Local Development Framework Consultation

Land Allocations Emerging Options Consultation Document *

All supporting foundational documents

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Oppose

My general views are based upon a range of aspects of major concern and I have set these in the context of their background.

My wife and I arrived in Kendal about 2 years ago and perhaps have a more critical viewpoint than many residents who have lived in the area for many years. We found locating an ‘affordable’ home (not at the very lowest levels in the documents but not expensive) to be an easy process. Kendal has a very large property base of all kinds, and appears to have good availability. It was also surprising that Kendal has clearly had very major expansion over the last decade. Every nook and cranny is filled with developments; and there appears to be much variety, from small flats to small mansions; and multiple business sites. It is difficult to see where more development could take place without losing the ‘small auld grey town’ in the expanding suburbs. The green-space is Kendal’s key asset.

Foundation in the Core Strategy

The SLDC LDF is founded on the Core Strategy (CS) formulated by SLDC in 2008 and adopted in late 2010 by the Council. After an inspection process, which assessed the ‘soundness’ of the planning, but importantly based upon directed regional strategy assumptions. This in turn was based upon the directions and methodologies arising from the previous government and in particular from the (John Prescott) Office of the Deputy Prime Minister (ODPM). One of the key aspects for this centrally directed development was the formation of Regional Spatial Strategies (RSS) which included a mechanism for imposed direction and specified targets for each region and subsidiary district.

The lead precedent for this ‘command development’ were directed major building programmes in many major cities in the UK led by the Regional Development Agencies. However, the early implmentations of these initiatives have been major failures. For example, the cities of Manchester, Liverpool, Leeds, Leicester and Nottingham all have major surpluses of low-cost, high-density housing; e.g. Leeds currently has 20,000 and Liverpool has 15,000 which have been empty now for several years since construction. These developments illustrate the dangers of major over-development and use of over-simplified and unreliable models that are not related to local needs and potential. It is not surprising that one of the first actions of the Con-Lib Coalition government in 2010 was to revoke the over-centralised and un-reliable RSS process.

Nevertheless, SLDC has continued to state its needs in terms of this discredited process. The Plans (Land Allocations Development Plan Document Emerging Options Consultation Edition, January 2011), introduces this background but side-steps this background by noting in all detailed plans the reference that the revoked RSS aligns with “local plans”. This is obviously a thinly disguised fiction. It is clear that all the underlying “requirements” are based upon this ‘top down’ process and have little basis in a well-established and risk-tested business case. The recent inspector’s report comments on this point:-

“Using the revoked RSS housing delivery requirement the national PPS3 stipulation for a rolling five year available housing land supply would require land for some 2,340 dwellings (468x5). [Here the inspector clearly confirms the point that the requirement are founded on the RSS]. To catch up to the gross former RSS figure by 2021, as suggested by some local house-builders, would lift the requirement to 491 dwellings per annum. In my opinion, having regard to recent delivery levels, this rate would be unsustainable by placing too great a burden on local communities and infrastructure even if the market conditions and building capacities were favourably inclined to deliver at this rate. In a period of national economic downturn the latter is highly questionable and for these reasons the Council’s annualised figure is therefore preferred as being more realistic and more likely to be achievable.”

In summary the inspector notes that the plans, in essence reflecting only the directions of the previous government’s planning process and their interpretation by a small team of SLDC planners (apparently influenced by local builders), are too large in scale. It is also of concern that the views of builders have been apparently at the core of the planning process when they will not have an independent view.

Councils have been mandated by the current government to continue plans, depending upon the work done, but to listen to the “aspirations of the local people”. This transitional process is intended to lead to the Locality Bill, whose aim is to place the views of local people at the forefront of local decision making. This is expected to be law within the next year. There has been no consultation which attempts to sense the “aspirations” of the people within the SLDC area. It is surprising therefore that the ‘allocation planning’ process has not be suspended until the new legislative framework is finalised. There appears to be an unseemly haste in taking the next steps before this happens when this project has a 15 year timescale.

The most worrying feature is the massive attention (and obvious high level of funding) paid to the physical aspects of the plans: the detailed surveys and inspections of many sites, the detailed reviews of the potential impacts (down to the European registered sites of natural interest) in comparison to the almost complete absence of assessment of examination of the business and societal cases. Of course these have also been subjected in minutiae to an examination by the District Inspector. But there has been no detailed and rigorous examination of the underlying assumption of the ‘business case’, or of the ‘population drivers’. These are taken as read without question from the RSS and related models. These indicate a level increase in population and insist that we plan for the ‘knowledge economy’.

Whereas these factors may be relevant to our major cities, the Lakes District (LD) is not a typical district. Its obvious major economic drivers are agri-business and tourism. There is no detailed aspect of how the CS develops or support these activities; but they are massively more important than the ‘knowledge economy’ to the Lakes, as many people recognise at the ‘common sense’ level. Having been involved in starting 3 ‘knowledge businesses’ I cannot see any distinctive reason why businesses would consider the LD to be a good area in general for such ventures; it has no supporting links to legal, design, IT and other specialist providers. The documents also note the need to increase financial services. Once again the integration of banking, accounting and money markets makes the choice of the LD unattractive to such businesses, as evidenced by the loss of a major FS company, Provincial Assurance, from Kendal some time ago.

In contrast to the high risk that ‘new areas’ will not develop it is clear that the current highly successful areas can be developed substantially. Other regions are stimulating the growth of distinctive high-value products that have a ready market in the ‘slow food’ marketplace. The LD has a major brand potential, but still has large segments of ‘subsistence farming’ which have not developed their potential.

The CS has the foundation assumption of the need to expand housing and local industry. The recent edition of the SLDC Lakeland News, No 16, Spring 2011, quotes SLDC Development Strategy Group Manager, Dan Hudson:-

“We have an ageing and declining population so sustainable development can secure local services and provides homes and jobs so people can stay in the district”

“The Council wants to deliver new and affordable homes and new high quality jobs across the district. This means building 400 each year as well as 60 hectares of employment land .. in Kendal and Ulverston”.

These statements include a suggestion that young people will return perhaps after leaving University or college. These are unrealistic assumptions in general. Most young people move away from their home town at this time and the majority do not return; but migrate to the place where they gain employment. Cumbria has no major University facilities (the University of Cumbria has very limited courses and a low standing in national and international terms). It is naive and unrealistic to expect that this trend will be reversed by the provision of affordable housing. Clearly people who already live in the area may wish to begin businesses that take advantage of modern methods that exploit IT. However, it is again naive to expect business to come to Cumbria, or re-locate to this area, unless they have a busines-related reason.

The (permanent) population may be ageing, but this is because the LD is a place that many choose as a retirement area, perhaps returning to their ‘roots’ after a long career elsewhere. However, most retirees will not require employment, and will create and support it through normal economic activity. In essence their employment has been ‘banked’ and is being ‘spent’ in the district.

Much of the documentation relates to the infrastructure and its limitations. Kendal for example, has major road stress points. The analysis funded by SLDC predicts major increases even if there are no developments.

For example, the traffic assessments are virtually ignored in the consultation review, despite the predictions that there will be major issues, for example in Kendal, even without the major housing development proposed. In the words of the District Inspector:-

“The problems of town centre peak period traffic congestion and related Air Quality problems are apparent. The County Council as the highway authority acknowledged that the level of growth was likely to be a challenge. The Kendal Transport Assessment 2009 (TRA1) modelled the likely transport scenario on the basis of potential development sites and concluded that several junctions now operating at or close to their theoretical capacity would exceed that and experience worsening traffic
congestion over the plan period.”

These findings are largely ignored in the recent consultation document in which the implicit conclusion is that a few hundred houses (and their mobile occupants) will not make much difference to an already congested area). There is no analysis of health-care provision or other critical services. However, the addition of 400 homes per year, with an average of 4 people would increase the permanent population of the district by 1600 each year.

Clarity and Objectiveness of the Public Consultation

A very short consultation process was mounted for the SLDC CS and the results are available on its website. It is noteworthy that the majority of these submissions were rather emotional responses and were opposed to the CS; many people considered the plans over-blown and out of tune with the needs of the community and local environment. It is not surprising in the circumstances that there are few if any ‘considered responses’.

The volume of documents in a large consultation is clearly a difficult issue. Simply making all documents available makes the process virtually unmanageable for a lay member of the public and can only lead to a meaningless “consultation”. It is practically impossible to absorb and review the thousands of pages of documents in any objectives fashion. It is apparent that the documents have taken thousands of person-hours to prepare. It is simply ridiculous to expect any coherent response, except at a trivial NIMBY level, which of course is then conveniently set aside and ignored as a partial viewpoint. This form of ‘divide and conquer’ consultation is in reality a cynical exercise which costs a large amount of money but whose results cannot be expected to yield a high quality considered response. To be effective consultations involving technical material must offer a roadmap guide to the materials, plus clear guidelines as to what responses would be valued, plus an indication of the mechanism for their subsequent use. Where possible consultations should be taken well in advance of decision-making, and not simply offer a ‘take it leave it’ (or ‘support’ or ‘oppose’). Where the latter is used it is obvious that the natural response will be ‘cancel or defeat the opposers’, as in the case of the CS consultation. (Many people are of the view that all of the SL area is 'our backyard' and seek to protect and preserve and permit scaled and carefuly costed and planned development, but oppose the arbitrary 'command' developments proposed).

There was no clear ‘road-map’ to guide readers through the rationale. The CS document is difficult to understand and had many puzzling aspects, but still forms the core of the current proposals. It presents multiple priorities and endless tables and lists. Many of these are difficult to comprehend, for example Table CS8.3b notes the “Quantity of open space, sport and recreation”. Curiously this table suggests that the “figure” (there are no units) “per 1000 population” of “natural and semi natural greenspace” should be: Kendal: 0.59; Ulverston 3.97; Grange: 32.59; Kirby Lonsdale: 15.20; Milnthorpe: 2.94. It is a mystery why the citizens of Kendal should be restricted to 0.59 of a resource for which the people of Grange require 60 times more.

It is not surprising then that the results of the CS consultation were dismissed in a few simple paragraphs in the response. There is little evidence that the consultation results were treated seriously in terms of their impact on the plans that have been developed in the LDF. Indeed after this poor quality consultation the CS was 'adopted' by the SLDC last year.

At least the present consultation is being carried out for a reasonable length of time and has been publicised.

However, in the current consultation the quality of the documents, in terms of their facilitation to support a decision making process is still very poor. There are countless tables, diagrams and lists. Buzzwords such as “sustainability”, “knowledge economy” and “affordable” are liberally scattered but are use in vague sense in this context. There are several points at which some factors have been ranked. However, there is no serious thread in the documents in which the multiple points are scored; and where these are brought together to allow an objective appraisal. Even the sites in the "Fact file" are listed in an apparently random order.

It is easy to arrive at a view that the “consultation”, like that apparently used for the CS, is a cynical process mainly designed to confuse with massive detail, create a myriad of disjointed comment that can be dismissed, so that the planning process can go forward unhindered by the mere views of the people who have to pay for it and live with its consequences. Once again the “consultation” does not specify any stated mechanism for how the results would be assessed and how they would influence the forward action. It simply says: “we will see what they say”. This is totally inadequate - the public have a right to know who will assess their views and how they will be taken into account in the decision making process.

Omissions and major new information

The Canal Head project is clearly a key issue for SLDC in the Kendal area where much of the planned allocations are sited. This potentially offers major opportunity for housing and employment on a brownfield site. No figures are included for this development; it is as though a major land area ripe for re-development is an ignored ‘elephant in the room’. It seems unacceptable that other green-field sites which have major landscape value on the sloping margins of the town are under threat of development when this area is mainly ignored in the priority list. It is mentioned in brief in one list.

The CS and other documents take considerable space to review and discuss the need for more housing and more affordable housing. Written in 2008 the examples and pricing used then are now inaccurate. Prices have reduced and there is ample property of all sizes and price bands on the market. The SL area is now well served for example by an integrated ‘estate agency’ newspaper which has literally 100’s of properties across the region. It is difficult to believe, unless you are a major housing developer, that there is any need to take any green-space land in the SLDC area.

Planning costs and need for efficiencies

This exercise appears to have been an extremely costly exercise. It would be useful as a matter of public record for the SLDC to disclose its full costs. Much of the work seems to have been of a token nature. For example, all ‘employment’ sites around Kendal have been visited but none have been selected save the one E4M site on the southern outskirts of the town. All other sites are dismissed on sustainability grounds. It is puzzling why a visit was made to every other site since thier evaluation arises purely from their location; with the common stated reason:-

“On balance taking into consideration the above, it is considered that there is a more preferable potentially available sustainably located site that spatially relates better to Kendal, performs better when applying the sequential test and has already / can be made more accessible to / from Kendal by alternative modes of transport. For the above reasons, site XXX has not been put forward as an emerging option for a strategic employment site to serve the Kendal area.”

It seems strange that only one site is suggested for further employment in the Kendal area. Other nearby sites are equally accessible by ‘alternative transport’.

Real sustainability

The word “sustainability” has been used endlessly in the documentation; in most cases to refer to the environmental costs of road transport. The plans completely ignore the new forms of energy that will be available from sustainable sources; e.g. of electric vehicles re-charged from renewable sources.

The word "sustainability" has many meanings. A key meaning refers to the land assets and what they can deliver. This meaning is much more critical, but has not been mentioned in the proposals at all. Once we have destroyed a green space and used it for yet more housing we cannot get it back. We only have one natural environment and landscape. There is a point at which the critical level of its usage has been surpassed in terms of the limits of infrastructure and landscape. Many of the areas proposed in the plans (for example the town of Kendal) have already exceeded this point in the view of many in the community.

Summary conclusions and recommendations

This costly process appears to offer minimal value and major negative impact, since it is based upon a flawed approach which concentrates on an imposed physical planning scenario, coupled with an inadequate analysis of real need and actual potential. The SLDC area has seen major development and expansion in the past 15 years. This does mean that should or can continue. Kendal in particular has over-stretched its landscape potential; many of the greenfield sites now proposed would fill ‘micro-gaps’ that characterise the town as the ‘Gateway to the Lakes’; for example in the approaches via the Milnthorpe and Sedburgh roads which are proposed to be destroyed by the E4M development.

Much is made of the need to avoid ‘nucleation’ in the countryside and preserve the green-space. The converse is equally true in the towns of the district. We need to avoid the ‘dis-nucleation’ of the green-spaces which define towns and villages in the district. Since such green-spaces are much rarer and hence more precious in towns, much more care must be directed to their preservation. These flawed proposals ignore this key point.

The proposals should be withdrawn and re-stated with a closer focus on the real needs of the communities. The variety of options should be placed openly before the communities in a simple set of options for development using the terms of the forthcoming Locality Act; to re-gain a local government that is representative of the needs of its communities and in line with general opinion.

In future, clear and choice mediated consultation should precede major planning exercises which require high costs. In my view we cannot afford such major wasteful planning exercises which have major flaws in their core assumptions.