I have read the guidance notes

LA1.3 Housing Allocations - RN131M,RN141#, RN321# &RN284# Ulverston - Gascow Farm

Yes

Representations on the Land Allocations DPD Submission Edition March 2012

I am writing on behalf of our clients, the owners of Gascow Farm, to register support for the soundness of the Land Allocations DPD Submission Edition with regard to the approach to housing delivery.

Further to this I would like to take the opportunity to reiterate the merits of allocating Croftlands East (Site Reference: R697 and Part R242) and Gascow Farm (Site Reference: RN131M, RN141#, RN321#, RN284#) under Policy LA1.3.

Soundness of the Land Allocations DPD

The Land Allocations DPD has been prepared within context of the adopted Core Strategy DPD (October 2010). The Core Strategy DPD provides the framework for the quantum and spatial distribution of housing to be delivered up to 2025. This framework was derived through the assessment of a number of factors, including the sustainability credentials of settlements, analysis of demographic and socio – economic data to identify current and future housing demand (i.e. SHMA) and the identification of potential housing land supply (i.e. SHLAA). The preliminary stages of the preparation of the Land Allocations DPD were undertaken alongside the emergence of these assessments and earlier drafts of the Core Strategy DPD. In the intervening period since the adoption of the Core Strategy DPD updated assessments have served to verify the evidence base that underpins the rationale behind the policies within the Land Allocations DPD. Throughout the preparation of both the Core Strategy DPD and the Land Allocations DPD an extensive programme of consultation with key stakeholders, including the public and statutory bodies (i.e. Environment Agency, Cumbria County Council, Highways Agency and the utilities infrastructure providers), has enabled the identification and consideration of issues relevant to the strategic and site – specific allocations of land.

This comprehensive and methodical approach, undertaken in accordance with the legal requirements of the Planning and Compulsory Purchase Act 2004, has ensured that the allocations and policies contained within the Land Allocations DPD are justified and deliverable; they are underpinned by a robust and up – to – date evidence base, informed by the outcomes of consultation, and in alignment with the strategic objectives of the Core Strategy DPD and national planning guidance.

With particular regard to the implementation of the policies, the requirement for major, complex or sensitive sites to be brought forward within the context of Development Briefs will provide the Local Planning Authority with a mechanism to secure forms of development that are responsive to site specific factors and that deliver benefits specific to the needs of the local communities. Furthermore, the Development Briefs will provide a degree of stimulus and confidence to developers, as the detailed planning guidance framework against which planning applications will be assessed will be clear at the outset.

Merits of allocating Croftlands East and Gascow Farm

The Core Strategy DPD designates 20% of the housing requirement for the District to Ulverston on the basis of its function as a Principal Service Centre. The importance of securing this housing growth to the long – term economic future of the town has recently been re – affirmed by the announcement that GlaxoSmithKline (one of the area’s largest employers) are to invest £350m in a new biopharmaceutical manufacturing facility, creating up to 500 permanent jobs. An additional £350m of investment in the future is also being considered.

The SHLAA demonstrates that the availability of brownfield land within the settlement to accommodate housing growth is limited. The consideration of greenfield sites adjoining the settlement boundary has therefore been necessary. However, the availability of such land is also restricted due to the high quality of the landscape to the north (Hoad Hill and the Sir John Barrow Monument), the extent of the flood risk area to the east and the need to avoid coalescence between Ulverston and Swarthmoor to the west. The only feasible option for meeting the Core Strategy DPD housing requirement is to concentrate growth to the south.

Consequently, Policy LA1.3 of the Land Allocations DPD includes three allocations which encompass land along the length of the southern boundary; Croftlands East (Site Reference: R697 and Part R242), Gascow Farm (Site Reference: RN131M, RN141#, RN321#, RN284#) and Croftlands West – Nook Farm (Site Reference: R690ULV, R69ULV, R126M, RN184, RN234# and Part R242). Our client holds an interest in Croftlands East and Gascow Farm.

I have three observations relating to these allocations in Policy LA1.3 which need further consideration:

1) There is an inconsistency with Policy 5.2 that needs to be clarified. Whilst Policy LA1.3 includes three allocations, Policy 5.2 and its accompanying text refers only to two. This is due to the two allocations Croftlands East and Gascow Farm being referenced as one under ‘Croftlands East – Gascow Farm’. As recognised in Policy 5.2, Croftlands East and Gascow Farm are intrinsically linked and it is logical that they should be considered as a whole and brought forward under a single Development Brief. This is necessary to ensure that the phasing of development is responsive to the site specific physical characteristics (detailed below) which need to be addressed through a co – ordinated approach. Policy LA1.3 needs to be amended to be consistent with Policy 5.2.

2) Policy LA1.3 designates the delivery of 219 units at Croftlands East over the three year period of 2022 – 2025. This translates into a rate of 73 units a year which is likely to be unachievable and housing delivery would therefore extend beyond the plan period. Further to the above observation, the 219 units should be distributed across all three phases for Croftlands East – Gascow Farm as a whole.

3) From Map 2.2 – Ulverston South accompanying the Land Allocations DPD, it has been ascertained that the boundary of the allocation for Croftlands West – Nook Farm extends beyond Mountbarrow Road into land under the ownership of our client. Although this does not prejudice the delivery of this area of land it would be more consistent for the boundary to be pulled back to Mountbarrow Road as the delivery of our clients land is most likely to occur independently of the adjoining owners.

The suitability of the allocation for residential use has been considered at length by the Local Planning Authority throughout the analysis of evidence base materials (i.e. SHLAA), the preparation of early drafts of the Land Allocations DPD and consultation with key stakeholders (including the public). In summary, the allocation represents a settlement extension that would share a relationship with existing residential areas, lie within close proximity of direct linkages to the town centre and deliver benefits such as a mix of family housing types (including affordable housing), public open space connected to the wider area through green routes, improvements to pedestrian / cycle / public transport facilities and contributions to community infrastructure.

In bringing the allocations forward there are site specific physical characteristics that need to be considered. The Land Allocations DPD clearly sets out that the future Development Brief will provide relevant guidance. Evidence base documents underpinning the Land Allocations DPD and dialogue with specialist consultants initiated by our client have determined that the physical characteristics will not prevent the delivery of the allocations. Further detailed surveys will be commissioned in the future and our client would be willing to share this information with the Local Planning Authority to assist in the preparation of the Development Brief. The main issues and our observations are outlined below:

Highways

The traffic study prepared by KR Synergy (February 2012) on behalf of the Local Planning Authority concludes that access can be achieved to the east via that which currently serves Gascow Farm (subject to highway improvement works) and to the west via Mountbarrow Road. Good visibility can be achieved onto each of these roads and both have the ability to accommodate the potential levels of traffic that would be generated. Therefore there are no barriers associated with highways and access to the site. Opportunities to provide pedestrian and cycle linkages through to Parkhead Road and Birchwood Drive would be explored in order to integrate the development into the adjoining neighbourhood, as would the options for improving public transport linkages to the town centre.

Ecology and Landscape

The landscape mitigation advice prepared by Woolerton Dodwell (December 2011) on behalf of the Local Planning Authority outlines a broad framework of landscape measures sensitive to local character that would help mitigate the potential landscape and visual impacts of the development of the allocations.

The structural landscape framework accompanying any development proposal would incorporate features such as trees, hedgerows and ponds and replacement / additional new planting as well as any required ecological mitigation measures. The framework would also incorporate provisions to enhance the interface with the adjacent caravan park. It is recognised that the area of land sterilised by the aqueduct running through the site represents a unique opportunity to provide incidental amenity space, landscape planting and green movement routes. These will complement an element of strategic open space at the core of the development, thus forming a green infrastructure network that will enhance amenity and leisure opportunities for use by the local community.

Surface Water / Foul Drainage

As demonstrated in the South Lakeland Strategic Flood Risk Assessment prepared by Jacobs (2007) on behalf of the Local Planning Authority the site lies in Flood Risk Zone 1 and has a very low likelihood of flooding. The issues regarding land drainage are acknowledged and advice has been received that a strategy for surface water management is achievable without prejudicing the development of the land, nor that to the west, or the adjoining neighbourhood. The development could readily connect into the foul sewage infrastructure located within Priory Road.

Summary

In terms of availability and deliverability, our client is free and willing to release the land. Expressions of interest have already been received from a number of developers, in particular Story Homes, who have been involved in assessing achievability and deliverability (please refer to their previous representations which affirm their views that the allocations are suitable for housing, economically viable and deliverable within the plan period). Although the allocations could be brought forward in isolation it is recognised that there is a direct relationship with the ‘Croftlands West – Nook Farm’ allocation. The development of the three allocations could occur simultaneously without prejudice to each other but there are merits of a co – ordinated approach that would benefit both landowners and the local community. As such, contact has been made with the agents acting on behalf of those holding the relevant land interests in order to establish the foundation for potential future working relationships.

I trust that the above will be given due consideration in the examination of the Land Allocations DPD. Should you have queries with regard to any comments or wish to discuss the merits of the allocation in any further detail please do not hesitate to contact me.

NO, I do not wish to participate at the oral examination

Please notify me

I have read the guidance notes

LA1.3 Housing Allocations - R697 & part R242 ULVERSTON CROFTLANDS EAST

Yes

Representations on the Land Allocations DPD Submission Edition March 2012

I am writing on behalf of our clients, the owners of Gascow Farm, to register support for the soundness of the Land Allocations DPD Submission Edition with regard to the approach to housing delivery.

Further to this I would like to take the opportunity to reiterate the merits of allocating Croftlands East (Site Reference: R697 and Part R242) and Gascow Farm (Site Reference: RN131M, RN141#, RN321#, RN284#) under Policy LA1.3.

Soundness of the Land Allocations DPD

The Land Allocations DPD has been prepared within context of the adopted Core Strategy DPD (October 2010). The Core Strategy DPD provides the framework for the quantum and spatial distribution of housing to be delivered up to 2025. This framework was derived through the assessment of a number of factors, including the sustainability credentials of settlements, analysis of demographic and socio – economic data to identify current and future housing demand (i.e. SHMA) and the identification of potential housing land supply (i.e. SHLAA). The preliminary stages of the preparation of the Land Allocations DPD were undertaken alongside the emergence of these assessments and earlier drafts of the Core Strategy DPD. In the intervening period since the adoption of the Core Strategy DPD updated assessments have served to verify the evidence base that underpins the rationale behind the policies within the Land Allocations DPD. Throughout the preparation of both the Core Strategy DPD and the Land Allocations DPD an extensive programme of consultation with key stakeholders, including the public and statutory bodies (i.e. Environment Agency, Cumbria County Council, Highways Agency and the utilities infrastructure providers), has enabled the identification and consideration of issues relevant to the strategic and site – specific allocations of land.

This comprehensive and methodical approach, undertaken in accordance with the legal requirements of the Planning and Compulsory Purchase Act 2004, has ensured that the allocations and policies contained within the Land Allocations DPD are justified and deliverable; they are underpinned by a robust and up – to – date evidence base, informed by the outcomes of consultation, and in alignment with the strategic objectives of the Core Strategy DPD and national planning guidance.

With particular regard to the implementation of the policies, the requirement for major, complex or sensitive sites to be brought forward within the context of Development Briefs will provide the Local Planning Authority with a mechanism to secure forms of development that are responsive to site specific factors and that deliver benefits specific to the needs of the local communities. Furthermore, the Development Briefs will provide a degree of stimulus and confidence to developers, as the detailed planning guidance framework against which planning applications will be assessed will be clear at the outset.

Merits of allocating Croftlands East and Gascow Farm

The Core Strategy DPD designates 20% of the housing requirement for the District to Ulverston on the basis of its function as a Principal Service Centre. The importance of securing this housing growth to the long – term economic future of the town has recently been re – affirmed by the announcement that GlaxoSmithKline (one of the area’s largest employers) are to invest £350m in a new biopharmaceutical manufacturing facility, creating up to 500 permanent jobs. An additional £350m of investment in the future is also being considered.

The SHLAA demonstrates that the availability of brownfield land within the settlement to accommodate housing growth is limited. The consideration of greenfield sites adjoining the settlement boundary has therefore been necessary. However, the availability of such land is also restricted due to the high quality of the landscape to the north (Hoad Hill and the Sir John Barrow Monument), the extent of the flood risk area to the east and the need to avoid coalescence between Ulverston and Swarthmoor to the west. The only feasible option for meeting the Core Strategy DPD housing requirement is to concentrate growth to the south.

Consequently, Policy LA1.3 of the Land Allocations DPD includes three allocations which encompass land along the length of the southern boundary; Croftlands East (Site Reference: R697 and Part R242), Gascow Farm (Site Reference: RN131M, RN141#, RN321#, RN284#) and Croftlands West – Nook Farm (Site Reference: R690ULV, R69ULV, R126M, RN184, RN234# and Part R242). Our client holds an interest in Croftlands East and Gascow Farm.

I have three observations relating to these allocations in Policy LA1.3 which need further consideration:

1) There is an inconsistency with Policy 5.2 that needs to be clarified. Whilst Policy LA1.3 includes three allocations, Policy 5.2 and its accompanying text refers only to two. This is due to the two allocations Croftlands East and Gascow Farm being referenced as one under ‘Croftlands East – Gascow Farm’. As recognised in Policy 5.2, Croftlands East and Gascow Farm are intrinsically linked and it is logical that they should be considered as a whole and brought forward under a single Development Brief. This is necessary to ensure that the phasing of development is responsive to the site specific physical characteristics (detailed below) which need to be addressed through a co – ordinated approach. Policy LA1.3 needs to be amended to be consistent with Policy 5.2.

2) Policy LA1.3 designates the delivery of 219 units at Croftlands East over the three year period of 2022 – 2025. This translates into a rate of 73 units a year which is likely to be unachievable and housing delivery would therefore extend beyond the plan period. Further to the above observation, the 219 units should be distributed across all three phases for Croftlands East – Gascow Farm as a whole.

3) From Map 2.2 – Ulverston South accompanying the Land Allocations DPD, it has been ascertained that the boundary of the allocation for Croftlands West – Nook Farm extends beyond Mountbarrow Road into land under the ownership of our client. Although this does not prejudice the delivery of this area of land it would be more consistent for the boundary to be pulled back to Mountbarrow Road as the delivery of our clients land is most likely to occur independently of the adjoining owners.

The suitability of the allocation for residential use has been considered at length by the Local Planning Authority throughout the analysis of evidence base materials (i.e. SHLAA), the preparation of early drafts of the Land Allocations DPD and consultation with key stakeholders (including the public). In summary, the allocation represents a settlement extension that would share a relationship with existing residential areas, lie within close proximity of direct linkages to the town centre and deliver benefits such as a mix of family housing types (including affordable housing), public open space connected to the wider area through green routes, improvements to pedestrian / cycle / public transport facilities and contributions to community infrastructure.

In bringing the allocations forward there are site specific physical characteristics that need to be considered. The Land Allocations DPD clearly sets out that the future Development Brief will provide relevant guidance. Evidence base documents underpinning the Land Allocations DPD and dialogue with specialist consultants initiated by our client have determined that the physical characteristics will not prevent the delivery of the allocations. Further detailed surveys will be commissioned in the future and our client would be willing to share this information with the Local Planning Authority to assist in the preparation of the Development Brief. The main issues and our observations are outlined below:

Highways

The traffic study prepared by KR Synergy (February 2012) on behalf of the Local Planning Authority concludes that access can be achieved to the east via that which currently serves Gascow Farm (subject to highway improvement works) and to the west via Mountbarrow Road. Good visibility can be achieved onto each of these roads and both have the ability to accommodate the potential levels of traffic that would be generated. Therefore there are no barriers associated with highways and access to the site. Opportunities to provide pedestrian and cycle linkages through to Parkhead Road and Birchwood Drive would be explored in order to integrate the development into the adjoining neighbourhood, as would the options for improving public transport linkages to the town centre.

Ecology and Landscape

The landscape mitigation advice prepared by Woolerton Dodwell (December 2011) on behalf of the Local Planning Authority outlines a broad framework of landscape measures sensitive to local character that would help mitigate the potential landscape and visual impacts of the development of the allocations.

The structural landscape framework accompanying any development proposal would incorporate features such as trees, hedgerows and ponds and replacement / additional new planting as well as any required ecological mitigation measures. The framework would also incorporate provisions to enhance the interface with the adjacent caravan park. It is recognised that the area of land sterilised by the aqueduct running through the site represents a unique opportunity to provide incidental amenity space, landscape planting and green movement routes. These will complement an element of strategic open space at the core of the development, thus forming a green infrastructure network that will enhance amenity and leisure opportunities for use by the local community.

Surface Water / Foul Drainage

As demonstrated in the South Lakeland Strategic Flood Risk Assessment prepared by Jacobs (2007) on behalf of the Local Planning Authority the site lies in Flood Risk Zone 1 and has a very low likelihood of flooding. The issues regarding land drainage are acknowledged and advice has been received that a strategy for surface water management is achievable without prejudicing the development of the land, nor that to the west, or the adjoining neighbourhood. The development could readily connect into the foul sewage infrastructure located within Priory Road.

Summary

In terms of availability and deliverability, our client is free and willing to release the land. Expressions of interest have already been received from a number of developers, in particular Story Homes, who have been involved in assessing achievability and deliverability (please refer to their previous representations which affirm their views that the allocations are suitable for housing, economically viable and deliverable within the plan period). Although the allocations could be brought forward in isolation it is recognised that there is a direct relationship with the ‘Croftlands West – Nook Farm’ allocation. The development of the three allocations could occur simultaneously without prejudice to each other but there are merits of a co – ordinated approach that would benefit both landowners and the local community. As such, contact has been made with the agents acting on behalf of those holding the relevant land interests in order to establish the foundation for potential future working relationships.

I trust that the above will be given due consideration in the examination of the Land Allocations DPD. Should you have queries with regard to any comments or wish to discuss the merits of the allocation in any further detail please do not hesitate to contact me.

NO, I do not wish to participate at the oral examination

Please notify me

I have read the guidance notes

LA5.2 Land at Croftlands

Yes

Representations on the Land Allocations DPD Submission Edition March 2012

I am writing on behalf of our clients, the owners of Gascow Farm, to register support for the soundness of the Land Allocations DPD Submission Edition with regard to the approach to housing delivery.

Further to this I would like to take the opportunity to reiterate the merits of allocating Croftlands East (Site Reference: R697 and Part R242) and Gascow Farm (Site Reference: RN131M, RN141#, RN321#, RN284#) under Policy LA1.3.

Soundness of the Land Allocations DPD

The Land Allocations DPD has been prepared within context of the adopted Core Strategy DPD (October 2010). The Core Strategy DPD provides the framework for the quantum and spatial distribution of housing to be delivered up to 2025. This framework was derived through the assessment of a number of factors, including the sustainability credentials of settlements, analysis of demographic and socio – economic data to identify current and future housing demand (i.e. SHMA) and the identification of potential housing land supply (i.e. SHLAA). The preliminary stages of the preparation of the Land Allocations DPD were undertaken alongside the emergence of these assessments and earlier drafts of the Core Strategy DPD. In the intervening period since the adoption of the Core Strategy DPD updated assessments have served to verify the evidence base that underpins the rationale behind the policies within the Land Allocations DPD. Throughout the preparation of both the Core Strategy DPD and the Land Allocations DPD an extensive programme of consultation with key stakeholders, including the public and statutory bodies (i.e. Environment Agency, Cumbria County Council, Highways Agency and the utilities infrastructure providers), has enabled the identification and consideration of issues relevant to the strategic and site – specific allocations of land.

This comprehensive and methodical approach, undertaken in accordance with the legal requirements of the Planning and Compulsory Purchase Act 2004, has ensured that the allocations and policies contained within the Land Allocations DPD are justified and deliverable; they are underpinned by a robust and up – to – date evidence base, informed by the outcomes of consultation, and in alignment with the strategic objectives of the Core Strategy DPD and national planning guidance.

With particular regard to the implementation of the policies, the requirement for major, complex or sensitive sites to be brought forward within the context of Development Briefs will provide the Local Planning Authority with a mechanism to secure forms of development that are responsive to site specific factors and that deliver benefits specific to the needs of the local communities. Furthermore, the Development Briefs will provide a degree of stimulus and confidence to developers, as the detailed planning guidance framework against which planning applications will be assessed will be clear at the outset.

Merits of allocating Croftlands East and Gascow Farm

The Core Strategy DPD designates 20% of the housing requirement for the District to Ulverston on the basis of its function as a Principal Service Centre. The importance of securing this housing growth to the long – term economic future of the town has recently been re – affirmed by the announcement that GlaxoSmithKline (one of the area’s largest employers) are to invest £350m in a new biopharmaceutical manufacturing facility, creating up to 500 permanent jobs. An additional £350m of investment in the future is also being considered.

The SHLAA demonstrates that the availability of brownfield land within the settlement to accommodate housing growth is limited. The consideration of greenfield sites adjoining the settlement boundary has therefore been necessary. However, the availability of such land is also restricted due to the high quality of the landscape to the north (Hoad Hill and the Sir John Barrow Monument), the extent of the flood risk area to the east and the need to avoid coalescence between Ulverston and Swarthmoor to the west. The only feasible option for meeting the Core Strategy DPD housing requirement is to concentrate growth to the south.

Consequently, Policy LA1.3 of the Land Allocations DPD includes three allocations which encompass land along the length of the southern boundary; Croftlands East (Site Reference: R697 and Part R242), Gascow Farm (Site Reference: RN131M, RN141#, RN321#, RN284#) and Croftlands West – Nook Farm (Site Reference: R690ULV, R69ULV, R126M, RN184, RN234# and Part R242). Our client holds an interest in Croftlands East and Gascow Farm.

I have three observations relating to these allocations in Policy LA1.3 which need further consideration:

1) There is an inconsistency with Policy 5.2 that needs to be clarified. Whilst Policy LA1.3 includes three allocations, Policy 5.2 and its accompanying text refers only to two. This is due to the two allocations Croftlands East and Gascow Farm being referenced as one under ‘Croftlands East – Gascow Farm’. As recognised in Policy 5.2, Croftlands East and Gascow Farm are intrinsically linked and it is logical that they should be considered as a whole and brought forward under a single Development Brief. This is necessary to ensure that the phasing of development is responsive to the site specific physical characteristics (detailed below) which need to be addressed through a co – ordinated approach. Policy LA1.3 needs to be amended to be consistent with Policy 5.2.

2) Policy LA1.3 designates the delivery of 219 units at Croftlands East over the three year period of 2022 – 2025. This translates into a rate of 73 units a year which is likely to be unachievable and housing delivery would therefore extend beyond the plan period. Further to the above observation, the 219 units should be distributed across all three phases for Croftlands East – Gascow Farm as a whole.

3) From Map 2.2 – Ulverston South accompanying the Land Allocations DPD, it has been ascertained that the boundary of the allocation for Croftlands West – Nook Farm extends beyond Mountbarrow Road into land under the ownership of our client. Although this does not prejudice the delivery of this area of land it would be more consistent for the boundary to be pulled back to Mountbarrow Road as the delivery of our clients land is most likely to occur independently of the adjoining owners.

The suitability of the allocation for residential use has been considered at length by the Local Planning Authority throughout the analysis of evidence base materials (i.e. SHLAA), the preparation of early drafts of the Land Allocations DPD and consultation with key stakeholders (including the public). In summary, the allocation represents a settlement extension that would share a relationship with existing residential areas, lie within close proximity of direct linkages to the town centre and deliver benefits such as a mix of family housing types (including affordable housing), public open space connected to the wider area through green routes, improvements to pedestrian / cycle / public transport facilities and contributions to community infrastructure.

In bringing the allocations forward there are site specific physical characteristics that need to be considered. The Land Allocations DPD clearly sets out that the future Development Brief will provide relevant guidance. Evidence base documents underpinning the Land Allocations DPD and dialogue with specialist consultants initiated by our client have determined that the physical characteristics will not prevent the delivery of the allocations. Further detailed surveys will be commissioned in the future and our client would be willing to share this information with the Local Planning Authority to assist in the preparation of the Development Brief. The main issues and our observations are outlined below:

Highways

The traffic study prepared by KR Synergy (February 2012) on behalf of the Local Planning Authority concludes that access can be achieved to the east via that which currently serves Gascow Farm (subject to highway improvement works) and to the west via Mountbarrow Road. Good visibility can be achieved onto each of these roads and both have the ability to accommodate the potential levels of traffic that would be generated. Therefore there are no barriers associated with highways and access to the site. Opportunities to provide pedestrian and cycle linkages through to Parkhead Road and Birchwood Drive would be explored in order to integrate the development into the adjoining neighbourhood, as would the options for improving public transport linkages to the town centre.

Ecology and Landscape

The landscape mitigation advice prepared by Woolerton Dodwell (December 2011) on behalf of the Local Planning Authority outlines a broad framework of landscape measures sensitive to local character that would help mitigate the potential landscape and visual impacts of the development of the allocations.

The structural landscape framework accompanying any development proposal would incorporate features such as trees, hedgerows and ponds and replacement / additional new planting as well as any required ecological mitigation measures. The framework would also incorporate provisions to enhance the interface with the adjacent caravan park. It is recognised that the area of land sterilised by the aqueduct running through the site represents a unique opportunity to provide incidental amenity space, landscape planting and green movement routes. These will complement an element of strategic open space at the core of the development, thus forming a green infrastructure network that will enhance amenity and leisure opportunities for use by the local community.

Surface Water / Foul Drainage

As demonstrated in the South Lakeland Strategic Flood Risk Assessment prepared by Jacobs (2007) on behalf of the Local Planning Authority the site lies in Flood Risk Zone 1 and has a very low likelihood of flooding. The issues regarding land drainage are acknowledged and advice has been received that a strategy for surface water management is achievable without prejudicing the development of the land, nor that to the west, or the adjoining neighbourhood. The development could readily connect into the foul sewage infrastructure located within Priory Road.

Summary

In terms of availability and deliverability, our client is free and willing to release the land. Expressions of interest have already been received from a number of developers, in particular Story Homes, who have been involved in assessing achievability and deliverability (please refer to their previous representations which affirm their views that the allocations are suitable for housing, economically viable and deliverable within the plan period). Although the allocations could be brought forward in isolation it is recognised that there is a direct relationship with the ‘Croftlands West – Nook Farm’ allocation. The development of the three allocations could occur simultaneously without prejudice to each other but there are merits of a co – ordinated approach that would benefit both landowners and the local community. As such, contact has been made with the agents acting on behalf of those holding the relevant land interests in order to establish the foundation for potential future working relationships.

I trust that the above will be given due consideration in the examination of the Land Allocations DPD. Should you have queries with regard to any comments or wish to discuss the merits of the allocation in any further detail please do not hesitate to contact me.

NO, I do not wish to participate at the oral examination

Please notify me

I have read the guidance notes

0.0 Whole Document

Yes

Representations on the Land Allocations DPD Submission Edition March 2012

I am writing on behalf of our clients, the owners of Gascow Farm, to register support for the soundness of the Land Allocations DPD Submission Edition with regard to the approach to housing delivery.

Further to this I would like to take the opportunity to reiterate the merits of allocating Croftlands East (Site Reference: R697 and Part R242) and Gascow Farm (Site Reference: RN131M, RN141#, RN321#, RN284#) under Policy LA1.3.

Soundness of the Land Allocations DPD

The Land Allocations DPD has been prepared within context of the adopted Core Strategy DPD (October 2010). The Core Strategy DPD provides the framework for the quantum and spatial distribution of housing to be delivered up to 2025. This framework was derived through the assessment of a number of factors, including the sustainability credentials of settlements, analysis of demographic and socio – economic data to identify current and future housing demand (i.e. SHMA) and the identification of potential housing land supply (i.e. SHLAA). The preliminary stages of the preparation of the Land Allocations DPD were undertaken alongside the emergence of these assessments and earlier drafts of the Core Strategy DPD. In the intervening period since the adoption of the Core Strategy DPD updated assessments have served to verify the evidence base that underpins the rationale behind the policies within the Land Allocations DPD. Throughout the preparation of both the Core Strategy DPD and the Land Allocations DPD an extensive programme of consultation with key stakeholders, including the public and statutory bodies (i.e. Environment Agency, Cumbria County Council, Highways Agency and the utilities infrastructure providers), has enabled the identification and consideration of issues relevant to the strategic and site – specific allocations of land.

This comprehensive and methodical approach, undertaken in accordance with the legal requirements of the Planning and Compulsory Purchase Act 2004, has ensured that the allocations and policies contained within the Land Allocations DPD are justified and deliverable; they are underpinned by a robust and up – to – date evidence base, informed by the outcomes of consultation, and in alignment with the strategic objectives of the Core Strategy DPD and national planning guidance.

With particular regard to the implementation of the policies, the requirement for major, complex or sensitive sites to be brought forward within the context of Development Briefs will provide the Local Planning Authority with a mechanism to secure forms of development that are responsive to site specific factors and that deliver benefits specific to the needs of the local communities. Furthermore, the Development Briefs will provide a degree of stimulus and confidence to developers, as the detailed planning guidance framework against which planning applications will be assessed will be clear at the outset.

Merits of allocating Croftlands East and Gascow Farm

The Core Strategy DPD designates 20% of the housing requirement for the District to Ulverston on the basis of its function as a Principal Service Centre. The importance of securing this housing growth to the long – term economic future of the town has recently been re – affirmed by the announcement that GlaxoSmithKline (one of the area’s largest employers) are to invest £350m in a new biopharmaceutical manufacturing facility, creating up to 500 permanent jobs. An additional £350m of investment in the future is also being considered.

The SHLAA demonstrates that the availability of brownfield land within the settlement to accommodate housing growth is limited. The consideration of greenfield sites adjoining the settlement boundary has therefore been necessary. However, the availability of such land is also restricted due to the high quality of the landscape to the north (Hoad Hill and the Sir John Barrow Monument), the extent of the flood risk area to the east and the need to avoid coalescence between Ulverston and Swarthmoor to the west. The only feasible option for meeting the Core Strategy DPD housing requirement is to concentrate growth to the south.

Consequently, Policy LA1.3 of the Land Allocations DPD includes three allocations which encompass land along the length of the southern boundary; Croftlands East (Site Reference: R697 and Part R242), Gascow Farm (Site Reference: RN131M, RN141#, RN321#, RN284#) and Croftlands West – Nook Farm (Site Reference: R690ULV, R69ULV, R126M, RN184, RN234# and Part R242). Our client holds an interest in Croftlands East and Gascow Farm.

I have three observations relating to these allocations in Policy LA1.3 which need further consideration:

1) There is an inconsistency with Policy 5.2 that needs to be clarified. Whilst Policy LA1.3 includes three allocations, Policy 5.2 and its accompanying text refers only to two. This is due to the two allocations Croftlands East and Gascow Farm being referenced as one under ‘Croftlands East – Gascow Farm’. As recognised in Policy 5.2, Croftlands East and Gascow Farm are intrinsically linked and it is logical that they should be considered as a whole and brought forward under a single Development Brief. This is necessary to ensure that the phasing of development is responsive to the site specific physical characteristics (detailed below) which need to be addressed through a co – ordinated approach. Policy LA1.3 needs to be amended to be consistent with Policy 5.2.

2) Policy LA1.3 designates the delivery of 219 units at Croftlands East over the three year period of 2022 – 2025. This translates into a rate of 73 units a year which is likely to be unachievable and housing delivery would therefore extend beyond the plan period. Further to the above observation, the 219 units should be distributed across all three phases for Croftlands East – Gascow Farm as a whole.

3) From Map 2.2 – Ulverston South accompanying the Land Allocations DPD, it has been ascertained that the boundary of the allocation for Croftlands West – Nook Farm extends beyond Mountbarrow Road into land under the ownership of our client. Although this does not prejudice the delivery of this area of land it would be more consistent for the boundary to be pulled back to Mountbarrow Road as the delivery of our clients land is most likely to occur independently of the adjoining owners.

The suitability of the allocation for residential use has been considered at length by the Local Planning Authority throughout the analysis of evidence base materials (i.e. SHLAA), the preparation of early drafts of the Land Allocations DPD and consultation with key stakeholders (including the public). In summary, the allocation represents a settlement extension that would share a relationship with existing residential areas, lie within close proximity of direct linkages to the town centre and deliver benefits such as a mix of family housing types (including affordable housing), public open space connected to the wider area through green routes, improvements to pedestrian / cycle / public transport facilities and contributions to community infrastructure.

In bringing the allocations forward there are site specific physical characteristics that need to be considered. The Land Allocations DPD clearly sets out that the future Development Brief will provide relevant guidance. Evidence base documents underpinning the Land Allocations DPD and dialogue with specialist consultants initiated by our client have determined that the physical characteristics will not prevent the delivery of the allocations. Further detailed surveys will be commissioned in the future and our client would be willing to share this information with the Local Planning Authority to assist in the preparation of the Development Brief. The main issues and our observations are outlined below:

Highways

The traffic study prepared by KR Synergy (February 2012) on behalf of the Local Planning Authority concludes that access can be achieved to the east via that which currently serves Gascow Farm (subject to highway improvement works) and to the west via Mountbarrow Road. Good visibility can be achieved onto each of these roads and both have the ability to accommodate the potential levels of traffic that would be generated. Therefore there are no barriers associated with highways and access to the site. Opportunities to provide pedestrian and cycle linkages through to Parkhead Road and Birchwood Drive would be explored in order to integrate the development into the adjoining neighbourhood, as would the options for improving public transport linkages to the town centre.

Ecology and Landscape

The landscape mitigation advice prepared by Woolerton Dodwell (December 2011) on behalf of the Local Planning Authority outlines a broad framework of landscape measures sensitive to local character that would help mitigate the potential landscape and visual impacts of the development of the allocations.

The structural landscape framework accompanying any development proposal would incorporate features such as trees, hedgerows and ponds and replacement / additional new planting as well as any required ecological mitigation measures. The framework would also incorporate provisions to enhance the interface with the adjacent caravan park. It is recognised that the area of land sterilised by the aqueduct running through the site represents a unique opportunity to provide incidental amenity space, landscape planting and green movement routes. These will complement an element of strategic open space at the core of the development, thus forming a green infrastructure network that will enhance amenity and leisure opportunities for use by the local community.

Surface Water / Foul Drainage

As demonstrated in the South Lakeland Strategic Flood Risk Assessment prepared by Jacobs (2007) on behalf of the Local Planning Authority the site lies in Flood Risk Zone 1 and has a very low likelihood of flooding. The issues regarding land drainage are acknowledged and advice has been received that a strategy for surface water management is achievable without prejudicing the development of the land, nor that to the west, or the adjoining neighbourhood. The development could readily connect into the foul sewage infrastructure located within Priory Road.

Summary

In terms of availability and deliverability, our client is free and willing to release the land. Expressions of interest have already been received from a number of developers, in particular Story Homes, who have been involved in assessing achievability and deliverability (please refer to their previous representations which affirm their views that the allocations are suitable for housing, economically viable and deliverable within the plan period). Although the allocations could be brought forward in isolation it is recognised that there is a direct relationship with the ‘Croftlands West – Nook Farm’ allocation. The development of the three allocations could occur simultaneously without prejudice to each other but there are merits of a co – ordinated approach that would benefit both landowners and the local community. As such, contact has been made with the agents acting on behalf of those holding the relevant land interests in order to establish the foundation for potential future working relationships.

I trust that the above will be given due consideration in the examination of the Land Allocations DPD. Should you have queries with regard to any comments or wish to discuss the merits of the allocation in any further detail please do not hesitate to contact me.

NO, I do not wish to participate at the oral examination

Please notify me

I have read the guidance notes

LA1.3 Housing Allocations - All Ulverston sites

Yes

Representations on the Land Allocations DPD Submission Edition March 2012

I am writing on behalf of our clients, the owners of Gascow Farm, to register support for the soundness of the Land Allocations DPD Submission Edition with regard to the approach to housing delivery.

Further to this I would like to take the opportunity to reiterate the merits of allocating Croftlands East (Site Reference: R697 and Part R242) and Gascow Farm (Site Reference: RN131M, RN141#, RN321#, RN284#) under Policy LA1.3.

Soundness of the Land Allocations DPD

The Land Allocations DPD has been prepared within context of the adopted Core Strategy DPD (October 2010). The Core Strategy DPD provides the framework for the quantum and spatial distribution of housing to be delivered up to 2025. This framework was derived through the assessment of a number of factors, including the sustainability credentials of settlements, analysis of demographic and socio – economic data to identify current and future housing demand (i.e. SHMA) and the identification of potential housing land supply (i.e. SHLAA). The preliminary stages of the preparation of the Land Allocations DPD were undertaken alongside the emergence of these assessments and earlier drafts of the Core Strategy DPD. In the intervening period since the adoption of the Core Strategy DPD updated assessments have served to verify the evidence base that underpins the rationale behind the policies within the Land Allocations DPD. Throughout the preparation of both the Core Strategy DPD and the Land Allocations DPD an extensive programme of consultation with key stakeholders, including the public and statutory bodies (i.e. Environment Agency, Cumbria County Council, Highways Agency and the utilities infrastructure providers), has enabled the identification and consideration of issues relevant to the strategic and site – specific allocations of land.

This comprehensive and methodical approach, undertaken in accordance with the legal requirements of the Planning and Compulsory Purchase Act 2004, has ensured that the allocations and policies contained within the Land Allocations DPD are justified and deliverable; they are underpinned by a robust and up – to – date evidence base, informed by the outcomes of consultation, and in alignment with the strategic objectives of the Core Strategy DPD and national planning guidance.

With particular regard to the implementation of the policies, the requirement for major, complex or sensitive sites to be brought forward within the context of Development Briefs will provide the Local Planning Authority with a mechanism to secure forms of development that are responsive to site specific factors and that deliver benefits specific to the needs of the local communities. Furthermore, the Development Briefs will provide a degree of stimulus and confidence to developers, as the detailed planning guidance framework against which planning applications will be assessed will be clear at the outset.

Merits of allocating Croftlands East and Gascow Farm

The Core Strategy DPD designates 20% of the housing requirement for the District to Ulverston on the basis of its function as a Principal Service Centre. The importance of securing this housing growth to the long – term economic future of the town has recently been re – affirmed by the announcement that GlaxoSmithKline (one of the area’s largest employers) are to invest £350m in a new biopharmaceutical manufacturing facility, creating up to 500 permanent jobs. An additional £350m of investment in the future is also being considered.

The SHLAA demonstrates that the availability of brownfield land within the settlement to accommodate housing growth is limited. The consideration of greenfield sites adjoining the settlement boundary has therefore been necessary. However, the availability of such land is also restricted due to the high quality of the landscape to the north (Hoad Hill and the Sir John Barrow Monument), the extent of the flood risk area to the east and the need to avoid coalescence between Ulverston and Swarthmoor to the west. The only feasible option for meeting the Core Strategy DPD housing requirement is to concentrate growth to the south.

Consequently, Policy LA1.3 of the Land Allocations DPD includes three allocations which encompass land along the length of the southern boundary; Croftlands East (Site Reference: R697 and Part R242), Gascow Farm (Site Reference: RN131M, RN141#, RN321#, RN284#) and Croftlands West – Nook Farm (Site Reference: R690ULV, R69ULV, R126M, RN184, RN234# and Part R242). Our client holds an interest in Croftlands East and Gascow Farm.

I have three observations relating to these allocations in Policy LA1.3 which need further consideration:

1) There is an inconsistency with Policy 5.2 that needs to be clarified. Whilst Policy LA1.3 includes three allocations, Policy 5.2 and its accompanying text refers only to two. This is due to the two allocations Croftlands East and Gascow Farm being referenced as one under ‘Croftlands East – Gascow Farm’. As recognised in Policy 5.2, Croftlands East and Gascow Farm are intrinsically linked and it is logical that they should be considered as a whole and brought forward under a single Development Brief. This is necessary to ensure that the phasing of development is responsive to the site specific physical characteristics (detailed below) which need to be addressed through a co – ordinated approach. Policy LA1.3 needs to be amended to be consistent with Policy 5.2.

2) Policy LA1.3 designates the delivery of 219 units at Croftlands East over the three year period of 2022 – 2025. This translates into a rate of 73 units a year which is likely to be unachievable and housing delivery would therefore extend beyond the plan period. Further to the above observation, the 219 units should be distributed across all three phases for Croftlands East – Gascow Farm as a whole.

3) From Map 2.2 – Ulverston South accompanying the Land Allocations DPD, it has been ascertained that the boundary of the allocation for Croftlands West – Nook Farm extends beyond Mountbarrow Road into land under the ownership of our client. Although this does not prejudice the delivery of this area of land it would be more consistent for the boundary to be pulled back to Mountbarrow Road as the delivery of our clients land is most likely to occur independently of the adjoining owners.

The suitability of the allocation for residential use has been considered at length by the Local Planning Authority throughout the analysis of evidence base materials (i.e. SHLAA), the preparation of early drafts of the Land Allocations DPD and consultation with key stakeholders (including the public). In summary, the allocation represents a settlement extension that would share a relationship with existing residential areas, lie within close proximity of direct linkages to the town centre and deliver benefits such as a mix of family housing types (including affordable housing), public open space connected to the wider area through green routes, improvements to pedestrian / cycle / public transport facilities and contributions to community infrastructure.

In bringing the allocations forward there are site specific physical characteristics that need to be considered. The Land Allocations DPD clearly sets out that the future Development Brief will provide relevant guidance. Evidence base documents underpinning the Land Allocations DPD and dialogue with specialist consultants initiated by our client have determined that the physical characteristics will not prevent the delivery of the allocations. Further detailed surveys will be commissioned in the future and our client would be willing to share this information with the Local Planning Authority to assist in the preparation of the Development Brief. The main issues and our observations are outlined below:

Highways

The traffic study prepared by KR Synergy (February 2012) on behalf of the Local Planning Authority concludes that access can be achieved to the east via that which currently serves Gascow Farm (subject to highway improvement works) and to the west via Mountbarrow Road. Good visibility can be achieved onto each of these roads and both have the ability to accommodate the potential levels of traffic that would be generated. Therefore there are no barriers associated with highways and access to the site. Opportunities to provide pedestrian and cycle linkages through to Parkhead Road and Birchwood Drive would be explored in order to integrate the development into the adjoining neighbourhood, as would the options for improving public transport linkages to the town centre.

Ecology and Landscape

The landscape mitigation advice prepared by Woolerton Dodwell (December 2011) on behalf of the Local Planning Authority outlines a broad framework of landscape measures sensitive to local character that would help mitigate the potential landscape and visual impacts of the development of the allocations.

The structural landscape framework accompanying any development proposal would incorporate features such as trees, hedgerows and ponds and replacement / additional new planting as well as any required ecological mitigation measures. The framework would also incorporate provisions to enhance the interface with the adjacent caravan park. It is recognised that the area of land sterilised by the aqueduct running through the site represents a unique opportunity to provide incidental amenity space, landscape planting and green movement routes. These will complement an element of strategic open space at the core of the development, thus forming a green infrastructure network that will enhance amenity and leisure opportunities for use by the local community.

Surface Water / Foul Drainage

As demonstrated in the South Lakeland Strategic Flood Risk Assessment prepared by Jacobs (2007) on behalf of the Local Planning Authority the site lies in Flood Risk Zone 1 and has a very low likelihood of flooding. The issues regarding land drainage are acknowledged and advice has been received that a strategy for surface water management is achievable without prejudicing the development of the land, nor that to the west, or the adjoining neighbourhood. The development could readily connect into the foul sewage infrastructure located within Priory Road.

Summary

In terms of availability and deliverability, our client is free and willing to release the land. Expressions of interest have already been received from a number of developers, in particular Story Homes, who have been involved in assessing achievability and deliverability (please refer to their previous representations which affirm their views that the allocations are suitable for housing, economically viable and deliverable within the plan period). Although the allocations could be brought forward in isolation it is recognised that there is a direct relationship with the ‘Croftlands West – Nook Farm’ allocation. The development of the three allocations could occur simultaneously without prejudice to each other but there are merits of a co – ordinated approach that would benefit both landowners and the local community. As such, contact has been made with the agents acting on behalf of those holding the relevant land interests in order to establish the foundation for potential future working relationships.

I trust that the above will be given due consideration in the examination of the Land Allocations DPD. Should you have queries with regard to any comments or wish to discuss the merits of the allocation in any further detail please do not hesitate to contact me.

NO, I do not wish to participate at the oral examination

Please notify me

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Local Development Framework Consultation