Response from Mrs Margot Harvey (Individual)
1. Mrs Margot Harvey (Individual) : 14 Apr 2011 23:55:00
Or, other document if it does not appear in the list above
All documents including the LAD
Page
Various
Paragraph no.
Various
Do you support, oppose or support in part this section of the document
Support in part
Please explain your reasons
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.