Local Development Framework Consultation

Land Allocations Emerging Options Consultation Document *

26 & 27

3.12

Draft Policy K3

Oppose

This whole policy K3 is unsound and in particular this line:
Ref Name Area Dwellings
(Ha) Phase
1 2 3
R170M LAND NORTH OF LAUREL GARDENS 8.04 150 101

It is unsound for the following reasons:
1. The site R170M is part of a Green Gap. This means by definition it has higher protection than Greenfields. People who purchased their properties believing this to be true now find that they will be subjected to a grave injustice if this proposal goes ahead. Site R170M should not have been included in proposed policy K3 because it was designated a Green Gap by a Government Inspector in the late 1990s. Such recent decisions made by a Government Inspector must not be overturned.

2. The SLDC Transport Report states an amber limit for acceptable Junction Congestion and that in 2008 there were 7 red (above limit) junctions with 11 red junctions forecast in 2025.
(see http://www.southlakeland.gov.uk/downloads/page2033/Kendal_TAJune_2009.pdf )
Pages 7 of this report specifically mentions the Middle Sparrowmire R170M site (referred to as “The Todds”) as being inappropriate because it would "worsen existing congestion on Windermere Road, as traffic travels into Kendal town centre. As the Windermere Road corridor already suffers congestion and delays during peak travel periods, it is considered that additional large-scale development in this area will lead to deterioration in traffic conditions."
The above statement means the proposed policy K3 is unsound to include this site until there is money in place to build the necessary infrastructure changes in Kendal for SLDC to meet their specified Junction Congestion requirements. Action plans have not worked in the past and so they must be proven to have worked (with spare junction capacity) before further expansion of Kendal is allowed.

3. Burneside has raw sewage regularly in the streets. Burneside P.C. has approached United Utilities who stated the "pipe requirements would cost £120 million for renewal from Burneside to the Kendal plant and then the plant would have to be upgraded".
It is not sound that site R170M be put on a map and proposed to be built-on before 2025 when there is no plan (and guarantee that funding will be available) to build the necessary infrastructure for both sewerage and traffic before 2025.

4. The SLDC Air Quality Report shows that air pollution is getting worse in Kendal and that SLDC are currently breaking the law on Air Quality
(see http://www.southlakeland.gov.uk/downloads/page857/PR_Report_Template_2010.pdf).
Extract from page 27 of Air Quality Report (PR_Report_Template_2010.pdf)
"It would be hoped that each individual action would add to a combined reduction in levels to meet the requirement above. However, the 2009 annual mean NO2 results of the diffusion tube monitoring and the continuous analyser within the AQMA actually show that levels remain high, close to or above the 2010 objective and have actually increased from 2008 levels in 2009 in some locations. Without radical progress by Cumbria County Council on changes to the road system, vehicle access and parking in Kendal it is unlikely that the objective will be achieved."
Note the word “hoped”, the law must be proven to be obeyed before further expansion of the Kendal area is allowed.
SLDC should be very concerned about anyone who has any bronchial condition (e.g. asthma) and for the future health of children walking to school through Kendal during times of peak pollution
Action plans have not worked in the past and therefore it must be proven that the law has been met (and can be kept) before further expansion of Kendal is allowed.
It is not sound that any Kendal sites be proposed to be built-on before 2025 when there is no money allocated to build the necessary infrastructure for both sewage and traffic before 2025.

5. The Cumbria County Council proposed Local Transport Plan 2011-2026
(see http://www.cumbria.gov.uk/eLibrary/Content/Internet/544/942/5997/40361123022.pdf )
shows no major planned infrastructure changes for Kendal apart from the possibility of a new bridge near the existing Miller Bridge. It is admitted by CCC that no significant amount of money is available before 2026 for the major infrastructure changes that are required in Kendal to meet the specified SLDC Air Quality and Junction Congestion requirements.
Traffic congestion greatly affects the well-being of local people. Action plans will not work without major infrastructure changes in Kendal and until money is in place to do this, development must take place in other areas of the SLDC district. Ones which have low traffic problems.

6. When planning the expansion of Kendal the health and well-being of the people must take top priority over everything else. This proposed policy K3 ignores this completely. This does not mean that expansion cannot take place in other more suitable low pollution / low traffic areas of South Lakeland District. Plenty of more suitable sites, originally on the AoL maps for the SLDC district, have not been included on the latest maps. The most logical area for expansion is the area between J36 M6 and Sedgwick Roundabout where access (a key word) is easily available. There is no planned development for this area on the latest maps. SLDC have chosen the sites which cost the least to develop (e.g. no compulsory purchase costs) and will make the most profit for the developer rather than those best for the health and well being of local people. Money is being put before health. The law’s limits on air pollution are the maximum, the spirit of the law is zero pollution.

7. Over the 6 years 2003-09 (good years for building) 1305 dwellings (217 dpa) were built in the SLDC area and of these 246 (19%, target was 50%) were "affordable". This means there was an inward migration of 4 (high cost) to 1 (affordable). The majority of the proposed SLDC development is for the Kendal area (35%, 140 dpa) and this will add greatly to traffic problems mentioned above. This inward migration must not be planned (or allowed) to continue until there is guaranteed money available to build the necessary infrastructure (roads, sewerage, doctors, dentists, schools, etc). It causes unnecessary stress to local people when unachievable targets/sites are proposed/planned. Instead the policy K3 should be reviewed every 5 years and sites added when guaranteed money is available for the required infrastructure and also that traffic monitoring shows that the SLDC specified requirements for Junction Congestion and Air Quality can be met and kept after the development.