Local Development Framework Consultation

Land Allocations Emerging Options Consultation Document *

Core Strategy

Oppose

The Responses Form (on-line use)

I think the response form is confusing and difficult to use. I felt it could lead to a misleading interpretation of the response. I realised that selecting 'limited support' might be construed as limited support for the site I am totally opposed to so I had to change my response.

There is no facility to object to one particular site and to suppport an alternative.

It is unclear where to put objections to the scale of development for a whole settlement, rather than comment on specific sites.

Land Allocations Emerging Options Consultation Document *

23

3.2

Oppose

I do not support the 35/65% split of affordable/non-affordable houses.

I do not support the blanket allocation of land around South Lakeland for development up to 2025.

I am concerned about the proposed 35/65% split for housing developments, whereby 35% is going to be ‘affordable’ for local residents. Such a lot of houses proposed to be built on mainly Greenfield sites and 65% will be attracting migration of people into the area along with all the problems associated with a rapidly expanding population, i.e. traffic pollution and congestion, services unable to cope, adding to already overcrowded, sprawling housing estates which add nothing to the character of the area. New houses being built on sacrificed green land should meet the needs of local people only, not 65% of the open market.

The blanket allocation of so much land in one go will help a small number of local residents in the housing market. What it will also do is hinder many other local residents who have already purchased houses at over-inflated prices, mortgaged themselves up to the hilt, and are struggling through these difficult economic times. They will find that the allocation of land for development near their hard-earned property will devalue that property, potentially for the next 15 years.

Do these unfortunate residents also not deserve to be looked out for by the SLDC, or do they not matter? As long as the SLDC are seen to be helping some members of the community, it doesn’t mind if other members are trodden upon as a result. Many people could fall into negative equity as a result of the proposed land allocation for development. In fact any one of hundreds of houses in South Lakeland that are nearby or overlooking development land on Greenfield sites.

Land Allocations Emerging Options Consultation Document *

27

3.12

K3

No view

The names for the R103M and R129M are at best misleading or just plain wrong. R103M is listed as Land at Stonecross, when the 01.4 Kendal South West.pdf shows it as an area better described as Stainbank Green (its name on OS maps, and area M41KM would be considered to be Stonecross being closer to the Stonecross hotel). Area R129M is described as Land S of Brigsteer Road, but 01.4 Kendal South West.pdf shows this to be an area to the NORTH of Brigsteer Road and south of Underbarrow Road.

Land Allocations Emerging Options Consultation Document *

104

S1

Oppose

Settlement Factfile: Cark & Flookburgh

18/19

Oppose

Land Allocations Emerging Options Consultation Document *

ALL

ALL

ALL

Oppose

A local development plan for South Lakeland was issued and commented on in May 2008. This document was in direct response to a directive to Local Authorities from the Labour Government at that time. Many local residents commented on SLDC's proposals for Land allocations for housing and industrial use with many in opposition to the proposals.
Following a change in government in 2010 much emphasis has been placed by the Conservative/Liberal coalition on the need for local communities to govern and regulate planning at local (grass roots) level. I was hopeful that SLDC (being Liberal controlled) would fully recognise the aspirations of the current government for citizens to take more responsibility; taking full account of the local population's opposition to their original (2008) proposals. I am however dismayed to find that current (2011) proposals on land allocation are almost exactly as they were in the 2008.
During the intervening 3 year (2008-2011) period I have spoken to many local residents about land allocation particularly in Kendal. The vast majority, are opposed to large scale developments which use up green field sites. They are however, not opposed in general, to the re-development of brown field sites such as the auction mart or the Cock and Dolphin. Many of the people I have spoken to have opinions, but feel for one reason or another they are unable to communicate their views to SLDC. In addition, some are put off re-making the comments they made in 2008. I must confess that I myself find it wearisome having to spend yet more time re-stating points I made in 2008.
SLDC's proposal documents are lengthy and the web site for many of us is intimidating. Yet many people have a view on local development and their voice should be heard.

I propose that the following should take place:

1. All comments submitted on land allocations in response to the 2008 development plan should be fully considered and any comments incorporated into the comments for the 2011 plan.

2. There should be a local referendum (on paper) sent to all residents of South Lakeland District Council to seek their views surrounding any proposed large scale development within their locality.

Land Allocations Emerging Options Consultation Document *

whole doc

Oppose

Sustainability Appraisal Main Report and Appendices

All plans relating to Ulverston

Oppose

This is a letter posted today and included here as aware of cut-off

Dear Mr McNeill
Ulverston Town Development Plan – A General Comment
Having had a look at the land allocation plans you have drawn up in respect of Ulverston town, I am disappointed at the woeful lack of imagination they display. Whilst topographical considerations clearly limit the scope of development, the allocations in general belie the existence of a longer term “development plan”. Such a plan would surely take into account significant future infra-structural changes, for example the re-routing of the A590.
The allocations to my mind have the appearance of the worst kind of planning. This is the periphery estate doughnutting which blights a majority of developed English small towns. Kendal is a case in point. In response to Ulverston’s topographical constraints this leads to a proposed southerly bulge to the existing Croftlands estate, with pockets of “in-fill” grasped at wherever the opportunity may more or less conveniently present itself. This is not Planning. Despite the undoubtedly great amount of work put into the enunciation of background principles, statements of objectives, research and fact gathering and so forth, what you have come up with is neither challenging nor imaginative.
My fear is that the proposals you put forward will lead to yet more amorphous, developer led estate building, without the backbone of a structural plan that will truly enhance our community, and preserve Ulverston’s thriving local character, a jewel of a small town in the context of the entire country, not just South Lakeland.
In my view the scale of expansion of the housing stock relating to Ulverston is both economically and socially unjustifiable, unless of course we see the need to create another large scale retirement home, in place of the diverse community we currently have. Given that the size and pace of expansion is a diktat we are forced to accept, then the most appealing solution would be that based on outlying satellite nodes of development, incorporating localised services, and preserving permanent green spaces between these nodes and the core community.
I understand that such a concept represents an enormous challenge. But it is precisely this kind of initiative and courage which the community should reasonably expect from our professional servants, if we are to keep the best of what we currently have, and create something bold and successful for tomorrow.
Yours sincerely
Rees Hare

Land Allocations Emerging Options Consultation Document *

All

Oppose

I wholeheartedly endorse the views expressed Dr Brian Hoyle in his excellent critique submitted today. I fully support all of the comments he makes as also the conclusions he draws. It should be clear to all involved in this currently severely flawed planning process that no further action should be taken until the new legislation empowering greater decision making at local level is put in place.

All documents including the LAD

Various

Various

Support in part

The overall methods employed by SLDC in producing the LDF have been perfectly acceptable - identify the problem – look for evidence – set out the ideas – invite a response - produce a final document etc.
However it seems to me that there are some extremely important defects in the process:

UNDERLYING ASSUMPTIONS:
The evidence for the underlying premise upon which the whole of the LDF is based i.e. that South Lakeland is going to experience significant growth within the period to 2025 is unconvincing.
• The Core Strategy states that the present population of South Lakeland of 105000 will increase to 117000 by 2026 i.e. an increase of 11.4%(0.75% per annum) but the ONS prediction for South Lakeland for the period 2008 to 2033 is for an increase of 7.4%. (0.3% p.a.) The ONS figures (taken from Cumbria’s Population: Recent Changes and Forecasts Nov.2010) are based on the actual trends for the period 1981 to 2009 when South Lakeland experienced 9.4% growth. The ONS prediction is supported by the population structure of South Lakeland with fewer than average young and far higher than average retired people (which could be as high as 36% by 2033). This inevitably means a high death rate compared with birth rate and suggests that real growth will be the result of inward migration. How much inward migration is there likely to be in the future now that South Lakes and Kendal in particular has lost so many of its major employers? It is very difficult to understand why therefore the LDF is based on a presumption of a relatively high increase in population.
• The Core Strategy states that 35% of the population of South Lakeland is in Kendal i.e. 39,000 but the actual population is 28,000. It also predicts that Kendal’s population will grow to 32000 (an increase of 14.3%) which given the ONS population trends above seems highly unlikely. If one accepts the ONS prediction of a 7.4% increase in South Lakeland the district would gain at most 8000 people of which, according to the LDF, 4000 would be in Kendal (50% rather than the 35% LDF figure). Again surely an exaggeration?
• The Regional Spatial Strategy (RSS) identified a need for 400 extra dwellings per year from 2003 to 2021. As this was based on a sharing out of housing need throughout the North West, logic suggests that the 400 was again an exaggeration of the actual need. The North West, which experienced a decline in population over the last 18 years of 0.6%, includes many towns and cities with problems of poor housing stock and industrial dereliction where it is easy to envisage the need to replace substandard housing and therefore a high demand. However, fortunately this is not a serious problem in the area of SLDC, so why is the predicted housing demand so high here? Additionally even though the RSS has been superceded the LDF has retained the 400 dwellings figure.
• South Lakeland does undoubtedly need affordable homes but again the evidence needs scrutiny: the Housing Needs Survey of 2006 seemed to accept the RSS figures; the report was written in 2006 at the height of the housing market following a period of exceptionally rapid price rises and since then prices have stabilised or fallen while household income has increased; the existence of extremely expensive housing within South Lakeland inevitably skews average prices; and it is interesting that the report used average house prices but median incomes. All of this suggests that although the lack of affordable housing is a significant problem, it is not quite as great as that identified by the report which called for 50% of new homes to be affordable and 75% in rural areas. The Housing Survey correctly identified the greatest need to be for ‘starter’ homes and small dwellings for retired people which one feels would be far better accommodated by infilling in central locations rather than the greenfield urban fringe locations proposed in the LDF. These facts suggest that building should not be left to the free market of the developer but should be focused on Social Housing schemes.
• The need for housing is also undermined by the number of dwellings that are already available and remain unoccupied. The ‘No Use Empty’ campaign has highlighted the existence of 1000 empty houses which immediately reduces the perceived need to 330 dwellings p.a. rather than 400, and in addition to that there are over 1000 homes for sale with a significant proportion below £150000 at the present time
• There is a constantly repeated statement throughout the documents that young people leave the area because of the cost of housing. While this may be of true of rural areas where housing is both limited in supply and very much more expensive than average for the district, a problem which the excellent ‘Home on the Farm’ scheme is seeking to address without resorting to the wholesale swallowing up of greenfield sites, it is not true overall. Young people move for higher education and work. Although South Lakeland has a low unemployment rate average wages and salaries are low. Young enterprising people leave to find well-paid work else where, as has always been the case since the Industrial Revolution.

CONTRADICTION OF PRINCIPLE AND EXECUTION
Having set out aims and objectives, and identified criteria for development in the Core Strategy and the Land Allocations Development Plan Document, which are entirely admirable and worthy of the support of the local population, in the subsequent allocation of land those principles are almost universally disregarded. It is as if SLDC is saying “this is what we believe and what we want to do, but this is what we are actually going to do”.

Just a couple of examples taken from the DPD (there are many more):

‘• A sequential approach looking firstly at previously used land and
buildings within settlements, secondly at suitable infill sites and thirdly at
other land which is well located for housing, jobs, services and
infrastructure;’

Why then are virtually all allocations on peripheral greenfield sites while the other sites are deemed too small for consideration?

‘Local Factors influencing the location of development;
3.5 Key local factors influencing the location of new development in Kendal are;
• Respecting the setting of the existing and potential future extent of the
Lake District National Park which is close to the town;
• Maintaining and enhancing the quality of the surrounding landscape
and the need to achieve urban edges which maintain or enhance the
character and appearance of the town when viewed from key approaches
by road and rail and from important viewpoints such as Kendal Castle,
The Helm, Kendal Fell and Scout Scar/Brigsteer Road;
• Minimising the impact of development on Kendal’s central traffic
system, promoting sustainable transport and achieving a positive impact
on the Kendal Air Quality Management Area;’

• The allocation of R103M, R129M, E33, and SL1B with the proposed extension of the Development Boundary to the west absolutely contradicts the aims of all these factors
• The fact that all the proposed sites for housing are on the edges of Kendal would make the second 2 aims simply unachievable, as they will degrade the surrounding landscape and encourage unsustainable transport choices.



ERRORS
There are many errors in the consultation documents, which indicate that they have not been read, checked and amended as carefully as they should have been. This not only reduces the reader’s confidence in the content of the documents but also reduces the ability to draw sound conclusions from them. Some examples:

R103M described as ‘Land at Stonecross’ or alternatively ‘Stonebank’;
R129M described as Land south of Brigsteer Road when it is patently south of Underbarrow Road.

Both these mistakes have serious repercussions as they misrepresent the actual location of the sites and consequently divert the attention of potentially interested parties away from them.

Within the Sustainability Assessment there has been inaccurate measurement or recording of various criteria, which again gives a false impression of the actual sustainability of the sites.
For example distances to a variety of services from the eastern part of R129M are:

Primary School recorded as 'less than 500m' is actually 650 m
Secondary School recorded as 'less than 1.5km' is actually 2.06 km (car) or 1.75 km (foot)
Higher Education or training recorded as 'less than 1 km' is actually 1.5 km (car & on foot)
Bus Stop - less than 400m -actually 450 m

These may indeed have been caused by the mistaken location of the site as it is likely that distances were measured via Brigsteer Rd to which there is no access from R129M.


THE CONSULTATION PROCESS
The consultation process was well intentioned and aimed at inviting a wide set of responses however it has been badly managed and information has been difficult to access.
• Based on an admittedly small sample in just one neighbourhood of Kendal it seems that a large proportion of residents were totally unaware of the LDF and the consultation.
• This suggests that the process in general was inadequately advertised, and ‘Drop in consultation days’ were too few, certainly in the main towns and again inadequately advertised. At the very least surely one edition of the SLDC paper could have been reserved entirely for a clear presentation on the LDF, or a supplement in the Westmorland Gazette?
• What publicity there was for the LDF featured the need for affordable housing, which did not inform the public of the full scope of the plans, and was likely to engender an acceptance of the proposals.
• Access to the documents at the inspection points was very difficult. At Kendal Town Hall cardboard boxes full of papers were hardly ‘user friendly’ (though the Planning staff were!) and the fact that many people were told that response forms were not available discouraged response from those without access to the internet.
• There was an over reliance on the use of the SLDC website which effectively disenfranchised many residents. There are still large numbers of people who do not have access to the internet, or the skill to use it.
• The SLDC website is cluttered and not easy to use. The links to relevant information were very indirect. Accessing documents needed persistence – I counted a total of at least 47 files which were relevant to Kendal; some files duplicated data; there was no adequate index; there was no information on where to find the keys for maps and diagrams except by sifting through all the files; the PDFs were presented at 150% magnification; the fact that one can’t save a specific page of a PDF file meant that the only way to retain information was by printing it out. Small wonder that even people well used to the internet failed to access the information they were looking for. (An observation again based on a small sample of computer literate, intelligent neighbours who I cannot believe are atypical).
• The response process was also difficult as the ‘preferred online method’ involved registration and forms, the format of which many found off-putting. A good example of this is this very form which expects precise details linked to specific pages and paragraphs rather than the whole process. The inability to format the layout successfully is also irritating. Some people have told me that they failed to submit their response on line and so had written or e-mailed a response. The need to ‘Send’ and ‘Confirm’ added to the problem.
• The responses of those who did not submit online have not yet appeared on the Consultation List. e.g. an emailed response sent 3 weeks ago, so there is concern over whether all responses will be considered.
• In summary SLDC website is not user friendly and the volume of data available, with frequently conflicting statements and figures, was confusing for any other than the very determined.

Land Allocations Emerging Options Consultation Document *

and other background documents

Various

-

Overall

Support in part

The premise on which the additional housing need is based is at least questionable.

The requirement for SLDC to produce a strategy stems from decisions made by the Blair government nearly ten years ago. The present government does not appear to endorse that policy.

Confusion
SLDC’s Core Strategy Document (which was adopted by the Council in 2010) and the Summary Document, use a variety of statistical sources on which to base its plans, but when one looks at the Regional Spacial Strategy (RSS) the Housing Needs Survey (HNS) and compares them with those of the Office of National Statistics (ONS) used by Cumbria County Council’s Cumbria’s Population: Recent Changes and Forecasts, there is a bewildering discrepancy between them. They cover various periods (2003-2021; 2003-2025; 2008-2033; 2010-2025; 2010-2026; by 2031; by 2033). They produce a variety of predictions of population growth, both in real terms, and in percentages, and in housing, and employment needs:
That Kendal will grow by 4,000;
That its population will rise by 14.3%
That Kendal will need to build 140 houses p.a. for 15 yrs (=2100)
That Kendal will need 2060 new houses
That Kendal will need 3080 new houses

That S. Lakeland’s population will rise by 7.4%
That S.Lakeland will need 8800 new dwellings
That S.Lakeland will need to build 400 houses p.a for 15 yrs (=6000)
That S.Lakeland will need to build 4128 houses
That 35% of these should be in Kendal (i.e 1445 houses)

To add to the confusion, the LDPA affirms that the National Park is largely inappropriate for this development, so most of it has to take place in the parts of S.Lakeland outside the National Park.

Demographics
Who will live in all these extra houses? It is a fact that the area has a lower proportion of young people (aged 15-29) than much of the rest of the country, but that is primarily because of a dearth of well-paid jobs, not because of a lack of affordable housing. There is not much point in getting a cheap house if you can’t get a job; if that were the case young, ambitious, qualified Kendalians would go to where housing is cheap (like Workington) rather than where there are jobs.

At the other end of the scale the demographics of South Lakeland clearly show that there is a higher than national average proportion of people over the age of 60. Over the next 20 years most of these people will die, ensuring a steady supply of available housing. It is very unlikely that this increase in death-rate will even be balanced by a corresponding rise in birth-rate, let alone lead to a large overall increase in total population.

So the predicted rise in population must come about through large numbers of 15-30 and 31-45 year olds moving into the area. Really?

Nature of development
Most of the proposed residential sites shown on the maps are “greenfield” sites predominantly peripheral to existing population centres, which if developed would only increase the sprawl of towns and villages. This type of development is likely to be 3/4 bedroom detached/semi-detached housing that is out of the reach of those seeking affordable housing such as first time buyers, as developers are profit fed. It is very sad to see that the most recently built flats in Kendal (at K-village) are on sale at £300,000. Why could not these have been affordable homes?

I read this week that our MP is “working with the council to bring an estimated 1000 empty houses across the district back into use.” An excellent scheme and as these are likely to be smaller properties suitable for first-time buyers, of much more use than releasing Greenfield sites for development.


Alternative
May I suggest what may be seen as a radical alternative solution? Following the example of Cambridgeshire and Dorset to mention but two and the National Government at various stages in the last century? Why not a completely new settlement/village/small new town, with houses shops, a primary school, employment, and social amenities? The ideal site would be Crooklands. The area already has some employment provision, the showfield is there, the Auction Mart will be there soon, there is a hotel, church, village hall, attractive canal, and what is probably its best selling point, its accessibility to the M6 (S & N) A65, and A590 to the E & W particularly important for commercial traffic, nor is it far from Oxenholme main line railway station.


Consultation Process
I have found the SLDC consultation process extremely user unfriendly:

The staff at SLDC offices were unable to produce the relevant documents when asked, as they had run out.
I have rarely come across such a complex web-site. It is a real minefield, and very user unfriendly.
I know of several people who have submitted their views by e-mail, or on paper but they are not listed as respondents. How many have not been recorded, and why? Will their views not be registered, thus giving a false impression of the results of the consultation?

Surely this issue is so important to everyone in the district that SLDC should have published a comprehensive explanatory document to be made available to everyone if only through a supplement for inclusion in the Westmorland Gazette.

Land Allocations Emerging Options Consultation Document *

I would like to make a general comment about the whole document. I do not believe that the issues surrounding inward migration and affordable housing have been adequately addressed. For example, the Briarrigg estate, next to sites R170 and R148, included a proportion of "affordable housing" when built. After speaking to residents it seems clear to me that, although some of the properties were smaller and priced lower than others, none would have been affordable in practice to those in the lowest paid jobs, who are most seriously affected by house prices. I understand that several of the "affordable" properties on the estate were sold on, and are now used as holiday homes. I believe that the construction of this kind of estate does little to address the housing problems of local people with low incomes, though it may encourage inward migration by people on high to moderate incomes, who work in the north-west. In my view a more radical approach to "affordable housing" is needed, to really make an impact.

Publlicity for LDf process

Land Allocations Emerging Options Consultation Document *

All supporting foundational documents

All

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.

Settlement Factfile: Kendal

Document as a whole

Oppose

The Kendal Fact File is difficult to reconcile in so far as inconsistency prevails between reasons given for inclusion/exclusion of sites chosen as emerging preferred site options. The Fact File in respect of R121M highlights a predominantly negative assessment of the suitability of the site for development from all parties, and yet somehow you conclude that "In view of the above it is suggested this site be considered as an emerging site option for development." - How/Why and on what basis has this conclusion possibly been drawn?

If the public had been invited to attend your site visits (as is often the case with planning issues) then we would have had an opportunity to show and explain our areas of concern in more detail on site. As it is I attended one of your Consultation 'drop-in' days and tried to question why the inconsistencies could have arisen, only to be told S.L.D.C. needed the numbers proposed in the Land Allocation Document - not a sound planning reason for inclusion of site R121M. How site RN154, which is located within the existing L.D.P. boundary can be suggested as a site to be retained as Open Space and the same suggestion is not afforded to site R121M which is outside the L.D.P. boundary just cannot be reconciled or justified, and I would hope that these issues can be revisited by yourselves.

Land Allocations Emerging Options Consultation Document *

General comment about the whole principle of so many extra houses in South Lakes

General comment about the whole principle of so many extra houses in South Lakes

Not applicable

General comment about the whole priniple of so many extra houses in South Lakes

Oppose

I would like to say that I completely oppose the proposal to build so many houses in the area.
Where we live is very unlikley to be affected, so this is not a NIMBY comment.
I can see no need for this development on this scale, neither the housing nor most of the commercial develelopment.
It has not been justified at all in my view.
In the present and foreseable future, bearing in mnd the economic climate why are the houses needed and where is the employment going to come from?
To some degree, Kendal was spoilt in the 80s & 90s by several large developments. But he population in the area is at a comfortable level, particularly as it is a rural and semi rural area. There is a very great danger the character of the area will be degraded.

Land Allocations Emerging Options Consultation Document *

General comment on volume of new properties planned for Ulverston

Oppose

I fail to see any justification for the number of new properties proposed for Ulverston. Development on this scale will dramatically change the town , destroying green-belt land and putting pressure on schools & other services. It is just not necessary unless significantly larger numbers of new jobs than seems likely could be brought to the area. Any development that is needed should be targetted at brown-field sites initially.

Land Allocations Emerging Options Consultation Document *

67

G1

Oppose

The wording of this policy will need to be amended once the final decisions are taken regarding which sites are to be allocated for development to delete the reference to “…and on allocations adjoining, “ as all new confirmed allocations are intended to be included within the revised development boundary.

Land Allocations Emerging Options Consultation Document *

70/71

G5

Oppose

Mixed Use Allocations policy
It is not clear what information relates to what site within the policy box.
Policy wording is at odds with the information contained in the Grange Fact File for Site MN25M. Policy states that 9.26ha will be used for housing, providing 120 houses in two phases, for example. Grange Fact File states that only half of the site will be developed (including employment). Policy should be amended to remove site MN25M.

However, if any part of this site is subsequently taken forward for development, it should be included as part of Policy G3 as a housing land allocation only, with development scheduled for Phase 3, only when other allocations within the town's development boundary have been developed and to meet an identified essential local need. Employment uses on Site MN25M should be deleted from the policy. The Development Plan document should set out clear guidance for developers for any part of Site MN25M rather than leave this to a Development Brief which does not have the same weight of the DPD.

Land Allocations Emerging Options Consultation Document *

71

G5

No view

Green infrastructure.
You appear to have two policy numbers G5.

Land Allocations Emerging Options Consultation Document *

78

LSC-K7

Oppose

This policy uses the same wording as Policy G6 to identify a green gap between Kents Bank and Allithwaite. Should this policy be merged with Policy G6 to provide an overall policy for the Cartmel Peninsula? Whichever policy/ies are taken forward, it/they should include reference to a green gap to be identified to maintain the seperate identity of Kents Bank from Grange over Sands (see other comments).

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72

G6

Oppose

The policy identifies a green gap between Allithwaite and Kents Bank which I support (see suggested amendments) but this policy should also include the identification of a green gap between Kents Bank and Grange over Sands (see other comments)

Land Allocations Emerging Options Consultation Document *

16

2.27/Table 2

Oppose

I question the need to find 3ha of employment land for Grange over Sands for the plan period and query what the take up of employment land has been in the town in previous years, monitored through the Annual Employment Land Availability statistics. There are also vacant premises available within Grange over Sands and the surrounding villages to meet some of these needs already. Land identified at Station Yard, Berners Close Car Park and Old Berners Pool (Sites EN34M, R381 and M378M) are more appropriate sites for employment land development to support rural employment development in the area, where employment uses can be better integrated with other business and commercial uses, with other suitable sites also identified in the surrounding villages.

Settlement Factfile: Grange over Sands

Oppose

This comment should be read in the context of my other comments submitted in relation to development proposals for site MN25M. Fact File states capacity of Site MN25M to be developed at 40 dwellings per ha. Core Strategy policy CS6.6 sets out suitable densities and densities of higher than 30 units per ha are to be in town centres and locations with good public transport and lower densities where there are environmental constraints. The density of development proposed is over intensive for this site and would have a detrimental impact on the quality and character of the landscape and on the amenity of the area and neighbouring properties.

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50/51

3.70 / 3.71 / 3.72

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44 & 47

3.51 & 3.61

All documents relating to Burneside,: factfile, consultation response form, core document,etc

All of them

All

Oppose

It is clear that the SLDC team have done a very professional and thorough job on preparing the paperwork BUT for the "average" resident it has been an overwhelming experience. So much so that many I have spoken to have given up trying to respond because:
1. There was too much written information which they had neither the time, inclination, and in some cases the education, to get to grips with.
2. The Number of sheets in the response form and the way it was presented was felt to be intimidating to some residents who could nbot understand what was required. A simpler 2 page document would often have sufficed.
3. Much of the work was on computer/web which in our area, even today, is not readily accessible by most residents. In addition the size of the data made downloading difficult for some, and the cost of hard copy of all the relevant documents would have been prohibitive.
4. The "Roadshows" were limited in the time they spent in the area, and in frequency. Many residents could not attend during the day set aside for Burneside.

As a result, the views you receive from the area may not be representative in quantity of quality thus making the exercise flawed.

South Lakeland LDF Land Allocations Development Plan Document Kendal Fact File

171-172 Emerging Options R150M (Part R150 + R596/R117)

Justification Bullet 5 / Mitigation measures Bullet 6 - both relate to transport issues

Oppose

While the first paragraph claims that increased congestion at the Burton Rd/Oxenholme Rd/Heron Hill Rd junction is acceptable (Kendal Transport Assessment Study) over the 15 year time frame, mitigation measures are noted to 'address local and wider highways impacts'. It seems that the key concern is not safety or health of the existing inhabitants but only that the flow of traffic is not unduly affected.
Under the existing plans, there are no access points into the proposed development on R150M which do not involve Hayclose Road. The railway on the east boundary of the site curtails access from that direction while the site is restricted on its south boundary by the driving range, Oxenholme Farm and Raysholme, none of which are included in the site R150M. Thus access is bound to be via the existing cul-de-sacs of Howe Bank Close, Hayclose Crescent and Kendal Parks Road. The latter two are completely inappropriate in scale and accessability for providing the major thoroughfares required by a development of 240 houses. To give some idea of the scale - 240 dwellings is approximately the same number as the existing Hayclose Road + Hayclose Crescent + Howe Bank Close area. Thus traffic using Hayclose Road will be doubled adding to the apparently insoluble existing problems of parking - both by residents and the increasing numbers of station users who won't pay for station parking - and associated congestion which makes junctions into accidents waiting to happen. Residents of Howe Gardens are already complaining about the difficulty of turning safety out of this cul-de-sac - what will it be like with twice (or more) the amount of traffic along Hayclose Road? Similarly access through Howe Bank Close would be via a cul-de-sac off a cul-de-sac off a cul-de-sac - at what point will someone say 'this is not a suitable access route' - perhaps when someone has been killed or injured by a collision at the blind junctions?
Our SLDC councillor Mrs Feeney-Johnson has suggested that this is an issue for the planning stage. I beg to differ - this is an issue which must have been solved before the planning stage as how can a developer come up with plans for a site without having the access routes confirmed?
Nor am I gullible enough to believe that developers will address the issue unless forced to do so.
Thus, unless and until there is a clear statement from SLDC about how this site will be developed in terms of safe and practical access from the existing highway - namely Oxenhome Road - I am strongly opposed to the site being considered as an option for residential development.

land allocations development plan document

appendix 2 evidence base page 52

site reference R75 - Suitability/Viability

Oppose

We are confused by the remarks made in Appendix 2-Evidence Base for site R75 on Page 52.

Suitability - Says very good site near residential and benefits from good access off A6 and Princess Way. However the South Lakeland Employment and Housing Land Search Study identifies Site 2 (R75- Heversham and Leasgill) that the proposed access would be unacceptable to Cumbria Highways.

It goes on to say that it is pastoral grazing field set within largely pastoral area west of the A road. However it is located to the East of the A6.

Viability - says it is a level greenfield site. However it has been identified, in the fact file on page 6, that this field slopes steeply from the road (A6) and the topography of site would make development difficult. There are power lines and electricity sub station.

We are also surprised by the remark that there would be minimal visual impact experienced by residential properties which overlook the site.
Our house is built on the road side (with no paths) facing West over site R75. Behind us, to the East, the land rises sharply and because of this our house is built into the hillside at the back with all rooms facing to the front (to the West) over site R75.
The summary of the main issues raised by members of the public during consultation (Page 11 of the interim consultation statement) included concerns regarding the impact on existing residential amenity and the loss of existing local amenity such as views, environment quality and landscape character.

We have tried to expressed, through the consultation process, the damage not just to our own loss of views, privacy and outlook; but that of the wider community through the loss of an existing local amenity at this valued viewpoint over open countryside towards the coast. People often stop outside our house to take in the open views over towards the coast from the village.
It is also a prominent steep site which would have an adverse visual impact on character of village from the coastal path where public access is widely used. The significant impact on views was identified on page 6 of the fact file for site R75 and we feel it should therefore be reflected in the evidence base (as it was site R109 and R164 ).
It is also adjacent to the flood zone and regularly floods at the access point to the site along the A6.

P.S. We cannot find the original response we submitted back in February 2009, to which this relates, on your consultation database. However we did receive an acknowledgement of our response from Alastair McNeill at the time dated 9th March 2009. Your Ref: AmcN/60.12.43.
Please can you look into this and confirm that you still have this on record.

Land Allocations Emerging Options Consultation Document *

Whole policy

The whole argument of homes not being affordable due to a lack of housing is fundamentally flawed as it is clear that we have more houses now than we have ever had. The high cost of housing is due to demand NOT supply. Building more houses will not stop the demand so the cause of high house prices will remain and we'll be facing the same problems in 15 years. Also building more houses on green fields is CLEARLY NOT SUSTAINABLE and will lead to further permanent destruction of the environment and threaten our future security.

Land Allocations Emerging Options Consultation Document *

Settlement Factfile: Heversham and Leasgill

10, p26 and Appendix 3

The nature of this form does not invite clear responses from the public, rather it invites responses within very narrow boundaries. Page 10 and page 26 make reference to the view to and from Humphrey Head when presumably the intention is Heversham Head. Appendix 3 indicates a shop and a secondary school in Heversham when neither exists.
It may be that these are typographical errors or they may represent slipshod work on behalf of the council which would be worrying in the context of this document. In either case the on-line forms available do not make it easy to draw this to your attention.

The choices to oppose, support or support in part a proposal fail to elict an individual's view. For example I oppose the proposal to build 99 house in Heversham but I do support the need to build some houses. If I indicate support in part, does that mean that I support in part the need for 99 houses or support the need for part of this proposal, ie to build houses but less than 99 in total? Your form has not helped me to fully express my views.

Land Allocations Emerging Options Consultation Document *

Support in part

1. I think that the team has made a very methodical, fair and good job of land allocations. It must be extremely difficult to do. There is always going to be somebody upset and plenty of people ready to criticize.
2.I have looked at many of the sites with a view to solar housing which I have been involved in for 35 years. I have made up a report on the suitability of the sites from a first visual inspection. Some of the sites provide some wonderful opportunities with south facing slopes.
3. I have previously commented on the core strategy in which i was pleased to find references to environmental sustainability. As far as I can see this has not been carried forward from the design, construction and layout/orientation point of view. I understand that there is no national planning policy to do this which is very disappointing when other government departments are supposedly encouraging sustainability.
3.Kendal has a very wet climate and we need to take advantage of every bit of sun we get to enhance our lives. Why else do people disappear from their homes to get some sunshine on holiday! How much better to take advantage of these south facing sites in our everyday lives.
4.I propose that the design briefs for these south facing sites make it a condition that core strategy policy CS8.7 is implemented particularly with orientation to maximise solar gain. Here I am not thinking particularly of technology in the form of solar panels but to bring sunlight into the gardens and houses. Care must obviously be taken to maximise the winter solar gains whilst guarding against summer overheating. This can easily be done by good passive design.
5. We are supposed to be aiming for code 6 standards by 2025. I spoke to a large local builder and they said they were having difficulties with the current standards and are not interested in working towards the higher standards. With this in mind, some land could be recommended for self build just as allocations have been made for affordable housing. In fact, the two could go hand in hand and as I did myself, self build can be a major contributor to making housing truly affordable.
In particular, it is self build individuals who are interested in the higher standards and are prepared to experiment and show the way forward with innovative design and construction which we desperately need if we are to ever achieve code 6.
6. In summary, well done with the land allocations but please take it that step forward towards sustainable housing, especially when good agricultural land is having to be used. Make good use of the opportunity with the south facing sites. We have a huge stock of unsustainable buildings which are difficult and costly to improve, please ensure that all future housing is truly sustainable as far as is possible.

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25

4.2

Oppose

1.The stated ambition of 673 new houses between 2003 and 2025 fails to recognise the effect of new housing stock on demand. Over the last 10 years about 80% of new build has been taken by inward immigration, predominantly of retirees from Northern towns and cities. More new houses will not solve a local housing shortage but will simply generate a higher population. The proposals will help to solve the housing problems of Lancashire towns but will have detremental impact on our local communities.

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66

4.5

Local factors influencing the location of development

Support

It is stated that the key local factors influencing development include ' preserving and enhancing the built heritage', 'maintaining and enhancing parks and open spaces' and 'enhancing the vitality and viability of Grange Town Centre'. Unfortunately the proposals for development fail all these objectives. The scale of development will damage the built heritage, put increased pressure on what few open spaces are left and will fail to enhance the vitality of the town.
Grange is known to have a very real traffic problem now. There are already plans to build on the town's largest car park at Berner's Close and to build a new supermerket adjacent to the Windermere road car park. Further major developments will exacerbate the problems of traffic flow and parking which will detract from the viability of the Town Centre.
IT SEEMS TO BE A CONSISTENT THEME THROUGHOUT THIS ENTIRE PROCESS THAT STATEMENTS OF INTENT ARE MADE AND THEN IGNORED.

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66

4.2

Affordable housing and social rented.

Support in part

The plan identifies the need for 236 units of affordable housing of which 130 should be social rented. The Core Strategy Principles (CS1.5) stated that 'It must be ENSURED that a high quality design is incorporated into all developments to retain the distinctive character and ENHANCE the existing built environment.' All existing evidence of new affordable and social rental build shows that this principle will not be met. It is significant that SLDC's own Conservation Officer, in the 2005 Grange Over Sands Character Appraisal indentified a large number of buildings that he categorised 'as having a damaging or detremental impact' on the Town. An analysis of those buildings shows that most of them were build either by the Local Authority or by housing assocciations in cooperation with the Local Authority.
YET AGAIN IN THIS WORK WE HAVE STATEMENTS OF FINE PRINCIPLES WHICH WILL BE IGNORED.

Land Allocations Emerging Options Consultation Document *

Oppose

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whole document

Oppose

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Land Allocations Development Plan Document Emerging Options Consultation Edition

Complete

Support in part

I respectfully suggest that there is no real expectation of meaningful consultation on these documents with the vast majority of residents…

• There are dozens of documents – many hundreds of pages long – thousands of pages in all…
• Typical sentence lengths are long – not conducive to easy understanding…
• The indexing is poor.
• The document summaries are often missing, or scattered in the body of the reports…
• The displays in the Westmorland Centre & Asda were simplistic & council staff were only helpful inasmuch as they explained the boards – no other information…

Given this, what feedback is expected?

Some other general points:

• I can see no overt justification for the assumptions…
• Why is an objective such as, ‘to make South Lakeland the best place to live, work and visit and achieve the Core Strategy vision and objectives’, correct/ worthwhile/ realistically achievable? Where is the justification? A very good place to live/ work might be achieved at a much lower cost…
• Surely, the SLDC’s duty is to the present ‘ratepayers’… I suggest that the vast majority do not want unrealistic goals further wasting their hard-earned money.
• Just because people aspire to live in the South Lakes, does not mean that SLDC has to meet these aspirations. We have all hoped for the impossible…
• I note that there is a core strategy to build c. 400 houses per annum (¶1.6)
• I can find no reference to:
o Amount of potential Brownfield sites & their potential?
o How many vacant properties there are at present – private & rented - & for how long?
o Why recent developments are standing empty months after completion?
o Why sites with planning permission stand vacant?
o How long properties are on the market before selling.
o The effect of current recession on the strategy…
• I would have expected an analysis of previous strategies… What is different about this one? We read about all the things that are wrong – whose plans resulted in this outcome?
• In respect of Kendal, the strategy seems like an early computer game (Tetris) – attempting to cram in the highest density of housing possible. In the event, destroying the very fabric of the South Lakes that makes it so attractive – both for residents & visitors.
• The in-fill strategy is misplaced. Kendal will become divorced from nature & its surroundings. The plan seems to draw a ring around Kendal & fill in to the maximum. Kendal should have ‘soft edges’, in keeping with a small market town.
• Can Kendal accept the planned growth?
o Traffic problems in the town have given rise to poor air quality in places.
o There is a shortage of car parking.
o Problems with the waste treatment plant in south Kendal have not been addressed.
o Many parts of Kendal have flooding or potential flooding issues - not just due to the rivers, but also in times of exceptional rain. Building on the remaining open spaces can only exacerbate these issues.
o The report identifies many of the potential problems associated with the planned developments. However, I can see no firm proposals on how or when these potential problems will be addressed…
• The paper on ‘Open Space, Sport & Recreation Assessment is flawed in my opinion.
o The sample size is small.
o There is no analysis of whether the sample size is representative of the ratepayers, when it was taken or how…
o There is no quantitative error analysis.
o In short, based on the report, numbers are pulled out of a hat & given spurious credibility…
• In respect of industrial premises, we are on a hopeless merry go round where neighbouring councils try to woo businesses away from competitors… The reality is that until market forces necessitate a change in commuting patterns, the majority of skilled & professional people will live in the Lakes & work outside…
• Finally, the continued blockage of the main road into Kendal by the Conservative Party building is an utter disgrace… If we cannot sort this, one can have little hope for such grandiose plans as those presented…

Land Allocations Emerging Options Consultation Document *

There has been no local publicity and the information has been buried on a website. No effort has been made to ensure that local residents are aware of the LDF proposals. If one of my neighbours wishes to get a new front door their planning application has to be visually displayed on site.

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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.

Interim Consultation Statement

Oppose

Failure to Directly Consult Residents
The informal process adopted by SLDC has failed to directly consult residents adjacent to the proposed development areas, and in doing so has a flawed engagement process. Our first knowledge of the suggested site for housing R90M was received from another resident who had stumbled across the plans. Talking to other neighbours it is clear that the information has not been communicated effectively. It is insufficient to assume that residents will be informed through local press and passive web sites or parish councils, SLDC has a duty to directly consult residents who may be affected by these processes and this requires a proactive approach in identifying, contacting and consulting.

It is highly probable that the number of responses to this process would be significantly increased had SLDC fulfilled its obligations and directly consulted with residents adjacent to or living in close proximity to the proposals, leading to a more accurate reflection of community views and a realistic impact assessment.

Land Allocations Emerging Options Consultation Document *

whole document

Oppose

Land Allocations Emerging Options Consultation Document *

Consultation process in general

The current consultation process is heavily biased towards those who have access to the internet. Not all residents have this access.

I’m concerned that so many neighbours I’ve spoken to were not aware that the consultation was even happening, consequently many people affected by the proposals will not have had their say. For those who did, many have said they found the response form too complicated and off-putting, and several clicks down through your website.

The document browser contains an enormous list of documents. There is no key, abstract or summary to indicate what document can be found where. Many documents have ambiguous titles, making finding relevant information difficult, for example in the settlement fact file folder there is a document called “Kendal first part”, is there a second, third?

A lot of the information in the fact files seems to be presented like a spread sheet. Improved formatting would be better for text and spatially based analysis.

Maps of emerging options: there should be a key with every map.

Land Allocations Emerging Options Consultation Document *

General methodology

I managed to save my initial attempt at preparing a response earlier this afternoon. However, on returning to the saved draft and adding further comment, I have been frustrated to find that on Saving a Draft,(this time at the foot of the page) my further comments have NOT in fact been added to the previous draft. This is most frustrating - it may well be that there is a simple explanation, but it would help if this was clarified as I have wasted considerable time, as it has now happened twice! Interestingly, I have now returned to the consulatation document and added a small change to check the saving process, and, of course, it worked correctly. Though I did notice that it kept me logged on, whereas before, on Saving a draft, I had been automatically logged off. i suppose ther is no way of retrieving my additional comments, as i put quite a lot of effort into them? Thank you.

The Responses Form (on line use)

I think the response form is confusing and could lead to a wrong analysis of the response. Having selected a village, then a map, then when answering the questions "Do you support ..... the suggested allocation for the uses shown below", it is not clear whether the selection boxes apply solely to the site being commented on or are a more general comment.

Having selected 'limited support', I realised this might be construed as limited support for the site I am totally opposed to so I had to backtrack to change my response.

I am concerned that other respondees, like myself, might not realise that to register a negative response for a particular site, they cannot show limited support for the proposals overall.

Interim Consultation Statement

4

2.2

Support in part

The AONB Partnership is not listed in the table of bodies engaged in the summer and autumn of 2010 informal consultation exercises given on page 4. As representative of a national designation within South Lakeland that has provided comments, why is the AONB Partnership missed out?

Interim Consultation Statement

Section 4 starting Page 8

Support in part

Section 4, starting on page 8 gives a ‘Summary of the Main Issues expressed through consultation and how they have been taken into account’. The AONB is listed as one of the specific interest groups which made a response to the Land Allocations Scoping Report. There is no evidence given, however, that any comments made by the AONB have been taken into account or the AONB designation considered in any way. There is no further reference to the AONB in the rest of the document.

In the ‘Summary of Main Issues raised by members of the public’, paragraph 4.11 identifies ‘Impact on existing levels of local/general amenity – views, environmental quality and landscape character’ as one of the main issues raised. It states that: ‘A significant proportion of responses raised by members of the public relate to concerns about loss of existing levels of general/local amenity. Such concerns relate to the potential for development to harm the environmental quality/appearance of an area, including loss of local and wider views from surrounding areas particularly where there may be public access (from public rights of way for example). Some responses related to more general concerns about the loss of environmental quality i.e. development would alter the character of an area or damage locally valued viewpoints. Some respondents raised concerns about the impact of development on the identity of different settlements and possible further coalescence of individual settlements. In almost all cases the recurring common theme was the need to ensure development was sympathetic to existing landscape character.’

Also of concern to the general public is the ‘Impact on heritage assets i.e. Conservation Areas, Scheduled Ancient Monuments, Listed Buildings, archaeological value and locally valued heritage assets/features. Paragraph 4.18 states ‘Some respondents raised concerns about the potential adverse impact of development on existing heritage assets. These often related to concerns that the design and appearance of a development may alter the character of an area to the detriment of existing heritage value or may alter the setting and identity of an area. Other responses related to the historic pattern/evolvement of settlements and how development of a particular site would not be in keeping with existing built patterns and forms. A small number of responses related to the possible impact of development on archaeological value and potential remains.’

Paragraph 4.24 then includes a Table to show how the main issues have been addressed in the development of the Land Allocations DPD Emerging Options Document. Against ‘Impact on existing levels of local/general amenity – views, environmental quality, landscape character’ the document states that ‘Impact on general amenity and landscape character is a fundamental factor that has been taken into account in the development of the Land Allocations DPD Emerging Options Document. It has been considered in the Sustainability Appraisal (SA) of site options. The site visits have been used to inform decisions regarding the scale of impact of likely development on local/general amenity and landscape character.’ There is no mention of engagement with the AONB Unit or consideration of the AONB Management Plan or of the AONB designation at all. In contrast, in addressing concerns over impact on biodiversity it is given: ‘The Council has ensured that it has engaged with key environmental bodies such as Natural England and Cumbria Wildlife Trust in the consideration of site Options’. European sites in the context of appropriate assessment under the Habitats Regulations are referred to as well as local designations - RIGS and Limestone Pavement Orders specifically.

Against ‘Impact on heritage assets i.e. Conservation Areas, Scheduled Ancient Monuments, Listed Buildings, site of archaeological value and locally valued heritage assets/features’ the document states ‘Engagement with English Heritage, Cumbria County Council and SLDC Conservation officers has ensured that the Council has taken into consideration the likely impact of any development on existing heritage assets. Evidence in the Council’s Draft Conservation Character Appraisals has been used to inform views/assessment of sites in respect of Conservation Areas. These factors have also been considered in the SA of site options through consideration of potential impacts of development on Conservation Areas, Scheduled Ancient Monuments (SAMs) and Listed Buildings as well as other heritage assets and features.’ Again, mention of other national designations but not the AONB and no engagement with the AONB Unit.

Responses on Biodiversity/Environment Issues by other organisations are considered on page 26. It is very disappointing that Natural England did not mention the AONB designation in its response, summarised in paragraphs 4.40 and 4.41.

There is no record in this section of any comments made by the AONB Unit.

It is noteworthy that Conservation Areas, SSSIs Scheduled Ancient Monuments, Listed buildings etc are mentioned specifically as being important and included in the sustainability assessments but there is no mention at all about the AONB designation in this document. There is mention of Habitats Regulations and assessment of impact on European sites but no mention of the European Landscape Convention.

Sustainability Appraisal Main Report and Appendices

19

4.2

Support in part

Section 4 Context & Objectives considers links to other policies, plans and programmes. Section 4.2 states ‘The context set by these documents has been considered throughout the SA process to ensure that the approach taken is compliant and consistent with statutory requirements and wider policy direction. Although the AONB Management Plan has been recognised as a document having implications for the Land Allocations DPD, the importance of the AONB designation has not been fully considered - please see my detailed comments on the SA Scoping Report.

Sustainability Appraisal Main Report and Appendices

19

4.3

Support in part

Baseline Data. Section 4.3 states: ‘Before undertaking an appraisal of the impact proposed site options are likely to have on sustainability, it is imperative to understand the current position of the District by establishing a set of baseline data. Without this information, it would be difficult to assess the key issues for the District and difficult to predict the nature of any possible impacts of developing particular sites…..The baseline data can be found in Appendix 2 of the SA Scoping
Report December 2010.’ This baseline data for landscape comprises % dwellings built on greenfield sites and No of Tree Preservation Orders made. The condition/status of the special landscape within the AONB is not mentioned at all whereas the condition/status of other designations such as SSSIs, listed buildings, SAMS etc. have been included as indicators for biodiversity/geodiversity and the built environment respectively. It is difficult to see how a meaningful assessment of the landscape impact can be made on the basis of such limited baseline data. Landscape Character Assessment could be used to strengthen assessment of sites.

Sustainability Appraisal Main Report and Appendices

20

4.10

Support in part

Paragraph 4.10 identifies the key environmental issues for South Lakeland: -
-Protecting a rich cultural heritage from unsympathetic alterations, development,
and activity securing resources for its repair and improvement;
-Protecting extensive nationally important nature conservation areas, often
vulnerable to leisure and recreation pressures more than direct development;
-Overall long term decline in wider characteristic habitats and species, including
that resulting from changing farming or land management practices;
-Vulnerability of landscape to erosion of character – also loss of tranquillity and
impact of lights on night sky;
-Bland or poor design can harm distinctiveness of local built character.

These issues include protection of nationally important nature conservation areas but excludes protection of nationally important landscape areas ie. the AONB, instead referring only to the vulnerability of the landscape in general to erosion of character. The importance of the AONB landscape does not appear to have been fully taken into account.

Sustainability Appraisal Main Report and Appendices

22

4.16

Support in part

The environmental objectives are set out in paragraph 4.16:
Effective Protection of the Environment
EN1 To protect and enhance biodiversity
EN2 To preserve and enhance landscape quality and character
EN3 To improve the quality of the built environment
Please see my comments on the Scoping Report concerning lack of consideration of the AONB designation.

Sustainability Appraisal Main Report and Appendices

22

4.17

Support in part

Paragraph 4.17 states: This set of objectives seeks to protect and enhance the unique manmade and natural environments of South Lakeland. Currently, although South Lakeland boasts a high quality landscape and many areas of environmental designation and protection, development pressures are a threat to the District’s environmental features. Meeting these objectives should ensure that whether subject to formal protection or not, the District’s wildlife, habitats, geology, landscape and distinctive character are retained for the benefit of future residents and visitors alike. This paragraph mentions areas of environmental designation and protection but does not mention areas of landscape designation and protection. As stated in the report, much of South Lakeland boasts a high quality landscape but it is important to distinguish the Arnside and Silverdale AONB as a specific designation for landscape where there are additional requirements for landscape protection.

Sustainability Appraisal Main Report and Appendices

23

4.24

Paragraph 4.24 refers to ‘cumulative’ impacts. It is not apparent how the cumulative impacts have been assessed in terms of erosion of landscape character within the AONB.

Sustainability Appraisal Main Report and Appendices

section starts page 29

Paragraph 7.1 ‘considers the significant positive and negative effects of the emerging site options, and thus the Land Allocations DPD against the sustainability criteria identified for the SA Framework’. The sustainability appraisal objective stated in the Scoping Report for landscape is ‘To conserve and enhance landscape quality and character for future generations.’ That quoted in the final document in section 7.1 is ‘To preserve and enhance landscape quality and character’. According to section 7.17, the SA assessed each site against potential landscape impacts based on the size of the site and the character and topography of the landscape. No mention is made of assessing the sites in the context of the special landscape character of the AONB. It is interesting to note, SSSIs are specifically mentioned under the objective ‘To preserve and enhance biodiversity’. The SA assessed each site against information on the location and type of biodiversity resource, such as designated sites of special scientific importance or records of the presence of particular species. There is no similar mention of assessment against type of landscape resource which would include the AONB designation.

Sustainability Appraisal Main Report and Appendices

36

8.2

Oppose

Paragraph 8.2 states ‘It should be remembered at all times that the Land Allocations document should be considered alongside the Core Strategy and that identified likely impacts of individual sites should be considered alongside the policies set out in that document, as it is the policies of the Core Strategy that potential sites for development would be required to comply with in order to achieve planning consent. For example, although a site might score poorly in relation to potential impact on the landscape or built environment, there are policies in the Core Strategy that would require the design, layout and type of new development on that site to take impacts on the landscape and built environment into account and thus minimise, mitigate or avoid any negative impacts’. This statement indicates that it is considered that mitigation can overcome local impact on landscape. It does not indicate that the impact of development on the special landscape of the AONB has been considered or that the cumulative impact of development on this designated landscape has been taken into account.

Sustainability Appraisal Main Report and Appendices

38

Section 9 Implementation and Monitoring – see previous comments on inadequacy of landscape indicators relevant to the AONB designation.

Sustainability Appraisal Scoping Report

6

1.1

As a Local Authority, the Council also has a statutory duty to have regard to the purpose of Areas of Outstanding Natural Beauty i.e. to conserve and enhance their natural beauty, as set out in Section 85 of the Countryside and Rights of Way Act (CROW) (2000). This duty is not mentioned here and this is a significant omission. By contrast the duty to have regard to the conservation of biodiversity as set out in the NERC Act is mentioned.

Sustainability Appraisal Scoping Report

10

In Section 3 Context Review, the Arnside/Silverdale AONB Management Plan 2009 is identified as having implications for the Land Allocations DPD as well as identifying sustainability objectives with relevance for the plan. It is listed as being reviewed under the ‘Biodiversity and Geodiversity’ and ‘Landscape’ headings.

Under the Biodiversity and Geodiversity topic, the relevant aims and / or objectives from the reviewed plans, includes ‘Recognising and protecting the special qualities of the AONB’. Under the heading ‘Main Implications for the DPD’, reference is also made to the AONB: ‘Land Allocations DPD must take account of the special qualities and features of the AONB and consider how the location of and type of development proposed for sites could affect these as well as seeking opportunities to reinforce and respect the landscape’.

Under the Landscape topic, the list of relevant aims and objectives includes ‘Recognising and protecting the special landscape of the AONB and other sensitive landscape areas as well as their contribution to the character of the wider area’. These references are welcomed. However, under the heading ‘Main Implications for the DPD’, the special landscape of the AONB is not specifically mentioned. This is a significant omission.

Under Culture and Heritage, the AONB Management Plan is not listed as a relevant document, despite having relevance. The AONB is mentioned briefly under Local Economy and Tourism but only in the context of identifying land adjacent the National Parks and AONB to provide, when necessary, locations for tourism development.

Sustainability Appraisal Scoping Report

section 4 starts page 29

32

Section 4 sets out current baseline information in relation to each topic is set out in a series of tables. The AONB designation is recognised within the Landscape topic (page 32) although its status as a landscape of national importance as well as county and district importance is not highlighted. Also, very little detail is given as to the important landscape characteristics of the AONB. The AONB Landscape Character Assessment is currently being finalised and could be a valuable additional document to contribute to this baseline information.

Sustainability Appraisal Scoping Report

section 5 starts page 37

Section 5 identifies sustainability issues and problems. A significant omission in this section is the absence of recognition of the AONB designation or mention of the AONB Management Plan. Biodiversity, geodiversity and landscape are considered together here, whereas previously in the document, landscape has been considered as an important separate issue. The vulnerability of the ‘wider landscape’ to development is acknowledged as an issue but impact on the AONB designation is ignored. In the ‘Supporting Evidence’ column, there is nothing cited at all for ‘Landscape’, a further significant omission.

The AONB Managment Plan is not referenced under Culture and Heritage in section 5.5.

Sustainability Appraisal Scoping Report

47

6.2

6.2 sets out the sustainability appraisal framework and appraisal questions together with any ‘Additional Decision Making Criteria (relevant to the Land Allocations DPD)’.

Sustainability Appraisal Objective EN2 is ‘To conserve and enhance landscape quality and character for future generations’. The questions posed refer to protection of local landscape quality and rural landscapes generally but no distinction is made for any particular protection for the designated, nationally important landscape character of the AONB.

Sustainability Appraisal Scoping Report

54

6.3

6.3 discusses Indicators and Data Collection and refers to Appendix 2 which sets out a series of proposed indicators. The condition or status of other designations such as SSSIs, listed buildings, SAMS etc. have been included as indicators for biodiversity/geodiversity and the built environment respectively. However, the special nature of the landscape within the AONB as defined by its designation is not differentiated from the landscape in general. The special status of the AONB landscape appears not to have been fully taken into account.

Appropriate Assessment Screening Report

58

7.1

Section 7 ‘Sustainability Appraisal Process’ gives information on the scoring system that is used with, in brackets, the source of information used to derive scores for each criteria.
For the impact on landscape character the following is given:

EN2
Effect on landscape character (maps, local knowledge and aerial photographs)
__ Potential for significant positive effect on landscape character
_ Potential for moderate positive effect on landscape character
~ Likely neutral effect on landscape character
X Potential for moderate negative effect on landscape character
XX Potential for significant negative effect on landscape character
No specific mention is made of the AONB designation as an area of special landscape quality and therefore warranting additional consideration and protection.

In contrast for impact on biodiversity, sites of biodiversity importance are identified specifically in the scoring of this criteria:
EN1
Protecting and enhancing biodiversity and potential to contribute (GIS layers of sites of biodiversity importance and species records)
To score this criteria, notes were made as to any biodiversity/geodiversity designation of species precorded that might be affected by the site.

Also, for the assessment of impact on the built environment, listed building designation and SAMS are referred to:
EN3
Effect on built environment and potential to contribute (GIS layers showing Scheduled Monuments and Listed Buildings, local
knowledge, aerial photos)
__ Clear potential to significantly improve built environment, including where this would enhance the setting of a listed building orSAM
_ Clear potential to moderately improve built environment, including where this would enhance the setting of a listed building or SAM
~ Limited potential to improve built environment but no evidence to suggest negative effects to built environment likely
X Moderate potential to detract from built environment, including where this would detract from the setting of a listed building or SAM

Sustainability Appraisal Scoping Report

In summary, it would appear that although the AONB Management Plan has been recognised as a document having implications for the Land Allocations DPD, the importance of the AONB designation as a nationally protected landscape has not been fully considered at the SA Scoping stage.

Sustainability Appraisal Main Report and Appendices

Appendix 1

In the Sustainability Appraisal for Arnside, the results table shows for the majority of sites an assessment of ‘potential for moderate negative effect on landscape character’ and identifies that the village is located within AONB.

The SA Scores summary states ‘Arnside scores least well in terms of access to a secondary school, take-up of greenfield land, landscape character, built environment and access to open space.’ Also, ‘Care will also need to be taken to ensure that impacts on the landscape, biodiversity, air quality and the built environment are avoided or minimised and that adequate water supply capacity is in place’. Although the AONB is identified within the landscape character column in the assessment table, this is not then reflected by a specific mention in the summary. It would again indicate that impacts on the landscape in general have been considered rather than impacts on the nationally important and protected landscapes of the AONB. Elsewhere, eg, on the SA Summary for Burton in Kendal, the impact on the landscape and built environment is specifically identified as ‘due to listed structures and the Conservation area’. There appears to be a lack of consistency in the application of the assessment methodology between settlements ie. consideration of certain attributes and designations in detail, eg listed structures, Conservation Areas, but not others such as the AONB designation.

In the Sustainability Appraisal for Storth and Sandside, the location of the settlements within the AONB is recognised but the assessed impacts vary widely from being potential significant positive effect to potential significant negative effect on landscape character depending on the individual sites.

The SA score summary states ‘Storth/Sandside sites score least well in terms of biodiversity and landscape impacts, the effects on the built environment, air quality, water supply and the take-up of Greenfield land’. Also ‘Care will also need to be taken to ensure that impacts on the landscape, biodiversity, air quality and the built environment are avoided or minimised and that adequate water supply/sewer capacity is in place.’ Again there is no mention of the AONB specifically and likely impacts on the designated landscape.

In the Sustainability Appraisal for Beetham and Slackhead again there is no mention in the SA score summary of the AONB specifically and likely impacts on the designated landscape.

In the Sustainability Appraisal for Carr Bank and also Rural East open countryside sites within the AONB, again there is no mention in the SA score summary of the AONB specifically and likely impacts on the designated landscape.

Land Allocations Emerging Options Consultation Document *

Overall comments on behalf of the AONB Partnership, can be summarised as follows:

- South Lakeland District Council has a statutory responsibility to pay due regard to the purpose of AONB designation in its decision making.
- The AONB Partnership welcomes the reduction in scale and number of sites under consideration within the AONB but remains concerned about negative impacts on this nationally protected landscape in some locations.
- Proposed development sites should only be taken forward as preferred options if they are consistent with policies within the AONB Management Plan.
- The AONB recognises the need for affordable housing in the local area.

The Arnside and Silverdale Area of Outstanding Natural Beauty (AONB)
Sites under consideration in Arnside, Storth, Sandside, Carr Bank, Beetham and Slackhead are within the Arnside and Silverdale AONB, a nationally protected landscape. Some sites under consideration in Milnthorpe are outside but important to the setting of the AONB. The landscape quality of an AONB is recognised in law to be of equal quality and national importance to that of a National Park. The statutory purpose of AONB designation is to conserve and enhance the natural beauty of the area. Under Section 85 of the Countryside and Rights of Way Act (2000) it is the statutory duty of South Lakeland District Council to pay due regard to the purpose of AONB designation in their decision making.

Planning policy
Policies CS5 and CS8.2 of the SLDC adopted Core Strategy afford a high level of protection to the AONB landscape and its setting including landscape, biodiversity, geodiversity and historic character, with the aim of safeguarding the AONB from inappropriate development.

The AONB Management Plan
In the 2009 - 2014 AONB management plan, which South Lakeland District Council has prepared jointly with Lancaster City Council, Lancashire County Council and Cumbria County Council, the vision for the built environment (residential and other development) within the AONB is as follows:

The villages, hamlets and farmsteads of the AONB are rural in scale and retain their distinctive characteristics and historic patterns. Infrastructure impacts, from necessary signs, street-lighting and overhead wires, are minimised. Affordable housing meets local needs; modern development and conversions of redundant buildings meet high design standards, are carbon-neutral and respect the local context, character and distinctiveness of the AONB.

Relevant management objectives relating to the built environment include:

BE1.1 Ensure local planning policies and decisions maintain and enhance the local distinctiveness of the area. Encourage the provision of appropriate advice about the character of settlements within the AONB.
BE1.3 Promote the positive conservation, enhancement and provision of open spaces and “green infrastructure” between and within the settlements that maintain historic settlement patterns, provide links to the surrounding countryside and reduce the scale and intensity of development.
BE2.1 Support infill and village edge development that avoid sites that if developed would have a detrimental impact on either the historic form or character of a village; its setting, visual amenity, tranquillity, wildlife interest and landscape character. Encourage the assessment of the impacts of development on the site, village and surroundings.

Proposed sites should only be taken forward as preferred options in the Allocations of Land DPD following rigorous assessment, which clearly demonstrates that there would be no significant adverse effect on:

- conservation of the landscape character, natural beauty and local distinctiveness of the area
- conservation of bio and geo diversity
- historic character of a village or settlement
- conservation of open space and “green infrastructure” within settlements
- setting, visual amenity and tranquillity of the AONB
- capacity of the surrounding road systems to cope with increased traffic
- adequacy of public transport and services provision

If sites that do not meet these criteria are eventually developed, this would contribute to an incremental degradation of the natural beauty and landscape character over time, precisely what the AONB designation is meant to prevent.


The AONB Unit would welcome the chance to work further with SLDC and Lancaster City Council to develop joint supplementary planning guidance for the AONB as part of the two Local Development Frameworks to ensure that future development is not detrimental to the AONB landscape. Modern development within the AONB offers an opportunity to achieve sustainable development that meets local affordable housing needs, is of high design quality, carbon neutral and respects the local context, character and distinctiveness of the AONB.

The AONB Unit would also encourage SLDC to work in partnership to look at options for habitat restoration and enhancement and provision of new access routes in conjunction with the development of sites in order to use this as an opportunity to achieve other management objectives within the AONB Management Plan.

Interim Consultation Statement

This document as it stands does not demonstrate that, through consultation, the AONB designation as a nationally protected landscape has been fully and appropriately considered at this stage in the SA process, despite comments being submitted.

Land Allocations Emerging Options Consultation Document *

Whole Document and Burton-in-Kendal Section

LDF Core Strategy policy of housing to support local need not supported by Land Allocations policy.

Oppose

The Parish Council notes that the LDF Core Strategy identifies the intention for small scale housing development to meet local need supported by evidence. The Parish Council supports this policy and wishes to see affordable homes built in the village to meet the needs of the recent housing needs survey.

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

Furthermore, rational detailed comment on the suitability of the sites was unachievable without being able to consider the density, infrastructure, type size and mix of housing as in the normal planning process.

The Parish Council has identified three potential sites which would be suitable for small developments which include affordable housing and would in total exceed the identified needs of the village. These were The Royal Hotel site, EN14M currently identified for employment use, and future use of the land occupied by the telephone exchange previously identified as PS20.

Land Allocations Emerging Options Consultation Document *

Support

Sustainability Appraisal Main Report and Appendices

Land Allocations Emerging Options Consultation Document *

99

F5

Support in part

Land Allocations Emerging Options Consultation Document *

23

3.3

Oppose

Land Allocations Emerging Options Consultation Document *

7

1.10

Oppose

Land Allocations Emerging Options Consultation Document *

19-20

2.41-2.44

Support

Land Allocations Emerging Options Consultation Document *

12-13

2.14-2.16

Support in part

Land Allocations Emerging Options Consultation Document *

92

U9

Support in part

Land Allocations Emerging Options Consultation Document *

60-61

S6

Support in part

Land Allocations Emerging Options Consultation Document *

49

M6

Support in part

Land Allocations Emerging Options Consultation Document *

78

LSC-K7

Support in part

Land Allocations Emerging Options Consultation Document *

38

K10

Support in part

Land Allocations Emerging Options Consultation Document *

72

G6

Support in part

Sustainability Appraisal Main Report and Appendices

Site Ref R124 Appendix 1 Page 71 and Appendix 3 page 140

Land east of Ullswater Road, Kendal (R124)

Oppose

Land East of Ullswater Road, Kendal

Appendix 1 - oppose Issues and Concerns regarding flood risk and large scale leve of public opposition as a reason to preclude housing development.

From the submission made in the context of the Allocations document the following comments are made on behalf of the landowners:-

6.23 The Environment Agency indicate “any further increase in surface water runoff as a result of development in this area could (our emphasis) compromise the storage capacity of the Stock Beck Detention Basin downstream.” At this point in time the Environment Agency are not certain that Stock Beck cannot accommodate more surface water. Further it is possible that an attenuation scheme restricting surface water runoff to greenfield rates would be a solution to avoid downstream issues.
6.24 Issues associated with the Stock Beck catchment area are referred to in the context of R121M, R563 and R663 which are all proposed to be allocated. In the context of other proposed allocations the Environment Agency make reference to Natland Beck and Blind Beck. There may be technical issues that need further investigation but given the Objection Site’s suitability in sustainability and landscape terms, these issues simply require further investigation and should not rule out the allocation of the site for housing development.
6.25
A technical solution was found for 94 dwellings (SL/05/0976) and the Objectors are of the opinion that a technical solution can be found for residential development at the Objection Site.


There is public opposition to many of the proposed developments around Kendal and is not a reason to preclude the release of this site for housing development.

Appendix 3 Page 140 - it is not understood why there should be air quality issues associated with this site any more than any other sites around the town.

Comments about all the documents and approach

Oppose

There must be hundreds if not thousands of pages full of text spread across numerous documents, reports, appraisals, fact files, topics within the Local Development Framework (LDF) which has been going on now for a number of years.
How on earth do you expect the ordinary person on the street to be fully conversant with all the information/text of the above documentation? How do you expect people who have no computer to be able to comment on anything at all to do with The Local Development Framework in this format?
There is a requirement to identify on which page, which paragraph no., which document/report/appraisals/fact files/topic etc. within the LDF framework policy you would like comments on?
Logically If you wanted to design a complex policy consultation response system that very few people would be able to respond/complain/object/comment on, then this is it.

As a result of the above comments and in an attempt to engage with constituents residing in the local area who will be affected by development at sites R170M, R148 and R149 the Kentrigg West Action Group has taken their AoL Consultation Response documentation on to the streets and canvassed for support within the local areas of Burneside Rd, Charles St, Aikrigg End/Ave, Kentrigg Walk, Applerigg, Kentrigg, Kent Lea, Briarigg Estate and parts of Acre Moss Lane and Moorfield Close. As a group we managed to visit some 310 Dwellings during a 6 week period collecting more than 350 Consultation Response Forms all supporting opposition to the proposed Development. Subsequent analysis of those 310 dwellings visited identified 80% of respondents were against the proposed development at Sites R170M, R148 and R149.

Land Allocations Emerging Options Consultation Document *

KL4

Oppose

Land Allocations Emerging Options Consultation Document *

14

2.20 TO 2.22

Settlement Factfile: Heversham and Leasgill

-

3.107 - 3.110 of Emerging Options document

Draft Policy S7

Oppose

SOUTH LAKELAND LDF – LAND ALLOCATIONS
EMERGING OPTIONS CONSULTATION RESPONSE
Introduction
I have been instructed by the Heversham and Leasgill Action Group to make representations concerning the scale of housing development proposed by SLDC for the three Emerging Option sites within the settlement. The group has approximately 100 members and is guided by a steering group of 4. It has presented its work to a Parish meeting which also attracted over 100 local residents.

Summary
It is the group’s view that the theoretical total of 99 dwellings capable of being accommodated on the three Emerging Option sites represents a gross over provision when set against the village’s ‘Small Village and Hamlet’ status, the small level of local need identified in the most recent Housing Needs Survey, and the social and physical infrastructure of the village. The figure is totally at odds with the District Council’s stated intention of providing only development at the scale appropriate to the identified needs of the village and there is no credible and robust evidence to support it. The addition of 99 new dwellings in the village would clearly imbalance, in terms of scale, any relationship with the existing 286 dwellings.
The Action Group believe that there is an identifiable need for only a small number of additional dwellings in the village and that any more could not be adequately supported by the village. However, if SLDC insist that sites for 6058 new dwellings have to be allocated within the District then it is the Action Group’s view that a figure of between 25 and 30 dwellings (ie around a 10% increase over the existing number) would be more appropriate.

Justification
The District Council’s approach is to focus growth and new development in the District’s larger settlements whilst restricting development in the surrounding rural areas. In all cases the scale and nature of development should take into account the capacity of essential infrastructure and respect the character of the locality. Such an approach accords with the objectives of national guidance, the North West Regional Spatial Strategy and the Cumbria and Lake District Structure Plan that all seek to direct development to the most sustainable locations. SLDC Core Strategy Policy CS1.2 sets out a 4 tier settlement hierarchy with approximate percentage shares of anticipated housing growth allocated to named Principal and Key Service Centres. A network of specified Local Service Centres, each with a range of local facilities is identified as the third tier. The final tier is a network of smaller village and hamlets which includes Heversham and Leasgill, although not all are named. Within this final category of settlements, where it is acknowledged that facilities are limited or non- existent, it is stated that development will be limited to infill and rounding off (both of which are defined), and at a scale appropriate to the identified need in each location. The settlements within this category vary considerably in terms of size and character and therefore what constitutes large and small scale will vary considerably from settlement to settlement. However it is generally accepted within the planning profession that developments of 10% or more of the number of existing dwellings within a settlement can be regarded as being “significant”, and therefore requires very close scrutiny. With a particular emphasis on producing affordable housing, the aim in these small villages is to build healthy sustainable communities by empowering rural communities to develop a local vision and identity, to identify and meet local needs and manage change in the rural economy and the landscape.

Within this lowest category of settlement, the Council has unusually decided to allocate specific sites for new housing. I say unusually because, at this level, many other Local Authorities have chosen to provide for only affordable housing where there is a proven need and then not to allocate sites but instead have opted for an approach of using exception sites, considering it necessary only to allocate sites where a particular locality has an extremely high identified housing need. As will be seen from the following analysis, that is not the situation here.

The most up to date housing need figures for Heversham and Leasgill ( CRHT Survey Oct 2007) reveal a need for 5 affordable housing units within the Parish until 2013, This figure reflects the previous rate of development within the village of approximately 1 dwelling per year for the last 15 years of which 6 could be described as ‘affordable being semi-detached or terraced units. If the figure of 5 dwellings were to be rolled forward to 2025 this would lead to a need for approximately 17 new affordable dwellings, always assuming that the questionable method of such a “roll forward “ were an appropriate method of measuring future need. Therefore if the approach adopted by other Local Authority’s was used a case could be made for 17 new houses. By proposing to cater for all forms of housing in these 4th tier settlements that figure would undoubtedly increase, but to nowhere near the 99 suggested by the emerging options. In the Heversham Housing Survey of 2007 a further 10 households considered that either the whole household, or someone living within the household, needed to move within the Parish by 2013 .These figures were discussed at a Parish meeting at which there was clear majority agreement that the affordable homes and a smaller number of open market housing were required within the village. It was considered that a figure of 45 was hugely significant in terms of the impacts that it would have on the character , physical infrastructure, and social capacity of the village, and that the figure would need to be less than this to be able to be accommodated. A range of 25-30 is recommended, along with a request for the District Council to update its housing market and land availability evidence base before considering anything above this.

Conclusion
It is the group’s view that the Emerging Options document fails to provide a proper and balanced consideration of the scale of the identified local need within the village. The village no longer has a shop or Post Office and only a limited public transport service. Existing residents have to travel to either Milnthorpe or Kendal for their shopping and for other facilities and therefore have a high dependency upon the private car. It is also unsustainable, in terms of attempting to achieve the global and national priority to reduce carbon emissions and private car use, to allocate land for up to 99 houses in a village with so few facilities. This figure is greater than that proposed for Levens, Storth and Natland, all of which are Local Service Centres with a far greater range of services and facilities than Heversham and Leasgill. Quite simply the potential scale of the development proposed far exceeds that which is appropriate to meet the identified needs of the village, is incompatible with national and regional planning policy and does not reflect the characteristics and limited infrastructure of the village.

Peter Winter
Head of Planning Services
PFK Planning

Settlement Factfile: Strategic Employment Sites outside Kendal to serve Kendal

-

-

-

-

Support

The document rejects the development of employment sites in the vicinity of Jnc 36 of the M6 (site refs E59,E58,E9,EN18,E57,E56 and M7). The Parish Council has long regarded this high value landscape as unsuitable and unsustainable for development on the grounds of adverse landscape impact, lack of services and public transport. Consequently the Parish Council fully supports the conclusions of the Fact File.

Land Allocations Emerging Options Consultation Document *

Land Allocations Emerging Options Consultation Document *

20 and others (see below)

pg 20 - 2.44

Draft Policy G5 (and others relating to Green Infrastructure)

Support in part

Paragraph 2.44 - recommend additional wording as follows;

Where the policy refers to open space being redeveloped in only exceptional circumstances, Sport England would recommend that a distinction be made for the exceptions where playing fields will be allowed to be redeveloped as opposed to other typologies of open space. Paragraph 15 of PPG 17 recognises this distinction and sets out specific criteria that would need to be met to allow for development on a playing field, something which is supported by SE's playing fields policy. The distinction would make it clear that proposals affecting playing fields will be considered in this context.

Policy G5 Green Infrastructure (and others relating to green infrastructure) - recommend minor alteration to wording as follows;

'....safeguarded from development and where possible managed to enhance their....FORMAL and informal SPORT and recreation....importance'

The inclusion of the words 'formal' and 'sport' recognises the primary role of playing fields for formal outdoor sport in the context of the above policy and will help to protect these attributes.

Land Allocations Emerging Options Consultation Document *

3.5

Land Allocations Emerging Options Consultation Document *

9

Prioritisation - how do we allocate sites?

Oppose

FINDING AND PRIORITISING HOUSING SITES – THE BALANCE BETWEEN SETTLEMENTS
In his examination of the Core Strategy, the Inspector removed the specific development targets for individual settlements smaller than Principal Service Centres (PCSs) and replaced these with grouped targets. The Core Strategy sets the combined overall target for the three Key Service Centres of Grange, Kirkby Lonsdale and Milnthorpe, and the criteria for distributing development between them. This is reiterated in section 2.5 of The Land Allocations DPD.

The Inspector’s report following his examination of the Core Strategy states that: ‘more detailed work looking at balancing local needs and environmental capacities outside the PCSs can properly be conducted as part of the Allocations of Land DPD process’. The inspector’s report also states that ‘further detail will be necessary to firm up specific plans (for the Cartmel Peninsula) but in my mind the level of further detail necessary is more appropriate to the forthcoming Allocation of Land DPD’.

The Land Allocations DPD states that the distribution will be based on the following:
• The capacity of existing services to accommodate development;
• Critical thresholds for new service investment;
• Size, character and environmental capacity of the settlement;
• The need to secure regeneration or investor confidence.

The criteria used to identify those settlements that are designated as Key Service Centres are:
• Good public transport links to outlying settlements;
• A primary school, secondary school, library, doctor’s surgery and a town centre function providing at least a post office and 2,000 sq m of retail floorspace;
• A population of more than 1,500.

Grange Town Council believes that Grange is less able to manage development which is sustainable than the other Key Service Centres for a number of reasons, namely access to services, the infrastructure (especially the road network) and the impact on the viability and vitality of Grange. The Town Council is also concerned about the lack of assessment of flood risk in the settlement fact files, and the lack of proper community involvement in the assessment of viable development targets and in the preparation of the Land Allocations DPD.

The Sustainability Appraisal assesses sites solely against those within the same settlement. Grange Town Council believes that, in deciding the split of development between Kirkby Lonsdale, Milnthorpe and Grange, sites within all three Key Service Centres should be assessed against each other.

The relative ability of each Key Service Centre to cope with development should also be assessed in order to guide the development split between Grange, Milnthorpe and Kirkby Lonsdale, and should take account of the impact of development in smaller neighbouring settlements on each of the three Key Service Centres.

ACCESS TO SERVICES
Compared to the other Key Service Centres, Grange is significantly further from the following essential services:
• Hospitals
• Trunk road system
Both Kirkby Lonsdale and Milnthorpe are on an ‘A’ road; access to the A590 for the vast majority of residents in Grange, and from all of the proposed development sites, means negotiating the narrow roads of the town centre.
• Motorway
Grange is significantly further from the M6 than either Kirkby Lonsdale or Milnthorpe, and again most traffic accessing the M6 from Grange has to pass through the narrow town centre streets.
• Principal Service Centre
Grange is further from Kendal than Milnthorpe is, and is significantly further away from Lancaster, the nearest city, than either Milnthorpe or Kirkby Lonsdale is.
• Secondary School and FE College
Of the three towns designated as Key Service Centres, Grange is the only one which does not have a secondary school. The nearest secondary school is in Cartmel, 2 miles from Grange, with some secondary age pupils also attending Dallam School in Milnthorpe, Ulverston Victoria High School, Lancaster Boys’ Grammar School, Lancaster Girls’ Grammar School and Queen Elizabeth School in Kirkby Lonsdale.

There is no possible route from Grange to Cartmel (where the nearest secondary school is located) that does not involve using narrow, winding roads, very steep in parts, with an unrestricted speed limit.

A safe walking or cycling route to Cartmel school from Grange cannot be created, so secondary school age children living in Grange all require transport to get to and from school. Although standard practice is for free bus travel to be offered only to children who live three miles or more from school, children in Grange attending Cartmel school are offered free transport because of the lack of a safe route. Children undertaking after school activities are not catered for by school buses and require collection by private vehicle.

As well as secondary school facilities, the other two Key Service Centres each have sixth form colleges. Pupils living in the Cartmel peninsula area who wish to continue their education post 16 have to travel to Milnthorpe, Ulverston, Lancaster, Kirkby Lonsdale, Kendal or Barrow.

The lack of a secondary school and FE College in Grange means that any additional housing development will put far greater demand on the transport network than commensurate development in the other Key Service Centres. Whilst some of this demand might be met through improved public transport, it would lead to significant additional journeys by private car.

SUSTAINABLE DEVELOPMENT
The Land Allocations DPD states that, for Kirkby Lonsdale, ‘as many dwellings as possible (should be) within walking distance of the town centre.’
For Milnthorpe, the aspiration is for ‘new homes and workplaces ... within easy walking distance of the village centre.’
No such ambition is given for Grange, though the relative accessibility of sites in Kirkby Lonsdale and Milnthorpe compared with Grange points to the potential for more sustainable growth in the other Key Service Centres.

Grange is bordered on three sides by Morecambe Bay, the Lake District National Park and Hampsfell and steep, wooded hillsides which severely limit the number of possible development sites, particularly those within walking distance of the town centre.

The proposed sites on the outskirts of Grange are not within walking distance of the town centre, and will inevitably increase the amount of traffic on the Esplanade, Kents Bank Road, the Pig Lane one-way system and down Main Street. This contradicts CS4 which states that the Council and its partners will aim to ‘improve the pedestrian experience of Grange Town Centre’. These sites cannot be developed sustainably.

Sufficient sites have been identified for Kirkby Lonsdale and Milnthorpe in the Land Allocations DPD to meet their current indicative development targets twice over. All the emerging sites in Milnthorpe and Kirkby Lonsdale are within walking distance of shops and essential services, including a secondary school.

In Grange, all of the identified sites would need to be developed in order to meet the current indicative target, even though many of these sites cannot be developed as sustainably as those identified in the other Key Service Centres.

The topography of Grange is not considered in the Land Allocations DPD, though the very steep hills in the town mean that the town centre is not accessible either by bicycle or on foot from some of the proposed development sites. Development on these sites contradicts CS10.1 ‘Accessing services’ which states that the Council will work with partners to improve accessibility within and beyond the plan area (which) will centre on:
‘Promoting a network of safe cycle and walking routes linking residential areas with employment areas, town and local centres, schools, recreational open space and facilities’.
This is simply not achievable for some of the sites proposed in Grange because of the steepness of the inclines.

ROAD NETWORK
Grange Town Council has consistently expressed concern about the level of development outlined for the town, and the inability of the infrastructure to cope with the proposed increase.

Grange is a tourist town, and in the visitor season (which runs from April to October) there is a huge increase in traffic through the town centre. Large numbers of vehicles and caravans travel through Grange to access the caravan sites in the area, including a large caravan site in Flookburgh, which has over 800 static units and space for 50 tourers. The Holiday Property Bond development of the Merlewood site on Windermere Road will create more than 50 apartments and cottages, and bring additional traffic through the centre of town. Local events such as Cartmel Races, Holker Garden Festival and Cumbria Steam Gathering bring significant numbers of vehicles through the town, including many larger vehicles that cannot easily pass through the town’s narrow road system.

Any additional development in Grange, and in the nearby local service centres of Allithwaite, Cark, Flookburgh and Cartmel, will have to travel through Grange to reach the train station, the A590 and the M6 beyond. The Land Allocations DPD gives an indicative target for Grange of a further 501 dwellings between now and 2025. A further 306 dwellings are planned across the Cartmel Peninsula for the Local Services Centres, smaller centres and open countryside within this period.

Whilst the Core Strategy seeks to encourage additional public transport provision, which Grange Town Council supports, the rural nature of the Cartmel peninsula means that increases to the number of dwellings in the area will inevitably lead to increased car use.

CS5.12 notes that ‘Access into the peninsula is poor, limited mainly to the B5277/8 looping off the A590 to run through Grange, Allithwaite and Cark, the B6271 from Lindale and minor roads north of Cartmel’.

By contrast, the Core Strategy notes that the East (including Kirkby Lonsdale and Milnthorpe) ‘benefits from excellent strategic transport links’ (CS6.11) and that ‘the Key Service Centres (of Milnthorpe and Kirkby Lonsdale) are easily accessible by road’ (CS6.12).

CS5.13 notes that Grange ‘suffers from problems associated with the impact of the private car on the built environment. For pedestrians, the Grange-over-Sands environment is noticeably poor...footpaths are narrow and there is a strong sense that the car is the dominant feature on Kents Bank Rd and Main St’.

Extrapolating from the figures in the 2001 census for car and van ownership in the area, it is reasonable to assume an increase of at least 1.4 cars or vans for each additional household in the area. Developing 807 new dwellings in the Cartmel peninsula would therefore be likely to lead to more than 1130 extra vehicles in the peninsula, the vast majority of which would be regularly using the narrow and congested roads in Grange town centre to access essential services in the town and beyond.

There are currently 5 car parks in Grange, all operated by the district council. The town centre car parks are busy and well-used, with spaces often at a premium in the tourist season. Planning permission has been granted for redevelopment of 2 of the car parks in the town, which will reduce the numbers of car parking spaces available to visitors and residents. The planned developments (mixed development at Berners Close car park and old pool site, Booths supermarket at Windermere Road car park) will increase the demand for car parking spaces, and add to the volume of traffic through the town centre.

The Inspector’s report into the Core Strategy states in paragraph 6.5 that ‘where necessary, further assessment may be required to assess the scale of impact of proposed development sites on traffic levels in different settlements, most notably Ulverston and Grange over Sands where there are known traffic congestion issues’.

Within the Core Strategy itself, CS10.2 ‘Transport impact of new development’ states that development proposals will be considered against criteria, including the following:
‘The expected nature and volume of traffic generated by the proposal could be accommodated by the existing road network without detriment to the amenity and character of the surrounding area, local air quality or highway safety’ and
‘The proposal provides for safe and convenient access on foot, cycle, public and private transport, addressing the needs of all, including those with a disability’.

The Core Strategy Preferred Options document outlines the need for a Travel Assessment/Travel Plan for both ‘Land off Grange Fell Road’ and ‘Land at Kents Bank’. Grange Town Council believes that a comprehensive survey of traffic flows and congestion both within Grange and within the Cartmel peninsula as a whole are required as part of the Allocations of Land process.

The only developments in Local Service Centres which would be likely to impact on traffic levels in and through Milnthorpe are those at Arnside and Sandside/Storth.

Because of its location, there would be no likely additional traffic levels in Kirkby Lonsdale from developments in Local Service Centres.

In effect, the impact of the indicative development numbers for Kirkby Lonsdale would bring an increase in car numbers using the village of approximately 165, compared with additional car numbers accessing and travelling through Grange of 1130. This must be taken into account when deciding on the level of development that is sustainable for each of the Key Service Centres.

The problems associated with Grange’s highways infrastructure cannot be improved; the footpaths cannot be widened without narrowing the roads, and the roads, already too narrow to cope with current traffic levels, cannot be widened.

Whilst the Core Strategy gives an aspiration to improve the situation for pedestrians in Grange by ‘upgrading the promenade, rebuilding footbridges and developing new links’, these measures would have little impact on the effect of the car on the main shopping streets of Kents Bank Rd and Main St. Neither would they affect the increased vehicular traffic in town that would be a consequence of additional development in the Cartmel Peninsula.

IMPACT ON VIABILITY OF GRANGE
Grange relies on tourism to maintain its viability and vitality. The Core Strategy notes that ‘Tourism is a fundamental part of the local economy’ (CS5.7). CS4 (Cartmel Peninsula) states that the Council and its partners will ‘Maintain and enhance the strength of tourism across the area’.

The Core Strategy accepts that Grange currently suffers from the impact of private cars, and this already has a considerable bearing on the attractiveness of the town to tourists. Alongside significantly higher car use and congestion in the town centre, the proposed levels of development will damage what Grange has to offer tourists by impacting negatively on the quality of the landscape surrounding the town centre. This is itself contrary to CS4.5. By contrast, Milnthorpe’s economy does not rely on tourism, so increasing the planned level of development in this area will not damage the core economy of the town.

The April 2008 version of the Core Strategy Preferred Options gave the population of Milnthorpe as 2,106. This figure is taken from the 2001 census, which gives an equivalent household figure of 921 (from the Key Figures for Milnthorpe ward in the 2001 census). The household figure now provided by the Development Plans Team for Milnthorpe, which has been used to set the current indicative target, is the smaller figure of 761, giving a smaller ‘pro rata’ development target for the town. It appears that different boundaries for Milnthorpe are now being used compared to 2008 Core Strategy Preferred Options, though no explanation has been given for this change.

FLOODING
The flooding assessments in the Sustainability Appraisal take no account of flooding from surface water run-off. The most recent flooding in the town (late summer 2008) was caused solely by run-off. The Environment Agency notes that ‘Surface Water Flooding...is much more difficult to predict and pinpoint...than river or coastal flooding.’

Risk of flooding from run-off should be considered fully, alongside EA flood risk zones. It is unacceptable, in an area with Grange’s topography and recent history of flooding from surface water, to take no account of this risk to proposed and existing dwellings when outlining possible development sites. Local knowledge regarding incidents of flooding from run-off should be sought in order to understand properly the current risk, and the likely impact of further development.

NEIGHBOURHOOD PLANNING
The Localism Bill sets out the intention for Local Planning Authorities to work with communities to produce Neighbourhood Plans. Grange Town Council accepts the need for some development in the town, to meet the need for affordable housing. The current Development Plan is being imposed on communities by the District Council, and there is no evidence that responses to earlier rounds of consultation have influenced the current Land Allocations documents.

Grange Town Council considers the Core Strategy to be an urban based model, which doesn’t fit a rural area like Grange and the Cartmel Peninsula.

Grange Town Council would like to work with the District Council to develop a Neighbourhood Plan that involves meaningful engagement with the local community.

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67

Draft Policy G1

Oppose

The Town Council does not consider the proposed sites adjoining the development boundary to be suitable sites for development. The distance from these sites to town centre facilities would result in considerable additional traffic on the already congested town centre roads. Additional concerns are provided in the response to ‘Draft Policy G3 Land for New Housing in Grange-over-Sands’.

Land Allocations Emerging Options Consultation Document *

67

Draft Policy G2

Support

The Town Council considers the proposed town centre area to be suitable as the preferred location for key town centre uses including offices, leisure, and food and drink.

Land Allocations Emerging Options Consultation Document *

68

Draft Policy G3

Oppose

The Town Council does not accept that the level of development outlined for the town is sustainable, and believes that the district council should work with local communities and town and parish councils to develop a neighbourhood plan. The Town Council has specific objections to the following areas of land outlined in the Allocations of Land DPD:

RN34 – Land North of Grange Fell Road
The Town Council is strongly opposed to development on this site. During earlier rounds of consultation, the Town Council opposed development on these fields and supported local residents’ request that this land be designated as Important Privately-Owned Open Space. The Town Council supports the view of local residents that this land should not be developed, for the following reasons:
• Increased flooding risk to other properties.
In the settlement fact file for this site, the comment from SLDC’s Environment Protection Team notes ‘Surface water from hills. Possible culverts crossing site. The more development there is in this part of Grange, the more drainage problems there will be in future’. The site visit notes ‘There are surface water issues on this site.’ Given that the site lies on the lower slopes of Hampsfell and above the town, any development on these fields is likely to have a significant effect in terms of increasing flood risk below the site. There are underground springs in the area, which already cause subsidence to the road surface.
• The impact on the attractiveness of Hampsfell to tourists and residents, in an area of the town that already has high population density.
The site visit notes ‘Site would form an extension into very open countryside and an historic limestone landscape. The setting of the listed field barn immediately north of the site would be negatively affected if (this site were) developed.’

R89 – Land North of Carter Road
The Town Council is opposed to development on this site, for the following reasons:
• In previous plans this site’s designation for residential development was withdrawn.
• There are issues relating to drainage (the settlement fact file notes the presence of limestone beneath the surface) which have not been investigated sufficiently.
• The Douglas Wheeler Regeneration Study of 2007 (which is a key source of evidence in the Core Strategy) concludes that ‘residential development of (this) site is likely to be controversial because of the Greenfield nature of the site’.

Land Allocations Emerging Options Consultation Document *

69

Draft Policy G4

Support

EEA4 - Station Yard
The Town Council agrees that this site should be safeguarded as an existing employment area.

EN34M – Land Adj Station Yard
The Town council agrees that this site is suitable as a local employment site.

Land Allocations Emerging Options Consultation Document *

70

Draft Policy G5

Support

R381, R383, M378M - Berners Pool
The Town Council agrees that these sites should be allocated for the mixed uses identified in the Land Allocations Development Document, namely Residential, Employment, Health Care and Leisure.

Land Allocations Emerging Options Consultation Document *

71

Draft Policy G5

Oppose

M25M - Land at Allithwaite Road
The Town Council is opposed to development on this site, for the following reasons:
• The large scale of the site.
• Use of the site by wildlife has not been properly explored.
• There are issues relating to drainage (the settlement fact file notes the presence of limestone beneath the surface) which have not been investigated sufficiently.

Given the large size of this site and its deliverability, Grange Town Council believes that if this site were to be developed, the target for affordable dwellings on the site should be increased above the minimum 35%.