Local Development Framework Consultation

MM094 Land North of Jack Hill

The wording "and the need for housing to be of a style that respects that of existing properties" should be deleted. The words are superfluous and unnecessary. For some this might be interpreted as simply mimicking the houses adjoining. Such an approach is not appropriate. The appropriateness of design should be considered in the context of a planning application.

The wording "The sites will each require a single access point" should be deleted as this is contrary to the written advice given by the highway authority to the planning authority dated 25th February 2013 to be sent under separate cover in relation to the land fronting Holme Lane. [See attached document for details]

Whilst the planning authority sought to lead the highway authority in agreeing a single access point is required the highway authority's response makes reference to the possibility of 2 courts of 4 houses rather than one access for 8 or frontage development.

MM090 Land west of Sedgwick Road, Natland

To avoid any misunderstandings, vehicular access will be from Sedgwick Road and across the existing footway and through the hedgerows. The second two sentences should therefore read:-

“It will be necessary to secure access through the existing hedgerows and remove at least some of the hedgerows to ensure appropriate visibility splays are provided. There will be a need to maintain the existing footway along Sedgwick Road either side of the vehicular access or accesses to the new residential development.”

FURTHER MAIN MODIFICATIONS
COMMENTS BY THE CUMBRIA HOUSE BUILDERS GROUP (CHBG)

MM075 SELF BUILD HOUSING

1. The National Planning Policy Framework (paragraph 50) encourages local planning authorities to plan to meet “the needs of different groups in the community (such as, but not limited to, families with children, older people, people with disabilities, service families and people wishing to build their own homes)...”

2. The CHBG does not object to the planning authority’s intention to be supportive of self build projects but objects to the reference – “Elsewhere development briefs for larger sites offer the opportunity to consider the incorporation of a self-build element.”

3. As is clear from the Revised Statement of Common Ground in relation to Housing Provision (EX044U), the authority already rely on the delivery of a significant number of housing completions from existing planning permissions, SHLAA small sites and unidentified windfalls. The CHBG consider there is considerable over reliance on unidentified sites, nevertheless the opportunity for self-build on small sites remains considerable.

4. Small self-contained sites are appropriate for self-build projects but seeking to incorporate a self-build element into a large housing development is impractical and could threaten housing delivery.

5. The CHBG has already objected to the requirement for the preparation for Development Briefs because of the inevitable delay that will result in bringing sites forward and delivering housing completions. That issue aside, the complexity of requiring parts of larger sites to be set aside introduces further complexity in the planning application and site purchase process and provides uncertainty in relation to the sale and take up of housing on the main part of a large site.

6. A few rhetorical questions are worth considering:-
a) Is the planning authority expecting the principle developer to secure planning permission for the self-build element of any site? If yes then the developer will be contractually bound to purchase the self-build element of the site and the authority will then no doubt seek to preclude completions on the main element of the site to force a sale to any potential self builders. Complex and introducing a significant element of risk to the developer. What if there are no self-builders interested in purchasing at a reasonable price? There is an additional risk to the developer impacting on land value and viability.
b) Which party is to bear the infrastructure costs associated with facilitating the self-build element, the main developer or the self-builders? If the principle developer must take on this additional financial burden then there is an impact on the land value and financial viability.
c) Is there to be an affordable housing element requirement associated with the self build element? If not then is the main developer going to be required to compensate with a higher number of affordable dwellings on the main part of the site? Again there would be an impact on land value and financial viability.
d) Who will be responsible for any other financial contributions, the developer of the self-builders?
e) Who will be responsible for bonds and road adoptions, the developer or the self-builders?

7. There are likely to be logistical issues relating to differing build programmes, the timing of the delivery of materials which may cause delays and costs to the principle developer and have health and safety implications.

8. The differences in design and build quality would be of concern for the principle developer and their potential purchasers, impacting upon the marketability of their own dwellings and the image of the site.

9. A developer of a large site requires control over the design and build quality of the scheme, on site health and safety, a construction programme and methodology that minimises inconvenience to purchasers and pricing at a level to secure sales at a reasonable rate per month. If these requirements are put at risk then the ability to attract purchasers becomes more difficult and the ability to deliver housing completions less likely.

10. The CHBG seek the deletion of the words:- “Elsewhere development briefs for larger sites offer the opportunity to consider the incorporation of a self-build element.”

MM076 EXTRA CARE HOUSING

11. It is difficult to provide a clear and definitive view in relation to the newly proposed extra care provision due to the limited available information relating to the proposed implementation and mechanics of the policy. There are also a number of issues which would need to be carefully explored prior to implementation of any requirement relating to potential complexities of land valuation, acquisition and impacts upon site viability.

12. Notwithstanding the above, the CHBG are willing to discuss with Cumbria County Council and South Lakeland District Council the provision of new extra care housing, where the need is fully justified and evidenced, within the context of larger schemes,as indicated in the suggested text:-

“...On planning applications of more than 60 dwellings, Cumbria County Council will consider the need for new extra care provision as part of the scheme and may request affordable provision, having regard to the existing level of provision in the area and the appropriateness of the site....”

13. The introductory text refers to the Older Persons Housing Strategy 2012-2017. Theme 1 of the Strategy is entitled “Encourage the development of a range of accommodation options which meet the needs and aspirations of older people.” Under this theme the Strategy states:-

“In terms of Planning, both districts have adopted Core Strategies which provide specific requirements for the delivery of affordable housing and state what will be the basis for accepting planning applications. Within this framework the Strategy encourages using the flexibility of the policy to seek homes of the types sought by older people in each locality which will meet their financial needs and future support needs.”

14. Under the Action Plan for Theme 1 the Strategy states:-

Task 4 b) “Work with private developers to encourage development of the right type. Use flexibilities of Core Strategy planning policy where appropriate to enable most suitable provision.”

15. Clearly the planning authority considers securing extra care housing requires the flexible application of Core Strategy planning policy. It is therefore appropriate to include this reference in the Proposed Main Modification and the following additional text is proposed as an amendment:-

“Core Strategy planning policies, including Policy CS6.3 relating to the provision of affordable housing, will be applied flexibly to encourage the provision of extra care homes. As envisaged by CS6.3 this may mean a lower requirement for affordable housing, to ensure developments remain viable and new housing is deliverable.”



N.B. As a result of holiday commitments of key personnel there has been no input into this representation from Applethwaite.

Garner Planning Associates 05/09/13