GSK Ulverston - GSK Biopharm Development Planning Statement
GSK Biopharm Development Planning Statement
GSK Biopharm Development Design & Access Statement
GSK Biopharm Development Statement of Need
GSK Biopharm Development Consultation Report
GSK Biopharm Development Environmental Statement Volume 1 - Non-Technical Summary
GSK Biopharm Development Environmental Statement Volume 2 - ES Chapters
GSK Biopharm Development Environmental Statement Volume 3 - ES Appendices
GSK Biopharm Development Flood Risk Assessment
GSK Biopharm Development Transport Assessment
10. GSK Biopharm Development Travel Plan
GSK Biopharm Development Screening for Likely Significant Effect Report (Habitat Regulation Assessment)
12. Construction & Environmental Management Plan
GSK Ulverston - GSK Biopharm Development Planning Statement
Lead Environmental Consultant
Flooding & Drainage Consultant and Transport Consultant
Our Ref: Q40055
INTRODUCTION ................................................................................................................................... 1
APPLICATION SITE AND SURROUNDING APPLICATION....................................................................... 3
APPLICATION DOCUMENTS ................................................................................................................ 7
PROPOSED DEVELOPMENT ................................................................................................................. 9
PLANNING POLICY OVERVIEW ..........................................................................................................16
CONSULTATION PROCESS .................................................................................................................26
KEY PLANNING CONSIDERATIONS ....................................................................................................30
PLANNING ASSESSMENT ...................................................................................................................32
Maximum Parameter Schedule
Planning Policy Guidance
Draft S106 Heads of Terms
This Planning Statement (PS) has been prepared by Quod on behalf of GlaxoSmithKline (‘GSK’ or
‘the Applicant) in support of an outline planning application for the construction of a new
pharmaceutical manufacturing facility at GSK’s existing site in Ulverston.
The application is submitted in outline with matters of layout, scale, appearance, access (for later
phases) and landscaping reserved within the parameters set out in the Parameter Plans and other
key documentation. The outline application aims to provide the necessary flexibility for the
detailed design of the scheme to be developed at the reserved matters stage while the Parameter
Plans provide a framework which will inform and control all reserved matters applications.
The proposed development will be brought forward in phases, which will include the appropriate
relocation of the existing sports and social facilities.
As set out on the application forms, outline planning permission is sought for:
“Pharmaceutical manufacturing facility (B2) of up to 119,000 sqm comprising
up to 3 production buildings, ancillary office and research and development
(B1a/B1b) floorspace, ancillary staff canteen (A3), an ancillary distribution and
storage warehouse (B8), a utilities building, a sports and social centre
comprising up to 3 pitches and a bowling green, a sports centre (D2) of up to
6,250 sqm, up to 2 associated sports facilities buildings (D2), a substation, a
waste water treatment plant, associated soft and hard landscaping, parking
areas, highway works and all other associated infrastructure.”
This Planning Statement explains the proposals and analyses their acceptability against the relevant
local and national planning policies and other material considerations. It covers the principle of the
development, other development management considerations, including likely impacts and
addresses any other issues that may be relevant in the consideration of this nationally important
Due to the nature of the Development, an Environmental Impact Assessment has been formally
scoped and undertaken in accordance with the Town and Country Planning (Environmental Impact
Assessment) Regulations 2011 ('the EIA Regulations'). In addition, other specialist and technical
analysis has been undertaken to help inform the design process. Where appropriate, this
information is included in the Environmental Statement ('ES') and in some instances this analysis is
submitted in the form of stand-alone documents. To avoid duplication, the Planning Statement
cross refers to relevant sections in the ES and other documents.
As recommended by the National Planning Policy Framework (NPPF) the submission of this
application follows a considerable period of positive pre-application consultation with South
Lakeland District Council (SLDC), other key stakeholders and the community. Further details of this
are set out within this Statement and the accompanying Consultation Report.
The remaining sections of this Planning Statement are structured as follows:
Section 2 provides the factual background, including a description of the site and
surrounding area, and relevant planning history;
Section 3 describes the documents that have been submitted as part of the outline planning
Section 4 provides detail on the proposed development;
Section 5 outlines the planning policy framework within which the application proposals
should be considered;
Section 6 summarises the public engagement process undertaken by the applicant prior to
the submission of the application;
Section 7 sets out the key planning considerations associated with the proposed
Section 8 provides an assessment of the principle of the proposed development against the
relevant policies and development management considerations; and
Section 9 draws overall conclusions.
THE APPLICATION SITE AND SURROUNDING AREA
This section of the Planning Statement describes the Application Site and surrounding area,
together with the relevant planning history.
Site and Surrounding Area
The GSK site (‘the site’) in Ulverston is located to the east of Ulverston, within the administrative
boundary of South Lakeland District Council and Cumbria County Council. The Site is approximately
1.2 miles (1.9 km) east of Ulverston town centre and is situated circa 0.3 miles (0.5 km) west of the
River Leven Estuary.
To the east of the GSK Site lies Morecambe Bay, designated as a Natura 2000 site for the
biodiversity that it supports. Morecambe Bay is designated as a Special Protection Area (SPA), Site
of Special Scientific Interest (SSSI), Special Area of Conservation (SAC) and RAMSAR site.
The North Lonsdale Road and Cross Lane Business Parks lie to the west of the GSK site, comprising
light industrial and business space. Residential areas lie to the north west of the site, including
Kennedy Street and North Lonsdale Road, along with the Ulverston Health Club. A number of
cottages and smaller businesses are located to the south west of the GSK site and residential
properties at Canal Foot.
The GSK site, which is just under 47 ha in size, is currently split into four separate elements, the
existing GSK manufacturing facility, known as the Cephalosporin (‘Cephs’) site; the West site which
is predominantly cleared after previous manufacturing use, the South site which currently includes
the Sports and Social facilities and playing fields; and the Southern Peninsula which houses two
waste water treatment plants on its northern edge. The four separate elements of the existing site
are discussed briefly below.
The Cephs Site
The existing manufacturing site is just over 12ha in size and is located north of Pulman Road. It
contains a variety of buildings and structures associated with the production of pharmaceutical
products, laboratories and ancillary office space. The Cephs site is secured by a 3 metre fence with
access via a security gatehouse on Pulman Road. The existing buildings are predominately one and
two storey structures, with some taller industrial buildings of approximately 6 metres and a four
storey office providing administrative functions located in the central part of the Site.
The ‘West Site’ is just under 11.5ha in size and is located on the western side of the masterplan
area. Demolition works have been carried out to remove redundant buildings and structures that
were previously on the site. The West Site also contains a small energy centre which will be
decommissioned as part of the proposed development, providing onsite electricity along with a
brick chimney associated with the site’s prior use as an iron works. Residential areas of Kennedy
Street and North Lonsdale Road are located immediately north and north-west of the West Site.
The South Site, located to the south of Pulman Road and the existing Cephs manufacturing facility,
contains a large surface car park serving the current manufacturing facility and the existing sports
centre and playing fields. It is just under 13.5ha in size. The sports facilities are used by GSK
employees and club members from the local community.
The Southern Peninsula of the GSK Site is just over 10ha and is the southernmost part of the site.
Two water treatment plants, one owned by GSK and linked to the existing Cephs manufacturing
process, and a treatment facility run by United Utilities, a local utilities company, are located in the
northern section of the site, accessed via a junction at Pulman Road. To the south of the waste
water treatment facility is open scrubland with identified ecological habitat which is discussed in
further detail within the Ecology chapter of the supporting ES.
The Application Site
Part of the West Site, the whole South Site and part of the Southern Peninsula site are contained
within the boundary of the planning application (‘the Application Site’), shown on the plan below.
The existing manufacturing plant and the part of the West Site covered by the recently approved
application for the Cephs Car Park (see below) are not included.
Figure 2.1: Parameter Plan 1a
Relevant Planning History
An overview of the planning history of the Application Site was obtained from South Lakeland
District Council. Due to the size of the site the Council were not able to perform a full Local Land
Charges Search (LLC1), the results therefore do not provide a definitive planning history of the site.
Notwithstanding this, the Council has confirmed that there are unlikely to be any other planning
permissions or refusals that have relevance to the proposed development. The Council's schedule
of planning revisions relating to the site is set out at Appendix 1.
The most recent application made by GSK at the Ulverston facility relates to the creation of a
replacement car park to serve the existing Cephs manufacturing site. The new car park, located
immediately west of the existing Cephs facility, will replace the existing car park located at the
The replacement car park application (app ref: SL/2014/0112) was approved by SLDC on 25 April
2014. The approved development description is as follows:
“Creation of a replacement vehicular access to the Cephalosporin’s site,
alterations to the public highway, including the construction of a new
roundabout, provision of a replacement car park, emergency access and
associated works, including landscaping, lighting and security fencing.”
The access created as a result of this application will form the access required for Phase 1 of the
proposed Biopharm development. The details for access relating to future phases of the Proposed
Development are reserved and will be subject to future applications.
An application for a new security and reception buildings has recently been submitted to SLDC to
provide details of the works to complete the replacement car parking and gatehouse arrangements
for the existing Cephs site.
This Outline Planning application for the proposed GSK Biopharm development is supported by a
number of core documents:
Completed Application Forms and Certificates – completed in accordance with the statutory
Site Location Plan – showing the boundary of the planning application site edged in red.
Environmental Statement (ES) – this presents the results of the Environmental Impact
Assessment (EIA) process, identifying the likely significant environmental impacts of the
Scheme and, where appropriate, proposed mitigation measures.
The ES comprises 3
volumes: Volume 1 is a non-technical summary of the ES, Volume 2 provides the main EIA
text, and Volume 3 provides the technical appendices.
Application Drawings (comprising Parameter Plans) – the Parameter Plans shows the
parameters to which the planning permission would be tied to for the purpose of ensuring
that the approved scheme is linked to the undertaken Environmental Impact Assessment.
They include 1:1,250 (1A) and 1:2,500 (1B) site plans as required for validation purposes.
Design and Access Statement – the statement explains and illustrates the design evolution
and principles of the proposed development.
The application is supported by the following standalone documents, which have also fed into the
Environmental Impact Assessment:
Transport Assessment – examines the likely transport impact of the development and,
where appropriate, provides details of proposed mitigation measures.
Flood Risk Assessment – examines the likely flood risk associated with the proposed
development and, where appropriate, provides details of proposed mitigation measures.
Screening for Likely Significant Effect Report (Habitats Regulation Assessment) – an
assessment of whether the proposed development will result in a likely significant effect on
Morecambe Bay SAC, SPA and Ramsar site, as required by Habitat Regulations;
Statement of Need – explains the rationale behind the proposed development and focusses
on its significant benefits.
In addition to the core documents identified above, the following supporting documents are
submitted with the Planning Application:
Non-Technical Summary – this document is published as part of the Environmental
Statement (ES) and provides a summary, in non-technical language, of the likely significant
environmental effects of the proposed GSK Biopharm development including the sports
facilities and the means to avoid or reduce adverse effects.
Interim Travel Plan – this provides information on the proposed control of highway and
pedestrian movements associated with the proposed scheme.
Outline Construction Environmental Management Plan (CEMP) – this sets out how the
impact of development’s construction on the site and the surroundings is to be managed and
Consultation Report – explains the consultation process undertaken by the applicant in
preparing the Planning Application and the matters arising from the process.
A description of the Proposed Development is set out in paragraph 1.4 of this Statement.
The application is submitted in outline and as such access, layout, scale, appearance and
landscaping are reserved for later approval. This is intended to provide the necessary flexibility for
the detailed design of the scheme at the reserved matters stage.
A series of Parameter Plans form part of this Application and provide the framework within which
future reserved matters applications will come forward.
The Parameter Plans are described in more detail within Appendix 2. They are:
PP1A Planning Application Area Scale 1/ 1,250
PP1B Planning Application Area Scale 1/2,500
PP2 Development Zones and Building Siting
PP4 Access and Circulation
PP7 Minimum and Maximum Building Heights and Site Levels
The Parameter Plans need to be read together as a set.
They define the layout of built
development and define key parameters including maximum heights, the location and minimum
extent of public realm, alignment of access routes, and proposed site levels across the
The principal elements of the application proposal are described below.
The Proposed Biopharmaceutical Development Buildings
Biopharmaceutical products are medicines engineered by scientists and manufactured by living
organisms to treat specific ailments. They are critical for the future competitiveness of the UK’s
pharmaceutical industry and research base.
Bio-pharmaceutical manufacturing has very specific requirements which influence the scale, layout,
design and location of the buildings in which it is undertaken. Closed, controlled bioreactors
cultivate cells or organisms to produce large quantities of the medicinal product. Once enough of
the product has been produced, the reactor contents are harvested. Further processing isolates,
purifies, and stabilises the bulk product.
Biopharmaceutical manufacturing facilities are commonly designed and constructed as a series of
separate building elements (typically, manufacturing, utility, warehouse and personnel blocks)
linked together by a spine corridor. This corridor enables people, material and services to move
between blocks in controlled conditions.
To keep production free from unintended contamination by naturally occurring microbes,
manufacture is carried out in a closed, clean and sterile environment. To meet good manufacturing
practice, regulatory and licence requirements of the Medicines and Healthcare Products Regulatory
Agency (MHRA), and the Food and Drug Administration (FDA), the existing manufacturing
operations and the new Biopharm development must be clearly segregated.
The production process can involve running a large number of very small batches or alternatively a
smaller number of large batches of the proposed product. This determines the size of reactor
required which can range from less than 100 litres (e.g. small scale microbial fermentation) to
20,000 litres (e.g. large scale therapeutic protein cell culture).
These processes will determine the layout inside a building and the number of floors required as a
production building of the same external dimensions can contain anything from a single floor to five
stories depending on the process equipment contained within it. Unlike most buildings, therefore,
the floorspace or Gross External Area (GEA) does not significantly alter the impacts of the building
or the number of staff within it. Instead these effects are driven by the production process.
At this time the actual medicines to be manufactured in the Ulverston development cannot be
known and could come from existing GSK medicines or GSK’s future pipeline. In order to give the
best possible definition for the proposed development to support the outline application, however,
GSK commissioned a comprehensive benchmarking study.
The study defined the parameters and envelope for the Biopharm development. PM Group, a
global leading biopharmaceutical engineering services design company completed the exercise by
reviewing thirty six different Cell Culture and Microbial biopharmaceutical facilities around the
world (in Europe, North America, Asia and Australia including facilities for GSK). Twenty four are in
operation and twelve are in design, construction or qualification.
Outputs from the benchmarking study were targeted to provide information to inform the outline
application content in the following areas:
buildings context (size, height, shape, layout);
operational assumptions by providing staffing estimates and likely vehicle movements; and
utilities consumption data and waste emissions.
Parameter Plans 2 and 7 set out the physical envelopes for the buildings including their location,
footprint, length, width and height. In the case of the utilities building, they also include the
location of flues and their maximum height. The maximum parameters have been used as a basis
to assess landscape, visual and other effects. The parameters allow flexibility for some slight
changes in the physical position and minimum and maximum scales for the buildings.
The parameters are set out in Appendix 2 to this document and have formed the basis of the
maximum floorspace assumptions for Phase 1 (up to 38,400 sqm) and Future Phases (up to 80,600
sqm) of the Biopharm development, although as noted above it is the building dimensions which
are of more significance in this case.
The operational requirements and likely utilities consumption and associated emissions have been
used to assess the likely impacts of the development, and have formed the basis for the
assessments contained in the relevant chapters in the ES. This methodology and the individual
assumptions are set out within that document.
The Proposed Sports and Social Centre
The development of the Biopharm will require the re-location of the existing Sports and Social
Centre and its associated pitches. The Illustrative Masterplan provides for quantitative ‘like for like’
replacement of the indoor facilities including space for a new building with capacity for an indoor
sports hall, cardio gym, dance studios, squash courts, changing rooms and toilets and a café
/reception area; a single storey bowls club hut and changing rooms for the sports pitches.
It also proposes like for like replacement of three full size football pitches (72m by 108m), one
floodlit, and a bowling green (circa 45m by 45m); in compliance with Sports England guidelines.
The Illustrative Masterplan also includes a comprehensive approach to landscaping including a
Green Corridor adjacent to Pulman Road, providing the required separation from the existing
manufacturing site and an improved route for pedestrians to Canal Foot. The Landscape Strategy
will provide linkages to footpaths and enhance the ecology of the site.
Figure 4.1 below shows the Illustrative Masterplan, described in detail in the Design and Access
Statement. This identifies the following building types:
Production Buildings – in which production of the products will take place;
Administration and Laboratory Buildings – which provide for administrative functions, testing
and quality control;
A Canteen building;
A Central Utilities building;
A Warehouse for storage; and
Sports and Social buildings including a sports centre, bowls club and changing rooms.
Figure 4.1: Illustrative Masterplan
These buildings are connected by a spine corridor which will allow for movement of people and
materials and also contain services. In addition to these buildings there are two utilities yards, a
waste water treatment plant, parking and servicing.
Figure 3.2 below, shows how the Illustrative Masterplan for the Biopharm buildings proposals fit
within the ‘envelope’ created by the Parameter Plans.
The Biopharm facility will be built in Phases. Parameter Plan 2 identifies a first Phase Zone, and a
Zone for future phases.
Figure 3.2: Parameter Plan ‘Envelope’
Phase 1 has been deliberately designed to avoid displacing the current Sports and Social Centre,
and to retain the main part of the existing Slag Bank which is a key feature of the site. As the area
closest to the site entrance from the town it will provide the front door to the development.
The ‘Head Block’ Building at the northern point of the phase will house the administration and
laboratories but will also provide the entrance to the first and future phases of the development,
located at the beginning of the Spine Corridor. The Phase 1 production building will contain all
utilities, and a small warehouse needed to support production. The utility yard will be to the south
of the production building with the Waste Water Treatment Plant beyond that. Access will be via
the upgraded existing road running south and then east to the security barriers to enter the
Future phases will be brought forward through reserved matters applications as pharmaceutical
products are identified. The Sports and Social Centre will be re-provided on the West site prior to
the commencement of any future phases that would displace existing facilities.
PLANNING POLICY OVERVIEW
Section 38(6) of the Planning and Compulsory Purchase Act 2004 requires planning applications to
be determined in accordance with the Development Plan unless material considerations indicate
The Development Plan for South Lakeland District Council is made up of the Core Strategy (October
2010), the Land Allocations Development Plan Document (December 2013) and ‘saved’ policies
from the South Lakeland Local Plan (September 2007)
The Core Strategy sets out the long term vision for the area, the Council’s objectives and the broad
amount of development proposed, its locations and policies to control it. The Land Allocations
Development Plan Document sets out specific site allocations and proposed uses.
Saved policies primarily relate to detailed development management issues which are yet to be
picked up by the Council’s recently adopted more strategic development plan documents. Where
the saved policies remain relevant, they will be referenced within this policy overview within the
Material considerations chiefly comprise the National Planning Policy Framework (NPPF, March
2012) the accompanying National Planning Practice Guidance (March 2014), and wider policies at
National, Sub-regional (Cumbria) and local level promoting economic growth and the
This policy overview does not seek to provide a detailed policy assessment of all relevant policies,
but rather considers the policies which address the key elements of the proposed development. A
full list of policies relevant to the proposed development is set out within Appendix 3.
The NPPF sets the overarching planning policy context within which local policies need to be
considered, and provides strong support for developments which contribute to sustainable
economic growth. The support for sustainable development is a central theme that runs through
the document. Paragraph 14 states:
“At the heart of the National Planning Policy Framework is a presumption in
favour of sustainable development, which should be seen as a golden thread
running through both plan-making and decision-taking”
The adopted Core Strategy identifies Ulverston as one of two ‘Principal Service Centres’, the highest
level settlement within the district. Policy CS3.1 sets out the main objectives for the Ulverston
area, which includes policies supporting regeneration, growth of the local economy and a
safeguarded and enhanced environment.
The supporting text confirms the Council’s broad support for GSK’s overall aspirations within
“Responding positively to the future intentions of GSK from Ulverston (as a
major employer in the area) through the development of a major employment
regeneration site” (page 45).
The more recently adopted Land Allocations DPD expands on the policies set out in the Core
Strategy, setting out more specifically the sites and locations to which the strategic policies set out
within the Core Strategy will apply.
The Site, largely because of its size extending to just under 47ha, is subject to three separate
designations within the Land Allocations DPD as follows:
The Development Boundary for Ulverston, which Policy LA1.1 states that development needs
will be met within in;
Existing Employment Sites, which will be safeguarded (Policy LA1.5); and
Outdoor Sports Facility, which will be safeguarded from development unless a suitable
replacement facility is provided in an accessible location in the same area of need for
demand. (Policy LA1.11)
The GSK site designations are summarised in the table below and illustrated in Figure 4.1.
Table 5.1: Designations relating to the GSK Site
Existing Employment Site
Figure 5.1: Local Plan Land Allocations DPD Site Designations
Source: Quod – based on SLDC Interactive Local Plan Policies Map
As set out above, the South site which is proposed to contain the new Biopharm manufacturing
facility, is therefore outside the adopted development boundary, and is in part allocated as an
Outdoor Sports Facility within the Land Allocations DPD.
The West Site, previously comprising redundant industrial buildings which have recently been
cleared and allocated as an existing employment site, is identified as an area for the proposed
replacement sports facilities.
It should be recognised that these designations pre-date GSK’s announcement to locate the new
Biopharm facility in Ulverston, a point explicitly acknowledged in paragraph 2.52 of the Land
Allocations document in relation to the Employment Land and Premises Study which informed the
specific site allocations in the plan. Elsewhere the document (page 109) highlights the importance
of GSK’s major employment site in strengthening the economic base of Ulverston, and (at para
5.42) highlights the potential of a new Biopharm facility.
As will be demonstrated in the planning assessment section below, and at greater length in the
Design and Access Statement, the proposed allocation of uses across the application site has been
based on a thorough assessment of the site context and development requirements and is
necessary to meet the Biopharm operational requirements. The impact of this arrangement will
result in the continued achievement of the objectives of policy – to ensure the retention of
employment uses and sports provision whilst protecting the countryside.
The following sections provide a thematic summary of the national and local planning policies that
are considered to be relevant and will provide the basis against which the development will be
New Employment and Strong Economy
Paragraph 9 of the NPPF states that supporting improvements to the built environment involves
creating jobs and paragraph 17 states that land-use principles should underpin local decision
making to include supporting high quality economic development to deliver business development
and thriving local places.
Paragraph 19 of the NPPF states that:
“The Government is committed to ensuring that the planning system does
everything it can to support sustainable economic growth. Planning should
operate to encourage and not act as an impediment to sustainable growth.
Therefore significant weight should be placed on the need to support
economic growth through the planning system.”
Paragraph 21 states that local planning authorities should (inter alia)
support existing business sectors, taking account of whether they are expanding or
contracting and, where possible, identify and plan for new or emerging sectors likely to
locate in their area. Policies should be flexible enough to accommodate needs not
anticipated in the plan and to allow a rapid response to changes in economic circumstances;
plan positively for the location, promotion and expansion of clusters or networks of
knowledge driven, creative or high technology industries;
The adopted SLDC Core Strategy recognises the importance of GSK to the economy and wellbeing
of Ulverston as a significant employer within the town. It envisages the strengthening of the
economy of Ulverston by responding positively to the aspirations of GSK for the major regeneration
of the site. Policy CS7.1 of the Core Strategy also states that sustainable employment related
development in existing employment areas would normally be permitted, including that:
“Suitable employment related development in existing employment areas,
including extensions to premises, will normally be permitted. It will be
necessary to ensure that the allocation of any greenfield land for employment
use is phased, in order to prioritise the use of previously developed land.”
The policy also states that best employment sites will be safeguarded from re-development for
Policy LA1.5 of the Site Allocations DPD allocates the existing GSK Ulverston site as an employment
site, with B1, B2 and B8 Use Classes considered acceptable. The overriding purpose of the policy is
to “ensure that a sufficient supply of employment land and premises is available to meet local
employment needs and promote new business creation”. The policy seeks to retain employment
uses within the allocated employment sites unless it can be demonstrated that the site is not
suitable for employment use, loss of the site would not compromise the district’s supply of
employment land or that the proposal relates to a mixed use development that would result in a
quantitative and qualitative improvement in the supply of employment land in the district overall.
As noted above the LA1.5 employment allocation includes the West Site.
Paragraph 7 of the NPPF states that there are three dimensions to sustainable development:
economic, social and environmental. The economic dimension should contribute to building a
strong, responsive and a competitive economy and paragraph 19 makes clear that particular weight
should be attached to the economic benefits of development. A social role should support strong,
vibrant and healthy communities and an environmental role should contribute to protecting and
enhancing the natural, built and historic environment.
Policy CS1.1 of the Core Strategy sets out the Council’s 11 sustainable development principles. This
includes that all developments should help to meet the diverse social and economic needs of the
local community. It also states that opportunities should be taken to mitigate against, and adapt
to, climate change including addressing flood risk and improving waste management. Policy CS8.7
of the Core Strategy details specific design procedures that would have to be implemented for
Policy CS8.7 (Sustainable Construction, Energy Efficiency and Renewable Energy) states that new
commercial buildings of more than 1,000 sq m. will normally be required to meet the BREEAM 'very
good' standard and by 2013 new buildings will need to achieve the BREEAM 'excellent' standard.
The Council will seek to achieve appropriate on-site renewable and low carbon energy sources
The most appropriate technology for the site and surrounding area should be used. The Design and
Access Statement (DAS) submitted with this application, as required by this policy, includes a
Sustainability Statement which shows how the proposed development will contribute to these and
other objectives of sustainable development.
Paragraph 100 of the NPPF states that development should be made safe without increasing the
flood risk elsewhere. It also states that local authorities should use opportunities offered by new
development to reduce the causes and impacts of flooding. Paragraph 101 states that a Sequential
Test is required to steer new development to areas with the lowest probability of flooding and a
Flood Risk Assessment is required to apply this test.
Where development cannot be steered to areas of less flood risk, Paragraph 102 states that an
Exception Test must be carried out so that the Flood Risk Assessment shows that the development
would be safe for its lifetime.
The NPPG states areas at risk of flooding means land within Flood Zones 2 and 3 or land within
Flood Zone 1 that has critical drainage problems and has been notified to the local planning
authority by the Environment Agency (Reference ID 7-003-20140306).
Policy CS1.1 addresses issues relating to flood risk and states that opportunities should be taken to
mitigate against and adapt to climate change including addressing flood risk. Policy CS8.8 deals
with Development and Flood Risk, which follows the guidance set out within national planning
policy, directing developments towards flood risk zone 1.
The policy states that development within flood risk 2, 3a and 3b would only be acceptable when it
is compatible with national policy and when the sequential and exception test has been satisfied.
Developments will need to demonstrate that they will not have a significant impact on the area’s
capacity to store floodwater, that flood risk measures can be implemented, that surface water can
be managed in a sustainable way, that arrangements for maintenance and management of any
flood protection and/or mitigation measures are in place and that the benefits of the proposal to
the community outweigh the flood risk.
High Quality Design
Paragraph 56 of the NPPF highlights that the Government attaches great importance to the design
of the built environment. Good design which is a key aspect of sustainable development. It is
indivisible from good planning and should contribute positively to making places better for people.
Paragraph 61 also states that high quality design goes beyond aesthetic considerations and, as
such, planning decisions should address the connections between people and places and the
integration of new development into the natural, built and historic environment.
Paragraph 109 of the NPPF states that the planning system should contribute to and enhance the
natural and local environment by protecting and enhancing valued landscapes, geological
conservation and soils. Paragraph 113 also states that local planning authorities should set criteria
policies against which proposals for any development on or affecting protected wildlife or
geodiversity sites or landscape areas will be judged. Paragraph 114 states that local planning
authorities should maintain the character of the undeveloped coast, protecting and enhancing its
Policy CS8.10 of the Core Strategy states that the siting, design, scale and materials of all
development should be of a character which maintains or enhances the quality of the landscape or
townscape and, where appropriate, should be in keeping with local vernacular tradition. It also
states that new developments should protect and enhance key local views and features /
characteristics of local importance and incorporate layouts that reinforce specific local
Policy CS8.6 is also of relevance to the consideration of the design of the proposal, supporting the
safeguarding and where possible enhancement of historic environment assets, including their
characteristic settings and any attributes that contribute to a sense of local distinctiveness. Such
assets include listed buildings and features, conservation areas, scheduled ancient monuments and
registered parks and gardens.
Saved policy C5 relates to external lighting which seeks to minimise the impacts of lighting on
Section 11 of the NPPF deals with conserving and enhancing the natural environment. Paragraph
109 states that the planning system should contribute to and enhance the natural and local
environment by minimising impacts on biodiversity and providing net gains where possible and
prevent both new and existing development from contributing to or being put at unacceptable risk
from, or being adversely affected by unacceptable levels of soil, air, water or noise pollution.
Paragraph 118 of the NPPF states that where the significant harm from a development cannot be
avoided, it should be adequately mitigated.
Policy CS8.4 of the Core Strategy states that all development proposals should protect, enhance
and restore the biodiversity and geodiversity value of land and buildings, maximise opportunities
for restoration, enhancement and connection of natural habitats and incorporate beneficial
biodiversity and geodiversity conservation features, including features that will help wildlife to
adapt to climate change where appropriate.
As set out within this Statement, the site is located in close proximity to Morecambe Bay, a
designated site of significant ecological value. Given Morecambe Bay’s designation as a SSSI,
among other ecological designations, a Screening for Likely Significant Effect Report (Habitats
Regulation Assessment) has been prepared and is submitted as part of the outline application
package. The findings and conclusions of the Screening Report are included within the ES.
Recreation and Access
Section 8 of the NPPF addresses the need to promote healthy communities and paragraph 69 states
that the planning system can play an important role in facilitating social interaction and creating
healthy, inclusive communities. Paragraph 70 also states that to deliver social, recreational and
cultural facilities and services the community needs, planning decisions should guard against the
unnecessary loss of valued facilities and ensure that established facilities are retained for the
benefit of the community.
Paragraph 73 also states that access to high quality open spaces and opportunities for sport and
recreation can make an important contribution to the health and well-being of communities and
paragraph 74 states that existing sports and recreational buildings and land including playing fields
should not be built on unless the loss resulting from the proposed development would be replaced
equivalent or better provision in terms of quantity and quality in a suitable location.
Policy LA1.11 of the SLDC Local Plan Land Allocations (2013) identifies the sports club and pitches in
the South site as an ‘Outdoor Sports Facility’ which is to be safeguarded from development unless a
suitable replacement facility is provided in an accessible location.
The policy for Outdoor Sports Facilities follows the approach set out in Sport England’s national
policy for playing fields. Their Planning Policy Statement, A Sporting Future for Playing Fields in
England, suggests that Sport England will oppose any development of existing playing fields unless
they are “replaced by a playing field or playing fields of an equivalent or better quality and of
equivalent or greater quantity, in a suitable location and subject to equivalent or better
management arrangements, prior to the commencement of development.”
Residential Amenity (Air Quality, Noise and Vibration)
Paragraph 109 of the NPPF specifically states that the planning system should contribute to and
enhance the natural and local environment by preventing both new and existing development from
contributing to or being put at unacceptable risk from, or being adversely affected by unacceptable
levels of soil, air, water or noise pollution or land instability.
Paragraph 123 states that policies and decisions should aim to mitigate and reduce to a minimum
adverse impacts on health and quality of life arising from noise from new development, but also
recognise that development will often create some noise and existing businesses wanting to
develop in continuance of their business should not have unreasonable restrictions put on them
because of changes in nearby land uses since they were established.
Paragraph 144 states that when determining planning applications, local planning authorities
should ensure that any unavoidable noise, dust and particle emissions and blasting vibrations are
controlled, mitigated or removed at source and establish appropriate noise limits for extraction in
proximity to noise sensitive properties.
The SLDC Core Strategy (2010) states within its strategic objectives that the Council will aim to
protect the unique character of the district by promoting prudent use of resources, minimising the
generation of waste, promote recycling, preventing where possible or mitigating against the effects
of air, water and soil pollution as well as noise.
The NPPF provides the Government’s overarching policies in relation to pre-application
engagement and front loading of the planning process. It advises that early engagement has the
significant potential to improve the efficiency and effectiveness of the planning system with good
quality pre-application discussions resulting in improved outcomes for the community. Paragraph
189 goes on to state that:
“Local Planning Authorities have a key role to play in encouraging other parties
to take maximum advantage of the pre-application stage”
Paragraph 190 states:
“The more issues that can be resolved at pre-application stage, the greater the
This positive approach to positive pre-application engagement is reinforced within the recently
published National Planning Practice Guidance (6 March 2014). The guidance states that the
positive impacts of pre-application discussions can be achieved by, amongst others:
“Working collaboratively and openly with interested parties at an early stage
to identify, understand and seek to resolve issues associated with a proposed
The Applicant has progressed in accordance with the spirit of positive pre-application discussions
set out within the NPPF and the NPPG, and the application proposals are subsequently submitted
following an extensive period of consultation with SLDC and CCC Officers, key statutory and nonstatutory stakeholders as well the wider local community.
The approach to public consultation is set out in detail within the enclosed comprehensive
Consultation Report. This section, therefore, provides only a summary of the local stakeholder
engagement process undertaken by the Applicant prior to the submission of the application.
The Applicant has engaged positively and pro-actively with SLDC, with a number of meetings having
taken place in the run up to the submission of the application. The meetings have sought to
identify any issues at the early stages of the development design process.
The submission of the application follows detailed dialogue with statutory consultees including the
Cumbria County Council, Environment Agency, Natural England and Sport England. As part of the
extensive pre-application discussions, the Applicant has also engaged with other key stakeholders,
such as the Royal Society for Protection of Birds, Cumbria Wildlife and United Utilities.
Details of the meetings with key stakeholders are set out within the Consultation Report which
supports the submission of the application.
A public exhibition and consultation event took place at Coronation Hall in Ulverston between 20
February and 1 March 2014. The exhibition was advertised in the local press and via GSK, and
attracted a significant level of interest from members of the public. Attendees were invited to
complete a questionnaire asking for their thoughts on the proposed development.
The public exhibition was well attended, with over 300 attendees at the exhibition. Over 70 visitors
to the exhibition completed a feedback form and, of those, over 88% strongly agreed, and 11%
agreed that the proposed development will bring a positive contribution to the area. The results
demonstrate that there is significant support for the proposed development from the local
A public consultation website showcasing the proposed development was also set up by GSK, and
publicised locally to increase awareness of the proposed development and its implication for
Ulverston. The website provides information in respect of the development, and provides an
opportunity for local stakeholders to provide direct feedback to the Applicant.
Response to Consultation
The Consultation Report sets out in detail the full range of issues that were identified and how
these have been addressed in the Masterplan and planning application.
The most commonly raised issues related to the potential benefits of the development including
jobs and local employment, training and up skilling of local people, and supply chain opportunities
for local businesses. GSK proposes, as part of the Section 106 Heads of Terms, to work with SLDC
and other local partners to maximise local benefits in these areas.
A number of environmental issues were also raised, although none by more than a third of
consultees. These include design and landscape, road traffic congestion, sports and recreation
provision and ecology.
The supporting Design and Access Statement sets out the high quality design aspirations of the
scheme, and the commitment to incorporating local materials throughout the development where
possible, as well as proposals to mitigate adverse impacts on views.
The Transport Assessment and draft Travel Plan set out how potential traffic impacts will be
managed and mitigated, including junction improvements to be undertaken prior to the second
phase of the Biopharm.
The Flood Risk Assessment identifies the commitment of the applicant, through its proposed
drainage strategy, to implementing a drainage scheme which has no negative impact on the local
flood water management issues that surround the site. As part of the development of the West
site, the drainage strategy will ensure that the current drainage problems associated with the
Kennedy Street drain will not be made worse and opportunities for improvement will be
investigated and considered.
The impact on the Sports and Social Centre and pitches was considered at an early stage, including
pre-application consultation with Sport England. The provision of the replacement Sports Provision
on the West site directly addresses the issues raised as well as formal planning policy.
The outline planning application has therefore benefitted from extensive consultation, and reflects
and addresses the issues raised through that process.
KEY PLANNING CONSIDERATIONS
The proposed development has been prepared taking full account of the detailed planning policy
relevant to the proposed development. A summary of the relevant policies is set out in the above
Section 5, and a full list of relevant policies is provided within Appendix 3.
As well as responding to the relevant national and local planning policy, the development proposals
have responded to comments received from statutory consultees and local stakeholders as part of
the pre-application process. The application follows the submission of a Scoping Report to SLDC on
31 January 2014. A formal Scoping Opinion was received on 19 March 2014 and has informed the
design and assessment process.
On the basis of the development proposals and key policies identified above the following areas are
considered to be the key planning considerations:
Principle of the development – the overall acceptability of the proposed development in the
context of the land use designations set out in the Land Allocations DPD;
Economic Development – the ability of the development to deliver significant employment
generation and economic development benefits to Ulverston;
Flood Risk – how the proposal and Flood Risk Assessment meet national and local policy
requirements particularly in relation to areas of the site falling within flood zones 2 and 3 ;
Ecological impacts – the findings of the assessment of potential impacts on protected
habitats sensitive ecological receptors, including Morecambe Bay and the Ulverston Canal,
and the ability to avoid or mitigate any impacts, as well as the ability to provide
environmental enhancements through the Landscape Strategy;
Impacts on Sports and Social Facilities – the extent to which proposals for the West Site
meet local and Sport England policy;
Design and Visual Impacts - meeting national and local policy requirements for high quality
design and consideration of the potential impacts of the development on landscapes and
Transport & Highways Impacts – the impact of the proposed development during the
construction stage as well as the operational phases on the existing highways network;
Impacts on Residential Amenity – the acceptability of any likely impacts including noise,
vibration and lighting on nearby residential amenity; and
Energy and sustainability – the sustainability and low energy measures that can be adopted
within the proposed development, taking into account the specific requirements of
Each of these matters are considered in turn below and should be read in conjunction with the
supporting information set out within the respective ES chapters, the relevant appendices and the
DAS. Appendix 2 summarises how the implementation of the outline planning application will be
controlled through parameters and the submission of additional information in conjunction with
reserved matters applications.
Principle of Development
The Statement of Need sets out the strong policy support at national, sub-regional (Cumbria) and
local levels for development which supports economic development and highlights the importance
of the pharmaceutical and life sciences sectors.
The Government’s Plan for Growth (March 2011) sets out how it aims to:
“achieve strong, sustainable and balanced growth that is more evenly shared
across the country and between industries.”
The Strategy for UK Life Sciences (2012) aims to consolidate the UK’s role as a “world-leading place
for life sciences investment.” It identifies life sciences as a highly innovative and dynamic sector
which is growing faster than the economy as a whole and provides highly skilled jobs.
The Local Growth White Paper (October 2010) sets out how the Government seeks to empower
local areas to deliver growth through, amongst other things, reform of the planning system; and the
establishment of Local Enterprise Partnerships to lead growth locally.
The Cumbria Local Enterprise Partnership in their Strategic Economic Plan (SEP) (2014-2024)
identifies Advanced Manufacturing Growth as one of the four priority themes of its strategy. It
specifically identifies GSK’s proposals which are the subject of this application as being a critical
element of this strategy.
As has been noted above, South Lakeland Council’s Development Plan also makes direct and
positive reference to forthcoming proposals for the GSK site, both in the Core Strategy and Site
The principle of the development has also drawn wide cross-party and community support,
evidenced by the collaborative working to secure the investment decision when GSK was selecting
a location for its investment. This support has been re-confirmed through the pre-application
consultation process in which over 95% of respondents were positive about the potential benefits
of the development for the area.
The DAS sets out the process through which the preferred development option, which is the basis
for this outline planning application, was reached. This involved an iterative process taking into
account planning policy, the site context and constraints and, critically, the operational
requirements of bio-pharmaceutical production.
Section 4 of the DAS sets out how the project requirements were defined, through the
benchmarking process described above, and refined into Masterplan and Sustainability Objectives.
These were then tested against the two parts of the GSK site which were, in principle, capable of
being developed – the West site and the South site. This process is described in Section 5 of the
The West Site, being within the Ulverston Development boundary and allocated for employment
uses was tested to see whether it could meet Biopharm operational and wider Masterplan and
sustainability requirements. This assessment found that the site was not appropriate for a number
Firstly, as a smaller site, (11.5 ha compared to 13.5 ha) it would be difficult to accommodate the
proposed scale of development whilst achieving sufficient separation from other uses to the east
and west. This would impact on the amenity of residential properties. And crucially it would make
it difficult to achieve clear physical segregation from the existing manufacturing facility. The
avoidance of cross contamination in either direction is a key regulatory requirement.
Secondly, the western part of the site is in an area of high flood risk (Zone 3) in which development
should be avoided if possible. Other parts are in Flood Zone 2.
Thirdly, the building footprints would also potentially be constrained by the limited site size which
could increase building heights and impose operational constraints.
Fourthly there would be limited potential for servicing access to the northern part of the site which
would make site operations more difficult. It would also reduce future flexibility.
For all these reasons the West Site was not an appropriate location for the Biopharm proposals.
The analysis of the South Site showed that, as a larger site, it was better able to meet the
operational requirements of the development, with clear segregation across Pulman Road and a
Campus Style development with a spine as is typically used for such developments.
As the proposed Biopharm development is located on the South Site it is outside of the adopted
development boundary identified in the Land Allocations DPD and technically contrary to Policy
To assess the significance of this it is important to understand the criteria used for identifying the
site allocations and therefore the purpose of South Lakeland District Council in setting these
policies. These boundaries were, of course, drawn up without knowledge at the time of the current
proposals, the principle of which the District Council supports.
The criteria for defining the boundaries of towns and large villages are set out in paragraph 2.2.
These criteria include “existing, shopping, and other urban uses” and “including recreational open
space”. The existing South Site currently combines a car park with a sports centre and therefore
there appears no reason in principle why it should not be included in the development boundary.
Leaving this aside, the defined development boundary of Ulverston was influenced by flood risk,
and the need to minimise landscape impacts and coalescence with other settlements (paragraph
5.7). However, given the self -contained nature of the South site – bounded by natural constraints
to the south, east and west, and the existing manufacturing plant and West site to the north - there
is no potential for this development to lead to coalescence. From a flood risk point of view, as we
shall describe below the South site is a preferable location to the West Site.
Therefore, subject to managing landscape impacts, the fact that the South Site is outside of the
defined boundary would not mean that development of the Biopharm there would be inconsistent
with the reasons why the policy itself was adopted. It should also be noted that not all of the South
Site will be developed and, therefore, there will be natural buffers to development formed by the
non-developed parts of the South Site and the retained slag bank.
In order for the development of the South site to be acceptable it was clearly understood that it
would be necessary to meet the requirements of Policy LA1.11 of the SLDC Local Plan Land
Allocations (2013) and Sport England’s national policy requirements for playing fields. This policy
test is dealt with further below in relation to Recreation and Access issues.
The use of the West Site for a non-employment use needs to be considered in relation to Policy
LA1.5 Existing Employment Areas. This policy seeks to retain employment uses on identified sites
(of which the West Site and existing manufacturing site form one) unless “loss of the site would not
compromise the district’s supply of employment land and premises.”
In the case of the proposals which are the subject of this application the employment uses on the
West site are effectively ‘swapped’ with the sports pitches on the South site. Given that the South
site is slightly larger this will result in a net increase in land in employment or ancillary use from
11.5 to 13.5 ha. This is regarded as being consistent with policy LA1.5 as, rather than compromising
the District’s supply of employment land, it would increase it.
In summary there is exceptionally strong policy support for growth in advanced manufacturing, and
life sciences and pharmaceuticals in particular, at National, Sub-Regional and local levels.
planning system is expected to facilitate such developments and address barriers to development
(NPPF paragraph 21), and work with LEPs, businesses and other local partners to ensure their
delivery. The Cumbria LEP Strategy and the Development Plan both make positive reference to
investment on the GSK site.
The proposals for the GSK site have been carefully developed in the context of planning policy and
are consistent with policies LA1.11 and LA1.5 of the Development Plan. The requirement to
develop the South site arises primarily from the operational needs of the Biopharm development
and meeting national and local policies on flood risk.
Development outside the Ulverston
development boundary is technically inconsistent with Policy LA1.1, however, as shown above this
would cause little conflict with the intentions of the policy and as such it is suggested that this
should be given limited weight in consideration of the proposals.
As well as addressing strategic policy objectives for economic growth the development will also
provide local benefits in terms of employment and business opportunities.
The proposed development is expected to provide a significant opportunity to reinforce and
increase the employment and skills base at the site; build experience in high-value added, high-tech
growth sectors; and create long-term, sustainable, permanent jobs in high value growth sectors in
line with policy objectives at all spatial levels.
The key socio-economic effect relating to the proposed development during both the construction
and operational phase of the scheme is the creation of employment opportunities. Phase 1 alone is
estimated to generate a peak construction workforce on site of approximately 430 workers. Further
employment will be created during the construction of subsequent phases. These jobs will provide
opportunities for training in a range of different construction activities.
The operational phase of the development is expected to accommodate 708 employees (208 in
Phase 1). These jobs will require a range of skills including entry level roles in supporting services.
In addition to the employment effects arising from the construction and operational phases, the
proposed development is also expected to have a beneficial impact on generating wages and
spending. The combined effect of spending by employees and business, particularly during the
operational phase, is expected to create a further 70 jobs which could be supported in the local
GSK will ensure that contractors work with local agencies to provide employment opportunities,
and operate a supply chain portal for local businesses. This commitment is set out in the Section
106 Heads of Terms at Appendix 4. The scale and quality of employment proposals is of at least
The development will therefore provide significant economic benefits, meeting a range of policies
set out in Section 8 of South Lakeland’s Core Strategy, notably Policy CS7.3 (Education and Skills).
The submitted ES is supported by a detailed Flood Risk Assessment (FRA) and a Drainage Strategy,
which is summarised within the Flood Risk chapter within the ES. The submitted information
addresses the policy requirements relating to Flood Risk, in particular, the development should not
increase flood risk elsewhere, and satisfy the requirements of the sequential test set out within the
NPPF, to steer new development to areas with the lowest probability of flooding.
As evidenced within the FRA, pre-application discussions in respect site flooding and drainage took
place with the EA, CCC, SLDC, as well as non-statutory stakeholders such as United Utilities and
local residents as part of the overarching pre-application community engagement exercise.
Part of the West Site (west of the disused railway line) is located within Tidal Flood Zone 3 (high
risk), and broadly the same area is also within Fluvial Flood Zone 3 (high risk). Small parts of the
western and eastern parts of the South Site are located within Tidal Flood Zone 2 (medium risk).
Maps demonstrating the areas subject to these flooding zones are located within Flood Risk
chapter of the ES. In the FRA, the Sequential Test has been applied and the development flood risk
vulnerability classifications have been shown to be suitable for the Flood Zones in which they are
As noted above it is preferable, in policy terms that the main part of the Biopharm development
should be located in the lowest flood risk zone, on the South site. The existing slag bank provides a
form of tidal flood protection and will be retained to maintain its function as a flood defence.
The area of the South site which is at risk of ‘overtopping’ from Morecambe Bay is in assumed
Phase 3 of the development and primarily zoned for car parking. Due to the timescales involved, a
flexible approach to addressing this issue will be maintained, with options that could include the
management of the risk through closing a section of the car park in advance of a storm event.
The proposed finished floor levels (FFL) of the buildings across both, the South and West sites, have
also been designed to prevent flooding of the buildings. It is in the interest of the applicant to
deliver flood resistant buildings given the value of the products to be manufactured at the
proposed facility, and as such appropriate FFL levels have been proposed and tested within the FRA
The proposed location of the sports & social facilities on the West site represents the
recommended approach in sequential policy terms. The Sports and Social building itself is located
in the low flood risk part of the site and the sports pitches which are considered to be ‘water
compatible’ and appropriate for Flood Zone 3, are located in the areas of highest flood risk.
Following the implementation of the mitigation measures set out in detail within the submitted
Flood Risk ES chapter, the residual flooding impacts on the West and South Sites are either minor or
negligible during the operational period of the development.
During the construction period, there is a minor to moderate risk from tidal flooding on the South
Site, and minor on the West Site. These impacts are temporary in their nature and will be mitigated
by appropriate contractor measures to prevent flooding impacting the construction programme.
The proposed development is therefore fully in accordance with paragraph 100 of the NPPF, and
the recently published NPPG. The development is also fully in accordance with adopted local Policy
CS1.1 and CS8.8.
The application site is located in close proximity to a number of sensitive ecological habitats. The
main ecological interest relates to the Morecambe Bay, designated as a Site of Special Scientific
Interest (SSSI) containing a number of protected species. The impact of the proposed development,
during the construction and operational phases on the sensitive ecological habitats therefore needs
to be considered, and appropriate mitigation proposed.
The Ecology chapter of the ES is supported by a Screening for Likely Significant Effect Report
(Habitats Regulation Assessment) given the proximity of the proposed development to the sensitive
ecological receptors and consequently the need to screen the proposal under Regulation 61 of the
Conservation of Habitats and Species Regulations 2010.
In line with the guidance set out in the NPPF, the applicant has entered into pre-application
discussions with both statutory and non-statutory consultees. Discussions with statutory bodies
such as the Environment Agency (EA) and Natural England (NE) have taken place alongside
discussions with interest groups such as the Royal Society for the Protection of Birds (RSPB) and
Cumbria Wildlife Trust (CWT). The pre-application discussions have provided important guidance
on how the impacts of the proposed development in this sensitive location should be assessed and
mitigated to make the development acceptable from an ecological perspective.
A number of detailed and comprehensive surveys have been undertaken to understand the value of
the site for ecology. These included bird, badger, reptile, bat, water vole, otter and detailed great
crested newt surveys amongst others. The surveys were undertaken over a period of a year
between October 2012 and October 2013 with methodologies agreed with the relevant statutory
bodies. It is important to note that the proposed development does not extend into the designated
In assessing the potential impacts of the proposal on Morecambe Bay, the Screening Report
concludes that the construction works would not have a likely significant effect on the features of
interest or the condition of the designated Morecambe Bay.
In relation to the Operational phase the Screening Report considers the potential effects of the
impacts of development on ecological receptors, notably the bird population on the Southern
Peninsula site, Ulverston Canal and Morecambe Bay.
The assessment included consideration of potential emissions from the proposed Central Utilities
Building on the South Site and concluded that given the identified locations and maximum heights
for flues identified in the draft Parameter Plans there would be no significant impacts. These
matters are fixed by Parameter Plan 7.
The assessment also considered the potential impact of lighting on birds and bats. It concludes
that, subject to an appropriate Lighting Strategy, which will need to be agreed when Reserved
Matters applications are brought forward, there would be no significant impacts.
A key ecology mitigation and enhancement measure is GSK’s commitment to actively manage the
Southern Peninsula to increase the ecological value of the site. A detailed Landscape Strategy is
also proposed which will include the green corridor within the South site, retention of existing trees
where possible and replacement with sensitive native species where appropriate, retention of most
of the slag bunds to maintain their contribution to the site wide ecology and installation of bird and
bat boxes where appropriate.
Detailed assessment of pre and post mitigation impacts on specific species identified to be present
or utilising the site are set out within the Ecology chapter of the ES. In overall terms, the
permanent impact of the proposed development on the designated Morecambe Bay site will be of
beneficial moderate significance.
The proposed development is therefore fully in accordance with paragraph 109 of the NPPF by
minimising impacts of developments on biodiversity and providing improvements to existing
habitats where possible. The proposal is in line with Policy CS8.4 of the Core Strategy requiring the
protection and enhancement of the biodiversity value of natural habitats, as well as incorporating
features that would be beneficial to existing wildlife.
Sport Pitches and Access
A key consideration in developing proposals for the South Site, once it was determined that it was
necessary for the Biopharm to be located on this site for operational reasons, was the need to
ensure compliance with Policy LA1.11 of the Allocations Document and Exception E4 of Sport
England’s Playing Fields Policy.
This required, as noted above, the replacement of sports provision of equivalent or better quantity
and quality in a suitable location. In considering this approach the Masterplan team selected an
option which allowed the Biopharm development to be phased from West to East across the South
Site, allowing the Sports and Social Club and sports pitches to remain in place for the first phase of
To enable future phases the Sports and Social Centre on the West site will need to be provided
prior to the cessation of use of the existing facility. This will be secured as part of the Section 106
agreement and is included in the Heads of Terms set out in Appendix 4.
Sport England were consulted on this proposed approach and confirmed, in January 2014, that
subject to further information the proposal could meet their Policy E4 and welcomed the approach
to phasing, although they reserved the right to comment on final proposals.
As noted above the design proposals also include a green corridor running along the northern edge
of the South site. The green corridor will improve accessibility to Hammerside Hill, Morecambe Bay
and Canal Foot, which will improve linkages from Ulverston and other nearby Open Rights of Way.
In providing new, improved sports facilities, and new amenity space the development proposals will
bring significant benefits and be in compliance with local and national policies including Sport
England’s in relation to Playing Fields.
Design and Visual Impact
The GSK site is generally accepted to be in a striking natural location, adjacent to Morecombe Bay
and close to the Lake District National Park. The area also has a strong industrial character and
heritage not only from the existing GSK manufacturing plant but also neighbouring industrial uses
running alongside the Ulverston Canal from Canal Head to Canal Foot. The proposals for the GSK
site have responded directly to this site context with a Masterplan and illustrative designs which
are of a high quality and respect the surrounding area.
The Design and Access Statement gives full details of the development of the design process and
the proposed illustrative Masterplan. As noted above the Appearance, Scale and Layout of the
buildings are Reserved Matters, and the DAS addresses explicitly the design philosophy that will
inform the detailed design.
Section 6.6 of the DAS describes in detail the approach to the appearance of the various buildings.
It is unnecessary to repeat that detail here but worth describing the approach to the two most
significant building types, the office/administrative ‘Head Block’ building which will form the
entrance to the Biopharm facility and the Production Buildings which will be the largest on site.
The ‘Head Block’ building will provide the main vista from the roundabout.
Its location ensures
that this building is a building of architectural significance. The proposed form is that it should be
simple and elegant with the final design naturally guiding the user into the entrance area. The
façade is intended to reflect the cleanliness of the research and production activities on site,
therefore, will have glazed areas allowing views into the operations. Like other buildings on the site
it will be composed of a palette of glazing, grey cladding and natural stone.
The entrance plaza in front of the office block will be carefully landscaped. Design features will
reflect the colours of the natural surroundings as well as the site history. The design is likely to use
a range of earthy, natural colours as well as natural stone or similar approved material for retaining
The production buildings will be the largest buildings on site.
Their facades will be dark as this
allows visual blending of the buildings into the landscape. Typically due to their size, the elevations
may be broken into several sections, with lighter-coloured finishes at ground level, reflecting
human scale. The key materials will again be glass, natural stone and metal cladding in shades of
grey. Facades facing Morecambe Bay and the Southern Peninsula will avoid extensive glazing.
The choice of siting, setting and materials is intended to address directly the requirements of Policy
CS8.10 to respect and enhance the local landscape.
The operational requirements of the production buildings mean that the maximum parameters
would result in substantial buildings being constructed on the site which will inevitably have
impacts on views from some points in the locality.
The ES is supported by a Landscape and Visual Impact Assessment (LVIA), which has been prepared
following pre-application discussions with SLDC and CCC to agree the viewpoints that are to be
assessed. This has used the maximum parameters set out on Plans 2 and 7.
The LVIA methodology takes a worst case scenario, assessing the maximum size parameters in the
most sensitive locations as defined by Parameter Plans 2 and 7. It therefore represents an
assessment of the ‘worst case’ scenario.
It assesses the general impact of the development on defined landscape areas and landscape
character, as well as on views from designated locations such as the National Park, Conservation
Areas, Scheduled Monuments and Listed Buildings, as well as local footpaths and neighbouring
Landscape impacts range from negligible to minor beneficial (on the West Site) to minor moderate
There would be no significant effects to views from designated sites or landscape,
including the Lake District National Park to the north of the site. Inevitably, given the maximum
size of the buildings necessary for operational purposes identified by the benchmarking study,
there are a small number of local views from footpaths and some residential properties where
there will be a moderate major adverse impact.
The applicant will seek, as far as possible, to provide screening and appropriate design responses to
mitigate these impacts. The residual impacts will need to be considered in the context of the
weight given to the need to economic growth and avoid barriers to economic development set out
in the NPPF and local policy as well as the significant range of benefits that the development will
The ES also includes an assessment of impacts on Cultural Heritage. The application site contains a
number of features of cultural heritage (defined as archaeological remains and historic buildings)
importance. There are three Grade II listed structures in the vicinity, but not within the site
The construction phase of the project will involve the removal of some non-designated 19th
century structures and some possible disturbance through excavations. Mitigation measures
include a programme of archaeological field work, recording and reporting to ensure that any
archaeological remains, disturbance to which cannot be avoided, are investigated satisfactorily and
information on the results of the investigations is made available.
The development of the proposals has involved a commitment to high quality design which will be
carried through into reserved matters applications.
The development will be brought forward
broadly in line with the approach set out in the Design and Access Statement with examples of
materials being provided to the Council in advance of development. Development on this scale will
inevitably have some impact on views but these have been limited to a small number in less
sensitive locations, and will be mitigated as far as possible through design, use of materials and
appropriate planting and landscaping. The development is in any event located in an existing
historic industrial location adjacent to a large existing facility.
Transport & Highways
The submitted Transport Assessment (TA) and the Transport Chapter of the ES are based on
detailed surveys and junctions assessments. A total of 9 junctions between the site and Ulverston
town centre were assessed as part of the work undertaken to support the evidence base. The
assessments were undertaken following detailed consultation with Cumbria County Council (CCC)
and the Highways Agency, with particular focus on the A590, which provides the main access route
The TA sets out the estimated increase in vehicle numbers during the construction as well as
operational periods over the three phases of the proposed development and the impacts that these
additional vehicles will create on various sensitive receptors. The assessment also considers the
impacts of the additional vehicle numbers on the capacity of junctions surrounding the site and in
key locations in Ulverston.
In considering pre-mitigation impacts of the proposed development, the assessment considers that
impacts during the construction phases are either negligible or minor adverse. The impacts of the
construction phase of the development are not therefore considered to be significant.
Mitigation measures to address the construction related impact are centred on the Construction
Environmental Management Plan (CEMP), which amongst other measures, will limit construction
vehicles to specific routes and spread construction vehicle movements throughout the day to
reduce impact of the construction phase on the local highway network.
In the operational phase of first phase of development the pre-mitigation impacts are regarded as
negligible. In future phases the impact in relation to driver delay and accidents and safety are
assessed as moderate adverse (and in all other respects as negligible). The assessment finds that
improvements to the A590/North Lonsdale junction will be necessary to mitigate impacts prior to
occupation of assumed Phase 2 (i.e. the Future Phases) of development.
The improvements to the junction have formed part of the pre-application discussions with CCC
and SLDC, and there is an in-principle agreement with the statutory stakeholders as to how the
junction is to be improved. The implementation of the junction improvements will reduce the postmitigation impact of the operational phase of the development to minor adverse.
All other impacts identified within the Transport chapter of the ES are either negligible or minor.
The required improvements will be secured through a legal agreement and are included in the
Section 106 Heads of Terms set out in Appendix 4.
It is an important aspect of Local Plan policy that consideration should be given to the effects of
development on homes close to the development site. These effects have the potential to occur
both in the construction and occupational phases. The ES considers the full range of potential
amenity impacts including noise and vibration, lighting and air quality and identifies appropriate
Noise levels during both the construction and operational phase of the scheme have been modelled
in order to assess the impact of the Project. Changes in noise and vibrations levels around the site
are expected as a result of construction activities and related traffic movements. However, for both
of these sources, the increase in noise levels is not expected to be significant for nearby resident
populations and ecological receptors.
Operational noise and vibration effects are expected to be generated via traffic movements and
process emissions i.e. those associated with process plant, and operational activities including Air
Handling Units (AHUs), compressors, refrigeration units and exhaust fans. Traffic movements are
not expected to generate significant levels of noise over the existing baseline. In the absence of
mitigation, it is expected that some locations would experience increases in ambient noise levels
due to plant noise which may be perceptible to residents. Mitigation measures will, therefore be
applied to ensure noise levels are minimised. These measures are based on good practice industry
standard approaches to noise reduction and include: selection of quieter equipment; installation of
acoustic enclosures; silencing of exhausts/outlets for air handling/cooling units; and locating
equipment to take advantage of screening inherent in the design.
The assessment of the scheme highlights the potential for air quality impacts to arise from dust and
traffic generated as a result of the construction phase of the scheme. The Construction
Environment Management Plan will include outline details of suitable dust mitigation measures.
The traffic numbers expected to be generated are not of a level to create significant air quality
During the operational phase of the scheme, two potential sources are identified as having the
potential to impact on air quality - namely, traffic and air emissions from the operational boilers.
Road traffic emissions have been assessed to be negligible whilst the predicted pollutant
concentrations at the locations of the nearest residents and nearest sensitive ecology receptors do
not breach accepted air quality thresholds for either the protection of human health or ecology.
Emissions will be governed by Environmental Permits within which the Biopharm development will
be required to operate.
An assessment has been undertaken to establish the potential effects of light pollution arising as a
result of the proposed development on the surrounding area. The West Site currently contains a
number of light fixtures around the boundary whereas the South Site is largely unlit other than in
the south and west where area lighting is provided for the existing car-parking and waste water
treatment plant. Immediately surrounding the site to the north and east, GSK's existing
manufacturing plant is substantially lit. Mitigation measures would include: maximum heights for
lighting columns; specific requirements regarding angle of luminaires; cowling where required; and
where specific high-level lighting is needed, this should be limited for task duration. The assessment
of impacts concludes that after mitigation, the impact of construction lighting would not create a
significant effect above current lighting levels on the site.
A lighting scheme would be prepared for the operational phase of the development in order to limit
potential light pollution as much as possible. Mitigation measures to be reflected within the lighting
scheme could include (inter alia): lighting to be provided only where it is necessary; consideration
will be given to the daytime appearance of lighting equipment; light fixtures will be positioned and
equipment selected to avoid spill into the sky and onto neighbouring properties or adjacent areas
of ecological sensitivity; sports pitch lighting will be located at a suitable stand-off from the
neighbouring residential properties and from the identified ecological receptors.
Overall, when taking into account the proposed mitigation measures, the development will not
have significant impacts on the amenity of neighbouring properties. These measures include a
comprehensive Construction Environmental Management Plan (CEMP), an outline draft of which
has been submitted with the application, and requirements to provide detailed information on the
operational management of noise, lighting and other issues which are listed in Appendix 2 of this
Statement. GSK will continue to engage closely with residents throughout the construction process
as it has through the Residents Liaison Group at pre-application stage, and will require its
contractors to do so also.
It is, therefore, concluded that the proposals will not have a significant impact on residential
amenity during the construction or operational phases of the proposed development, in
accordance with national and local planning policy.
Energy and Sustainability
Policy CS8.7 requires applications for major developments to include a Sustainability Statement.
This is incorporated into the DAS at Section 4.3. An Energy Statement is also appended to the DAS.
The Sustainability Statement provides a summary of the sustainability commitments for the
development and is based on GSK corporate sustainability themes. This contains the following
Energy and Carbon - Target for building energy consumption, excluding biopharm production
energy, to be at least 25% better than Building Regulation minimum requirements;
Water - Target for non-production building water consumption, excluding biopharm
production water, to be at least 20% better than Building Regulation requirements;
Materials - Target for 100% responsible sourcing of key materials and selection of materials
to promote building user health;
Waste - Target for achievement of best practice construction site waste reduction including
95% diversion from landfill;
Ecology and Biodiversity - Target for development delivery with zero net loss of ecological
Sustainable Operations - BREEAM Excellent achieved on all relevant buildings/areas;
Sustainable Infrastructure - Facilities provided to support sustainable mobility, scalable low
carbon energy delivery, and sustainable surface water management;
Our People and Communities - Active engagement with local suppliers to optimise
opportunities, engagement on skills and education, and ongoing engagement with local
The main buildings delivered as part of the proposed development will be designed to achieve
BREEAM Excellent ratings. The current relevant version of BREEAM is New Construction 2011, and
it is proposed to use this methodology to assess all relevant buildings/areas.
It is important to note that under BREEAM, the production areas of the development are excluded
because of their specialist requirements.
This is of particular importance to the Biopharm
production buildings which require a steady and constant supply of power using proven
technologies. It also includes the warehouse, central utilities building and waste water treatment
plant. The standard would therefore apply to the office/admin block in Phase 1, the canteen and
the Sports and Social centre. The Energy Statement sets out how the development will seek to
minimise energy requirements through design and technologies which could be considered as
future phases are brought forward, always subject to the over-riding operational requirements of
the manufacturing process.
The Strategy, therefore, is considered to demonstrate a strong commitment to the sustainability of
the Proposed Development and is in compliance with Policy CS8.7 (Sustainable Construction,
Energy Efficiency and Renewable Energy) of the Core Strategy.
The proposed biopharmaceutical facility at Ulverston will be the first new factory built by GSK in the
UK for nearly 40 years. It will be of national significance, helping to meet the Government's
objectives and those of the local authorities and the Cumbria Local Enterprise Partnership. It will
provide a multi-million pound investment in a sector which is critical for the UK's competiveness,
and which is of major importance for Cumbria and the wider North West.
The approach to the development of the Illustrative Masterplan has been exemplary, involving the
full consideration of the site context, planning policy framework, site requirements and the views of
stakeholders. This Planning Statement has considered the development proposals against the key
planning policy requirements and found that:
The principle of the proposals has exceptionally strong policy support at all levels;
The location of Proposed Development within the application site is based on the operational
requirements of a Biopharm facility, taking into account flood risk and other factors;
The ‘swap’ of sports provision currently on the South Site with industrial designation on the
West Site is consistent with adopted plan policies;
Although the South Site is outside the Ulverston Development Boundary, its current uses are
consistent with being included within it and the proposed use as a Biopharm facility would
not be inconsistent with the purpose of the policy;
The Proposed Development will bring significant benefits including new jobs and supply chain
opportunities in the construction phase and completed development, environmental and
ecological enhancements, and a range of sustainability benefits;
The Proposed Development will be of a high design quality using design principles and
materials that respect the local environment and landscape. Inevitably buildings of the
maximum size proposed will have adverse impacts on some local views, but the scheme has
been designed to avoid significant impacts on long range views and from designated
locations including the National Park;
The HRA screening assessment concludes that there will be no significant impacts on
sensitive ecological receptors and that mitigation and enhancement measures proposed will
result in net ecological benefits;
The Flood Risk Assessment concludes that uses are located appropriately and proposes
appropriate mitigation measures that meet local and national policy requirements;
The full range of other likely environmental and amenity impacts have been assessed and
appropriate measures can be put in place to ensure that there are no major significant
The application is for outline planning permission with all matters reserved. To ensure that the
conclusions described above remain sound the development will be controlled through a series of
Parameter Plans which set the Framework against which reserved matters applications will be
assessed. The applicant will also be required for each phase to provide details of how the
construction process will be implemented and controlled through a Construction Environmental
Management Plan and provide further detailed information in relation to the full range of
operational issues identified in Appendix 2.
Maximum Parameters Schedule
This maximum parameters schedule sets out a detailed description and explanation of the outline
planning application. It explains the parameter plans that will apply to applications for reserved
matters and other approvals required under the planning permission sought in this application.
It should be noted that the proposed development will require an Environmental Permit, issued by
the Environment Agency in order to operate. The Environmental Permit will be the subject of a later
application to the Environment Agency by the applicant. The Environmental Permit will be the
principal means of regulation and monitoring of the key potential environmental impacts of the
proposed development, once operational. Environmental Permits are only issued once the
Environment Agency is satisfied that a facility will be operated and maintained to meet stringent
emissions regulations so that human health and the environment are protected. As such, matters
which are controlled by the Environmental Permitting regime, which include emissions to air and
water and waste management, should not be subject to (potentially conflicting) planning
requirements and conditions.
The Planning Application is submitted in outline with matter of layout, scale, appearance, access and
landscaping reserved within the parameters set out in the Parameter Plans and other key
documentation. A roundabout that will serve as the westerly access into the Site was approved by
SLDC under planning application ref: SL/2014/0112 in April 2014.
As set out in the planning application forms, permission is sought for the following development:
“Pharmaceutical manufacturing facility (B2) of up to 119,000 sqm comprising up to 3 production
buildings, ancillary office and research and development (B1a/B1b) floorspace, ancillary staff
canteen (A3), an ancillary distribution and storage warehouse (B8), a utilities building, a sports and
social centre comprising up to 3 pitches and a bowling green, a sports centre (D2) of up to 6,250
sqm, up to 2 associated sports facilities buildings (D2), a substation, a waste water treatment
plant, associated soft and hard landscaping, parking areas, highway works and all other associated
The Planning Application is submitted in outline to provide the necessary flexibility for the detailed
design of the scheme at a later date. However the Parameter Plans provide a framework of controls
which will inform and control all reserved matters applications.
Article 2 of the Town and Country (Development Management Procedure) (England) Order 2010 (as
amended) (‘DMPO’) sets out requirements for outline planning applications. The following matters,
based on the DMPO definitions, are ‘reserved’ for later approval:
Layout – relates to the way in which buildings, routes and open spaces are provided, situated and
orientated in relation to each other and to buildings and spaces outside the development. The
Planning Application seeks approval of parameters associated with key spaces and routes as set out
in the Parameter Plans.
Scale – defined as the height, width and length of each building in relation to its surroundings. At
this stage the Outline Planning Application seeks approval for the maximum building heights shown
on the Parameter Plans.
Appearance – defined as the aspects of a building or place within the development which determine
the visual impression the building or place makes, including the external built form of the
development, its architecture, materials, decoration, lighting, colour and texture. The Outline
Planning Application seeks approval of the design principles which would be applied at the reserved
Landscaping – defined as the means of treatment of land for the purposes of enhancing or
protecting the amenities of the proposed development. The Outline Planning Application seeks
approval for the open spaces on the Parameter Plans 2, 3 and 5.
Means of Access – defined as accessibility to and within the site for vehicles, cycles and pedestrians
in terms of the positioning and treatment of access and circulation routes and how they fit into the
surrounding network. Parameter Plan 4 describes the alignment of the routes within the Site and
the access points to the proposed West and South sites.
Permission is not sought at this stage for the reserved matters but instead seeks to gain approval for
the principle of the development through an outline planning permission based on the Parameter
Plans relating to size and height of the buildings, appearance, landscaping, access and lighting
There are a number of parameter plans which form part of the Planning Application. These provide
the parameters for the future reserved matters applications. The Parameter Plans identify those
elements of the scheme which are to be fixed as part of the planning permission and those elements
which are subject to parameters.
The parameter plans relate to the following matters:
Parameter Plan 1A: Application Area (1:1250)
Parameter Plan 1B: Application Area (1:2500)
Parameter Plan 2: Development Zone and Building Siting
Parameter Plan 3: Landscape
Parameter Plan 4: Vehicular Access and Circulation Including Pedestrian and Cycle Access
Parameter Plan 5: Lighting
Parameter Plan 6: Demolition Plan
Parameter Plan 7: Minimum and Maximum Building Heights and Site Levels
The text below explains the function of each Parameter Plan, and its key features. The planning
application boundary is included on most of the Parameter Plans for ease of reference.
Parameter Plan 1A: Application Area (1:1250)
Parameter Plan 1A shows the existing layout of the Site, prior to the commencement of
development. It includes the application area (red line boundary) and ownership boundary (blue
Parameter Plan 1B: Application Area (1:2500)
Parameter Plan 1B shows the existing layout of the site at a higher scale. Similarly to Plan 1A, it
shows the Site prior to the commencement of development and includes the red line and blue line
Parameter Plan 2: Development Zone and Building Siting
Parameter Plan 2 shows the proposed layout and development zones which relate to the West Site
and South Site. The Plan provides limitations to the development within each development zone in
relation to maximum size and height. No development therefore would be permitted that would
exceed the identified height and size limited shown on Parameter Plan 2. For ease the table is
Parameter Plan 3: Landscape
Parameter Plan 3 shows the existing trees and vegetation that would be retained after the
development. Given the importance of the long distance views to and from the Site, Parameter Plan
2 also shows the new landscaping screening consisting of natural vegetation and trees.
Parameter Plan 4: Vehicular Access and Circulation including Pedestrian and Cycle Access
Parameter Plan 4 shows the existing vehicular and pedestrian entrance and private road network to
the Site. It also defines the proposed vehicular and pedestrian entrance and private road network
within the Site to ensure fluid traffic movements to and from the Site once operational.
Parameter Plan 5: Lighting
Parameter Plan 5 shows the proposed lighting plan as part of the development which seeks to
ensure that the negative impacts of light spillage is minimised as best as possible. The Plan defines
the specific light wattage to be used on the different parts of the Site (i.e. 200 lux light level for the
football pitch and 20 lux light level for the roadway and car park).
Parameter Plan 6: Demolition Plan
Parameter Plan 6 defines the maximum extent of the demolition area for Phase 1 and for the future
phases of the development. The Plan also provides a table which sets out the specific buildings that
would be demolished on each development zone and at which phase this would take place.
Parameter Plan 7: Minimum and Maximum Building Heights and Site Levels
Parameter Plan 7 defines the maximum and minimum building heights proposed as part of the
development over the different development zones and phases. These height parameters for the
buildings will provide limitations to what the development cannot exceed. The Plan also shows the
proposed alteration to existing site levels in metres throughout all of the development zones.
This section of the Maximum Parameters Schedule sets out the environmental standards and
commitments which will apply across the GSK Biopharmaceutical development.
Construction Environmental Management Plan
All construction activity will be in compliance with the Construction Environmental Management
Plan (CEMP). The applicant will adopt this code and it will be mandatory for all principal contractors
appointed by the Applicant (and their sub-contractors) and for all development or others who
deliver the development. This will be imposed by contract or other legal agreement with those
parties as well as being enforceable by the Local Planning Authority under a condition anticipated on
the planning permission sought.
Site-Wide Landscape Strategy
This strategy will be based on Parameter Plan 3: Landscape along with the Landscape and Visual
Impact Assessment which includes details of planting plans and written specifications for
maintenance and management associated with plant and grass establishment.
Landscaping Management Plan
This Plan will include long-term design objectives, management responsibilities and maintenance
schedules for all landscape areas associated with that phase.
External Lighting Scheme
This scheme will set out details of lighting provisions for all of the aspects of the development.
Phase Specific Travel Plan
This plan will set out access and egress arrangements as part of the development for vehicles and
pedestrians. It will also set out the proposed private highway routes for vehicle travel within the
Site-Wide Surface Water and Foul Water Drainage Strategy
This will include a scheme of surface water and sewerage disposal based on the SUDS hierarchy. The
strategy will seek to ensure that the scheme maximises the use of measures to control water at
source as far as practicable.
This will include details of a mitigation strategy identified within the Environmental Statement
approved as part of this planning permission along with the results of any required update surveys.
Contaminated Land Assessment / Remediation Strategy
This will include all works to be undertaken, proposed remediation objectives and remediation
criteria, appraisal of remedial options, and proposal of the preferred option and a timetable of works
and site management procedures.
National Planning Policy
National Planning Policy Framework (NPPF, March 2012)
a) Achieving Sustainable Development
Paragraph 7 states that there are three dimensions to sustainable development comprising
economic, social and environmental roles. It states that an economic role should contribute
towards a responsive and competitive economy by supporting growth, a social role by
supporting vibrant communities and an environmental role that seeks to protect and enhance
the natural and built environment. It states:
“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
an 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”.
Paragraph 8 states that these three roles cannot be undertaken in isolation because they rely
on each other to result in successful sustainable development. Specifically paragraph 8 states:
“These roles should not be undertaken in isolation, because they are mutually
dependent. Economic growth can secure higher social and environmental
standards, and well-designed buildings and places can improve the lives of
people and communities. Therefore, to achieve sustainable development,
economic, social and environmental gains should be sought jointly and
simultaneously through the planning system. The planning system should
play an active role in guiding development to sustainable solutions”.
Paragraph 9 states that supporting improvements to the built environment involves creating
jobs, encouraging good design and improving the conditions in which people live and work.
Paragraph 9 states:
“Pursuing sustainable development involves seeking positive
improvements in the quality of the built, natural and historic environment,
as well as in people’s quality of life, including (but not limited to):
making it easier for jobs to be created in cities, towns and villages;
moving from a net loss of bio-diversity to achieving net gains for nature;6
replacing poor design with better design;
improving the conditions in which people live, work, travel and take leisure;
widening the choice of high quality homes”.
Paragraph 10 also states that decisions need to take into account local circumstances to
ultimately contribute towards sustainable development:
“Plans and decisions need to take local circumstances into account, so
that they respond to the difference opportunities for achieving
sustainable development in different areas”.
b) Core Planning Principles
Paragraph 14 states that in relation to decision making, local authorities should approve
development proposals that accord with the development plan and where the development
plan is absent or relevant policies are out of date, permission should be granted unless
adverse impacts would outweigh the benefits. Specifically paragraph 14 states:
“At the heart of the National Planning Policy Framework is a presumption in
favour of sustainable development, which should be seen as a golden
thread running through both plan-making and decision-taking.
For plan-making this means that:
local planning authorities should positively seek opportunities to meet
the development needs of their area;
Local Plans should meet objectively assessed needs, with sufficient flexibility
to adapt to rapid change, unless:
any adverse impacts of doing so would significantly and demonstrably
outweigh the benefits, when assessed against the policies in this
Framework taken as a whole; or
specific policies in this Framework indicate development should be restricted.
For decision-taking this means:
approving development proposals that accord with the development
plan without delay; and
where the development plan is absent, silent or relevant policies are out-ofdate, granting permission unless:
any adverse impacts of doing so would significantly and demonstrably
outweigh the benefits, when assessed against the policies in this
Framework taken as a whole; or
specific policies in this Framework indicate development should be
Paragraph 17 states that there are a set of core land-use planning principles that should
underpin decision making to include empowering local people to shape their surroundings,
find ways to enhance and improve the places in which people live their lives and support high
quality economic development to deliver business units and thriving local places. Specifically
paragraph 17 states:
“Within the overarching roles that the planning system ought to play, a set of
core land-use planning principles should underpin both plan-making and
decision-taking. These 12 principles are that planning should:
be genuinely plan-led, empowering local people to shape their
surroundings, with succinct local and neighbourhood plans setting out a
positive vision for the future of the area. Plans should be kept up-to-date, and
be based on joint working and co-operation to address larger than local
issues. They should provide a practical framework within which decisions on
planning applications can be made with a high degree of predictability and
not simply be about scrutiny, but instead be a creative exercise in finding
ways to enhance and improve the places in which people live their lives;
proactively drive and support sustainable economic development to deliver
the homes, business and industrial units, infrastructure and thriving local
places that the country needs. Every effort should be made objectively to
identify and then meet the housing, business and other development needs
of an area, and respond positively to wider opportunities for growth. Plans
should take account of market signals, such as land prices and housing
affordability, and set out a clear strategy for allocating sufficient land which
is suitable for development in their area, taking account of the needs of the
residential and business communities;
always seek to secure high quality design and a good standard of amenity
for all existing and future occupants of land and buildings;
take account of the different roles and character of different areas,
promoting the vitality of our main urban areas, protecting the Green Belts
around them, recognising the intrinsic character and beauty of the
countryside and supporting thriving rural communities within it;
support the transition to a low carbon future in a changing climate, taking
full account of flood risk and coastal change, and encourage the reuse of
existing resources, including conversion of existing buildings, and encourage
the use of renewable resources (for example, by the development of
contribute to conserving and enhancing the natural environment and
reducing pollution. Allocations of land for develoment should prefer land of
lesser environmental value, where consistent with other policies in this
encourage the effective use of land by reusing land that has been
previously developed (brownfield land), provided that it is not of high
promote mixed use developments, and encourage multiple benefits from the
use of land in urban and rural areas, recognising that some open land can
perform many functions (such as for wildlife, recreation, flood risk mitigation,
carbon storage, or food production);
conserve heritage assets in a manner appropriate to their significance, so
that they can be enjoyed for their contribution to the quality of life of this
and future generations;
actively manage patterns of growth to make the fullest possible use of public
transport, walking and cycling, and focus significant development in
locations which are or can be made sustainable; and
take account of and support local strategies to improve health, social and
cultural wellbeing for all, and deliver sufficient community and cultural
facilities and services to meet local needs”.
c) Building a Strong, Competitive Economy
Paragraph 18, 19 and 20 state that the Government is committed to ensuring the planning
system does everything it can to support economic growth. Paragraph 18, 19 and 20 of the
“The Government is committed to securing economic growth in order to
create jobs and prosperity, building on the country’s inherent strengths,
and to meeting the twin challenges of global competition and of a low
The Government is committed to ensuring that the planning system does
everything it can to support sustainable economic growth. Planning should
operate to encourage and not act as an impediment to sustainable growth.
Therefore significant weight should be placed on the need to support
economic growth through the planning system.
To help achieve economic growth, local planning authorities should plan
proactively to meet the development needs of business and support an
economy fit for the 21st century”.
d) Good Design
Paragraph 56 and 57 state that great importance is placed on the design of the built
environment. It states,
“The Government attaches great importance to the design of the built
environment. Good design is a key aspect of sustainable development, is
indivisible from good planning, and should contribute positively to making
places better for people.
It is important to plan positively for the achievement of high quality and
inclusive design for all development, including individual buildings, public and
private spaces and wider area development schemes”.
e) Promoting Healthy Communities
Paragraph 70 states that local authorities should plan and decide positively to ensure there is
the provision, use and protection of shared space and community facilities including sports
venues. It states:
“To deliver the social, recreational and cultural facilities and services the
community needs, planning policies and decisions should:
plan positively for the provision and use of shared space, community
facilities (such as local shops, meeting places, sports venues, cultural
buildings, public houses and places of worship) and other local services to
enhance the sustainability of communities and residential environments;
guard against the unnecessary loss of valued facilities and services,
particularly where this would reduce the community’s ability to meet its
ensure that established shops, facilities and services are able to develop and
modernise in a way that is sustainable, and retained for the benefit of the
ensure an integrated approach to considering the location of housing,
economic uses and community facilities and services”.
Flood Risk and Climate Change
Paragraph 93 of the NPPF states that planning plays a key role in helping shape places in order
to provide resilience to the impacts of climate change. It states,
“Planning plays a key role in helping shape places to secure radical
reductions in greenhouse gas emissions, minimising vulnerability and
providing resilience to the impacts of climate change, and supporting the
delivery of renewable and low carbon energy and associated infrastructure.
This is central to the economic, social and environmental dimensions of
Paragraph 100 of the NPPF states that development in areas at risk of flooding should be
avoided but where development is necessary, it should be made safe without increasing flood
risk elsewhere. Paragraph 103 states that local planning authorities should consider
development appropriate in areas at risk where it has been informed by a flood risk
assessment. The paragraph states:
“When determining planning applications, local planning authorities should
ensure flood risk is not increased elsewhere and only consider development
appropriate in areas at risk of flooding where, informed by a site-specific
flood risk assessment following the Sequential Test, and if required the
Exception Test, it can be demonstrated that:
Within the site, the most vulnerable development is located in areas of
lowers flood risk unless there are overriding reasons to prefer a different
Development is appropriately flood resilient and resistant, including safe
access and escape routes where required, and that any residual risk can be
safely managed, including by emergency planning, and gives priority to the
use of sustainable drainage systems”.
g) Conserving and Enhancing the Natural Environment
Paragraph 109 of the NPPF states that the planning system should contribute to and enhance
the natural and local environment by protecting and enhancing valued landscapes, geological
conservation interests and soils.
“The planning system should contribute to and enhance the natural and
local environment by:
Protecting and enhancing valued landscapes, geological conservation
interests and soils;
Recognising the wider benefits of ecosystem services;
Commitment to halt the overall decline in biodiversity, including by
establishing coherent ecological networks that are more resilient to current
and future pressures;
Preventing both new and existing development from contributing to or being
put at unacceptable risk from, or being adversely affected by unacceptable
levels of soil, air, water or noise pollution or land instability; and
Remediating and mitigating despoiled, degraded, derelict contaminated
and unstable land, where appropriate.
Paragraph 111 states where possible, the effective re-use of brownfield land should be
encouraged to ensure that greenfield land is suitably protected. It states:
“Planning policies and decisions should encourage the effective use of land
by re-using land that has been previously developed (Brownfield land),
provided that it is not of high environmental value. Local planning
authorities may continue to consider the case for setting a locally
appropriate target for the use of brownfield land”.
h) Historic Environment
Paragraph 126 states that local planning authorities should recognise that heritage assets are
an irreplaceable resource and should conserve them in a manner appropriate to their
significance. Paragraph 170 states that landscape character assessment should also be
prepared where appropriate. It states,
“Where appropriate, landscape character assessments should also be
prepared, integrated with assessment of historic landscape character, and for
areas where there are major expansion options assessments of landscape
National Planning Practice Guidance (NPPG, March 2014)
On 6 March 2014 the Department for Communities and Local Government launched the new
planning practice guidance. It is a web-based resource which offers guidance on how to
implement the policies set out in the National Planning Policy Framework superseding a
number of separate policy guidance documents.
The NPPG states that the NPPF sets strict tests to protect people and property from flooding
which all local planning authorities are expected to follow. Where these tests are not met,
national policy clear that new development should not be allowed. The main steps to be
followed are set out below which, in summary, are designed to ensure that if there are better
sites in terms of flood risk, or a proposed development cannot be made safe, it should not be
permitted. (Reference ID: 7-001-20140306).
The NPPG states that the public authorities in England must have regard to the purpose of
conserving biodiversity and to embed consideration of biodiversity as an integral part of policy
and decision making throughout the public sector, which should be seeking to make a
significant contribution to the achievement of the commitments made by the Government.
(Reference ID: 8-007-20140306).
k) Environmental Impact Assessment (EIA) Application Requirements
The process of Environmental Impact Assessment is governed by the Town and Country
Planning (Environmental Impact Assessment) Regulations 2011. These regulations apply the
EU directive on the assessment of the effects of certain public and private projects on the
environment. The NPPG also states that the regulations only apply to certain types of
development and/or projects.
For those projects where the regulations do apply, the NPPG also sets out the five stages of
the Environmental Impact Assessment comprising:
Preparing an Environmental Statement
Making a planning application and consultation
Decision making (Reference ID: 4-003-20140306)
Local Planning Policy
South Lakeland Core Strategy (October, 2010)
Policy CS1.1 – Sustainable Development Principles
Policy CS1.1 aims to protect the countryside and enhance its unique character, it sets out a
sequential approach to development and seeks to support sustainable growth of the local economy
through promoting local business development attracting new investment. Policy CS1.1 states that
opportunities must be taken to mitigate against and adapt to climate change including addressing
flood risk, minimising the use of non-renewable resources and increase the proportion of energy
derived from renewable.
CS1.1 states that where possible, development should minimise the need to travel and provide a
choice of sustainable transport modes for all sections of the community including the provision of
cycling and pedestrian infrastructure. Additionally the policy states that development should accord
with a sequential approach comprising using existing buildings including conversions with
settlements and previously development land within settlements, use other suitable infill
opportunities within settlements and the development of land that is well located in relation to
housing, jobs and other services. In full, policy CS1.1 states that:
1. “Opportunities must be taken to mitigate against and adapt to climate change
including addressing flood risk, improving waste management, improving air
quality, strengthening ecosystem services to enhance resilience of the natural
environment, minimizing the use of non-renewable resources and increasing
the proportion of energy derived from renewables or other more sustainable
2. It is vital to protect the countryside for its intrinsic beauty, diversity and natural
resources and also for its ecological, geological, cultural and historical,
economic, agricultural, recreational and social value;
3. There is a need to take account of and enhance landscape character and
features particularly the AONB and coastal areas. The area’s role as a setting for
and gateway to the Lake District and Yorkshire Dales National Parks should be
4. There is a need to safeguard the essential character and appearance of those
buildings and sites that make a positive contribution to the special architectural
or historic interest of the area, including the numerous conservation areas and
listed buildings, whilst encouraging the appropriate re-use of buildings or sites
which are causing harm;
5. It must be ensured that a high quality, localised and appropriate design is
incorporated into all developments to retain distinctive character/sense of place
and enhance the existing built environment;
6. Wherever possible, minimise the need to travel and provide a choice of
sustainable transport modes for all sections of the community, including the
provision of cycling and pedestrian infrastructure to encourage a shift in travel
7. Most new developments should be directed to existing service centres where
there is adequate service and infrastructure capacity to accommodate the
required levels of development. Where necessary, ensure the provision of further
physical, social and green infrastructure to support growth;
8. Development should accord with the following sequential approach:
• first, using existing buildings (including conversion) within settlements,
and previously developed land within settlements;
• Second, using other suitable infill opportunities within settlements;
• Third, the development of other land where this is well located in
relation to housing, jobs, other services and infrastructure.
9. All developments should help to meet the diverse social and economic needs of
our local communities, from more densely populated service centres down to the
more remote rural areas;
10. Local housing markets must deliver a broad range of housing, including more
that is affordable to help retain more young people in the area as well as
meeting the particular needs of the large proportion of residents who are over
11. There is a need to grow the local economy in a sustainable way, supporting the
vitality and viability of service centres, fostering local business development and
rural diversification and attracting new investment into the area, thus reducing
dependency on lower-paid sector jobs and high level jobs in areas outside the
district. Support for tourism, which is a key driver of the local economy, needs to
be balanced with protecting and enhancing the attractiveness of the area”.
m) Policy CS3.1: Ulverston and Furness
Policy CS3.1 sets out the main objectives for the Ulverston and Furness area which
includes policies to support regeneration, the growth of the local economy,
improved access and a safeguarded and enhanced environment. It states that the
Council would ensure that new development enhances the natural environment.
The policy states:
The Ulverston and Furness area strategy includes the following settlements:
• Ulverston (Principal Service Centre);
• Kirkby-in-Furness, Greenodd/Penny Bridge, Swarthmoor, Great/Little Urswick,
Broughton-in- Furness, (Local Service Centres);
• A number of smaller rural settlements and hamlets including Bardsea,
Baycliff, Gleaston, Leece, Loppergarth, Newbiggin, Scales, Stainton with
The Council and its partners will aim to:
• Designate a regeneration area at Ulverston Canal Head Area (see CS3.2).
• Build on the successful outcomes from the Market Town Initiative in
Ulverston and continue with regeneration.
• Make provision for in the region of 1,760 additional dwellings in Ulverston
between 2003 and 2025, prioritising previously developed land and sites within
the urban area.
• Make provision for small-scale housing development, including affordable
housing, in the Local Service Centres and smaller rural settlements.
• Seek to ensure that 35% of housing delivered within Furness Peninsula is
affordable and that up to 60% of affordable housing is social rented, based on
local need, to be sought and delivered by a variety of means including
Registered Social Landlords, public subsidy from the Homes and Communities
Agency and developer contributions in accordance with the approach set out in
• Expand Ulverston to accommodate in the region of 12 hectares of
employment development between 2010 and 2025.
• Where possible, locate new employment uses (B1 b and c, B2 and B8) where
they are not only accessible (or can be made accessible) by walking, cycling
and public transport from main residential areas, but also provide good
connections to the strategic transport network without any detrimental impact
on the town centre network.
• Support small-scale economic development in the Local Service Centres and
smaller rural settlements.
• Protect and enhance the vitality and viability of Ulverston town centre,
including improving pedestrian and cycle access and ensuring effective town
• Focussing as far as possible new office development (use class B1 a) in or
adjacent to Ulverston town centre. Support the development of new retail
provision in the town centre to accommodate both convenience and
• Support and enhance tourist attractions, building on the Laurel and Hardy
connection, the festival theme and specialist boutique shopping in the town
• Support improvements to the operation of transport routes linking Furness to
the M6 and national rail links.
• Work with partners on public transport initiatives as part of a comprehensive
sustainable transport network within the Furness Area to support the planned
• Improve footpaths and cycle routes.
• Safeguard and enhance buildings, sites and areas of heritage and cultural
importance such as the Hoad Monument and Birkrigg Stone Circle.
• Improve parks and green spaces/green infrastructure.
• Designate (as required) a series of green gaps to prevent the coalescence of
individual settlements and thereby protect their individual character and
• Ensure greenfield development is sympathetic to the landscape character of
the Furness Peninsula and individual settlements.
• Ensure new development safeguards and enhances the natural environment
and local biodiversity, notably the SSSIs and SACs within the area, including
Morecambe Bay, and County Wildlife Sites, and supports habitat creation.
Health and Wellbeing (Sustainable Communities)
• Maintain, and where necessary enhance, sports and community facilities.
• Provide further infrastructure (including health and education) in accordance
with identified need, responding to significant changes in local demographics.
n) Policy CS7.1 – Meeting the Employment Requirement
Policy CS7.1 states that it will ensure suitable employment related development in existing
employment areas, including extensions to premises, will normally be permitted. It also states
that the Council will work with owners and developers of several of the sites with
surmountable constraints to bring forth mitigation measures sufficient to make them
attractive for commercial use. In full Policy CS7.1 states that:
“The Core Strategy will seek to ensure that around 4 hectares of employment
land are allocated per annum between 2010 and 2025.
The Council will seek to maintain a rolling provision of five years’ worth of
high quality, unconstrained land for each employment land market sector,
that is readily available for development at any one time. This will be
distributed across the District in accordance with the sequential hierarchy in
CS1 and linking areas of opportunity and need. It equates to around 20
hectares of land. This will be kept under review to ensure that the Council
does not over or under develop sites in relation to the actual scale of
economic growth in light of a review of employment trends and needs in the
Suitable employment related development in existing employment areas,
including extensions to premises, will normally be permitted. It will be
necessary to ensure that the allocation of any greenfield land for
employment use is phased, in order to prioritise the use of previously
SLDC will work with owners and developers of several of the sites with
surmountable constraints to bring forth mitigation measures sufficient to
make them attractive for commercial use. Due to the relative lack of
unconstrained and available sites in the District, it is necessary to strongly
enforce policies aimed at safeguarding and maintaining the best
employment sites from redevelopment for other uses.
Good quality unallocated sites which are currently in employment use will be
preserved. Conversely, those sites that have been identified as being
uneconomical, severely constrained or otherwise unavailable for future
employment use and which satisfy the criteria for release in W4 of the RSS
should not be allocated in the Allocations of Land DPD. Consideration will be
given to a range of alternative uses
Proposals will be encouraged to improve the quality of the environment,
signage, security and accessibility of the sites”.
o) Policy CS8.1 – Green Infrastructure
Policy CS8.1 states that just as growing communities need to improve and develop their grey
infrastructure their green infrastructure needs to be upgraded and expanded in line with
growth. CS8.1 states that it will ensure that green infrastructure is an integral part of creating
sustainable communities and will be incorporated into new developments. It also states that
it will protect and enhance the linkages between open spaces within the service centres, other
rural settlements and in the wider countryside, supporting the creation of additions to the
footpath network in liaison with Parish Councils.
CS8.1 states that it will seek to contribute towards an improved network of green corridors of
value for wildlife, recreation and the amenity needs of the community and protect species and
habitats and create new habitats and wildlife corridors. In full Policy CS8.1 states:
“The Core Strategy will seek to:
Ensure that green infrastructure is an integral part of creating sustainable
Incorporate green infrastructure into new developments, particularly where it
can be used to mitigate the negative impacts of the development;
Attain high standards of environmental design that fit with the surrounding
countryside and landscape setting;
Protect the countryside from inappropriate development whilst supporting its
positive use for agriculture, recreation, biodiversity, health, education and
Protect and enhance the linkages between open spaces within the service
centres, other rural settlements and in the wider countryside, supporting the
creation of additions to the footpath network in liaison with Parish Councils;
Protect and enhance important open spaces within settlements to contribute
towards an improved network of green corridors of value for wildlife,
recreation and the amenity needs of the community;
Protect species and habitats and create new habitats and wildlife corridors
where biodiversity conservation and enhancement is affected by development;
Conserve and enhance existing trees and woodlands including requiring the
planting of new trees and woodlands on appropriate development sites.
Ensure the protection and enhancement of watercourses and wetlands which
are important contributors to the network of blue and green corridors for
wildlife, recreation and the amenity needs of the community”.
p) Policy CS8.3a: Accessing Open Space, Sport and Recreation
This policy states that the Land Allocations DPD (2013) identifies the important open spaces
which it is important to safeguard. This is covered in more detail in the following section.
q) Policy CS8.4 – Biodiversity & Geodiversity
Policy CS8.4 states that any development proposals at risk of creating an adverse effect on
nationally, sub-regional, regional or locally designated sites and non-protected sites will not be
permitted unless certain qualifying criteria are met. This criteria comprises development that
cannot be located alternative sites that would cause less or no harm, the benefits of the
development clearly outweighing the impacts on the features of the site and the wider
network of the natural habitats and prevention mitigation and compensation measures are
CS8.4 also states that development proposals should protect, enhance and restore the
biodiversity and geodiversity value of land and buildings, maximise the opportunities for
restoration enhancement and connection of natural habitats including links to habitats
outside South Lakeland and incorporate beneficial biodiversity and geodiversity conservation
features, including features that will help wildlife adapt to climate change where appropriate.
In full Policy CS8.4 states:
“All development proposals should:
Protect, enhance and restore the biodiversity and geodiversity value of land
Minimise fragmentation and maximise opportunities for restoration,
enhancement and connection of natural habitats (including links to habitats
outside South Lakeland); and
Incorporate beneficial biodiversity and geodiversity conservation features,
including features that will help wildlife to adapt to climate change where
Proposals should particularly seek to contribute towards the UK priority
habitats and species in South Lakeland, and any additional Cumbria
Biodiversity Action Plan species.
Development proposals that would have a direct or indirect adverse effect on
nationally, sub-regional, regional and local designated site and non-protected
sites that are considered to have geological and biodiversity value, will not be
They cannot be located on alternative sites that would cause less or no harm;
The benefits of the development clearly outweigh the impacts on the features
of the site and the wider network of natural habitats; and
Prevention, mitigation and compensation measures are provided.
Development proposals where the principal objective is to conserve or enhance
biodiversity or geodiversity will be supported in principle”.
r) Policy CS8.5 – Coast
The Core Strategy seeks to conserve and enhance the coastal and estuarine landscape and
cultural heritage. To do this, the CS seeks to control access to the beach and foreshore of
Morecambe Bay to prevent damage to habitats and disturbance. This would be done through
measures such as restrictions on parking and vehicle access in sensitive areas.
Additionally CS8.5 states that it will have regard to the possible effect of climate change and
protect the finite resource of the undeveloped coast from unnecessary development. It also
states that it would ensure that thorough and effective assessments of drainage impact and
flood risks are carried out and that sustainable approaches to drainage management
measures are included whilst ensuring that risk to life and property by flooding is reduced. In
full, policy CS8.5 states:
“The Core Strategy seeks to:
Conserve and enhance the coastal and estuarine landscape and cultural
Conserve and enhance biodiversity and protect wildlife habitats. Access to the
beach and foreshore of Morecambe Bay needs to be controlled to prevent
damage to habitats and disturbance, through measures such as restrictions on
parking and vehicle access in sensitive areas;
Ensure that the area’s natural resources are managed in a sustainable way;
Have regard to the possible effect of climate change, such as sea level rise and
increased flood and storm events in determining the location of development
and approaches to coastal defence;
Protect the finite resource of the undeveloped coast from unnecessary
Provide for new development, including land-based maritime uses for coastal
recreation and tourism;
Development proposals should make reference to the Morecambe Bay Strategy
and the Morecambe Bay European Marine Site Management Scheme and Action
Plan. Natural England needs to be involved in these discussions and delivery;
Provide information to encourage responsible recreation use and help visitors to
understand the special features of the protected sites of Morecambe Bay;
Protect the quality of all water bodies, including coastal and transitional waters;
Ensure that thorough and effective assessments of drainage impact and flood
risks are carried out; that sustainable approaches to drainage management
measures are introduced; and that risk to life and property by flooding is
Support the strategy for the management/protection of the shoreline as set
out in the current Shoreline Management Plan for the North West and North
Where necessary, the Council will support stricter mitigation measures in terms
of zoning and byelaw enforcement to ensure the protection of Morecambe Bay
s) CS8.6 - Historic Environment
Policy CS8.6 states that it supports development the adaptive reuse redundant of functionally
obsolete listed buildings or important buildings within conservation areas, without harming
their essential character. It also states that it supports the consideration of the introduction
of tighter controls within conservation areas and other sites or areas of heritage importance
by implementing Article 4 (2) Directions to control certain types of permitted development,
which, if unchecked, would cause harm to the special character and appearance of such areas.
In full, CS8.6 states:
“The Core Strategy supports:
The safeguarding and, where possible, enhancing of historic environment assets,
including their characteristic settings and any attributes that contribute to a
sense of local distinctiveness. Such assets include listed buildings and features
(both statutory and locally listed), conservation areas, scheduled ancient
monuments and registered parks and gardens.
Seeking the adaptive reuse of redundant or functionally obsolete listed
buildings or important buildings within conservation areas, without harming
their essential character.
The preparation of a list of buildings and features of local architectural or historic
importance in order to assist in the planning of a prioritised programme of
conservation management for such buildings and features.
The production of conservation area management plans to identify and explain
how the Council will seek to preserve and enhance the special interest of such
Actions that will ensure the proper conservation of all heritage assets, giving
particular priority to those identified as being at risk.
Working with owners of heritage assets to ensure their maintenance and repair
accessibility and, where opportunities exist, there use as an educational
Consideration of the introduction of tighter controls within conservation areas
and other sites or areas of heritage importance by implementing Article 4 (2)
Directions to control certain types of permitted development, which, if
unchecked, would cause harm to the special character and appearance of such
The safeguarding and, where possible enhancement of, locally important
archaeological sites and features within the historic environment”.
t) CS8.7 – Sustainable Construction, Energy Efficiency, and Renewable Energy
Policy CS8.7 states new commercial buildings of more than 1,000 sqm will normally be
required to meet the BREEAM 'very good' standard and by 2013 new buildings will need to
achieve the BREEAM 'excellent' standard. It also states that the Council will seek to achieve
appropriate on-site renewable and low carbon energy sources wherever possible and the
most appropriate technology for the site and surrounding area should be used, having regard
to the physical nature of the development such as aspect, building height and the amount of
an open site open space, and the environmental quality of the surrounding area.
CS8.7 states that the Council will undertake a study on renewable energy potential and
viability, in addition to the Wind Energy SPD already developed jointly with Cumbria County
Council, with a view to including targets for energy to come from decentralised and renewable
sources within a review of the Core Strategy or subsequent DPD. In full CS8.7 states:
“New residential development and conversions will be required to meet the
Code for Sustainable Homes as required by building regulations.
These standards require initiatives such as:
Use of low water volume fittings and grey water systems and rainwater
Orientation to maximise solar gain;
High levels of insulation;
Adequate provision for separation and storage of waste for recycling;
Use of materials from a sustainable local source in new development.
New commercial buildings of more than 1000 sq. m. will normally be
required to meet the BREEAM 'very good' standard and by 2013 new
buildings will need to achieve the BREEAM 'excellent' standard.
The Council will seek to achieve appropriate on-site renewable and low
carbon energy sources wherever possible. The most appropriate technology
for the site and surrounding area should be used, having due regard to the
physical nature of the development such as aspect, building height and the
amount of open site open space, and the environmental quality of the
The design and access statement accompanying new development will be
required to contain a sustainability statement including information
necessary to show how the proposed development will contribute to the key
planning objectives set out in PPS1 and this Core Strategy.
The Council will undertake a study on renewable energy potential and
viability, in addition to the Wind Energy SPD already developed jointly with
Cumbria County Council, with a view to including targets for energy to come
from decentralised and renewable sources within a review of the Core
Strategy or subsequent DPD”.
u) CS8.8 – Development and Flood Risk
This policy notes that development within the Environment Agency’s flood risk 2, 3a and 3b
will only be acceptable when it is compatible with national policy when the sequential and
exception test, where applicable has been satisfied. Development would be permitted if it can
demonstrate that it would not have a significant impact on the capacity of an area to store
floodwater and the management of flood risk and surface water is managed in sustainable
where there is flood risk that this outweighed by benefits for the community. Policy CS8.8
“Most new development should be located in flood risk 1. Development
within the Environment Agency’s flood risk 2, 3a and 3b will only be
acceptable when it is compatible with national policy and when the
sequential and the exception test, where applicable, as set out in PPS25, have
All new development will only be permitted if it can be demonstrated that:
It would not have a significant impact on the capacity of an area to store
Measures required to manage any flood risk can be implemented;
Surface water is managed in a sustainable way;
Provision is made for the long term maintenance and management of any
flood protection and/or mitigation measures;
The benefits of the proposal to the community outweigh the flood risk;
Applications will be considered with regard to South Lakeland District
Council’s Strategic Flood Risk Assessment”.
v) CS8.10 – Design
Policy CS8.10 states that the siting, design, scale and materials of all development should be of
a character which maintains or enhances the quality of the landscape or townscape and,
where appropriate, should be in keeping with the local tradition. It also states that design that
support and enhance local distinctiveness will be encouraged and new developments should
protect and enhance key local views and features and characteristics of local importance. In
full Policy CS8.10 states:
“The siting, design, scale and materials of all development should be of a
character which maintains or enhances the quality of the landscape or
townscape and, where appropriate, should be in keeping with local
Where necessary, the Council will publish planning and design guidance
dealing with particular sites or types of development.
Designs that support and enhance local distinctiveness will be encouraged.
New developments should protect and enhance key local views and
features / characteristics of local importance and incorporate layouts that
reinforce specific local distinctiveness”.
w) CS9.2 – Developer Contributions
Policy CS9.2 states that the Council will require new developments to secure improvements
which are necessary to make the development acceptable by planning condition or obligations
and these must be phased so as to be in place in accordance with any agreed time frame prior
to the occupation of an agreed number of units. It also states that planning obligations may
also be required for maintenance payments and the Council will work with developments and
service providers to secure the necessary improvements to the following types of
infrastructure and determine the appropriate range and level of provision / contributions.
Policy CS9.2 states:
“In accordance with the provisions set out within planning Circular 05/2005,
the Council will require new developments to secure improvements which
are necessary to make the development acceptable by planning condition
or obligations, and these must be phased so as to be in place in accordance
with any agreed time frame prior to the occupation of an agreed number of
Planning obligations may also be required for maintenance payments, to
meet the initial running costs of services and facilities and to compensate for
loss or damage caused by development.
The Council will work with developers and service providers to secure the
necessary improvements to the following types of infrastructure and
determine the appropriate range and level of provision /contributions:
Physical infrastructure, which could include –
Transport relating to highways/roads, rail, waterways, bus/other vehicular
public transport, cycle, bridleway and pedestrian access and the securing of
Waste recycling and management facilities;
Drainage and flood defence/prevention measures;
Other utilities such as gas, electricity and telecommunications services.
Social/Community infrastructure, which could include –
Health Care facilities;
Education including local labour, training initiatives and childcare;
Community facilities (for example libraries, community centres/village halls,
cultural, leisure and religious facilities).
Green infrastructure, which could include –
Recreation provision (including open space, allotments, play and sport
Enhancement of the public realm, including public art, civic space and the
x) CS10.2 – Transport Impact of New Development
Policy CS10.2 states that development will be designed to reduce the need to travel and to
maximise the use of sustainable forms of transport appropriate to its particular location. It
also states that if the proposal were to have significant transport implications, then it is
accompanied by an air quality assessment, transport assessment, the coverage and detail of
which reflects the scale of development and the extent of the transport implications, and also,
a travel plan. Additionally it states that proposals should incorporate parking standards that
are in accordance with any adopted and emerging sub-regional and / or local policy and
guidance. In full, the policy states:
“Development will be designed to reduce the need to travel and to
maximise the use of sustainable forms of transport appropriate to its
particular location. Development proposals will be considered against the
The proposal provides for safe and convenient access on foot, cycle, public
and private transport, addressing the needs of all, including those with a
The proposal is capable of being served by safe access to the highway
network without detriment to the amenity or character of the locality;
The proposal does not involve direct access on to a Principal Route, unless the
type of development requires a Principal Route location;
The expected nature and volume of traffic generated by the proposal could
be accommodated by the existing road network without detriment to the
amenity or character of the surrounding area, local air quality or highway
If the proposal would have significant transport implications, it is
accompanied by an air quality assessment, transport assessment, the
coverage and detail of which reflects the scale of development and the extent
of the transport implications, and also, a travel plan.
The proposal incorporates parking standards that are in accordance with
any adopted and emerging sub-regional and / or local policy and guidance
Thresholds identified in national guidance and any new regional and / or local
guidance relating to when travel assessments and travel plans are required”.
South Lakeland Land Allocations Development Plan Document (December, 2013)
y) Policy LA1.1: Development Boundaries
This policy sets out the locations the Council support for new homes and
workplaces over the plan period. It has been produced to ensure that these new
developments are located in sustainable locations and protect the character of the
surrounding landscape. Policy LA1.1 states:
Development boundaries are defined for the following settlements:
Kirkby Lonsdale, Milnthorpe, Grange-Over-Sands;
burneside, burton-in-kendal, Endmoor, Holme, Levens, Natland,
Allithwaite, Cark/Flookburgh, Cartmel;
Broughton-In-Furness (outside the lake district national park), Great and
Little Urswick, Kirkby-In-Furness, Penny Bridge/Greenodd And
Between 2010 and 2025 the development needs of these settlements will be
met within the development boundaries defined on the policies map.
z) Policy LA1.5: Existing Employment Areas
This purpose of this policy is to ensure that there is sufficient supply of employment
land and premises available to meet the employment needs. Policy LA1.5 states:
The council will seek to retain the following sites, identified on the policies
map and premises within them in employment use unless it can be
The site is not suitable for employment use; or
Loss of the site would not compromise the district’s supply of employment
land and premises; or;
The proposed development is a mixed-use development that would result in
a quantitative and qualitative improvement in the supply of employment
land and premises.
aa) Policy LA1.11: Existing Outdoor Formal Sports Facilities
The purpose of this policy is to ensure that where there is a need for outdoor sports
facilities, existing provisions are maintained and enhanced. The policy states:
The outdoor formal sports facilities identified on the policies map will be
safeguarded from development unless a suitable replacement facility is
provided in an accessible location within the same area of need or demand
and where sites are also identified as greenspace or as a green gap, the
requirements of policy la1.10 or la1.9 (as applicable) are met.
South Lakeland Local Plan ‘Saved’ Policies (1997)
bb) Policy E4 – New Development and Extensions to Premises
Policy E4 states:
“Suitable employment-related development in existing employment areas,
including extensions to premises, will be permitted providing that:
(a) the development would not cause harm to the character of the area or the
amenity of nearby residents because of its scale, appearance or traffic
(b) adequate parking and servicing arrangements and appropriate provision for
cyclists are provided; and
(c) landscaping details, where necessary, form an integral part of the
cc) Policy E5 – Redevelopment
Policy E5 states:
“Favourable consideration will be given to proposals to redevelop obsolete
employment premises where:
(a) proposed development is not detrimental to its surroundings
(b) the proposed development incorporates satisfactory design, siting,
landscaping and access; or;
(c) employment uses are proposed”.
dd) Policy E6: Loss of Employment Sites and Premises
The purpose of the policy is to ensure that employment land is protected from
development that wishes to change from employment uses. It states:
Proposals to change the use of existing employment land and buildings to a
non-employment use will not be permitted except where:
The existing use is un-neighbourly because of traffic generation, noise, or
disturbance to the amenity; or
The change of use could assist a move to alternative and more suitable
premises in the vicinity”.
ee) Policy C5: External Lighting
This policy seeks to ensure that light spillage is minimised and to ensure that the
overall impacts of lighting on neighbouring areas are minimised. Policy C5 states:
Applications for development requiring, or likely to require, external lighting
shall include details of lighting schemes, which will be expected to
(a) the lighting scheme proposed is the minimum required to undertake the
(b) light spillage is minimised;
(c) in edge of town or village locations, or in rural areas, landscaping measures
will be provided to screen the lighting installation from view from
neighbouring countryside areas; and
(d) there will be no dazzling or distraction or drivers using nearby highways.
ff) Policy C6 – Sites of International Nature Conservation Importance
Policy C6 states:
“Proposals for development or land use change which may affect a
European site, a proposed
European site, or a Ramsar site will be subject to the most rigorous
examination. Development or land use change not directly connected
with or necessary to the management of the site and which is likely to
have significant effects on the site (either individually or in combination
with other plans or projects) and which adversely affects the integrity of
the site, will not be permitted unless the authority is satisfied that:
(a) there is no alternative solution; and
(b) there are imperative reasons of overriding public interest for the
development or land use change. Where the site concerned hosts a
priority natural habitat type and/or a priority species, development or
land use change will not be permitted unless the authority is satisfied that
it is necessary for reasons of human health or public safety or for
beneficial consequences of primary importance for nature conservation.
Where such development does proceed, the authority will consider the use
of planning obligations to secure all compensatory measures necessary to
ensure that the overall coherence of Natura 2000 is protected”.
gg) Policy C7 – National Sites
Policy C7 states:
“Proposals for development in or likely to affect Sites of Specific
Scientific Interest will be subject to special scrutiny. Where such
development may have a significant adverse effect, directly or indirectly
on interests of nature conservation importance it will not be permitted
unless the reasons for the development clearly outweigh the value of
those interests and the national policy to safeguard the intrinsic nature
conservation value of the national network of such sites”.
Where the site concerned is a National Nature Reserve (NNR) or a site
identified under the Nature Conservation Review (NCR) or a Geological
Conservation Review (GCR), particular regard will be paid to the individual
site’s national importance.
where development is permitted the authority will consider the use of
conditions or planning obligations to ensure the protection and
enhancement of the site’s nature conservation interest”.
hh) Policy C23: Tidal and River Defences
The purpose of this policy is to ensure that development does not negatively impact
the tidal and river defences. Policy C23 states:
“Development which would adversely affect the integrity of tidal and river
defences will not be permitted unless appropriate measures to ensure
their stability can be implemented as part of the development”.
ii) Policy L8: Provision of Club Houses and Car Parking
This policy states that the club houses and parking would be permitted as long as
they are suitably located and landscaped. It states:
“The provision of club houses and car parking areas in association with
golf courses and driving ranges will be permitted, provided they are
suitably located, landscaped, of appropriate size and scale and of a high
standard of design, using traditional materials. Details of any buildings
should be submitted with the initial application for the establishment of a
jj) Policy S2 – South Lakeland Design Code
Policy S2 states:
“All new development is expected to take account of the following South
Lakeland Design Code. Planning permission will not be given for
development which fails to take proper account of that Code:
Character: The design of new buildings should take account of existing
distinctive local character. This should not exclude good contemporary
architecture in keeping with its surroundings. A good original design will be
preferable to a poor copy of past style.
Setting: The setting of any building should be carefully considered, whether
in the countryside or in a built-up area. Attention should be paid to its
impact on public views into, over or out of the site. Those views should not
be significantly harmed and opportunities should be taken to enhance them
or open-up new views. In the countryside, or on the edge of settlements,
buildings should be located to sit comfortably in the landscape and skyline
development should be avoided.
Context: New buildings should relate effectively to others around them
adding interest and variety. New roofs should respect the roofscape of the
Proportion: New buildings should be well proportioned and in scale with
their surroundings. Extensions should be in scale and character with the
building to which they are added. Where appropriate, elevations should be
in proportion with one another and with surrounding buildings. The size,
spacing and location of openings should also be in proportion and related to
the function of the building, and harmonious with its architectural style.
Shopfronts should acknowledge the character and architectural style of upper
floors; they should distinguish between separate buildings, be of materials
and colours appropriate to the building, and be well proportioned in
Detail and Decoration: In the design of new buildings, opportunities may be
taken to add interesting details, ornamentation and expressions of local
craftmanship, while avoiding excessive and inappropriate clutter. The nature
and colour of external woodwork, cladding and rainwater goods, should
harmonise or where appropriate may contrast with the colour of the walling
materials. In areas around buildings, the use of natural paving materials and
traditional boundary treatments will be encouraged.
Building Materials: Materials used in new buildings should respect the local
context and any local vernacular tradition. Local or traditional materials such
as stone, slate, painted woodwork and renders should predominate in
important historic settings such as Conservation Areas or listed buildings.
These materials, or high quality substitutes, will also be encouraged in other
urban or rural settings, particularly where an important or distinctive
vernacular tradition forms the local or wider context.
Craftmanship: Building materials particularly local stone, should be used in
the traditional manner, with careful attention to its bedding or ‘grain’, the
width of courses, the colour and style of pointing; the laying of slates in
diminishing courses, and the texture and materials used in rendered finishes”.
kk) Policy S3: Landscaping
The purpose of this policy is to ensure that all new development incorporates a high
level of landscaping and maintenance of the said landscaping.
“A high standard of landscaping will be required of all new development, both
for the initial scheme and it’s long-term maintenance. Where possible, existing
landscape features shall be integrated into landscape schemes. Where the
District Council intends to adopt an area of landscaping, principally of benefit
to the development itself, a commuted payment will be required to meet the
cost of 10 years maintenance. The requirements of this policy will be
implemented as a condition of planning consent, or by planning obligation, as
ll) Policy S4: Important Open Space for Amenity
This policy states that development proposals would not be permitted on important
open space in the districts towns and villages. Specifically it states,
“Development proposals will not be permitted on important open space in the
district’s towns and villages. Exceptions to this policy will only be considered
where the proposal is for the extension, redevelopment or refurbishment of
educational, community or recreational facilities.
Key important open spaces are identified in the Proposals Plan, but other
unspecified sites such as private gardens, allotments, village greens etc., may
also be judged to form important open space and will be considered on their
merits as development proposals arise”.
Policy S10: Parking Provision in New Development
The purpose of this policy is to ensure that there is the provision of off-street car
parking where there are not other locations which have good access to other
means of travel.
“Off-street parking will be required for new development. The District Council
will calculate the requirement based on Cumbria County Council’s published
guidelines. However, the guidelines will be applied flexibly and will be relaxed
in circumstances such as town centres and other locations which have good
access to other means of travel than the private car”.
nn) Policy S26: Sewage Treatment and Disposal
This policy states that new development needs to provide adequate means of
sewage disposal and treatment. It states,
“Development which fails to provide adequate means of sewage disposal and
treatment, or where the capacity of the existing foul sewerage system or
treatment works would be exceeded, will not be permitted.
The installation of septic tanks will be favourably considered where connection
to the main sewers is not feasible, provided there is no adverse impact on
Where necessary, the District Council will impose planning conditions, or
secure a planning obligation, to ensure that adequate sewage treatment
facilities are available to serve the development.”
oo) Policy S29: Waste Recycling Facilities
The purpose of this policy is to ensure that proposals for waste recycling facilities as
long as there is adequate access to the site and does not detract from the amenity
of residential areas.
“Proposals for waste recycling facilities, where determined by the District
Council, will be favourably considered, providing they meet the following
(a) there is adequate and convenient access to the site;
(b) the proposal does not detract from the amenity of residential areas;
(c) adequate arrangements are made to maintain the site”.
Draft S106 Heads of Terms
Planning obligations should only be used where the purpose cannot be achieved by a planning
condition. This usually relates to items/processes outside the red line boundary or aspects too
complex to deal with in a condition.
Planning obligations are required to meet the following tests: necessary to make the development
acceptable in planning terms; directly related to the development; and fairly and reasonably related
in scale and kind. These tests are set out as statutory tests in the Community Infrastructure Levy
Regulations 2010 and as policy test in the National Planning Policy Framework.
The heads of terms set out below have been identified in response to the assessment of the impacts
of the proposed development and aspects identified within the Planning Statement.
Sports and Social Centre – defining the minimum requirements that replacement facilities
will need to delivery and the process for delivery including the possibility of off-site provision
should this be necessary. This will meet a policy requirement for the quantum and quality of
sports provision in the District to be maintained and/or improved;
Transport – implementation of junction improvements to the A590/North Lonsdale Road
prior to Phase 2. This will ensure the development does not place unnecessary pressure on
the local road network;
Skills and Education – contractors to use reasonable endeavours to: provide
apprenticeships; engage with relevant training providers; and run education initiatives in
local schools. This will ensure the proposed development maximises opportunities for local
people to benefit from the employment generated as a result of the construction phase of
Skills and Education - GSK to operate supply chain portal. This will ensure the development
deliveries economic benefits to the LEP area;
Improvements to Walking and Cycling Routes – ensure the Landscape Strategy identifies
enhancements or new links to key routes across the different phases of development. This
will ensure the GSK campus and, in particular, the Sports and Social Centre is easily and
safely accessible by sustainable modes of transport; and
Monitoring – contribution to the cost of monitoring S106 obligations and implementation of