Local Development Framework Consultation

Stainton Court, Stainton, Kendal, Cumbria, LA8 0LQ
info@coatesassociates.co.uk
T: 015395 61749 F: 015395 61849







Your Ref:
Our Ref: DHC/
Date: 2 May 2013

Development Plans
Amenities + Development
SLDC
South Lakeland House
Lowther Street
Kendal
Cumbria
LA9 4DL



Dear Sirs

Land Allocations DPD – MM016, Allithwaite, Land west of Brackenedge
Policy LA 1.3

I note the Council now proposes to delete the proposed housing allocation at the above by way of a main modification. This is welcomed, given the overwhelming evidence that there is no right of access to the land and that the existing narrow lane can not be widened or improved to meet highway standards

However, despite the proposed main modification to delete the housing allocation, the Council proposes to retain the same area, but as unallocated ‘White Land’, within the development boundary. It was envisaged that the Council’s agreement to delete the housing allocation would also include modifying the development boundary so that the area remains outside the development boundary. The Council’s current suggestion that the site could be suitable for development at some point in the future is illogical. This is because, as the site has been found not to have a right of access to it, a fact the Council appears to have accepted, the site is therefore unsuitable for any development.

Consequently, as there is no right of access to the land, the inclusion of this land within the development boundary is NOT sound. Furthermore, even if a right of access to the land did exist, the existing narrow lane and junction with Holme Lane can not be widened or improved to an adoptable Highway standard by reason of the existing housing either side of it. This further demonstrates that inclusion of the land within the development boundary as ‘White Land’ is NOT sound. In addition, the allocation of ‘White Land’ does not form part of a strategy within the Land Allocations DPD as a whole, which further demonstrates that the proposed inclusion within the development boundary is NOT sound.

The Inspector is requested to recommend that the development boundary be modified to exclude the area of land (hatched black on the attached plan) to ensure that the plan is sound. This is also consistent with the core strategy and the approach taken by the Council on other sites.


Yours faithfully





David H Coates
Coates Associates

Please ensure that the boundary line is amended to its original position re land West of Brackenedge previously R265~now MM016.

The land has been consulted on,agreed as unsound and deleted from the allocation document, as such the boundary should be re instated back to its original position, behind the houses on Holme Lane.This is in line with the core stategy and consistent with SLDC's approach to boundaries on other previously consulted land agreed as unsound and not suitable to go forward.(both in Allithwaite and across South Lakeland)

Regards

Paul and Gail Airey

Brandreth
Holme Lane
Allithwaite
Grange-Over-Sands
Cumbria

Re plot M38M Burneside tennis club and Willink field
I have previously written to you about the above site. This site is placed in the Willink trust. When Mr Willink died he left the field in trust to the people of Burneside as a recreational field.
The field now has 3 trustees, one of which is James Cropper.
A meeting was held on Wednesday February 27th in Burneside School Hall with the people of Burneside and the trustees of the Willink Field. The representative of the trustees was James Cropper.
It became very obvious as the evening progressed that all Burnesiders wished to keep the recreational field where it is and not have it moved, by a HUGE majority.Also it was pointed out that the field James wishes to sell to the village for the new club, floods with sewage every year and is up a road with no pavements, lighting, and HGV's going along it regularly, hardly suitable.
At the end of the evening, James admitted that Burneside wished to keep the field where it is and that he would withdraw it from the land allocations. A planning officer from SLDC was there at the time and witnessed this.We were all happy with this outcome.
However a week later James has said that it is still being put up for sale as HE feels that there were not enough people at this meeting (the room was full!) and it wasn't representative of the people of Burneside. It was an open meeting and anyone could attend. It was also well advertised. Anyone interested in the Willink field was there. Is this what James Cropper calls democracy???? He should be thoroughly ashamed of himself and it is a total betrayal of the Willink trust. Trustee my ass!!!!He clearly is not putting the Burneside people first here!


Yours sincerely,

Gillian Allder B.Ch.D.

Dear Sir / Madam,

I wish to make comment on the Major Amendments Document.
Firstly MM 051 the Berners Site.
The main modification states there will be “leisure use” and the development will “create a cluster of facilities and attractions”.
The Core Strategy states that “tourism, leisure and heritage sectors are to be developed in order to achieve a sustainable local economy”.
The proposed plan for this site AND the town does not fulfil these stated objectives.

Secondly, infrastructure provision to support the proposed development area to the south of Grange.
The footpath provision linking Lindale to Grange is on the opposite side of the town to the proposed development area which is approx 2 ¼ miles away.
This cannot be described or classified as “supportive infrastructure” for the proposed development area.

MM052 I would now make reference to the proposed cycleway / footpath from the Promenade to Kentsford Road.
No due consideration has been given to the route being of an acceptable standard to accommodate the mixed use of pedestrians, cyclists and the disabled. Risk assessment shows that with the physical restrictions alongside the sections adjacent the railway line (the highest risk section being immediately behind the properties on Kentsford Road) there is a substantial increase in the risk for all users. This is predominantly due to width and poor sight lines.
To simply dedicate this substandard route that does not comply with your own strategy documents for multi use is unacceptable. The design criteria must take into account the complete spectrum of all user groups if this facility is to be considered as truly supportive infrastructure. There are a number of these facilities in South Lakeland where use by the designated groups is extremely low, this is predominantly due to poor design and not being fit for purpose.

The Core Strategy states;
Policy T4, “all development and associated highway proposals should provide for safe, direct, convenient and attractive means of movement on foot”.

Policy T5, on cycling states “when assessing development and associated highway proposals, safe, direct, convenient and attractive provision for cyclists will be sought”. This may also include “detailed traffic management and traffic calming schemes to ensure both cyclist safety and priority of movement”.

Policy T13, “seeks the safe and convenient movement of pedestrians and cyclists as well as people in cars”.
It is clear that pedestrians, cyclists and the disabled (the less able bodied also) should not have to use substandard or potentially unsafe infrastructure as part of community development as is proposed with this route. These user groups are entitled to the same consideration as other highway users when assessing “safe and convenient movement”.

I would now describe the problems associated with the current proposal using the Promenade / Kentsford Road footpath;
Starting at Kentsford Rd, access is via numerous steep concrete steps onto a section of narrow elevated path alongside the railway line. This section of footpath is not wide enough to allow two people to pass comfortably and will not accommodate multi use safely. This first section has the railway track at a lower level on one side and retaining walls to the rear gardens of properties on Kentsford Rd on the other side. The use of bicycles on this section will create conflict between user groups, its inevitable given the restricted width.
The next section of concern is the access directly onto the Promenade from Cart Lane. The section under the railway track onto the Promenade is via two 90 degree turns within 3 metres, both are blind turns with restricted width. This combination will significantly increase the risk of accident. There is also a severe height restriction at this point and its possible that an adult on an upright commuting bicycle will risk a head injury. At the opposite end of the Promenade near the railway station again there is a 90 degree turn. The risk at this location is reduced, due to the width of the access road and Promenade at this point giving better sight lines, this may lead to an increase in the speed of access / egress by less responsible cyclists.

Lastly, the Core Strategy states that Grange has a number of cycle ways crossing the town, this is totally untrue. The town is on the Walney to Weir cycle route using the National Cycle Network. This route descends Low Fell Gate down the B5277 into Kentsbank Road, down Main Street and into the Meathop road near the golf club. This route is far from ideal and at times is dangerous due to the volume of traffic, this will not benefit any of the development proposals. This route would not conform or satisfy policies T3, T4 and T 13. There are no other designated cycle routes in the town.

The Local Plan should comply with Core Strategy Policy, it should not be selectively applied to the detriment of any section of the community in relation to essential supportive safe infrastructure.

[see attached document]

Reference MM033 page 67 Policy LA2.8

I was pleased to note the modification that there will be a contamination assessment. I would ask that the language read:

... approval of a contamination assessment 'of both landfills' to examine the 'current and potential future airborne and land' risk .......

At the end: 'This should be completed with cognizance of EU regulations relating to landfills containing hazardous waste'

As mentioned at the hearing at least one of the landfills is known to contain hazardous waste and I have not seen evidence that the other - older- landfill does not.

Studies on the impact of landfills were cited during the hearing.

Many thanks for your consideration

Giles Archibald

[see attached document]

[see attached document]

[see attached document]

[see attached document]

[see attached document]

To Mr Simon Berkeley BA MA MRTPI,
Planning Inspector


Dear Mr Berkeley


Response to Schedule of Main Modifications (SMM) of SLDC Land Allocations DPD, April 2013, and supporting new evidence base, particularly in regard to site R121M, land east of Castle Green Lane/Road

1. In response to point MM0088 of the SMM regarding the assumption by Cumbria County Council (CCC) of responsibility for flood risk and surface water management, I note that neither CCC nor SLDC have as yet presented evidence or even plans for assessing site R121M. SLDC has so far ignored evidence presented by local residents in regard to the flood risk on this site and its impact on the Stock Beck Scheme.

2. In response to point MM024 of the SMM which states that site specific Development Briefs will be developed for major, complex or sensitive sites, I note that no such brief is listed for R121M. Why is this? R121M should count as both a complex and sensitive site. Local residents have catalogued in great depth a whole series of issues relating to flood risk, poor highways access, impact on landscape and environment etc. What are the criteria for selecting sites for specific Development Briefs?

3. While I note the requirement for the Viability Studies prepared by HDH Planning and Development to demonstrate that site R121M may or may not generate sufficient sale value for the landowner and profit for the developer, such studies seem pointlessly abstract without further evidence of the costs and implications of trying to develop the site. The site is subject to major concerns and has been rejected for development on previous occasions. In the Viability Study appendix showing the site specific map (pp 21-22), HDH Planning and Development state that the promoter of the site has estimated abnormal costs of £336,176. What exactly does this cover and how has this cost been estimated?

4. However it is the Further Highway Evidence Report prepared by AECOM which I gives me greatest concern (and in particular those relating to R121M on page 60). The 'findings' are so cursory as to be risible. In particular:
4.1. the lack of even the most outline of plans showing potential road layouts, entrance/egress to and from Castle Green Road
4.2. the issue regarding orientation of the cul-de-sac stub in Oak Tree Road which would necessitate a 180 degree turn for a route to enable onward access into any new estate
4.3. the narrowness of parts of Oak Tree Road which is down to 4.25 metres at its narrowest and most dangerous point close to the entrance to Castle Green Road
4.4. the susceptibility of the most of the lower part and entrance of Oak Tree Road to frost, snow and ice; this has been demonstrated several times over every Winter when passage to and from the estate has been hazardous or impassable except to four-wheel drive vehicles
4.5. the complete unsuitability of attempting to convert what is essentially a quiet estate road (Oak Tree Road) into potentially a throughway from one part of Castle Green Road to another part of Castle Green Road via Oak Tree Road
4.6. the number of blind bends and pinch points on Oak Tree Road which with the current low traffic of a quiet estate will inevitably lead to accidents, danger to pedestrians and cyclists when the road has to serve as a busy through road for well over double the residences (including both Oak Tree Road and the new site) the existing road was meant to serve
4.7. the impact on residents on Oak Tree Road of increased traffic from the new estate with potential restrictions on their own parking, and a huge increase in noise, pollution and subsequent reduced quality of life

This 'Evidence report' (which hardly merits the name) leaves me with little else to conclude that this is vacuous study funded by CCC which does little else but approve CCC's own totally inadequate desktop assessment. It illustrates the lack of independence and reliability of a study funded by CCC to validate its own findings by a paid third party (AECOM). It also illustrates that both CCC and SLDC have failed to carry out a proper highways assessment for site R121M and its impact on Oak Tree Road.

I should also remind you of my previous objections presented to SLDC which have covered the impact of this proposed development on drainage, flooding, biodiversity, environment and landscape. I regret to inform you that SLDC have comprehensively failed to engage with local residents and our concerns, and continue to ignore evidence and information which we have presented and which they find inconvenient and contrary to their intentions.

I thank you for your attention in this matter

Yours sincerely


David R Baxter

[see attached document]

I should like to comment on the updated Main Modification MM004

"Development boundaries defined for Broughton in Furness..... as defined on Policies Map"

As you are no doubt aware the interactive Policies Map on your website has no Land Allocations for housing shown on it yet, therefore how is it possible to be sure what the 'defined' boundaries are? The site R163M-mod identified for housing has been through a number of incarnations, and there have been at least two maps drawn, neither of which accurately represent the situation on the ground. I assume you are going with the 'Proposals' map, or has there been another change? As definitions go, this is ambiguous. Also, as the site has changed from R163 to R163M and then R163M-mod, some of the relevant information from the fact files has been lost. In particular, for R163, United Utilities said there was a water main crossing the site which could not be built over and therefore was a potential viability issue.This water main still crosses the modified site. It crosses it diagonally, which may well affect the ease with which the site can be developed and therefore it's potential viability. (Incidentally, United Utilities have plotted the water main in the wrong position on their plan.)

Re E063 LA DPD_5.4.13.pdf

May we record our opposition to the inclusion of R170M in the Land Allocations Plan on the following grounds based on unsoundness.

1. Traffic. We have lived in this location since 1983 and have seen a steady increase in traffic numbers, owing to the building of the Briery Meadows Estate and the opening of the Carus Green Golf Club. The existing Croppers traffic has always been accepted, however the ‘rat run’ effect caused by the build-up on Windermere Road is not. To consider a further increase of 285 from a 190 unit build is unpalatable in the extreme. This is only a ‘C’ class highway and is mainly residential with properties egressing and having to back into and out of drives in front of flowing traffic. Is this acceptable?

2. Air Pollution. The air pollution standards in the centre of Kendal(Lowther Street, Highgate, Wildman Street)are some of the worst in the Country. As you are aware this effects the health of the community as a whole. The plan proposes a significant increase with no real amelrioration save encouragement to walk and cycle, which we would support. The main problem is at traffic junctions such as Burneside Road with Windermere Road where pedestrians stand and breathe in the toxic fumes.

3. The Green Gap. The value of the Green Gap has been long established, supported by the previous Inspector and valued by wild life, farmers and residents. Why is this principle, yet again, being challenged by SLDC ? The coalescence with Burneside is a distinct possibility.

4. Flooding and sewerage. The two are interrelated; in 2012/13 properties in the vicinity of Carus Green suffered flooding caused by the nearby River Kent and run-off from the fields(Limestone is found on the escarpment and Silurian Slate at valley level). It is well known by the Council and Utilities that the sewer is over loaded and sewerage appears in Burneside and below Applerigg on Burneside Road. Further increase of sewerage will compound the situation. A costly upgrade is required, is this budgeted for ?

5. General comment. The Council claims that 400 unit build is required annually, these figures have been challenged by Kendal Town Council, we would support that view and that the considerable build in the brownfield/windfall category must go a long way to meeting demand, at least in this year e.g Auction mart site(90 units), Cock and Dolphin and alongside Kent Court.

Thank you for considering these comments, David and Valerie Birkett

Main modification reference MM041
I note the Main Modifications proposed by South Lakeland District Council to work in partnership with Lancaster City Council, the relevant Parishes, the management of The Arnside & Silverdale Area of Outstanding Natural Beauty, and others to produce a new Local Plan for the AONB.
I also note that this will apply appropriate policies in this area specifically intended to get the correct balance between protection of its special landscape and other local needs such as housing provision and other amenities.
I believe that this will produce a much better plan than SLDC’s previous version and therefore am in enthusiastic support of this new proposal. I look forward to hearing how I can support this process in practice.

MM 050 - Bristeer.

With regard to site MM 050, the updated Main Modification document states that " it is considered that the degree of community involvement and support for this proposal .......justify its inclusion as a land allocation."

There is considerable opposition to the proposal in Brigsteer, which was demonstrated by the voting at the Parish Meeting on 10th April 2012 with 17 or 21 votes supporting (depending on the time-scale) and 30 votes against the proposal. The proposal was also rejected by the current Parish Council, based on the majority community decision. It seems that there is no evidence to support the statement on 'the degree of community involvement and support ' put forward in the updated Main Modification and I cannot understand how the data can have been misinterpreted. There has been very limited consultation on the proposal which was developed by the Helsington Community Land Trust, although this group does not have a majority mandate from the Brigsteer Community to do so.

For the above reasons, I feel that the proposal is still 'unsound' and therefore should be removed from the Schedule of Main Modifications.

[see attached document]

[see attached document]

Glyndon
Allithwaite Road
Grangw-over-Sands
Cumbria
LA11 7EN
20th March 2013
Chief Planning Officer
South Lakeland District Council
South Lakeland House
KENDAL
Cumbria

Dear Sir,
We wish to object to the proposed building of 43 dwellings on land called Berry Bank in Grange ( land between Allithwaite Road and Carter Road ).

We have four main objections:-

1) That the development will have the potential of increasing traffic onto the main and only road through Grange by approximately 80 vehicles plus the extra raffic of visitors an deliveries etc.
This road is already busy and at times it is very difficuilt to access easily and safely. The road has
only one pavement which is very narrow and would be very difficult and dangerous for families walking into Grange.

2) Berry Bank land should be left as a green open space and also to act as a divide between
Grange and Kents bank. We would have a ribbon of buildings from Yew Tree Road junction to past Carter Road junction if this piece of land was developed.

3) The housing proposed is not in character with the surrounding properties, the present houses have a good frontage to the main road, making access safer the proposed buildings appear have very little frontage and therefore a danger to children possibly running out into the traffic. There appears to be no provision for any play area .

4) The main problem in Grange is the availability of affordable houses. We believe that some have already been passed in grange and that brown field sites should be used before any green field sites are even concidered

We hope that this project will not go ahead for the sake of the whole of Grange. The B5277 road takes all the traffic from Grange and the surrounding villages, it is already very busy, and actually parking in Grange is almost impossible at times.

Yours faithfully,

Tom & Ann Blakemore

Land Allocations DPD
Objection to Main Modification – Land Allocations put forward for final inclusion dated 5.4.13

Reference MM015

RN79#-mod,
Allithwaite, Land North of Jack Hill
Extension of allocated area

This proposed Modification is Unsound on the following basis:
1. Key issues have been raised historically regarding the Western part of the site with reference to:
a. Access arrangements, local traffic management, access points, safe travel within the village, traffic and pedestrian safety specifically regarding this site – see Land Allocations Development Plan Document – March 2012 and other references below.
b. The removal of species-rich, long established, continuous hedgerow that surrounds an existing field, housing many nesting birds and other wildlife.
2. The access arrangements and position for this part of the site also affect the whole village in the following ways:
a. Consideration of all aspects of concerns regarding the entrance of the village from Residents, local and County Councils, other interested parties.
b. Consideration of all aspects of concerns regarding Holme Lane from Residents, local and County Councils, other interested parties
c. The road safety aspect
d. Pedestrian safety and accessibility
e. Key Environmental impact
f. The impact of character on key topographical site
g. The surrounding countryside and Landscape setting
h. Reducing the availability of Important Open Space

Highways Evidence Report was issued 2.4.13.
This Report requires inclusion and referring to in the Land Allocation for this site and in addition cross-referencing with site R347# - Land rear of Bankfield which refers to site RN79# with particular regard to the entrance to Jack Hill which might necessitate a new junction / mini-roundabout.
1. The Sustainability Appraisal Reports for RN79# cannot be considered sound for the reasons:
Taking the Highways Report into Account and also the considerable concerns from the Village about many aspects of this including items of road safety on Holme Lane and Jack Hill for example, Sustainability Appraisals for RN79# and R128 are Unsound – Many supporting key issues cannot be justified or mitigated.
Part of the access point for RN79# on the West part of the site will necessitate removing several meters of a species-rich, long established hedgerow which houses many nesting birds and other wildlife.
2. The Core Strategy policy of Green Infrastructure is unsound in the following ways:
a Species-rich hedgerow removal.
b The Highways requirements for access and transport statements on the Western part of the site throw into doubt the position, size, landscape, character of the site; changes necessary at the dangerous bend entering the village – the entrance to Jack Hill, which includes the position of the post that has many times ended up in the Western field of RN79#-mod when cars have driven too fast into it. Local residents, Parish Council, County Council are all aware of the danger for pedestrians and vehicles and the consideration needed to be given to the entrance to the village. These are key issues for this site.
c Access arrangements still to be made both for the Western part of the site (which include the entrance to the Village) will have a substantial effect - the pedestrian facilities, routes to access footpaths, bus stops, letter boxes etc in safety.
d The effect on the Landscape setting will be substantial:- the present approach into the village from Grange opens up long views over countryside and out to Morecambe Bay, at the top of a hill looking over the
valley, continuing the feel of green space over, at present, Important Open Space. This would be entirely lost if it were built on. Nowhere else could offer this – the position is unique.
e The proposed size of the site would undoubtedly require a large roadway and turning to accommodate emergency services, public service vehicles. Streetlighting may be necessary. Access positions, pedestrian facilities, safety, particularly on Holme Lane are some of the key issues that have historically been raised. This is a prominent area in the village – at present Important Open Space. During SA for both RN79# and R128, many concerns were raised about retaining the space. This proposed area can be seen from all areas in the village. During the SA’s, site R128 has been associated with RN79# but not been clearly defined on a map. SA provides insufficient information regarding the extent of the site which was remaining Important Open Space at 17th September 2012, it has not recorded sufficient historical concerns / reports / information provided by local residents, local and other interested parties which concern the site R128, RN79# and also Holme Lane. This amounts to lack of due diligence in my mind.

The impact of increasing the size of this site is much greater than may appear as it would not merely be merging a small area of a large site of open space with another already allocated area, but increasing the already allocated area to a size that could not be anticipated in the SA, therefore making it unsound. Having canvassed many local residents, this is the opinion of all.

[see attached document]

Re MM003,
Regarding the council's duty to co-operate, in December2012, SLDC came to agreement with Eden and Carlisle to have a M6 corridor initiative. This agreement does not appear to have been taken on board by the plan, in fact in para 2.49 it specifically excludes further development at junction 36.

Re MM003 together with MM033(LA2.8)
The duty to co-operate has not been reflected in the planning brief for R 129M - land to the south of Underbarrow Road. Although it makes provision for a transport assessment, there is no requirement in the brief to co-ordinate with SLDC's E33, LDNP'S KFO1W and Cumbria's plan to relocate the Household Waste Recycling Centre to Kendal Fell. Throughout the allocations procedure there has been a vagueness and lack of transparency regarding the cumulative affects of all these proposals and these need to be clarified. The Aecom evidence was at best a superficial rubber stamping of Cumbria's findings and doesn't give an answer as to how E33 can be accessed without getting in the way of the LDNP allocation and Cumbria's HWRC proposals.
The LDNP plans require a transport assessment to accompany a planning application.
I would suggest a sensible way forward would be to have a joint transport assessment agreed by all the stakeholders and for this requirement to be included in the plan.

MM024,
Policy LA1.3 R129m - land south of Underbarrow Road- it would appear that this allocation has moved from phase 2 to phase 1 without any evidence or explanation as to why .

[see attached document]

[see attached document]

[See attached document]

Response to revised DPD Main Modification ref MM 050

In general the Land Allocation DPD has excluded development in small rural communities, but has made an exception in the case of Brigsteer (see paras 2.13, 3.150 and 3.151 of the marked-up DPD) despite the many indicators against this site in the Fact Sheet (eg lack of infrastructure, transport links, employment opportunities, etc).

The revised DPD refers to “degree of community involvement and support” as the reason for making an exception from the usual policy for small hamlets. This is based on a misconception which has been generated by the self appointed Helsington Community Trust who have made no attempt to engage with the community.There is a danger that a small non-elected pressure group will bulldoze their own ideas with SLDC support without a mandate.Indeed, the Parish elections in May 12 presented the electorate with the only opportunity open to them to voice their opinion of the operations of the Helsington Community Land Trust by voting out HCLT members who had been using their majority on the Parish Council to lobby their personal agendas. Subsequently, the new Parish council carried out the wishes of the majority and withdrew their support for the development. Previously the views of the community was clearly demonstrated at the public meeting, but ignored. A request for the Helsington Community Land Trust was also made to consult and provide more transparency to their aims and business plan. Despite promises to the contrary,adequate communications have not been forthcoming, further fueling concerns at the real aims of the Group.

I believe that a well presented transparent plan for affordable housing would be well received by the community but this proposal is unsound and promotes over-development of the village providing a small number of affordable homes financed by a substantial commercial open market housing development which will give no assistance to current local needs.

MM002/1.23

“Presumption in favour of sustainable development:”
“...to secure development that improves the economic, social and environmental conditions in South Lakeland.”
1. Objection re environmental conditions: the amended plan does not address the well-known traffic bottlenecks on the B5277 through Grange-over-Sands at Main Street and Risedale Hill; neither does it address the problem of flooding caused by rainwater run-off alongside the railway embankment, Cart Lane and Kents Bank station. There are also the issues of the loss of important greenfield sites, and the loss of open space between Kents Bank and Allithwaite.
2. Objection re economic conditions: the amended plan does not recognise the importance of the tourism industry to Grange-over-Sands. The plan removes 164 parking places and does not allow for tourist coach parking. If the Berner’s development is to be a success, we need more parking, not less. Otherwise we will end up with another failed project. Even if coach parking were to be available, coaches avoid driving up through Grange to the town centre because of the serious traffic issue of driving up Main Street. Only one lane of traffic is possible up Main Street if there is an HGV vehicle, a wide load, or a large coach. This frequently happens, even outside the tourist season.

MM007/2.23 also refers to taking into account:
• “General criteria such as ... the ease of accessing the site”. The B5277/Main Street is inadequate as an access road into Grange-over-Sands. Local traffic flow data was based on a traffic survey at Risedale Hill on 29th January 2013, 8-9am and 5-6pm - which is hardly representative.
• “Sustainability considerations including the distance of key services, the quality of public transport ... the risks of flooding...”. SLDC assert that Grange-over-Sands is a Key Service Centre, but it does not comply with SLDC’s own criteria: it is not the main employment centre for the surrounding villages; there is no secondary school or educational provision for children 16 and over; there is no direct bus link to the nearest hospital at Kendal; the nearest petrol station is a 12-mile round trip; there are no buses in the evening or on Sundays.
• “Landscape and settlement considerations including the potential impact of development on landscape and views, the scale of development relative to the settlement size, whether the site preserves the separate identity of settlements...” 735 new homes in Grange-over-Sands and district is severely out of proportion with the settlement size and will have an adverse affect on landscape and views. We will lose our attraction as a tourist centre. The assessment of housing need is based on flawed statistics, i.e. questionnaires returned by only 18.7% of households in the area, 2001 census figures, and the assertion that Grange is a Key Service Centre. The separate identity of settlements will disappear.

MM008/2.25
“Once all elements of the Flood and Water Management Act 2010 have been implemented.... that meet National Standards for development.” No building should go ahead until there is an effective, proven flood management strategy.

MM053/Policy LA3.2
“...land south of Allithwaite Road, Kent’s Bank.... B8 employment uses will not be permitted on the site.” This is a red herring - B8 employment units were not included in the original plan anyway (MN25M).

“... the retention of the westernmost portion of the site for open space and landscaping.” The acceptability of this statement depends on the size of the proposed portion.

I submit my comments as a Grange-over-Sands resident, in the hope that they will be taken into account - but in truth with no confidence that they will be, based on past experience.
Yours sincerely
Margaret Carter

Response to revised DPD Main Modification ref MM 050

The inclusion of the Brigsteer site RN 213 in the revised Land Allocation DPD is unsound.

Brigsteer is a small rural community and should be excluded from development in line with the general approach of the DPD. The DPD reason for including Brigsteer relates to an apparently high level of community support, yet there is considerable local opposition to the development. The facts are that at the Helsington Parish Council meeting on 10/4/12, 31 people voted against the development, and 17-20 people voted in favour (depending on the development time-frame).

If the DPD is committed to reviewing evidence for each development option, then clearly, there is no evidence of sufficient community or involvement in the proposed Brigsteer site. Although the site may be supported by a self-appointed local land trust, this is not the official body for representing community views. It is unclear why the DPD is still struggling to interpret the results of the public voting at the Parish Council in April last year.

The land between Holme Lane and Jack Hill in Allithwaite is unsuitable for the ill conceived, proposed housing development. The site is elevated well above surrounding houses and will not lie sympathetically within the existing housing and landscape. Provision of access and services will be problematical. The proposed numbers appear to be guesswork and not evidence based on local requirements.

[see attached document]

We wish to object to the updated proposed Land Allocation Development Plan Document (LADPD) particularly as it relates to the Grange over Sands and Kents Bank Area, for the following reasons:

1. Inadequate infrastructure to cope with projected increase in traffic. In the absence of any plans to improve the roads and public transport the existing problems with bottlenecks in Allithwaite, on Risedale Hill and Main Street will be significantly worsened if developments are allowed to proceed following the proposed plans.
2. Loss of green gap between Kents Bank and Allithwaite. The proposed developments (MN25N) south of Allithwaite Road will effectively cover with buildings the very pleasant green fields between these two areas, leaving only 220metres of open space. The whole of the Grange, Kents Bank and Alliwthaite will be joined together in one urban sprawl.
3. Over-provision of expensive housing in the Grange area. The allocation given to the Grange area appears to be based on the fact that it is a key service centre even though it does not possess many of the facilities and infrastructure required. The most urgent need for housing in this area is for low cost and low rent homes. All proposed developments at the moment, which rely on the open market to meet demand, are completely unsustainable. This is because in return for a tiny number of “affordable” homes the builders/developers always additionally require a large number of additional houses (which hardly anyone can afford to buy in the current economic climate). Covering the open fields of Grange and Kents Bank (and the rest of South Lakeland) with concrete is a foolish and environmentally disastrous way to try and solve the problem of a lack of affordable housing.

Yours faithfully,
Mr & Mrs T. Cook

Land development R121M-mod (Kendal)
We would like to express our concerns regarding the possible use of Oak tree Road & Rowan Tree Crescent as road access points, should Area R121M be developed for new housing.
Our concerns are as follows;-
Use of Oak tree road as access to Area R121M would put a great strain upon the existing road system in Oak Tree Road & Rowan Tree Crescent.
As any thorough and detailed site inspection and any consultation with existing residents would confirm, the road is already too narrow and congested for its current us. Increasing the volume of traffic would make matters much worse.
The problem is partly due to the original driveways being too narrow for modern day vehicles which means that many residents find it necessary to park exclusively upon the road side.
This is made worse because many residents have more than one car per household.
Consequently, delivery and waste collection vehicles have great difficulty negotiating the route around the existing estate.
It is particularly difficult to safely pass other vehicles on the road. This is almost impossible at the corners of the estate.
If access to the proposed new estate was through these roads, the current roads could not cope with extra traffic and there would be significant problems of congestion and road safety.
The increased number of cars could be in the order of 120, in order to serve 60 modern households. This extra volume of traffic would have a very detrimental effect upon the resident’s quality of life, with lots of extra noise and concerns for safety. This would more than double the existing volume of traffic.
The entrance to Oak Tree Road, which is directly on to Castle Green Road, is a very dangerous junction close to a bend on to a busy road. Castle Green Road is frequently used as a means of avoiding Kendal’s one-way system and consequently the majority of road users disregard the existing 30 mph speed limit.
Some reasons for this are that the junction is situated too near to the change in speed limit from 30 to 40 mph for vehicles leaving Kendal. Consequently they speed up to climb the hill at the higher limit. Traffic entering Kendal is descending a hill, so it requires a greater effort to slow down to comply with the reduced speed limit.
Clearly, it must be a number of years since traffic surveys have been taken on Castle Green Road, or else the position of the change in speed limit would have been re-located.
Consequently, entering and leaving Oak Tree Road can be dangerous as there is also a difficult hill with a bend directly upon entering Oak Tree Road.
Increasing the volume of traffic using this already unsatisfactory & dangerous junction can only increase the risks to traffic & pedestrians, considerably. As any recent traffic survey would confirm, at certain parts of the day crossing Castle Green road to Oak Tree Road, either in a vehicle or on foot, can be extremely difficult, time consuming and potentially hazardous.
It is surprising that the exit from existing estate to new estate, utilising the existing cul-de-sac stub, is considered to be viable when this will require a 180 degree turn up what is likely to be a very steep hill. Clearly the difficulty of the topography in this area for location of an access road has not been adequately taken into account.
With known risk of flooding in this area, winter conditions are likely to be treacherous. The existing road is too narrow to be adequately and regularly gritted in winter, and residents have to make their own arrangements to remove snow and ice for safe access to their homes. Again, it is clear that the local residents have not been adequately consulted regarding their knowledge on this issue.
In fact it is clear that there is no evidence that the views and current background knowledge of the local community being taken into account for any aspect of this proposal.
John & Jane Corbett

5th May, 2013.
SLDC LDF DPD

SUBMISSION TO THE INSPECTOR
Consultation on the Updated Schedule of Main Modifications to the DPD.

Submission by E.W.Craker.

1. General point regarding submissions.

Although my main interest is in the proposals for Quarry Lane, Storth, this point is relevant to all the SLDC Planning area.

Submissions have been invited by an email from Mr D Hudson dated 5th April.
That email states that “Comments must only relate to the published updated Schedule of Main Modification (Quoting the main modification reference number)”.

There are of course other recently published documents, e.g. the AECOM highway Study and the HDH Viability Assessment.

It is only because of correspondence with Mr Hudson and Mr McNeill that I am aware that comment may be made on these new documents.

Others are therefore not likely to be aware, and thus effectively have been denied the opportunity to comment.

This is not as it should be, and is not in the spirit or interest of democracy or open government.

2. Comments on the March 2013 AECOM Highway Study.

This includes 4 options for access to M683sM-mod

As a general comment on the Study, the AECOM unit cost figures seem very low. By their own admission, they are taken straight from a textbook, and make no allowance for the fact that the underlying strata is rock (therefore very high excavation costs) and that most of the necessary highway works are immediately adjacent to a deep and almost vertically sided railway cutting.

Option A. (Road in thro’ Travis Perkins yard).
On its own this only gives access to EN 40. Other than to emphasis my general point above regarding optimistic costings, I make no further comment at this stage.

Option B. (Access to M683sM-mod from Storth Road.
AECOM make no allowance for upgrading the existing (unadopted) road between Storth Road and the entrance to the site, a distance of some 60 metres.
CCC (Mr McGeough, at a site meeting on 12th November 2012 said that the minimum acceptable would be a 6m carriageway and two 1.8m footways, i.e. a total of 9.6m.
Quarry lane is only 5.8m wide at best, and is constrained by private land on one side (my garden for the major part of the length) and the almost vertically sided railway cutting on the other. Even using AECOM’s optimistic rates for new carriageway, that would be an additional cost of £78,000 plus very significant extra costs to deal with the railway cutting.
Also, there is no allowance for providing the necessary visibility sight lines at the Storth Road/Quarry Lane junction. CCC require 2.4m x 45m.
This is not achievable without major alterations to the existing bridge and its parapet (Owned by BR). 2m extra width would be required, and using AECOM’s figures, 25m (the bridge is on a skew) x 2m x £3000 = £150,000.
In addition the southward visibility problem remains, for which land purchase would be required.
Therefore the total cost would be £83,952 + (£78,000 + £150,0000)1.44 = £412,272 plus land purchase, which is unlikely to be achievable.

Option C (New bridge from Dallam Drive)
AECOM admit that (even at their optimistic figures) this is not feasible.
Therefore I make no further comment at this stage, other than to say there would almost certainly be numerous objections from Dallam Drive.

Option D (Widening of Quarry Lane in conjunction with Option A)
AECOM make no allowance for the significant probability of contaminated land (part of the site was an oil distribution dept – an oil storage tank and fuel delivery pump are clearly visible.
Again, there is no allowance for the proximity of the almost vertically sided railway cutting.

3. HDH Viability Assessment.

The calculations in this document for M683sM-mod are based on 42 units. This is 11 units (an increase of 35%) more than SLDC have proposed up to now!
Also, the calculations are based on the AECOM estimated figures for the necessary highway improvements. As I have shown above, these are very optimistic.
The HDH Viability Assessment for site M683sM-mod is based on erroneous information (cost of highway works, number of units and purchase of private land) and is therefore seriously flawed.

4. Conclusion.

• SLDC have (as at 5th May) not replied to questions I put to them in an email on 1st April (and have sent reminders since) therefore I have possibly been denied the opportunity to make a full and fully reasoned response.
• The existence of the growing evidence base, particularly the Highway Study and the Viability Study has not been made aware to the general public. Indeed the email from SLDC of 5th April inviting comments strongly steers potential consultees away from these key documents. This is wrong, and is not in the interests of democracy and open government.
• The Highway Study, whilst thorough in its selection of alternative accesses for the Quarry Lane sites is highly optimistic in its costings ad assumptions.
• The Viability Study is largely based on the highly optimistic highway figures. Additionally, it is based on 42 units, 35% more than the 31 units used up to now.
• If this site (M683sM-mod) were to make its way into the adopted plan, it is highly unlikely that it would be taken up. This would not serve the planning process well.

[see attached document]

[see attached document]

Response to revised DPD Main Modification ref MM 050

In general the Land Allocation DPD has excluded development in small rural communities, but has made an exception in the case of Brigsteer (see paras 2.13, 3.150 and 3.151 of the marked-up DPD) despite the many indicators against this site in the Fact Sheet (eg lack of infrastructure, transport links, employment opportunities, etc).

The revised DPD correctly shows that Helsington Parish Council has withdrawn its previous support for this development, but continues to give “degree of community involvement and support” as the reason for making an exception in the case of Brigsteer. This is based on a misconception.

The proposal to develop site RN 213 (land opposite the Wheatsheaf) was made by Helsington Community Land Trust. Prior to May 2012, five of the seven members of Helsington Parish Council were also directors of the Community Land Trust, which is why the Parish Council originally supported the proposal. However, at a well-attended public meeting on 10th April 2012 it was clear that the majority opinion expressed was opposed to the development. The minutes of the Parish Council meeting immediately following the public meeting can be seen at http://www.helsingtonpc.org.uk/Minutes_10_4_2012.pdf which records the votes taken.

31 members of the public voted to oppose the development and 17 or 20 voted in favour, depending on the development timescale. The 17 and 20 votes were largely by the same people, but the Community Land Trust added them together to make it appear that 37 people were in favour and 31 against.

This misrepresentation caused such bad feeling that, at the Parish Council election on 3rd May 2012 three of the Community Land Trust directors on the old Parish Council were voted off, which is why Helsington Parish Council no longer supports the proposal.

I hope the above shows that, far from there being “community involvement and support” for the proposed development, there is in fact considerable local opposition. The revised DPD, as far as Brigsteer site RN 213 is concerned, is therefore still “unsound”.

[see attached document]

[see attached document]

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[see attached document]

My husband and I support the modifications proposed by South Lakeland District Council to work in partnership with Lancaster City Council, the relevant parishes, the Management of the AONB and others to produce a new local plan for the whole of the AONB.

As a joint approach to planning was first talked about some 20+ years ago, in the days of the Joint Parishes Commission, one wonders why it has taken so long to see sense?
Yours Sincerely,
Mr&Mrs J.S. Fisher

Levens Site RN121M-MOD
(Levens Former Poultry Sheds, Brigsteer Road)
Ref: MM014

I submitted a representation dated 13 April 2012 on behalf of North Levens Residents in respect of the above site. The representation argued that the SLDC proposals for the site did not comply with the legal and soundness requirements of the planning legislation and was accompanied by a petition signed by around 80 local residents.

We note that in the Updated Schedule of Main Modifications you propose removing this site allocation. We welcome and support this proposal.

However, we also note that you propose that the Village Development Boundary should incorporate the site and we have the following observations:

1. The Inspector specifically drew public attention to this point during the Hearings last year. It was notable that there was no open statement explaining the reasons why it was proposed to retain the site within the development boundary. No explanation was offered at the hearing.

2. The statement that “part of this site is no longer available” is disingenuous. There is no evidence that it was ever available.

3. The reason now given to retain the site within the development boundary should be clarified and expanded upon. It is asserted that retaining the site within the development boundary “offers the opportunity to bring about significant environmental improvements”. I have previously pointed out (my representation dated 13 April 2012) that SLDC has statutory powers in circumstances where there are derelict buildings and that a failure to exercise such powers should patently not be an accepted reason to encourage development. SLDC is therefore asked to state clearly what environmental improvements it is referring to. An explanation of why it has not exercised statutory powers would also be helpful.

4. We remain concerned about the vague and open implications of this proposal. If it were more specific we may be able to support suitable employment use for the site providing it is limited to Class B1 (without generating any nuisance to local residents) or to housing development if the scale, density and quality is similar and complementary to the existing housing development in the immediate vicinity.

Finally, I would welcome the opportunity to give evidence at the re-convened hearings.

John R Fitch

MM50 Brigsteer
I consider the updated main Modification MM50 is unsound for the following reasons.

Paragraph 2.13 of the modified DPD states that Brigsteer is the sole exception to the exclusion of small villages and hamlets from the DPD, where development will normally be small scale and related to local needs. Those development criteria apply as much to Brigsteer as any other small village or hamlet and it is unsound to make an exception of Brigsteer.

Paragraph 3.151 and MM50 state that "it is considered that the degree of community imvolvement and support for this proposal and the intention to seek a high proportion of affordable dwellings, justify its inclusion as a land allocation". At the same time, the modification rightly removes the clause "supported by Helsington Parish Council" because Helsington Parish Council has made clear to SLDC that, based on the views of its electors, it does NOT support the allocation. Nor can the Community Land Trust claim that it has consulted or involved the community of Brigsteer when, apart from an initial meeting in December 2010 which was a complete surprise to the community, it has called no meetings to discuss its plans with the residents of Brigsteer or to elicit their opinions and suggestions. The CLT has operated as a private club, whose rules specifically prevent its own members opposing any actions or proposals of its directors.

In an opinion survey completed in 2011 by two thirds of residents on the electoral roll 88% agreed that it would be better to use smaller sites and existing buildings and that affordable housing should be spread across the parish and integrated into the community, not concentrated on a separate site. In other words, as in other small villages and hamlets, development should be small scale and related to local needs.

Therefore, for all those reasons I submit that it is entirely unsound to base the exceptional allocation of land in Brigsteer on a supposed high degree of community involvement and support.

[see attached document]

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[see attached documents]

Sir, we wish to comment on the soundness of the supporting documents that SLDC have published regarding the updated schedule of main modifications to the Local Plan - Land Allocation DPP.
May we respectfully question why these plans do not address any modifications with regard to Grange Over Sands? SLDC still insist that Grange is a key service centre, even though it does not adhere to SLDC own definitions. Grange does not have a secondary school, a permanent police station, it has unsuitable road and public transport links and does not have a direct bus link to the nearest hospital.
We understand that the housing needs for Grange Over Sands is based on questionnaires returned by less than 19% of households and 2001 census figures. Current data needs to be collected before the housing needs of Grange can be taken as 'sound'
We believe that the amended plans regarding road infrastructure is based on flawed evidence. Contrary to SLDC belief, Grange does have a traffic problem especially Main street and Risedale Hill. To carry out a traffic survey, in a tourist town, on a Tuesday Morning in January is like counting the number of Christmas trees sold during the month of August. This survey cannot be classed as 'sound' and used to make the decision that the road structures in Grange can cope with the increase in housing as planned by SLDC. A traffic survey completed in 2008 recorded over 4200 vehicles per day, in either direction at the brow if Risedale Hill. This was in early July, not even during school holidays.
We do not dispute the need for affordable housing in Grange. What we do disagree with is the loss of important green spaces (especially resulting in the linking of Grange, Kents Bank and Allithwaite) when brownfield sites are left undeveloped (contrary to Government guidelines) SLDC will be dictated to by developers whose main concern is profit, not the housing needs of local people.
Sir, we respectfully ask you to take into account our concerns If developed, these last green spaces in Grange will be lost for ever and it will be left to the people of Grange to deal with the aftermath.

Mr & Mrs I Grant

[see attached document]

MM052 MM053 MM054 and other affected areas in Grange and the Cartmel Peninsula.
As I and others (including Grange's Councillor Harvey) have said - Grange and the Cartmel peninsula are accessed in the main by narrow, winding and often hilly roads. The residents of the local villages use Grange as the shopping hub of the area.
My main points are:
1. Due to its layout, the centre of Grange does not appear to offer any chance of road widening to accommodate the extra traffic that would be generated by a large increase in local housing. It is hard to see how the traffic study carried out in January can accurately estimate the traffic effects at a time well into the future when hundreds more houses have been built on the peninsula and many more vehicles, private and commercial are added to the number. The traffic flows both now and in the future have to be seen in the light of the road conditions described above. The direct effects on the environment and residents is far greater than it would be if traffic numbers were simply measured on a dual-carriageway away from the town.
2. The talk in SLDCs document of 'sustainability' and 'environment' ring very hollow when put against the actual experience of those that have offered comments so far. The latest worth noting would be a letter to the May issue of 'Grange-Now' which describes the writer's experience when listening to the SLDC meeting of 26th March where the Land Allocation Plan was discussed. This report if accurate, reflects the experience of others - that this is an arrogant council that has already made up its mind and has no intention of listening to the genuine concerns of residents. Difficulties with its plan are simply brushed away and platitudes (if I hear the word vision once more...) offered in place of any real acknowledgement of flaws in the plan or real engagement with criticism.
The use of words such as 'green gaps' just appear as sophistry when the reality of what is planned is looked at first hand - go and look at the proposed 'Berrybanks' development in relation to Allithwaite and Grange. Also view the proposed site of the industrial units. Is Kents Bank really a suitable place for these proposals? The existing industrial units between Lindale and Grange work because they are close to the dual carriageway and screened from residents. It is a matter of appropriateness.
3. Few people deny that housing stocks have to be added to and renewed and that forward planning is a good idea. Berners is an example where most support the idea of extra housing and renewal and updating of public facilities. However in those areas where housing cannot be built in large numbers without seriously damaging the environment and quality of life of the residents then it should not take place. Simply hoping for the best and ignoring evidence that challenges your plan is not good enough. It may well be that by the time Grange and the surrounding area are suffering the adverse effects of this plan those responsible will have moved on or retired. The rest of us will have to live with the consequences of their decisions.

Dear Sir or Madam

We are writing to object to SLDC’s Land Allocation Development Plan Document.
According to the plan Grange-over-Sands is expected to have hundreds of new houses built, mostly to the south of the town. The basis for this huge development is the designation of Grange as a “Key Service Area” for the surrounding villages. Our objections are:

- Grange does not qualify as a “Key Service Area”. It is not a centre of employment and does not have a secondary school. Grange is little more than a tourist and retirement village. The vast majority of the working population travel to Kendal, Ulverston, Barrow and Lancaster to work. More houses will mean even more people commuting from the town to these centres.

- The town already has traffic congestion at busy times. Main Street is steep, narrow and the only route through the town to the motorway. There are frequent deliveries to the shops on Main Street, meaning that there is often only one lane for the 2-way traffic. More houses will lead to unacceptable congestion.

- We live on Kents Bank Road on the way out of town to Allithwaite. The road past our house is already very busy in the morning and evening rush hours. There is no pavement on our side of the road and the one on the opposite side of the road is very narrow. Cars frequently pass our driveway at excess of the speed limit, which can be quite frightening when leaving the drive. Additional traffic on this road will make life for residents and pedestrians even more difficult.

The only solution to the inevitable and unacceptable traffic congestion to which your plans will lead would be a new road from Allithwaite to the A590 via the Vale of Cartmel. There are many other objections which could be made to these plans but we will leave these to other objectors.

Yours faithfully

Michael Green
Anke Green

[see attached document]

[see attached document]

Re: Natland Mill Beck Farm MM031

Feedback on land south of Natland Mill Beck Farm

Please find attached points to consider/requests on this proposed development: -
Requests
• We request that the northern boundary be pushed back – this is currently too near various properties in Mill Beck yard – one of which is grade two listed – and also cottages on the lane.
• We request that the green space screening between the development shown on the plans is a solid wall, and banking screened with trees. The wall should be at such a height that would deter access onto Natland Mill Beck Lane by pedestrians not wishing to use other routes to access the canal path into Kendal.
• We request that should the development go-ahead that Lakeland slate be used for the roofing of the houses. This is fully in keeping with the properties on Natland Mill Beck Lane and the Mill yard.
• We request a designated cycle path to Natland and into Kendal – the road to Natland from Kendal is too narrow for current use and many near misses have happened. With the proposed 78 houses this will undoubtedly bring many families into the area and a proper cycle route should be invested in.


• Please could you email us a plan to show the actual height of proposed houses and also one to show the actual positions of houses. We have studied the draft proposals available at the leisure centre.
Considerations
• There are bats on the lane and around the farm. As bats and their roosts are protected by law planners have to do feasibility studies and consider various factors such as provision of roosting opportunities, the availability of foraging/commuting habitat and appropriate management.
• There are owls and woodpeckers in the trees which need to be considered.
• Light pollution will occur with the proposed development.
As a keen astronomer the glow of street lights and extra house lighting will spoil the night sky for me and many others on the lane.
• Natland Mill Beck Lane is full of character properties – part of ours (Stable Cottage) dates back to the 18th century. It is important that this historic area should not be destroyed by a modern housing development being so close.
• There is currently a walk to school policy in Kendal and the development is not in walking distance of any primary or secondary school. We understand that a donation would be made to Natland primary school to extend the school but no mention of secondary school education has been made.
• Traffic turning right along Natland Road will come to parked cars once entering Kendal. There are cars parked on the left of the road and at times this part becomes one way and is a hazard to cars travelling towards Natland due to a blind spot on the brow of the hill leaving Kendal. The extra houses will cause more traffic on this road and potentially vehicles wishing to go to Asda or the hospital will use Rinkfield as a rat run. This junction is already busy and possibly a mini roundabout needs to be thought about?

I wish to object to the updated proposed LADPD as it relates to the Cartmel peninsular in general, and Grange-over-Sands in particular.
1. To base the impact of traffic increase in Grange on a study carried out in January between the hours of 8am to 9am and 5pm to 6pm is ridiculous! Tourists and tourist related business traffic fill the town during the tourist season - from about April to October, generally between the hours of 9am and 5pm!
2. Is there really a housing need in Grange? Is Grange really a Key Service Area? I personnaly do not think so. You only need to observe the number of 'For Sale' and 'For Rent' signs to give the answer. In any case surely any housing developements should be on 'Brown Field' sites first (such as Berners), and not on 'Green Fields'.
SLDC appear to be justifying the housing need on 18.7% of returned questionairres. But SLDC are supposed to serve the whole community! Some effort must be made to get the views of the silent 81.3%.
3. We appear to be getting more frequent rainstorms and experts tell us that things will get worse in future. When we get heavy rain in Grange we get flooding. In particular Methven Road and Kents Bank road become rivers; clearly the drainage system is not adequate today let alone in the future.
Part of the problem is run-off from domestic properties built in recent years. I suggest it would make sense to improve the drainage system (and other infrastructure elements such as gas, electricity, schools etc) before building more properties.
In conclusion, most people I talk to in Grange think the amended LADPD is flawed and based on faulty or non-existant evidence. I strongly support GADAG,s opposition to it and beleive most Grange residents do as well.

[see attached document]

[see attached document]

Dear Mr Berkeley
South Lakeland Land Allocation Development Plan
R121M – Land off Castle Green Lane Kendal
I am writing again regarding my objections to the continued inclusion of this parcel of land in the council’s development plan.
Despite previous concerns leading to the rejection of this site in 1997 for residential development SLDC appears to be blind to the potential issues that may occur if developed and have still to provide a fully costed feasibility study.
The latest reviews by CCC and AECOM based on a desktop exercise and dubious site photographs which appear to have been taken with a wide angle lens (to give a false impression?) have again failed to highlight the problems which increased traffic along Oak Tree Road and Rowan Tree Crescent will cause.
The access onto Castle Green Lane from Oak Tree road is on a steep hill with a blind corner a few meters from the junction. Conditions in winter are treacherous and an increased volume of traffic will almost inevitably lead to an increase in accidents
The road narrows considerably after the junction shown in one of the photographs on both Oak Tree road and Rowan Tree Crescent. Many residents have to park on the pavement to allow through access for other traffic.
The cul-de-sac at the end of Oak Tree road will require a 180 degree loop through R56 & R141 to gain access to R121M.
The number of volume of additional vehicles generated by an additional 60 house will increase the existing problems with parking, movement and waiting time to join the A684.
These objections should not be taken in isolation as they will also impact seriously on drainage, flooding, pollution, bio-diversity including the colony of great crested newts. It is already know that they are colonising a larger area moving from R677K across R56 and into the gardens on Rowan Tree Crescent and Oak Tree road.
Thank you for taking the time to read this letter which I hope will be taken into consideration when deciding on the development of R121M
Yours sincerely

Harry Howson

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Ref. RN57-Mod

I have read the comments in the modifications document made by Cumbria County Council.
I wish to draw your attention to matters relating to the access road (St Anthonys Hill) not addressed by CCC.
When leaving the main road (A6) to access the estate, after approx.15 mtrs there is a sharp left hand bend. It is not possible to see oncoming traffic until nearly at the bend which is not wide enough for two vehicles to pass without mounting the already narrow pavement..
The next section of the access road is on many occasions especially at weekends and in the evenings reduced to a single lane due to residents parking on the side of the road opposite the pavement. This causes passing vehicles to mount the pavement.
The next bend is a right hand blind bend where accidents have already occurred, this is followed by the only straight section of road adjacent to the proposed development with clear vision for drivers. It is regrettable that the two photographs published in the report only show this section of road A clearer picture would have been given if photographs had been published of the problem sections of the road.
To access the A6 it is necessary to position a vehicle partly on to the A6 in order to get a clear view of oncoming traffic, this is particularly necessary when checking for traffic travelling South, Approaching vehicles can clearly be seen moving to the centre of the road to avoid traffic waiting to access the A6
When planning permission was granted for St Anthonys Hill approx. 25 years ago the volume of traffic was considerably less on the estate and on the A6.

Yours faithfully
Margaret Kelly

[see attached document]

SLDC Local Development Framework Land Allocation DPD

Response to the April 2013 consultation from Kevin Lasbury CBE CEng FCIHT

I note your restriction that comments on this latest consultation must only relate to the published updated Schedule of Main Modifications. That constraint is unacceptable as it attempts to deny the public the opportunity to comment on the raft of documents that supposedly support the Council’s current position.

For various reasons, I have only been able to skim the contents of this latest vast volume of material. I do however have the following comments/observations/objections which may or may not be comprehensive and may or may not be added to when I appear at the Hearing whenever it is reconvened.

Main Modifications

From the Table of updated proposed Main Modifications I have the following comments:

MM001. It remains wrong, and thus entirely unsound to exclude allocation of land within Canal Head from this document and to use a specific Local Plan to deal with such an extensive, and potentially intensive, development in the heart of the town. Canal Head will/would generate traffic volumes which would have a dramatic impact on the infrastructure of the whole of Kendal. This is being ignored in the documents purporting to support the Land Allocation Document (CCC Traffic Study etc). But, last year an Inspector felt able to reject an application for a site on Shap Road because of potential conflict with one possible element within Canal Head, which, even now has no formal status in public.

MM002. This policy states “...proposals can be approved...secure development that improves the economic, social and environmental conditions in South Lakeland”. The evidence being used by the Council in support of the Document, when assessed in detail, actually demonstrates that the impact of the proposals for Kendal fail to achieve this policy. The resulting congestion and air quality consequences will have an increasingly adverse effect on the economic viability of, and the environment within, Kendal.

MM024. This modification appears to bring forward the Land Allocation in site R170M, Land north of Laurel Gardens, when elsewhere within the documents are references to a later timescale to allow United Utilities to upgrade their waste water infrastructure.

MM028. Brief for land north of Laurel Gardens. This modification (together with MM024 above) suggests an unhealthy drive to speed development of this site in contravention of all supporting evidence on the capacity of the waste water infrastructure and the uncertainties surrounding the delivery of enhanced capacity. Hardly a month goes by that United Utilities are not on site dealing with problems associated with the outfall from the Briery Meadows development into the sewage system. It is obvious that any further development affecting this part of the network cannot go forward until after this capacity constraint has been physically resolved. Another example of the unsoundness of the Council’s approach to this site.
Having seen in MM034 reference to the importance of visual impact on Route 6 of the National Cycle Route in Natland Road, it is clearly an omission in respect of this site which will also have a potentially adverse impact on this route – Burneside Road forms part of Route 6 also.
My comments in respect of MM028 do not indicate an acceptance of the suitability of this site. I maintain my position that safe access cannot be achieved to this site.

OTHER COMMENTS
I believe that it is appropriate to comment on the supporting documents published in the last few weeks despite the constraints imposed within this latest consultation.

Draft Infrastructure Delivery Plan.

What a disappointing document this is. It does nothing to convince me that any in depth thought has been given since the Hearing was suspended in November 2012. No doubt, due to the volume of material produced, a lot of work has been undertaken but it has produced nothing of any substance.
However, the following illustrate without any doubt that the entire plan in respect of Kendal is undeliverable and thus totally unsound.

Kendal Highway Infrastructure. The proposals here do not vary from those considered in November. After meeting with CCC and SLDC at the Inspector’s request in November, I prepared a comprehensive paper which fully demonstrates the inadequacy of the highway proposals to cater for the development proposed and challenges much of the assessment methodology. This paper was forwarded to the Programme Officer on 19th November 2012 and I intend presenting it to the resumed Hearing.
I am astounded that his latest document states categorically that the Allocations DPD is not reliant on the Kendal Northern Development Route being delivered. This mischievously ignores the huge development proposed within the centre of Kendal and the impact the Canal Head will have on the entire urban area. Doing so has to be entirely unsound and illogical planning practice. In doing so, you totally ignore the conclusions of the County Council traffic assessments .
The comprehensive package of “sustainable traffic improvements” is insufficient, to deliver the significant reduction in vehicular movements assumed within the CCC Traffic Improvement Report. The County Council themselves acknowledge that this figure is taken from a literature review. Additionally, experience, on a daily basis, of the performance of the “sustainable infrastructure” in place within the town now, shows how inadequate they are to encourage modal shift. For example, Pelican crossing response times to pedestrian demand are exceptionally long. And the components of the crossings designed to ensure efficient operation of these crossings invariably fail to work.

United Utilities. There are severe capacity constraints within the United Utilities network, not least the foul sewer system in North Kendal. There is no guarantee that UU can deliver the enhancement needed. The only certainty they have given is that they will bid for the funds in competition with all other demands and pressures across the entire North West. A Plan based on such a position cannot have any degree of confidence.

Schools in Kendal. The report is contradictory in that it states in several locations that one or two new primary schools will be needed in Kendal at a cost of somewhere between £2 and 3 million (Table 25) and yet in para 2.170 the document states “there is no need to allocate land to accommodate additional new school provision”.

Hospitals. Para 2.234 only partially, and somewhat inaccurately, describes the hospital shortfall in the area and contains no indication of the ability of those hospitals to accommodate the consequences of the additional development. Everyone living within the area is fully aware of, and concerned about, the limited access to primary health provision here now. The lack of formal confirmation of additional capacity within the Plan timescale again confirms that it is unsound.

Section 106 Contributions/Community Infrastructure Levy. Many vague comments are made about funding the infrastructure needed through these mechanisms. The County Council state they have no funds for capital highway works; the County Council needs £££s for additional educational facilities; and there are many other areas where such funding could be needed. I have raised several times the question about the scale of financial demands on each potential development, including, of course, the need to fund a significant affordable house percentage. I suspect those demands will far exceed the figure (£1500) used by the consultant within the Viability Study. If that is the case, then the viability of many more development sites must be in doubt.
Recent evidence from a planning application in Kendal, which has been referred to Appeal, fully supports this contention.
Two alternatives result:- Either the developments are not viable because of the financial demands, which means they do not proceed;
Or, in order to secure the development, the Council compromises on its demands. This, either does not achieve the affordable house component driving this whole exercise, or does not secure the appropriate contribution to the infrastructure consequences of the development.
Both of which result in yet further reasons why the entire proposals in respect of Kendal are UNSOUND.

Highways Study Main Evidence Report produced by Aecom

I do not accept the consultant’s interpretation of the application of the two Standards used for ensuring safe access to development sites – Manual for Streets and Design Manual for Roads and Bridges.
The definition of the highways to which the two Manuals apply is clearly defined in para 2.2.1 of Manual of Streets – “A clear distinction can be drawn between streets and roads. Roads are essentially highways whose main function is accommodating the movement of motor traffic. Streets are typically lined with buildings and public spaces, and while movement is still a key function, there are several others, of which the place function is the most important”
The consultant’s interpretation clearly diverges from this clear and precise definition and thus casts considerable doubt over the reliability of the entire document.
I will go further in a paper on this at the resumed hearing (originally drafted for the resumed November Hearing and forwarded to the Programme Officer on 19th November 2012)

Site R170M
I have always maintained that access from Burneside Road cannot be achieved safely in accordance with highway design standards. I notice that CCC have proposed tinkering with highway channel alignments, narrowing the carriageway, introducing traffic calming on Burneside Road and the consultant suggests extending the 30 mph limit throughout the rural section to Burnside.
However the conclusion within the Report that this access can be safely achieved is wrongly founded and does not consider the proposed access in context of the route as a whole (which incidentally is part of the National Cycle Network).
The proposal to introduce a secondary access into Briarigg is unacceptable, even if restricted to emergency use. It would remove an invaluable formal play area for the local children. Any access through this site could not be policed and would inevitably be abused. The highway layout within the Briery Meadows estate, and the junction between Briarigg and Burneside Road are not suitable for additional traffic. Such a secondary access is not mentioned in Main Modification 028.
I maintain my position that R170M should be removed from the Land Allocation on the grounds that safe access cannot be achieved.

K A Lasbury CBE CEng FCIHT
21 April 2013

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LAPD MM052 R89
We fully support all the points raised by Allithwait Road Action Group in their objections to
proposed developement on the above land(R89).
The rock head is very near the surface on this land and would be very difficult to drain, soak-aways or holding tanks would not be successful or even possible.The land frequently floods after heavy prolonged rain in the South East corner and runs into Carter Road and Kentsford Road, developing this land would increase the run off considerably and cause problems with neighbouring
properties.
In our view retention of the open area is particularly important to ensure the break in developement between Berry Bank and Kents Bank and avoid "ribbon developement".This is a "Green Field" site and should remain so,there are numerous "Brown Field" sites available which should be used first.
Russell Armer`s proposed housing plan`s have detailed the elevation of the buildings,however we cannot understand how they will be able to maintain the elevation because of the close proximity of the rock head to the suface, it would mean a considerable amount of work with Jack Hammers,the noise would be horrendous for weeks on end.There is the danger of this work altering the water course and diverting run off to neighbouring properties.
We feel that with the points Allithwaite Road Action Groups have made and the ones we have made regarding this land(R89) it should be taken out of the plan.
Mr and Mrs Peter and Nancy Mallinson.

Dear sir
Policy LA1.1 and Flookburgh Policies Map
SLDC have not given due consideration to amending the development boundary to enable a small parcel of land at Fieldgate off Allithwaite Road Flookburgh your ref: IE/2012/0236 to be developed to meet a local need.
The role of the Allocations DPD is to identify and allocate sites for development and to carry out a review of development boundaries. I submitted this site for consideration for residential development approx. 2 years ago when SLDC were searching for sites to be included in the Strategic Housing Land Availability Study. The site was below the threshold SLDC set for inclusion in the study so was not considered for a formal allocation due to its small scale. However, dialogue has taken place via telephone and correspondence with SLDC to try and enable development of this small piece of land. I will forward copies of correspondence and a map of the site this representation relates to by post.
SLDC have failed to consider a review of the development boundary using the criteria set out in paragraph 2.2 of the Allocations DPD in relation to this small parcel of land, particularly by applying the third criterion which states “including small infill or rounding off sites” to amend the development boundary. It appears that development boundaries have only been amended to allow the formal allocation of larger sites being proposed by SLDC. This site should be included within the development boundary for Flookburgh to enable a small development to be undertaken to meet a local need.
your faithfully
Mrs Helen Manning

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REVISIONS TO SLDC DEVELOPMENT FRAMEWORK PLAN APRIL 2013
ALLOCATED SITE REF : MM057 Policy 4.26

I note that this proposed allocation now includes ( in the para text only ) the creation of a “ direct pedestrian route “ to the centre of the village from the site. Being itemised in RED one wonders whether this indicates an advance “ PREFERRED ROUTE “ situation ie commitment / agreement of landowners to setting aside land for such a purpose ? Is one correct in assuming that this proposal has the full backing of Lower Allithwaite Parish Council ? Not clear.

An advance planning brief connected to this particular site may or may not exist but certainly of utmost importance to it would be published data related to B5277. Existing traffic flow / speeding traffic, commercial traffic of 5+ axle vehicles / turning movements / type of traffic using the Narrows as well as X roads at Locka Lane & Wraysholme Lane junction are all pertinent to the suitability / support for this site development in the future.

Without such information it is difficult to give a considered opinion & I, therefore, do NOT support this proposal.


May I suggest that in any future discussion about this allocated site the following must be established in advance of development :

Traffic Management :

1. Investigate the feasibility of establishing LOCKA LANE Lane as a “ green corridor “ . Examples of how these work successfully exist in the RIbble Valley where access is for pedestrians / property access only. This lane will become more urban in appearance otherwise & a the enjoyment of a pleasant walk for both residents & visitors to the area, could be somewhat diminished without a sympathetic approach to design.

2. Examine the existing use / traffic flow on LOCKA LANE as well as the turning movements as it currently attracts both private & commercial traffic. With a 30mph speed limit, local drivers do use it as a cut through & alternative route to B5277. Additional turning traffic from a site of up to 30 dwellings ( high density @ 1.1 ha ) , located at the bottom of its steep hill, would mean “ sight lines “ become more rather than less important at the junction with B5277. Any new layout will have an effect at the junction with B5277 & should, therefore. be part & parcel of advance plans for the Barn Hey site.


Margaret McDonagh ( Mrs )

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I should be grateful if you would forward the attached submission to the Planning Inspector prior to the resumption of his enquiry.
It is not about modifications to the LADP per se but about the Infrastructure Development Plan and the implications for the Cartmel Peninsula.

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In response to MM050, allocation of land at site RN213, Brigsteer, I contend that the Plan is unsound because in general the Land Allocation DPD has excluded development in small rural communities, but has made an exception in the case of Brigsteer, despite the many indicators against this site in the Fact Sheet (e.g. lack of infrastructure, transport links, employment opportunities) and the lack of sustainability criteria for those qualifying for ‘Affordable Housing’ – including the necessity for travel to work, the high cost of heating compared to towns: all of which does not meet, and contradicts, the revised criteria set out in MM002 Par 1.23
Secondly the Plan makes an exception due to the “the degree of community involvement and support for this proposal“– this runs counter to actual events and is tantamount to gerrymandering – a surprise announcement in Dec 2010, a single meeting of the Parish at which the majority expressed many concerns, which have been ignored by a undemocratic and self-appointed group who have been working in secret, as far as the community at large is concerned.

In response to MM050 allocation of land at site RN213 Brigsteer I contend the plan is unsound. The Land Allocation DPD has excluded development in all small communities except Brigsteer, although there are no sustainable criteria for being made an exception. (No transport, shops, school, employment opportunities etc).
Secondly the Plan makes an exception due to “the degree of community support” for this proposal. Nothing could be further from the truth. A small number of people put this proposal through with NO consultation with the rest of the village. They had no meetings to which anybody was invited who were not members of the CLT, and a condition of membership requires that you cannot question the decision of the UNELECTED directors.
I would support very small development of affordable housing on an obvious local need basis but not a development of this scale, which increases the size of the village by almost 10% and would provide even more private housing with a high potential to be bought as second homes.

Dear Sirs
With reference to Land allocation MM004 field ref. R339#.
I would like to make these following points.
Unfortunately we were away and unable to attend the meeting where the decision was taken to remove field ref R69# from it's status of being a site selected for development to not suitable and then to reallocate field R339 to take it's place as viable for development. No information has been furnished to explain this change of choice, our property will be very much affected by this action due to our views being very much obstructed and removed. Our property which is directly alongside field R339# does not have the benefit of a road/lane at the bottom of our property as Wartbarrow Road does to give any separation from the proposed development.
In addition to this our property was built 80 years ago with septic tank services which drain directly into field R339#, a point which we have already advised our local councillor and county councillor.
Being very much aware of these suggested proposals put forward for the development of field R339# as myself SLDC must be aware that changes can be made to such plans and the site could become further away from this proposal to just another housing estate as Templand Park to the Persimmon site Greenfields already in Allithwaiite. Mr & Mrs GK Reddish

The census on traffic carried out on 29/1/13 between 08.00 and 09.00 and 17.00 to 18.00 this is not the time of day that the town of Grange and villages suffer their main problems the day that it was carried out followed the worst day of winter with roads closed and blocked due to heavy snowfall in surrounding areas.
Green Lane at present has suffered from excess surface water this year and upon builing houses on a soakaway files will create even further problems. There is no drainage in Greeen Lane.
GK & ON Reddish

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It appears that the REAL opinions of the residents of Brigsteer are NOT being consider by the Land Allocation DPD. The original proposal was put forward by an unelected Community Land Trust who took it upon themselves to evaluate the need and position (RN213) for affordable homes within Brigsteer. This CLT also had many members within Helsington Parish Council and therefore bulldozed their way through with the proposal on the assumption that THEIR wishes were the wishes of the residents of Brigsteer. The fact that the members of the CLT involved with Helsington Parish Council were unelected at the soonest possibility from the Parish Council speaks volumes for the wishes of the Brigsteer community. The statement that this allocation has "community involvement and support" for this proposal is in fact far from the truth and is totally unsound,infact the proposal is very strongly opposed to by many Brigsteer residents.

Modification MM050 -Brigsteer

It appears that the REAL opinions of the residents of Brigsteer are NOT being consider by the Land Allocation DPD. The original proposal was put forward by an unelected Community Land Trust who took it upon themselves to evaluate the need and position (RN213) for affordable homes within Brigsteer. This CLT also had many members within Helsington Parish Council and therefore bulldozed their way through with the proposal on the assumption that THEIR wishes were the wishes of the residents of Brigsteer. The fact that the members of the CLT involved with Helsington Parish Council were unelected at the soonest possibility from the Parish Council speaks volumes for the wishes of the Brigsteer community. The statement that this allocation has "community involvement and support" for this proposal is in fact far from the truth and is totally unsound,infact the proposal is very strongly opposed to by many Brigsteer residents.

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Dear Sirs,

Re: modification ref MM050

I would like to make known that it is my opinion and the general opinion of the many residents of Brigsteer that I have had chance to discuss the matter with that the development of the land known as plot RN213, in the centre of Brigseer, for housing, whether affordable or not, is not desired. I have not found any evidence of the 'overwhelming support' referred to in the MM050 summary as one of the principal reasons that the development of this plot was not rejected. I also attended the meetings, in the village hall, where there was a great deal of 'ovewhelming' concern that this plot be developed and the consequent effect on village life. It would appear that there has been a misinterpretation of the villagers desire that affordable housing be made available in Brigsteer, but most definitely not on plot RN213.

I would also like to add that no alternative arguments for plot RN213 have been aired that I am aware of, but, as the landowner would appear to have philanthropic intentions, I suggest the plot would be ideally situated for a children's playgound/village recreation facility. Then, when a more acceptable plot is found for the affordable housing project, at least there would be a few more facilities to offer a growing and potentially younger community.

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Response from Allan Steward (on behalf or Levens Residents Group Committee), with reference to the Main Modifications proposed for Levens under ref. MM072, re. site RN121M-mod (Former Poultry Sheds, Brigsteer Road, Levens), and green space at Lane Foot. i.e., to delete proposed allocation of RN121M-Mod for 23 houses. In view of the facts that the mod regarding RN121M-Mod is acceptable to nearby residents &SLDC has not proposed a replacement site in Levens for the 23 houses proposed for RN121M-mod, we support the proposed modification.

We also, in principle, support the proposal to amend the map to show the correct boundaries of the green space at Lane Foot. However, as we are not sure exactly which land is currently not in the area represented on the map as the green space, we add this qualification to our support - that the correction should not make appropriate redevelopment of the disused carpet warehouse (site RN123) unviable, if, for example a small amount of extra space, for use as parking, would make the difference. We see a possibility that the village could be left with a permanent eyesore if access to the site is too restricted, and think that this might be the case if a formal change to, or confirmation of its status, alienates the adjacent space in perpetuity.

We are residents of Kents Bank, Grange-over-Sands, and wish to express our concern about SLDC's proposals for house-building in the Grange area. Your Plan does not address road access problems or the potential increase in flooding at Kents Bank station which we have already experienced several times. We do not believe that the local infrastructure of roads, drainage, schools, health provision, etc. could support the proposed developments. Also, It appears that the impact on local tourism has not been considered. We wish to register our opposition to this Plan and would be grateful to receive your acknowledgement and comments.

Mary and Andrew Stokes

In response to the revised DPD Main Modification ref MM 050.

The electoral parish of Helsington contains about 270 electors of whom 60% live in the settlement of Brigsteer. The would-be developer of site RN 213, the Helsington Community Land Trust, draws its membership from the whole of the electoral parish and also from people working in the parish and relatives of those living in the parish. Most of the HCLT’s support appears to come from outside of Brigsteer.

Before the Helsington parish election in May 2012, it became apparent that five of the sitting seven councillors were directors of the HCLT. This meant that the parish council policy towards the development of site RN 213 was determined by the HCLT board. This became an issue at the 2012 election with the result that only two HCLT directors were elected. Four HCLT directors fought the election, publishing a joint party manifesto which was distributed to electors outside of Brigsteer only. I assume it was not distributed in Brigsteer in an attempt to avoid drawing attention in Brigsteer to their involvement with site RN 213.

Following the HCLT’s loss of control of the Helsington Parish Council, the council has voted against the development of site RN 213.

The DPD does not generally support development in small rural areas, but has made an exception for Brigsteer because of the degree of community involvement and support. The majority of the people of Brigsteer do not support site RN 213 development and neither does the parish council. I have previously submitted on the unsuitability of Brigsteer as a location for affordable housing due to its lack of services and isolation for families deserving of affordable housing that cannot afford to run two cars.

For the above reasons, I consider the SLDC DPD is unsound in relation to site RN213.

I consider the plan for Grange over Sands and district to be unsound for the following reasons:

1. 735 new homes is proportionately too large an increase on the existing number.
2. The increase in traffic would be a major problem to Grange's already congested streets.
3. The character of the area would be greatly impaired due to massive loss of green space.
4. There is an increased flooding risk at Kents Bank Station and Cart Lane railway embankment.
5. The change in local character would have an adverse effect on tourism which is vital to the area.
6. Parking in the area is already very limited.
7. Proper consideration has not been given to other local infrastructure e.g. schools and health provision.
8. The need for new homes has not been adequately demonstrated.
9. The local community does not want such a large development.

Yours faithfully
Howard Turner

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With reference to SLDC’s LADP I have a number of observations and objections:

1) As I live on the Kents Bank Road at a particularly narrow part of the road I am already concerned at the volume of traffic at peak times. While I would welcome a limited number of developments in the area I object to the size and location of the proposed developments on the grounds that the roads to the south of GoS are inadequate. I suggest SLDC consider sites to the north of GoS, as these would obviously be better serviced by roads (A590 and M6).

2) At least one proposed development is within a conservation area (Trickett’s Field), as is my property. SLDC, understandably, places significant control on development in the area: no UPVC windows, traditional stone, cladding and facia materials etc. Any new developments should only be allowed if they meet the same exacting standards.

3) Brown field sites should be developed before any further consideration. It is highly undesirable to develop green field sites for a number of reasons: effect on wildlife, coalescence of development, effect on drainage.

4) I understand the LADP for GoS area is based upon GoS being a ‘Key Service Area’. I only wish this was the case! This is a complete nonsense for there is: no petrol station, no public swimming pool, no public gym, limited playing fields, no secondary school, no cable/fibre Internet, no major supermarket, no (as of yet) health centre, no A road serving it, limited bus and train transport and no hospital. It will soon have no police station.

5) Tourism provides a major source of prosperity to the GoS area. As a provider of holiday let accommodation I am concerned at the impact the LADP will have on tourism. Clearly some growth in the area together with provision of some of the key service functions listed above could well improve things. However, if housing development is carried out in the numbers proposed, all to the south of GoS and with no planned service area development, this is likely be to the detriment of the tourist industry.
Yours sincerely
Mr W.R.A.Wakefield

MM007, MM008, MM015, MM051,MM052, MM053.
The proposals under land allocations in respect of Grange over Sands and area, run counter to the objectives stated in the core strategy: Grange is an Edwardian town its character being central to its tourist industry, this, local traders and residents will be disadvantaged under the proposals.

The area does not have the infrastructure to support the development proposed. Under the plans Grange will lose its remaining green areas – I understand that a number of these have already been sold for development, while small pockets of brownfield land are ignored.

I would point to the 2007 regeneration plan that proposed a balanced and holistic development for the town – and provision of affordable homes. A plan which better meets the Core Strategy than the current proposals.

I would also like to draw the councils attention to the example of Hornby council, who are making small developments of 10 houses to be sold on a shared ownership basis to locals.

More specifically:

Sustainability considerations - Grange is not a key service centre as it does not meet the definition of such in the core strategy - public transport links are poor, both to other towns/villages and within the town itself
- walking and cycle links from the proposed developments dangerous for pedestrians particularly those with young children.
'Heritage considerations -the erosion of green land will have a significant impact on our natural habitat and local species. Much of the development planned is on land currently used for agriculture I do not believe that the destruction of our green spaces can ever be 'organic and sympathetic' to the town. Our green spaces are in fact a key feature of our town and are vital for the wellbeing of residents and the tourist industry.
'Landscape and Settlement, Community Infrastructure, Other demands: the developments proposed will siginificantly increase traffic in the local area. The road networks in the area were not designed for the current level of car use. Grange, Allithwaite, Flookburgh and onward rely on the B5277; a road incapable of absorbing the additional traffic that would result. Some local bottlenecks and access routes to the proposed sites eg Risedale Hill on Allithwaite Road,junction Cart Lane/Cartmel Road and Kents Bank Road are already dangerous. Flooding remains a problem throughout the area, despite the holding tanks installed by United Utilities.

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Dear Sir/Madam,
In response to Proposed amendments to SLDC’s
Land Allocation Development Plan Document (LADPD)

I note from SLDC ‘s Framework Land Allocations Development Plan Document, fact file the following statement,

The attractiveness of the area and proximity to major towns has resulted in pressures to expand the historic villages; this may continue in order to support housing and economic growth. Ensure new developments respect the scale, traditional form and materials of villages and do not infill important open spaces such as orchards and gardens integral to their character. Enhance settlements through sensitive environmental improvements to village greens, ponds, lakes and other features.

It seems SLDC is set to destroy the attractiveness of the area with a stretch of urban sprawl likely to take away important requirements wildlife around us. Development of any kind has far reaching demands, Grange over Sands will not be able to cope without even more development to help it do so.

What about a plan to build another B road through the Cartmel valley and relieve some of the
traffic build up through the centre of Grange? create a proper urban area.

Better public transport is of great importance in an urban area.

A secondary school will probably be needed in an urban area.

This area at present can be described as rural in another 25 years the balance between urban and
rural will have vanished, we need to preserve as much as possible now, instead of constantly changing the rules and allowing developers to get away as much as they can. I hope SLDC are
looking carefully at those areas likely to flood from run-off as more land becomes covered.

But never mind builders rule the country we have to accept this.

Yours faithfully,
B.White
Beverley White

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Mr Dan Hudson
Development Plans Manager
South Lakeland District Council
South Lakeland House
Lowther Street
Kendal, LA9 4DL 5th May 2013

Dear Mr Hudson

Consultation on the updated Schedule of Proposed Main Modifications to the Local Plan Land Allocations DPD


We support the proposal by South Lakeland District Council to work in partnership with Lancaster City Council, the relevant Parishes, the management of The Arnside & Silverdale Area of Outstanding Natural Beauty, and others to produce a new Local Plan for the AONB.
It was reassuring to note the latest revision of the plans provides a blank canvas that will enable the inherent natural beauty of the area to be preserved as a prime priority. This approach has our total support.
Such affordable housing as may be realistically justified needs to be introduced in small sites of two or three dwellings where the incumbents can be given the opportunity to integrate naturally into the village rather than be segregated into larger developments.
In order that the views and needs of all the interested parties can be equally assimilated it is important that the Chairmanship of this new body is freed from political bias and possible council aspiration of increased revenue.
Furthermore we commend to your attention and support the work of Arnside Parish Plant Trust or Arnside Parish Council to whom we remain indebted for their hard work and positive objectivity to the key essentials which will ensure this haven of tranquility is preserved for future generations of tourists and residents alike.

G H and S Wright.

Proposed modification for site RN 79 Jack Hill Allithwaite

I refer to our discussions regarding the above. As landowner of this site I want to confirm that the enlarged area shown in the document currently with the Independent Planning Inspector is not acceptable as far as I am concerned.

Firstly if implemented this would take away my field access at the top of Holme Lane which I don't want to lose or move.

Secondly I am not looking to implement a development of 28 properties on this site as I feel that this would be excessive for this location. From the outset I stated that i would only want a development here that would be in keeping with the village and intend this to happen if this proceeds.

regards
Mike Jackson

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Main Modification Reference number - MM041

Consultation on the updated Schedule of Proposed Main Modifications to the Local Plan Land Allocations DPD

Arnside Parish Plant Trust notes the Main Modifications proposed by South Lakeland District Council to work in partnership with Lancaster City Council, the relevant Parishes, the management of The Arnside & Silverdale Area of Outstanding Natural Beauty, and others to produce a new Local Plan for the AONB.
We also note that this will apply appropriate policies in this area specifically intended to get the correct balance between protection of its special landscape and other local needs such as housing provision and other amenities.
We believe that this will produce a much better plan than SLDC’s previous version and therefore are in enthusiastic support of this new proposal. We look forward to hearing how we can support this process in practice.

Pete McSweeney
Chairman
Arnside Parish Plan Trust

Consultation on the updated Schedule of proposed Main Modifications to the Local Plan Land Allocations DPD

Main Modification reference MM041

Arnside Village Society notes the Main Modifications proposed by South Lakeland District Council – i.e. to work in partnership with the Management of Arnside & Silverdale A O N B, Lancaster City Council, the parishes within the A O N B and others, to produce a new Local Plan for the for the entire A O N B.
We note that this will produce policies appropriate for the A O N B, to ensure the correct balance between the landscape, and housing and other needs, within the area.
We believe that this will provide a much improved plan for this area, and the Village Society is pleased to support these new proposals.
Christine Marland
Chairperson, Arnside Village Society

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MM030. Policy LA2.5 – Land West of Oxenholme Road


1. These representations relate to the introduction of a detailed requirement by MM030 relating to the treatment of areas adjoining an un-named tributary of the Natland Beck watercourse within the allocated housing site. MM030 introduces an explicit requirement for a landscape buffer zone and habitat of 10 metres around the watercourse

2. These representations request that the explicit reference to a 10 metre buffer zone is deleted, on the basis that such a requirement is overly precautionary at this location, and is unnecessarily prescriptive within a Local Plan document.

3. Our client, Oakmere Homes (North West) Limited, is the developer who is promoting residential development of the allocation West of Oxenholme Road through an outline planning application.

4. In the context of that outline planning application our client has commissioned specific ecology/biodiversity advice from Wardell Armstrong (“WA”). WA considers that the River Kent SAC and this tributary could be safeguarded and other landscape and biodiversity benefits could be achieved at this location with reduced landscape and wildlife corridor width. In the context of the outline planning application WA proposed to incorporate an undeveloped landscape and wildlife corridor adjacent to both banks of the tributary of 8m width on one bank to provide necessary maintenance access required by the Environment Agency and a minimum width of 4m to 6m on the opposite bank – this would be subject to a design to be agreed with the Environment Agency and Natural England through development management.

5. WA have considered relevant literature and research and have based their suggestions on site specific circumstances. WA’s experience is “that the success, or otherwise, of landscape and wildlife corridors in a residential context can turn on the quality of design and long term management of the habitat”. A policy requirement to secure and deliver a good quality and effective landscape and wildlife corridor is more important than what is effectively an arbitrary corridor width of 10m.

6. The detailed assessment undertaken by WA to inform their view is based on:

- The low risk to water quality posed by residential development in comparison to (current/historic) agricultural use of herbicides, pesticides and approaching livestock;

- The lack of clear evidence base to justify a 10m buffer zone in a residential context;

- The small size of the watercourse (i.e. the corridor should be proportionate to the size of the watercourse);

- The ability to access both sides of the watercourse from one bank for maintenance purposes (therefore an 8m corridor only need to provided on one bank);

- The ability to provide a high quality functioning landscape and habitat corridor at a width less than 10m.

7. Both the Environment Agency and Natural England have accepted that a functioning landscape and habitat corridor can be achieved at a width less than 10m.

8. The precise detail and ultimate agreed width for any landscape and wildlife corridor is a matter for development management. In our view the explicit 10m width contained in MM303 is not justified or effective and does not represent positive planning. It is inappropriate for the Land Allocations DPD to seek to pre-judge and specify a width at this stage.

9. We respectfully request that the explicit reference to a 10m width buffer be deleted.

10. We note also that Policy LA2.5 continues to make reference to “measures to mitigate impacts on Great Crested Newts”. As far as we are aware there is no evidence to suggest that Great Crested Newts are present at the Oxenholme Road allocation and we would, therefore, question the relevance of this particular element of text.

RE: R89 BERRY BANK FIELD, GRANGE OVER SANDS

In your report on the above it would appear that you are of a mind to allow development on R89 to be included on the SLDC Development Framework DPD.

In 2001 planning application was refused for development, and the report from SLDC stated that this land, R89, should NEVER be built upon because of the access to it.
The only thing that has changed since then is the volume of traffic on Allithwaite Road which is far heavier than it was 12 years ago!
We have lived at Cardrona Court for 10 years and now have difficulty in accessing Allithwaite Road from the driveway in safety.

I am writing on behalf of 17 residents who live at Cardrona Court and are very concerned.

Susan Jackson, Director/Chairman
Cardrona Court Management Compnay Ltd

Response from the concerned residents of Swarthmoor and Cross-a-Moor
(RN109) regarding the SLDC Land Allocations DPD dated 5th >April 2013

Having read through the amended document it is clear that there have
been some minor changes with regard to the Swarthmoor and Cross a Moor
area in response to the public consultation event. However, as
concerned residents we would like to raise the following points -



Ref LA1.0 The term 'presumption in favour of development with the Local
Plan' is a term which requires further clarification. Does this term
mean that once the local plan has been approved the developments will
go ahead regardless of concern raised by the community? The area RN109
is barely referred to in the amended document, whereas other areas are
identified in detail. Does this mean that there is no change to the
plans of the SLDC, and that planning consent will be given regardless
of the issues raised during the public consultation? We would like
reassurance that there will be a full consultation exercise as stated,
and that the technical use of language is not a 'smoke screen'.

Ref MM007 The information contained in this section underpins the
concerns raised by many RN109 residents, significantly -

- the ease of accessing the site,

- the impact of topography and relief and the scope to meet identified
needs,

- Local and wider Community views including those expressed through
Community engagement and through Parish Plans and the Sustainable
>Community Strategy; Sustainability considerations including the
distance to key services, - the risks of flooding and contamination, -
Landscape and Settlement considerations including the potential impact
of development on landscape and views, the scale of development
relative to the settlement size, whether the site preserves the
separate identity of settlements (Swarthmoor and Cross a Moor are
separate settlements, the fact that house building has taken place on
one side of the village should not set precedence) and the impact of
development on site features such as trees, watercourses and buildings;
- Community Infrastructure including impacts on the local highways,
water, sewerage and energy networks, the delivery of future
infrastructure needs, impacts on Green Infrastructure and local
community infrastructure needs and the potential regeneration benefits
of development;

Ref MM0214 We welcome the statement that a Development Brief will be
prepared in consultation with the community before moving forward with
any plans for Cross-a-Moor and Swarthmoor, which, we must reinforce,
are separate communities (please see comment above). However, the
'presumption in favour of development' statement must be clarified.
What are the member of the community to be consulted on if there is a
presumption in favour of development?



Those who have acted as key contacts for the community during the
consultation exercise would like to be kept informed of developments as
much as is possible, and are willing to set up meetings (book venues,
publicise meetings, invite members of the communities and local
councillors etc) in order to ensure that as much information is
available as possible so that all members of both communities feel they
have been listened to in a democratic way.



We welcome the seriousness with which the SLDC planning team members
are taking this process. To quote George Osborne "houses have to be
built in the right places for the right reasons". The concerns detailed
and submitted during the public consultation remain our main priority.
We do not want to create a High and Low Swarthmoor as was created in
High and Low Newton. We do not want to have to petition for a bypass in
years to come to address the road safety fears further house building
will impact on - with further agricultural land being required to build
such a bypass. We strongly believe there are more appropriate sites for
house building which will not remove high quality grazing agricultural
land from the local infrastructure.



We want decisions to be taken by local councillors and members of the
community - those who will be directly affected by any development
plans, and not by those who see this as an exercise to 'square off'
>the village.
Lorraine Thompson, on behalf of the concerned residents of Cross a Moor
and Swarthmoor

[see attached document]

Proposed Main Modifications
Ref: MM010. Page: 23. Policy/para/table: POLICY LA1.3

I would like to confirm Cumbria County Council’s (CCC) support as Lead Local Flood Authority for the removal of Kendal, Acre Moss Garages (0.35 acres) from the housing allocations due to flood risk of the site.

CCC’s Local Flood Risk Management Team (LFRM) supported by the Making Space for Water Group (made up of representatives from Environment Agency, United Utilities, South Lakeland District Council and CCC’s Highways and LFRM teams) are currently working to reduce the flood risk to properties in Low Garth, Kendal. I have enclosed a copy of the report for your information but please note that this is at draft stage.

Dear Sir

Consultation on the Updated Proposed Schedule of Main Modifications to the Local Plan - Land Allocations Development Plan Document - Representations by Electricity North West Ltd

We write on behalf of Electricity North West Ltd (ENWL) to set out its representations on the Updated Proposed Schedule of Main Modifications to the Local Plan - Land Allocations Development Plan Document.

The stated closing date for receipt of the representations was 6th May 2013. Unfortunately as this was a Bank Holiday it was not possible to lodge them on that date. Nonetheless we trust they will be accepted as having been duly made given that they were lodged first thing today.

I can confirm that ENWL’s interest in the draft DPD stems from ownership of land in Kendal. This includes land in the Canal Head Area and other parts of the borough.

As requested ENWL’s representations concern only the Proposed Schedule of Main Modifications to the Local Plan - Land Allocations Development Plan Document (LADPD).

Where relevant we suggest changes to the proposed text or additional text as necessary.

Representations by ENWL

Ref. MM001 – Minor and Consequential Change to Main (Policy/paragraph 1.6, Page 9)

The proposed main modifications confirm that the draft LADPD local plan will not allocate land within a number of specified areas including Kendal Canal Head Area. This is because these areas will be covered through local plans specific to the areas in question.

The Council progressed work some years ago on a plan for the Canal Head Area, the Canal Head Area Action Plan (CHAAP). Although the plan remains draft as it was never adopted it has since it reached the equivalent of preferred options stage used for development management purposes and related planning decisions.

What is not clear from this part of the draft LADPD is whether it is the Council’s intention to progress the still draft CHAAP in its current form, i.e., this version of the plan will simply be resurrected and progressed to adoption or whether this plan will effectively be abandoned in favour of a new plan which will be drafted in future.

It would be helpful for the purposes of clarity and to assist future planning decisions if this could be confirmed in this section of the plan.

Ref. MM002 – Presumption in Favour of Sustainable Development (Policy/paragraph 1.23, Page 12)

ENWL acknowledges that draft LADPD was prepared before the National Planning Policy Framework (NPPF) was published, and accepts that key principles relating to the need to plan positively to meet identified needs have underpinned the plan making process from the start.

In determining planning applications, the draft LADPD confirms that the Council will apply the principles set out in NPPF regarding the need to be supportive of economic growth and the creation of jobs, high value jobs in particular.

An area where the principles of positive planning will be applied so as to ensure that necessary development takes place, including having regard to the employment benefits of uses which fall outside the employment use classes, and taking a flexible approach to high quality development where it can be shown to be essential to the delivery of employment sites and premises, is enabling development.

ENWL acknowledges that enabling development can have an important role to play in the delivery of employment opportunities particularly where an employment development might be marginal in terms of its value in commercial terms. As a consequence it is keen that this form of development is fully acknowledged in the plan as having the potential to assist in delivering development that might not otherwise proceed because it is not viable. In addition, ENWL sees it to be important that the draft LADPD acknowledges that sites which might offer the potential for enabling development to assist non-viable employment generating developments might be in areas of the borough which are not covered by the draft LADPD plan.

Ref. MM002 – Policy LA1.0 Presumption in Favour of Sustainable Development (Policy/paragraph 1.23, Page 12)

ENWL generally supports this draft policy given that it reflects the presumption in favour of sustainable development set out in NPPF.

Complementing the presumption in favour of sustainable development (as set out in NPPF), the NPPF encourages local planning authorities through their local plans to deliver a wide choice of high quality homes, indeed paragraph 47 of NPPF requires authorities ‘to boost significantly the supply of housing.’

As a consequence ENWL proposes the following changes (emboldened) to the second paragraph of the policy:

‘IT WILL ALWAYS WORK PROACTIVELY WITH APPLICANTS JOINTLY TO FIND
SOLUTIONS WHICH MEAN THAT PROPOSALS CAN BE APPROVED WHEREVER
POSSIBLE, AND TO SECURE DEVELOPMENT THAT BOOSTS SIGNIFCANTLY THE SUPPLY OF HOUSING, IMPROVES THE ECONOMIC, SOCIAL AND ENVIRONMENTAL CONDITIONS IN SOUTH LAKELAND.

Ref. MM009 – Viability Study (Policy/paragraph 2. (27A))

Any requirement for the likes of affordable housing and infrastructure contributions and other requirements to be provided through development should also to take into account whether the development is fully or partially enabling another development for which there is either plan support and/or which the Council wishes to support.

In essence it should be acknowledged in the text that the Council will consider whether it is appropriate to request what would otherwise be the normal full provision of, for example affordable housing, if the development in question falls within the category of enabling development.

Proposed change to this paragraph is as follows:

‘….and, taking account of the normal cost of development and mitigation, and whether the development is ‘enabling’ another development, has ensured that development……….’

I would be grateful if you would acknowledge receipt of these representations and take them into account as the draft LADPD progresses.

Thank you.

Yours faithfully


John Francis

Representation on behalf of Mr R. Crowder in relation to Land at Brigsteer Road, Levens (R682 and RN121M)

MM005
The figures do not match those in the April 2013 tracked changes document.


MM006
The figures do not match those in the April 2013 tracked changes document.

MM010 – MM016
The implications of amendments to housing allocations need to be considered against the overall housing requirement.

Concerns have previously been expressed about the lack of any flexibility and contingency in the housing allocations. The planning authority rely on each and every allocation to deliver the required number of units in the plan period and then contributions from windfalls, broad locations and previously unachieved rates of development in the small villages/hamlets and open countryside.

The planning authority are intent on making only limited provision which is contrary to NPPF’s intention to boost housing supply with a presumption in favour of sustainable development.

The allocations are insufficient to meet housing requirements in every category of settlement including the Local Service Centres.

Land at Brigsteeer Road, Levens should be identified to accommodate 70 dwellings(3.14ha).

Christopher Garner
Garner Planning Associates

Land East of Ullswater Road, Kendal (R124)
Representation on behalf of Estate of Mrs E. McCallum

MMOO4
The development boundary should include land east of Ullswater Road within the settlement boundary.

MMOO9
The Main Modifications state “that development will provide competitive returns to a willing land owner and willing developer to enable the development to be deliverable.” The Viability Study does not demonstrate this to be the case.

The Main Modifications state that the Viability Study demonstrate that “standards and policies will not put implementation of the plan at serious risk.” The Study assumes an unacceptably low competitive return for a land owner, putting housing delivery at risk.


MM010 – MM016
The implications of amendments to housing allocations need to be considered against the overall housing requirement.

Concerns have previously been expressed about the lack of any flexibility and contingency in the housing allocations. The planning authority rely on each and every allocation to deliver the required number of units in the plan period and then contributions from windfalls, broad locations and previously unachieved rates of development in the small villages/hamlets and open countryside.

The planning authority are intent on making only the minimum provision which is contrary to NPPF’s intention to boost housing supply with a presumption in favour of sustainable development.

The allocations are insufficient to meet housing requirements.

Land east of Ullswater Road, Kendal should be identified to accommodate approximately 70 dwellings.

Christopher Garner
Garner Planning Associates

Land west of Queen Elizabeth School, Kirkby Lonsdale (R118).
Representation on behalf of Russell Trust.

MMO04
The settlement boundary should be drawn to include this land within the settlement.

MM009
The Main Modifications state “that development will provide competitive returns to a willing land owner and willing developer to enable the development to be deliverable.” The Viability Study does not demonstrate this. Policy burdens need to be reduced.

The Main Modifications state that the Viability Study demonstrate that “standards and policies will not put implementation of the plan at serious risk.” The Study assumes an unacceptably low competitive return for a land owner, putting housing delivery at risk.

MM010 – MM016
The implications of amendments to housing allocations need to be considered against the overall housing requirement.

Concerns have previously been expressed about the lack of any flexibility and contingency in the housing allocations. The planning authority rely on each and every allocation to deliver the required number of units in the plan period and then contributions from windfalls, broad locations and previously unachieved rates of development in the small villages/hamlets and open countryside.

The planning authority are intent on making only the minimum provision which is contrary to NPPF’s intention to boost housing supply with a presumption in favour of sustainable development.

The allocations are insufficient to meet housing requirements.

Land west of Queen Elizabeth School, Kirkby Lonsdale should be allocated to accommodate 44 dwellings.

Christopher Garner
Garner Planning Associates

Land at Greenside Farm, Hincaster (RN128, EN43 and additional land).
Representation on behalf of Mr and Mrs McHardy.

MM005
The figures do not match those in the April 2013 tracked changes document.

MM006
The figures do not match those in the April 2013 tracked changes document.

MM009
The Main Modifications state “that development will provide competitive returns to a willing land owner and willing developer to enable the development to be deliverable.” The Viability Study does not demonstrate this. There needs to be flexibility in the applicaiton of policy burdens and a commitment by SLDC to this.

The Main Modifications state that the Viability Study demonstrate that “standards and policies will not put implementation of the plan at serious risk.” The Study assumes an unacceptably low competitive return for a land owner, putting housing delivery at risk.

MM010 – MM016
The implications of amendments to housing allocations need to be considered against the overall housing requirement.

Concerns have previously been expressed by the CHBG about the lack of any flexibility and contingency in the housing allocations. The planning authority rely on each and every allocation to deliver the required number of units in the plan period and then contributions from windfalls, broad locations and previously unachieved rates of development in the small villages/hamlets and open countryside.

The planning authority are intent on making only the minimum provision which is contrary to NPPF’s intention to boost housing supply with a presumption in favour of sustainable development.

The allocations to be insufficient to meet housing requirements.

In the remainder of the plan period the authority assume 626 dwelling will be completed in the small villages and hamlets and open countryside (121 dwellings permitted + 7 dwellings identified small sites + 491 windfalls + 7 dwellings allocated at Brigsteer)i.e. 52 per annum.

In the 10 year period of the plan to date 298 dwellings have been completed i.e. 30 dwellings per annum.

The authority are relying on a significant increase in contributions from the small villages and hamlets in the remainder of the plan period.

Land at Greenside Farm, Hincaster should be identified for 18 dwellings to assist in delivering housing in the small villages and hamlets and meeting the districtwide housing requirements.

Christopher Garner
Garner Planning Asscociates

Land between Portree and The Ashes, New Hutton.
Representation on behalf of Mr B. Cox

MM005
The figures do not match those in the April 2013 tracked changes document.

MM006
The figures do not match those in the April 2013 tracked changes document.

MM009
The Main Modifications state “that development will provide competitive returns to a willing land owner and willing developer to enable the development to be deliverable.” The Viability Study does not demonstrate this. There needs to be flexibility in the applicaiton of policy burdens and a commitment by SLDC to this.

The Main Modifications state that the Viability Study demonstrate that “standards and policies will not put implementation of the plan at serious risk.” The Study assumes an unacceptably low competitive return for a land owner, putting housing delivery at risk.

MM010 – MM016
The implications of amendments to housing allocations need to be considered against the overall housing requirement.

Concerns have previously been expressed by the CHBG about the lack of any flexibility and contingency in the housing allocations. The planning authority rely on each and every allocation to deliver the required number of units in the plan period and then contributions from windfalls, broad locations and previously unachieved rates of development in the small villages/hamlets and open countryside.

The planning authority are intent on making only the minimum provision which is contrary to NPPF’s intention to boost housing supply with a presumption in favour of sustainable development.

The allocations are considered to be insufficient to meet housing requirements.

In the remainder of the plan period the authority assume 626 dwelling will be completed in the small villages and hamlets and open countryside (121 dwellings permitted + 7 dwellings identified small sites + 491 windfalls + 7 dwellings allocated at Brigsteer)i.e. 52 per annum.

In the 10 year period of the plan to date 298 dwellings have been completed i.e. 30 dwellings per annum.

NB The 2013Housing Land Position Report's figures vary from the above.

The authority are relying on a significant increase in contributions from the small villages and hamlets in the remainder of the plan period.

Land at New Hutton should be identified to assist in delivering housing in the small villages and hamlets and meeting the districtwide housing requirements.

Christopher Garner
Garner Planning Associates

Representation on behalf of Mr T.Griffiths, Arnside

MM005
The figures do not match those in the April 2013 tracked changes document.

MM006
The figures do not match those in the April 2013 tracked changes document.

MM009
The Main Modifications state “that development will provide competitive returns to a willing land owner and willing developer to enable the development to be deliverable.” The Viability Study does not demonstrate this. There needs to be flexibility in the applicaiton of policy burdens and a commitment by SLDC to this.

The Main Modifications state that the Viability Study demonstrates that “standards and policies will not put implementation of the plan at serious risk.” The Study assumes an unacceptably low competitive return for a land owner, putting housing delivery at risk.


MM041
The suggested gross requirement 216 dwellings 2003-2025 as referred in Table 1A as revised April 2013 should be inserted.

A net requirement of 170 dwellings should be referred to taking into account completions 01/04/03 to 31/03/13 of 46 dwellings.

The reference to 123 dwellings should be removed.

Christopher Garner
Garner Planning Associates

INTRODUCTION

These representations in relation to the Land Allocations Proposed Main Modifications are submitted on behalf of the Cumbria House Builders Group (CHBG)including the following companies:- Applethwaite, Cumbrian Homes, Holbeck Homes, Leck Construction, Oakmere Homes, Russell Armer Homes and Story Homes.

The CHBG control approximately 2250 dwellings allocated for development in the draft Land Allocations document.
MM001

In paragraph 1.6 reference should also be made to the fact that the Land Allocations document does not allocate any land in or on the edge of small villages and hamlets.

MM002
In paragraph 1.23 reference should also be made to the intention of the Local Plan to boost significantly the supply of housing.

MM005
The figures do not match those in the April 2013 draft document.

Footnote 4 – the number of dwellings referred to adds to 2343 but this figure cannot be found on Page 77 of the Core Strategy as suggested.

Footnote 6 – all housing figures should be updated to 31/03/2013 given the 2013 Housing Land Monitoring Report has been issued.
MM006
The figures do not match those in the April 2013 draft document.

MM009
The Main Modifications state “that development will provide competitive returns to a willing land owner and willing developer to enable the development to be deliverable.” The CHBG agree this would be the case if policy burdens are reduced. The plan as drafted is considered to be unsound as housing sites will not come forward based upon the level of competitive return suggested in the Viability Study as acceptable for landowners.

The Main Modifications state that the Viability Study demonstrate that “standards and policies will not put implementation of the plan at serious risk.” The CHBG does not agree. The Study assumes an unacceptably low competitive return for a land owner, putting housing delivery at risk.
The NPPF indicates that Community Infrastructure Levy charges should be worked up and tested alongside the Local Plan where practical (NPPF para 175). This is not SLDC’s approach. Despite an understanding that the Viability Study was something entirely separate from CIL, CHBG members are concerned that the planning authority intend that this Viability Study “will form the basis of the evidence as required by CIL Regulations” (para 2.18). The Study is simply not robust enough to form such a basis.

The Study has been prepared on the basis that the policy burdens must be applied (see paragraph 1.3 and 1.5 of the Study) and it is the land owners’ expectations that must be significantly modified going forward. This is not the approach recommended by the NPPF (see para 173 NPPF). The authority should be reviewing its policy burdens to ensure competitive returns are achievable for land owners and developers to enable development to be delivered. This viability theme is now emphasised by the Growth and Infrastructure Act and the Department of Communities and Local Government’s recently issued guidance Section 106 Affordable Housing Requirements.

The consultation process was undertaken over a short period of time which the Study acknowledges at 2.47 was not ideal. The CHBG consider their views have not been properly represented in the final Viability Study report. The Study makes several references to issues being agreed at specific meetings and consultation events, which is not the case.

On a number of detailed matters the CHBG wish to highlight the following points. This does not mean there are not other points of concern, such as development costs.

1. Methodology

CHBG members are very familiar with residual land valuation and agree that it is appropriate to approach the Study from the basis of understanding what a developer could afford to pay and then set this against what a landowner might consider to be a competitive return. However, the appraisal methodology is not clear. To examine the assumptions one needs to refer to several different pages of information rather than a simple residual appraisal per site. It is not clear that the information from one page has been directly transferred to the other, indeed the basis of some figures such as Build Cost in the summaries cannot be clearly established. Clarification from SLDC is required.

The result is the CHBG are not clear that the residual land values for the modelled sites are representative and have been correctly formulated. Excel spreadsheets were requested several times during the consultation process to seek to understand the approach but these have not been provided. Members consider a higher residual land value may well be achievable on the modelled sites, even with all the policy burdens imposed, but CHBG members cannot confirm the position at this stage.

There was no “universal agreement” (2.38) that it was appropriate to follow the Harman Guidance. CHBG members agree it is a material document as is the RICS guidance Financial Viability in Planning and their own professional opinions.

2. Affordable housing

Core Strategy Policy CS6.3 indicates that the 35% affordable housing rate is subject to a viability test. With this in mind it is not correct to approach affordable housing as a fixed policy burden regardless of the impact on viability (see para 1.3).

The Viability Study refers to the Shinfield appeal. This appeal decision indicates that it was the policy of 40% affordable housing, subject viability, that needed to be adjusted to 2% to ensure competitive returns for the developer and landowner were achievable.

The Study highlights that the authority considers affordable housing to be high priority (10.30) and considers the affordable housing target is not set at the limit of viability. This is not agreed by the CHBG as the limit of viability assumes a very low land value. The Study suggests the planning authority is achieving the delivery of affordable housing at 35% through the development management process, but the schedule provided in Appendix 9 suggests otherwise. Since 2010, when the Core Strategy was adopted, only 3 schemes with over 30% affordable housing have been completed or started. This would suggest the policy burden has not proved viable to date.

3. Developers’ Profit

None of the CHBG members would progress development on a loss making basis as referred to in 2.28. The delivery of housing in South Lakeland, is dependent on private sector small and medium sized, profit focussed, house building companies.

The Study reluctantly accepts that 20% Gross Domestic Value is an adequate competitive return for a developer (7.48). The planning authority rejects overhead costs as a legitimate cost, so therefore the authority’s reference to 20% profit is a net profit rather than a gross profit (10.17). 20% net profit is agreed by the CHBG to be an appropriate competitive return to apply in the Viability Study.

4. Land Values

The Study refers on several occasions to there being no consensus view from the development industry as to the land value a willing land owner would accept. This is not the case. Indeed there was consensus between CHBG and land agents on this point.

CHBG members attended all three consultation events and none can recall any suggestion from delegates that £400,000 per ha would be acceptable to landowners across the District or that Existing Use Values represented a competitive return or that a local land agent suggested £500,000 per ha would be acceptable (the reference here was to per net acre).

The very clear message given at the meeting on 11th March was that as a minimum a landowner would expect would be £500,000 per net developable acre (i.e. £1,235,500 per net developable ha). A reduced value of £1,000,000 per net ha could only apply in the western part of the District i.e. around Ulverston.

The Viability Study indicates that South Lakeland District Council considers “that the case made by representatives of the industry was aspirational rather than realistic.” (10.24) and “out of date” (12.23). The authority firmly rejects the views of developers and landowners on the issue of what a competitive return is for landowners and indicates they “have given little weight to this aspiration” (10.24) whilst accepting some landowners will not make their land available at this level.

The suggestion that some landowners might accept a 5% uplift or £25,000 per ha or five times that figure (6.25) is not considered realistic by the CHBG and this comment simply highlights the significant difference of opinion on this issue. Further the CHBG do not agree that Wrexham “is a relevant reference point” (6.8) for South Lakeland land values.

Developers undertake residual land valuations to determine what they can afford to pay for a site taking into account revenues, costs and a developer’s profit. This does not mean that the residual land value will be a value that will meet a landowner’s aspirations who might have very different views on the value of their land. As the RICS guidance confirms, many landowners do not have to sell or wish to sell at lower land prices and will therefore tend to hold on to their land holdings. (E1.14).

The Viability Study refers to the Shinfield appeal and quotes large parts of the appeal decision, but without appearing to draw any specific conclusions from it. The Inspector concluded that in this instance allowing the landowner a competitive return of 50% of the uplift in value would be acceptable. However this was in the context of the Inspector agreeing that £250,000 per net acre was the existing use value of the site. This approach is not transferable to agricultural land, which forms a significant part of the intended source of development in South Lakeland.

CS1.2 refers to a target of 28% of the housing requirement to be accommodated on previously developed land. So 78% is to be accommodated on greenfield sites. CHBG members do not agree that a competitive return for land owners is related to agricultural land values plus a premium. Land owners expectations will be based upon what they know and understand has been paid for residential land on the open market. The RICS guidance note on this subject firmly rejects the current use value plus premium approach and that a competitive return relates to its potential for development (See Appendix E E1.8 to E1.11).

One can say that if a residual valuation is below existing use value then the value will certainly not be attractive to a land owner. If the residual valuation is above the existing use value it may be attractive to a land owner, but not necessarily. For farmers, the principle of considering existing use values at the outset is not relevant.

Whilst many landowners understand the implications of the housing market and some of the policy burdens, it is the CHBG members’ view that land values, at the level suggested in the Viability Study as a competitive return i.e. existing use value plus 20% plus £250,000 or £400,000 per ha on greenfield sites will result in many landowners not releasing their land for development and therefore new housing being restricted.

CIL may well further suppress residual land values but it will then be for land owners to determine whether or not the suppressed value is attractive enough for them to sell their land for development. In the opinion of the CHBG, the land value viability thresholds suggested by SLDC will put the delivery of housing at risk if applied as a basis for CIL contributions and any individual site viability testing.

Table 10.3 indicates how viability can be improved by reducing affordable housing requirements.

In the CHBG’s view the Land Allocations document will be viable if there is some significant flexibility in the consideration of policy burdens, as envisaged by the Core Strategy affordable housing policy CS6.3 and as is suggested is SLDC’s current practice at 10.31 of the Viability Study (but with little evidence of that actually being the case).

The plan as drafted is considered to be unsound as housing sites will not come forward based upon the level of competitive return suggested in the Viability Study as acceptable for landowners. The plan can be made sound if the Land Allocations document confirms that the planning authority will apply their policy burdens flexibly to ensure competitive returns and the viability of sites.

MM010 – MM016
The implications of amendments to housing allocations need to be considered against the overall housing requirement.

Based upon the tracked changes to the Land Allocations document, the respective positions of South Lakeland District Council and the House Builders is set out in Appendix A Table 1.

Tables 2-7 analyse net requirements by settlement category.

There are disparities between the figures provided in 1A and 1B compared to the Housing Land Position Report 2013 and the Main Modifications that need clarification by the planning authority.

For some mixed use sites such as Berners and Ulverston Canal Head there remains a reference to residential development but the number of dwellings has been deleted. Clarification of anticipated housing completions is required. For ease of reference there should be a table showing the anticipated contributions from all housing allocations, mixed use sites and broad allocations in the period to 2025.

Concerns have previously been expressed by the CHBG about the lack of any flexibility and contingency in the housing allocations. The planning authority rely on each and every allocation to deliver the required number of units in the plan period and then contributions from windfalls, broad locations and previously unachieved rates of development in the small villages/hamlets and open countryside.

The planning authority are intent on making only the minimum provision which is contrary to NPPF’s intention to boost housing supply with a presumption in favour of sustainable development.

The CHBG consider the allocations to be insufficient to meet housing requirements.

MM024
The requirement for the preparation for Development Briefs is unnecessary and will delay bringing forward housing sites and the delivery of housing completions.

Appendix 4 of the Housing Land Position Report 2013 lists those site that are considered to be capable of delivering significant housing completions in the five year period to 31/03/18, however for 9 sites a development brief is required before planning permission is granted, 4 with briefs expected to be in place before December 2014 and 5 with briefs expected to be in place before December 2016.

The number of completions that can be delivered in the five year period for sites with briefs before December 2014 will be significantly reduced and for those sites with briefs to be prepared before December 2016 there are unlikely to be any housing completions before 31/03/18.

The requirement for development briefs will delay planning permissions and as a result there will not be five years worth of housing. It would be preferable for the wording of individual site policies and the more general policy guidance is relied upon in the consideration of planning applications.

MMO27-MM033
The requirement for development briefs should be deleted for the reason set out in MM024.


MM039
The reference to 7 ha and 156 dwellings requires clarification.

The housing allocation R151M-mod described as South of Milnthorpe in LA1.3 is to accommodate 70 dwellings on 3.41 ha and Firs Road to the east of Milnthorpe is to accommodate 96 dwellings on 3.19 ha (MM011), but there is a discrepancy with the number of units referred to in the Land Allocations tracked changes. Clarification is required over the total number of units and site area.

MM040
The requirement for development briefs should be deleted for the reason set out in MM024.

MM041
The suggested gross requirement 216 dwellings 2003-2025 as referred in Table 1A as revised April 2013 should be inserted.

A net requirement of 170 dwellings should be referred to after taking into account completions in the period 01/04/03 to 31/03/13.

The reference to 123 dwellings should be removed.

MM047
The requirement for development briefs should be deleted for the reason set out in MM024.

MM053
The requirement for development briefs should be deleted for the reason set out in MM024.

MM054
The requirement for development briefs should be deleted for the reason set out in MM024.

MMO72
All yellow star Development Brief designations should be deleted from housing allocations.


This submission will be submitted by email including Appendix A and B.

[see attached document]

I enclose the response of the Green Spaces Committee, representing eight campaign and residents’ groups, to the latest consultations on the DPD. I should be grateful for an acknowledgement.

The Inspector is asked to note and consider our serious reservations about how the process has been handled since the Hearings were suspended.

[see attached document]

[see attached document]

Dear Sir or Madam

Please find attached a representation to the Site Allocations DPD Schedule of Main Modifications on behalf of Time & Tide (North West) Ltd.

The representation is accompanied by a Landscape and Visual Impact Assessment. The LVIA is attached to this email. The LVIA figures cannot be emailed because they are 50MB. A CD containing the figures is following by post.

Regards

Dan

[see attached document]

LOWER ALLITHWAITE PARISH COUNCIL
STEERING GROUP RESPONSE TO SLDC LAND ALLOCATION DPD - CONSULTATION ON MAIN MODIFICATIONS
23 April 2015
MM015 The Jack Hill site is a sensitive site on a prominent ridge. The steering group, which worked closely with the planners to identify suitable potential small sites, felt it could support a small development behind the high hedge bordering Jack Hill
Following the community plan consultation the Parish Council’s aspiration was for developments of around 10 – 15 maximum.
The indicative numbers allocated for Allithwaite was originally 80 and is now 107. This increase will be a significant impact on the village particularly as they are all allocated in the first phase. This means that supply will exceed local demand for the affordable homes and they will not be allocated to local people in such a short space of time.
Jack Hill must retain its character as a lane as it is part of the Cumbria Coastal Way and this must be preserved
We feel the proposed site extends too far into what has always been recognised as a significant open space. The site slopes steeply to the west to The Ridgeway and more gently to a defined steep drop at the old field boundary. Any developments must be kept well back from the edge of the steep drop in order to avoid giving an over bearing impact on the rest of this important open space. The site will have a significant visual impact on both the entrance to the village and the view from the northerly elevated part of the village with 15 houses and this impact will become overbearing with 28 houses.
The development should have limited height rooflines and should not extend past the originally proposed line of development on the Ridgeway.
The high hedge at the village entrance is an important feature and defines this entrance to the village.
.Any increase in housing allocation exacerbates the hazards of pedestrian access from Holme Lane through the square to the school/church/playground/recreation area
The AECOM study, suggesting access onto Holme lane is ludicrous as the lamp post at this point is regularly knocked down indicating an already hazardous location. Adequate sight lines would not be possible without significant hedge removal, which would lead to increased traffic speeds. This would require further works to calm/limit traffic flow.
The AECOM recommendation for a staggered road junction ignores the cumulative effect of other development s in the area – eg the proposed creation of an access to the large Grange development MM052 land south of Allithwaite onto Kirkhead road as well as the further small developments in this area..
MM016 Land west of Bracken Edge. The Parish Council consider the extension of the village development boundary around this withdrawn site as making no sense and should be withdrawn to its original position. The proposed line of the village boundary behind Holme Lane does not represent what is the natural boundary of the village which currently is the rear of the Holme Lane properties. If, in the future, land to either side of the Stack Yard(access to Bracken Edge) should become developable then that is the time to consider changes to the village boundary. The current arbitrary line assumes that the plot to the rear of Holme Lane will automatically become part of the LDP if access should become available.

MM057 Land at Barn Hey The Parish Council welcomes the inclusion of a safe pedestrian route to village. This needs to be a requirement for all sites in particular Land behind Almond Bank which accesses onto a particularly dangerous stretch of road ( AECOM study recorded average speeds of around 30 mph on blind bend with no footpaths at site entrance)

Lower Holker Parish Council have considered the Modifications including the Further Highway Evidence Report at their meeting on 3rd May 2013 and would make the following comments:

EN42 Station Road, Cark-in-Cartmel
Prior to any further development taking place improved access is required including improved visibility for traffic entering and leaving the site and a footpath for pedestrians.

R687 North of Allithwaite Road, Flookburgh
It is essential that prior to any development taking place a pedestrian footbridge over the Railway be erected to ensure pedestrian safety.

Yours faithfully

Lyn Prescott

[see attached document]

[see attached document]

[see attached document]

Dear Sir/Madam
Natural England responded to SOUTH LAKELAND LOCAL DEVELOPMENT FRAMEWORK
LAND ALLOCATIONS DEVELOPMENT PLAN DOCUMENT (DPD)
Public Examination – Consultation on the updated Schedule of Proposed Main Modifications to the DPD in a response dated: 2nd May, reference 83266.
In addition to this response Natural England would like to provide an additional response to provide some clarification over buffers –Oakmere Homes (North West) Limited, is the developer who is promoting residential development of the allocation West of Oxenholme Road through an outline planning application.
This response is in light of the current planning application and will hopefully clarify the position with buffers.
We are aware of recent correspondence relating to the proposed buffers around housing allocations, in particularly the case relating to the proposed Oxenhome Road housing development and impacts on the River Kent Special Area of Conservation (SAC). As such, we clarify our position below:
Any advice relating to the requirements for buffer zones adjacent to residential housing allocations is based upon the evidence base provided in the Habitats Regulations Assessment (HRA) accompanying the proposed plan. In order to satisfy the requirements of the Habitats Regulations appropriate mitigation is required in order to ensure no adverse effect to the integrity of any European designated site. Any proposed mitigation has to be sufficiently robust in order to ensure deliverability through the plan and the precautionary principle has to be applied in accordance with the Habitats Directive. Natural England appreciates that a buffer of less than 10m may be appropriate in certain areas, however this will be dependent on the local circumstances affecting individual housing allocations. Additional survey data at the local level may indicate a variation in the buffer requirement. Such evidence may only emerge at the detailed planning stage. As highlighted below, there may be scope for flexibility in policy terms, however in terms of the site allocations plan as a whole the Appropriate Assessment has recommended that a 10m buffer is required in order to ensure no adverse effect to site integrity. Should you require any further advice on this issue, particularly in terms of policy wording to cover this issue, please do not hesitate to contact us.
Thank you
Kind regards
Kate Wheeler
Lead Adviser
Land Use Operations Team

[see attached document]

[see attached document]

Subject to confirmation at its meeting on the 13th May ,Preston Patrick Parish Council continues to oppose the development of land at Gatebeck Road, Endmoor, for industrial/ business purposes. The reasons for this are set out in the Council’s earlier response on this matter.
Lesley Winter
Clerk, Preston Patrick Parish Council

[see attached document]

I enclose the TOG response to the latest consultations on the DPD, together with an attachment.
The Inspector is asked to note the request for a ruling on site RN133M, outlined in section 2 of the response.

[see attached document]

We have commented only on the Main Mods as requested but would like to know whether there will be an opportunity to comment on all the other updated documents published since October 2012, before the resumed hearing.