Local Development Framework Consultation

I have read the guidance notes

1.9

Yes

No

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

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

The Consultation Process
Throughout the consultation process the Council and its officers have not answered
pertinent questions on the development allocations for each area. The standard answer
has been we note your comments, this has not resulted in any meaningful dialogue with
communities. In the case of Grange over Sands despite representation made by residents
and the Town Council nothing has changed from the LDF's inception. The District
Council have when confronted with any fact that is not complimentary to their current
plan tended to fall back on "if we do not have a plan developers will build where they want
and win on appeal if we turn down applications". Despite the Town Council and residents
agreeing a plan is needed there has never been an alternative discussed. A more
appropriate plan involving the Town Council and residents would satisfy local needs and
stand scrutiny at appeal. The only sensible way forward is to have community
involvement using the Core Strategy as the principal guiding document.

All meetings with SLDC have taken the form of presentation. Despite many concerns
being raised about the document, we have never received any answers or reassurances
from Council Officers or Councillors. The standard phrase continually used is "we will
note your questions and comments". This has never resulted in any follow up response
from SLDC. When residents have requested that SLDC Officers and Councillors meet
with our Town Council to resolve the outstanding issues, this has occurred, but at the
insistence of SLDC the meeting has been informal with no official minutes, no justification
or change in the proposed development for the town. Furthermore an application by the
Town Council to become a Local Planning Group in order to allocate development within
the town to ensure a sustainable economic future for Grange was rejected. SLDC by their
actions have shown that Public Consultation was in reality presentation and the original
LDF will proceed, as originally conceived. In order to justify this to the 98% of the 4,800
respondents across the district who objected, sections of the core strategy document
relating to green open spaces and infrastructure have become less specific and more generic with balance towards developers and a justification of the current proposals. Even
minor alterations to the Core Strategy at this late stage is totally unacceptable given that
all previous discussions and "presentations" by SLDC have been based upon the "original Core Strategy",

YES, I wish to participate at the oral examination

Read Notes

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I have read the guidance notes

LA1.3 Housing Allocations - R89 GRANGE-OVER-SANDS NORTH OF CARTER ROAD

Yes

No

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

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

1. DEALLOCATE RS9 AND DEFINE AS IMPORTANT OPEN SPACE
When this site was deallocated in Alteration 1 final proposals October 2001 for the South
Lakeland Local Plan 2006 it was stated that it would "contribute to the public amenities of
this part of the built up area of Grange over Sands" SLDC agreed with this statement and
"earmarked it as important open space".
In summary the public inquiry said "The request to designate the Berry Bank site (now
R89) as important open space is easier to justify given its landscape and amenity
qualities", this is still the case today.
National Planning Policy Framework
76. Local communities through local and neighbourhood plans should be able to
identify for special protection green areas of particular importance to them. By
designating land as Local Green Space local communities will be able to rule out
new development other than in very special circumstances. Identifying land as
Local Green Space should therefore be consistent with the local planning of
sustainable development and complement investment in sufficient homes, jobs and
other essential services. Local Green Spaces should only be designated when a plan
is prepared or reviewed, and be capable of enduring beyond the end of the plan
period.
I would also make reference to a comment made by Cumbria County Council in the
Emerging Option Document for Grange over Sands page 75 which states that the site
"could also be an important open space that contributes to the character of the
settlement" . The Core Strategy Document Section 8 of Green Infrastructure page 13
states "that a private open space should meet ONE of the following criteria in order
to be classified as important open space for amenity. In reality R89 satisfies SEVEN
out of the TEN criteria listed, whilst the green open space is compromised by a tall
hedge on the Allithwaite Road, from the Kents Bank estate it is most visible and an
important area of green open space/infrastructure as it is most visible from this widely
used local route, Carter Road.
1. Land Assessment and Consultants Recommendations to the Council
The SHLAA Final Report Assessment lists R89 as a Category 3 site
Category 3 is defined as sites that achieve low scores on assessment below 35 out of
50 and "perform least well against the assessment criteria, facing at least three
significant constraints (least developable sites) The reference document is Roger Tym
and Partners M9233 March 2009 Final Report Section 6 para 6.5 page 33. This
document should then be cross referenced with the Grange over Sands Fact File -
Febrnarv 2012 page 104 Paragraph:- justification/issues to be addressed states that
"The site scored FULL MARKS in the SHLAA assessment". This is simply a
deliberate misrepresentation of the site to ensure allocation in favour of landowners and
developers. This decision on land parcel R89 is unsound and completely unjustified. The
Fact File Document also states that the site "could be an important open space that
contributes to the character of this part of the settlement".
I would now refer to the Douglas Wheeler Associates Regeneration Study dated 2007
and the Gillespies Report and Plan dated December 2008.
The Douglas Wheeler Regeneration study stated "that residential development of the
Allithwaite Road/Carter Road site is likely to be controversial because of the "Greenfield
nature of the site" and do not include this site in their final list of preferred
development"
Gillespies Report dated December 2008 This report and plan acknowledges there are
some parts of Grange "to the east of the B5277 the coastal plain is open and allows
attractive views toward the estuary. Development in this area would impact significantly
on these views and no development should be considered to the east of Grange over
Sands. East Grange lies tight to the existing railway line and estuary edge along the east
shore of the estuary. There is no room for development within this area. The majority of
sites facing the water have been occupied and fall within the existing development
boundary. Only four sites were put forward by the Gillespies Report, North of Grange
Road, Kents Bank Road/Cartmel Road, Kents Bank (see plan). Some of the conclusions
of the Gillespies Report compliment the DWA Regeneration Study, unfortunately the
outcome has remained the same, land that is not included or recommended for
exclusion now forms part of the final land allocation document. I refer you to page
33, Southlakeland Employment and Housing Land Search Study Gillespies Dec 2008:The
eastern section includes R89 land parcel.
I would also once again make reference to the comment made by Cumbria County Council
in the Emerging Option Document for Grange over Sands page 75 which states that the
site "could also be an important open space that contributes to the character of the
settlement" .
2. Land Allocation Development Plan Document Page 195 R89 Effect on Landscape
Character
The rating is classified as neutral. Given the recommendations by Douglas Wheeler
Associates, Gillespies Report, the Green infrastructure Section 8 of the Core
Strategy, Cumbria Country Councils comments and the Category 3 rating how can
one consider the effect on the Landscape Character as being neutral. FORTY FIVE
dwellings on this important and only green open space for this part of the Kents
Bank, located on a strategic route bas MORE THAN A NEUTRAL EFFECT. THE
NEUTRAL RATING IS UNSOUND AND UNJUSTIFIED
There is no accurate or technical assessment of the increased localised flooding to
dwellings at a lower elevation. There are serious omissions in relation to biodiversity and
wild life migration. There is no mention of the limestone wall running the entire
length of the frontage on Cater Road this wall has been a characteristic of the
roadway for at least 100 years, however bushes and trees on the remainder of the
perimeter are noted. As the current LDF has an over provision of up to 20%, there is no
possible reason why this important green open space for the community and its category 3
rating should not preclude it from the development programme.
The location of the site in relation to accessing services in the town does not consider
the topography. All routes involve returning up a severe gradient that at times exceeds
1: 6. One route has a narrow footpath down one side the other is a single track road with
no footpaths so the needs of people with disabilities are not being considered. Walking
and cycling will not be safe as an alternative means of transport as this will cause conflict,
between motorised traffic, cyclists and pedestrians using these unsuitable routes. No
Transport Assessment has been carried out.
Built Environment R89
A neutral rating
There will be no potential to "improve the built environment" Refer to Dogulas Wheeler
Associates recommendation and comments. Page 14 para 3 When referring to the Kents
Bank area, it states "open outlook, becoming suburban, some large detached by villas,
open spaces important they also conclude that residential development of the
Allitbwaite Road/Carter Road site should not be on the list of preferred
development.
The Gillespies Report also excluded the site. SHLAA Rated Category 3 site.
The neutral rating for the built environment is unsound and unjustified. Therefore
the rating should be X
Water Supply/Surface Water R89
The top soil on this site greatly reduces the risk of serious localised flooding at times of
heavy down pours. Over the last four years there has been some localised property
flooding in the immediate vicinity of this site. The minimal impact has been due to the
topsoil absorption at periods of heavy rain. With the proposed development of 45
properties the hard standing will increase the run off potential, this cannot be disposed of
into the local sewerage system as the Water Company have already prohibited this. Given
the nature of the ground conditions in this area, mainly limestone with a top soil covering,
disposal of surface water run off will be a major factor to consider. SLDC have been
informed of this problem over 12 months ago, the rating should therefore be X and not
left as an open issue to be addressed later.
Greenfield or Brownfield R89
I refer you to the Category 3 rating. This designation requires that all other more suitable
sites are to be developed before this category is to be considered. It is proposed by SLDC
that R89 is now included in the phase 1 development programme. This contradicts the
Category 3 rating and SHLAA assessment.
Education and Training R89
Totally the wrong rating, rating ECI, EC3. Further Higher Education and Training is not
located within a 1-4km radius of Grange over Sands. A training facility to be rated as
positive should provide a range of training that is varied enough to meet the demands of
the local community. The nearest facilities are Kendal 24km, Barrow 42km and Ulversto
24km away. The rating using the Council's own criteria should be XX.
Access to Jobs R89
With the potential for another 500 properties in Grange over Sands it is doubtful that
tourism, heritage and leisure will cater for the increased population. I refer to SP2 "no
criteria were used to assess sites against this objective" as all housing sites will
automatically help to provide people with homes and all employment sites will support
access to homes by helping raise average incomes and provide jobs, which in tum will help
people to access housing. In order to fulfil criteria set down in the Core Strategy on
excessive travelling and the environment, employment land should be in close proximity to
housing. This is not the case for Grange over Sands, which has been allocated 8% of the
13% housing allocation for the three Key Service Centres compared with 3% for Milnthorpe and Kirkby Lonsdale (as Appendix 1 -proposed distribution of development)
(Kirkby Lonsdale had twice the amount of land required for development). The
employment land has largely been allocated to Milnthorpe and Kirkby Lonsdale, with
Milnthorpe receiving 50% of the three Key Service Centres total and approx 33% of the
housing development..
Open Space R89
The rating given to R89 when assessing the loss of this green open space is incorrect. The
Kents Bank area is and has always been accepted as a "stand alone" area within Grange by virtue of its location and the elevation above the town. Green open spaces are an
important feature and can act as a visual amenity to the settlement, and helps to
prevent the area becoming totally suburban. The importance of this site for wildlife
migration (deer) as "stepping stones Pockets of habitat that, while not necessarily
connected, facilitate the movement of species across otherwise inhospitable
landscapes". This is acknowledged in the Douglas Wheeler report were it stated, that
the open spaces are important in this area and its subsequent omission and confirmation in the Gillespies Report.
Access to Educational Facilities R89
In relation to R89 the Primary and Secondary assessments are the wrong way around.
The secondary school is just over the 3 km, therefore it falls into assessment band X and
not as indicated.
Biodiversity R89
21 species have been identified but no further information is given despite these being
identified as key species. The potential for water voles has also been identified but there is
no mention of deer or their movement across the site daily.
Surface Water Flooding R89
The assessment is not accurate SLDC have not accepted two instances of localised
flooding when there has been heavy down pours or even asked for further information
from respondents who have identified this problem. The top soils absorbent surface
manages to alleviate most of these problems at periods of heavy rain. A further factor is
that the substrata is limestone, this is not renown for its ability to provide adequate soak
away. The Water Company, United Utilities have already stated that no run off water will
be permitted to enter the public sewer. Therefore given its location to any other disposal
points, soakways would have to be considered, it will be difficult to construct these to be
effective without them "overtopping" to the road drainage and ultimately overloading the
sewerage system something the Water Company will not permit.
South Lakeland Local Development Framework Land Allocation Development Plan
Document page 223
Overall, Grange over Sands scores best in terms of access to jobs, a shop, education and
training, transport and health services. Sites also score generally well against access to a
village hall, a secondary school, recycling facilities and open spaces (although some sites
would remove provision if developed) as well as in terms of flood risk and sites' locations
in relation to the existing community. It then goes on to contradict these statements with
Grange over Sands sites score least well in terms of impact upon biodiversity and air
quality.
The mediocre scores against access to cultural and leisure facilities suggest that
Grange over Sands would benefit from more local provision of such facilities.
Mediocre scores were also given against water supply/sewerage capacity and against
the potential for the use of energy efficiency measures and renewable as well as
recycled materials in new developments.
Scores are variable against access to primary schools and impacts upon landscape
and the build environment as well as in terms of the take-up of Greenfield land and
potential for coalescence.
Care will need to be taken to ensure that use of recycled materials and energy
efficiency/renewable energy measures are encouraged as few of the sites in Grange
over Sands have any clear evidence of in-place opportunities for this.
Care will also need to be taken to ensure that impacts on the landscape, biodiversity,
air quality and built environment are avoided or minimised and that adequate
water supply/sewer capacity is in place
The sites that score best overall are R381, R378, R383, R376, R673, MN16, MN2
and MN1 score poorly overall in comparison to other.
NO REFERENCE IS MADE TO R89
There can be no doubt that what is emerging in site options document for
Grange over Sands is that developers are setting the development programme as in the
case of R89. I refer you once again to page 104 of the Grange over Sands Fact File Feb
2012 where it states in Site Availability "Russell Armer have confirmed available" and in
Justification Issues to be Addressed "The site scored full marks in the SHLAA
Assessment" This is simply untrue, misleading and stated in order to achieve the
developer/landowner/council objective of inclusion. Further more I would again draw
your attention of the Category 3 rating of the site and its limitation on potential use, it is
certainly not to be developed in the way it is currently proposed. Enclosed documents
confirm this classification and the misrepresentation of classification. All
recommendations and assessments of R89 confirm that this land parcel should be removed from the LDF and remain as important green open space for the local community. This failure to do so confirms the "unsoundness" of the Councils development proposals and a disregard of Core Strategy and SHLAA assessment in favour of landowners and
developers. This is unsound and totally unacceptable.

YES, I wish to participate at the oral examination

Read notes

Please notify me

I have read the guidance notes

0.0 Whole Document

Yes

No

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

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

I wish to make representation on the proposed Local Development Framework by South
Lakeland District Council. There is in this current plan numerous contradictions with the
Core Strategy that make it "unsound". Reports compiled by their Consultants used to
develop the Core Strategy and eventually the Development Plan have been used "piece
meal" when serious concerns about locations and magnitude of development are raised. ·
The strategy 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.

YES, I wish to participate at the oral examination

Read notes

Please notify me