Local Development Framework Consultation

Kendal

1 (4 of 6) Kendal South West

R129M

Oppose

1. Quality of the environment. R129M is an open ‘Greenfield’ site of “high landscape quality” with no infrastructure in place. Using the criteria of the SLDC LDF Core Strategy and Sustainability Appraisal this is the kind of site that should be the LAST to be considered for development.

2. Character of the land. At present this area forms a clear ‘Green Belt’ of pasture and woodland, which delimits the edge of Kendal. It is one of only 2 unspoilt rural gateways to Kendal (the other being the Old Sedbergh Road), which have not been subject to urban sprawl. As such it forms an appropriate transition from an historic part of Kendal with its conservation area and Lime Kiln to the Lake District National Park, the boundary of which is just 100m to the west of R129M.

3. Biodiversity It has been recognised that this area provides valuable natural habitats for wildlife including a wide variety of birds, and bats, which wood clearance and building would destroy. Cumbria Wildlife Trust mentions badger setts in this area (Appendix 1B page 124, Consultation Responses after October 1st 2010)

4. Visual impact At present Kendal as seen from the west (Scout Scar) and north (the golf course and Kendal Fell) is attractive because the trees in R129M effectively shield the majority of modern housing estates from view. The area therefore has a very high visual amenity value. To remove these trees and build housing on R129M would present a clearly visible urban landscape from the LDNP as well as from the public amenity area on Kendal Fell.

5. Relief and drainage. Much of the site is elevated and gently sloping to the SE and would present no physical constraints for building, BUT the most easterly part (around GR 507923) is very steep and bisected by a natural drainage channel and is totally unsuited to building. (There is confirmation of this in Appendix 1A page 75 Consultation Responses which states: “Eastern part of site suffers from flooding, development should be avoided here”). Drainage presents a problem for the whole site as it is underlain by permeable limestone and so natural drainage towards Blind Beck is underground. After prolonged periods of rain springs appear to the south of the site e.g. at GR 507922 and Blind Beck becomes a watercourse. The creation of hard surfaces combined with the removal of trees would increase surface water volume, impede the natural ground drainage system and create several water problems: a) surface run off would be much higher with risk of flooding to the south east of the site b) the disposal of water into Blind Beck would be much greater which in turn would impact lower down stream. The steep gradients involved would exacerbate the problem. United Utilites has recognised the need for a complete surface drainage system, and the Environmental Agency in July 2010 identified the disposal of water into Blind Beck as an issue. (Consultation Responses Appendix 1A).

6. Lack of infrastructure and inadequate access. R129M is only accessible from Underbarrow Road, which is very much a rural, winding, secondary road, which narrows from 8m wide at the top of Greenside to less than 6m at the western edge of the site. It has no provision for cyclists or pedestrians and is unlit. To provide safe access to R129M this road would need to be widened and upgraded, in addition to other internal roads, paths and cycle-ways providing access to any housing development. The site would require separate sewage and surface drainage systems, and what has been described by National Grid-Gas Network as “major infrastructure/investment” and deemed “Unfeasible” (Appendix 1A page 75 Consultation Responses).

7. Traffic generation. Viewed on a map this site appears to be close to Kendal town centre and in a location where sustainable travel choices (cycling, walking) would be easy. However this is far from the truth because the site is on average a kilometre away from the town centre and 75m (250 feet) above it at the top of a steep hill. Research* has demonstrated that 5 times as much energy is required to cycle from the Town Hall or Booths to R129M as would a similar journey on the flat. Therefore the reality is that the only people who would walk or cycle into town, to work, or school are those that are physical capable of it, or that have the time to spare – in other words largely physically fit retired people. Therefore the journey to work, ‘school run’, or shopping, would largely be done by car so contradicting the Sustainability Objectives (NR1.1,1.2 &1.3) of the LDF in several ways:
a) Fuel consumption, emissions, and noise are dramatically increased when climbing a hill such as that from the Town Hall to R129M. A typical car would average 15 mpg on this climb and would expend more than 4 times as much energy/fuel as it would on the flat.*
b) Traffic flows would increase significantly on Greenside, Queens Road and Gillinggate all of which are residential areas, with consequent increased risk to pedestrians particularly at the already hazardous junctions at LowTenterfell/Bankfield, Summerhill, and Brigsteer Road/Bankfield, and the school crossing patrol on Gillinggate.
c) It is highly likely that the speeding problems experienced on Greenside would be exacerbated.
d) Traffic would add to the already extreme congestion on All Hallows Lane and the town centre with it’s already recognised problem of air pollution. The Kendal Transport Assessment in 2009 indicated that the highway network would be over capacity if there were any developments on the far western side of Kendal.
Previous schemes to develop the area within R129M have been refused because of problems associated with traffic. Nothing has changed except that traffic volumes are now much higher.
* Research carried out by Small World Consulting Ltd based on the model from ‘Sustainability Without the Hot Air’, David Mac Kay 2009.

8. False perceptions of proximity to services. In the Sustainability Appraisal distance from the most easterly part of R129F is markedly different from the actual distance as follows:

Primary School less than 500m ACTUAL DISTANCE=650 m
Secondary School less than 1.5km ACTUAL DISTANCE =2.06 km (by road) 1.75 km (on foot)
Higher Education less than 1 km ACTUAL DISTANCES =1.5 km (by car & on foot)
Bus Stop less than 400m ACTUAL DISTANCE =450 m

The distances to the western part of the site would be far greater – at least another 250 metres which demonstrates that the bus network would have to be extended, and that there would be a heavy reliance on cars.

9. Health risk. Most of R129M is within 500m of the most recent landfill site north of SL1B, which because of the methane and leachate associated with such sites might well provide a health hazard. An European Union Directive passed in April 1999 stated that all new non-hazardous landfill sites should be at least 500m from property. Consequently does not logic suggest that new housing should not be built within 500m of an existing site?

10. Affordable housing. It is highly unlikely that any building here would fall into the ‘affordable housing’ category which would, instead, be offset by developments in locations perceived to be less desirable and offering lower profits to the developer. Therefore R129M would not even fulfil the prime objective of the Core Strategy, which is to provide affordable housing to fulfil local need.

Clearly marked rumble strips at the top of Greenside to dissuade drivers from speeding.

Kendal

1 (4 of 6) Kendal South West

R129M

Oppose

1. Quality of the environment. R129M is an open ‘Greenfield’ site of “high landscape quality” with no infrastructure in place. Using the criteria of the SLDC LDF Core Strategy and Sustainability Appraisal this is the kind of site that should be the LAST to be considered for development.

2. Character of the land. At present this area forms a clear ‘Green Belt’ of pasture and woodland, which delimits the edge of Kendal. It is one of only 2 unspoilt rural gateways to Kendal (the other being the Old Sedbergh Road), which have not been subject to urban sprawl. As such it forms an appropriate transition from an historic part of Kendal with its conservation area and Lime Kiln to the Lake District National Park, the boundary of which is just 100m to the west of R129M.

3. Biodiversity It has been recognised that this area provides valuable natural habitats for wildlife including a wide variety of birds, and bats, which wood clearance and building would destroy. Cumbria Wildlife Trust mentions badger setts in this area (Appendix 1B page 124, Consultation Responses after October 1st 2010)

4. Visual impact At present Kendal as seen from the west (Scout Scar) and north (the golf course and Kendal Fell) is attractive because the trees in R129M effectively shield the majority of modern housing estates from view. The area therefore has a very high visual amenity value. To remove these trees and build housing on R129M would present a clearly visible urban landscape from the LDNP as well as from the public amenity area on Kendal Fell.

5. Relief and drainage. Much of the site is elevated and gently sloping to the SE and would present no physical constraints for building, BUT the most easterly part (around GR 507923) is very steep and bisected by a natural drainage channel and is totally unsuited to building. (There is confirmation of this in Appendix 1A page 75 Consultation Responses which states: “Eastern part of site suffers from flooding, development should be avoided here”). Drainage presents a problem for the whole site as it is underlain by permeable limestone and so natural drainage towards Blind Beck is underground. After prolonged periods of rain springs appear to the south of the site e.g. at GR 507922 and Blind Beck becomes a watercourse. The creation of hard surfaces combined with the removal of trees would increase surface water volume, impede the natural ground drainage system and create several water problems: a) surface run off would be much higher with risk of flooding to the south east of the site b) the disposal of water into Blind Beck would be much greater which in turn would impact lower down stream. The steep gradients involved would exacerbate the problem. United Utilites has recognised the need for a complete surface drainage system, and the Environmental Agency in July 2010 identified the disposal of water into Blind Beck as an issue. (Consultation Responses Appendix 1A).

6. Lack of infrastructure and inadequate access. R129M is only accessible from Underbarrow Road, which is very much a rural, winding, secondary road, which narrows from 8m wide at the top of Greenside to less than 6m at the western edge of the site. It has no provision for cyclists or pedestrians and is unlit. To provide safe access to R129M this road would need to be widened and upgraded, in addition to other internal roads, paths and cycle-ways providing access to any housing development. The site would require separate sewage and surface drainage systems, and what has been described by National Grid-Gas Network as “major infrastructure/investment” and deemed “Unfeasible” (Appendix 1A page 75 Consultation Responses).

7. Traffic generation. Viewed on a map this site appears to be close to Kendal town centre and in a location where sustainable travel choices (cycling, walking) would be easy. However this is far from the truth because the site is on average a kilometre away from the town centre and 75m (250 feet) above it at the top of a steep hill. Research* has demonstrated that 5 times as much energy is required to cycle from the Town Hall or Booths to R129M as would a similar journey on the flat. Therefore the reality is that the only people who would walk or cycle into town, to work, or school are those that are physical capable of it, or that have the time to spare – in other words largely physically fit retired people. Therefore the journey to work, ‘school run’, or shopping, would largely be done by car so contradicting the Sustainability Objectives (NR1.1,1.2 &1.3) of the LDF in several ways:
a) Fuel consumption, emissions, and noise are dramatically increased when climbing a hill such as that from the Town Hall to R129M. A typical car would average 15 mpg on this climb and would expend more than 4 times as much energy/fuel as it would on the flat.*
b) Traffic flows would increase significantly on Greenside, Queens Road and Gillinggate all of which are residential areas, with consequent increased risk to pedestrians particularly at the already hazardous junctions at LowTenterfell/Bankfield, Summerhill, and Brigsteer Road/Bankfield, and the school crossing patrol on Gillinggate.
c) It is highly likely that the speeding problems experienced on Greenside would be exacerbated.
d) Traffic would add to the already extreme congestion on All Hallows Lane and the town centre with it’s already recognised problem of air pollution. The Kendal Transport Assessment in 2009 indicated that the highway network would be over capacity if there were any developments on the far western side of Kendal.
Previous schemes to develop the area within R129M have been refused because of problems associated with traffic. Nothing has changed except that traffic volumes are now much higher.
* Research carried out by Small World Consulting Ltd based on the model from ‘Sustainability Without the Hot Air’, David Mac Kay 2009.

8. False perceptions of proximity to services. In the Sustainability Appraisal distance from the most easterly part of R129F differed markedly from the actual distances as follows:

Primary School less than 500m ACTUAL DISTANCE=650 m
Secondary School less than 1.5km ACTUAL DISTANCE =2.06 km (by road) 1.75 km (on foot)
Higher Education less than 1 km ACTUAL DISTANCES =1.5 km (by car & on foot)
Bus Stop less than 400m ACTUAL DISTANCES =450 m

The distances to the western part of the site would be far greater – at least another 250 metres which demonstrates that the bus network would have to be extended, and that there would be a heavy reliance on cars.

9. Health risk. Most of R129M is within 500m of the most recent landfill site north of SL1B, which because of the methane and leachate associated with such sites might well provide a health hazard. An European Union Directive passed in April 1999 stated that all new non-hazardous landfill sites should be at least 500m from property. Consequently does not logic suggest that new housing should not be built within 500m of an existing site?

10. Affordable housing. It is highly unlikely that any building here would fall into the ‘affordable housing’ category which would, instead, be offset by developments in locations perceived to be less desirable and offering lower profits to the developer. Therefore R129M would not even fulfil the prime objective of the Core Strategy, which is to provide affordable housing to fulfil local need.

Clearly marked rumble strips at the top of Greenside to dissuade drivers from speeding.

Kendal

1 (4 of 6) Kendal South West

E33

Oppose

Oppose

I oppose the allocation of land at E33 for ‘Employment’ types B1 & B2 for the following reasons:
1. Lack of demand. Although there is clearly a need to generate employment in Kendal the fact that the existing ‘Employment’ area south of SL1B (E34) remains only 2/3rds occupied, and is going to be extended suggests that there will be over capacity of this kind of provision without the development of E33. It also suggests that large warehousing units at this location are not attractive to potential employers.

2. Low potential for employment. Based on existing evidence of the adjacent site where the units are large yet employ very few e.g. 5 people in a 10000sq.ft unit it seems that further units would do little to contribute to Kendal’s work opportunities.

3. Visual impact. The large warehouse units already south east of E33 are entirely inappropriate to the character of this area between the historic edge of Kendal with its Greenside Lime Kiln and conservation area, and the LDNP. However any similar development at E33 would be far worse because it is actually adjacent to the National Park. E 33 is also larger and much higher than the existing area and SL1B and would consequently be visible not just from the public amenity area of Kendal Golf Course (from where the existing development is a scar on an otherwise delightful landscape) but also from Scout Scar in the National Park to the west. It seems extraordinary that having regenerated the old landfill site above the Kendal Fell Waste Handling area to a pleasing standard this area may now be degraded by future development. Adequate screening of units of this size is simply not possible because of the time taken for trees to mature.

4. ‘Swallowing ‘of existing residential property. E33 lies adjacent to and above 2 houses to the south and would clearly represent a highly ‘unneighbourly’ land use if it were allowed to develop as an area of large warehouse units. The only kind of development which might be acceptable here would be B1 uses only on a very small ‘domestic’ scale, low rise, low density, and in local stone.

5. Access. There is no direct access to this site from Boundary Bank Lane or Underbarrow Roads. The entrance to Boundary Bank Lane, which is also a public footpath, is already a traffic hazard because it is just beyond the brow of the hill, and lorries emerging from the Waste Handling Site have to pull across the crown of Underbarrow Road in order to negotiate the exit.

6. Traffic generation. Traffic accessing this site would either use Greenside or Underbarrow Road. Greenside has a weight restriction, which is already frequently flaunted, and because it is a steep hill, fuel consumption, noise and emissions are much higher than they would be on a flat route. Commercial traffic using Greenside would inevitably also have to use the highly congested All Hallows Lane and Beast Banks, or Gillinggate and Queens Road – both residential areas with traffic restrictions. Underbarrow Road is equally unsuitable as it is a narrow country road (less than 6.4 m wide), with concealed entrances from the 2 adjacent residential properties and no pedestrian provision. Because lorries accessing this area do so largely from the bypass, travel distances are increased which in turn increases fuel consumption, and emissions and consequently contradicts SLDC’s stated aims of encouraging sustainable transport.

7. Allowing the construction of the existing industrial site at this rural gateway to Kendal was a gross error. To allow further construction here would transform the edge of the Lake District National Park and the public amenity area of Kendal Fell into a large industrial zone suitable only for the urban ‘edgelands’ – a truly unsympathetic development. To do so would contradict the Sustainability Objective EN2 ‘To conserve and enhance landscape quality and character for future generations.’

Kendal

1 (4 of 6) Kendal South West

SL1B

Oppose

I oppose the proposed transfer of the waste recycling facility from Canal Head to this location at SL1B for the following reasons:

1. Although it would be adjacent to the Waste Handling Depot so that journeys by lorry would be very much reduced, this, would be outweighed by the increased distances travelled by the commercial and private vehicles that use the recycling site.

2. Traffic accessing the site would have to use routes through residential areas: up & down Gillinggate with it’s primary school and narrow carriageway; Kirkbarrow with it's congestion at Glebe Road; along Queens Road with its traffic calming; via All Hallows Lane which is already very heavily congested, and up Beast Banks and Greenside which are, like Gillinggate, steep, so that fuel consumption, emissions and noise are all far greater than they are on the flat. Consequently this is not a ‘green’ solution and does not achieve the sustainability objectives of the LDF.

3. The amenity value of the affected residential areas would be significantly reduced by the increased traffic generated – particularly on Sundays when a degree of tranquillity would otherwise be the norm.

4. There would be conflict between the use of private cars and heavy lorries within the confined area of Boundary Bank Lane, which would cause a significant safety hazard particularly as the entrance to this area is at the brow of the hill at the top of Greenside.

5. There would a very significant loss of amenity to the adjacent residential properties on Underbarrow Road, and to those above the site on Boundary Bank Lane, as well as to those large numbers of people who use the surrounding area on Kendal Fell and in the LDNP to the west for recreation and enjoyment.

5. This is an inappropriate land use for a rural area within 120m of the LDNP boundary, Kendal Golf Club, and a historic part of Kendal on Greenside with its conservation area and Lime Kiln. The old landfill site has been reclaimed sympathetically and even the Waste Handling Depot was tucked away fairly unobtrusively but then the character of the area was compromised by the very unwise building of large warehouse units. To allow the waste recycling area in SL1B and a further’ Employment’ area in E33 would create an large industrial zone encroaching on the LDNP and fit only for the suburban ‘edgelands’ of a large town or city, and not the rural gateway to an attractive market town from a National Park. It would again contradict all the fine aspirations of the Core Strategy of the LDF.

Kendal

1 (4 of 6) Kendal South West

Development Boundary

Changing the Development Boundary west of Kendal

Oppose

I oppose any movement of the present Development Boundary to the west of Kendal as it would result in 'urban sprawl' towards the Lake District National Park - an inappropriate land use for this rural area. To move the development boundary further west would be to endanger the environment, not to protect it, contrary to the stated aim of the LDF.