Local Development Framework Consultation

DM1 - General Requirements for all development

Yes

No

The DPD is not effective

The policy is too prescriptive.

2.1.1 The explanatory text indicates development should “seek to enhance its surroundings” etc. If that is the intention then the policy should not be to “require” enhancement.

Note: The Cumbria House Builders Group includes the following companies:
- Applethwaite
- Holbeck Homes
- Oakmere Homes
- Persimmon Homes Lancashire
- Russell Armer; and
- Story Homes

Delete “Subject to other policies…provided it;”
Add “Development proposals should, where relevant, seek to address the following:-“

The “where relevant” wording is used in Policy DM2 so should also be applicable here.

For each bullet point delete “ensure” as the first word.

•1. Second bullet point should read “retention or provision”
•1. Delete “ensures it responds appropriately” and add “respond appropriately”
•5. Delete – it is not clear how developments ensure a healthy environment.
•6. Should say “protection or enhancement”.
•7. Should say “protection or enhancement”.
•8. Delete the words “and enhancement”. This criteria and the wording of 2.1.6 and 2.1.7 will be interpreted by some that if you can see it from a National Park or AONB the development is not acceptable.

No, I do not wish to participate at the oral examination

Please notify me.

DM2 - Achieving Sustainable High Quality Design

Yes

No

The DPD is not effective

The policy is too prescriptive.

Note: The Cumbria House Builders Group includes the following companies:
- Applethwaite
- Holbeck Homes
- Oakmere Homes
- Persimmon Homes Lancashire
- Russell Armer; and
- Story Homes

•1. Delete “and reinforce and promote”. It should be sufficient that development proposals respond to local distinctiveness. The change of wording would allow the use of contemporary and innovative styles envisaged in the second bullet point.
•2. Third bullet point change wording from “retains and enhances the existing landscape” to “retains or enhances the existing landscape”.
•4. Second bullet point add “by” so the phrase reads “address streets and routes by avoiding presentation of blank frontages or gables.”

No, I do not wish to participate at the oral examination

Please notify me.

DM3 - Historic Environment

Yes

No

The DPD is not effective

The DPD is not consistent with national policy

Listed Buildings

The policy does not comply with the Listed Buildings Act 1990 which allows works to listed buildings, including demolition, if the works are authorised.

Archaeology

It is not clear where sites of national or local significance are defined.

Conservation Areas

The policy should comply with Section 72 of the Listed Buildings Act 1990 which refers to “preserving or enhancing”.

Note: The Cumbria House Builders Group includes the following companies:
- Applethwaite
- Holbeck Homes
- Oakmere Homes
- Persimmon Homes Lancashire
- Russell Armer; and
- Story Homes

Listed Buildings - Delete this section.

Archaeology - Delete “or a site of national or local interest or their setting”.

Conservation Areas - First sentence the wording should be “preserve or enhance”.

No, I do not wish to participate at the oral examination

Please notify me.

DM4 - Green and Blue Infrastructure, Open Space, Trees and Landscaping

Yes

No

The DPD is not effective

The DPD is not consistent with national policy

Trees:

The policy wording is too inflexible in requiring the protection and enhancement of existing trees. The NPPF refers to preventing the loss or deterioration of ancient woodland and the loss of aged or veteran trees found outside of ancient woodland unless the benefits outweigh the loss (see NPPF 118).

Trees should not be considered a constraint on development regardless of the quality of the trees.

The policy towards the loss of trees should be based on an assessment of the trees quality and the appropriateness of removing trees should be considered on the basis of an assessment of the benefits outweighing the loss.

Open Space:

New developments of over 10 dwellings are required to provide for on-site open space provision of a type and size appropriate to the site, but no guidance is given as to what type and size of open space is considered appropriate.

If new development does not generate a need for new open space then there is no justification for seeking a commuted sum of any amount. It is noted that the 10 dwelling threshold does not apply to the commuted sum element of the policy.

The requirement for commuted sums to fund works unrelated and not justified by the development is contrary to CIL Regulations. The intention to pool funds from several schemes, including schemes of less than 10 dwellings, is contrary to CIL Regulations and PPG.

Note: The Cumbria House Builders Group includes the following companies:
- Applethwaite
- Holbeck Homes
- Oakmere Homes
- Persimmon Homes Lancashire
- Russell Armer; and
- Story Homes

Trees:
Delete this whole section and replace with:-

“Planning applications that impact upon existing trees should be accompanied by a tree survey.

If it is proposed to remove existing trees it must be demonstrated that the benefits of the development outweigh the loss.”

Open Space:

Delete the first to paragraphs and replace with wording that gives an indication to both developers and decision makers as what is considered to be an appropriate type and size of open space.

Delete the paragraph “Where new open space is not required…evidence of local needs at the time of the application.”

No, I do not wish to participate at the oral examination

Please notify me.

DM6 - Flood Risk Management and Sustainable Drainage Systems

Yes

No

The DPD is not effective

The DPD is not consistent with national policy

The policy is unnecessary and contradicts national policy. If the policy is not deleted then amendments suggested in Question 7 are proposed along with the reasoning for these amendments.

Note: The Cumbria House Builders Group includes the following companies:
- Applethwaite
- Holbeck Homes
- Oakmere Homes
- Persimmon Homes Lancashire
- Russell Armer; and
- Story Homes

Location of Development – Avoiding areas of Flood Risk.

The four bullet points relate to new development in Zones 1, 2 and 3.

First bullet point – it is not clear why there is a need to mimic natural drainage. This bullet point should be deleted.

Third bullet point – if the site is within Zone 1, the most vulnerable development should be acceptable but the wording indicates that such development must be located in the lowest flood risk area within Zone 1 which is presumably higher ground. This is not appropriate and perhaps not the intention so delete the third bullet point.

The paragraph “Areas shown to be at risk…flood storage can be provided” should be deleted as it contradicts NPPF and associated Technical Guidance which sets out the circumstances where development is acceptable in Zones 2 and 3.

Surface Water disposal

It is not clear why drainage systems must mimic natural drainage systems as closely as possible.

First bullet point – delete. It should not be a developer’s responsibility to reduce the causes and impacts of flooding but instead to ensure the development is safe without increasing risk elsewhere.

Second bullet point – delete. A developer cannot remove pollutants at source if the source of the pollutants is not on site.

It is not clear why runoff should be managed on the surface, therefore this reference should be deleted.

It should not be necessary to provide a Flood Risk Assessment and Drainage Strategy for each application. The NPPF and Technical Guidance sets out the circumstances where FRA’s are required. Reference is made to the Cumbria Design Guide but the relevant section is not referred to. Rather than contradict national policy the sentence “An appropriate Flood Risk Assessment…and local guidelines” should be deleted.
Maintenance and management arrangements do not necessarily need to be secured by way of planning obligations a planning condition could be acceptable. Delete from last sentence “secured by way of planning obligations and”

Designing Sustainable Drainage System measures

First bullet point – the non-statutory standards referred to need to be specified.

Second bullet point – designing for a SUDs and its failure is belt and braces and excessive. Delete.

Third bullet point – there can be health and safety issues with managing run off on the surface. The policy should not be prescriptive on this point and should allow for site specific design. Delete third bullet point.

Last bullet point – delete. A development should not be required do provide betterment.

Yes, I wish to participate at the oral examination

To assist the Inspector with the developer's perspective.

Please notify me.

DM7 - Addressing Pollution, Contamination Impact, and Water Quality

Yes

No

The DPD is not effective

Location of development:

There is a contradiction between Core Strategy CS1.1’s pre-NPPF sequential approach to development, with the first priority including previously developed land/CS1.2’s reference to 28% of new housing taking place on such sites and a policy that appears to discourage development where there is pollution.

There are of course benefits to remediating contaminated sites.

Pollution:

It is not clear how the effect of the various elements of pollution will be assessed to determine the impact on health.

If all residential developments are going to be assessed on the basis that there can be no increased pollution, when all such developments generate traffic movements, then there will be no new residential developments. That is surely not the intent of the policy.

Air Quality:

It is not clear how a residential development can be made to have a positive and beneficial impact on air quality when traffic movements create pollution.

The circumstances in which an Air Quality Assessment is required should be clarified.

New residential developments will increase air pollution. The Land Allocations document indicates significant peripheral expansion of Kendal and there is an AQMA in Kendal town centre. It is not clear how such development can comply with a policy that precludes the introduction of additional sources of air pollution.

Contaminated Land and exposure to contamination

It is not the correct approach to assume contamination on all sites, including greenfield sites, where the proposed uses are particularly sensitive to contamination, including residential schemes. This means all planning applications for these uses must be accompanied by a contaminated land survey of one form or another.

Note: The Cumbria House Builders Group includes the following companies:
- Applethwaite
- Holbeck Homes
- Oakmere Homes
- Persimmon Homes Lancashire
- Russell Armer; and
- Story Homes

Delete whole policy and replace with:-

“Where on-site contamination is known or suspected to occur, planning applications should be accompanied by an appropriate level of investigation and assessment. Where contamination is present a remediation strategy will need to be agreed with the local planning authority prior to the commencement of the development.”

The explanation to the policy should be deleted and replaced with commentary on the three stages of assessment i.e.

Stage One – Desk Study;
Stage Two – Intrusive site investigation; and
Stage Three – Remediation Strategy.

No, I do not wish to participate at the oral examination

Please notify me.

DM8 - High Speed Broadband for New Developments

Yes

No

The DPD is not justified

The DPD is not effective

The DPD is not consistent with national policy

This policy is not required and will delay and inhibit the delivery of housing. The planning policy should not go beyond Building Regulations requirements (Part R).

The policy sets out requirements but 2.8.5 indicates that schemes will be considered on a case by case basis. If that is the intention then the policy should say this.

Development proposals must do three things as set out in the three bullet points but:-

1. Early engagement - What if the infrastructure providers do not have the capacity to enter into early engagement? BT’s website indicates that, in order to help them deliver on time they will “now accept registrations at outline stage.” It is not clear if this means at outline submission stage or outline consent stage, but given workload this is most likely to mean they will focus on developments that are likely to happen rather than those that are not yet confirmed as acceptable residential schemes in principle. There is no confirmation that they will engage prior to the submission of a planning application and no indication that they will engage for small schemes of 2 dwellings. The draft policy may preclude the submission of planning applications for anything other than single dwellings.
2.Broadband Statement - The requirement is a Broadband Statement not a Connectivity Statement. The difference is not clear but Openreach have confirmed they no longer provide connectivity statements (see attached email dated 07/12/12). So it would appear the requirement for a Broadband Statement may preclude the submission of planning applications for anything other than single dwellings.
3.Provision of high speed (superfast) broadband - It is not clear what developers must do to comply with the requirement to “undertake all reasonable actions to enable a superfast connection at a future date.” This must mean that the planning authority intend a planning condition that requires those reasonable actions to be undertaken. Such a condition may not comply with the six tests for planning conditions set out in the NPPF (paragraph 206) i.e. necessary, relevant to planning and to the development, enforceable, precise and reasonable in all other respects.

The draft policy requires the provision of Fibre to the Premises (FTTP) for any schemes of 30 dwellings or more. BT will only “fund the building of fibre infrastructure if commercially viable” (see attached). At the time of the submission of a planning application it may not be clear if FTTP is commercially viable and therefore the cost of the developer providing FTTP may also not be clear. The press release (Evidence Paper Appendix 2) estimates half of new properties can be connected to fibre broadband free of charge to developers, so half cannot. The press release refers to developer fixed cost contributions. The planning authority is wrong to assume that there will be no cost to the developer, as it does in the Evidence Paper: High Speed Broadband in New Developments August 2017. There are cost implications not considered in the authority’s viability assessment.

Openreach’s website (see attached) indicates that FTTP is a pure fibre connection all the way from the exchange into your home or business, with speeds up to 1Gbps. Their network serves 345,000 premises, with an intention to reach two million homes and businesses by the end of 2020. So the requirement for FTTP could potentially preclude the delivery of housing in South Lakeland for any large sites not yet with the benefit of planning permission.

2.8.1 Reference is made to the Council’s recent survey work of people buying new homes. This survey should be made available as part of the evidence base if it is part of the justification for the policy. The Evidence Paper: High Speed Broadband in New Developments August 2017 refers to a March 2017 survey. More detail should be released as to the numbers of respondents and what broadband speeds they were dissatisfied with.

2.8.2 The NPPF in Section 5. Supporting high quality communications infrastructure encourages the local planning authorities to support the expansion of electronic communications networks, including telecommunications and high speed broadband (paragraph 42) in the context of radio and telecommunications masts. The NPPF does not encourage local planning authorities to seek to restrict development if certain broadband speeds are not achieved.

2.8.5 The planning authority accept that there is not yet universal high speed broadband coverage, that in some cases new build developments may not be located in areas of high speed coverage and will not require superfast broadband where the costs are disproportionate and schemes will be considered on a case by case basis. This contradicts the policy requirements that will preclude developments of sites of 30 units or more unless there is FTTP.

2.8.6 There is no need to have planning policy to support Building Regulations Part R, it is sufficient to rely on Part R.
[APPENDIX: SEE ATTACHED DOCUMENT]

Note: The Cumbria House Builders Group includes the following companies:
- Applethwaite
- Holbeck Homes
- Oakmere Homes
- Persimmon Homes Lancashire
- Russell Armer; and
- Story Homes

Delete Policy.

If the policy is not to be deleted then the wording of the policy should be on the basis of:-

“Proposals for new residential development of over 10 dwellings should indicate how they will seek to work with infrastructure providers to seek to provide occupiers with sufficient broadband connectivity.”

No more need to be said than that.

Yes, I wish to participate at the oral examination

To provide a developer's perspective on the implications of the policy.

Please notify me.

DM11 - Accessible and Adaptable Homes

Yes

No

The DPD is not positively prepared

The DPD is not justified

The DPD is not effective

The DPD is not consistent with national policy

Policy

The policy requires all dwellings to be Building Regulations Requirement M4(2): Category 2 – Accessible and Adaptable dwellings with exemptions where this is not practically achievable, or where there would be significant harm to financial viability.

In addition, there is a requirement that on sites of over 40 dwellings 5% of the dwellings must be M4(3) Category 3: Wheelchair user dwellings in suitable locations, with the caveat that “If evidence at the time of a planning application indicates a different level of need then this element will be applied flexibly.”

The policy does not make clear what is to be considered a suitable location for M4(3) dwellings.

Lack of Evidence to support the draft policy

Planning Practice Guidance says: - “…Local planning authorities should take account of evidence that demonstrates a clear need for housing for people with specific housing needs and plan to meet this need.” (ID:56-005-20150327).

In September 2016 the planning authority produced an Evidence Paper: Optional Housing Standards. This was updated in June 2017 and again in August 2017. A Strategic Housing Market Assessment was adopted in November 2017. Within these documents it is difficult to find evidence that supports a clear need for 100% M4(2) housing or 5% M4(3) for sites over 40 dwellings.

It is agreed there is evidence of an ageing population but this in itself does not justify the requirements referred to in draft policy. PPG requires a clear need to be demonstrated but the planning authority have failed to demonstrate the need to support the policy requirements.

At 2.54 of the June 2017 Evidence Paper the Council’s position is simply it “would be too problematic in methodological terms” to attempt to define a specific proportion of homes to be M4(2) compliant (see attached extract), so it would be sensible to require all homes to be of M4(2) standards. This has been deleted from the August 2017 Evidence Paper, but it is nevertheless clear that this has been the planning authority’s long standing approach to determining the amount of M4(2) dwellings. It is considered a more robust case is required to justify 100% provision.

The August 2017 Evidence Paper does set out a “wider social justice” reasoning for the draft policy (2.55) which might explain the stance being adopted, but not the clear need for the percentages suggested.

A more appropriate way forward would be to establish the percentage of homes where persons may require Accessible and Adaptable Dwellings and to apply that percentage to newly built homes on schemes above a certain minimum threshold, to houses of a certain size and type, in appropriate locations and always, subject to a comprehensive viability assessment of the policy in the context of other policy requirements.

The June 2017 Evidence Paper indicates the new SHMA will calculate the need for specialist housing for older people (see attached). Section 10 of the SHMA considers both accessibility/wheelchair housing standards and the specific needs of older people. The SHMA does not provide evidence that justifies the requirement for all homes to be M4(2) or 5% of homes on certain schemes to be M4(3).

The SHMA includes analysis of Health-related Population Projections (10.17 to 10.20), People with Disabilities (10.21 to 10.27) and Wheelchair User Housing (10.28 to 10.31) but the statistics do not support the draft policy.

The analysis suggests that at least 40% of the population will have a mobility problem (SHMA 10.20) and 26.1% of households will have someone with a health problem (SHMA Figure 10.9). Neither point to a 100% requirement for M4 (2) or indeed 5% M4 (3) dwellings.

The analysis is partly based upon the 2011 Census returns with the Census question being “Do you have any long-term illness, health problem or disability which limits your daily activities or the work you can do?” This does not mean that those persons require either M4(2) or M4(3) dwellings. This is a broad self-assessment question. A person may have difficulty with physical work, but that does not mean they necessarily have problems getting around their home.

Reference is made in the August 2017 Evidence Paper to South Lakelands’s New Build Home Survey 2017. There does seem to be a lack of meaningful analysis with a tabular format, which might be because the number of respondents was limited, but we do not know.

The text at 2.43 of the August 2017 Evidence Paper simply seems to suggest:-
1. that new home residents may wish to have a larger home if they had children or more children - this would not be a surprising finding, but not one that justifies the policy requirements;
2. a preference for a bungalow for one or a number of residents; and
3. there was no confirmation as to the number of persons who had raised mobility issues.

The Key Findings at 2.57 of the August 2017 Evidence Paper refers to local surveys indicating a desire for older people to remain in their own homes or move to alternative open market housing, as a partial justification for the policy, so this evidence should be made available. This document should be a background paper so its empirical evidence can be analysed.

The planning authority must demonstrate a clear need for the percentages in the draft policy and they have failed to do this.

Proportion

Planning Practice Guidance says: - “…They (the local planning authority) should clearly state in their Local Plan what proportion of new dwellings should comply with the requirements…”
(Paragraph 008 Reference ID 56-008-20160519).

A reasonable definition of proportion is ‘a part, share or number considered comparative to a whole.’

The clear expectation is that, where there is evidence of a need then a proportion, not 100%, of dwellings, will have enhanced accessibility or adaptability standards. A more appropriate way forward would be to establish the percentage of homes where persons may require Accessible and Adaptable Dwellings and to apply that percentage to newly built homes on schemes above a certain minimum threshold, to houses of a certain size and type, in appropriate locations and always, subject to a comprehensive viability assessment of the policy in the context of other policy requirements.

Flexible application

For schemes of over 40 dwellings, the suggested variation to the 5% requirement, based on whatever interpretation of revised evidence, means the 5% requirement can go up or down with the M4 (2) requirement applying wholly to the residual dwellings

The evidence the Council will use to apply the 5% flexibly will be the SHMA, local housing needs surveys, the Housing Register or other relevant sources, but of course such evidence is open to interpretation and there will be some uncertainty as to what developers will be required to provide at the time of the application.

Appropriate only in certain locations

4.1.3 The Reasoned Justification indicates that the M4 (3) dwellings will be required on “larger housing developments in suitable locations”. If that is the intention the policy should say this and confirm what are considered to be suitable locations e.g. perhaps by referring to the Core Strategy settlement hierarchy i.e. Principal and Key Service Centres.

Viability

The policy allows for exemptions from the M4(2) provision where” it would significantly harm the financial viability of the scheme”. After the text setting out requirements in relation to M4(3) there is reference to “Where exemptions are sought on viability grounds…obtain an independent assessment of the appraisal.” It would seem the intention is to allow viability exemptions to both M4 (2) and M4 (3) requirements although this is not entirely clear (and it should be made clearer) that a viability test applies to both standards.

At 2.50 August 2017 Evidence Paper it is indicated that “The Council commissioned a new district wide viability study in early 2017 to support the preparation of the new Development Management policies and to underpin the early work on the new Local Plan….” The October 2016 Consultation Draft already included a policy requiring 100% M4(2) dwellings which would suggest viability considerations came after the planning authority embarked on this policy objective.

The NPPF (173 and 174) refers to the need to avoid a scale of obligations and policy burdens that threaten development viability.

Planning Practice Guidance states:-
“… Decision-taking on individual schemes does not normally require an assessment of viability. However viability can be important where planning obligations or other costs are being introduced. In these cases decisions must be underpinned by an understanding of viability, ensuring realistic decisions are made to support development and promote economic growth. Where the viability of a development is in question, local planning authorities should look to be flexible in applying policy requirements wherever possible."

Paragraph: 001 Reference ID: 10-001-20140306

The Cumbria House Builders Group (CHBG) have concerns about the viability implications of this policy in the context of other policy requirements, including 35% affordable housing and a Community Infrastructure Levy (current rate £55.80 per sq.m) and the implications for ensuring competitive returns for developers and landowners.

A considerable number of housing sites have topographical challenges which means costs of providing level access could be high and there will be implications on density and mix as there will be an inevitable need to provide larger dwellings to accommodate revised ground floor arrangements.

Contrary to PPG, it is likely that viability assessments will be required for most housing sites, large and small. It should be noted that the planning authority do not accept that there should be reduced affordable housing provision on sites of 10 units or less which means that affordable housing is a continued policy burden for many small schemes. There are already a significant number of housing sites where the principle of reduced affordable housing has been accepted by the planning authority based on viability grounds. This is likely to increase if this policy is implemented in its current form.

Planning Practice Guidance also refers to the need for a realistic understanding of costs, the value of development and the operation of the market. Direct engagement with developers is considered to be helpful and a collaborative approach is encouraged. PPG specifically encourages “transparency of evidence.”

Paragraph: 004 Reference ID: 10-004-20140306

The Cumbria House Builders Group have been frustrated by the planning authority’s unwillingness to engage in dialogue with them from the early conception of this policy in 2015 and make viability evidence available. This frustration is explained most succinctly in correspondence to the planning authority in a letter dated 30/10/17 which refers to previous representations to the planning authority.

It is unfortunate that financial viabilities have only become available very late in the plan making process and only after the planning authority’s Cabinet had committed to the publication of the Plan and shortly before Full Council confirmed that publication should proceed.

On 28/09/17 a Statement on Behalf of the Cumbria House Builders Group – South Lakeland Viability Study – Consultation Draft was submitted to the planning authority. This document, submitted before any actual viabilities were made available for inspection, raises a number of issues regarding:-
• Build Cost assumptions;
• Abnormal Cost assumptions;
• Sales Values;
• Transfer Values of affordable dwellings;
• Profit assumptions; and
• Threshold Land Values.

These concerns remain.

M4(3) should not be applied to market housing

PPG states:-
“Local Plan polices for wheelchair accessible homes should be applied only to those dwellings where the local authority is responsible for allocating or nominating a person to live in that dwelling.” (ID56-009-20150327).

Any M4(3) requirement can therefore only apply to the affordable housing element, where the local authority may have nomination rights. So the 5% requirement would represent a significant proportion of the affordable housing element of any scheme. The requirement is likely to require the support of housing associations. That support may only be able to be given on a site by site basis in particular locations. The policy exemptions for M4(3) do not allow for a circumstance where there is no identified need at a particular location and reluctance by affordable housing providers to include M4(3) dwellings.

Impact on Housing Supply:

The local context is one of significant under delivery of housing to meet housing requirements and CHBG members fear the implication of DM11 particularly will compound the continued under delivery of housing (see Figure 1 in Appendices).
[SEE APPENDICES ATTACHED]

Note: The Cumbria House Builders Group includes the following companies:
- Applethwaite
- Holbeck Homes
- Oakmere Homes
- Persimmon Homes Lancashire
- Russell Armer; and
- Story Homes

Delete the policy and replace with the following:-

“The Council will support the provision of dwellings that are designed and constructed in a way that enables them to be adapted to meet the changing needs of their occupants.”

Yes, I wish to participate at the oral examination

To provide a developer's perspective on the policy and to discuss the 'evidence'.

Please notify me.

DM12 - Self-Build and Custom Build Housing

Yes

No

The DPD is not justified

The DPD is not effective

SLDC’s Housing Monitoring Report 2017 refers to a significant number of small sites (less than 10 dwellings) with planning permission (621 dwellings on 422 sites). Many of these will be potentially available to self-builders and custom builders.

Developers will not embrace self-build or custom build housing on their developments with any enthusiasm. Apart from contractual difficulties, potential new house purchase customers may be discouraged from purchasing because of concerns and uncertainty of the nature of the self-build dwellings and the timing of delivery. This has an impact on both viability and deliverability. There are also practical concerns over start and finish of construction, the provision of services and health and safety management issues.

The best assistance the planning authority can provide to self-builders is to increase affordable housing thresholds, as the threshold of three or more dwellings outside Principal and Key Service Centres means a self-build scheme of more than two dwellings is not practical or viable.

Note: The Cumbria House Builders Group includes the following companies:
- Applethwaite
- Holbeck Homes
- Oakmere Homes
- Persimmon Homes Lancashire
- Russell Armer; and
- Story Homes

The sentence “In areas where the Council has evidence of strong local demand…incorporated into development schemes as part of the housing mix” should be deleted.

No, I do not wish to participate at the oral examination

Please notify me.