Response from Mr R A Crowder, c/o Garner Planning Associates
1. Mr R A Crowder, c/o Garner Planning Associates : 9 May 2012 10:24:00
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Policy/Site No.
LA1.3 Housing Allocations - Site Omission
If you have selected a ‘Site omission’ please enter the site reference or location and relevant policy below
R682LV- part
R682 (plus additional land to the north) Brigsteer Road, Levens
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
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.
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.
2.3 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.
1.1
These representations are submitted on behalf of Mr R. Crowder, the owner of land to the north of Levens. The extent of the site, approximating to 3.14 ha is identified on the plan appended at A.
1.2
Levens is a Local Service Centre. It is considered that the site is suitable and deliverable for residential development and should therefore be identified in Policy LA13: Housing Allocations as capable of accommodating 70 dwellings.
1.3
Before discussing the merits of the site to accommodate residential development, a brief analysis of housing land supply to meet Core Strategy is undertaken. This demonstrates a significant shortfall of housing provision at both District level and in the Local Service Centres.
2. SITE DESCRIPTION
2.1
The site is located on the northern edge of Levens, abutting existing residential development on three sides.
2.2
The site slopes down from east to west, with houses on the eastern side being higher and more prominent than the site.
2.3
The site is in close proximity to the settlement centre and associated facilities and bus stop.
3. HOUSING REQUIREMENTS
3.1
The planning authority indicate how Core Strategy gross housing requirements are to be accommodated by a combination of housing completions, planning permissions, small site contributions, housing allocations, mixed use sites, broad locations and assumed contributions from small villages and hamlets.
3.2
It is the Objector’s view that the planning authority under estimate net requirements and over estimate likely delivery of housing completions in the plan period. As a result a significant housing land shortfall has been identified.
3.3
The detailed case is set out in appendices B to D inclusive but the table below indicates the extent of housing shortfall in each settlement category.
Table 1: Housing Land Shortfalls by Settlement Category - see attached document
3.5
The Objector considers there is a clear shortfall of housing provision in the district as a whole and in the Local Service Centre settlement category.
4. LOCAL SERVICE CENTRE HOUSING REQUIREMENTS
4.1
The comparative positions in relation to Local Service Centres are summarised in Table 2.
4.2
Table 2: Local Service Centres Housing Requirements/Supply - see attachment
4.3
The Objector considers there is a shortfall of housing provision in the Local Service Centres to meet Core strategy requirements
5. CONCLUSION ON HOUSING LAND REQUIREMENTS
5.1
From the above analysis it is apparent there is a significant district wide shortfall of housing allocations to provide for sufficient housing to meet Core Strategy housing requirements and a shortfall in the Local Service Centres.
5.2
Analysis set out in Appendix D would suggest the amount of housing likely to be delivered in and on the edge of smaller villages and hamlets is likely to be significantly below the policy rate and housing completions from sites in the open countryside are likely to be negligible in the future.
5.4
Bearing in mind the above, it is important that the defined settlements, including the Local Service Centres, accommodates more than the approximate percentages referred to in CS1.2, rather than less.
5.4
It is the Objector’s view that the land north of Levens should be identified for housing development to meet a clear shortfall in housing provision in the District as a whole and the Local Service Centres in particular.
6. SCOPE TO ACCOMMODATE ADDITIONAL HOUSING IN AND AROUND LEVENS
6.1
The village is higher than the A595 to the south and therefore any development to the south would be extremely prominent in landscape terms. Land to the west is within the flood plain.
6.2
The opportunity to provide for additional housing in Levens is limited to the proposed allocation to the east off Greengate Crescent (R51M) and land to the north.
6.3
The proposed allocation described as the “Former Poultry Sheds, Brigsteer Road” to accommodate 23 dwellings, is a greenfield site but is not as well related to the settlement as the objection site. This site should be deleted and a more appropriate rounding off location found to accommodate housing development i.e. R682.
7. SUITABILITY OF THE SITE FOR HOUSING
7.1
The National Planning Framework indicates that :-
“47. To boost significantly the supply of housing, local planning authorities should:-
Use their evidence base to ensure that their Local Plan meets the full, objectively assessed needs for market and affordable housing in the housing market area, as far as is consistent with the policies set out in this Framework, including identifying key sites which are critical to the delivery of the housing strategy over the plan period;...”
7.2
The Emerging Options Consultation Edition dated January 2011 identified part of the site (1.1ha) for residential development to accommodate 24 dwellings in the period 2019-2025.
7.3
The above version of the Land Allocations document identified three sites for residential development:
- R51M Land east of Greengate Crescent – 50 dwellings
R682LVM Land west of Brigsteer Road – 24 dwellings
R71M Land west of Hutton Lane – 10 dwellings.
Total provision 84 dwellings.
7.4
In allocating these sites the document referred to the population of about 1,000 people and facilities which include a village shop, pub, post office and primary school. Among the key issues are:- The need to sustain local facilities and public transport; The need to avoid developing in areas at risk to flooding, particularly in the moss lands; The need for development to avoid unacceptable exposure to noise from the A595 (T) dual carriageway; and The need for homes to be within walking distance of key facilities.
7.5
The Emerging Options Edition stated:-
“3.92 Within Levens, the development of three sites on the northeastern edge of the village is proposed for housing where landscape impact is minimised and growth of the settlement would be organic...”
7.6
The nature of the village has not changed. The need to sustain local facilities and public transport remains, the area to the north remains the least sensitive in landscape terms, is unaffected by noise or flooding issues. The Submission Land Allocations document however now only identifies 50 dwellings at Greengate Crescent and 23 dwellings at the former poultry sheds site. The latter site is unrelated to the village and is not considered by the Objector as being within easy walking distance of local facilities and representing an
appropriate extension to the village.
8. DELIVERABILITY
8.1
The National Planning Framework indicates that planning authorities should:-
47...identify and update annually a supply of specific deliverable sites...”
Footnote 11 indicates that:-
“To be considered deliverable, sites should be available now, offer a suitable location for development now, and be achievable with a realistic prospect that housing will be delivered on the site within five years and in particular development of the site is viable...”
8.2
The site is available now because there is a willing landowner and the site has no legal constraints to development.
8.3
The site is in a suitable location for housing development being located on the edge of a Local Service Centre.
8.4
The site is achievable with a reasonable prospect of the site being delivered within five years.
9. CONCLUSIONS
9.1
The Allocations document does not identify sufficient housing land to meet Core Strategy housing requirements in the period 2003-2025 and therefore a significant amount of additional housing needs to be provided for. The Objection site should be identified for housing development to meet the identified shortfalls at both District and Local Service Centre levels.
9.2
The site has previously been identified by the planning authority as suitable for housing development and in the most suitable location for further peripheral expansion of the settlement.
9.3
The site should be identified in Policy LA1.3: Housing Allocations, as a site capable of accommodating approximately 70 dwellings in Phase 1.
SEE APPENDIX A to D ATTACHED
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
Technical nature of representation
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