Response from Ms E Baber (Individual)
1. Ms E Baber (Individual) : 17 Apr 2012 11:59:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
0.0 Whole Document
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The DPD has not been prepared in accordance with the Town & County Planning Regulations 2004 (as amended)
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
SLDC used the company arc4 to do their research for them - they in turn came up with the SHMA report.
arc4 website states they use Household surveys & a range of data including 2001 census etc. They also state that they regularly organise focus group discussions with local residents!!!!!
I checked some of their data in their Draft Report & was most surprised to find omissions of important data, local knowledge not being taken into account, basic mathematical errors & incorrect copying of numbers from research documents.
1. HOUSEHOLDS SURVEYED - Table A2 response rates - arc4 states 26%, this figure only represents the percentage of contacted household returns. The true figure of 9.53% has been omitted.
2. RESIDENT NUMBERS - 2001 census = 102,283 - ONS 2009 mid year population estimates = 103,800 (approx 1,520 population growth in 7/8 years) SHMA survey (9.53% grossed)= Table B3 - 107,873 or Table B6 - 107,861. which would mean there has been 4,000+ population growth in 2 years!
Much of the research seems to rely on the 2011 household survey, I think this proves that the base figures are unreliable & therefore UNSOUND.
3. LOCAL KNOWLEDGE - Table B7 Overseas nationals applying to work in SLDC 2005/6 - 2009/10 annual average = 842. This figure cannot possibly be considered as 2005-2008/9 there was a huge influx of overseas nationals to work on the cockle beds when there was a 'glut' of cockles. This can clearly be seen in Table B7 data.
4. MATHEMATICAL ERRORS - Table B3 Tenure & Age Profile - All Residents percentage totals have been incorrectly calculated (basic maths) - Table B8 Economically Active 76.3 + 4.5 does not = 79.8!
Tables B8-B9-B10 Three different Base Figures have been used for the Economically Active a difference of 4000+ between lowest & highest base figures!
5. COPYING DATA - Table B18 Newbuild activity states Source: CLG Housing statistics Table 253. These tables state 1090 completions in 6 years. arc4 states = 1084!
6. MORE INCORRECT STATEMENTS - Table B18 Newbuild activity, arc4 state that over the period 2005/6 to 2009/10 completions have averaged 166 each year - using their figures the average is 176 (another mathematical error) arc4 states that their figure is at odds with local sources, surely someone should have checked these simple mistakes!
The need for housing has been based on arc4 research, on the basis of the above I regard the whole SHMA Document to be UNSOUND. Land Allocations have been based on this document - need I say more!
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
