Local Development Framework Consultation

I have read the guidance notes

0.0 Whole Document

No

The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy

1. INTRODUCTION
1.1 Emery Planning Partnership is instructed by Pure Leisure Group Ltd to submit
representations to the South Lakeland Land Allocations DPD - Proposed Submission Edition
(March 2012).
1.2 Our client has a number of interests in South Lakeland as follows:
· Fell End Caravan Park, Hale, Milnthorpe, LA7 7BS;
· Hall More Caravan Park, Hale, Milnthorpe, LA7 7BP; and
· Former Ulverston Abattoir, North Lonsdale Road, LA12 9AU
1.3 Site location plans are attached as Appendix EPP1.
1.4 These submissions relate to the established leisure uses on site in respect of Fell End and
Hall More and to the potential redevelopment opportunities of the Former Abattoir site. In
respect of this latter site our submissions centre on the potential for residential or mixed
uses which we consider offer the most suitable basis for bringing the redevelopment of
this site forward.

2. PLANNING POLICY CONTEXT
2.1 The current development plan comprises:
· the Regional Spatial Strategy for the North West (September 2008);
· the South Lakeland Core Strategy (October 2010);
· the saved policies of the Joint Cumbria and Lake District Structure Plan (April
2006); and
· the saved policies of the South Lakeland Local Plan (September 1999).
2.2 The following documents are material considerations:
· Ulverston Canal Head Masterplan (2005)
National Planning Policy
2.3 The National Planning Policy Framework (NPPF) was published on 27th March 2012. It
supersedes all previous Planning Policy Guidance notes (PPGs) and Planning Policy
Statements (PPSs).
2.4 Paragraph 14 confirms that at the heart of the NPPF is a presumption in favour of
sustainable development, which should be seen as a golden thread running through both
plan-making and decision-taking. For plan-making, this means that:
· local planning authorities should positively seek opportunities to meet the
development needs of their area; and
· local plans should meet objectively assessed needs, with sufficient flexibility to
adapt to rapid change.
2.5 Paragraph 47 states that local planning authorities should identify and update annually a
supply of specific deliverable sites sufficient to provide five years worth of housing against
their housing requirements with an additional buffer of 5% (moved forward from later in
the plan period) to ensure choice and competition in the market for land. Where there has
been a record of persistent under delivery of housing, local planning authorities should
increase the buffer to 20%. Specific, developable sites or broad locations for growth
should be identified for years 6-10 and, where possible, for years 11-15.
2.6 Paragraph 159 states that Local Planning authorities should have a clear understanding of
housing needs in their area. They should prepare a Strategic Housing Market Assessment
(SHMA) to assess their full housing needs, working with neighbouring authorities where
housing market areas cross administrative boundaries. The SHMA should identify the scale
and mix of housing and the range of tenures that the local population is likely to need over
the plan period, which:
· meets household and population projections, taking account of migration and
demographic change;
· addresses the need for all types of housing, including affordable housing and
the needs of different groups in the community; and
· caters for housing demand and the scale of housing supply necessary to meet
this demand.
2.7 Local Planning authorities should also prepare a Strategic Housing Land Availability
Assessment (SHLAA) to establish realistic assumptions about the availability, suitability and
likely economic viability of land to meet the identified need for housing over the plan
period.
3. PLAN PERIOD
3.1 We note that paragraph 1.19 of the consultation document states the Council expects the
Land Allocations DPD to be adopted in autumn 2012. However, the consultation document
only sets out housing allocations to 2025. Even if the Land Allocations DPD is adopted in
2012, this would mean that land would only be allocated for a maximum 13 years at best
if what we consider to be an optimistic timetable is adhered to.
3.2 As set out above, paragraph 47 of the NPPF states that local planning authorities should
identify specific deliverable sites sufficient to provide five years worth of housing against
their housing requirements. Specific, developable sites or broad locations for growth
should be identified for years 6-10 and, where possible, for years 11-15.
3.3 Paragraph 157 of the NPPF states that crucially, local plans should be drawn up over an
appropriate time scale, preferably a 15-year time horizon, take account of longer term
requirements, and be kept up to date.
3.4 The Land Allocations DPD should plan for a 15 year period from adoption. As the Core
Strategy sets out the requirements for South Lakeland to 2025, these requirements should
be rolled forward to allow the Land Allocations DPD to plan for a 15 year period.

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.

8. SUMMARY AND CONCLUSIONS
8.1 Emery Planning Partnership is instructed by Pure Leisure Group Ltd to submit
representations to the South Lakeland Land Allocations DPD - Proposed Submission Edition
(March 2012).
8.2 A summary of our representations is as follows:
· The Land Allocations DPD should be extended so that it provides allocations for
at least a 15 year period in line with the guidance set out in the NPPF. At
present, the consultation document is contrary to national planning policy as it
only provides allocations for up to 2025, which means that only 12-13 years are
planned for, depending on when the Land Allocations DPD is finally adopted.
· The Land Allocations DPD needs to allocate more land within the first phase
(2012-17) for the following reasons:
- firstly, it is not clear how many dwellings currently benefit from
planning permission. The figure set out in the consultation
document does not seem to correlate to the evidence base, which
suggests a lower figure;
- secondly, the NPPF requires that the Council should identify an
additional 20% of supply in the first five years; and
- finally, the housing trajectory for the first five years as set out in
appendix 4 of the consultation draft is overly ambitious.
· The Land Allocations DPD should consider bringing forward sites from later
phases to meet the requirement – including the Ulverston Canal Head site.
· The Land Allocations DPD should provide more flexibility for those sites which
provide tourist accommodation in line with policies CS5 and CS7.6 of the Core
Strategy. As it stands, these sites are not catered for in the consultation
document.
· Whilst the allocation at the Ulverston Canal Head is broadly welcomed, we
question whether the Council is being overly ambitious in preparing 18
development briefs across the borough and adopting them as SPDs within just
8/9 years. Given the importance of the site and the previous delays in securing
its redevelopment, the development brief for the Ulverston Canal Head should
be prioritised and brought forward to an earlier phase in the plan period.
· As the masterplan for the Ulverston Canal Head is now seven years old, it is now
out of date. A developer led development brief team should be assembled to
take forward the development brief for the site. Our client should be invited to
join the development brief team.
8.3 This concludes our representations to the South Lakeland Land Allocations DPD - Proposed
Submission Edition (March 2012)

YES, I wish to participate at the oral examination

Examination provides our clients with the opportunity to critically examine the councils position in order to ensure the plan is sound. Oral examination allows for a more forensic examination of the evidence and in depth analysis of the various opinions.

Please notify me

I have read the guidance notes

2.18

No

The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy

See text below

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 consistent with national policy.

4. SECTION 2 – LAND ALLOCATIONS
4.1 Tables 1A and 1B of the Land Allocations DPD set out the overall housing requirement and
allocation phasing.
4.2 In line with Core Strategy Policy CS6.1, table 1A sets out the number of dwellings required
to meet the requirement of 8,800 dwellings between 2003 and 2025. This is summarised
as follows:
Completions 2003-2011 1,690
Permitted 2011 1,042
Identified small sites 289
Phase 1 requirement (2012-17) 2,103
Phase 2 requirement (2017-22) 2,402
Phase 3 requirement (2022-25) 1,273
Total 8,799
4.3 Table 1B sets out a summary of the housing allocations between 2012 and 2025. This is
summarised as follows:
Phase 1 allocations (2012-17) 1,473
Phase 2 allocations (2017-22) 2,242
Phase 3 allocations (2022-25) 2,366
Total 6,081
Completions
4.4 We note that 1,690 dwellings (net) have been completed between April 2003 and March
2011. This is summarised as follows:
2003/04 2004/05 2005/06 2006/07 2007/08 2008/09 2009/10 2010/11 Total
Requirement 400 400 400 400 400 400 400 400 3,200
Completions 221 232 303 238 156 155 282 103 1,690
4.5 As the above table demonstrates, the Council has failed to meet its annual requirement
every year since 2003.
Planning permissions
4.6 It is unclear where the figure of 1,042 dwellings with planning permission in table 1A is
taken from. Footnote 7 explains that the source for this is the Council’s Annual Monitoring
Report (AMR, 2010), but the table reference is not given. The AMR 2010 is based on the
Housing Land Position Statement 2010, which stated that at 1st April 2010, there were 940
dwellings with planning permission.
4.7 Table 1A needs to be updated to reflect the latest evidence. Unfortunately, the Council
does not appear to have published its AMR for the period April 2010 to March 2011.
However, the Housing Land Position Statement 2011 was published in September 2011.
Appendix 3 of this document states that at 1st April 2011, there were 1,003 dwellings with
planning permission comprising 445 units under construction and 558 dwellings not
started.
4.8 Footnote 7 of table 1A also notes that a deduction of 20% should be applied to cover
permissions not implemented on small sites. We therefore question whether the number
of dwellings with planning permission should actually be 800 (i.e. 1,003 dwellings with
planning permission minus 20%) rather than either 1,042 or 1,003.
Identified small sites
4.9 Footnote 8 states that these sites are those identified in the SHLAA, adjusted to exclude
permissions and completions with the balance adjusted by 80% to account for sites not
implemented.
Phase 1 requirements and allocations
4.10 We are concerned that the consultation document does not allocate enough dwellings in
phase 1 to meet the requirement set out in Core Strategy policy CS6.1 (of 400 dwellings
per annum).
4.11 Firstly, the shortfall in housing delivered since 2003 (of 1,510 dwellings) means that the
annual requirement has increased for the remainder of the plan period.
4.12 We note that appendix 4 of the consultation document sets out the housing trajectory and
anticipates that just 275 dwellings will be delivered between 2011-12. This means that the
shortfall would increase to 1,635 by 2012.
4.13 If the shortfall were to be split over the remaining 13 years of the plan period, this would
equate to an annual requirement of 551 dwellings (2012 to 2025). This would equate to a
five year requirement of 2,755 dwellings.
4.14 We note however that as set out in table 4.1 of the Housing Land Position Statement
2011, the Council is seeking to meet the shortfall in the first five years. This means that
the annual housing requirement for the first five years (i.e. 2012 to 2017) is 727 dwellings,
equating to 3,635 dwellings over the five year period. Under this scenario, the requirement
for the remainder of the plan period (i.e. 2017 to 2025) would drop to 400 dwellings per
annum.
4.15 Table 1B shows that for phase 1 (2012-17), 1,473 dwellings have been allocated.
Consequently, assuming the 1,042 dwellings with planning permission and the 289
identified small sites are delivered as set out in table 1A, this means that in the five year
period between 2012 and 2017, the Council is planning to deliver 2,529 dwellings, which
falls short of the requirement under both scenarios set out above.
4.16 In addition, paragraph 47 of the NPPF is clear that where there has been a record of
persistent under delivery of housing against their requirement, local planning authorities
should identify an additional 20% of sites, moved from later in the plan period and add
this to the five year supply.
4.17 There has been a persistent under delivery of housing in South Lakeland since the
beginning of the RSS / Core Strategy plan period in 2003. As set out above, the Council
has failed to meet the annual requirement of 400 net dwellings in every year since 2003.
Consequently, to accord with national policy, South Lakeland must identify an additional
20% of supply in the first five years (i.e. phase 1). This will have implications in relation to
phases 2 and 3 of the plan as some of the supply for these phases will need to be brought
forward to the first five years.
4.18 The following table summarises this position:

Requirement Scenario 1 –
Shortfall
made up over
period to
2025 Scenario 2 –
Shortfall
made up over
first five years
A Requirement April 2003 to March 2025
(400 dwellings per annum) 8,800 8,800
B Completions April 2003 to March 2011 1,690 1,690
C Anticipated completions April 2011 to
March 2012 275 275
D Total completions
April 2003 – March 2012 1,965 1,965
E Shortfall in delivery
April 2003 – March 2012 1,635 1,635
F Residual requirement 2012-25 (A-D) 6,835 6,835
G Requirement April 2012 to March 2017 2,630 3,635
H Annual requirement
April 2012 to March 2017 (G/5) 526 727
I Plus additional buffer (G+20%) 3,156 4,362
Supply
J Supply - April 2011 to March 2017

•?Permitted sites (1,042)
•?Identified small sites (289)
•?Allocated sites (1,473)
•?Estimated completions 2011-12 (-275) 2,529 2,529
K Shortfall in allocation (I-G) -101 -1,106
L Shortfall in allocation including
20% buffer (IH) -627 -1,833

ALSO REFER TO ATTACHED DOCUMENT- SECTION 2

8. SUMMARY AND CONCLUSIONS
8.1 Emery Planning Partnership is instructed by Pure Leisure Group Ltd to submit
representations to the South Lakeland Land Allocations DPD - Proposed Submission Edition
(March 2012).
8.2 A summary of our representations is as follows:
•?The Land Allocations DPD should be extended so that it provides allocations for
at least a 15 year period in line with the guidance set out in the NPPF. At
present, the consultation document is contrary to national planning policy as it
only provides allocations for up to 2025, which means that only 12-13 years are
planned for, depending on when the Land Allocations DPD is finally adopted.
•?The Land Allocations DPD needs to allocate more land within the first phase
(2012-17) for the following reasons:
- firstly, it is not clear how many dwellings currently benefit from
planning permission. The figure set out in the consultation
document does not seem to correlate to the evidence base, which
suggests a lower figure;
- secondly, the NPPF requires that the Council should identify an
additional 20% of supply in the first five years; and
- finally, the housing trajectory for the first five years as set out in
appendix 4 of the consultation draft is overly ambitious.
•?The Land Allocations DPD should consider bringing forward sites from later
phases to meet the requirement – including the Ulverston Canal Head site.
•?The Land Allocations DPD should provide more flexibility for those sites which
provide tourist accommodation in line with policies CS5 and CS7.6 of the Core
Strategy. As it stands, these sites are not catered for in the consultation
document.
•?Whilst the allocation at the Ulverston Canal Head is broadly welcomed, we
question whether the Council is being overly ambitious in preparing 18
development briefs across the borough and adopting them as SPDs within just
8/9 years. Given the importance of the site and the previous delays in securing
its redevelopment, the development brief for the Ulverston Canal Head should
be prioritised and brought forward to an earlier phase in the plan period.
•?As the masterplan for the Ulverston Canal Head is now seven years old, it is now
out of date. A developer led development brief team should be assembled to
take forward the development brief for the site. Our client should be invited to
join the development brief team.
8.3 This concludes our representations to the South Lakeland Land Allocations DPD - Proposed
Submission Edition (March 2012).

YES, I wish to participate at the oral examination

Examination provides our clients with the opportunity to critically examine the councils position in order to ensure the plan is sound. Oral examination allows for a more forensic examination of the evidence and in depth analysis of the various opinions.

Please notify me

I have read the guidance notes

0.3 Section 3

Response refers to Paragraphs 3.77 to 3.88 of the DPD

No

The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy

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.

5. SECTION 3 – LAND ALLOCATIONS – KENDAL AND SURROUNDING
AREA - refers to paragraphs 3.77 to 3.88 of the DPD
5.1 As set out above, our client has two sites in Hale, to the south of Milnthorpe:
•?Fell End Caravan Park, Hale, Milnthorpe, LA7 7BS;
•?Hall More Caravan Park, Hale, Milnthorpe, LA7 7BP; and
5.2 These sites are located within the Arnside and Silverdale Area of Natural Beauty (AONB).
5.3 Paragraphs 3.74 to 3.88 of the consultation document discuss the AONB within the context
of Core Strategy policy CS8.2, which seeks to protect and enhance the Arnside and
Silverdale Area of Natural Beauty.
5.4 The Land Allocations DPD needs to recognise the importance of tourist accommodation on
sites within the AONB such as the two caravan parks at Fell End and Hall More. This
means allowing the flexibility to expand whilst seeking to protect the AONB. This should be
within the context of Core Strategy policies CS7.6 and CS5, which seek to maintain and
enhance the strength of tourism.

8. SUMMARY AND CONCLUSIONS
8.1 Emery Planning Partnership is instructed by Pure Leisure Group Ltd to submit
representations to the South Lakeland Land Allocations DPD - Proposed Submission Edition
(March 2012).
8.2 A summary of our representations is as follows:
•?The Land Allocations DPD should be extended so that it provides allocations for
at least a 15 year period in line with the guidance set out in the NPPF. At
present, the consultation document is contrary to national planning policy as it
only provides allocations for up to 2025, which means that only 12-13 years are
planned for, depending on when the Land Allocations DPD is finally adopted.
•?The Land Allocations DPD needs to allocate more land within the first phase
(2012-17) for the following reasons:
- firstly, it is not clear how many dwellings currently benefit from
planning permission. The figure set out in the consultation
document does not seem to correlate to the evidence base, which
suggests a lower figure;
- secondly, the NPPF requires that the Council should identify an
additional 20% of supply in the first five years; and
- finally, the housing trajectory for the first five years as set out in
appendix 4 of the consultation draft is overly ambitious.
•?The Land Allocations DPD should consider bringing forward sites from later
phases to meet the requirement – including the Ulverston Canal Head site.
•?The Land Allocations DPD should provide more flexibility for those sites which
provide tourist accommodation in line with policies CS5 and CS7.6 of the Core
Strategy. As it stands, these sites are not catered for in the consultation
document.
•?Whilst the allocation at the Ulverston Canal Head is broadly welcomed, we
question whether the Council is being overly ambitious in preparing 18
development briefs across the borough and adopting them as SPDs within just
8/9 years. Given the importance of the site and the previous delays in securing
its redevelopment, the development brief for the Ulverston Canal Head should
be prioritised and brought forward to an earlier phase in the plan period.
•?As the masterplan for the Ulverston Canal Head is now seven years old, it is now
out of date. A developer led development brief team should be assembled to
take forward the development brief for the site. Our client should be invited to
join the development brief team.
8.3 This concludes our representations to the South Lakeland Land Allocations DPD - Proposed
Submission Edition (March 2012).

YES, I wish to participate at the oral examination

Examination provides our clients with the opportunity to critically examine the councils position in order to ensure the plan is sound. Oral examination allows for a more forensic examination of the evidence and in depth analysis of the various opinions.

Please notify me

0.5 Section 5

Response refers to Policy 5.3 and paragraphs 5.43 - 5.45

No

The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy

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.

Response refers to Policy 5.3 and paragraphs 5.43 - 5.45

6. SECTION 5 – LAND ALLOCATIONS – ULVERSTON AND FURNESS
6.1 Our client’s site at the Ulverston Abattoir falls within the land allocated for mixed use
development at Ulverston Canal Head as shown on the proposals map 2.3 (site ref: M28).
Paragraphs 5.43 to 5.45 of the consultation document discuss the Canal Head Mixed Use
Site.
6.2 Policy 5.3 – Mixed Use Allocation, Ulverston Canal Head of the consultation document
explains that the allocation is for a mix of housing (with an estimated capacity of 86
dwellings), heritage, leisure and tourism development. This policy continues to state that
1.93 ha of the site would be used for residential use and 2 ha for heritage, leisure and
tourism. The policy considers that the 86 dwellings at the site would be delivered in phase
3 (i.e. 2022-25).
6.3 Policy 5.4 – Land at Ulverston Canal Head – Development Brief explains that a
development brief will be prepared to guide the development of the two sites at the Canal
Head in Ulverston (i.e. the mixed use site described above and a strategic employment
site). In terms of the mixed use site at the canal head, this policy states that development
must make provision for the following:
•?achievement of a ‘sense of place’;
•?a sympathetic setting for grade II listed buildings at Sunderland Terrace;
•?the opening up of views to the canal and basin;
•?the retention and improvement of the canal as a public amenity;
•?the provision of strong pedestrian and cycle connectivity between the different
parts of the canal head site, the strategic employment site, the rest of the canal
corridor and the town centre;
•?the provision of any necessary flood risk mitigation / attenuation measures;
•?the provision of mitigation measures to offset impact of the existing highway
network;
•?the mitigation of any biodiversity impacts;
•?and any necessary works required to the canal itself and arrangements for
maintenance; and
•?a scheme for canal side landscaping.
6.4 In general, we welcome the inclusion of our client’s site in the Land Allocations DPD and
the recognition by the Council that this site could be delivered within the plan period. The
proposed allocation would be in accordance with Core Strategy policy CS3.2
6.5 We do however have some concerns in relation to the proposed allocation as set out
below.
Timetable for the preparation of the development brief
6.6 Paragraph 2.66 of the consultation document states that the development of major and
complex sites will be guided by development briefs. This paragraph confirms that the
development briefs will be Supplementary Planning Documents. Paragraph 2.67 of the
consultation document lists some 18 sites where development briefs are to be prepared in
the plan period. The footnotes to table 1B are also relevant as they state that in terms of
the delivery of sites, the following timescales are assumed:
•?a maximum annual yield of 30 dwellings per site;
•?up to 1 year is anticipated to prepare a development brief (if required); and
•?up to 2 years is anticipated for design and consents on sites of more than 40
dwellings.
6.7 Consequently, on those sites where a development brief is to be prepared, the very latest
year in which a development brief could begin so that there would be some delivery in the
plan period would be 2021 (i.e. 1 year for the development brief, 2 years for the design
and consents and 1 year to deliver a maximum of 30 units). This means that according to
the consultation document, 18 development briefs are to be prepared and adopted within
the first nine years of the plan period (2012-21). This could extend to 18 development
briefs in an eight year period should the Land Allocations DPD not be adopted until 2013.
We question whether this ambition is realistic or whether it accords with the stated aims of
the NPPF which is to promote the development of sites without undue delay and to
promote growth.
6.8 We also note that the 86 dwellings to be delivered at the site are to be delivered in phase
3 (i.e. 2022-25). We question whether given the importance of the site, the fact that an
existing masterplan has already been prepared and the need to identify an additional 20%
of deliverable sites in the first five years in accordance with NPPF as set out above the
development brief could be prioritised and the allocation brought forward earlier in the
plan period than phase 3.
Preparation of the development brief
6.9 Core Strategy policy CS3.2 states that the specific land allocations for the Ulverston Canal
Head and Corridor will be pursued through the Land Allocations DPD, informed by the
Ulverston Canal Head Masterplan and any subsequent review of its contents. Paragraph
5.45 of the consultation document confirms that the allocation is in line with the
masterplan.
6.10 This document, prepared in 2005 identifies our client’s site as ‘Site C’. Section 11 states:
“A prerequisite of the redevelopment at Canal Head will be the
reorganisation of the Auction Mart to create available land. This will
require the acquisition of the adjacent vacant abattoir site to provide
alternative servicing areas for the mart. It would be possible to provide
an experience for visitors, to view the animals and see auctions taking
place. This could be a popular attraction for families and, with
interpretation, could help to improve awareness and understanding of
South Lakeland’s farming industry and local food products. The Auction
Mart Company has indicated that their car parking area could be made
available to the public on non auction days.”
6.11 It is important to note that the masterplan dates back to 2005, and is now seven years
old. Consequently, the proposed development brief should provide the opportunity to
update the proposals for the area with a view to precipitating development quickly on a
site which has been subject to delayed redevelopment proposals since the 1990s. In
particular, the location of housing within the site allocation should be on sites that are
deliverable within the plan period.
6.12 We note that policy 5.4 of the consultation document states that the Council will be
responsible for preparing the development brief. The development brief should be
developer led. Given the importance of our client’s site in relation to the proposals set out
in the masterplan, we request that our client is invited to be a partner in the preparation
of the development brief. We would also add that in the absence of the development brief
progressing, the council should look favourably on development proposals which do not
undermine or prejudice the overall development of the allocation and accord with the
general principles for development of the site.

8. SUMMARY AND CONCLUSIONS
8.1 Emery Planning Partnership is instructed by Pure Leisure Group Ltd to submit
representations to the South Lakeland Land Allocations DPD - Proposed Submission Edition
(March 2012).
8.2 A summary of our representations is as follows:
•?The Land Allocations DPD should be extended so that it provides allocations for
at least a 15 year period in line with the guidance set out in the NPPF. At
present, the consultation document is contrary to national planning policy as it
only provides allocations for up to 2025, which means that only 12-13 years are
planned for, depending on when the Land Allocations DPD is finally adopted.
•?The Land Allocations DPD needs to allocate more land within the first phase
(2012-17) for the following reasons:
- firstly, it is not clear how many dwellings currently benefit from
planning permission. The figure set out in the consultation
document does not seem to correlate to the evidence base, which
suggests a lower figure;
- secondly, the NPPF requires that the Council should identify an
additional 20% of supply in the first five years; and
- finally, the housing trajectory for the first five years as set out in
appendix 4 of the consultation draft is overly ambitious.
•?The Land Allocations DPD should consider bringing forward sites from later
phases to meet the requirement – including the Ulverston Canal Head site.
•?The Land Allocations DPD should provide more flexibility for those sites which
provide tourist accommodation in line with policies CS5 and CS7.6 of the Core
Strategy. As it stands, these sites are not catered for in the consultation
document.
•?Whilst the allocation at the Ulverston Canal Head is broadly welcomed, we
question whether the Council is being overly ambitious in preparing 18
development briefs across the borough and adopting them as SPDs within just
8/9 years. Given the importance of the site and the previous delays in securing
its redevelopment, the development brief for the Ulverston Canal Head should
be prioritised and brought forward to an earlier phase in the plan period.
•?As the masterplan for the Ulverston Canal Head is now seven years old, it is now
out of date. A developer led development brief team should be assembled to
take forward the development brief for the site. Our client should be invited to
join the development brief team.
8.3 This concludes our representations to the South Lakeland Land Allocations DPD - Proposed
Submission Edition (March 2012).

YES, I wish to participate at the oral examination

Examination provides our clients with the opportunity to critically examine the councils position in order to ensure the plan is sound. Oral examination allows for a more forensic examination of the evidence and in depth analysis of the various opinions.

I have read the guidance notes

6.4 Appendix 4

No

The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy

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.

7. APPENDIX 4 – HOUSING TRAJECTORY
7.1 Appendix 4 of the consultation document provides the latest housing trajectory. No figures
are given, but the chart suggests approximately the following will be delivered in the five
year period 2011-16:
•?2011/12 – 275 dwellings
•?2012/13 – 525 dwellings
•?2013/14 – 525 dwellings
•?2014/15 – 525 dwellings
•?2015/16 – 525 dwellings
7.2 We question whether the housing trajectory is realistic – particularly in the years 2012/13
to 2015/16 as the Council has failed to deliver 525 dwellings in any of the previous years
from 2003 to 2011.


8. SUMMARY AND CONCLUSIONS
8.1 Emery Planning Partnership is instructed by Pure Leisure Group Ltd to submit
representations to the South Lakeland Land Allocations DPD - Proposed Submission Edition
(March 2012).
8.2 A summary of our representations is as follows:
•?The Land Allocations DPD should be extended so that it provides allocations for
at least a 15 year period in line with the guidance set out in the NPPF. At
present, the consultation document is contrary to national planning policy as it
only provides allocations for up to 2025, which means that only 12-13 years are
planned for, depending on when the Land Allocations DPD is finally adopted.
•?The Land Allocations DPD needs to allocate more land within the first phase
(2012-17) for the following reasons:
- firstly, it is not clear how many dwellings currently benefit from
planning permission. The figure set out in the consultation
document does not seem to correlate to the evidence base, which
suggests a lower figure;
- secondly, the NPPF requires that the Council should identify an
additional 20% of supply in the first five years; and
- finally, the housing trajectory for the first five years as set out in
appendix 4 of the consultation draft is overly ambitious.
•?The Land Allocations DPD should consider bringing forward sites from later
phases to meet the requirement – including the Ulverston Canal Head site.
•?The Land Allocations DPD should provide more flexibility for those sites which
provide tourist accommodation in line with policies CS5 and CS7.6 of the Core
Strategy. As it stands, these sites are not catered for in the consultation
document.
•?Whilst the allocation at the Ulverston Canal Head is broadly welcomed, we
question whether the Council is being overly ambitious in preparing 18
development briefs across the borough and adopting them as SPDs within just
8/9 years. Given the importance of the site and the previous delays in securing
its redevelopment, the development brief for the Ulverston Canal Head should
be prioritised and brought forward to an earlier phase in the plan period.
•?As the masterplan for the Ulverston Canal Head is now seven years old, it is now
out of date. A developer led development brief team should be assembled to
take forward the development brief for the site. Our client should be invited to
join the development brief team.
8.3 This concludes our representations to the South Lakeland Land Allocations DPD - Proposed
Submission Edition (March 2012).

YES, I wish to participate at the oral examination

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