Local Development Framework Consultation

I have read the guidance notes

LA1.3 Housing Allocations - Site Omission

R118 Kendal Road, Kirkby Lonsdale

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 DPD is not consistent with national policy.

See Attached document

LAND WEST OF QUEEN ELIZABETH SCHOOL, KENDAL ROAD, KIRKBY LONSDALE, CUMBRIA
REPRESENTATIONS IN RELATION TO SOUTH LAKELAND LAND ALLOCATIONS DEVELOPMENT PLAN DOCUMENT
Our Ref: CNG/223/CSL
LPA SITE REF: R118

1. INTRODUCTION
1.1
These representations are submitted on behalf of the Russell Trust, the owners of land to the south of Kendal Road, Kirkby Lonsdale. The extent of the site is identified on the plan attached (Appendix A).
1.2
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 44 dwellings.
1.3
Before discussing the merits of the site to accommodate residential development, a detailed 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 Key Service Centres.
2. SITE DESCRIPTION
2.1
The site is located on the western side of Kirkby Lonsdale and is in easy walking distance of Kirkby Lonsdale town centre, Booths supermarket and all the services the town provides.
2.2
The site comprises 2.98 ha and is bounded by Kendal Road to the north and west, A65 to the south and west and Queen Elizabeth School to the east.
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 but the table below indicates the extent of housing shortfall in each settlement category.

See Table 1 in attached document

3.5
In the above table given that contributions from small villages and hamlets is based largely assumed contributions rather than allocations, the slippage rate applied is the same as the net requirement.
4. KEY SERVICE CENTRE HOUSING REQUIREMENTS
4.1
Kirkby Lonsdale is identified in Policy CS1.2 as a Key Service Centre along with Grange over Sands and Milnthorpe. The comparative positions of the planning authority and the Objector in relation to the Key Service Centres are summarised in Table 2.

See table 2 in attached document

4.3
The Objector considers there is a clear shortfall of housing provision in the Key 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 shortfall of housing provision to meet Core Strategy housing requirements in all settlement categories including the Key Service Centres.
5.2
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.
5.3
Bearing in mind the above, it is important that the defined settlements, including Kirkby Lonsdale, as one of the three Key Service Centres, accommodate more than the ‘approximate’ percentages referred to in CS1.2, rather than less.
5.4
It is the Objector’s view that the land west of Queen Elizabeth School should be identified for housing development to meet a clear shortfall in housing provision in the District as a whole and in the Key Service Centres in particular.
6. SCOPE TO ACCOMMODATE ADDITIONAL HOUSING IN AND AROUND KIRKBY LONSDALE
6.1
The opportunities to provide for additional housing in and around Kirkby Lonsdale are realistically limited to the land west of Queen Elizabeth School.
6.2
The planning authority specifically rejected the idea of functional areas in the context of the Core Strategy and preferred instead to distribute housing by settlement hierarchy. This was supported by the Inspector. Table 1 on page 17 of the Land Allocations document appears to suggest a return to a functional area approach. In the wider context, Kirkby Lonsdale is geographically remote from other Principal, Key and Local Service Centres. Only the small villages and hamlets of Barbon and Casterton could be considered satellite communities to Kirkby Lonsdale.
6.3
The town of Kirkby Lonsdale must therefore be the focus for housing development in this part of South Lakeland. However, the opportunity to accommodate further housing development on peripheral expansion sites is limited to the land west of Queen Elizabeth School.
6.4
To the east of the town, expansion is restricted by a combination of the slope down to the River Lune and the associated flood risk area, to the north west growth is similarly constrained beyond the mixed use allocation (R127M) by topography and flood risk, to the north east expansion is restricted given the elevated nature of the land and to south by the A65.
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 SHLAA produced by Roger Tym & Partners in March 2009, which forms part of the evidence base, identifies the Objection Site as a Category 2 i.e. a developable site, with a gross area of 2.95 ha capable of accommodating 89 dwellings.
7.3
The Emerging Options Consultation Edition dated January 2011 identified the site for residential development to accommodate 44 dwellings in the period 2014-2019.
7.4
Representations were made by several parties in relation to the proposed allocation of the site and several issues were raised including the following:-
Overprovision to meet requirement in the town of 118 dwellings; Landscape; Development would restrict school expansion; and Traffic
These issues are addressed below.
8. RESPONSE TO OBJECTIONS
8.1 Overprovision of housing in Kirkby Lonsdale
8.1.1
The general shortfalls of housing land provision to meet Core Strategy requirements are discussed above. There is a shortfall of housing allocations in the Key Service Centres and a need for the three Key Service Centres to compensate for shortfalls elsewhere, particularly in the small villages and hamlets.
8.1.2
The reference to a requirement for 118 dwellings net additional dwellings is not based upon a Core Strategy housing requirement for the town. Kirkby Lonsdale is one of three Key Service Centres where an overall housing requirement figure is referred to.
8.1.3
Kirkby Lonsdale’s arbitrary gross requirement of 232 new dwellings is simply an apportionment of the 13% of the gross Core Strategy requirement across the three settlements based on existing housing stock. The suggested gross requirement for the town is not a Core Strategy requirement. Providing more than 232 new dwellings in the plan period would still be compliant with the Core Strategy. Indeed to have any chance of meeting housing targets it is important the Key Service Centres accommodate additional housing.
8.2 Landscape
8.2.1
The landscape situation has not changed since the site was identified as suitable for development in the Emerging Options Land Allocations document. The South Lakeland Housing and Employment Land Search Study does not make any reference to any specific landscape issues on the western side of Kirkby Lonsdale. Indeed the plan associated with that document (see Appendix x) makes reference to the site being identified as suitable for development in an earlier study.
8.2.2
The Cumbria Landscape Character Toolkit does not indicate any specific issues in relation to the Kendal Road site and SLDC in their response to objections refer simply to the need for mitigation measures.
8.2.3
The site does have topographical challenges and the development of the site would need to be dealt with sensitively to ensure a high quality scheme that respects the site’s gateway position and the proximity of the school adjoining. The suggested level of development in the Emerging Options document of 44 dwellings would seem an appropriate amount of development to ensure topography is taken into account in an appropriate manner.
8.3 Development would preclude school expansion
8.3.1
Kirkby Lonsdale and District Civic Society’s representation is summarised as:-
“If development takes place the school will be “hemmed” and hinder its expansion in a time of increasing population.”
SLDC’s response is;-
“Noted – we consider this to be an important point.”
8.3.2
If the planning authority accepts that the site may be required for future school expansion the authority are presumably accepting further built development west of the existing school is acceptable, as clearly the site would not be suitable for additional playing field provision. The acceptance of built development contradicts landscape objections to the development of at least part of the site.
8.3.3
At the present time there is no evidence that there is currently, or there is likely to be a need to expand the school. The Objector is seeking dialogue with the School to determine if there is indeed any aspiration to expand the school onto the objection site. A housing allocation would not preclude the purchase of part of the site for school expansion if any such aspiration is apparent.
8.4 Traffic
8.4.1
Cumbria County Council has not objected on highways grounds and it is understood a Transport Assessment will form part of any planning application.
9. DELIVERABILITY
9.1
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...”
9.2
The site is available now because there is a willing landowner and the site has no legal constraints to development.
9.3
The site is in a suitable location for housing development being located on the edge of a Key Service Centre.
9.4
Vehicular access is achievable and an appropriate easement can be incorporated into any development to accommodate the Haweswater Aqueduct on the eastern side of the site.
9.5
The site is achievable with a reasonable prospect of the site being delivered within five years.
10. CONCLUSIONS
10.1
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 in the first phase of the plan to meet the identified shortfalls at both District and Key Service Centre levels and in the first phase of the plan.
10.2
The site is the only place where further peripheral expansion of the settlement can be accommodated.
10.3
It would seem that the reason for not allocating the site are principally housing land supply in Kirkby Lonsdale and the possible future expansion requirements of Queen Elizabeth School. The overall housing land supply shortfalls discussed at length above. There is no evidence that the school have any aspirations to expand school facilities and even if there were a housing allocation would not preclude negotiations taking place.
10.4
The site should be identified in Policy LA1.3: Housing Allocations, as a site capable of accommodating approximately 44 dwellings in Phase 1.

SEE Attached document for Appendices

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