5 responses from Mr Jason Horner, c/o Steven Abbott Associates LLP
1. Mr Jason Horner, c/o Steven Abbott Associates LLP : 23 May 2012 13:55:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
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Policy/Site No.
LA1.1 Development Boundaries- NATLAND
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 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.
Representations by Jason Horner
Site at Natland
1. These representations are made on behalf of Jason Horner and relate to a site identified as part of a proposed Green Gap on the eastern edge of Natland. We believe that a portion of the proposed Green Gap immediately adjoining the current settlement boundary formed by existing houses on Longmeadow Lane should be excluded from the proposed Green gap and should be allocated for housing as an alternative. Representations at previous stages of the DPD process have indicated a modest level of additional housing in this location as a logical and beneficial rounding off of the settlement on this edge of the settlement of Natland.
2. In our view the rounding off will provide an opportunity to provide a more appropriately treated and ‘softer’ visual and physical edge to Natland which will actually augment the ability of the remaining open land to act as a Green Gap between Natland and Oxenholme.
3. The rest of these representations will put forward the need for additional housing allocations to be made to ensure that the Council’s objectively assessed housing needs are met in full.
4. The NPPF (paragraph 182) sets out the matters that will be considered through Local Plan Examination, namely:
• Positively prepared – the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development;
• Justified – the plan would be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence;
• Effective – the plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities; and
• Consistent with national policy – the plan should enable the delivery of sustainable development in accordance with the policies in the Framework.
5. We believe that changes to the DPD are required in order to make it sound. As currently drafted we do not believe that the housing aspects of the DPD represent a plan which is positively prepared or which is consistent with national policy. In particular the LPA faces significant challenges associated with housing delivery (including a past record of under-delivery) and it is imperative that the policy framework in the DPD promotes and encourages the early delivery of new housing.
6. The following aspects of the NPPF are particularly relevant:
• Paragraph 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, so far as is consistent with the policies set out in this framework, including identifying sites which are critical to the delivery of the housing strategy over the plan period;
- 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% (moved forward from later in the plan period) to provide a realistic prospect of achieving the planning supply and to ensure choice and competition in the market for land;
- identify a supply of specific, developable sites or broad locations for growth, for years 6-10 and, where possible, for years 11-15;
- for market and affordable housing, illustrate the expected rate of housing delivery through a housing trajectory for the plan period and set out a housing implementation strategy for the full range of housing describing how they will maintain delivery of a five-year supply of housing land to meet their housing target; and
- set out their own approach to housing density to reflect local circumstances.”
7. South Lakeland District Council is in a position where there has been a record of persistent under delivery of housing. That is clear if one considers the five year housing land position (based on the most up-to-date information) for South Lakeland. We have utilised the Housing Land Position Statement 2011 as the most up-to-date information. Table 4.1 has been utilised as the basis for our assessment.
Annual Requirement 2003-2011 (8 years) = 3,200 (400 p.a.)
Net Completions 2003-2011 (8 years) = 1,690 (211 p.a.)
Shortfall – 1,511 dwellings
Five Year Requirement – 3,510 (1,510 shortfall plus 5 x 400)
• annual requirement – 702
Sites with Planning Permission – 947
That represents a mere 1.35 year supply of sites in terms of committed sites with planning permission. Even if one adds in 94 dwellings on sites in progress through the planning system only 1,041 dwellings are likely, or a 1.48 year supply.
The 2,677 SHLAA Category 1 sites are effectively “windfall” sites at this stage, and should not be considered to be deliverable. They should not be relied upon as a committed source of housing supply.
Despite the best efforts of the author of the Housing Land Position Statement 2011 we do not believe that Table 4.1 provides a realistic and robust assessment of the five year supply position.
8. That record of under delivery is also clear from the table provided at paragraph 2.8 of the DPD. It is of concern that paragraph 2.8 refers to the “ambition to deliver 400 dwellings per year between 2003 and 2025.” That term “ambition” is also used within Table 1A of the DPD.
For clarity Policy CS 6.1 of the adopted Core Strategy sets a “housing requirement” of 400 dwellings which should be met. The DPD should properly recognise that requirement as such and not refer to it as an ambition. The DPD must clearly and unequivocally ensure that the full objectively assessed need for new housing is planned for and met if it is to accord with paragraph 47 of the NPPF.
9. Furthermore, because of the record of persistent under delivery the DPD should seek to ensure that five years worth supply of sites for housing plus a 20% buffer is provided for (moved forward from later in the plan period).
10. Other parties will be making combined representations suggesting that the DPD is not sound because it does not provide a policy framework which will meet the full, objectively assessed needs for market and affordable housing in South Lakeland. We concur with those general representations. As a result it will be necessary, in our view, for additional deliverable sites to be identified in the DPD, in particular to meet the short term needs generated by the historic pattern of under delivery.
11. Currently the edge of the developed part of Natland at Longmeadow Lane is visually harsh, primarily due to the absence of a meaningful landscape treatment. The Council is seeking to establish a Green Gap which will ensure that the identity of Natland with Oxenholme will not be compromised. The text at paragraph 2.58 of the DPD suggests that Green Gaps will be identified on land which:
• If developed, would cause or add to the risk of future coalescence of the two or more settlements between which it is important to retain a distinction;
• Helps to maintain a settlement’s identity, setting and character;
• Is predominantly open and maintains an open aspect;
• Affords recreational and biodiversity opportunities.
12. In our view the limited area in question is not required in respect of those bullet points. In particular we would dispute that the area in question, if developed, would cause or add to the risk of future coalescence of Natland and Oxenholme. The raised railway line which runs in the area between Natland and Oxenholme creates an absolute physical buffer which avoids potential coalescence. Furthermore, the topography of the area is such that visually the site we promote could be developed without apparent encroachment. Furthermore, we would envisage carefully refined proposals which would ensure that any development would reflect the identity, setting and character of Natland .
13. It is recognised that the area to the east of Longmeadow Lane, Natland up to the railway line is currently open. However, it is envisaged that any scheme would include substantial buffer screening beyond the proposed housing development. This would have the dual effect of maintaining the setting of Natland by providing a more rural landscaped edge (in contrast to the rather stark developed edge which currently exists), and affording much greater recreational and/or biodiversity opportunities.
14. We note other proposed allocations elsewhere at Natland which will involve use of currently open areas. We do not believe that the allocation of land for housing on a limited area to the east of Longmeadow Lane would compromise the objectives or function of the proposed Green Gap. On the contrary we would suggest that a carefully conceived and modest development could secure a long term boundary to the east of Natland which is robust in the long term and which would be desirable in visual impact and landscape terms.
15. For these reasons we request the following changes to the DPD:
• Amendment of the Natland Settlement Boundary/Green Gap Boundary to the east of Longmeadow Lane, Natland;
• The allocation of a modest area of land to the east of Longmeadow Lane for housing under Policy LA1.3;
16. These changes would ensure that the DPD was sound in terms of the consideration of reasonable alternatives and ensuring that the most appropriate strategy is adopted for this locality.
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.
To assist the Inspector's understanding of key issues and to thoroughly present the objectors case
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
2. Mr Jason Horner, c/o Steven Abbott Associates LLP : 23 May 2012 14:00:00
A typed or handwritten document was submitted. This has been scanned and can be downloaded below:
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations
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 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.
Representations by Jason Horner
Site at Natland
1. These representations are made on behalf of Jason Horner and relate to a site identified as part of a proposed Green Gap on the eastern edge of Natland. We believe that a portion of the proposed Green Gap immediately adjoining the current settlement boundary formed by existing houses on Longmeadow Lane should be excluded from the proposed Green gap and should be allocated for housing as an alternative. Representations at previous stages of the DPD process have indicated a modest level of additional housing in this location as a logical and beneficial rounding off of the settlement on this edge of the settlement of Natland.
2. In our view the rounding off will provide an opportunity to provide a more appropriately treated and ‘softer’ visual and physical edge to Natland which will actually augment the ability of the remaining open land to act as a Green Gap between Natland and Oxenholme.
3. The rest of these representations will put forward the need for additional housing allocations to be made to ensure that the Council’s objectively assessed housing needs are met in full.
4. The NPPF (paragraph 182) sets out the matters that will be considered through Local Plan Examination, namely:
• Positively prepared – the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development;
• Justified – the plan would be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence;
• Effective – the plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities; and
• Consistent with national policy – the plan should enable the delivery of sustainable development in accordance with the policies in the Framework.
5. We believe that changes to the DPD are required in order to make it sound. As currently drafted we do not believe that the housing aspects of the DPD represent a plan which is positively prepared or which is consistent with national policy. In particular the LPA faces significant challenges associated with housing delivery (including a past record of under-delivery) and it is imperative that the policy framework in the DPD promotes and encourages the early delivery of new housing.
6. The following aspects of the NPPF are particularly relevant:
• Paragraph 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, so far as is consistent with the policies set out in this framework, including identifying sites which are critical to the delivery of the housing strategy over the plan period;
- 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% (moved forward from later in the plan period) to provide a realistic prospect of achieving the planning supply and to ensure choice and competition in the market for land;
- identify a supply of specific, developable sites or broad locations for growth, for years 6-10 and, where possible, for years 11-15;
- for market and affordable housing, illustrate the expected rate of housing delivery through a housing trajectory for the plan period and set out a housing implementation strategy for the full range of housing describing how they will maintain delivery of a five-year supply of housing land to meet their housing target; and
- set out their own approach to housing density to reflect local circumstances.”
7. South Lakeland District Council is in a position where there has been a record of persistent under delivery of housing. That is clear if one considers the five year housing land position (based on the most up-to-date information) for South Lakeland. We have utilised the Housing Land Position Statement 2011 as the most up-to-date information. Table 4.1 has been utilised as the basis for our assessment.
Annual Requirement 2003-2011 (8 years) = 3,200 (400 p.a.)
Net Completions 2003-2011 (8 years) = 1,690 (211 p.a.)
Shortfall – 1,511 dwellings
Five Year Requirement – 3,510 (1,510 shortfall plus 5 x 400)
• annual requirement – 702
Sites with Planning Permission – 947
That represents a mere 1.35 year supply of sites in terms of committed sites with planning permission. Even if one adds in 94 dwellings on sites in progress through the planning system only 1,041 dwellings are likely, or a 1.48 year supply.
The 2,677 SHLAA Category 1 sites are effectively “windfall” sites at this stage, and should not be considered to be deliverable. They should not be relied upon as a committed source of housing supply.
Despite the best efforts of the author of the Housing Land Position Statement 2011 we do not believe that Table 4.1 provides a realistic and robust assessment of the five year supply position.
8. That record of under delivery is also clear from the table provided at paragraph 2.8 of the DPD. It is of concern that paragraph 2.8 refers to the “ambition to deliver 400 dwellings per year between 2003 and 2025.” That term “ambition” is also used within Table 1A of the DPD.
For clarity Policy CS 6.1 of the adopted Core Strategy sets a “housing requirement” of 400 dwellings which should be met. The DPD should properly recognise that requirement as such and not refer to it as an ambition. The DPD must clearly and unequivocally ensure that the full objectively assessed need for new housing is planned for and met if it is to accord with paragraph 47 of the NPPF.
9. Furthermore, because of the record of persistent under delivery the DPD should seek to ensure that five years worth supply of sites for housing plus a 20% buffer is provided for (moved forward from later in the plan period).
10. Other parties will be making combined representations suggesting that the DPD is not sound because it does not provide a policy framework which will meet the full, objectively assessed needs for market and affordable housing in South Lakeland. We concur with those general representations. As a result it will be necessary, in our view, for additional deliverable sites to be identified in the DPD, in particular to meet the short term needs generated by the historic pattern of under delivery.
11. Currently the edge of the developed part of Natland at Longmeadow Lane is visually harsh, primarily due to the absence of a meaningful landscape treatment. The Council is seeking to establish a Green Gap which will ensure that the identity of Natland with Oxenholme will not be compromised. The text at paragraph 2.58 of the DPD suggests that Green Gaps will be identified on land which:
• If developed, would cause or add to the risk of future coalescence of the two or more settlements between which it is important to retain a distinction;
• Helps to maintain a settlement’s identity, setting and character;
• Is predominantly open and maintains an open aspect;
• Affords recreational and biodiversity opportunities.
12. In our view the limited area in question is not required in respect of those bullet points. In particular we would dispute that the area in question, if developed, would cause or add to the risk of future coalescence of Natland and Oxenholme. The raised railway line which runs in the area between Natland and Oxenholme creates an absolute physical buffer which avoids potential coalescence. Furthermore, the topography of the area is such that visually the site we promote could be developed without apparent encroachment. Furthermore, we would envisage carefully refined proposals which would ensure that any development would reflect the identity, setting and character of Natland .
13. It is recognised that the area to the east of Longmeadow Lane, Natland up to the railway line is currently open. However, it is envisaged that any scheme would include substantial buffer screening beyond the proposed housing development. This would have the dual effect of maintaining the setting of Natland by providing a more rural landscaped edge (in contrast to the rather stark developed edge which currently exists), and affording much greater recreational and/or biodiversity opportunities.
14. We note other proposed allocations elsewhere at Natland which will involve use of currently open areas. We do not believe that the allocation of land for housing on a limited area to the east of Longmeadow Lane would compromise the objectives or function of the proposed Green Gap. On the contrary we would suggest that a carefully conceived and modest development could secure a long term boundary to the east of Natland which is robust in the long term and which would be desirable in visual impact and landscape terms.
15. For these reasons we request the following changes to the DPD:
• Amendment of the Natland Settlement Boundary/Green Gap Boundary to the east of Longmeadow Lane, Natland;
• The allocation of a modest area of land to the east of Longmeadow Lane for housing under Policy LA1.3;
16. These changes would ensure that the DPD was sound in terms of the consideration of reasonable alternatives and ensuring that the most appropriate strategy is adopted for this locality.
For clarification re site ref see text below (see also attached plan):
The lack of clarity stems from the fact that the online submission facility did not include an opportunity to upload site plans to identify the area in question.
I have attached a sketch plan produced by JMP Architects on which I have highlighted the area to which the representations apply with a solid red line. The broken red edge indicates other land in the same ownership which could be provided as managed informal open space/landscaped areas in order to reinforce the Green Wedge concept.
I hope this clarification is of assistance.
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.
to assist the Inspector's understanding of key issues and thoroughly present the objectors case
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
3. Mr Jason Horner, c/o Steven Abbott Associates LLP : 23 May 2012 14:03:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.9 Green Gaps between - OXENHOLME and NATLAND
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 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.
Representations by Jason Horner
Site at Natland
1. These representations are made on behalf of Jason Horner and relate to a site identified as part of a proposed Green Gap on the eastern edge of Natland. We believe that a portion of the proposed Green Gap immediately adjoining the current settlement boundary formed by existing houses on Longmeadow Lane should be excluded from the proposed Green gap and should be allocated for housing as an alternative. Representations at previous stages of the DPD process have indicated a modest level of additional housing in this location as a logical and beneficial rounding off of the settlement on this edge of the settlement of Natland.
2. In our view the rounding off will provide an opportunity to provide a more appropriately treated and ‘softer’ visual and physical edge to Natland which will actually augment the ability of the remaining open land to act as a Green Gap between Natland and Oxenholme.
3. The rest of these representations will put forward the need for additional housing allocations to be made to ensure that the Council’s objectively assessed housing needs are met in full.
4. The NPPF (paragraph 182) sets out the matters that will be considered through Local Plan Examination, namely:
• Positively prepared – the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development;
• Justified – the plan would be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence;
• Effective – the plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities; and
• Consistent with national policy – the plan should enable the delivery of sustainable development in accordance with the policies in the Framework.
5. We believe that changes to the DPD are required in order to make it sound. As currently drafted we do not believe that the housing aspects of the DPD represent a plan which is positively prepared or which is consistent with national policy. In particular the LPA faces significant challenges associated with housing delivery (including a past record of under-delivery) and it is imperative that the policy framework in the DPD promotes and encourages the early delivery of new housing.
6. The following aspects of the NPPF are particularly relevant:
• Paragraph 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, so far as is consistent with the policies set out in this framework, including identifying sites which are critical to the delivery of the housing strategy over the plan period;
- 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% (moved forward from later in the plan period) to provide a realistic prospect of achieving the planning supply and to ensure choice and competition in the market for land;
- identify a supply of specific, developable sites or broad locations for growth, for years 6-10 and, where possible, for years 11-15;
- for market and affordable housing, illustrate the expected rate of housing delivery through a housing trajectory for the plan period and set out a housing implementation strategy for the full range of housing describing how they will maintain delivery of a five-year supply of housing land to meet their housing target; and
- set out their own approach to housing density to reflect local circumstances.”
7. South Lakeland District Council is in a position where there has been a record of persistent under delivery of housing. That is clear if one considers the five year housing land position (based on the most up-to-date information) for South Lakeland. We have utilised the Housing Land Position Statement 2011 as the most up-to-date information. Table 4.1 has been utilised as the basis for our assessment.
Annual Requirement 2003-2011 (8 years) = 3,200 (400 p.a.)
Net Completions 2003-2011 (8 years) = 1,690 (211 p.a.)
Shortfall – 1,511 dwellings
Five Year Requirement – 3,510 (1,510 shortfall plus 5 x 400)
• annual requirement – 702
Sites with Planning Permission – 947
That represents a mere 1.35 year supply of sites in terms of committed sites with planning permission. Even if one adds in 94 dwellings on sites in progress through the planning system only 1,041 dwellings are likely, or a 1.48 year supply.
The 2,677 SHLAA Category 1 sites are effectively “windfall” sites at this stage, and should not be considered to be deliverable. They should not be relied upon as a committed source of housing supply.
Despite the best efforts of the author of the Housing Land Position Statement 2011 we do not believe that Table 4.1 provides a realistic and robust assessment of the five year supply position.
8. That record of under delivery is also clear from the table provided at paragraph 2.8 of the DPD. It is of concern that paragraph 2.8 refers to the “ambition to deliver 400 dwellings per year between 2003 and 2025.” That term “ambition” is also used within Table 1A of the DPD.
For clarity Policy CS 6.1 of the adopted Core Strategy sets a “housing requirement” of 400 dwellings which should be met. The DPD should properly recognise that requirement as such and not refer to it as an ambition. The DPD must clearly and unequivocally ensure that the full objectively assessed need for new housing is planned for and met if it is to accord with paragraph 47 of the NPPF.
9. Furthermore, because of the record of persistent under delivery the DPD should seek to ensure that five years worth supply of sites for housing plus a 20% buffer is provided for (moved forward from later in the plan period).
10. Other parties will be making combined representations suggesting that the DPD is not sound because it does not provide a policy framework which will meet the full, objectively assessed needs for market and affordable housing in South Lakeland. We concur with those general representations. As a result it will be necessary, in our view, for additional deliverable sites to be identified in the DPD, in particular to meet the short term needs generated by the historic pattern of under delivery.
11. Currently the edge of the developed part of Natland at Longmeadow Lane is visually harsh, primarily due to the absence of a meaningful landscape treatment. The Council is seeking to establish a Green Gap which will ensure that the identity of Natland with Oxenholme will not be compromised. The text at paragraph 2.58 of the DPD suggests that Green Gaps will be identified on land which:
• If developed, would cause or add to the risk of future coalescence of the two or more settlements between which it is important to retain a distinction;
• Helps to maintain a settlement’s identity, setting and character;
• Is predominantly open and maintains an open aspect;
• Affords recreational and biodiversity opportunities.
12. In our view the limited area in question is not required in respect of those bullet points. In particular we would dispute that the area in question, if developed, would cause or add to the risk of future coalescence of Natland and Oxenholme. The raised railway line which runs in the area between Natland and Oxenholme creates an absolute physical buffer which avoids potential coalescence. Furthermore, the topography of the area is such that visually the site we promote could be developed without apparent encroachment. Furthermore, we would envisage carefully refined proposals which would ensure that any development would reflect the identity, setting and character of Natland .
13. It is recognised that the area to the east of Longmeadow Lane, Natland up to the railway line is currently open. However, it is envisaged that any scheme would include substantial buffer screening beyond the proposed housing development. This would have the dual effect of maintaining the setting of Natland by providing a more rural landscaped edge (in contrast to the rather stark developed edge which currently exists), and affording much greater recreational and/or biodiversity opportunities.
14. We note other proposed allocations elsewhere at Natland which will involve use of currently open areas. We do not believe that the allocation of land for housing on a limited area to the east of Longmeadow Lane would compromise the objectives or function of the proposed Green Gap. On the contrary we would suggest that a carefully conceived and modest development could secure a long term boundary to the east of Natland which is robust in the long term and which would be desirable in visual impact and landscape terms.
15. For these reasons we request the following changes to the DPD:
• Amendment of the Natland Settlement Boundary/Green Gap Boundary to the east of Longmeadow Lane, Natland;
• The allocation of a modest area of land to the east of Longmeadow Lane for housing under Policy LA1.3;
16. These changes would ensure that the DPD was sound in terms of the consideration of reasonable alternatives and ensuring that the most appropriate strategy is adopted for this locality.
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.
To assist the Inspectors understanding of the key issues and provide an opportunity for the objectors case to be thoroughly presented
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
4. Mr Jason Horner, c/o Steven Abbott Associates LLP : 24 May 2012 12:03:00
A typed or handwritten document was submitted. This has been scanned and can be downloaded below:
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
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
RN303#
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 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.
Representations by Jason Horner
Site at Natland
1. These representations are made on behalf of Jason Horner and relate to a site identified as part of a proposed Green Gap on the eastern edge of Natland. We believe that a portion of the proposed Green Gap immediately adjoining the current settlement boundary formed by existing houses on Longmeadow Lane should be excluded from the proposed Green gap and should be allocated for housing as an alternative. Representations at previous stages of the DPD process have indicated a modest level of additional housing in this location as a logical and beneficial rounding off of the settlement on this edge of the settlement of Natland.
2. In our view the rounding off will provide an opportunity to provide a more appropriately treated and ‘softer’ visual and physical edge to Natland which will actually augment the ability of the remaining open land to act as a Green Gap between Natland and Oxenholme.
3. The rest of these representations will put forward the need for additional housing allocations to be made to ensure that the Council’s objectively assessed housing needs are met in full.
4. The NPPF (paragraph 182) sets out the matters that will be considered through Local Plan Examination, namely:
• Positively prepared – the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development;
• Justified – the plan would be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence;
• Effective – the plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities; and
• Consistent with national policy – the plan should enable the delivery of sustainable development in accordance with the policies in the Framework.
5. We believe that changes to the DPD are required in order to make it sound. As currently drafted we do not believe that the housing aspects of the DPD represent a plan which is positively prepared or which is consistent with national policy. In particular the LPA faces significant challenges associated with housing delivery (including a past record of under-delivery) and it is imperative that the policy framework in the DPD promotes and encourages the early delivery of new housing.
6. The following aspects of the NPPF are particularly relevant:
• Paragraph 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, so far as is consistent with the policies set out in this framework, including identifying sites which are critical to the delivery of the housing strategy over the plan period;
- 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% (moved forward from later in the plan period) to provide a realistic prospect of achieving the planning supply and to ensure choice and competition in the market for land;
- identify a supply of specific, developable sites or broad locations for growth, for years 6-10 and, where possible, for years 11-15;
- for market and affordable housing, illustrate the expected rate of housing delivery through a housing trajectory for the plan period and set out a housing implementation strategy for the full range of housing describing how they will maintain delivery of a five-year supply of housing land to meet their housing target; and
- set out their own approach to housing density to reflect local circumstances.”
7. South Lakeland District Council is in a position where there has been a record of persistent under delivery of housing. That is clear if one considers the five year housing land position (based on the most up-to-date information) for South Lakeland. We have utilised the Housing Land Position Statement 2011 as the most up-to-date information. Table 4.1 has been utilised as the basis for our assessment.
Annual Requirement 2003-2011 (8 years) = 3,200 (400 p.a.)
Net Completions 2003-2011 (8 years) = 1,690 (211 p.a.)
Shortfall – 1,511 dwellings
Five Year Requirement – 3,510 (1,510 shortfall plus 5 x 400)
• annual requirement – 702
Sites with Planning Permission – 947
That represents a mere 1.35 year supply of sites in terms of committed sites with planning permission. Even if one adds in 94 dwellings on sites in progress through the planning system only 1,041 dwellings are likely, or a 1.48 year supply.
The 2,677 SHLAA Category 1 sites are effectively “windfall” sites at this stage, and should not be considered to be deliverable. They should not be relied upon as a committed source of housing supply.
Despite the best efforts of the author of the Housing Land Position Statement 2011 we do not believe that Table 4.1 provides a realistic and robust assessment of the five year supply position.
8. That record of under delivery is also clear from the table provided at paragraph 2.8 of the DPD. It is of concern that paragraph 2.8 refers to the “ambition to deliver 400 dwellings per year between 2003 and 2025.” That term “ambition” is also used within Table 1A of the DPD.
For clarity Policy CS 6.1 of the adopted Core Strategy sets a “housing requirement” of 400 dwellings which should be met. The DPD should properly recognise that requirement as such and not refer to it as an ambition. The DPD must clearly and unequivocally ensure that the full objectively assessed need for new housing is planned for and met if it is to accord with paragraph 47 of the NPPF.
9. Furthermore, because of the record of persistent under delivery the DPD should seek to ensure that five years worth supply of sites for housing plus a 20% buffer is provided for (moved forward from later in the plan period).
10. Other parties will be making combined representations suggesting that the DPD is not sound because it does not provide a policy framework which will meet the full, objectively assessed needs for market and affordable housing in South Lakeland. We concur with those general representations. As a result it will be necessary, in our view, for additional deliverable sites to be identified in the DPD, in particular to meet the short term needs generated by the historic pattern of under delivery.
11. Currently the edge of the developed part of Natland at Longmeadow Lane is visually harsh, primarily due to the absence of a meaningful landscape treatment. The Council is seeking to establish a Green Gap which will ensure that the identity of Natland with Oxenholme will not be compromised. The text at paragraph 2.58 of the DPD suggests that Green Gaps will be identified on land which:
• If developed, would cause or add to the risk of future coalescence of the two or more settlements between which it is important to retain a distinction;
• Helps to maintain a settlement’s identity, setting and character;
• Is predominantly open and maintains an open aspect;
• Affords recreational and biodiversity opportunities.
12. In our view the limited area in question is not required in respect of those bullet points. In particular we would dispute that the area in question, if developed, would cause or add to the risk of future coalescence of Natland and Oxenholme. The raised railway line which runs in the area between Natland and Oxenholme creates an absolute physical buffer which avoids potential coalescence. Furthermore, the topography of the area is such that visually the site we promote could be developed without apparent encroachment. Furthermore, we would envisage carefully refined proposals which would ensure that any development would reflect the identity, setting and character of Natland .
13. It is recognised that the area to the east of Longmeadow Lane, Natland up to the railway line is currently open. However, it is envisaged that any scheme would include substantial buffer screening beyond the proposed housing development. This would have the dual effect of maintaining the setting of Natland by providing a more rural landscaped edge (in contrast to the rather stark developed edge which currently exists), and affording much greater recreational and/or biodiversity opportunities.
14. We note other proposed allocations elsewhere at Natland which will involve use of currently open areas. We do not believe that the allocation of land for housing on a limited area to the east of Longmeadow Lane would compromise the objectives or function of the proposed Green Gap. On the contrary we would suggest that a carefully conceived and modest development could secure a long term boundary to the east of Natland which is robust in the long term and which would be desirable in visual impact and landscape terms.
15. For these reasons we request the following changes to the DPD:
• Amendment of the Natland Settlement Boundary/Green Gap Boundary to the east of Longmeadow Lane, Natland;
• The allocation of a modest area of land to the east of Longmeadow Lane for housing under Policy LA1.3;
16. These changes would ensure that the DPD was sound in terms of the consideration of reasonable alternatives and ensuring that the most appropriate strategy is adopted for this locality.
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.
To assist the Inspector's understanding of key issues and to thoroughly present the objectors case
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
5. Mr Jason Horner, c/o Steven Abbott Associates LLP : 24 May 2012 12:09:00
A typed or handwritten document was submitted. This has been scanned and can be downloaded below:
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
2.18
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 consistent with national policy.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
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.
Representations by Jason Horner
Site at Natland
1. These representations are made on behalf of Jason Horner and relate to a site identified as part of a proposed Green Gap on the eastern edge of Natland. We believe that a portion of the proposed Green Gap immediately adjoining the current settlement boundary formed by existing houses on Longmeadow Lane should be excluded from the proposed Green gap and should be allocated for housing as an alternative. Representations at previous stages of the DPD process have indicated a modest level of additional housing in this location as a logical and beneficial rounding off of the settlement on this edge of the settlement of Natland.
2. In our view the rounding off will provide an opportunity to provide a more appropriately treated and ‘softer’ visual and physical edge to Natland which will actually augment the ability of the remaining open land to act as a Green Gap between Natland and Oxenholme.
3. The rest of these representations will put forward the need for additional housing allocations to be made to ensure that the Council’s objectively assessed housing needs are met in full.
4. The NPPF (paragraph 182) sets out the matters that will be considered through Local Plan Examination, namely:
• Positively prepared – the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development;
• Justified – the plan would be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence;
• Effective – the plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities; and
• Consistent with national policy – the plan should enable the delivery of sustainable development in accordance with the policies in the Framework.
5. We believe that changes to the DPD are required in order to make it sound. As currently drafted we do not believe that the housing aspects of the DPD represent a plan which is positively prepared or which is consistent with national policy. In particular the LPA faces significant challenges associated with housing delivery (including a past record of under-delivery) and it is imperative that the policy framework in the DPD promotes and encourages the early delivery of new housing.
6. The following aspects of the NPPF are particularly relevant:
• Paragraph 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, so far as is consistent with the policies set out in this framework, including identifying sites which are critical to the delivery of the housing strategy over the plan period;
- 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% (moved forward from later in the plan period) to provide a realistic prospect of achieving the planning supply and to ensure choice and competition in the market for land;
- identify a supply of specific, developable sites or broad locations for growth, for years 6-10 and, where possible, for years 11-15;
- for market and affordable housing, illustrate the expected rate of housing delivery through a housing trajectory for the plan period and set out a housing implementation strategy for the full range of housing describing how they will maintain delivery of a five-year supply of housing land to meet their housing target; and
- set out their own approach to housing density to reflect local circumstances.”
7. South Lakeland District Council is in a position where there has been a record of persistent under delivery of housing. That is clear if one considers the five year housing land position (based on the most up-to-date information) for South Lakeland. We have utilised the Housing Land Position Statement 2011 as the most up-to-date information. Table 4.1 has been utilised as the basis for our assessment.
Annual Requirement 2003-2011 (8 years) = 3,200 (400 p.a.)
Net Completions 2003-2011 (8 years) = 1,690 (211 p.a.)
Shortfall – 1,511 dwellings
Five Year Requirement – 3,510 (1,510 shortfall plus 5 x 400)
• annual requirement – 702
Sites with Planning Permission – 947
That represents a mere 1.35 year supply of sites in terms of committed sites with planning permission. Even if one adds in 94 dwellings on sites in progress through the planning system only 1,041 dwellings are likely, or a 1.48 year supply.
The 2,677 SHLAA Category 1 sites are effectively “windfall” sites at this stage, and should not be considered to be deliverable. They should not be relied upon as a committed source of housing supply.
Despite the best efforts of the author of the Housing Land Position Statement 2011 we do not believe that Table 4.1 provides a realistic and robust assessment of the five year supply position.
8. That record of under delivery is also clear from the table provided at paragraph 2.8 of the DPD. It is of concern that paragraph 2.8 refers to the “ambition to deliver 400 dwellings per year between 2003 and 2025.” That term “ambition” is also used within Table 1A of the DPD.
For clarity Policy CS 6.1 of the adopted Core Strategy sets a “housing requirement” of 400 dwellings which should be met. The DPD should properly recognise that requirement as such and not refer to it as an ambition. The DPD must clearly and unequivocally ensure that the full objectively assessed need for new housing is planned for and met if it is to accord with paragraph 47 of the NPPF.
9. Furthermore, because of the record of persistent under delivery the DPD should seek to ensure that five years worth supply of sites for housing plus a 20% buffer is provided for (moved forward from later in the plan period).
10. Other parties will be making combined representations suggesting that the DPD is not sound because it does not provide a policy framework which will meet the full, objectively assessed needs for market and affordable housing in South Lakeland. We concur with those general representations. As a result it will be necessary, in our view, for additional deliverable sites to be identified in the DPD, in particular to meet the short term needs generated by the historic pattern of under delivery.
11. Currently the edge of the developed part of Natland at Longmeadow Lane is visually harsh, primarily due to the absence of a meaningful landscape treatment. The Council is seeking to establish a Green Gap which will ensure that the identity of Natland with Oxenholme will not be compromised. The text at paragraph 2.58 of the DPD suggests that Green Gaps will be identified on land which:
• If developed, would cause or add to the risk of future coalescence of the two or more settlements between which it is important to retain a distinction;
• Helps to maintain a settlement’s identity, setting and character;
• Is predominantly open and maintains an open aspect;
• Affords recreational and biodiversity opportunities.
12. In our view the limited area in question is not required in respect of those bullet points. In particular we would dispute that the area in question, if developed, would cause or add to the risk of future coalescence of Natland and Oxenholme. The raised railway line which runs in the area between Natland and Oxenholme creates an absolute physical buffer which avoids potential coalescence. Furthermore, the topography of the area is such that visually the site we promote could be developed without apparent encroachment. Furthermore, we would envisage carefully refined proposals which would ensure that any development would reflect the identity, setting and character of Natland .
13. It is recognised that the area to the east of Longmeadow Lane, Natland up to the railway line is currently open. However, it is envisaged that any scheme would include substantial buffer screening beyond the proposed housing development. This would have the dual effect of maintaining the setting of Natland by providing a more rural landscaped edge (in contrast to the rather stark developed edge which currently exists), and affording much greater recreational and/or biodiversity opportunities.
14. We note other proposed allocations elsewhere at Natland which will involve use of currently open areas. We do not believe that the allocation of land for housing on a limited area to the east of Longmeadow Lane would compromise the objectives or function of the proposed Green Gap. On the contrary we would suggest that a carefully conceived and modest development could secure a long term boundary to the east of Natland which is robust in the long term and which would be desirable in visual impact and landscape terms.
15. For these reasons we request the following changes to the DPD:
• Amendment of the Natland Settlement Boundary/Green Gap Boundary to the east of Longmeadow Lane, Natland;
• The allocation of a modest area of land to the east of Longmeadow Lane for housing under Policy LA1.3;
16. These changes would ensure that the DPD was sound in terms of the consideration of reasonable alternatives and ensuring that the most appropriate strategy is adopted for this locality.
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.
To assist the Inspectors understanding of the key issues and provide an opportunity for the objectors case to be thoroughly presented
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
