre to either Windermere Road or upper Grange Fell Road. The recent development of 59 apartments at Merlewood included no proposals for safe cycling and pedestrian routes (and none are being delivered), and is therefore likely to add to the traffic congestion in the town centre. And this is indicative of the doubts we have over the sustainable deliverability of the whole plan.
Paragraph CS10.2 of the Core Strategy states that development proposals will be considered against criteria, including whether the expected nature and volume of traffic generated by the proposal could be accommodated by the existing road network without detriment to the amenity and character of the surrounding area. This assessment has not visibly been carried out.The responses to the consultations raised the issue repeatedly. The reply by DLDC has been formulaic “The Council has liaised with the Local Highways Authority and Highways Agency to identify the likely impacts of new development for the local and strategic road network in terms of highways safety, congestion and access arrangements. Mitigation measures will be a requirement to offset any potential adverse impact.”
In meetings with the Town Council, SLDC have confirmed that there are few viable improvements that can be made to the highway infrastructure, either road based or for cyclists and pedestrians – given the topography and existing town layout. So the replies given to the consultation responses by SLDC are meaningless, as they require mitigation measures that SLDC themselves accept are not possible.
In these same meetings the Town Council have repeatedly asked for the traffic surveys and modelling on which the assumption that the infrastructure will cope have been based. These have been promised, but not delivered. SLDC have recently (7 March 2012) confirmed to the Mayor that such modelling has not actually taken place: “We are not aware of any recent traffic modelling in Grange undertaken by CCC. We have consulted with CCC’s Highways department throughout the process of preparing the Land Allocations DPD. The department has commented on all the sites in Grange that we propose to put forward for allocation and none of their comments express concerns about individual sites. The department has however made the same generic statement for many towns and villages across the LDF area, including Grange, highlighting that significant development may increase traffic and parking pressures.”..........

3.7 In summary - no infrastructure plans have been devised for Grange-over-Sands or the surrounding area to deal with the proposed level of development. The Highway Authority’s consultation responses have been site specific rather than looking at the impact of the whole proposal – which is far greater.
3.8 The Core Strategy warns (CS5.32) that “Given the problem of town centre congestion in Grange at peak times, it is imperative that improvements are made to reduce dependency on private car use. Significantly higher traffic levels could well threaten the core economic activity of the town, namely tourism.” The combination of the following means that there is an obvious contradiction to the requirement for the DPD to show how the policies and proposals help to ensure that the social, environmental, economic and resource use objectives of sustainability will be achieved:
If housing is increased by 30% in Grange, then immediately local traffic will almost certainly increase by about 30% as well;
Additional traffic will be generated by developments in Allithwaite, Flookburgh, Cartmel, and elsewhere that will all have to pass through Grange;
The new supermarket at Batemans will generate further traffic at an existing congestion point;
No plans have been developed to improve the pedestrian or traffic experience;
There are no stated plans to improve public transport links;
There is an acceptance that the topography and layout of the town means that there are no obvious mitigation measures that can actually be put into place.

4. Green Gaps
4.1 The DPD identifies the importance of maintaining green gaps between settlements, and in particular (4.5) identifies the need to avoid coalescence with the neighbouring settlement of Allithwaite.
4.2 Appendix 5 of the Grange Fact File includes the Green Gap Assessment of the proposed green gap between Grange and Allithwaite and contains the following statements:
Coalescence has already taken place to some degree as Kentsford Road joins Kent’s Bank/Grange to the SE corner of Allithwaite. [NB – it is assumed that this refers to Kirkhead Road, not Kentsford Road]
But the gap (distance between one settlement ending and the other starting) is already quite limited.
The swallowing up of more dispersed parts of Allithwaite could risk the village taking on a feel of being a continuation or ‘suburb’ of Grange.
Inter & Intra-visibility - The edges of both settlements can be seen from within the area proposed as green gap and the edge of the other settlement can be seen from each settlement edge. Although you do still get a sense of leaving each settlement as you enter the area proposed as green gap, due to the intra and inter visibility, this could potentially be lost if development took place on either side of Allithwaite Road.
4.3 The allocation of land MN25M would appear to go against the very things identified as being important – especially when looked at in the light of the proposals in neighbouring Allithwaite, which are not shown on the Grange Maps (RN79). A mere 200 yard gap would be retained.
4.4 This issue has been raised repeatedly by residents, yet the consultation statement merely says that “The proposal at this site incorporates areas of public open space and a green gap is proposed to the west of the site.” The points made by the residents that such a small gap is insufficient, and the views would be irrevocably changed have simply not been addressed or explained away.
4.5 As identified by SLDC in the Fact File - a gap needs to be on both sides of the entrance point to be effective, and MN25M would appear to directly contravene this.
4.6 One further point ignored in the DPD, which weakens its whole credibility, is that Grange and Kents Bank are actually separate settlements when seen from the main road. This will be completely lost, and therefore existing coalescence between these two settlements will be compounded by the allocation of MN25M..............

For MN25M the assessment says:
o the site was identified as forming a gap between Grange-over-Sands and Allithwaite. The site includes an important wildlife area. Cumbria County Council state that the site should only be used if a strategic housing allocation is required in the area. Development of this site in isolation would constitute a very large extension into open countryside that would be very prominent in the landscape and would also result in the merging of Grange and Kent’s Bank with the village of Allithwaite.
o The site is immediately adjacent an area that is subject to a Limestone Pavement Order.
o The site is very undulating and the lay of the land splits the site into several distinct areas as well as consisting of several separate fields – the site is not of consistent character throughout. This site does strongly reflect the open farmland and pavements landscape character typology of this area.
o The site has high biodiversity value; in particular as a result of its close proximity to Greaves Wood Limestone Pavement and the fact that it includes a small but important copse as well as many hedgerows.
The assessment concludes “Taking into account the overall site assessment, it is proposed to allocate a significant part of this site for development as part of site MN25M.”
But there is no detailed assessment of why the special features of the site are deemed to be less important than the proposed housing and mixed use development. Nor how the decision to allocate the land has actually been reached – that is, it appears to have been allocated because it is open space that the owner wishes to develop, rather than because it is actually the best site in terms of infrastructure and so on.

6.3 The Core Strategy (CS4) identifies as key aim for Grange as being to: “Maintain and enhance the strength of tourism across the area”. For modern tourism, it is unfortunately necessary to provide adequate car parking facilities. Grange currently has four main car parks. Under the allocation proposals two of the largest will be unavailable for tourists (Windermere Road is to become a supermarket car park, and Berners is allocated for mixed residential, leisure, and so on). This will restrict the car parking capacity for tourists to Main Street, Hampsfell and Kents Bank car parks – both of which are often already very busy. In addition, it is likely that some on-road parking will be removed as part of any mitigation measures to cope with the additional traffic. This double whammy will reduce the tourism potential, and also reduce the vitality of the town centre as locals will not be able to park either.

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

No

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

No

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

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

The DPD is not consistent with national policy.

2. Deliverability
2.1 There are also serious doubts about the deliverability of the plan. For example, R110 has been allocated for 66 dwellings (35% of which should be affordable housing). However, the recent proposals on display by a developer in the Victoria Hall (late 2011) only made room for 55 dwellings, and the developers were vague when pressed as to how many of these would be affordable. This shows what developers consider appropriate and would imply that there will be difficulties in delivering the plans. It also raises questions about the strength of the relationships with delivery partners required for the plan to be considered sound......

6. Contradictions and inadequate assessments
6.1 The assessments, in some cases, contradict themselves. Which reflects the lack of justification and credibility of a number of the allocations and the plan as a whole.

6.2 For instance, one of the key features identified for Grange is the open views across Morecambe Bay, along with the general character of the settlement.
? For allocation R110 the assessment states “ It is part of a wider area designated as an Important Open Space in the Local Plan.... provide[s] one of few views from the road out over the Bay.”
o This will be lost under the proposed allocations – yet there is no explanation within the documentation as to why this loss is considered not to impact upon the amenity of the town.

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

No

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

No

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

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

The DPD is not consistent with national policy.

4.2 Appendix 5 of the Grange Fact File includes the Green Gap Assessment of the proposed green gap between Grange and Allithwaite and contains the following statements:

Coalescence has already taken place to some degree as Kentsford Road joins Kent’s Bank/Grange to the SE corner of Allithwaite. [NB – it is assumed that this refers to Kirkhead Road, not Kentsford Road]
But the gap (distance between one settlement ending and the other starting) is already quite limited.
The swallowing up of more dispersed parts of Allithwaite could risk the village taking on a feel of being a continuation or ‘suburb’ of Grange.
Inter & Intra-visibility - The edges of both settlements can be seen from within the area proposed as green gap and the edge of the other settlement can be seen from each settlement edge. Although you do still get a sense of leaving each settlement as you enter the area proposed as green gap, due to the intra and inter visibility, this could potentially be lost if development took place on either side of Allithwaite Road.

4.3 The allocation of land MN25M would appear to go against the very things identified as being important – especially when looked at in the light of the proposals in neighbouring Allithwaite, which are not shown on the Grange Maps (RN79). A mere 200 yard gap would be retained.

4.4 This issue has been raised repeatedly by residents, yet the consultation statement merely says that “The proposal at this site incorporates areas of public open space and a green gap is proposed to the west of the site.” The points made by the residents that such a small gap is insufficient, and the views would be irrevocably changed have simply not been addressed or explained away.

4.5 As identified by SLDC in the Fact File - a gap needs to be on both sides of the entrance point to be effective, and MN25M would appear to directly contravene this.

4.6 One further point ignored in the DPD, which weakens its whole credibility, is that Grange and Kents Bank are actually separate settlements when seen from the main road. This will be completely lost, and therefore existing coalescence between these two settlements will be compounded by the allocation of MN25M.

1.9

No

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

No

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

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

The DPD is not consistent with national policy.

5. Community Participation and Community Support
5.1 Although there have been a number of consultations, they have been, in the main, confusing and overwhelming. More importantly, the responses to the consultations have not really been taken into account.

5.2 For instance; with regard to Grange Town Council, we have raised numerous questions over the years, mainly about the underlying assumptions, evidence and reasoning (rather than individual sites) – few of which have been satisfactorily answered. GTC has submitted a number of detailed submissions since the beginning of the LDF consultation process that commenced in 2008. There is no evidence that any of the substantive points have been taken into consideration in the various documents that have emerged subsequently. No real responses have been received from SLDC regarding the serious issues raised.

5.3 Indicative of this is the consultation statement included as part of the DPD which says:
Few people supported any of the suggested housing site options, although several sites did receive some support, in particular the sites involved in the Berners proposals.
Many comments expressed concerns about the overall amount of development proposed for Grange, in light of infrastructure constraints (highways infrastructure in particular), the services, facilities and jobs available in Grange, the area’s popularity as a tourism destination and the wider environmental capacity of the area to sustainably accommodate additional development on this scale, including with regards to wildlife, settlement character and surface water flood risk.
Many people questioned the need for any additional development in Grange other than for affordable housing. The Parish Council reiterated many of the concerns raised by residents.

A number of people supported the concept of retaining a green gap between Grange and Allithwaite, though most suggested that the area proposed as green gap was not extensive enough.

5.4 These points have simply not been addressed within the DPD. Referring back to the green gap between Allithwaite and Grange – the consultation responses were that the proposed gap was not extensive enough. Yet, the gap has not been increased to take account of residents’ concerns.

5.5 There is no evidence in the local community to support the proposed number of new houses. The allocation appears to have been made based on the erroneous categorisation of Grange as a key service centre. The target for the three KSCs (Grange, Milnthorpe and Kirkby Lonsdale) is a pro rata split based on current numbers of dwellings. Grange’s poor road infrastructure, the cumulative effect of development across the Cartmel Peninsula on traffic flows in Grange town centre and the distance from Grange to the secondary school in Cartmel make Grange the least able of the three KSCs to cope with development on a sustainable basis.

5.6 This lack of flexibility indicates that the DPD does not have the support of the community and has not fully taken account of the community participation events – thus not meeting the requirements.

5.7 It is also a concern that many of the comments from experts such as the Wildlife Trusts have merely been ‘noted’ (consultation statements) without an actual substantive response as to why their advice has been effectively overridden.

1.10

No

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

No

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

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

The DPD is not consistent with national policy.

5. Community Participation and Community Support
5.1 Although there have been a number of consultations, they have been, in the main, confusing and overwhelming. More importantly, the responses to the consultations have not really been taken into account.

5.2 For instance; with regard to Grange Town Council, we have raised numerous questions over the years, mainly about the underlying assumptions, evidence and reasoning (rather than individual sites) – few of which have been satisfactorily answered. GTC has submitted a number of detailed submissions since the beginning of the LDF consultation process that commenced in 2008. There is no evidence that any of the substantive points have been taken into consideration in the various documents that have emerged subsequently. No real responses have been received from SLDC regarding the serious issues raised.

5.3 Indicative of this is the consultation statement included as part of the DPD which says:
Few people supported any of the suggested housing site options, although several sites did receive some support, in particular the sites involved in the Berners proposals.
Many comments expressed concerns about the overall amount of development proposed for Grange, in light of infrastructure constraints (highways infrastructure in particular), the services, facilities and jobs available in Grange, the area’s popularity as a tourism destination and the wider environmental capacity of the area to sustainably accommodate additional development on this scale, including with regards to wildlife, settlement character and surface water flood risk.
Many people questioned the need for any additional development in Grange other than for affordable housing. The Parish Council reiterated many of the concerns raised by residents.

A number of people supported the concept of retaining a green gap between Grange and Allithwaite, though most suggested that the area proposed as green gap was not extensive enough.

5.4 These points have simply not been addressed within the DPD. Referring back to the green gap between Allithwaite and Grange – the consultation responses were that the proposed gap was not extensive enough. Yet, the gap has not been increased to take account of residents’ concerns.

5.5 There is no evidence in the local community to support the proposed number of new houses. The allocation appears to have been made based on the erroneous categorisation of Grange as a key service centre. The target for the three KSCs (Grange, Milnthorpe and Kirkby Lonsdale) is a pro rata split based on current numbers of dwellings. Grange’s poor road infrastructure, the cumulative effect of development across the Cartmel Peninsula on traffic flows in Grange town centre and the distance from Grange to the secondary school in Cartmel make Grange the least able of the three KSCs to cope with development on a sustainable basis.

5.6 This lack of flexibility indicates that the DPD does not have the support of the community and has not fully taken account of the community participation events – thus not meeting the requirements.

5.7 It is also a concern that many of the comments from experts such as the Wildlife Trusts have merely been ‘noted’ (consultation statements) without an actual substantive response as to why their advice has been effectively overridden.