Local Development Framework Consultation

Draft Development Management policy DPD (Oct 2016).
Specific comment re policy DM21 Renewable and Low Carbon energy Development.
Pleased to see the comment “This policy contains criteria regarding residential amenity and should positively contribute towards protecting health and wellbeing.” (5.6 box page 70).
But I am not clear on what this means:
(5.6.4) “The proposed policy above is a positively worded criteria based policy that will provide a clear decision making framework for renewable and low carbon energy projects to encourage and support suitable energy development in South Lakeland”.
Does this refer to the 9 points made in the initial box in this section? Are these points "criteria"?
(5.6.5) In principle I am pleased to see that this policy repeats and reinforces the current criteria on which planning decisions in relation to planning decisions relating to wind turbines.

In the light of recent flooding events throughout Cumbria, I feel strongly that every planning application should have as part of it’s requirement, the inclusion of a detailed plan regarding the removal and disposal of foul water, ground water and surface water, that also illustrates the position and nature of all existing watercourses.

That a full inspection of the site be made by the Authority with regard to this aspect and that any work undertaken in respect of this aspect be checked by and approved in writing by the Authority, before any planning permission can commence or continue.

Yours Sincerely

P L Hobbs

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Aldingham Parish Council have now looked at this consultation in more detail. They did feel the consultation document was difficult to translate to relevance to the PC at this stage. However, they are happy with the policies as an appropriate basis on which to consider planning applications in their Parish and will of course refer to this once it is completed. They do not wish to add anything further.

Thank you for the extension and opportunity to comment.

Regards,

Beth Moon
Clerk

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1. After studying the document, I recognise the aim appears to be to cover as many issues as possible. Nevertheless I respectfully recommend a review of the volume of words to avoid being repetitive and eliminate any jargon e.g. 'inclusiveness' and 'project level HRA' in DM1 3. & 7. respectively (I know technical terms are in the glossary). Succinctness would mean the non professional in particular would not be overawed with reference to DM1 & 2 in particular.

2. In DM1 & 2 the verb 'must' is too prescriptive, given the tone of the NPPF & NPPG. 'Should' throughout would be more user friendly and engender constructive negotiation of proposals including that vital creativity for designers.

3. Similarly the verb 'and' could also be interpreted as too controlling rather than for management of development. Instead, the DM1 opening clause could include 'as appropriate'.

4. If the opening clause of DM1 is mandatory, should it not be emboldened text?

5. Could a map show the boundaries of the National Park to ensure the area for these policies is clear, or at least please provide a link or a location where these can be checked?

6. Car parking standards are appropriately tabulated e.g. under DM9 as the location of them on the CCC website is not easy to find and because the DPD opening paragraphs refer to the application of standards.

7. DM3 is an example of where 'assessments could be expected as the norm for validation of planning applications, which could deter them because of the up front risk costs contrary to the 'enabling' essence of town planning & the various benefits that new development provides. Why not omit assessments? They are referred to in the NPPF anyway.

8. Also regarding DM3 and 2.3.9 please publish the 'Local list' or provide a link and explain it's status for 'heritage assets'.

These are better shared at a forum of officers and agents, as requested.

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Paragraph 2.3 - Policy DM3 - Historic Environment - The Trust would like to see reference made within the supporting text to this policy that the former Lancaster Canal and supporting infrastructure are heritage assets.

Paragraph 2.4 - Policy DM4 - Green Infrastructure - Reference should be made within paragraph 2.4.1 to the Kendal-Lancaster Canal as a potential source of green infrastructure/open space. This would better reflect that the former canal is more than just a recreational route.

Paragraph 2.5 - Policy DM5 - Rights of Way - The Trust would like to see specific reference being made to the former route of the Lancaster Canal as a recreational route and that development adjacent to the route should seek to create access to it.

Paragraph 3.2 - Policy DM10 - Transport Improvements - The Trust is pleased that the policy and supporting text to the policy do not only seek to protect the line of the former Lancaster Canal by ensuring that development does not prevent or impede its future restoration but that the policy also seeks to maximise opportunities for its enhancement and wider public use, recognising its potential multi-functional nature.

Paragraph 6.2 - Policy DM24 - Kendal Canal Head - The Trust supports the inclusion of this policy and the aim to create a policy framework and apply a holistic approach to Kendal Canal Head Area. The Trust is pleased that the policy and supporting text to the policy do not only seek to protect the line of the former Lancaster Canal by ensuring that development does not prevent or impede its future restoration but also maximise opportunities for its enhancement and wider public use, recognising its multi-functional nature.

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Policy DM3 – Historic Environment

The policy is supported, but it is recommended that two amendments are included to make it more compliant with the NPPF. Firstly, paragraph 134 of the NPPF differentiates between substantial harm and less than substantial harm to designated heritage assets. Secondly, paragraph 133 of the NPPF states that substantial harm to a designated heritage asset must be demonstrated to be necessary (and also that the development achieves public benefits that outweigh the harm). It is recommended that these two considerations in determining the suitability of proposals that impact upon designated heritage assets are included in Policy DM3 to bring it in to line with the NPPF.

Policy - DM8

I have looked over the draft policy and from Connecting Cumbria’s point of view this is really good and one of the best policies from the point of view of ensuring superfast broadband planning by developers that I have seen so far. The only changes I would have proposed would be:

• The government has redefined Superfast broadband as over 30Mbps – there has always been a range of definitions for superfast, our Connecting Cumbria contract was agreed at the time that the government defined it as over 24Mbps thus we use this measure but the government has since changed to define this as over 30Mbps and this number might be the better one for development team to keep in mind.

• For developments of over 30 properties to be required to demonstrate they had considered the installation of Ultrafast broadband (100Mbps or more) connectivity however this might require a separate policy from that which is applied to smaller developments. I’m uncertain how many projects of this scale are likely to be in contemplation in south lakes in the next few years so focusing on this might not be key but the government is moving to a greater focus on encouraging ultrafast in urban and commercial areas so this may be something to consider at the next policy review.

We would endorse the broadband sections of your policy

Going forward I would be really interested to see how the application of this policy works in practice over the next few years. If it results in more positive expansion of superfast services or if it cause an increased level of complaints/issues from planning applicants that might not have previously considered broadband in their projects. Would it be at all possible to arrange to review this issue with you 6-12months after the policy becomes active?

Kind regards

Cathy

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Helsington Parish Council cannot comment on any of these policies until its Community Led Plan is complete (which will be outside the consultation period).

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6.1 - Policy DM23 - Retail uses outside of town centres
We believe the proposed threshold of 2000 sq.m gross is too high for new retail floorspace outside of Kendal town centre. We propose the threshold be set at 1500 sq.m gross in order to protect the trading conditions and vitality of the town centre.

5.7 - Policy DM22 - Hot food takeaways
We agree that the Council should be able to carefully consider the location of new hot foot takeaways. Does the proposed policy go far enough, however? It may still allow every other shop to be a takeaway and only open at night - affecting the look, feel and vitality of the town centre during the day. We would support stricter criteria.

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Whilst the Parish Council welcome the opportunity to be consulted on this policy the information provided is too complex to be properly considered at a regular Parish Council meeting due to the length of the documentation (150 pages) and the technical terms employed.

Yours sincerely

Lyn Prescott

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Thank you for the opportunity to provide feedback to the proposed policy.

Network Rail is the public owner and operator of Britain’s railway infrastructure, which includes the tracks, signals, tunnels, bridges, viaducts, level crossings and stations – the largest of which we also manage. All profits made by the company, including from commercial development, are reinvested directly back into the network.

Network Rail is looking at how we can work smarter to help enable development near to the railway.

(1)
It has come to our attention that where applications have an impact on the railway network, in particular on level crossings, the application is delayed or is objectionable because negotiations with developers are not agreed before a Planning Application is submitted.

I am sure you are aware that Network Rail is a statutory consultee for any planning applications within 10 metres of relevant railway land (as the Rail Infrastructure Managers for the railway, set out in Article 16 of the Development Management Procedure Order) and for any development likely to result in a material increase in the volume or a material change in the character of traffic using a level crossing over a railway (as the Rail Network Operators, set out in Schedule 4 (J) of the Development Management Procedure Order); in addition you are required to consult the Office of Rail and Road (ORR).

Where there is an adverse impact on the operation of the railway, Network Rail will require appropriate mitigation measures to be delivered as part of the planning application process. By this stage in the process our request for further information such as a Transport Assessment (to provide detail of the suspected impact) and where necessary, the provision of planning obligations can cause significant delay. This can be highly frustrating for any developer who has undertaken pre-application advice, and invested time and money, in working through mitigation measures including Heads of Terms for Section 106 agreements.

To help alleviate this problem it is requested that you add a standard paragraph to any pre- application response you provide. I have put together a paragraph which if included as general advice, may help avoid any disruption further along the process.

Should your development be likely to increase the level of pedestrian and / or vehicular usage at a level crossing any future planning application should be supported by a full Transport Assessment assessing such impact. Any required qualitative improvements to the level crossing as a direct result of the development proposed should be included within the Heads of Terms.

(2)
Within Transport Assessment’s there is a review of local needs regarding public transport; this usually focuses on buses. However, Transport Assessments should also take into account their impact upon footfall at railway stations. Developers are encouraged to consider including within Transport Assessments trip generation data at railway stations. Location of the proposal, accessibility and density of the development should be considered in relation to the relevant railway station in the area.

Where proposals are likely to increase footfall at railway stations the Local Planning Authority should consider a developer contribution (either via CIL, S106 or unilateral undertaking) to provide funding for enhancements as stations as a result of increased numbers of customers.

At its meeting last night New Hutton Parish Council made the following comments on the draft development management policies:

• Policy DM4 – Green infrastructure and open space – All planting should be of native species as foreign ones do not support other wildlife well.

• Policy DM8 – Telecommunications and broadband – All developments (not just two or more) should have fast broadband or provision for it. A hyperfast network is being installed to all homes and businesses that want it in New Hutton so if it can be done in this very rural parish it can be done anywhere.

• Policy DM8 - Telecommunications and broadband – Paragraph 2.8.3 refers only to Openreach. Other providers offer a free assessment service and are local companies. Either all should be named or references to Openreach should be removed as inclusion will introduce bias to the policy.

• Policy DM13 – Housing development in small villages and hamlets – A minimum hamlet size of 10 seems arbitrary. It would limit organic growth to only one group of houses in New Hutton. Bearing in mind that a requirement exists for a successful planning application to fulfil the criterion of either rounding off or infill, the Parish Council favours a minimum size for a hamlet to be 5 houses. This would introduce more flexibility and scope for organic growth in the parish.

• Policy DM14 – Rural exceptions sites – The word “development” is ambiguous because for some policies it is used to mean “change” but in this policy it means “the building of a new house”. It should be made clear that the policy refers to new building.

• Policy DM14 – Rural exceptions sites – The policy of allowing new building in rural areas only if they are affordable homes in perpetuity has completely failed in this parish. Houses cannot be built for the price they could be sold for. The policy should be changed to require not that they are affordable homes but that they have a local occupancy/ownership condition in perpetuity.

• Policy DM15 – Essential dwellings for workers in the countryside – Again it should be made clear that this policy refers to new-build homes. Workers’ homes could be created by the conversion of disused buildings.

• Policy DM16 – Conversion of buildings in rural areas – Somewhere in this policy there should be mention of the NPPF right to convert disused buildings such as barns to dwellings without the need to go through normal planning procedures. It is not clear how the two differ.

• Policy DM16 – Conversion of buildings in rural areas – The word “significant” is important and needs definition in the policy otherwise there will be inconsistency across the District. For instance, would reconstruction of the roof be included in “significant”?

• Policy DM16 – Conversion of buildings in rural areas – In point 5 it is not clear what “readily available” means. Nor is “utilities” defined; for instance, would provision of, or for, fast broadband (DM8) be included in “utilities”?

• Policy DM18 – Tourist accommodation – caravans, chalets, log cabins, camping and new purpose built self-catering accommodation – Planning applications made under this heading seem to be viewed more favourably than building in a hamlet. Is this not discrimination?

• Policy DM19 – Equestrian-related development – Field shelters for horses are intrusive in the landscape if they protrude above the landscape. They should be screened by the planting of native species of bushes and trees. This policy has been used by the Parish Council for many years.

Regards

Arthur Robinson
Parish clerk

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Old Hutton & Holmescales Parish Council discussed the draft policies at its meeting last night and made the following comments:

DM4 - statements throughout DM4 should refer to the planting of native species in order to prevent foreign species which do not support wildlife as well.

DM8 – all developments (not “two or more”) should have provision for fast broadband. It is now recognised as a major utility equal to the telephone and power.

DM8 – paragraph 2.8.3 – reference to Openreach should be removed to give equality to all providers. Experience in the parish has shown that Openreach has often given incorrect information and very little information about local wireless providers of broadband.

DM13 – point 5 – a minimum of 10 dwellings is too big. The parish council favours a more flexible approach in the context of the criteria for rounding off and infilling, the minimum size of hamlet being 5 dwellings. Several former farms in the parish have been converted to dwellings but a minimum of 10 would prevent any rounding off and infilling at sites which would be ideal and this would be particularly harmful to young people wanting to self-build.

DM14 – it is not clear that DM14 is a policy for new buildings; rural exception sites are allowed by national policy if they involve the conversion of disused buildings such as barns.

DM15 – paragraph 4.5.2 in the reasoned justification section – as with DM14 it should be made clear that this policy is for new buildings and not the conversion of disused ones.

DM16 – in point 1 the meaning of “significant” needs to be defined. Failure to give this will result in inconsistency across the District.

DM19 – field shelters for horses should be screened by planting native bushes and trees. This parish has a number of shelters and they are visually obtrusive in the landscape.

Regards,

Arthur Robinson
Parish clerk

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Please find attached our representation to Policy DM22 of the Draft South Lakeland Development Management Policies Document.

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NE Kendal FLAG objects to Policy DM1 and DM6, whose combined effect will not be sufficient to control (and if necessary refuse) developments that cause flooding off site in flood sensitive areas, for example in Kendal. We consider these policies are unsound because they do not conform to to relevant sections in NPPF paragraphs 99 to 103 which culminate in Para 103. "When determining planning applications, local planning authorities should ensure flood risk is not increased elsewhere" , but also in Para 102 "without increasing flood risk elsewhere, and, where possible, will reduce flood risk overall".
Para 100 makes the same point saying "safeguarding land from development that is required for current and future flood management, and using opportunities offered by new development to reduce the causes and impacts of flooding";

Neither policy attempts to require development to leave areas that naturally currently provide a flood storage facility, or make a positive contribution to a flooding problem area, or reduce the causes or impacts of flooding as required by NPPF. This is essential in our local situation, where Cumbrian rainfall is more intense and of longer duration that the national average, and is predicted to worsen more quickly under the impacts of climate change.

Specifically DM1. (General Requirements for all development) :
NE Kendal FLAG considers that the policy wording "ensuring there is effective flood risk management " in bullet 6 is too vague and non-specific and fails to achieve the stated aim to... "create a safe, secure and healthy environment " . The Sustainability Appraisal score is, in our view far too positive because there is no evidence to support the view that the policy would prevent worsening flooding in areas where urban drains are already inadequate.
AND
Policy DM6 – Surface Water disposal, Foul Water disposal and treatment, watercourses, flood defences and consideration of wider
land drainage interests .
We object to DM6 because it does NOT conform to the paragraphs quoted above from the NPPF, and would not achieve its' purpose, particularly to REDUCE the flood risk in the district,". For example: The policy does not require developers to contribute to improving water retention on sites, nor even in fact to assess the amount of water stored on site in winter conditions prior to development. The policy simply requires developers to act as water companies prefer, and enables the performance of the drainage system to be measured against the non statutory guidance (LASOO document March 2015) . The assessment of surface water drainage, together with groundwater flooding, is actually a much more complex matter that the current guidelines would indicate, and the policy should ensure that a full professional understanding of the local and site situation is applied, rather than a simplified tick box. e.g. LASOO refers to (national average !) storms of 6 hours duration, and does not require infiltration tests to be conducted in wet or winter conditions, and therefore following that advice would not achieve the requirements of NPPF in local conditions. In the Kent Valley rainfall events are often much longer, and groundwater levels often at or above the ground surface in prolonged wet periods.
The policy should say that developers should only use SUDS where appropriate, i.e. where they can demonstrate by thorough and locally specific assessments that neither on-site nor off-site flooding will result from floods such as occurred during Storm Desmond, and the likely worsening events over the next 100 years (probable life of the buildings). Also where discharge of surface water to water courses or existing sewers is proposed , this should not be permitted unless those routes for disposal have adequate capacity, even when all cumulative effects of a flood event are taken into account.
The policy should make it clear that, if it cannot be demonstrated that the development will not cause more flooding from SUDS or water courses or sewers downstream, development should be refused.

Policy DM1: Expand both the policy and reasoned justification to integrate the 10 key principles of 'Active Design' to create opportunities for physical activity to accord with Section 8 (Promoting Healthy Communities) and Section 7 (Requiring Good Design) of NPPF, and to help implement the objectives in Sport England's Strategy 'Towards an Active Nation'. Active Design can be found on Sport England's webiste and was published in partnership with Public Health England.

Policy DM2: comments as for DM1

Policy DM4: This policy relates to Green Infrastructure and open space, of which outdoor sport and playing fields is a specific typology. The policy makes no reference to outdoor sport and playing field provision, neither is there a seperate policy covering this typology. Housing and employment growth generate additional demand for sport and recreation and the impact of that increased demand must be factored in when assessing planning applications for new development. Sport England strongly suggest creating a new policy that covers all aspects of sport, indoor and outdoor. The Core Strategy policy CS8.3b contains quantity standards for playing pitches which are to be used in conjunction with the accessibility standards contained in policy CS8.3a.

However, there are no accessibility standards for playing pitches within that policy so policy CS8.3b cannot be implemented for playing pitches or any other outdoor sport. A separate development management policy to cover outdoor sport will help bridge that gap. It should be noted that accessibility and quantitative standards are not appropriate for outdoor sport because demand is derived from certain sections of the community and not the population as a whole. A Playing Pitch Strategy will provide evidence of what shortfalls/spare capacity exists and where, and which sites require capacity to be increased to accommodate demand from housing growth. A formula can then be devised to obtain contributions to increase capacity at existing sites or create new. It should be noted that Sport England do not support the creation of single pitch sites within housing developments because they do not contribute to the pitch supply. They often become unusable for matchplay and there use is as informal kick about areas and informal greenspace for other community activities. Any new provision must be capable of providing pitches with supporting ancillary facilities to meet an identified demand from specific clubs/teams. Sport England would be happy to provide guidance and be included in the preparation of a Playing Pitch Strategy and wider Sports Facility Strategy to help inform policy and contributions. Any new sport policy will need to reflect locally the requirements of paragraph 73 and 74 of NPPF.

Physical Activity: Sport England would wish to see higher priority given to Sport and Physical Activity. This DPD should reflect how the development management policies can help promote sport and physical activity as a core theme throughout the Plan in accordance with Section 8 (Promoting Healthy Communities). The Government has also changed their thinking around this area published in the DCMS Strategy "Sporting Future: A New Strategy for an Active Nation". In response to this strategy Sport England has published 'Towards an Active Nation' which sets out how Sport England will work in partnership with a range of organisations, including Local Planning Authorities, to implement the Strategy. Both Strategies can be found on Sport England's website. Sport England and Public Health England has prepared guidance called 'Active Design' which helps planners, developers and suchlike to incorporate key principles into new development which creates physical activity opportunities. Sport England would wish to see these principles embodied into all design policies. The guidance can be found on Sport England's website.

Sport and Recreation policy: see comments for Policy DM4. There is a significant policy gap in relation to sport and physical activity within both the adopted Core Strategy policies and the proposed DPD policies. Given South Lakeland is a very popular destination for sporting activities, given it's proximity to the Lake District and Yorkshire Dales, this policy gap is surprising. Sports clubs contribute tot he economy whether they are grassroots or premier/superleague. Research carried out by Sport England 'Economic Value of Sport' (2013) shows that sport contributed £20.3 billion GVA and was 14th in the Industry Sector League Table ahead of telecoms and architectural and engineering services. There is also a clear link to the health agenda with sport representing £11.2 billion towards health. To provide evidence of the value of sport to South Lakeland, Sport England has produced a tool called 'Economic Value of Sport - Local Model (Updated 2015)'. This can be accessed via the Research page of Sport England's website.

Open Space Sport and Recreation evidence base: the study cited in the evidence base refers to the out of date 2008 Open Space Sport and Recreation Study (EvE08 and EvE08a). The Council do not have an up to date and robust Needs Assessment as required by paragraph 73 of the NPPF. As the Needs Assessment is required to help inform the preparation of policy the Needs Assessment should be undertaken prior to submission of this DPD. However, it should be noted that a combined Open Space, Sport and Recreation Study is not appropriate for playing pitches. The assessment of playing pitches requires a completely different methodology to that used by other open space typologies. There is also a separate methodology for non-pitch outdoor sport. Guidance can be found on Sport England's website. It should also be noted that Sport England as statutory consulted on all planning applications that affect playing fields use Playing Pitch Strategies to help assess proposals against the requirements of paragraph 74 of NPPF and Sport England's Playing Fields Policy. Sport England's policy and guide to how we assess planning applications can be found on our website. Sport England are likely to object to any proposal that uses an out of date Needs Assessment to justify any loss of playing field or creation of new where there is no evidence of strategic need. In addition the Needs Assessment should be used to provide a clear direction of what mitigation is required and where in those instances where loss occurs and requires replacement. The Needs Assessment should also be used to provide evidence of additional demand for sport generated by housing growth. The Needs Assessment should then be used to help calculate and obtain developer contributions that can be used to either build in additional capacity at existing facilities or create new provision. It shoud be noted that paragraph 73 of NPPF no longer require local standards to be set because demand for individual sports is specific to certain groups of people and not to the population as a whole. Developer contributions must be related to specific sites. In particular the Playing Pitch Strategy and Indoor/Outdoor Sports Startegy will result in a site specifc action plan that can be used to help calculate appropriate developer contributions.

Thank you for consulting The Coal Authority on the above document.

Within South Lakeland there are approximately 24 recorded mine entries and a range of other mining legacy features are present, in total The Coal Authority High Risk Development Area, however only covers approximately 0.01% of the Council area, outside of the National Park. The mining legacy is not located where new development in South Lakeland is likely to occur.

Having reviewed the document therefore, I confirm that we have no specific comments to make at this stage.

Yours sincerely

Mark Harrison BA(Hons), DipTP, LLM, MInstLM, MRTPI
Principal Manager

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Policy DM4 - Green Infrastructure, Open Space, Trees and Landscaping The wording of the propsoed policy requires that all developments over 10 dwellings will required to provide either on-site open space or commuted sums of £200 per bedspace to meet the standards set in this policy.

The legal tests for when you can use a s106 agreement are set out in regulation 122 and 123 of the Community Infrastructure Levy Regulations 2010 and as Policy test in the NPPF. The tests are:
1. necessary to make the development acceptable in planning terms
2. directly related to the development; and
3. fairly and reasonably related in scale and kind to the development.

Additionally the PPG advises that 'Planning obligations may only constitute a reason for granting planning permission if they meet the tests that they are necessary to make the development acceptable in planning terms, directly related to the development, and fairly and reasonably related in scale and kind.' Any request for open space contributions must therefore be support by clearly identified proposal that is directly relatable to the proposed development. Strategic open space provision should be delivered through the Community Infrastrucutre Levy.

Specialist Older Persons' accommodation or age restricted housing that will not house families or children should not be therefore provide contributions for play areas or open space provision for young people as this would not be directly relatable to the development.

Draft Policy DM17 - The Theatres Trust supports the inclusion of this policy as it aims to safeguard cultural facilities in accordance with guidance in para 70 and 156 of the NPPF.

We do, however, caution on relying on viability as justification for the loss of a community or cultural facility, and instead recommend there by more emphasis on community need.

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