Local Development Framework Consultation

Heversham and Leasgill

23 Heversham and Leasgill

R48M

Oppose

Objection on behalf of Residents Group to Emerging Option Site Ref: R48M – Heversham and Leasgill

I am instructed by a local Residents Group to oppose the inclusion of Site Ref: R48M as an Emerging Option site.

The group notes that the LDF Core Strategy identifies the intention for small scale housing development in defined small villages such as Heversham to be allowed only where it meets local need, and where supported by evidence of such a need. The group supports this policy and wishes to see affordable homes built in the village to meet the needs of the recent housing needs survey in order to help retain a vibrant, living community.
However, the scale of growth envisaged in Heversham, as set out in the Land Allocations consultation, greatly exceeds the identified need, cannot be supported by the existing physical and social infrastructure of the village and would change the character of the village to its detriment. Separate representations on this aspect have been made by PFK Planning on behalf of the villagers and should be read in association with the following site specific comments.

R48M comprises a single field and was originally put forward by the some of the owners as two separate sites - R48 and R455. The Heversham and Leasgill Fact File indicates that the site may be capable of accommodating up to 25 dwellings. It was subsequently established , that the northern end of the site , comprising approx 20 % of the total site area, was owned by a third party who had indicated that this portion of the site was not available for development . He has requested that it should be removed from any further consideration. This has now been acknowledged by SLDC. The group considers that the development of R48M is unacceptable for the following reasons;

1) Heversham / Leasgill is a north-south linear settlement set a field depth back from the ‘relatively recently’ constructed A6, Princes Way, to the west of the village. The traditional mediaeval core of the village was built on the slightly elevated western edge of a band of small limestone hills and glacial moraines that lie immediately to the east of the wide estuary flood plain (known as the Moss) formed by both the River Kent and the upper tidal reaches of Morecambe Bay. Princes Way runs along the toe of the limestone hills to the west of the mediaeval core, and on the flood plain. R48M is situated just to the south of the southern entrance to the village from the A6, Princes Way. This field, and the others that slope down from the village from a along the entire length of Princes Way, helps to characterise the historic development and landscape setting of the village as one built along the higher ground above the floodline of the Moss and the wider estuary. R48M plays a very important role in the local landscape at this southern end of the village by separating the bungalows of the Dugg Hill Estate from the A6, and by providing a wide vista towards the locally important landscape feature of Heversham Heads beyond to the north , and the architecturally significant property “Tidal Reaches “ to the south . Any development on R48M, or any of the other fields between the village and the A6 Princes Way, would compromise this characteristic setting of the village and destroy the vistas referred to above. Furthermore because the closet dwellings to site are mainly bungalows it will be impossible to come up with a design solution for any new dwellings that is attractive and appropriate at the entrance to a village but that would not compromise the amenities enjoyed by the residents of those existing properties. Evidence of this adverse impact can be seen where such, albeit limited, residential development has taken place close to Princes Way, resulting in the rural character being replaced by a domestic appearance close to the road.


2) R48M slopes down from the Dugg Hill development, westwards towards the A6. At its western most point i.e. immediately adjacent to the A6, the field is some 1 – 3 metres below the level of the A6 and is often flooded with rain water runoff from both the main road and Dugg Hill. This is particularly so on the R455 section of the site. Thus for topographical, land drainage and residential amenity reasons the development of an additional 20% of the site is not feasible or desirable. With the northern section of the site having been removed from consideration and this south western section being unsuitable , R48M is reduced to an oddly shaped area protruding out between two sections of the field . Any development upon the section of the field left would appear very awkward in massing and townscape terms and would not be able to provide for an appropriate style of development at this visually important entrance to the southern end of the village.
3. The site is served by a very narrow and poorly aligned section of Dugg Hill that has very limited capacity to accommodate additional traffic and certainly not the very significant increase in traffic generation that the development of R48M would bring. This is reinforced by the amount of on street parking that of necessity takes place on Dugg Hill thereby reducing the carriageway to a single line in places particularly in the evenings. Any new access direct from the A6 would be highly dangerous because of its position on a fast section of theA6 and its close proximity to the southern entrance into the village.
4. Two properties overlooking the site, “Tidal Reaches” and “Lawnswood,“ are served by septic tanks , with their drainage systems being situated in Field R48M . Clearly any new dwellings could not be on septic tanks. However the ground levels are such that any new public sewage system would have to involve costly pumping and it is doubtful, if such high expenditure could be justified when the reduced site is only capable of providing for a small number of additional properties.

5. The existing vehicular access to “Tidal Reaches”, “Horncop” and “Lawnswood ” is privately owned, is at least a metre above the level of R48M and is not practical or available to provide vehicular access into that section of R48M referred to as R455.

The inclusion of R48M on the list of emerging options sites has drawn widespread criticism from The Parish Council, the parish meeting and local residents for the reasons set out above. There is no support for its inclusion from anywhere in the local community. The Parish Council’s suggestion that that part of the site referred to as R455 could be developed as a standalone site is totally impracticable for the reasons set out in sections 2) and 5) above . I therefore consider that R48M should be removed from the allocation process, with efforts being concentrated on identifying other more suitable infill and rounding off sites within the village away from the A6 corridor. With this in mind the group considers that in landscape, highway, design, amenity and, phasing terms it would be more appropriate to concentrate any additional dwellings deemed necessary onto sites RN118M ( Land off Park House Drive and the western section of R168E – Wilson’s Field which it is understood is now being made available for development by Dallam School ) , and R445 the school car park, whilst at the same time investigating measures to reduce any impacts on the surrounding residents.


Peter Winter
Head of Planning Services
PFK Planning

Heversham and Leasgill

23 Heversham and Leasgill

R41

Oppose

Objection on behalf of Residents Group to Emerging Option Site Ref: R41 – Heversham and Leasgill

I am instructed by the “R41 Local Residents Group” to oppose the inclusion of this site as an Emerging Option in the SLDC LDF Land Allocations Development Plan Document..

The group notes that the LDF Core Strategy identifies the intention for small scale housing development in small villages such as Heversham to meet local needs where it is supported by incontrovertible evidence. It supports this policy and wishes to see affordable homes built in the village to meet the needs identified in the recent village housing needs survey.

However, the scale of growth envisaged in the Land Allocations consultation greatly exceeds the identified need, cannot be supported by the existing physical and social infrastructure of the village and would adversely change the character of the village.

The group considers that the development of R41 is unacceptable for the following reasons;

1) Heversham / Leasgill is a north-south linear settlement set a field depth back from the ‘relatively recently’ constructed A6, Princes Way, to the west of the village. The traditional medieval core of the village was built on the slightly elevated western edge of a band of small limestone hills and glacial moraines that lie immediately to the east of the wide estuary flood plain (known as the Moss) formed by both the River Kent and the upper tidal reaches of Morecambe Bay. Princes Way runs along the toe of the limestone hills to the west of the mediaeval core, and on the flood plain. Field Ref: R41 slopes down from the mediaeval core to Princes Way. This field, and others that slope down from the village to Princes Way, helps to characterise the historic development and landscape setting of the village as one built along the higher ground above the floodline of the Moss and the wider estuary. The distinctive character and quality of Site R41 was recognised in the Cumbria and Lake District Joint Structure Plan by its designation as being a part of a defined ‘County Landscape’. Within such areas development detrimental to its character was resisted unless required to meet local infrastructure needs. Any development on R41, or any of the other fields between the village and the A6 Princes Way, would compromise this characteristic setting of the village. Evidence of this adverse impact can be seen where such, albeit limited, residential development has taken place close to Princes Way, bringing a domestic appearance close to the road.

2) R41 is immediately adjacent to the historic core of Heversham, which is dominated by the mediaeval church of St Peter with its substantial bell tower. This area is designated as a Conservation Area, where the Local Panning Authority has a series of statutory responsibilities to retain and enhance the area’s character, appearance and setting. The Church sits in a slightly elevated position and is a major landmark focus in views both across the Conservation Area and from outside of it. Its churchyard also provides opportunity for important glimpses outwards across the Kent estuary. As acknowledged in the Council’s Heversham Conservation Area Character Appraisal, the character of the Conservation Area has been frequently compromised by 20th Century developments immediately adjacent to it, including Princes Way and housing developments. Any development on this site will further detract from the appearance of the Conservation Area. From the A6 Princes Way there are important public views of St Peter’s and the rear of the slightly curving Chestnut House/Church View Row, all of which are Listed. Alongside are a number of other unlisted buildings that all, along with the high drystone limestone boundary wall and intermittent trees that separates them from R41, make a considerable contribution to the quality of the local scene and make a particularly positive contribution to the Conservation Area and its special architectural/historic appearance. These include Tower House, with its highly accentuated corner form and noteworthy yew trees, Fairfield, Meadowbank, Bannersgate and Threave. All are viewed from across R41 and are key buildings in views into the Conservation Area from the south and west, and help to frame a very significant view of the church. Careful attention therefore needs to be given to any development proposals that are likely to have an adverse impact upon them. R41 is very much associated with the Conservation Area and forms a hugely important part of its setting. I consider that any development on R41, no matter how well done, will obscure important views of St Peter’s Church, adversely affect the nature and quality of views of the buildings in the historic core of the village and diminish its wider landscape setting.

3) The only realistic vehicular access to R41 is at its northern end directly off the narrow ginnel known as Moss Lane. This lane leads west to join the A6 (Princes Way), and east to the narrow junction with the old A6, the main road through the village. Both of these junctions are totally unsuited to any increase in vehicular movements. The junction with Princes Way is on the inside of a fast bend in the road where traffic speeds are high , visibility restricted particularly in summer and where there are a number of recorded road traffic accidents. There is no ability to carry out the extensive works required to improve this junction. I note that Cumbria Highways state on page 13 of the Fact File that this access point raises safety concerns and is therefore unacceptable. I concur with this view. The village junction is close to a series of bends and at a position where the tall stone retaining wall of the churchyard forms a convex curve to the street edge. Additional turning movements here where visibility is restricted would again be detrimental to road safety and to the safety of the many pedestrians who walk past here daily, including children on their way to the primary School. There is no footway and no potential for one, or other highway improvements, because of the high walls of the Church and Heversham House.

4) Paragraph 2.25 of the SL Core Strategy indicates that small scale infilling and rounding off development will be permitted in small villages. The paragraph then goes on to set out definitions for both infilling and rounding off to which the Council will have regard. Clearly R41 does not meet the definition of an infill site. I also consider that it fails to meet the definition of “rounding –off” as set out and that development upon it would distort the character of the Heversham Conservation Area in an undesirable way.

CONCLUSION

The inclusion of R41 on the list of emerging options sites has drawn widespread criticism from The Parish Council, the parish meeting and local residents for the reasons set out above. There is no support for its inclusion from anywhere in the local community. I therefore consider that it should be removed from the allocation process, with efforts being concentrated primarily on identifying other more suitable infill and rounding off sites within the village away from the Conservation Area and the A6 corridor. It is proposed that, subject to a detailed investigation being carried out to very significantly reduce the scale, and any landscape, highway and amenity harm, development should be explored on both RN118M (Land behind Dugg Hill) and the village side road frontage of R445 (Dallam School Car Park).
Peter Winter
Head of Planning Services
PFK Planning

Greenodd and Penny Bridge

39 Greenodd and Penny Bridge

RN152

Support

PFK Planning had put forward this site at the earlier consultation stage on behalf of the owners. We are pleased to see that it is now an Emerging Option and can confirm that it remains available for development.

Kendal

1 (3 of 6) Kendal North East

R121M

Oppose

OBJECTION TO EMERGING OPTION SITE REF: R121M

I am writing on behalf of a resident of the Sedbergh Road area of Kendal in response to the current LDF Emerging Options consultation. My client is primarily an environmentalist who wishes to make a meaningful contribution to the next generation by the development and implementation of local solutions to global concerns relating to energy production and consumption, water security, climate change, soil degradation and carbon reduction. As a resident of the Sedbergh Road area she also wishes to express her objection to site Ref: R121M being included as an Emerging Option in the Council’s current consultation DPD on future Land Allocations. Representations were made to the Council concerning the site at the “Discussion Paper and Sites Under consideration” stage.

Introduction

The Bigger Picture
Planning shapes the places where people live and work. Done well it makes a positive difference to people’s lives, in terms of homes and jobs, whilst protecting and enhancing the natural and historic environment. Done badly it can result in a legacy for current and future generations of impoverishment on many levels.

The core principle underpinning modern day planning is that of Sustainable Development - defined as “development that meets the needs of the present without compromising the ability of future generations to meet their own needs” Government has set out four aims for sustainable development:
1. Social progress which recognises the needs of everyone
2. Effective protection of the environment
3. The prudent use of natural resources
4. The maintenance of high and stable levels of economic growth and employment.

However, we believe that that there is a need to go further. All activity needs to be pursued within the environmental limits of the ecosystems we depend upon. Climate change poses serious challenges to our economic and social systems, and quite simply it is clear that society will not be able to carry on as it has done. It’s no longer “business as usual”, rather its “business not as usual”. As the Government seeks to introduce short term measures to bring the country out the largest and deepest economic crisis since the 1930’s there is a real danger that it will ignore the deteriorating ecological situation or life’s support systems. These include climate change, water over –abstraction/aquifer protection , biodiversity loss, soil degradation and energy supply issues associated with the concept of Peak Oil – defined as the point in time when the maximum level of global oil and gas production is reached , beyond which production levels will decline. This is vitally important to us all as the economy is a sub set of the biosphere, not the other way around. First and foremost we need to stabilise and then reduce carbon emissions. To do this will require public policies that put an accurate price on carbon-based fuels and create the incentives necessary to deploy energy efficiency and renewable energy technologies, as expounded by the Institute of Civil Engineers. Put another way we need to create a practical vision of post- carbon prosperity, develop the financial means to deliver the vision, and then actually build the alternative energy infrastructure necessary to deliver it. Water is essential to virtually all human endeavours, from food production to manufacturing and of course for drinking.
Policy CS1.1 of the South Lakeland LDF Core strategy seeks to interpret sustainable development principles at this level in the following manner:
1.Opportunities must be taken to mitigate against and adapt to climate change including addressing flood risk, improving waste management, improving air quality, strengthening ecosystem services to enhance resilience of the natural environment, minimizing the use of non-renewable resources and increasing the proportion of energy derived from renewable or other more sustainable options;


2. It is vital to protect the countryside for its intrinsic beauty, diversity and natural resources and also for its ecological, geological, cultural and historical, economic, agricultural, recreational and social value

3. There is a need to take account of and enhance landscape character and features particularly the AONB and coastal areas. The area’s role as a setting for and gateway to the Lake District and Yorkshire Dales National Parks should be developed;

4. There is a need to safeguard the essential character and appearance of those buildings and sites that make a positive contribution to the special architectural or historic interest of the area, including the numerous conservation areas and listed buildings, whilst encouraging the appropriate re-use of buildings or sites which are causing harm;

5. It must be ensured that a high quality, localised and appropriate design is incorporated into all developments to retain distinctive character/sense of place and enhance the existing built environment;

6. Wherever possible, minimise the need to travel and provide a choice of sustainable transport modes for all sections of the community, including the provision of cycling and pedestrian infrastructure to encourage a shift in travel behaviour;

7. Most new developments should be directed to existing service centres where there is adequate service and infrastructure capacity to accommodate the required levels of development. Where necessary, ensure the provision of further physical, social and green infrastructure to support growth;

8. Development should accord with the following sequential approach:
• first, using existing buildings (including conversion) within settlements, and previously developed land within settlements;
• second, using other suitable infill opportunities within settlements;
• third, the development of other land where this is well located in relation to housing, jobs, other services and infrastructure.

9. All developments should help to meet the diverse social and economic needs of our local communities, from more densely populated service centres down to the more remote rural areas;

10. Local housing markets must deliver a broad range of housing, including more that is affordable to help retain more young people in the area as well as meeting the particular needs of the large proportion of residents who are over 60;

11. There is a need to grow the local economy in a sustainable way, supporting the vitality and viability of service centres, fostering local business development and rural diversification and attracting new investment into the area, thus reducing dependency on lower-paid sector jobs and high level jobs in areas outside the district. Support for tourism, which is a key driver of the local economy, needs to be balanced with protecting and enhancing the attractiveness of the area.



You will see that these mirror the principles that my client is championing but she considers that the Council should be taking a far greater lead in these matters by promoting innovative solutions that challenge mainstream thinking on economic, environmental and social issues through the Local Development Framework process and encourage resilience (Resilience in the context of building the ability to adapt to shock, to flex and modify, rather than crumble.) and self sufficiency by for example:
1. the greater promotion of/ practical implementation of /renewable energy schemes
2. the refurbishment of empty properties to provide affordable homes / live work units
3. the provision of shared allotments/ shared orchards , and gardens big enough to allow for home food production ,
4. promoting permaculture schemes
5. ensuring that all new large housing schemes contain a community building and an outdoor space that can be used for communal activities / community shops/food storage schemes
6. insisting on rainwater harvesting schemes and biodigesters.
7. increasing the availability of local food, by linking local farmers and producers with retailers and local restaurants

Many of these can be implemented in cooperation with community owned schemes of which there are many examples both locally ( eg Harlock Hill Community Wind Farm , Witherslack Community Shop ), and throughout the country. In effect we are arguing for The Great Transition, the aim of which is to equip communities for the dual challenges of climate change and peak oil.
Core Strategy


Objections to R121M.

The visual amenity and landscape setting of Kendal is one of its greatest assets, and gives it a real sense of place. It is the local context of views of Kendal together with the surrounding countryside which is really valued, and enjoyed, on a daily basis by the local community. The recently produced Kendal Local Level Landscape Character Assessment, commissioned by the Town Council, defines the character and significance of land around the town by reference to various criteria. Housing development on the eastern fringe of Kendal, (either side of Castle Green Lane), will compromise the views and landscape character of this highly visible area. Together with the surrounding land R121M, an area defined as a drumlin pasture, forms an extensive tract of valuable open countryside that helps to define the nature of Kendal’s historic development as a market town, and its landscape setting when approached from the M6 Junction 37/Sedbergh direction. In detail it comprises the following parcels of land:

? R56 – This field is pasture land that extends to 0.9 hectares and undulates upwards in an easterly direction from Castle Green Lane, which forms its western boundary. To the north it is bounded by the residential development of Oak Tree Road and Rowan Tree Crescent. A stream intersects the field. The field was proposed for residential development in the deposit draft of the South Lakeland Local Plan 2006. Objections to this were heard by an Inspector in 1996. In his report he stated that in his view the land is a visually important link between the open land west of Castle Green Road and the higher slopes of the hillside to the east. He found that the field provided an important visual buffer between the Oak Tree Road, Rowan Tree Crescent development and the converted farmstead development to the south, and concluded “I believe that the (allocation) site has a visual quality of some considerable importance in the local landscape which outweighs the very small contribution which it can make to the housing land need” He therefore recommended that the site be deleted from the residential allocation and this was duly done. I
consider the Inspector’s conclusions remain entirely valid today.
? R141, R121 and R676 – These sites comprise the fields that lie to the north and east of R56 and to the rear of Oak Tree Road and have a parkland quality and provide a high level of amenity value, a point acknowledged by the Fact File Commentary. The land rises steeply up from the rear of Oak Tree Road towards the West Coast Main Line railway and the fields are extremely prominent in both local and distant views (e.g. from Queens Road on the western side of the town). These fields were not put forward by the Council for development in 1996 as it considered that development on them would be “unduly prominent.” The importance of R141 and its visually significant wooded backdrop to the local landscape has been recognised by its inclusion in the Landscape of County Importance designation by Cumbria County Council as part of the then Structure Plan process (Policy E36). Whilst this policy has been superseded by policies DP7 and EM1(A) of the North-West of England Regional Spatial Strategy the thrust of the policy remains the same i.e. that distinctive features that contribute to the character of the landscapes of the North-West should be protected. Sites R121 and R676 are situated alongside R141, and have the same topography and visual characteristics as R141. Indeed the County Council’s Landscape and Countryside Officer came to the same conclusion in 1999 when he stated “Logically it should be included within this designation”.


My client accepts that it is a challenging task to find a way of protecting the character and environment of an area at the same time as allocating sufficient land to meet development needs. However she considers that these sites, both individually and collectively, contribute significantly towards the character and setting of this eastern side of Kendal and that development upon any of them would have a significant negative effect upon landscape character and the visual appearance of the area.

.



All too often such sensitive landscapes immediately adjacent to town development boundaries contain urban/rural paraphernalia such as timber stables, sheds, golf driving ranges etc. that adversely affect a town’s setting. In this case, there is a marked absence of such features and the land, with its characteristic drystone walls, trees and streams adds greatly to the character of this eastern part of Kendal,

The Kendal Fact File sets out in detail the concerns of the Environment Agency concerning any development on the site. It floods on a regular basis, provides an important storage function and any increase in surface water runoff could compromise the storage capacity of the vitally important Stock Beck Detention Basin downstream. Clearly anything that compromises the ability of the Stock Beck scheme to perform its task at its maximum would have serious consequences for the existing dwellings in the area. To solve this problem once and for all is clearly going to require a very significant sum of money and one is left to wonder if it would be really worth that expenditure when other sites without such difficulties could be brought forward elsewhere in the town.

Conclusions
For the above reasons it is my client’s clear view that Emerging Option R121M is totally unsuitable for development of any kind and that it should be omitted from the final document .

P J Winter
Head of Planning Services
PFK Planning
Agricultural Hall
Skirsgill
Penrith

Kendal

1 (2 of 6) Kendal North West

Land to north of E33 and E34 see below

The land immediately to the north of E33 and E34 would appear to form part of the Kendal Fell Quarry within South Lakeland (Outside of the Lake District National Park).Discussions are ongoing with the LDNPA , Cumbria County Council and South Lakeland concerning the appropriate future uses of that part of the Quarry within the National Park and it would make sense to include this land within these discussions.

Endmoor

8 Endmoor

R670

Oppose

Site Ref: R670 - Proposed Housing Allocation, rear of Dove Nest Lane, Endmoor


I have been instructed by Mrs J Clark of Challon Hall, Preston Patrick and Mr & Mrs I Cowperthwaite of Challon Hall Bungalow, Preston Patrick, to oppose the allocation of the above site for housing development until such time as:

a) adequate measures are put in place to prevent rainwater run-off from the site discharging downhill towards Challon Hall and Peasey Beck. During periods of high rainfall localised flooding is experienced, including buildings where livestock and farm machinery are housed, and any development would exacerbate this problem;

b) adequate traffic measures are in place to prevent traffic entering and exiting the site using the lower end of Dove Nest Lane. The lane, Challon Bridge and the C5077 leading to the A65, are exceedingly narrow, single track in places and totally unsuitable to take any additional traffic;

c) any access arrangements to the site do not interfere with the ancient hedgerows on the section of Dove Nest Lane between the village of Endmoor and Challon Hall.

d) improved sewage facilities are in place at the Low Park WwTW; and:

e) the existing parking difficulties in the vicinity of Dove Nest Lane, Enyeat Road and Low Park Cottages are resolved.