5 responses from Mr Richard Johnston (Individual)
1. Mr Richard Johnston (Individual) : 20 Mar 2012 10:37:00
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Policy/Site No.
LA1.3 Housing Allocations - Site Omission
If you have selected a ‘Site omission’ please enter the site reference or location and relevant policy below
Site R209
East of Lindal in Furness (adjacent the A590T)
Policy LA1.3
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The Land Allocations Document (DPD) is not within the Local Development Scheme and the key stages have not been followed
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
There was no public consultation in regard to land allocation prior to the adoption of the core strategy. In particular the draft document allowed for a 'Local Service Centre' at Lindal in Furness and this was excluded from the final document without proper consultation
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 effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Lindal in Furness - I am aware that site R209 was put forward as an alternative site by a number of residents of Swarthmoor and Cross - a - Moor etc. during the latest round of public consultation. Whilst searching on Google for Ore Mill Sidings Lindal, I came across a report dated February 2012 by SLDC www.southlakeland.gov.uk/.../LINDAL%2010%20 FURNESS.pdf The report entitled 'South Lakeland Local Development Framework Land Allocations Development Plan Document' Lindal in Furness Fact File is probably available on SLDC's normal website but I have been unable to find it by this method.
The report acknowledges that the site was regarded as category 1 for sustainability and deliverability in the study commissioned by SLDC. That same study also stated that the site was brown field (it has had a history of industrial use from 1850 to 1962). Previousl;y the Council described the site as derelict with nil use. In the 2012 report the designation has now changed to a green field site. My understanding of the term green field is land that has no history of development whatsoever and this is clearly not the case. I submit that the Council are seeking to mislead the inspector and the general public as well as making it more difficult to obtain planning permission in the future in line with the new NPPF policy.
The comments of the CPRE are contrary to those of the consultants appointed by the SLDC and I doubt if the CPRE have ever visited the site unlike the consultants. The site clearly lies within the confines of the existing village with speed limits, village signing and housing adjacent on two sides, East View and Bank Terrace. I feel that the CPRE comments are generic once they have been provided with certain information by SLDC and the site was not considered by the CPRE in isolation.
With particular regard to site R209, Land at Ulverston Road, Lindal in Furness, the early documents proposed a combination of 89 houses and employment land with the site having been identified as a 'local service centre' and with the site being described as A1, by external consultants, with regard to developability and sustainability. The site is 'brown field' having previously been railway sidings and a crushing mill etc.
In a planning appeal against the refusal for a disabled person's bungalow the council gave as one of their reasons for refusal was that the land had been identified for development in the forthcoming LDF plan.
I considered that the core strategy document in its draft form was sound and that the development of various 'local service centres' was an excellent idea which could meet the needs of local housing, including low cost, and local employment thereby removing the need to travel to work.
Whilst the majority of sites in the draft document are to go ahead, Lindal in Furness, has been excluded.
The reason given by SLDC for the sites exclusion was that it was as a result of objections by the neighbouring authority, Barrow Borough Council, on the basis that it would conflict with their proposed dock development scheme. I have found no evidence of this objection and I am aware that Lindal Parish Council were not consulted.
With regard to the proposed development to the west of Ulverston on green field sites, I am aware that there are major objections from local residents over the loss of farming land and that a number of them put forward the brown field site at Lindal in Furness as one alternative site. The council do not appear to have taken on board the concerns or proposals of residents raised at public consultations.
The question as to the green field sites being available went unanswered at the public consulation and it is my understanding that the land has to be available before it can be identified. No evidence of a willingness to 'sell' was provided by the council with the residents being of the opinion that it was not available.
I am concerned that the planners attending the public consulation held the view that the land they had identified was to to the south of Ulverston when 'South Ulverston' is a totally different area.
This demonstrated a lack of local knowledge and it should be made clear that they meant to develop to the west.
In particular the document does not allow for sufficient low cost housing and I propose that the whole of the site at Lindal in Furness be reinstated as a Local Service Centre in view of local support and the consultants favourable comments
In my own case, my land at Lindal in Furness, an avaialble 6 acre brown field site R209, was identified as category A1 with regard to sustainability by the Council's expert but the SLDC chose to delete it from their options prior to any public consultation. I was content to have the whole site be used for affordable homes (89 houses put forward by consultants) especially as the adjoining 4 acre site had been ientified as employment land. A s the Borough of Barrow in Furness have no development plans for Lindal in Furness and the SLDC have made no provision then the village will continue to decline, which is of course contrary to the National Planning Policy Framework.
The current requirement is for affordable homes and employment. Given that the Councils proposed plans have taken seven years to get to this stage they are not relevant to current needs or Central Governments evolving policies with regard to husing and local development.
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 hear first hand the comments made by SLDC and the reasons for their decisions.
As I have now been diagnosed with Parkinsons and my wife has advanced MS this will be my LAST CHANCE to find a suitable use for the site having tried for the past 25 years.
My two sons have no interest in the site not living locally and no use can be found then it will remain derelict.
Having lived in the area all my life I have a strong local knowledge
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2. Mr Richard Johnston (Individual) : 20 Mar 2012 15:11:00
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Paragraph No.
1.9
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The Land Allocations Document (DPD) is not within the Local Development Scheme and the key stages have not been followed
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not had regard to the Sustainable Community Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
There was no public consultation in regard to land allocation prior to the adoption of the Core Strategy. In particular the draft document allowed for a 'Local Service Centre' at Lindal in Furness and this was excluded from the final document without proper consultation.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
There was no public consultation in regard to land allocation prior to the adoption of the Core Strategy. In particular the draft document allowed for a 'Local Service Centre' at Lindal in Furness and this was excluded from the final document without proper consultation.
The reason given by SLDC for the sites exclusion was that it was as a result of objections by the neighbouring authority, Barrow Borough Council, on the basis that it would conflict with their proposed dock development scheme. I have found no evidence of this objection and I am aware that Lindal Parish Council were not consulted.
With regard to the proposed development to the west of Ulverston on green field sites, I am aware that there are major objections from local residents over the loss of farming land and that a number of them put forward the brown field site at Lindal in Furness as one alternative site. The council do not appear to have taken on board the concerns or proposals of residents raised at public consultations.
The question as to the green field sites being available went unanswered at the public consulation and it is my understanding that the land has to be available before it can be identified. No evidence of a willingness to 'sell' was provided by the council with the residents being of the opinion that it was not available.
The site numbers M31 and R209 located at Ulverston Road, Lindal in Furness, Cumbria were identified in the draft Core Strategy as part of the 'Local Service Centre' for Lindal in Furness. As originally proposed I considered the proposal to be sound and wrongly assumed that it would proceed through to the allocation of land process.
The sites were removed prior to any public consultation despite being identified as A1 for developability and sustainabiity by independent planning consultants.
At no stage were the public able to comment on this site or the adjoining site R209 as both were removed from the adopted Core Strategy document and all relevant documentation removed or buried in the web site archives.
In the original Core Strategy the site M31 was identified as employment land and would have provided much needed opportuities for local residents.
The sites are brown field having previously been used as railway sidings, a gas works,a wagon repair works, an ore crushing mill and a farm known as Lowfield House.
The Councils officers have missed the opportunity to use a very suitable and more imoprtantly available brown field site and have opted to identify unavailable green field sites and have not given the relevant residents the opportunity to comment at the public consultation days as the sites had already been removed.
The Council have stated that the site was excluded by them due to objections from Barrow Borough Council and that the Council's concerns regarding possible effects on their much delayed docks development. I can find no evidence to support this claim.
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.
As a local resident for the past 67 years I have knowledge of the local area and current local needs
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
3. Mr Richard Johnston (Individual) : 29 Mar 2012 09:26:00
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I have read the guidance notes
Paragraph No.
0.0 Whole Document
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
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
The DPD has not had regard to the Sustainable Community Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Extract from introduction to NATIONAL PLANNING POLICY FRAMEWORK:
2 ‘Planning law requires that applications for planning permission must be determined in accordance with the development plan,2 unless material considerations indicate otherwise.3 The National Planning Policy Framework must be taken into account in the preparation of local and neighbourhood plans, and is a material consideration in planning decisions.4 Planning policies and decisions must reflect and where appropriate promote relevant EU obligations and statutory requirements’.
If the SLDC’s proposed Development Plan is adopted it will mean that only sites that they have previously identified will be considered for planning approval.
Given that the publication of the National Planning Policy Framework was on the 27th March 2012, reflecting the current governments thinking, how can it be possible that the SLDC’s Development Plan and Local Development Framework Plan, having taken seven years to evolve, be relevant or ‘take into account’ the current National Policy?
Extract from introduction to NATIONAL PLANNING POLICY FRAMEWORK:
7. There are three dimensions to sustainable development: economic, social and environmental. These dimensions give rise to the need for the planning system to perform a number of roles:
an economic role – contributing to building a strong, responsive and competitive economy, by ensuring that sufficient land of the right type is available in the right places and at the right time to support growth and innovation; and by identifying and coordinating development requirements, including the provision of infrastructure;
a social role – supporting strong, vibrant and healthy communities, by providing the supply of housing required to meet the needs of present and future generations; and by creating a high quality built environment, with accessible local services that reflect the community’s needs and support its health, social and cultural well-being; and
environmental role – contributing to protecting and enhancing our natural, built and historic environment; and, as part of this, helping to improve biodiversity, use natural resources prudently, minimise waste and pollution, and mitigate and adapt to climate change including moving to a low carbon economy.
The NPPF states that there should be a presumption in favour of sustainable development but this becomes irrelevant if the SLDC development plan is adopted and only sites that they have identified prior to the LPPF publication will be considered.
In my own case, my land at Lindal in Furness, an available 6 acre brown field site-R209, was identified as category A1 with regard to sustainability by the council’s expert consultants but the SLDC chose to delete it from their options prior to any public consultation. I was content to have the whole site be used for affordable homes (89 houses put forward by consultants) especially as the adjoining 4 acre site had been identified as employment land.
As the Borough of Barrow in Furness have no development plans for Lindal-in-Furness and the SLDC have made no provision then the village will continue to decline, which is of course contrary to the National Planning Policy Framework.
With regard to the economic role element, it would help if the government and/or local councils suspended planning fees, which can run to many thousands of pounds and with no guarantee of approval. As things stands the fees are a deterrent to any applicant irrespective of the size of development.
I suggest that the SLDC plan be scrapped or at least delayed and revised to take account of the current National Planning Policy Framework.
The whole of the plan should be reviewed to take account of the current financial situation, current housing needs and the new NATIONAL PLANNING POLICY FRAMEWORK. A clear policy needs to be developed for sites excluded / not covered by the evolving structure plan especially any that would provide employment opportunities and low cost housing for locals in the very near future. I have no doubt that a lot of good work has been done by the Planning Officers over the past seven years and it should not be necessary to scrap the whole document considering the expense to date.
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.
For the reasons stated above (at Question 1.3)
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 hear the evidence put forward by SLDC
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
4. Mr Richard Johnston (Individual) : 14 Apr 2012 09:49:00
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I have read the guidance notes
Policy/Site No.
LA1.8 Local Employment Allocations - Site Omission
If you have selected a ‘Site omission’ please enter the site reference or location and relevant policy below
Site number M31
East of Lindal in Furness, adjacent the A590T
Policy LA1.8 - Local Employment
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
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
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The whole of the plan should be reviewed to take account of the current financial situation, current housing needs and the new NATIONAL PLANNING POLICY FRAMEWORK.
A clear policy needs to be developed for sites excluded/not covered by the evolving structure plan especially any that would provide employment opportunities and low cost housing for locals in the very near future.
I have no doubt that a lot of good work has been done by the planning officers over the past seven years and it should not be neccessary to scrap the whole document considering the expence to date.
The site numbers M31 and R209 located at Ulverston Road, Lindal in Furness, Cumbria were identiifed in the draft core strategy as part of a Local Service Centre for Lindal in Furness. As originally proposed I considered the proposal to be sound and wrongly assumed that it would proceed through to the allocation of land process.
The sites were removed prior to any public consultation despite being identified as A1 for developability and sustainabiity by independent planning consultants.
At no stage were the public able to comment on this site or the adjoining site R209 as both were removed from the adopted Core Strategy document and all relevant documentation removed or buried in the web site archives.
In the original Core Strategy the site M31 was identified as employment land and would have provided much needed opportuities for local residents.
The sites are brown field having previously been used as railway sidings, a gas works,a wagon repair works, an ore crushing mill and a farm known as Lowfield House.
The Council's policy of concentrating employment employment and housing in the main settlement areas of Kendal, Ulverston and although not in the SLDC area, Barrow in Furness, does not allow any choice for the numerous residents of the many surrounding villages with the majority of residents required to travel considerable distances to work. The policy does nothing to address the cost of travel either financially or environmentally and does not address rural or agricultural specific needs which are not pertinent to the main settlements.
The Council's Officers have missed the opportunity to use a very suitable and more importantly available brown field site and have opted to identify unavaialble green field sites and have not given the relevant residents the opportunity to comment at the public consultation days as the sites had already been removed.
The Council have stated that the site was excluded by them due to objections from Barrow Borough Council and that Councils concerns regarding possible effects on their much delayed docks development. I can find no evidence to support this claim.
I am aware that some residents of Ulverston, Swarthmoor and Cross - a - Moor objected to the use of their surrounding green fields and nominated the brown field site at Lindal as one alternative, this being due to local knowledge and not the LDF documents. I can find no evidence that the Council have considered the residents proposal. I propose that the relevant sites are reinstated.
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Lindal in Furness
The whole of the plan should be reviewed to take account of the current financial situation, current housing needs and the new NATIONAL PLANNING POLICY FRAMEWORK.
A clear policy needs to be developed for sites excluded/not covered by the evolving structure plan especially any that would provide employment opportunities and low cost housing for locals in the very near future.
I have no doubt that a lot of good work has been done by the planning officers over the past seven years and it should not be neccessary to scrap the whole document considering the expence to date.
The site numbers M31 and R209 located at Ulverston Road, Lindal in Furness, Cumbria were identiifed in the draft core strategy as part of a Local Service Centre for Lindal in Furness. As originally proposed I considered the proposal to be sound and wrongly assumed that it would proceed through to the allocation of land process.
The sites were removed prior to any public consultation despite being identified as A1 for developability and sustainabiity by independent planning consultants.
At no stage were the public able to comment on this site or the adjoining site R209 as both were removed from the adopted Core Strategy document and all relevant documentation removed or buried in the web site archives.
In the original Core Strategy the site M31 was identified as employment land and would have provided much needed opportuities for local residents.
The sites are brown field having previously been used as railway sidings, a gas works,a wagon repair works, an ore crushing mill and a farm known as Lowfield House.
The Council's policy of concentrating employment employment and housing in the main settlement areas of Kendal, Ulverston and although not in the SLDC area, Barrow in Furness, does not allow any choice for the numerous residents of the many surrounding villages with the majority of residents required to travel considerable distances to work. The policy does nothing to address the cost of travel either financially or environmentally and does not address rural or agricultural specific needs which are not pertinent to the main settlements.
The Council's Officers have missed the opportunity to use a very suitable and more importantly available brown field site and have opted to identify unavaialble green field sites and have not given the relevant residents the opportunity to comment at the public consultation days as the sites had already been removed.
The Council have stated that the site was excluded by them due to objections from Barrow Borough Council and that Councils concerns regarding possible effects on their much delayed docks development. I can find no evidence to support this claim.
I am aware that some residents of Ulverston, Swarthmoor and Cross - a - Moor objected to the use of their surrounding green fields and nominated the brown field site at Lindal as one alternative, this being due to local knowledge and not the LDF documents. I can find no evidence that the Council have considered the residents proposal. I propose that the relevant sites are reinstated.
I am aware that site R209 was put forward as an alternative site by a number of residents of Swarthmoor and Cross-a-Moor etc. during the latest round of public consultation.
Whilst searching on Google for Ore Mill Sidings Lindal, I came across a report dated February 2012 by SLDC www.southlakeland.gov.uk/.../LINDAL%20IN%20FURNESS.pdf The report entitled ‘South Lakeland Local Development Framework Land Allocations Development Plan Document’ Lindal in Furness Fact File is probably available on SLDC’s normal website but I have been unable to find it by this method.
The report acknowledges that the site was regarded as category 1 for sustainability and deliverability in the study commissioned by SLDC. That same study also stated that the site was ‘brownfield’ (it has had a history of industrial use from 1850 to 1962). Previously the council described the site as ‘derelict with nil use’
In the 2012 report the designation has now changed to a ‘greenfield’ site. My understanding of the term ‘greenfield’ is land that has no history of development whatsoever and this is clearly not the case. I submit that the council are seeking to mislead the inspector and the general public as well as making it more difficult to obtain planning permission in the future in line with the new NPPF policy.
The comments by the CPRE are contrary to those of the consultants appointed by the SLDC and I doubt if the CPRE have ever visited the site unlike the consultants. The site clearly lies within the confines of the existing village with speed limits, village signing and housing adjacent on two sides, East View and Bank Terrace. I feel that the CPRE comments are generic once they have been provided with certain information by SLDC and the site was not considered by the CPRE in isolation.
The Borough of Barrow in Furness currently have no plans for the village and I am not aware of any suitable sites being available in the part of the village covered by that authority, but I am sure SLDC will already know this. I understand that Barrow wish to concentrate on their proposed dock development scheme and already have enough sites for their purposes. I have also received confirmation that the Barrow Borough Council raised no objections to any proposed development at the Ore Mill Sidings, Lindal
The report also states that site ‘M31 will is also considered as a strategic employment site’ but I am not sure what this means. I think that at some stage R209 formed part of M31 and it maybe that the council are still considering the site for employment.
From my point of view and given the post 2008 financial situation I would welcome any commercial operation that provided the opportunity of employment for local residents with a number of low cost houses.
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 hear the comments of the planning department first hand
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
5. Mr Richard Johnston (Individual) : 22 May 2012 15:48:00
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
Paragraph No.
1.10
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The Land Allocations Document (DPD) is not within the Local Development Scheme and the key stages have not been followed
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not had regard to the Sustainable Community Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
There was no public consultation in regard to land allocation prior to the adoption of the Core Strategy. In particular the draft document allowed for a 'Local Service Centre' at Lindal in Furness and this was excluded from the final document without proper consultation.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The reason given by SLDC for the sites exclusion was that it was as a result of objections by the neighbouring authority, Barrow Borough Council, on the basis that it would conflict with their proposed dock development scheme. I have found no evidence of this objection and I am aware that Lindal Parish Council were not consulted.
With regard to the proposed development to the west of Ulverston on green field sites, I am aware that there are major objections from local residents over the loss of farming land and that a number of them put forward the brown field site at Lindal in Furness as one alternative site. The council do not appear to have taken on board the concerns or proposals of residents raised at public consultations.
The question as to the green field sites being available went unanswered at the public consulation and it is my understanding that the land has to be available before it can be identified. No evidence of a willingness to 'sell' was provided by the council with the residents being of the opinion that it was not available.
I am concerned that the planners attending the public consulation held the view that the land they had identified was to to the south of Ulverston when 'South Ulverston' is a totally different area.
This demonstrated a lack of local knowledge and it should be made clear that they meant to develop to the west.
In particular the document does not allow for sufficient low cost housing and I propose that the whole of the site at Lindal in Furness be reinstated as a Local Service Centre in view of local support and the consultants favourable comments
I am aware that some residents of Ulverston, Swarthmoor and Cross - a - Moor objected to the use of their surrounding green fields and nominated the brown field site at Lindal as one alternative, this being due to local knowledge and not the LDF documents. I can find no evidence that the Council have considered the residents proposal. I propose that the relevant sites are reinstated.
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 hear the comments of the planning department first hand.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me