1481 responses.
1. Dr Henry Adams (Individual) : 17 Apr 2012 16:33:00
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Policy/Site No.
LA2.4 Land at Kendal Parks
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
The DPD has not had regard to the Sustainable Community Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
This refers to R107M & R150M - fields on East side of Kendal Parks
These fields should not be built on because they form part of the obvious natural physiographic boundary of Kendal as they form the lower slopes of the Eastern valleyside of the Kent valley.
This landscape importance has been over-ridden by the SLDC.
Other facts relating to the steepness have also been given inadequate consideration:
Loss of privacy and quality of life to those inhabiting existing houses along the foot of the slope.
These points are described and illustrated here: http://www.southlakeland.gov.uk/LDFDocuments/AdamsH_EM414_210411.pdf
Local democracy has also been over-ridden - over 94% of Hayclose Crescent residents I contacted objected to development here (49 out of 52 households objected, 2 of the remainder were temporary residents).
It appears that the main reason for selection of these fields for housing is because they are available for purchase by developers who have expressed an interest in building on them.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Answer as 1.3 above.
I agree with / endorse what has been written by Richard Pearse of the Friends of the Lake District on this site.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
Inadequate weight has been given to the points I made in my submission http://www.southlakeland.gov.uk/LDFDocuments/AdamsH_EM414_210411.pdf
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2. Dr Henry Adams (Individual) : 17 Apr 2012 16:47:00
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Policy/Site No.
LA1.9 Green Gaps between - KENDAL and OXENHOLME
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
The DPD has not had regard to the Sustainable Community Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The Kendal-Oxenholme Green Gap should be kept as Green Gap.
I have described and illustrated the importance of the Strawberry field lapwing site and its environs in the following document but this has been ignored or over-ridden by recent SLDC decisions: http://www.dragonfly1.plus.com/LetterHenryAdamsToSLDCreStrawberryFieldandLapwings2011.pdf and http://www.southlakeland.gov.uk/LDFDocuments/AdamsH_EM414_210411.pdf
I agree with the thorough submissions by Dennis Reed for Green Spaces Committee and Richard Pearse of Friends of The Lake District.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
As for 1.3 above:
The Kendal-Oxenholme Green Gap should be kept as Green Gap.
I have described and illustrated the importance of the Strawberry field lapwing site and its environs in the following document but this has been ignored or over-ridden by recent SLDC decisions: http://www.dragonfly1.plus.com/LetterHenryAdamsToSLDCreStrawberryFieldandLapwings2011.pdf and http://www.southlakeland.gov.uk/LDFDocuments/AdamsH_EM414_210411.pdf
I agree with the thorough submissions by Dennis Reed for Green Spaces Committee and Richard Pearse of Friends of The Lake District.
3. Dr Henry Adams (Individual) : 17 Apr 2012 16:54:00
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Paragraph No.
0.0 Whole Document
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
As regards the green spaces on the edge of Kendal such as the Kendal-Oxenholme Green Gap and the fields along the East edge of Kendal Parks Estate (& estate to North) the DPD is in accordance with the draft NPPF in respect of it being a "developers charter" but does not comply with the recently published NPPF (27th March 2012) in which environmental, landscape, wellbeing, green space values are given consideration.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
As 1.3 above
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
4. Dr Henry Adams (Individual) : 16 May 2012 15:48:00
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I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - R107M mod and R150M KENDAL KENDAL PARKS
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
The DPD has not had regard to the Sustainable Community Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
This refers to R107M & R150M - fields on East side of Kendal Parks
These fields should not be built on because they form part of the obvious natural physiographic boundary of Kendal as they form the lower slopes of the Eastern valleyside of the Kent valley.
This landscape importance has been over-ridden by the SLDC.
Other facts relating to the steepness have also been given inadequate consideration:
Loss of privacy and quality of life to those inhabiting existing houses along the foot of the slope.
These points are described and illustrated here: http://www.southlakeland.gov.uk/LDFDocuments/AdamsH_EM414_210411.pdf
Local democracy has also been over-ridden - over 94% of Hayclose Crescent residents I contacted objected to development here (49 out of 52 households objected, 2 of the remainder were temporary residents).
It appears that the main reason for selection of these fields for housing is because they are available for purchase by developers who have expressed an interest in building on them.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Answer as 1.3 above.
I agree with / endorse what has been written by Richard Pearse of Friends of the Lake District on this site.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
Inadequate weight has been given to the points I made in my submission
http://www.southlakeland.gov.uk/LDFDocuments/AdamsH_EM414_210411.pdf
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
5. Mr and Mrs P. Alaimio (Individual) : 19 Apr 2012 16:00:00
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Policy/Site No.
LA1.3 Housing Allocations - RN121M-mod LEVENS FORMER POULTRY SHEDS, BRIGSTEER ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not been prepared in accordance with the Town & County Planning Regulations 2004 (as amended)
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Parish Council was remiss in suggesting in their letter to SLDC that a change of use would be appropriate on land in the vicinity of the old chicken farm. Particularly as they made no effort to seek the views of those who live closest to the site.
No vote took place, 'comments' made, not explored in formal discussions or documentation.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Parish Council minutes 172/11 makes it clear that no vote took place & their letter 27/9/11 to SLDC made comments on individual sites even though they clearly found the issue too difficult to discuss and vot on. Local opposition against the development is strong & clear from the number of signatures we have.
Contents of attached letter as follows:
I am writing this letter in the hope that it will oppose the residential development planned at the site of the old poultry farm RN121M -mod in Levens.
I am a resident in this northern part of the village, and have lived here with my family, husband and two sons for fifteen years. I have raised my sons here in the confidence that we are safe to use our road, Brigsteer Road which leads out of this cul de sac.
My concern is increased traffic, large heavy goods vehicles using a narrow lane, parts of it only wide enough for one car. My sons are older and not at home full time, but learning to drive etc. causes them concerns. There are now two new families here with very young pre-school of primary school age children, who will be at risk on the road, as well as our older adults who use the road to walk for exercise & dog walkers, it is very popular. It is pitch black here in winter, there are no street lights for trucks to see pedestrians easily. The cycle route runs through here also & is well used.
Sizergh Fell Road, leads onto the A590 where traffic moves very fast to the roundabout, there have been numerous accidents as vehicles cross the dual carriageway at the Heaves Hotel. Local people know not to use the steep road up past the Heaves in winter when it is icy as it is not passable, causing cars to skid and get stuck.
The prospect of a building site with the above traffic risks fills me with horror, the roads, lanes are unsuitable. Deer cross and stand on the back roads past Heaves Farm, the area is beautiful, and the wildlife show us this.
I feel it is a misguided decision to build these houses, the land is meant for a small rural type of business, which is what local people were expecting.
I hope you will take my views & concerns into account.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
6. Mrs Thelma Aldridge (Individual) : 24 Apr 2012 16:22:00
Policy/Site No.
LA2.13 Mixed Use Allocation at Green Dragon Farm, Burton-in-Kendal
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
BURTON IN KENDAL / HOLME DEVELOPMENT FRAMEWORK
Please find my following comments / objections to your final draft proposal for the above LDF.
- Burton is a village, the proposal area (MN26#-Mod) at Dragon Green Farm for a mixed residential / employment site places industrial units in the heart of the village which is against government guidelines for preserving rural areas.
- Employment sites suitable for further development already exist at Dalton Hall, Clawthorpe Hall, Moss End Farm and the ideally located "NEW" Agricultural Quarter at the junction where the A6070 joins the A65. There is no need for further employment sites within Burton and Holme!
- I know of no other new areas where such a close mix of residential / employment sites has been successfully established. Homes and industrial units DON'T MIX. What about safe access for families and allowing children to play normally, not just in designated areas.
The proposal for (MN26# - Mod) shows 92 homes plus employment units, that means in excess of 138 parking places for vehicles - there is nowhere else in the village! What about garden space? Burton is a village and development should be in keeping with the existing environment. The build density for this proposal is back to the estates of the 1960s which have now been replaced.
Burton in Kendal infrastructure is NOT SECURE for the development of a further 146 houses.
- Main Street, Barker Terrace and Tanpits Lane are still subject to flooding during heavy rainfall
- Run-off water already causes man-hole covers to partially lift at the top of Neddy Hill during heavy rainfall
- Water treatment works serving Burton and Holme has not been upgraded to deal with additional build
- Burton Morewood School is already full
- Pedestrian access from the South (MN26#) and from the North (R76M) is already dangerous with a suitable footpath existing in some places on only one side of the road and by the church, no footpath at all.
146 new homes in Burton increases the size of the village by 710% - I would suggest this is over-development.
There is no demand in the village for 146 affordable houses. Where is this demand coming from? Windermere, Bowness, the Lake District National Park should be required to sort themselves out - not impose their requirements on others
7. Mrs Thelma Aldridge (Individual) : 24 Apr 2012 16:32:00
Policy/Site No.
LA1.3 Housing Allocations - All Burton-in-Kendal sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Burton in Kendal infrastructure is NOT SECURE for the development of a further 146 houses.
- Main Street, Barker Terrace and Tanpits Lane are still subject to flooding during heavy rainfall
- Run-off water already causes man-hole covers to partially lift at the top of Neddy Hill during heavy rainfall
- Water treatment works serving Burton and Holme has not been upgraded to deal with additional build
- Burton Morewood School is already full
- Pedestrian access from the South (MN26#) and from the North (R76M) is already dangerous with a suitable footpath existing in some places on only one side of the road and by the church, no footpath at all.
146 new homes in Burton increases the size of the village by 710% - I would suggest this is over-development.
There is no demand in the village for 146 affordable houses. Where is this demand coming from? Windermere, Bowness, the Lake District National Park should be required to sort themselves out - not impose their requirements on others
8. Dr Gillian Allder (Individual) : 11 Apr 2012 16:34:00
Policy/Site No.
LA1.3 Housing Allocations - M38M BURNESIDE LAND OPPOSITE HOLME HOUSES
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I would like to lodge my complaint that the proposed development of the above site does not go ahead.
I have a number of objections:-
1) The field is in a trust named the Willink trust for the use of the people who live in Burneside. It cannot be used for any other purpose, bar recreational. If it was to be used to build upon, the people of Burneside must vote on this. It is NOT for the trustees to decide. They do not have a balanced view.
2)There are very few playing fields left in Burneside. This being one of the last. The building of houses by the Youth Club has already reduced the area for play dramatically. The youth of Burneisde are able to play freely on this field without being a member of any club.
3) Due to the decreased area of field, there is decreased absorption of water. This means there will be more run off and more flooding. Burneside already has a problem with flooding and sewage due to ancient sewers. Obviously this will make the matter 10 times worse.
4) The river Kent in Burneside is home to the White clawed crayfish. This is its last stronghold left in Europe. If there is more run off into the river, which WILL be the case if more land is developed, more pollution will get into the river. The white clawed crayfish are very susceptible to pollution, and further building in Burneside could endanger the crayfish further. We also believe there are several types of bat living and breeding in and around this site which are also protected.It is believed that Great crested newts inhabit this area too.
Due to all the above points I would like to question the soundness of the proposal to build in the areas of M38M and SF32.
9. Dr Gillian Allder (Individual) : 11 Apr 2012 16:46:00
Policy/Site No.
LA1.10 Existing Green Infrastructure
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I would like to lodge my complaint that the proposed development of the above site does not go ahead.
I have a number of objections:-
1) The field is in a trust named the Willink trust for the use of the people who live in Burneside. It cannot be used for any other purpose, bar recreational. If it was to be used to build upon, the people of Burneside must vote on this. It is NOT for the trustees to decide. They do not have a balanced view.
2)There are very few playing fields left in Burneside. This being one of the last. The building of houses by the Youth Club has already reduced the area for play dramatically. The youth of Burneisde are able to play freely on this field without being a member of any club.
3) Due to the decreased area of field, there is decreased absorption of water. This means there will be more run off and more flooding. Burneside already has a problem with flooding and sewage due to ancient sewers. Obviously this will make the matter 10 times worse.
4) The river Kent in Burneside is home to the White clawed crayfish. This is its last stronghold left in Europe. If there is more run off into the river, which WILL be the case if more land is developed, more pollution will get into the river. The white clawed crayfish are very susceptible to pollution, and further building in Burneside could endanger the crayfish further. We also believe there are several types of bat living and breeding in and around this site which are also protected.It is believed that Great crested newts inhabit this area too.
Due to all the above points I would like to question the soundness of the proposal to build in the areas of M38M and SF32.
10. Mr Neil Alldridge (Individual) : 15 Apr 2012 21:16:00
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I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - All Allithwaite sites
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The inclusion of field R339 in its entirety (part of field RN73 was included originally) was not included in the original consultation, and therefore was not up for objection at the earlier stages of this process. The above field (R339) was not shown as part of the consultation at any of the public meetings held in the village(RN73was objected too at all the consultations in the village by myself and others).Indeed the inclusion of R339 was only included in the final submission from Allithwaite Parish Council due to a pressure group seeking to divert inclusion of the fields they were objecting too(RN290 and others). It is against the soundness of the proposal to run a series of consultations, then to change the basis of these consultations at the last minute. Thus depriving the public of the full information available to decision makers and therefore skewing the process in favour of a desired outcome.It should be noted that several other areas were included for possible development in the original plans and that almost none of these actually made it to the final document, other sites being included instead with similar backgrounds to my objection.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
11. Mr Neil Alldridge (Individual) : 11 May 2012 16:01:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - R339# ALLITHWAITE LAND SOUTH OF GREEN LANE
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The inclusion of field R339 in its entirety (part of field RN73 was included originally) was not included in the original consultation, and therefore was not up for objection at the earlier stages of this process. The above field (R339) was not shown as part of the consultation at any of the public meetings held in the village(RN73was objected too at all the consultations in the village by myself and others).Indeed the inclusion of R339 was only included in the final submission from Allithwaite Parish Council due to a pressure group seeking to divert inclusion of the fields they were objecting too(RN290 and others). It is against the soundness of the proposal to run a series of consultations, then to change the basis of these consultations at the last minute. Thus depriving the public of the full information available to decision makers and therefore skewing the process in favour of a desired outcome.It should be noted that several other areas were included for possible development in the original plans and that almost none of these actually made it to the final document, other sites being included instead with similar backgrounds to my objection.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
12. Mr Neil Alldridge (Individual) : 11 May 2012 16:05:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
1.9
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The inclusion of field R339 in its entirety (part of field RN73 was included originally) was not included in the original consultation, and therefore was not up for objection at the earlier stages of this process. The above field (R339) was not shown as part of the consultation at any of the public meetings held in the village(RN73was objected too at all the consultations in the village by myself and others).Indeed the inclusion of R339 was only included in the final submission from Allithwaite Parish Council due to a pressure group seeking to divert inclusion of the fields they were objecting too(RN290 and others). It is against the soundness of the proposal to run a series of consultations, then to change the basis of these consultations at the last minute. Thus depriving the public of the full information available to decision makers and therefore skewing the process in favour of a desired outcome.It should be noted that several other areas were included for possible development in the original plans and that almost none of these actually made it to the final document, other sites being included instead with similar backgrounds to my objection.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
13. Mr Neil Alldridge (Individual) : 17 May 2012 11:15:00
Policy/Site No.
LA1.3 Housing Allocations - R339# ALLITHWAITE LAND SOUTH OF GREEN LANE
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I have fought to keep this field green for over forty year and again I will try again to
keep this green field.
This field is the only green field here; over the past forty years the village has grown
too big to be a village. Templand Park, Greendales, High cliff drive, Mayshelles
orchard, uplands fellside, Jack hill, Hazledene, plus in fill. Farm buildings and shops
have been converted to dwellings and shops. In Allithithwaite we have one shop/post
office which services this area.
The proposed dwellings on filed number R319, between Green lane and boarbank
lane, would increase traffic and parking, which there are already problems with on
these 2 roads, the sewerage system is old and would be inadequate for another 22
dwellings.By building on this land would be taking away residents on Green lane
and Boarbank roads only green field.
We are asking that other land be considered on the right hand side of Holme lane
fields NO RN230 AND RN65, the reason we ask for this land to be considered is
there is better access for cars it would mean traffic would not be brought threw the
centre of the village passed the school reducing the risk of accidents.
My final point is the village has already expanded and is now bigger than a village
yet it has no business to offer employment to people from the village, so to increase
housing without the facilities such as jobs would be of no benefit to the village.
I do understand there is a shortage of housing within this area, and many others in
the country, but rather than just build housing for the sake of building I would ask that
they be built on suitable sites with the least impact on the present residents.
14. Mr Neil Alldridge (Individual) : 17 May 2012 11:17:00
Policy/Site No.
LA1.3 Housing Allocations - Site Omission
If you have selected a ‘Site omission’ please enter the site reference or location and relevant policy below
Site omission - RN230
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I have fought to keep this field green for over forty year and again I will try again to
keep this green field.
This field is the only green field here; over the past forty years the village has grown
too big to be a village. Templand Park, Greendales, High cliff drive, Mayshelles
orchard, uplands fellside, Jack hill, Hazledene, plus in fill. Farm buildings and shops
have been converted to dwellings and shops. In Allithithwaite we have one shop/post
office which services this area.
The proposed dwellings on filed number R319, between Green lane and boarbank
lane, would increase traffic and parking, which there are already problems with on
these 2 roads, the sewerage system is old and would be inadequate for another 22
dwellings.By building on this land would be taking away residents on Green lane
and Boarbank roads only green field.
We are asking that other land be considered on the right hand side of Holme lane
fields NO RN230 AND RN65, the reason we ask for this land to be considered is
there is better access for cars it would mean traffic would not be brought threw the
centre of the village passed the school reducing the risk of accidents.
My final point is the village has already expanded and is now bigger than a village
yet it has no business to offer employment to people from the village, so to increase
housing without the facilities such as jobs would be of no benefit to the village.
I do understand there is a shortage of housing within this area, and many others in
the country, but rather than just build housing for the sake of building I would ask that
they be built on suitable sites with the least impact on the present residents.
15. Mr Neil Alldridge (Individual) : 17 May 2012 11:18:00
Policy/Site No.
LA1.3 Housing Allocations - Site Omission
If you have selected a ‘Site omission’ please enter the site reference or location and relevant policy below
Site omission - RN65
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I have fought to keep this field green for over forty year and again I will try again to
keep this green field.
This field is the only green field here; over the past forty years the village has grown
too big to be a village. Templand Park, Greendales, High cliff drive, Mayshelles
orchard, uplands fellside, Jack hill, Hazledene, plus in fill. Farm buildings and shops
have been converted to dwellings and shops. In Allithithwaite we have one shop/post
office which services this area.
The proposed dwellings on filed number R319, between Green lane and boarbank
lane, would increase traffic and parking, which there are already problems with on
these 2 roads, the sewerage system is old and would be inadequate for another 22
dwellings.By building on this land would be taking away residents on Green lane
and Boarbank roads only green field.
We are asking that other land be considered on the right hand side of Holme lane
fields NO RN230 AND RN65, the reason we ask for this land to be considered is
there is better access for cars it would mean traffic would not be brought threw the
centre of the village passed the school reducing the risk of accidents.
My final point is the village has already expanded and is now bigger than a village
yet it has no business to offer employment to people from the village, so to increase
housing without the facilities such as jobs would be of no benefit to the village.
I do understand there is a shortage of housing within this area, and many others in
the country, but rather than just build housing for the sake of building I would ask that
they be built on suitable sites with the least impact on the present residents.
16. Mr and Mrs David and Emma Andrews (Individual) : 9 May 2012 15:56:00
Policy/Site No.
LA1.3 Housing Allocations - M41KM KENDAL SOUTH OF LUMLEY ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I am writing again to object to the proposed allocation of land for development to the south of Lumley Road (M41KM (please refer to origianl letter sent may 2008). Also I am objecting to the proposed allocation of land for development E4M. I do not consider the proposed alocations to be 'sound'.
The development of land M41KM and E4M will ruin the presently rural and attractive feel of the main A6 route as it enters this historical market town. Kendal is named the 'Gateway to the Lakes'; it is a vibrant heritage town. With this development its unique rural character will be much diminished.
The surrounding landscape in addition to the specific site allocations would be greatly affected. The A6 is already severely congested at certain times of the day - highway capacity and safety are two major issues that would have to be addressed with disastrous consequences for this very green edge of town. Inevitablty there would be a massive negative impact on the local wildlife and ecology.
These developments would be extremely detrimental to the reality of Kenal as the gateway to the world-famous Lake District National Park - Kendal our historiacl market town, visited by thousands of tourists every year, enjoying its rural, traditional feel set within a beautiful landscape.
I cannot see any changes which would make these proposed land allocations for development 'sound' other than for them to be deleted from the Land Allocations DPD.
17. Mr and Mrs David and Emma Andrews (Individual) : 9 May 2012 15:57:00
Policy/Site No.
LA1.6 Strategic Employment Sites - E4M KENDAL LAND AT SCROGGS WOOD, MILNTHORPE ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I am writing again to object to the proposed allocation of land for development to the south of Lumley Road (M41KM (please refer to origianl letter sent may 2008). Also I am objecting to the proposed allocation of land for development E4M. I do not consider the proposed alocations to be 'sound'.
The development of land M41KM and E4M will ruin the presently rural and attractive feel of the main A6 route as it enters this historical market town. Kendal is named the 'Gateway to the Lakes'; it is a vibrant heritage town. With this development its unique rural character will be much diminished.
The surrounding landscape in addition to the specific site allocations would be greatly affected. The A6 is already severely congested at certain times of the day - highway capacity and safety are two major issues that would have to be addressed with disastrous consequences for this very green edge of town. Inevitablty there would be a massive negative impact on the local wildlife and ecology.
These developments would be extremely detrimental to the reality of Kenal as the gateway to the world-famous Lake District National Park - Kendal our historiacl market town, visited by thousands of tourists every year, enjoying its rural, traditional feel set within a beautiful landscape.
I cannot see any changes which would make these proposed land allocations for development 'sound' other than for them to be deleted from the Land Allocations DPD.
18. Ms Marian Armstrong (Individual) : 30 Mar 2012 10:11:00
Policy/Site No.
LA1.3 Housing Allocations - All Levens sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I would like to register that I am in agreement with points raised at a recent meeting of Levens Residents Group in connect on with the Development Plan.
I endorse the points made at this meeting
As far as grounds of soundness (raised at that meeting and outlined in South Lakeland News Spring 2012) it concerns me that a great deal is left to conjecture on a long-term scale on the soundness of this plan.
It seems to rely too heavily on the speculation of potential contractors for the building of affordable houses (subject to the take- up executive, full cost housing) giving too little attention to employment availability in the locality and thus the possibility to find sufficient people who will be in a position to qualify to benefit. Considering the economic uncertainty within the time scale how likely are local independent builders to be in a position to undertake this sort of commitment. Surely this will play into the hands of larger contractors who can afford to speculate and invest long term. This does not seem to me to engage the desired spirit of encouraging local people and would seem likely to miss an opportunity to provide much desired employment prospects.
19. Mr Roger Atkinson (Individual) : 4 May 2012 14:05:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - R170M-mod KENDAL NORTH OF LAUREL GARDENS
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Site R170M Middle Sparrowmire I'
This site has also been referred to,· in various documents, as The Todds I
and Land north of Laurel Gardens
I
Green Gap.
In 1996 the land now denoted as site R170M had already been designated as
part of a· Green Gap by SLDC. In his report, at that time, on the public
enquiry into South Lakeland Local Plan 2006 the inspector, Patrick T
Whitehead, said in his Inspectors Conclusions, and in answer to Mr. F
Downham, whose objection requested that site R170M should be removed ·
from the Green Gap.
Inspectors Conclusions:
6.9 The objection by Mr Downham is not concerned with. the provision of a
green gap, but the extent ofthat gap. It is argued that the green gap, as
shown in the Consultation draft of the Plan, follows a public footpath
running between substantial hedges, a clearly defmed landscape boundary:
whilst the residential allocation at Sparrowmire has been reduced in the · ·
Deposit Draft, an equivalent extension to the green gap is not necessary~
However, and most importantly in my view, the objection indicates that the
"land should remain unallocated as white land so that when the plan is·
reviewed in 10 years time· it can be considered as potential residential/and".
I consider this underlying reason for excluding the land from the green .
gap identifies the very reason it should remain so designated. Structure
Plan Policy 14 and the reasoried justification make no reference to the length
of time during which the vulnerable areas of countryside between
settlements should be protected. Although policies and proposals in the
Local Plan must clearly relate to the Plan period, and can be subject to
review thereafter, it appears to me common sense that what is
unacceptable now, will most probably be equally unacceptable at the
end ofthe Plan period: ·certainly I consider the Plan should seek to
engender a degree of public confidence that the separation secured will
not at some future time, be lightly squandered. For those reasons I believe
that, where a green gap is seen as necessary, it is more important that the
whole gap between settlements should be designated as green gap than that ·
the substantial, but arbitrary landscape features should be rigidly followed. I
also consider the inter-visibility of settlements is not a factor which should
affect the definition of green gaps.
Where, in his conclusions, the Inspector states that "what is unacceptable
now, will most probably be unacceptable at the end of the Plan period"
and that the Plan should "engender a degree of public confidence that the
separation secured will not at some future time, be lightly squandered"
he makes a point which will ring true to most of the 98% of3000
respondents who were against the LA DPD and even more so to the
394voterswho were against the inclusion of site R170M in the LADPD at
the last round of consultations.
Paragraph 20 of the well respected Taylor Report is also heavily critical of
building on land such as site Rl70M Middle Sparrowmire stating that ·
houses will be built "on exactly the land of most value to the existing
community"
In the doeumentSouth Lakeland Local Plan 2006, SLDC state:"
In these "Green Gaps" development will not be permitted unless:"
(b) ·"It does not cause significant harm to the open.character of the ''Green
Gap" area;" The development of site R170M will cause significant harm to
this open first rate agricultural land.
SLDC's Local Development Framework, Core Strategy states that Green
Gaps "Contribute to maintaining a settlement's identity, landscape setting
and character.'' "Compromise predominantly open land maintaining an
'open' aspect." And "Where possible afford recreational and biodiversity
opportunities". Site Rl 70 M Middle Sparrowmire ·fulfills all these conditions
and to include it in the LA DPD is both unsound and totally against the
spirit of the Local DevelopmentFramework.
As SLDC has made no apparent effort to justify their inclusion of site
R170M in the. present LA DPD or outline their thought processes and
reasons for doing so I would ask them to do so before the document is
subject to a Public Enquiry.
I am convinced that, in view of the above, the decision to include site
R170M in the LA DPD is unsound.
Traffic.
The proposed entrance to site R170M from the C class Burneside Road,
opposite the entrance to the popular Carus Green Golf Club and onto a bend
will be a junction with severely limited visibility, in both directions, and
restricted visibility, for drivers on Burneside Road, of standing traffic .
waiting to turn in to the new development. This, along with the additional
traffic on an, in places, narrow road which is heavily used by school children
and pedestrians as well as commercial vehicles will create an unnecessarily
hazardous highway.
The additional traffic generated by the development of Middle Sparrowmire
and the other proposed sites in Bumeside will add to the, already
unacceptable, and worsening, traffic congestion and pollution at the
Wmdermere Road/Burneside Road junction and consequently onto the other
unacceptable"Red Junctions" in the market town of Kendal. The SLDC
commissioned Atkins Report also considered this development
inappropriate; these facts make the development of site R170MMiddle
Sparrowmire unsound and also raises the question. Why commission a
report and:tben ignore it?
Sewerage.•
By delaying the proposed starting date for the development of site R170M
SLDC have acknowledged that the sewers which would serve the. site, and
the proposed sites in the village ofBurneside, are already at full capacity and
all too often overflowing. There .is also a plan to separate the ''run oft" water
fromroofs, roads and drives frorrithe foul water drain system. The task of
increasing the capacity of the foul water sewers and providing a new system
for the "run off1 water would require an immense financial investmentfor
which United Utilities will have to apply for funding and it is hard to
imagine this funding being readily available in the present fmancial
situation. Furthermore the cost of a civil engineering project on this scale
would surely add such an amount to the cost of each home as to make them
unaffordable and undeliverable. This again makes the inclusion of site
R170M in the LA DPD unsound . .
Flooding.
The north east corner of site R170M has a history of flooding; there are also
several springs and' other boggy areas on the proposed site. The Environment
Agency commented, when advising against the use of this site, that it has
"Surface water issues, due to limited capacity of the water course on the
eastern boundary and inadequate culvert capacity''.
Several houses close to the north east comer of the site have flooded in
recent years, a phenomenon which has only occurred since Briery Meadows
was built.
The proposed. separate "run off' drainage scheme will also add to the
flooding problems in the nearby River Kent, . ·
All the above points are either adding cost, or making the site unsuitable for
building, and therefore making its inclusion in the LA DPD unsound and
undeliverable;
Kendal Town Council's "Response to Consultation" April2011.
In this considered and thoughtful document Kendal Town Council,
representing the people of Kendal, point out, on page 8, that the 2009 SLDC
commissioned Atkins report, Kendal Transport Assessment stated "the
existing highway network plus proposed .improvements would just about
accommodate the. forecast levels oftraffic provided three sites were
removed" KTC then point. out that. The Todds west ofBurneside Road was
one of the three sites and was not temoved.KTC then point out, on page 12, ·
that site R170M Land North of Laurel Gardens has major problems under
their dependency headings of Traffic, Hydro and Sewer. Another example of
commissioning. a report and then ignoring it, and again highlighting the
unsoundness of site R170M's inclusion in the LA DPD.
General Comments.
We are being told by Councilors who are promoting this housing .plan that it
is the right plan for South Lakeland. I would question this. by saying that
they have only considered land which is readily available to develop, that is
to say, land where the owner is already a developer or a willing vendor. This
indicates to me that SLDC have not taken a wider view and considered
reasonable alternative options, where housing development would be of
the greatest benefit to the population of South Lakeland, and where such
developments would cause the least traffic congestion, pollution, visual
intrusion, destruction of green gaps and prime agricultural land. This "easy
option" approach to the LA DPD brings into question the legal compliance
and soundness of the whole document.
I ask that I may both appear and speak at any public hearing or enquiry which may be called.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
To communicate the depth of feeling against the LA DPD and SLDC's high handed treatment of the local population.
20. Sir Christopher Audland (Individual) : 19 Apr 2012 14:06:00
Policy/Site No.
LA1.3 Housing Allocations - RN140 MILNTHORPE LAND AT OWLET ASH FIELDS, ACKENTHWAITE
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
My representations relate to two specific proposals. First, to the proposal for new affordable housing at Site RN 140; and second, to the proposal for new business and industrial land adjacent to the Mainline Industrial Estate by Milnthorpe Station (Site E13M-mod). I submit separate notes for each site (attached).
My understanding of the wording of the AOL DPD is that, when the formal consultation period ends, the Council will consider the representations received and submit the Document to the Secretary of State for Independent Examination by a Planning Inspector whose job it will be to consider whether the document is sound. I should be grateful for confirmation that the 3 attachments to this message will at the same time be submitted to the Inspector. And I should welcome confirmation that there will be an opportunity for me to speak about these matters at the Public Inquiry.
1. Paragraph 3.68 of the DPD states that 'this small, overgrown site (RN 140) adjacent to the existing housing estate at Owlet Ash fields offers the opportunity for a small affordable housing development. The site has been unused for some years and investigation of its wildlife importance will be necessary. There may be opportunities for habitat creation as part of the development.'
2. I submit that this proposal is neither justified nor effective.
Lack of justification
3. So far as justification is concerned, the proposal is totally in conflict with several important policy statements contained in the same DPD, which are recalled below.
4. The DPD declares, in its paragraph 1.5., that the objective of this plan is to deliver the vision and objectives set out in the Council's adopted Core Strategy and help to make South Lakeland the best place to live, work and visit by identifying and setting the key development requirements for 6 matters: one of these is to maintain Green Gaps to prevent settlements losing their identity. In its paragraph 2.21, the DPD clearly states that 'Sites are excluded from allocation' for development if they breach certain criteria: these include cases where development would compromise an identified Green Gap, as would be the case here.
5. Paragraph 3.66. of the DPD states that 'Milnthorpe lies very close to the adjoining settlement of Ackenthwaite and continued development at Dallam School and recent development on the north side of Ackenthwaite mean that there is a risk of these settlements coalescing and Ackenthwaite losing its separate identity. For this reason, a Green Gap is identified separating Milnthorpe and Ackenthwaite.' One would have thought that this argument alone would be sufficient to eliminate RN 140 from consideration. But, without further explanation, the same paragraph goes on to argue that 'The existing Green Gap boundaries identified in the old South Lakeland Local Plan have been reviewed having regard to the criteria set out in Paragraph 2.39 and changes have been made to remove some areas that do not perform a visual or functional separation.' In fact, paragraph 2.39 is completely irrelevant as it deals uniquely with 'the need to retain Strategic Employment Sites and Business/Science Park sites in employment use'. So what was the true basis of the review?
7. In paragraph 3.66 of its earlier 'Emerging Options Consultation Edition' of January 2011, SLDC argued that changes had been proposed to this particular Green Gap 'to remove some areas that do not perform a visual or functional separation'. This position is totally illogical. The whole area of RN140 consists of grass land, large bushes or trees. If that does not constitute visual or functional separation, what does?
8. The DPD sets out, in its paragraph 3.61, what SLDC considers to be the key local factors influencing the location of new development in Milnthorpe. These include the following: 'avoiding coalescence with the neighbouring settlements of Heversham [and] Ackenthwaite'.
9. Policy CS5, dealing specifically with Milnthorpe, states that there should be 'a series of green gaps to prevent the coalescence of individual settlements and thereby protect their individual character and setting'.
10. Policy CS8.2, on the protection and enhancement of landscape and settlement character, states that 'development will be supported within green gaps where it is essential for the needs of agriculture, forestry, and local community infrastructure and where it cannot be located elsewhere'. Only the last of these 4 consideranda could possibly be held to apply to Owlet Ash Fields. But I cannot believe there is nowhere else in South Lakeland where there is room for this small number of affordable houses.
11. Until recently there was a green gap of some 200 metres between the Owlet Ash Fields Estate and the nearest Dallam School building. In 2005, however, SLDC permitted Dallam School to build a new Sports Centre, which reduced the gap by 63 metres. If the new development were permitted, the gap between the developed site and the Sports Centre would then be a mere 67 metres. This is clearly not enough.
12. The Monitoring Framework envisaged in the DPD states that there is 'a target of a Zero reduction in extent of green gaps allocated in the Document'.
13. In short, the proposal is not justified.
Lack of Effectiveness
14. Another point - not even mentioned in the DPD - is the question of vehicular access to the proposed housing development site.
15. It must surely not be acceptable to consider routing such traffic through the Dallam School grounds.
16. There is no practicable access between the existing houses in Owlet Ash Fields. The largest gap between properties along the west edge of the estate is just south of No 66: it is 2.4. metres wide.
17. The only remaining approach would be to the north of the row of houses numbered 72-76. It has been suggested to me that the garage NE of that row could be removed; and that the road and pavement there could then be extended, north of the group, by digging into the steeply rising bank of earth, and building a support wall to retain what remained. I consider that this would sharply reduce the quality of life for the occupants of these houses. Their backyards (on the north side) are shallow, having a maximum depth of 5 metres. Instead of looking out onto a green bank, with bushes behind, their back gates would open directly onto a pavemented road, across which they would see a brick or stone bank some 2 metres high.
18. In short, the proposal could not reasonably be implemented, and should therefore be deleted from the DPD.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
21. Sir Christopher Audland (Individual) : 19 Apr 2012 14:13:00
A typed or handwritten document was submitted. This has been scanned and can be downloaded below:
Policy/Site No.
LA1.8 Local Employment Allocations - E13M MILNTHORPE LAND ADJ MAINLINE BUSINESS PARK
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
My representations relate to two specific proposals. First, to the proposal for new affordable housing at Site RN 140; and second, to the proposal for new business and industrial land adjacent to the Mainline Industrial Estate by Milnthorpe Station (Site E13M-mod). I submit separate notes for each site (attached).
With regard to Site E13M-mod, I also attach a photograph of the Site, to which the relevant note makes reference, and which therefore forms part of my representations.
My understanding of the wording of the AOL DPD is that, when the formal consultation period ends, the Council will consider the representations received and submit the Document to the Secretary of State for Independent Examination by a Planning Inspector whose job it will be to consider whether the document is sound. I should be grateful for confirmation that the 3 attachments to this message will at the same time be submitted to the Inspector. And I should welcome confirmation that there will be an opportunity for me to speak about these matters at the Public Inquiry.
The Proposal
Paragraph 3.64 of the DPD is misleading when it suggests that the Mainline Business Park is in the tiny hamlet of Deepthwaite. It lies within the boundary of Milnthorpe Civil Parish.
Paragraph 3.70 of the DPD reads as follows. 'There is a significant area, around 12.44 ha of land adjacent to the existing Mainline Business Park off the B 6385 Milnthorpe-Crooklands road next to the West Coast Main Line railway. This area is visually contained, has relatively level topography and could accommodate a significant amount of new employment development including B8 employment uses. Major development here would need to provide for improvements to the Canal crossing at Crooklands.'
Comments
I submit that this proposal is not justified.
Policy CS8.1 on green infrastructure provides that 'the Core Strategy will seek to … protect the countryside from inappropriate development whilst supporting its positive use for agriculture, recreation, biodiversity, health, education and tourism.' None of these 6 factors for supporting development is relevant in the present case.
Paragraph 2.42 of the DPD states as follows. 'Based on employment land needs identified in the South Lakeland Employment Land and Premises Study, the Core Strategy identifies a need for the development of 4 hectares (ha) per annum of employment land between 2010 and 2025, a total of 60 ha.'
Paragraph 2.43 argues that 'New employment allocations are needed, to provide a supply of land and premises to ease the very low vacancy rates currently experienced in South Lakeland.' Comment. Whatever the overall vacancy rates may be, in the Milnthorpe area, substantial areas of existing development land are currently unused. These include large parts of both the Mainline Estate and also of the recently authorised Parkhouse Lakeland Industrial Estate.
Paragraph 2.43 goes on to allocate the 60 ha. It provides for an employment site in Milnthorpe of 4.5 ha. Comment. It is not clear, therefore, why SLDC considers that Milnthorpe, besides supplying an additional 1 ha. at the Site adjacent to Bridge End Business Park (Site M9M1-Mod), and a small amount of land by the Dallam Sawmill (Site EN17M), should be called upon to produce a further 12.44 ha adjacent to the Mainline Site.
The SLDC's 'Emerging Options Paper' of 2011 envisaged that just one more field, of 6.37 ha., would be made available for Business Development there, adjacent to the Mainline Estate and alongside the railway. Now, the DPD - without further explanation - envisages a further one & a half fields being made available, running east from the original field and down to the banks of Stainton Beck, which in fact constitutes the Parish Boundary. The total area has thus nearly doubled.
Comment. The statement that this area is 'visually contained' is very misleading. It is true to a certain extent of the existing Mainline site, because a drumlin lies along its eastern edge. But the drumlin does not extend far enough south to cover the proposed new development land at all. As a result, the large buildings to be expected on the site would be prominent from the eastern skyline (Scout Hill & Farleton Knot). Farleton Knot - it should be noted - is much used by walkers & horseriders, who revel in the wonderful views from its peak. Much of the proposed new development land would also be highly noticeable from stretches of the M6, from Overthwaite Farm, and from parts of Whasset & Holme. Some of the buildings - if of comparable size with the larger ones on the existing Mainline Site - would even be visible from the B 6385 road running towards Crooklands.
So large an extension of the Mainline Site would also add substantially to the gradual industrialisation of the hitherto pleasant, drumlin-studded valleys of the River Bela, and its tributaries, Stainton Beck and Peasey Beck. This process started with the creation of Libby's Milk Factory in the 1930's. The surrounding Mainline Estate was developed soon after WW2 (the Second World War). The process of industrialisation continued with the creation of the Industrial Estate at Elmsfield, some years ago, which is just over 1 km. south of Mainline. The process is currently being furthered by the building of the 'Auction Mart Site' - which is in fact a large Agri Industrial Estate - at Moss End, less than 2 kms to the east. I would recommend that the Inspector views this complex of sites, for himself, from Farleton Knot, before deciding whether this proposal is sound.
The visual impact of the proposed extension is very clear from the attached photograph. It was taken by myself, on 18 March, 2012, from the western cairn on the summit of Farleton Knot. The Mainline site, and the existing J T Leyland Industrial Site (just west of the railway), are both clearly visible towards the top of the photo, in front of the hamlet of Ackenthwaite. The proposed new development would take in the brown fields to the left of the Mainline Site, and also half of the field to the right of the nearer one.
Conclusion
To sum up. Milnthorpe was required to find 4.5 ha. of employment land. Over 1 ha. will be provided in the two village sites. Even the 6.37 ha. originally envisaged for addition to the Mainline Site would take Milnthorpe well over its ration. No good arguments have been adduced by SLDC for increasing this particular allocation. On the other hand, the damage to the pleasant countryside alongside the banks of the Bela and its tributaries would be massive. In my submission, therefore, the proposal is not justified, and SLDC should be required to revert to its original proposal for a single field addition to the site.
Following my email to you of 19 March (with its attachments), I now wish to submit further representations to SLDC regarding the Allocations of Land DPD.
My further representations relate to the proposal for new business and industrial land adjacent to the Mainline Industrial Estate by Milnthorpe Station (Site E13M-mod). Please find these further representations attached.
1. Since my earlier comments on this proposal were made, it has become apparent to me that there are strong objections - additional to the ones I already advanced - to the proposed doubling of the area of the Mainline Industrial Estate, namely objections in terms of access to the proposed extension.
2. The only comment relating to access made in the DPD, is to indicate that major development in the area concerned 'would need to provide for improvements in the Canal crossing at Crooklands'. While this is true - and the interpretation of the word 'improvements' should certainly be filled out before any land is allocated by SLDC for development - it is very far from being the only access problem.
3. It has now come to my attention that there is apparently no path available for traffic, entering or leaving the proposed new area for development, through the existing Mainline Estate. The thinking apparently is, that a new road would be created, which would leave the B 6385 some 70 metres NE of the easternmost access to the Mainline Estate, and therefore right on the dangerous blind corner at that point.
4. Such a road - which would have to run some 300 metres over open fields to reach the site - should presumably be wide enough for incoming and outgoing HGV's to pass each other. Given that the maximum width of an HGV is 2.75 metres, the carriageway would need to be at least 7 metres broad in order to be safe. Presumably there would also be need for a footpath. This road would be running right along the crest of the drumlin, whose existence has always been represented by Planning Authorities as protecting the Mainline Estate from viewers to the east.
5. It must also be borne in mind that the creation of a junction between the access road and the B 6385 would be a major undertaking. As the junction would be on the blind corner, there would clearly be a need for traffic lights, or alternatively a full roundabout.
6. To anyone travelling from Milnthorpe in an easterly direction, this roundabout would follow what is already a very dangerous stretch of road. Some 90 metres after passing over the top of the blind railway bridge, the driver of a vehicle is confronted, on his/her right side, by no less than 6 successive access roads, over a distance of just over 200 metres (the 1st being to the VOSN site, and then 5 more to the Mainline Estate). I am advised that there have been 3 accidents in this short section in the past year, fortunately without any serious injury.
7. A final important consideration is that - even if the Crooklands Canal crossing were improved - most HGV's leaving the new site for Ulverston or Barrow, would be far more likely to drive through Ackenthwaite and Milnthorpe, to reach the A 590 at Levens, than to take the much longer route via Crooklands, the M6 Exit 36 roundabout, and the A 590, via Brettagh Holt roundabout. This extra traffic would of course further incommode the inhabitants of Ackenthwaite and Milnthorpe.
8. To conclude - in the light of these additional considerations about access - I would urge that not even the single field originally proposed should be allocated for development, and still less the 2 ½ fields now under discussion.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
22. Mr and Mrs David and Janet Austin (Individual) : 4 May 2012 14:51:00
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I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - RN121M-mod LEVENS FORMER POULTRY SHEDS, BRIGSTEER ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not been prepared in accordance with the Town & County Planning Regulations 2004 (as amended)
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The existing roads are not adequate for the additional traffic that would be generated and the site is composed of steep ground and existing woodland. The site was originally proposed for light industrial use and I would see no objection to returning the site to that purpose. The site as a whole is completely impractical for the building of 23 houses and nothing can alter this fact. Scrap the proposal!
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The DPD is not justified in this area in that one third of the propsed land for development is not available and therefore I would say it is not possible to put 23 houses on the site. I would also mean what amounts to building a settlement on the outskirts of the village i.e. another village!! The size and steepness of the site means that the plan is not deliverable.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
23. Dr Robert Aylmore (Individual) : 16 Apr 2012 20:01:00
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I have read the guidance notes
Policy/Site No.
LA1.1 Development Boundaries- PENNY BRIDGE/GREENODD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Site Ref RN152 is not appropriate for housing development for the following reasons:
- The land is known to be part of a natural drainage channel. Problems with drainage are well known with many properties downhill of the site suffering standing water and flooding after significant rainfall. Disturbance to the water course by building is likely to create further problems with water run-off and the properties erected on the site may suffer from flooding and dampness.
- The sewerage infrastructure in Penny Bridge and Greenodd (upstream on the new treatment works) is inadequate for current needs. Addition of new-build housing will only exacerbate this existing and serious deficiency.
- The village school and pre-school already run at their nominal capacity with little capacity for expansion.
- Building on the site with completely change the character of the adjacent church, limiting views destroying the rural atmosphere.
- The demand for this level of development in the village has yet to be rigorously established. Job creation in the locality is severely limited and many properties within the area have remained unsold for extended periods.
- Traffic increase during construction and occupation of the new properties will add to the existing problems of access and parking within the Penny Bridge and Greenodd villages.
- The land is not an 'infill' site as stated being on the edge of the village with only the church grounds separating it from agricultural pasture land.
THIS PLOT IS ENTIRELY INAPPROPRIATE FOR HOUSING DEVELOPMENT.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
24. Dr Robert Aylmore (Individual) : 15 May 2012 14:19:00
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I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - RN152 GREENODD LAND AT THE OLD VICARAGE
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Site Ref RN152 is not appropriate for housing development for the following reasons:
- The land is known to be part of a natural drainage channel. Problems with drainage are well known with many properties downhill of the site suffering standing water and flooding after significant rainfall. Disturbance to the water course by building is likely to create further problems with water run-off and the properties erected on the site may suffer from flooding and dampness.
- The sewerage infrastructure in Penny Bridge and Greenodd (upstream on the new treatment works) is inadequate for current needs. Addition of new-build housing will only exacerbate this existing and serious deficiency.
- The village school and pre-school already run at their nominal capacity with little capacity for expansion.
- Building on the site with completely change the character of the adjacent church, limiting views destroying the rural atmosphere.
- The demand for this level of development in the village has yet to be rigorously established. Job creation in the locality is severely limited and many properties within the area have remained unsold for extended periods.
- Traffic increase during construction and occupation of the new properties will add to the existing problems of access and parking within the Penny Bridge and Greenodd villages.
- The land is not an 'infill' site as stated being on the edge of the village with only the church grounds separating it from agricultural pasture land.
THIS PLOT IS ENTIRELY INAPPROPRIATE FOR HOUSING DEVELOPMENT.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
25. Ms E Baber (Individual) : 17 Apr 2012 11:59:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
0.0 Whole Document
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The DPD has not been prepared in accordance with the Town & County Planning Regulations 2004 (as amended)
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
SLDC used the company arc4 to do their research for them - they in turn came up with the SHMA report.
arc4 website states they use Household surveys & a range of data including 2001 census etc. They also state that they regularly organise focus group discussions with local residents!!!!!
I checked some of their data in their Draft Report & was most surprised to find omissions of important data, local knowledge not being taken into account, basic mathematical errors & incorrect copying of numbers from research documents.
1. HOUSEHOLDS SURVEYED - Table A2 response rates - arc4 states 26%, this figure only represents the percentage of contacted household returns. The true figure of 9.53% has been omitted.
2. RESIDENT NUMBERS - 2001 census = 102,283 - ONS 2009 mid year population estimates = 103,800 (approx 1,520 population growth in 7/8 years) SHMA survey (9.53% grossed)= Table B3 - 107,873 or Table B6 - 107,861. which would mean there has been 4,000+ population growth in 2 years!
Much of the research seems to rely on the 2011 household survey, I think this proves that the base figures are unreliable & therefore UNSOUND.
3. LOCAL KNOWLEDGE - Table B7 Overseas nationals applying to work in SLDC 2005/6 - 2009/10 annual average = 842. This figure cannot possibly be considered as 2005-2008/9 there was a huge influx of overseas nationals to work on the cockle beds when there was a 'glut' of cockles. This can clearly be seen in Table B7 data.
4. MATHEMATICAL ERRORS - Table B3 Tenure & Age Profile - All Residents percentage totals have been incorrectly calculated (basic maths) - Table B8 Economically Active 76.3 + 4.5 does not = 79.8!
Tables B8-B9-B10 Three different Base Figures have been used for the Economically Active a difference of 4000+ between lowest & highest base figures!
5. COPYING DATA - Table B18 Newbuild activity states Source: CLG Housing statistics Table 253. These tables state 1090 completions in 6 years. arc4 states = 1084!
6. MORE INCORRECT STATEMENTS - Table B18 Newbuild activity, arc4 state that over the period 2005/6 to 2009/10 completions have averaged 166 each year - using their figures the average is 176 (another mathematical error) arc4 states that their figure is at odds with local sources, surely someone should have checked these simple mistakes!
The need for housing has been based on arc4 research, on the basis of the above I regard the whole SHMA Document to be UNSOUND. Land Allocations have been based on this document - need I say more!
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
26. Mr Richard Bagguley (Individual) : 17 Apr 2012 16:51:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - R81 ARNSIDE REDHILLS ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not had regard to the Sustainable Community Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Changes are needed in order to comply with the NPPF. There is a lack of sound evidence in the current DPD which does not comply with SLDC's core strategy.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
1.The Land allocated is a green field site which has been accorded 'Important Open Space' status within the AONB for many years.The SLDC proposal has failed to explain or justify its significant policy change notwithstanding 'the highest level of protection'accorded such sites.
2. The SLDC has not given consideration/priority to brown field sites in the land allocations as could reasonably be expected by not only the residents but also visitors and be demanded of the managers,custodians and guardians of the area.
3. The SLDC has given little or no consideration for the impact of their proposals on the importance of the land to the local community or the tourism trade given the strategic position of the land and its use as a currently picturesque route to and from Arnside Knott.
4. The SLDC has failed to demonstrate how it will deliver on the need for affordable rented social housing and maintain that provision. Past experience questions the local authority's ability to maintain its commitment in this regard.
The SLDC has failed to demonstrate anything other than minimal need and certainly not 'exceptional need' for market housing
5.We have carefully considered and agree with the comments and objections raised by and on behalf of the Arnside Parish Plan Trust and Arnside Parish Council.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
27. Mr Richard Bagguley (Individual) : 8 May 2012 15:08:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - All Arnside sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
2. The SLDC has not given consideration/priority to brown field sites in the land allocations as could reasonably be expected by not only the residents but also visitors and be demanded of the managers,custodians and guardians of the area.
3. The SLDC has given little or no consideration for the impact of their proposals on the importance of the land to the local community or the tourism trade given the strategic position of the land and its use as a currently picturesque route to and from Arnside Knott.
4. The SLDC has failed to demonstrate how it will deliver on the need for affordable rented social housing and maintain that provision. Past experience questions the local authority's ability to maintain its commitment in this regard.
The SLDC has failed to demonstrate anything other than minimal need and certainly not 'exceptional need' for market housing
5.We have carefully considered and agree with the comments and objections raised by and on behalf of the Arnside Parish Plan Trust and Arnside Parish Council.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
28. Mr Richard Bagguley (Individual) : 8 May 2012 15:12:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
0.0 Whole Document
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not had regard to the Sustainable Community Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Changes are needed in order to comply with the NPPF. There is a lack of sound evidence in the current DPD which does not comply with SLDC's core strategy.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
29. Mr Arthur Baldry (Individual) : 1 May 2012 14:05:00
Policy/Site No.
LA1.3 Housing Allocations - All Grange-over-Sands sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Re : 500 New Houses in Grange over Sands
Grange does not need the planned additional 500 new homes thrust upon it by SLDC . It
should be allowed to develop organically protected by the old planning rules that have
served and protected it so well in the past.
The town has kept its character, primarily as a holiday/retirement town, and, as such, has
not developed any other industry. SLDC should be promoting it as such, not trying to
change it into a 'run of the mill' dormitory town.
The concept of building 325 houses to help fmance 175 affordable ones makes no sense
at all. It would be preferable for the government to help finance housing projects in the
areas where they are actually needed, i.e. near to centres of industry, close to the
motorways and on the many rundown and brown field sites in towns and cities which are
in urgent need of regeneration.
I am sure that you have heard all the arguments against the building of so many houses,
such as road access and lack of suitable infrastructure many times.
I have not yet spoken to one person who is in agreement with the SLDC plans.
Please listen to the electorate and fight the plans.
30. Mr Arthur Baldry (Individual) : 4 May 2012 13:19:00
Policy/Site No.
LA3.1 Mixed Use Allocation at Berners Pool, Grange-over-Sands
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Re : 500 New Houses in Grange over Sands
Grange does not need the planned additional 500 new homes thrust upon it by SLDC . It
should be allowed to develop organically protected by the old planning rules that have
served and protected it so well in the past.
The town has kept its character, primarily as a holiday/retirement town, and, as such, has
not developed any other industry. SLDC should be promoting it as such, not trying to
change it into a 'run of the mill' dormitory town.
The concept of building 325 houses to help fmance 175 affordable ones makes no sense
at all. It would be preferable for the government to help finance housing projects in the
areas where they are actually needed, i.e. near to centres of industry, close to the
motorways and on the many rundown and brown field sites in towns and cities which are
in urgent need of regeneration.
I am sure that you have heard all the arguments against the building of so many houses,
such as road access and lack of suitable infrastructure many times.
I have not yet spoken to one person who is in agreement with the SLDC plans.
Please listen to the electorate and fight the plans.
31. Mr Arthur Baldry (Individual) : 4 May 2012 13:20:00
Policy/Site No.
LA3.2 Mixed Use Allocation at Land South of Allithwaite Road, Kent's Bank, Grange-over-Sands
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Re : 500 New Houses in Grange over Sands
Grange does not need the planned additional 500 new homes thrust upon it by SLDC . It
should be allowed to develop organically protected by the old planning rules that have
served and protected it so well in the past.
The town has kept its character, primarily as a holiday/retirement town, and, as such, has
not developed any other industry. SLDC should be promoting it as such, not trying to
change it into a 'run of the mill' dormitory town.
The concept of building 325 houses to help fmance 175 affordable ones makes no sense
at all. It would be preferable for the government to help finance housing projects in the
areas where they are actually needed, i.e. near to centres of industry, close to the
motorways and on the many rundown and brown field sites in towns and cities which are
in urgent need of regeneration.
I am sure that you have heard all the arguments against the building of so many houses,
such as road access and lack of suitable infrastructure many times.
I have not yet spoken to one person who is in agreement with the SLDC plans.
Please listen to the electorate and fight the plans.
32. Mr Arthur Baldry (Individual) : 4 May 2012 13:22:00
Policy/Site No.
LA3.3 Mixed Use Allocation at Guide's Lot, Grange-over-Sands
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Re : 500 New Houses in Grange over Sands
Grange does not need the planned additional 500 new homes thrust upon it by SLDC . It
should be allowed to develop organically protected by the old planning rules that have
served and protected it so well in the past.
The town has kept its character, primarily as a holiday/retirement town, and, as such, has
not developed any other industry. SLDC should be promoting it as such, not trying to
change it into a 'run of the mill' dormitory town.
The concept of building 325 houses to help fmance 175 affordable ones makes no sense
at all. It would be preferable for the government to help finance housing projects in the
areas where they are actually needed, i.e. near to centres of industry, close to the
motorways and on the many rundown and brown field sites in towns and cities which are
in urgent need of regeneration.
I am sure that you have heard all the arguments against the building of so many houses,
such as road access and lack of suitable infrastructure many times.
I have not yet spoken to one person who is in agreement with the SLDC plans.
Please listen to the electorate and fight the plans.
33. Mr Niven Ballantyne (Individual) : 16 Apr 2012 16:47:00
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I have read the guidance notes
Policy/Site No.
LA2.15 Housing Site at Milnthorpe Road, Holme
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I refer to the property,Greystone,Milnthorpe Road Holme LA61PX.The property was originally included for housing development as shown in Plan R653M but after consultation in July 2011 was removed and is excluded from the revised Plan R653M-mod.I note however that two neighboring properties,Laurel Bank and Rosecroft have their gardens joined in an area for the development of 72 houses which would obviously impact on my property which backs on to Rosecroft.The gardens sit on higher ground and any development in the gardens as envisaged would have a detrimental impact on me.
The National Planning Policy Framework deals specifically with 'garden grabbing' and I would refer you to paras 48 and 53 of the document which states that Planning Authorities should resist inappropriate development of residential gardens which clearly this is .Hence, the land allocations referred to above should be removed in order that the DPD is legally compliant.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
If my recommendation re garden development is not accepted then I would wish to present my case direct with the Inspector
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
34. Mr Niven Ballantyne (Individual) : 8 May 2012 17:03:00
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I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - R653M-mod HOLME EAST OF MILNTHORPE RD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I refer to the property,Greystone,Milnthorpe Road Holme LA61PX.The property was originally included for housing development as shown in Plan R653M but after consultation in July 2011 was removed and is excluded from the revised Plan R653M-mod.I note however that two neighboring properties,Laurel Bank and Rosecroft have their gardens joined in an area for the development of 72 houses which would obviously impact on my property which backs on to Rosecroft.The gardens sit on higher ground and any development in the gardens as envisaged would have a detrimental impact on me.
The National Planning Policy Framework deals specifically with 'garden grabbing' and I would refer you to paras 48 and 53 of the document which states that Planning Authorities should resist inappropriate development of residential gardens which clearly this is .Hence, the land allocations referred to above should be removed in order that the DPD is legally compliant.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
If my recommendation re garden development is not accepted then I would wish to present my case direct with the Inspector
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
35. Mrs Daphne Banks (Individual) : 3 May 2012 15:36:00
Policy/Site No.
LA1.3 Housing Allocations - R121M-mod KENDAL EAST OF CASTLE GREEN ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The Land Allocations Document (DPD) is not within the Local Development Scheme and the key stages have not been followed
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
1. The policy set out in former LDS's (199, 2006, 2008) to preserve Kendal's eastern hilsides as visual assets has been ignored.
2. Recent consultation procedure has been followed but the outcome rejected (400 against inclusion of R121, 2 for, plus objections from Friends of the Lake District, Wild Life Organisations adn Kendal town Council). Solution: Omit R121, use brown-field sites and create new settlements.
Please omit site R121 from the DPD. I would welcome more use of empty properties, brown-field sites, or out-of-town sites, where a vibrant new settlement could be created (Taylor Review, 2011 for market towns).
The National Planning Policy Framework March 26th 2012 states that a LDS must:
1. take into account the wishes of a local community (400 against R121, 2 supporters)
2. benefit the community; Kendal's projected housing need has halved to 205p.a. - do we need these expensive houses?
3. be encouraged to use 'brown' sites over green fields.
4. preserve green corridors, open spaces and landscapes - a lovely approach to kendal would be lost.
5. preserve agricultrual land - today the fields have sheep and lambs.
6. protect sits of specific interest, even if not designated; the area is home ot the great crested news and uncommon birds.
7. not build on flood-prone land; the site has numerous springs, drainage of which would seriously imbalance the current Stock Beck scheme.
8. always consider the well-being of all residents; there would be pollution and traffic danger to Oaktree Road.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
36. Mrs Daphne Banks (Individual) : 4 May 2012 15:37:00
Policy/Site No.
LA1.3 Housing Allocations - All Kendal sites
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The Land Allocations Document (DPD) is not within the Local Development Scheme and the key stages have not been followed
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
1. The policy set out in former LDS's (199, 2006, 2008) to preserve Kendal's eastern hilsides as visual assets has been ignored.
2. Recent consultation procedure has been followed but the outcome rejected (400 against inclusion of R121, 2 for, plus objections from Friends of the Lake District, Wild Life Organisations adn Kendal town Council). Solution: Omit R121, use brown-field sites and create new settlements.
Please omit site R121 from the DPD. I would welcome more use of empty properties, brown-field sites, or out-of-town sites, where a vibrant new settlement could be created (Taylor Review, 2011 for market towns).
The National Planning Policy Framework March 26th 2012 states that a LDS must:
1. take into account the wishes of a local community (400 against R121, 2 supporters)
2. benefit the community; Kendal's projected housing need has halved to 205p.a. - do we need these expensive houses?
3. be encouraged to use 'brown' sites over green fields.
4. preserve green corridors, open spaces and landscapes - a lovely approach to kendal would be lost.
5. preserve agricultrual land - today the fields have sheep and lambs.
6. protect sits of specific interest, even if not designated; the area is home ot the great crested news and uncommon birds.
7. not build on flood-prone land; the site has numerous springs, drainage of which would seriously imbalance the current Stock Beck scheme.
8. always consider the well-being of all residents; there would be pollution and traffic danger to Oaktree Road.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
37. Mrs Daphne Banks (Individual) : 4 May 2012 15:43:00
Policy/Site No.
LA1.4 - Kendal Sites
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The Land Allocations Document (DPD) is not within the Local Development Scheme and the key stages have not been followed
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
1. The policy set out in former LDS's (199, 2006, 2008) to preserve Kendal's eastern hilsides as visual assets has been ignored.
2. Recent consultation procedure has been followed but the outcome rejected (400 against inclusion of R121, 2 for, plus objections from Friends of the Lake District, Wild Life Organisations adn Kendal town Council). Solution: Omit R121, use brown-field sites and create new settlements.
Please omit site R121 from the DPD. I would welcome more use of empty properties, brown-field sites, or out-of-town sites, where a vibrant new settlement could be created (Taylor Review, 2011 for market towns).
The National Planning Policy Framework March 26th 2012 states that a LDS must:
1. take into account the wishes of a local community (400 against R121, 2 supporters)
2. benefit the community; Kendal's projected housing need has halved to 205p.a. - do we need these expensive houses?
3. be encouraged to use 'brown' sites over green fields.
4. preserve green corridors, open spaces and landscapes - a lovely approach to kendal would be lost.
5. preserve agricultrual land - today the fields have sheep and lambs.
6. protect sits of specific interest, even if not designated; the area is home ot the great crested news and uncommon birds.
7. not build on flood-prone land; the site has numerous springs, drainage of which would seriously imbalance the current Stock Beck scheme.
8. always consider the well-being of all residents; there would be pollution and traffic danger to Oaktree Road.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
38. Mrs Maureen Barber (Individual) : 25 Apr 2012 12:05:00
Paragraph No.
7.1 General Comment
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I feel that it is beyond the competence of the ordinary individual to comment on the
"soundness" or otherwise of this long and complex consultation process.
May I however express my thanks that the special nature of Bardsea Green
RN102 has been recognised and hopefully protected.
39. Mr and Mrs David and Julie Barker (Individual) : 4 May 2012 15:53:00
Policy/Site No.
LA1.3 Housing Allocations - R121M-mod KENDAL EAST OF CASTLE GREEN ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
R121M (housing) and R141 (access to housing):
We object to the proposed Land Allocation submission with regard to the above sites, deeming it to be unsound for the following reasons:
1) The site was deemed worthy of County Landscape designation in 1999, and SLDC's Local Plan of 2006 stated that "Development of higher hillsides further east (of R56) would be unduly prominent".
SLDC has subsequently stated that "Changing circumstances need to be taken into account. Past planning decisions may not be relevant ..." However, the site's prominance is unchanged and we have seen no firm evidence that the 60 houses proposed could not be relocated elsewhere in the 19 possible development sites with less landscape damage. Without such evidence available to the community, the claim of changed circumstances is unsound, in our opinion.
2) The map apparently continues to misrepresent the size of ponds, the gully, reed beds and the full extent of watercourses during high rainfall periods. The sumbission is unsound without an accurately plotted and labelled plan available for consultation.
3)There seems to be no fully detailed access proposal across site R141 with some vagueness about the width of Oak Tree Road. Being too narrow for 2-way traffic at its present 'nub end' a firm viable proposed alternative link road and junction with an existing road should be in the public domain.
4) There seems to be no firm proposal for extra foot / cycle access points from other roads. We consider these important for safety for a fairly isolated and potentially trapped community - e.g. if police had to close the road in an emergency - of 60 houses which otherwise have only one way in and out via a longish, presumably fenced or walled access road across a field to Castle Green Lane. There other access points would then need to be in the DPD and available for consultation and risk assessment. (e.g. if such an access was onto Sedbergh Road there would be an issue with the blind bend and lack of pavement)
5) The flooding and landslip risk due to run-off and springs on all the steep land below the main railway does not seem to have sound evidence of its assessment. In particular Prof. R Jackson's expert report apparently contains recommendations which have not been carried out.
Please could you confirm that these observations will be brought to the attention of the Inspector who will be appointed to review the process.
40. Mr and Mrs David and Julie Barker (Individual) : 4 May 2012 15:56:00
Paragraph No.
1.9
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
We object to the proposed Land Allocation submission with regard to the above sites, deeming it to be unsound for the following reasons:
- If the Friends of the Lake District (CPRE) and Kendal Town Council (Galpin) reports were not accepted as part of the evidence base, the local community would not seem to have been fairly consulted
41. Mrs Jacqueline M Barnfield (Individual) : 24 Apr 2012 09:57:00
Paragraph No.
5.21
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The proposal does not indicate:
Management of ancient flood water meadows
Management of underground streams
Management of water table which floods after several hours of persistent rainfall
The proposed area has Flora & Fauna that is indicative of ancient water meadows and no reference to/or account has been taken of these facts.
The proposed area was subject to an enquiry in 1992 and the judgement ruled against using this agricultural land for building purposes as it provided a green barrier between the Croft lands' development and the ancient landmark of Brikrigg moors. As no-one has ever informed us as to when this ruling was overturned one has to assume that SLDC is simply ignoring the findings. This makes their decision unsafe and not a sound one.
The most recent development on the High Carley hospital site still has problems re sewage. There are days when I and other residents can smell sewer gas as the problem has to be regularly dealt with. Adding numerous homes to an already overworked sewage disposal system cannot possibly be sound!
To destroy good agricultural land for homes can never be sound. The world's population is increasing at an alarming rate and millions face food shortages and starvation. Removing productive land from food cultivation is unsound. We are on the earth as guardians for future generations, to take productive land for homes is short sighted and a blight for future generations. At present the land soaks up, like an enormous sponge, the vast quantities of rain we experience. Even then it floods as the underground aquifers are replenished. Build on this area and many future residents will concrete over their gardens and tarmac their drives adding enormous amounts of water to the drainage system which already struggles to cope.
Sadly no local planners seemed to be aware of this matter when the proposals were first muted. Their publicity materials say they have been addressed but no-one has seen any evidence of their resolutions. To me this is yet another example of the lack of soundness in this plan.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
42. Mrs Jacqueline M Barnfield (Individual) : 24 Apr 2012 10:10:00
Paragraph No.
5.21
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
SLDC has not adopted many of the issues raised by local residents.
The proposal does not indicate:
Management of ancient flood water meadows
Management of underground streams
Management of water table which floods after several hours of persistent rainfall
The proposed area has Flora & Fauna that is indicative of ancient water meadows and no reference to/or account has been taken of these facts.
The proposed area was subject to an enquiry in 1990 and the judgement ruled against using this agricultural land for building purposes as it provided a green barrier between the Croft lands' development and the ancientlandmarkof Brikriggmoors.As such it was confirmed as an "Areaof Great Landscape Value''. As no-one has ever informed us as to when this ruling was overturned one has to assume that SLDC is simply ignoring the findings. This makes their decision unsafe and not a sound one.
The most recent development on the High Carley hospital site still has problems re sewage. There are days when I and other residents can smell sewer gas as the problem has to be regularly dealt with. Adding numerous homes to an already overworked sewage disposal system cannot possibly be sound!
To destroy good agricultural land for homes can never be sound. The world's population is increasing at an alarming rate and millions face food shortages and starvation. Removing productive land from food cultivation is unsound. We are on the earth as guardians for future generations, to take productive land for homes is short sighted and a blight for future generations. At present the land soaks up, like an enormous sponge, the vast quantities of rain we experience. Even then it floods as the underground aquifers are replenished. Build on this area and many future residents will concrete over their gardens and tarmac their drives adding enormous amounts of water to the drainage system which already struggles to cope.
Sadly no local planners seemed to be aware of this matter when the proposals were first muted. Their publicity materials say they have been addressed but no-one has seen any evidence of their resolutions. To me this is yet another example of the lack of soundness in this plan. Another indicator of the lack of soundness is the lack of provision for the development of the infrastructure should the plans succeeds. Already public transport has a difficult task to pass through
Croftlands given the number of homes who use the roads and pavements as additional parking spaces! Aly increase this problem and no thought or mention has been made of this in the plans. The current roads servicing the area are country lanes. We are led to believe that there will be no electrification of the railway line so train services provision will decline accordingly. This will impact upon the car usage. Nor are there any plans to improve the A590, the scene of numerous accidents resulting in fatalities and serious injuries. So it difficult to understand the logic that there will be more industries in Ulverston area: thus more work and more people. The proposed Glaxo development will result in more local work available but once it is up and running it will be highly educated professionals who move into the area and there will be limited posts available for the local workdorce. So one has to query the soundness of the thinking re sustainable housing!
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
It is important for our concerns to be heard. Sadly because of the past behaviours of several politicians etc - one no longer trusts decision makers to make decision based on balanced information and not political gain.
43. Mr Paul Bates (Individual) : 16 Apr 2012 23:44:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - R81 ARNSIDE REDHILLS ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Site R81 should be removed from the DPD.
Changes are required to comply with the National Planning Policy Framework and with the Core Strategy of SDLC. Site R81 is a greenfield site bordering on woodland and sits within the Arnside and Silverdale AONB, which is afforded a level of protection similar to a National Park. As such “planning permission should be refused for major developments in these designated areas except in exceptional circumstances”. Further, “planning policies and decisions should encourage the effective use of land by re-using land that has been previously developed (brownfield land)”. In my view SDLC has not made a credible case that development in R81 is an exceptional circumstance, nor has it allowed sufficient time or expended sufficient energy in exploring development of alternative brownfield sites within Arnside that would, in contrast to exploiting site R81, actually enhance the area.
Community involvement in developing the DPD with respect to Arnside has almost exclusively consisted of ignoring the wishes of local residents. The Inspector will be aware of a local petition against development of R81 and the views of the Parish Council, Arnside Parish Plan Trust and AONB management, none of whom support development on this site. I am yet to meet any local person who is in favour of development on this site. Thus SDLC have not taken account of the views of the community.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Site R81 should be removed from the DPD.
In my view there is no justification for substantial housing development in Arnside. Widely varying estimates for housing needs have been made and revised several times, these are at best internally inconsistent, do not stand close scrutiny and are grossly overstated. Already the largest village in south Lakeland, building on any significant greenfield sites such as The Common (R81) should not happen, and would seriously compromise the environment for residents and visitors alike. This is neither needed nor wanted and it is surprising that this is being contemplated at all in an AONB. Although there is much comment about affordable housing being needed in the general area, the Inspector should be aware that Arnside itself already has a good mixed housing stock, with many existing apartments, terraced and smaller semi-detached properties available. I would support development on brownfield sites within the village as this would make good use of redundant land and actually enhance the village. I would also support sustainable development in the area outside the AONB. However, there is no justification for any significant building on greenfield sites within an AONB – these small but precious regions of our landscape must be protected for future generations.
The proposal to build 30 properties on The Common seems particularly ill considered. Even a cursory examination of the site reveals that these will be high density dwellings – it is difficult to see how they could be crammed in and certainly not in keeping with the surroundings. Moreover, this area has been designated an “important open space”, and it gives an enjoyable aspect to a popular walking route to Arnside Knott used by both residents and visitors. As tourism is one of the few sources of local commerce any action that threatens this is to be avoided. Another problem with developments at this site would be a big increase to congestion at an already busy junction where Redhills Road joins Silverdale Road, and further the need to create a new access road on a bend and close to the junction with High Knott Road and/or through Lawrence Drive, with attendant road safety concerns, again hardly likely to enhance tourism. It is also disingenuous to refer to R81 as an “infill site”. In reality it is a strip of land bounded on one side by woodland (providing contiguity with a large area of mixed woodland and open areas to the south) and on the other by the back gardens of residents on Redhills Road. The dimensions of the site are such that it would not be possible to build houses on both sides of any access road for much of it (the site is too narrow) also meaning any road would have to run along the back gardens or by the footpath. It should also be noted that the site provides a link for wildlife through to the Ashmeadow area, which would otherwise become more isolated. It is true that R81 is not currently accessible to the public other than via the footpath along the southern boundary. However, rather than building on this site it would be better to acquire and develop this site of limestone grassland for the enjoyment of the public (e.g. like Dobshall Wood and meadow) and with advice from AONB management to enhance its biodiversity, for example as a hay meadow that would support wild flora and fauna. This would be consistent with AONB management plan objectives and the recent award of the Morecambe Bay Limestones and Wetlands Nature Improvement Area recognising the national importance of this area to biodiversity.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
44. Ms Michelle Bates (Individual) : 16 Apr 2012 23:56:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - R81 ARNSIDE REDHILLS ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Site R81 should be removed from the DPD.
Changes are required to comply with the National Planning Policy Framework and with the Core Strategy of SDLC. Site R81 is a greenfield site bordering on woodland and sits within the Arnside and Silverdale AONB, which is afforded a level of protection similar to a National Park. As such “planning permission should be refused for major developments in these designated areas except in exceptional circumstances”. Further, “planning policies and decisions should encourage the effective use of land by re-using land that has been previously developed (brownfield land)”. In my view SDLC has not made a credible case that development in R81 is an exceptional circumstance, nor has it allowed sufficient time or expended sufficient energy in exploring development of alternative brownfield sites within Arnside that would, in contrast to exploiting site R81, actually enhance the area.
Community involvement in developing the DPD with respect to Arnside has almost exclusively consisted of ignoring the wishes of local residents. The Inspector will be aware of a local petition against development of R81 and the views of the Parish Council, Arnside Parish Plan Trust and AONB management, none of whom support development on this site. I am yet to meet any local person who is in favour of development on this site. Thus SDLC have not taken account of the views of the community.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Site R81 should be removed from the DPD.
In my view there is no justification for substantial housing development in Arnside. Widely varying estimates for housing needs have been made and revised several times, these are at best internally inconsistent, do not stand close scrutiny and are grossly overstated. Already the largest village in south Lakeland, building on any significant greenfield sites such as The Common (R81) should not happen, and would seriously compromise the environment for residents and visitors alike. This is neither needed nor wanted and it is surprising that this is being contemplated at all in an AONB. Although there is much comment about affordable housing being needed in the general area, the Inspector should be aware that Arnside itself already has a good mixed housing stock, with many existing apartments, terraced and smaller semi-detached properties available. I would support development on brownfield sites within the village as this would make good use of redundant land and actually enhance the village. I would also support sustainable development in the area outside the AONB. However, there is no justification for any significant building on greenfield sites within an AONB – these small but precious regions of our landscape must be protected for future generations.
The proposal to build 30 properties on The Common seems particularly ill considered. Even a cursory examination of the site reveals that these will be high density dwellings – it is difficult to see how they could be crammed in and certainly not in keeping with the surroundings. Moreover, this area has been designated an “important open space”, and it gives an enjoyable aspect to a popular walking route to Arnside Knott used by both residents and visitors. As tourism is one of the few sources of local commerce any action that threatens this is to be avoided. Another problem with developments at this site would be a big increase to congestion at an already busy junction where Redhills Road joins Silverdale Road, and further the need to create a new access road on a bend and close to the junction with High Knott Road and/or through Lawrence Drive, with attendant road safety concerns, again hardly likely to enhance tourism. It is also disingenuous to refer to R81 as an “infill site”. In reality it is a strip of land bounded on one side by woodland (providing contiguity with a large area of mixed woodland and open areas to the south) and on the other by the back gardens of residents on Redhills Road. The dimensions of the site are such that it would not be possible to build houses on both sides of any access road for much of it (the site is too narrow) also meaning any road would have to run along the back gardens or by the footpath. It should also be noted that the site provides a link for wildlife through to the Ashmeadow area, which would otherwise become more isolated. It is true that R81 is not currently accessible to the public other than via the footpath along the southern boundary. However, rather than building on this site it would be better to acquire and develop this site of limestone grassland for the enjoyment of the public (e.g. like Dobshall Wood and meadow) and with advice from AONB management to enhance its biodiversity, for example as a hay meadow that would support wild flora and fauna. This would be consistent with AONB management plan objectives and with the recent award of the Morecambe Bay Limestones and Wetlands Nature Improvement Area recognising the national importance of this area to biodiversity.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
45. Mr Paul Bates (Individual) : 14 May 2012 16:21:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
1.10
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Community involvement in developing the DPD with respect to Arnside has almost exclusively consisted of ignoring the wishes of local residents. The Inspector will be aware of a local petition against development of R81 and the views of the Parish Council, Arnside Parish Plan Trust and AONB management, none of whom support development on this site. I am yet to meet any local person who is in favour of development on this site. Thus SDLC have not taken account of the views of the community.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
46. Mr Paul Bates (Individual) : 14 May 2012 16:27:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - All Arnside sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
In my view there is no justification for substantial housing development in Arnside. Widely varying estimates for housing needs have been made and revised several times, these are at best internally inconsistent, do not stand close scrutiny and are grossly overstated. Already the largest village in south Lakeland, building on any significant greenfield sites such as The Common (R81) should not happen, and would seriously compromise the environment for residents and visitors alike. This is neither needed nor wanted and it is surprising that this is being contemplated at all in an AONB. Although there is much comment about affordable housing being needed in the general area, the Inspector should be aware that Arnside itself already has a good mixed housing stock, with many existing apartments, terraced and smaller semi-detached properties available. I would support development on brownfield sites within the village as this would make good use of redundant land and actually enhance the village. I would also support sustainable development in the area outside the AONB. However, there is no justification for any significant building on greenfield sites within an AONB – these small but precious regions of our landscape must be protected for future generations.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
47. Ms Michelle Bates (Individual) : 15 May 2012 09:31:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
1.10
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Community involvement in developing the DPD with respect to Arnside has almost exclusively consisted of ignoring the wishes of local residents. The Inspector will be aware of a local petition against development of R81 and the views of the Parish Council, Arnside Parish Plan Trust and AONB management, none of whom support development on this site. I am yet to meet any local person who is in favour of development on this site. Thus SDLC have not taken account of the views of the community.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not consistent with national policy.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
48. Ms Michelle Bates (Individual) : 15 May 2012 09:36:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - All Arnside sites
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
In my view there is no justification for substantial housing development in Arnside. Widely varying estimates for housing needs have been made and revised several times, these are at best internally inconsistent, do not stand close scrutiny and are grossly overstated. Already the largest village in south Lakeland, building on any significant greenfield sites such as The Common (R81) should not happen, and would seriously compromise the environment for residents and visitors alike. This is neither needed nor wanted and it is surprising that this is being contemplated at all in an AONB. Although there is much comment about affordable housing being needed in the general area, the Inspector should be aware that Arnside itself already has a good mixed housing stock, with many existing apartments, terraced and smaller semi-detached properties available. I would support development on brownfield sites within the village as this would make good use of redundant land and actually enhance the village. I would also support sustainable development in the area outside the AONB. However, there is no justification for any significant building on greenfield sites within an AONB – these small but precious regions of our landscape must be protected for future generations.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
49. Robert Baxter (Individual) : 15 Apr 2012 17:46:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - R121M-mod KENDAL EAST OF CASTLE GREEN ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The Land Allocations Document (DPD) is not within the Local Development Scheme and the key stages have not been followed
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
The DPD has not had regard to the Sustainable Community Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
There are a number of areas where inclusion of R121M in the DPD is unsustainable.
Firstly, the site specific Flood Risk Assessment mentioned in the DPD needs to be done before any further consideration of this site proceeds. This site has serious and repeated flooding issues which are well-documented. There is grave sensitivity as R121M acts as a green 'sponge' to prevent rapid release of water into the Stock Beck Flood Alleviation Scheme (SB). There has been no assessment of the impact on the SB of further run-off from developed land. This is particularly remiss in terms of likely increased and severe rainfall due to climate change.
Here I must also refer to my letter to Dan Hudson of 20 February 2012 which gives further information of the flooding and water management issues relating to the defective culvert at Oak Tree Road (response by Dan Hudson on 24 February 2012 given SLDC reference DL/60.12.43). I have emailed copies of my letter of 20 February to SLDC asking that it be included in this my further response.
Furthermore this site has been included without reference to any wider hydrological, water management, drainage and flood alleviation for Kendal.
Development of R121M is unsustainable in terms of the affordable housing and local occupancy agendas of the Local Development Framework. The site has been reduced from a planned 147 houses to an estimated 60 houses. However the site has not been placed before planning committees to consider the configuration and breakdown of the proposed development into affordable and high-end housing. This site is likely to be used by the developer for only profitable high-end housing, despite Kendal being well-served for such housing. Instead development of R121M will destroy an outstanding landscape and risk flooding and pollution all for the sake of providing unwanted houses which are only likely to be bought either as second homes or by people from the south of England cashing in on higher property values there. It is therefore unsustainable and illogical. The need in Kendal is for affordable housing, yet the strategy to achieve this is flawed – giving developers remit to develop 'unaffordable' high-end housing in an unsustainable manner. SLDC's Sustainability Appraisal for the Core Strategy Preferred Options Sustainability Objective EN2: was 'To preserve and enhance landscape quality and character' and states that 'significant development is proposed for Kendal, particularly around the edges where the town meets the wider countryside and thus, there is potential for harm to the quality and character of the landscape and it is certain that the landscape will be at least changed'. Building on R121M therefore constitutes unsustainable development.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Inclusion of R121M is unsound in a number of areas, including:
Illogical and against precedent, given that R56 which will form part of the development for access purposes was rejected by a Planning Inspector on a previous proposal in 1997 and that R121M was deemed worthy of County Landscape designation in 1999. This should have been included in the 'robust and credible evidence base'.
The grave errors in the approach taken by SLDC also mean that the DPD is not deliverable in terms of R121M and is unsound in regard to community consultation and the localism agenda of the National Planning Policy Framework. SLDC has inferred it will disregard objections from residents affected by development and has also disregarded important information and previous research by other relevant local bodies, including recommendations against development on this site presented by Kendal Town Council and Friends of the Lake District. There has still been no detailed survey of this site in regard to flooding, environmental impact and transport access and the relevant planning official did not visit the site until July 2011.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
50. Mr and Mrs R and K Baybutt (Individual) : 23 Mar 2012 14:48:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - RN57M MILNTHORPE ADJ. TO ST ANTHONY'S CLOSE
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
We would like you to pass on our objections to the Planning Inspector. This is regarding the development of housing on the field behind St. Anthony's Close. We have stated in previous correspondence that we feel the development will make access to the A6 more dangerous than it already is. As you have looked at the site you will have noted that access via the steep hill with sharp bends and limited visibility makes it unsafe for pedestrians and motorists alike, not to mention the heavy vehicles that will be needed for construction.
Yours faithfully
R & K Baybutt
PS Is there a need for housing as several houses have been on the market for a very long time!!
51. Mr David Benyon (Individual) : 9 May 2012 14:54:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - M41M ENDMOOR NORTH OF SYCAMORE DRIVE
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The Land Allocations Document (DPD) is not within the Local Development Scheme and the key stages have not been followed
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not been prepared in accordance with the Town & County Planning Regulations 2004 (as amended)
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
The DPD has not had regard to the Sustainable Community Strategy
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Reduce the density and number of houses in M41M / R670. Reduce the size of the area of the village development boundary such that theses will be: more compliant with the Dev. Framework Sect 2 Par216 sustainable development principles CS1.1-2&3.
Improve the sustainability appraisal score for Endmoor on open space, greenfield land and impact on landscape. The village development boundary was increased without consultation with the village community - this is contrary to any number of compliance regulations - quite simply wrong.
Protect the countryside for its intrinsic beauty diveristy and natural resources. Take account of and enhance landscape features and character.
Take account of the poor score on open space, greenfield land and impact on landscape. Reduce density and number of houses in M41M / R670 to meet requiremetns. Improve the sustainability appraisal score. Reduce the village development boundary - consult with the community before increase.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
52. Mr David Benyon (Individual) : 9 May 2012 14:57:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - R670-mod ENDMOOR SOUTH OF BOWLING GREEN
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The Land Allocations Document (DPD) is not within the Local Development Scheme and the key stages have not been followed
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not been prepared in accordance with the Town & County Planning Regulations 2004 (as amended)
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
The DPD has not had regard to the Sustainable Community Strategy
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Reduce the density and number of houses in M41M / R670. Reduce the size of the area of the village development boundary such that theses will be: more compliant with the Dev. Framework Sect 2 Par216 sustainable development principles CS1.1-2&3.
Improve the sustainability appraisal score for Endmoor on open space, greenfield land and impact on landscape. The village development boundary was increased without consultation with the village community - this is contrary to any number of compliance regulations - quite simply wrong.
Protect the countryside for its intrinsic beauty diveristy and natural resources. Take account of and enhance landscape features and character.
Take account of the poor score on open space, greenfield land and impact on landscape. Reduce density and number of houses in M41M / R670 to meet requiremetns. Improve the sustainability appraisal score. Reduce the village development boundary - consult with the community before increase.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
53. Mr David Benyon (Individual) : 9 May 2012 15:12:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - All Endmoor sites
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The Land Allocations Document (DPD) is not within the Local Development Scheme and the key stages have not been followed
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not been prepared in accordance with the Town & County Planning Regulations 2004 (as amended)
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
The DPD has not had regard to the Sustainable Community Strategy
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Reduce the density and number of houses in M41M / R670. Reduce the size of the area of the village development boundary such that theses will be: more compliant with the Dev. Framework Sect 2 Par216 sustainable development principles CS1.1-2&3.
Improve the sustainability appraisal score for Endmoor on open space, greenfield land and impact on landscape. The village development boundary was increased without consultation with the village community - this is contrary to any number of compliance regulations - quite simply wrong.
Protect the countryside for its intrinsic beauty diveristy and natural resources. Take account of and enhance landscape features and character.
Take account of the poor score on open space, greenfield land and impact on landscape. Reduce density and number of houses in M41M / R670 to meet requiremetns. Improve the sustainability appraisal score. Reduce the village development boundary - consult with the community before increase.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
54. Mr David Benyon (Individual) : 9 May 2012 15:14:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.1 Development Boundaries- ENDMOOR
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The Land Allocations Document (DPD) is not within the Local Development Scheme and the key stages have not been followed
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not been prepared in accordance with the Town & County Planning Regulations 2004 (as amended)
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
The DPD has not had regard to the Sustainable Community Strategy
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Reduce the density and number of houses in M41M / R670. Reduce the size of the area of the village development boundary such that theses will be: more compliant with the Dev. Framework Sect 2 Par216 sustainable development principles CS1.1-2&3.
Improve the sustainability appraisal score for Endmoor on open space, greenfield land and impact on landscape. The village development boundary was increased without consultation with the village community - this is contrary to any number of compliance regulations - quite simply wrong.
Protect the countryside for its intrinsic beauty diveristy and natural resources. Take account of and enhance landscape features and character.
Take account of the poor score on open space, greenfield land and impact on landscape. Reduce density and number of houses in M41M / R670 to meet requiremetns. Improve the sustainability appraisal score. Reduce the village development boundary - consult with the community before increase.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
55. Mr David Benyon (Individual) : 9 May 2012 15:17:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA2.14 Land North of Sycamore Drive, Endmoor
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The Land Allocations Document (DPD) is not within the Local Development Scheme and the key stages have not been followed
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not been prepared in accordance with the Town & County Planning Regulations 2004 (as amended)
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
The DPD has not had regard to the Sustainable Community Strategy
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Reduce the density and number of houses in M41M / R670. Reduce the size of the area of the village development boundary such that theses will be: more compliant with the Dev. Framework Sect 2 Par216 sustainable development principles CS1.1-2&3.
Improve the sustainability appraisal score for Endmoor on open space, greenfield land and impact on landscape. The village development boundary was increased without consultation with the village community - this is contrary to any number of compliance regulations - quite simply wrong.
Protect the countryside for its intrinsic beauty diveristy and natural resources. Take account of and enhance landscape features and character.
Take account of the poor score on open space, greenfield land and impact on landscape. Reduce density and number of houses in M41M / R670 to meet requiremetns. Improve the sustainability appraisal score. Reduce the village development boundary - consult with the community before increase.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
56. Ms Emma Beresford (Individual) : 17 May 2012 11:30:00
Policy/Site No.
LA1.3 Housing Allocations - R339# ALLITHWAITE LAND SOUTH OF GREEN LANE
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I have fought to keep this field green for over forty year and again I will try again to
keep this green field.
This field is the only green field here; over the past forty years the village has grown
too big to be a village. Templand Park, Greendales, High cliff drive, Mayshelles
orchard, uplands fellside, Jack hill, Hazledene, plus in fill. Farm buildings and shops
have been converted to dwellings and shops. In Allithithwaite we have one shop/post
office which services this area.
The proposed dwellings on filed number R319, between Green lane and boarbank
lane, would increase traffic and parking, which there are already problems with on
these 2 roads, the sewerage system is old and would be inadequate for another 22
dwellings.By building on this land would be taking away residents on Green lane
and Boarbank roads only green field.
We are asking that other land be considered on the right hand side of Holme lane
fields NO RN230 AND RN65, the reason we ask for this land to be considered is
there is better access for cars it would mean traffic would not be brought threw the
centre of the village passed the school reducing the risk of accidents.
My final point is the village has already expanded and is now bigger than a village
yet it has no business to offer employment to people from the village, so to increase
housing without the facilities such as jobs would be of no benefit to the village.
I do understand there is a shortage of housing within this area, and many others in
the country, but rather than just build housing for the sake of building I would ask that
they be built on suitable sites with the least impact on the present residents.
57. Ms Emma Beresford (Individual) : 17 May 2012 11:33:00
Policy/Site No.
LA1.3 Housing Allocations - Site Omission
If you have selected a ‘Site omission’ please enter the site reference or location and relevant policy below
Site omission - Ref RN230
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I have fought to keep this field green for over forty year and again I will try again to
keep this green field.
This field is the only green field here; over the past forty years the village has grown
too big to be a village. Templand Park, Greendales, High cliff drive, Mayshelles
orchard, uplands fellside, Jack hill, Hazledene, plus in fill. Farm buildings and shops
have been converted to dwellings and shops. In Allithithwaite we have one shop/post
office which services this area.
The proposed dwellings on filed number R319, between Green lane and boarbank
lane, would increase traffic and parking, which there are already problems with on
these 2 roads, the sewerage system is old and would be inadequate for another 22
dwellings.By building on this land would be taking away residents on Green lane
and Boarbank roads only green field.
We are asking that other land be considered on the right hand side of Holme lane
fields NO RN230 AND RN65, the reason we ask for this land to be considered is
there is better access for cars it would mean traffic would not be brought threw the
centre of the village passed the school reducing the risk of accidents.
My final point is the village has already expanded and is now bigger than a village
yet it has no business to offer employment to people from the village, so to increase
housing without the facilities such as jobs would be of no benefit to the village.
I do understand there is a shortage of housing within this area, and many others in
the country, but rather than just build housing for the sake of building I would ask that
they be built on suitable sites with the least impact on the present residents.
58. Ms Emma Beresford (Individual) : 17 May 2012 11:34:00
Policy/Site No.
LA1.3 Housing Allocations - Site Omission
If you have selected a ‘Site omission’ please enter the site reference or location and relevant policy below
Site omission - Ref RN65
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I have fought to keep this field green for over forty year and again I will try again to
keep this green field.
This field is the only green field here; over the past forty years the village has grown
too big to be a village. Templand Park, Greendales, High cliff drive, Mayshelles
orchard, uplands fellside, Jack hill, Hazledene, plus in fill. Farm buildings and shops
have been converted to dwellings and shops. In Allithithwaite we have one shop/post
office which services this area.
The proposed dwellings on filed number R319, between Green lane and boarbank
lane, would increase traffic and parking, which there are already problems with on
these 2 roads, the sewerage system is old and would be inadequate for another 22
dwellings.By building on this land would be taking away residents on Green lane
and Boarbank roads only green field.
We are asking that other land be considered on the right hand side of Holme lane
fields NO RN230 AND RN65, the reason we ask for this land to be considered is
there is better access for cars it would mean traffic would not be brought threw the
centre of the village passed the school reducing the risk of accidents.
My final point is the village has already expanded and is now bigger than a village
yet it has no business to offer employment to people from the village, so to increase
housing without the facilities such as jobs would be of no benefit to the village.
I do understand there is a shortage of housing within this area, and many others in
the country, but rather than just build housing for the sake of building I would ask that
they be built on suitable sites with the least impact on the present residents.
59. Miss Ellen Bernfield (Individual) : 15 Apr 2012 15:49:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - R81 ARNSIDE REDHILLS ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Regard to National Policy
SLDC’s Core Strategy (CS8.2) cites the principles of “protection and enhancement of landscape and settlement character” in the Arnside and Silverdale AONB. SLDC has a statutory duty to pay due regard to the AONB designation in their decision-making. AONBs and National Parks are recognised under the Countryside and Rights of Way Act (2000) to be of equal landscape quality and are both afforded the highest level of protection in relation to landscape and scenic beauty as nationally designated landscapes.
National Planning Framework policy (NPPF 14, Footnote 9) also designates for special protection “an Area of Outstanding Natural Beauty”. Again NPPF 115 cites “Areas of Outstanding Natural Beauty, which have the highest status of protection in relation to landscape and scenic beauty” and “planning permission should be refused for major developments in these designated areas except in exceptional circumstances” (NPPF 116).
Furthermore, the NPPF specifically states that, for both plan-making and decision-taking “specific policies in this Framework indicate development should be restricted” in protected sites such as “land designated as….Local Green Space” (NPPF 14, Footnote 9) and that “planning policies and decisions should encourage the effective use of land by re-using land that has been previously developed (brownfield land)” (NPPF 111).
SLDC has failed to thoroughly test the viability of existing brownfield sites within the AONB as a first priority for development.
The DPD has therefore not had regard to the Core Strategy, or national policy for the protection of AONBs in general, it has not had regard to national policy on the protection of "local green spaces" and it has not had regard to national policy on the re-use of brownfield land.
I wish the DPD to be changed to have regard for SLDC’s duty, as specified in the Core Strategy and the National Planning Policy Framework, to afford the highest status of protection to the Arnside and Silverdale AONB and to its greenfield and local protected green spaces, and to follow government policy of restricting development in these areas.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I submit that the SLDC Land Allocations Development Plan Document (DPD) for Arnside, and specifically for Site R81 Redhills Road, fails the tests for soundness to be justified (community participation), to be effective (coherence with neighbouring strategies), and for consistency with national policy as laid down in the National Planning Policy Framework (NPPF).
Justified
SLDC have not “taken proper account of the views of the community” as promised in their Local Development Framework (LDF 13.10) in ignoring the community’s wish to protect its greenfield sites and designated “Important Open Spaces” within the village, in spite of numerous objections from Arnside residents (including a 550 name petition), from Arnside Parish Council (APC), Arnside Parish Plan Trust (APPT) and the management of the Arnside and Silverdale Area of Outstanding Natural Beauty (AONB), among others.
LDF 13.8 states that “under the Localism Bill, the council will be subject to a duty to cooperate with local communities preparing neighbourhood plans” including giving “support, advice and information” where needed. In fact, SLDC have pushed ahead with greenfield land allocations exclusively, knowing that a Neighbourhood Plan for Arnside (which proposes several alternative brownfield sites) is in preparation by APC/APPT. NPPF Section 8, 69 also requires councils to “create a shared vision with communities of the residential environment and facilities they wish to see” and to “facilitate neighbourhood planning”, and SLDC Core Strategy (CS8.1) aims to “protect and enhance important open spaces within settlements…of value for wildlife, recreation and the amenity needs of the community” and to “encourage the development of smaller, previously developed sites with constraints, and thus contribute to the target of 50% of housing on brownfield sites” (CS7.14).
SLDC fail to provide evidence of the participation of the local community, and others having a stake in the area and, in fact, have ignored their representations.
The SLDC Plan is therefore not justified in that it is not the most appropriate strategy.
For more detailed comment on the soundness of SLDC’s evidence base for viability, plus its research and facts, I refer you to the submission document entitled Specific Concerns and Objections of Arnside Parish Plan Trust (APPT) and Arnside Parish Council regarding SLDC’s Current Land Allocations, which I have read, and with whose points and requests for revision I am in full agreement.
Effective
The Arnside and Silverdale AONB crosses county borders, and is administered by both SLDC and the Lancashire City and Lancashire County councils, who make policy and take decisions respectively on planning matters across their areas.
The new National Planning Framework (NPPF 178) sets out a “duty to cooperate on planning issues across administrative boundaries, particularly those which relate to the strategic priorities set out in paragraph 156”. Strategic priorities include policies to deliver “conservation and enhancement of the natural and historic environment, including landscape.”
Furthermore, NPPF 179 expects planning authorities to “work collaboratively with other bodies to ensure that strategic priorities across local boundaries are properly coordinated” to meet development requirements which might otherwise “cause significant harm to the principles and policies of this Framework.”
NPPF 181 states that “local planning authorities will be expected to demonstrate evidence of having effectively cooperated to plan for issues with cross-boundary impacts when their Local Plans are submitted for examination. This could be by way of plans or policies prepared as part of a joint committee, a memorandum of understanding or a jointly prepared strategy which is presented as evidence of an agreed position.” NPPF 182 states that the Local Plan must prove that it “has been prepared in accordance with the Duty to Cooperate”.
SLDC have failed to provide evidence, in preparing the Land Allocations DPD for Arnside (Site R81) that they have fulfilled the requirement of effective cross-boundary consultation for impacts with regard to the special protection of the Arnside and Silverdale AONB. It is therefore not effective in that the document is not deliverable.
In addition, for more detailed comment on the soundness of SLDC’s evidence base for deliverability, I refer you to the submission document entitled Specific Concerns and Objections of Arnside Parish Plan Trust (APPT) and Arnside Parish Council regarding SLDC’s Current Land Allocations, which I have read, and with whose points and requests for revision I am in full agreement.
Consistent with National Policy
I refer you to my specific comments above relating to community participation and coherence with neighbouring authorities (both of which are required by the National Planning Policy Framework), and additionally:
SLDC’s own adopted Core Strategy (CS8.2) cites the principles of “protection and enhancement of landscape and settlement character” in the Arnside and Silverdale AONB. SLDC has a statutory duty to pay due regard to the AONB designation in their decision-making. AONBs and National Parks are recognised under the Countryside and Rights of Way Act (2000) to be of equal landscape quality and are both afforded the highest level of protection in relation to landscape and scenic beauty as nationally designated landscapes.
National Planning Framework policy cited above (NPPF 14, Footnote 9) also designates for special protection “an Area of Outstanding Natural Beauty”. Again NPPF 115 cites “Areas of Outstanding Natural Beauty, which have the highest status of protection in relation to landscape and scenic beauty” and “planning permission should be refused for major developments in these designated areas except in exceptional circumstances” (NPPF 116).
Furthermore, the NPPF specifically states that, for both plan-making and decision-taking “specific policies in this Framework indicate development should be restricted” in protected sites such as “land designated as….Local Green Space” (NPPF 14, Footnote 9) and that “planning policies and decisions should encourage the effective use of land by re-using land that has been previously developed (brownfield land)” (NPPF 111).
There is thus a national planning barrier to delivery on the greenfield and designated “local green space” sites (for example, Site R81) within the Arnside AONB. SLDC must therefore fulfil its declared and statutory duty to thoroughly test the viability of existing brownfield sites as a first priority. It has failed to show evidence for this.
The DPD is therefore not consistent with national policy for the protection of AONBs, it is not consistent with national policy on the protection of "local green spaces" and it is not consistent with national policy on the re-use of brownfield land.
I wish the DPD to be changed (to be justified) to take proper account of the views of the community of Arnside (in particular the Arnside Parish Plan Trust Neighbourhood Plan), as required by the SLDC Core Strategy, the Localism Bill and the National Planning Policy Framework (NPPF).
I wish the DPD to be changed (to be effective) to show evidence that SLDC have fulfilled the duty to cooperate, as specified in the National Planning Policy Framework (NPPF), for effective joint cross-boundary consultation with Lancashire City and County councils for cross-boundary impacts within the Arnside and Silverdale AONB which has the highest national status of protection.
I wish the DPD to be changed (to be consistent with national policy) to take account of SLDC’s statutory duty, as specified in the National Planning Policy Framework (NPPF), to afford the highest status of protection to the Arnside and Silverdale AONB and to its greenfield and local protected green spaces, and to follow government policy of restricting development in these areas.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
60. Miss Ellen Bernfield (Individual) : 15 May 2012 11:30:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - All Arnside sites
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Regard to National Policy
SLDC’s Core Strategy (CS8.2) cites the principles of “protection and enhancement of landscape and settlement character” in the Arnside and Silverdale AONB. SLDC has a statutory duty to pay due regard to the AONB designation in their decision-making. AONBs and National Parks are recognised under the Countryside and Rights of Way Act (2000) to be of equal landscape quality and are both afforded the highest level of protection in relation to landscape and scenic beauty as nationally designated landscapes.
National Planning Framework policy (NPPF 14, Footnote 9) also designates for special protection “an Area of Outstanding Natural Beauty”. Again NPPF 115 cites “Areas of Outstanding Natural Beauty, which have the highest status of protection in relation to landscape and scenic beauty” and “planning permission should be refused for major developments in these designated areas except in exceptional circumstances” (NPPF 116).
Furthermore, the NPPF specifically states that, for both plan-making and decision-taking “specific policies in this Framework indicate development should be restricted” in protected sites such as “land designated as….Local Green Space” (NPPF 14, Footnote 9) and that “planning policies and decisions should encourage the effective use of land by re-using land that has been previously developed (brownfield land)” (NPPF 111).
SLDC has failed to thoroughly test the viability of existing brownfield sites within the AONB as a first priority for development.
The DPD has therefore not had regard to the Core Strategy, or national policy for the protection of AONBs in general, it has not had regard to national policy on the protection of "local green spaces" and it has not had regard to national policy on the re-use of brownfield land.
I wish the DPD to be changed to have regard for SLDC’s duty, as specified in the Core Strategy and the National Planning Policy Framework, to afford the highest status of protection to the Arnside and Silverdale AONB and to its greenfield and local protected green spaces, and to follow government policy of restricting development in these areas.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I submit that the SLDC Land Allocations Development Plan Document (DPD) for Arnside, and specifically for Site R81 Redhills Road, fails the tests for soundness to be justified (community participation), to be effective (coherence with neighbouring strategies), and for consistency with national policy as laid down in the National Planning Policy Framework (NPPF).
Justified
SLDC have not “taken proper account of the views of the community” as promised in their Local Development Framework (LDF 13.10) in ignoring the community’s wish to protect its greenfield sites and designated “Important Open Spaces” within the village, in spite of numerous objections from Arnside residents (including a 550 name petition), from Arnside Parish Council (APC), Arnside Parish Plan Trust (APPT) and the management of the Arnside and Silverdale Area of Outstanding Natural Beauty (AONB), among others.
LDF 13.8 states that “under the Localism Bill, the council will be subject to a duty to cooperate with local communities preparing neighbourhood plans” including giving “support, advice and information” where needed. In fact, SLDC have pushed ahead with greenfield land allocations exclusively, knowing that a Neighbourhood Plan for Arnside (which proposes several alternative brownfield sites) is in preparation by APC/APPT. NPPF Section 8, 69 also requires councils to “create a shared vision with communities of the residential environment and facilities they wish to see” and to “facilitate neighbourhood planning”, and SLDC Core Strategy (CS8.1) aims to “protect and enhance important open spaces within settlements…of value for wildlife, recreation and the amenity needs of the community” and to “encourage the development of smaller, previously developed sites with constraints, and thus contribute to the target of 50% of housing on brownfield sites” (CS7.14).
SLDC fail to provide evidence of the participation of the local community, and others having a stake in the area and, in fact, have ignored their representations.
The SLDC Plan is therefore not justified in that it is not the most appropriate strategy.
For more detailed comment on the soundness of SLDC’s evidence base for viability, plus its research and facts, I refer you to the submission document entitled Specific Concerns and Objections of Arnside Parish Plan Trust (APPT) and Arnside Parish Council regarding SLDC’s Current Land Allocations, which I have read, and with whose points and requests for revision I am in full agreement.
Effective
The Arnside and Silverdale AONB crosses county borders, and is administered by both SLDC and the Lancashire City and Lancashire County councils, who make policy and take decisions respectively on planning matters across their areas.
The new National Planning Framework (NPPF 178) sets out a “duty to cooperate on planning issues across administrative boundaries, particularly those which relate to the strategic priorities set out in paragraph 156”. Strategic priorities include policies to deliver “conservation and enhancement of the natural and historic environment, including landscape.”
Furthermore, NPPF 179 expects planning authorities to “work collaboratively with other bodies to ensure that strategic priorities across local boundaries are properly coordinated” to meet development requirements which might otherwise “cause significant harm to the principles and policies of this Framework.”
NPPF 181 states that “local planning authorities will be expected to demonstrate evidence of having effectively cooperated to plan for issues with cross-boundary impacts when their Local Plans are submitted for examination. This could be by way of plans or policies prepared as part of a joint committee, a memorandum of understanding or a jointly prepared strategy which is presented as evidence of an agreed position.” NPPF 182 states that the Local Plan must prove that it “has been prepared in accordance with the Duty to Cooperate”.
SLDC have failed to provide evidence, in preparing the Land Allocations DPD for Arnside (Site R81) that they have fulfilled the requirement of effective cross-boundary consultation for impacts with regard to the special protection of the Arnside and Silverdale AONB. It is therefore not effective in that the document is not deliverable.
In addition, for more detailed comment on the soundness of SLDC’s evidence base for deliverability, I refer you to the submission document entitled Specific Concerns and Objections of Arnside Parish Plan Trust (APPT) and Arnside Parish Council regarding SLDC’s Current Land Allocations, which I have read, and with whose points and requests for revision I am in full agreement.
Consistent with National Policy
I refer you to my specific comments above relating to community participation and coherence with neighbouring authorities (both of which are required by the National Planning Policy Framework), and additionally:
SLDC’s own adopted Core Strategy (CS8.2) cites the principles of “protection and enhancement of landscape and settlement character” in the Arnside and Silverdale AONB. SLDC has a statutory duty to pay due regard to the AONB designation in their decision-making. AONBs and National Parks are recognised under the Countryside and Rights of Way Act (2000) to be of equal landscape quality and are both afforded the highest level of protection in relation to landscape and scenic beauty as nationally designated landscapes.
National Planning Framework policy cited above (NPPF 14, Footnote 9) also designates for special protection “an Area of Outstanding Natural Beauty”. Again NPPF 115 cites “Areas of Outstanding Natural Beauty, which have the highest status of protection in relation to landscape and scenic beauty” and “planning permission should be refused for major developments in these designated areas except in exceptional circumstances” (NPPF 116).
Furthermore, the NPPF specifically states that, for both plan-making and decision-taking “specific policies in this Framework indicate development should be restricted” in protected sites such as “land designated as….Local Green Space” (NPPF 14, Footnote 9) and that “planning policies and decisions should encourage the effective use of land by re-using land that has been previously developed (brownfield land)” (NPPF 111).
There is thus a national planning barrier to delivery on the greenfield and designated “local green space” sites (for example, Site R81) within the Arnside AONB. SLDC must therefore fulfil its declared and statutory duty to thoroughly test the viability of existing brownfield sites as a first priority. It has failed to show evidence for this.
The DPD is therefore not consistent with national policy for the protection of AONBs, it is not consistent with national policy on the protection of "local green spaces" and it is not consistent with national policy on the re-use of brownfield land.
I wish the DPD to be changed (to be justified) to take proper account of the views of the community of Arnside (in particular the Arnside Parish Plan Trust Neighbourhood Plan), as required by the SLDC Core Strategy, the Localism Bill and the National Planning Policy Framework (NPPF).
I wish the DPD to be changed (to be effective) to show evidence that SLDC have fulfilled the duty to cooperate, as specified in the National Planning Policy Framework (NPPF), for effective joint cross-boundary consultation with Lancashire City and County councils for cross-boundary impacts within the Arnside and Silverdale AONB which has the highest national status of protection.
I wish the DPD to be changed (to be consistent with national policy) to take account of SLDC’s statutory duty, as specified in the National Planning Policy Framework (NPPF), to afford the highest status of protection to the Arnside and Silverdale AONB and to its greenfield and local protected green spaces, and to follow government policy of restricting development in these areas.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
61. Miss Ellen Bernfield (Individual) : 15 May 2012 11:34:00
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I have read the guidance notes
Paragraph No.
1.9
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Justified
SLDC have not “taken proper account of the views of the community” as promised in their Local Development Framework (LDF 13.10) in ignoring the community’s wish to protect its greenfield sites and designated “Important Open Spaces” within the village, in spite of numerous objections from Arnside residents (including a 550 name petition), from Arnside Parish Council (APC), Arnside Parish Plan Trust (APPT) and the management of the Arnside and Silverdale Area of Outstanding Natural Beauty (AONB), among others.
LDF 13.8 states that “under the Localism Bill, the council will be subject to a duty to cooperate with local communities preparing neighbourhood plans” including giving “support, advice and information” where needed. In fact, SLDC have pushed ahead with greenfield land allocations exclusively, knowing that a Neighbourhood Plan for Arnside (which proposes several alternative brownfield sites) is in preparation by APC/APPT. NPPF Section 8, 69 also requires councils to “create a shared vision with communities of the residential environment and facilities they wish to see” and to “facilitate neighbourhood planning”, and SLDC Core Strategy (CS8.1) aims to “protect and enhance important open spaces within settlements…of value for wildlife, recreation and the amenity needs of the community” and to “encourage the development of smaller, previously developed sites with constraints, and thus contribute to the target of 50% of housing on brownfield sites” (CS7.14).
SLDC fail to provide evidence of the participation of the local community, and others having a stake in the area and, in fact, have ignored their representations.
The SLDC Plan is therefore not justified in that it is not the most appropriate strategy.
I wish the DPD to be changed (to be justified) to take proper account of the views of the community of Arnside (in particular the Arnside Parish Plan Trust Neighbourhood Plan), as required by the SLDC Core Strategy, the Localism Bill and the National Planning Policy Framework (NPPF).
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
62. Miss Ellen Bernfield (Individual) : 15 May 2012 11:36:00
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I have read the guidance notes
Paragraph No.
1.10
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Justified
SLDC have not “taken proper account of the views of the community” as promised in their Local Development Framework (LDF 13.10) in ignoring the community’s wish to protect its greenfield sites and designated “Important Open Spaces” within the village, in spite of numerous objections from Arnside residents (including a 550 name petition), from Arnside Parish Council (APC), Arnside Parish Plan Trust (APPT) and the management of the Arnside and Silverdale Area of Outstanding Natural Beauty (AONB), among others.
LDF 13.8 states that “under the Localism Bill, the council will be subject to a duty to cooperate with local communities preparing neighbourhood plans” including giving “support, advice and information” where needed. In fact, SLDC have pushed ahead with greenfield land allocations exclusively, knowing that a Neighbourhood Plan for Arnside (which proposes several alternative brownfield sites) is in preparation by APC/APPT. NPPF Section 8, 69 also requires councils to “create a shared vision with communities of the residential environment and facilities they wish to see” and to “facilitate neighbourhood planning”, and SLDC Core Strategy (CS8.1) aims to “protect and enhance important open spaces within settlements…of value for wildlife, recreation and the amenity needs of the community” and to “encourage the development of smaller, previously developed sites with constraints, and thus contribute to the target of 50% of housing on brownfield sites” (CS7.14).
SLDC fail to provide evidence of the participation of the local community, and others having a stake in the area and, in fact, have ignored their representations.
The SLDC Plan is therefore not justified in that it is not the most appropriate strategy.
I wish the DPD to be changed (to be justified) to take proper account of the views of the community of Arnside (in particular the Arnside Parish Plan Trust Neighbourhood Plan), as required by the SLDC Core Strategy, the Localism Bill and the National Planning Policy Framework (NPPF).
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
63. Ms Linda Berriman (Individual) : 16 Apr 2012 17:32:00
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I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - R121M-mod KENDAL EAST OF CASTLE GREEN ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
The DPD has not had regard to the Sustainable Community Strategy
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
My proposed change would be to exclude R121M on the basis of unsoundness;
To build houses on this piece of land would be unsound for the following reasons:-
Justified and Effective
"The DPD should show how the policies and proposals help to ensure that the social, environmental and resource use of objectives of sustainability will be achieved"
Numerous development proposals for this site in the past have been rejected because of:-
-the importance of the approaches to Kendal,
-biodiversity,
-flooding (which will not be alleviated by the Stockbeck system as this is already at capacity),
-access and highways safety (Oaktree Road and Sedbergh Road are too narrow).
Overall, previous reports by SLDC, Friends of the Lake District and others have rejected this site because of the sensitivity of the landscape and its low capacity for development. It therefore becomes uneconomic in terms of returns on investment in the infrastructure to support relatively few houses. Would this housing then be 'affordable' in terms of the price? Who would subsidise it?
SLDC has not provided enough costed detail to make this judgement.
SLDC's own Core Strategy policies on green infrastructure,open spaces,landscape and settlement character are not being adhered to. SLDc's Local plan 2006 has rejected this site because the 'development of higher hillsides further East would be unduly prominent'.
SLDC has not taken notice of the community in the form of Kendal Town Council who supported the view that R121 should not be developed for sound reasons stated previously.
It's engagement with the community has been low level and complicated, dependant on access to a computer.Ac cessing this website has been complicated for someone fairly computer literate - for the majority of the occupants living around this site who are elderly, this would not be an option let alone user friendly.
The site was originally considered by SLDC as being unsound for development- the site hasn't changed. Therefore,is it reasonable to assume that other political considerations (targets?) are taking precedence over sound i.e.justified and effective criteria.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
I have given authority to the Save Our Landscape East Kendal (SOLEK)to represent me in any Oral examination.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
64. Mr and Mrs Gordon J. and D. Biddle (Individual) : 26 Apr 2012 09:49:00
Policy/Site No.
LA1.3 Housing Allocations - RN121M-mod LEVENS FORMER POULTRY SHEDS, BRIGSTEER ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not been prepared in accordance with the Town & County Planning Regulations 2004 (as amended)
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
1. Inadequate consultation re RN121M-mod
2. Failure to ascertain whether site is available
3. An isolated pocket of development immediately outside and visible from national park - as existing and even more when extended
4. Could be start of later 'creeping development' to even greater detriment of landscape and village
5. wooded site - some of it ancient woodland containing protected species - and very steeply sloping
6. inadequate road accessand non-existent services ie water, surface drainage, fould drainage
7. out of keeping with surroundings
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Land use should continue to be agricultural and SLDC should exercise its powers to have derelict poulty sheds repaired (or preferably removed) and site cleaned up.
If it can be clearly proved that employment land is needed I would accept B1 (as SLDC originally proposed) provided tree screening is adequately maintained.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
To emphasise the serious flaws in SLDC's strategy with regard to site RN121M-mod
65. Mr Martin Birch (Individual) : 1 May 2012 13:52:00
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I have read the guidance notes
Policy/Site No.
LA1.10 Existing Green Infrastructure - Site Omission
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
This representation relates to the area of land wrapping around the
northern end of Helme Drive at Kendal, adjacent to the area ofland
designated as AS85 on the Kendal South East map
In the former South Lakeland Local Plan all the land wrapping around
Helme Drive at Kendal was designated as Open Important Space, which
meant there was a presumption against development. In the Land
Allocation Development Plan Document (DPD) only the southern part of
this field is allocated as Amenity Space, which, I understand, means there
is a similar presumption against development.
I believe the northern section of the field should also be designated in this
way as it has similar open space and amenity value. It lies next to the
former Kendal Canal, which may well be re-opened in the future - open
fields adjoining such a canal would have far more amenity value than
houses or other development. The land is close to the historic canal
bridge on Natland Mill Beck Lane and allows open views from that
bridge. The field's unusual mounds and hollows suggest that it would be
worthy of archaeological excavation. It is also close to Natland Mill
Beck, which should be protected.
I believe the DPD is 'unsound' because it fails to recognise the open
space and amenity value of the land to the north of Helme Drive. This
objection would be resolved if the plan was amended so that this land is
also allocated as Amenity Space.
66. Mr. Christopher Bisco (Individual) : 14 Apr 2012 18:11:00
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I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - All Arnside sites
If you have selected a ‘Site omission’ please enter the site reference or location and relevant policy below
Alternative sites listed in APPT/APCs submission shown in "Soundness" section below below
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
The DPD has not had regard to the Sustainable Community Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
A series of changes should be made in order to comply with the NPPF and in order to deal with the lack of sound evidence in the current Land Allocations. Changes also need to be made to comply with SLDC's core strategy.
The proposed changes are listed in detail in our objections paper attached below in answer 2.3 of this form.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
SPECIFIC CONCERNS AND OBJECTIONS OF ARNSIDE PARISH PLAN TRUST (APPT) AND ARNSIDE PARISH COUNCIL (APC) REGARDING SLDC’s CURRENT LAND ALLOCATIONS.
1. SUMMARY
Arnside Parish Plan Trust and Arnside Parish Council believe that SLDC has produced a Land Allocation plan which does not pass the main tests of soundness and which;
• is not consistent with the detailed policies set out in its Core Strategy designed to apply the duty of the Council to protect the special characteristics and historic landscape of the Arnside and Silverdale Area of Outstanding Natural Beauty. In particular, its land allocations for housing propose using exclusively greenfield sites and land rated currently as "Important Open Space" which will have an adverse impact on the AONB landscape and on Arnside's settlement character.
• fails to identify how specific local needs (for affordable rented social housing) will be delivered in practise, and who will deliver that need.
• does not reconcile effectively the “highest status of protection” given to land within an AONB, as expressed in the new version of the NPPF, with delivering the local needs which qualify as “exceptional circumstances”.
• has failed to explore sufficiently all potential alternatives and to apply the appropriate land use hierarchy. Instead it defaults to allocating greenfield sites and Important Open Spaces within the AONB which currently have “the highest level of protection” and are particularly valued by the local community and by the management of the AONB.
• fails to address the need to regenerate brownfield sites in the village to repair the environmental damage they are inflicting.
• has failed to win the support of the local community (550 signed petition against) and to respond to emerging local plans. Neither does it have the support of the management of the AONB, Arnside Parish Council, Arnside Parish Plan Trust and other bodies important to the management of the specially protected environment of the AONB.
• relies on a planning policy which is not sustainable because it sets too high a site threshold of 0.3ha which could prevent a more organic approach to land use which will impose less damage than the development of large sites.
• assumes that a planning policy of relying on commercial development to provide affordable housing through a 65/35% allocation ratio is viable, without providing any evidence that this policy is workable in today’s and foreseeable market conditions.
• assumes that this 65/35% ratio (which consumes three times the amount of land needed for affordable housing) can be justified in relation to “the highest status of protection” provided by the NPPF against inappropriate development of land within an AONB.
• is not sustainable. Instead, it will damage the rural, open character of the village and its attraction to residents and visitors alike in a sensitive location within the AONB. This will undermine the economy on which the local community depends for a viable future.
APPT and APC set out in more detail below the basis of its objections. The process for filing objections is complex and difficult for lay people to use with confidence. As this document has been prepared without the benefit of advice from a planning lawyer, we hope that all our points will still be considered even if not categorised correctly.
We also reserve the right to make further submissions, and to present emerging new information, at the Inspector’s hearing.
2. AMPLIFICATION
2.1. Overview
Our principal objections to the current Land Allocations for Arnside are that SLDC has not met the standards of evidence and proof required to justify the allocation of greenfield sites against the special protections afforded to such land by the national policies contained in the new version of the NPPF, and, as a result, neither has it gained the support of the local community. The Allocations are not sound in the context of the specific circumstances of Arnside.
Apart from one brownfield site allocated for employment purposes, all sites allocated for housing are greenfield sites, and two of these are currently designated “Important Open Spaces”. Land within an AONB has the highest status of protection under the NPPF and, within this AONB, these Important Open Spaces have, over a long time, been regarded by the community as having special value to the character and sustainability of Arnside.
We assert that SLDC has a special duty to apply to these sites the highest status of protection available. We further assert that they have not demonstrated to the standard required that there are no other viable alternatives within Arnside, or in surrounding areas, to meet specific local needs for affordable housing. Market housing does not fit the criteria of "need" in this context, especially as there are consistently over 70 dwellings available for sale in all price ranges in Arnside.
The Arnside community (through Arnside Parish Council and Arnside Parish Plan Trust) believe that there are viable alternatives which could be brought into play over the extended period covered by the Land Allocations process. Under the new Community Planning and Neighbourhood Planning regimes, SLDC should therefore take the opportunity to explore these alternatives more effectively with community representatives and to establish whether a better plan could be produced.
Because of the failure of SLDC to demonstrate that it has used its best endeavours to explore all reasonable alternatives, and because of a number of weaknesses in the evidence base used as set out in more detail below, we object to SLDC’s current Land Allocations because they fail the test of soundness on a number of points.
2.2. Housing needs in Arnside
We recognise and accept that more affordable housing is needed in Arnside. The most accurate survey currently available of need in the area (dated 2009) indicates that there is a short term need for 27 affordable homes in the village. It is clear that by far the main element of that need is for social rented housing. Longer term needs are still very unclear.
There is already an adequate supply of market housing with available stock being sustained at over 70 homes for sale of all types and price ranges, so there is no “exceptional need” to allocate land for market housing.
There is also a history within the village of affordable housing being built but failing to be maintained as part of the ongoing affordable housing stock because it has been traded on as holiday homes and general market housing. This needs to be avoided in future.
We understand that, within a confined area such as Arnside, it is difficult to find sites which balance the conflicting objectives of providing needed affordable housing while at the same time preserving the character of the settlement within the AONB to the “highest status of protection” that SLDC, and we, are obliged to achieve.
We are concerned, however, that SLDC has produced a range of numbers to justify its Land Allocations. The attached Appendix illustrates the range of numbers cited in the plan. Under pressure from the local community, SLDC has reduced progressively the numbers allocated to the AONB in proportion to other areas within South Lakes District to try more effectively to minimise the adverse impact on the core characteristics of the AONB. We welcome the reduction in numbers and the attempts to address this challenge.
However, the fact that these numbers have only recently been further amended, and that they are based on proportional data drawn from the wider region rather than specific local needs, illustrates the lack of certainty and the weak evidence base for the need within Arnside.
This is important because precise allocations are required to deliver the right types of homes, and in order to avoid the allocation of inappropriate sites, and the unnecessary - and avoidable - destruction of highly valued greenfield space. We therefore believe that this element of the plan is unsound because the calculation of need requires further work to ensure the correct housing types are delivered, and to ensure that unnecessary damage to the character of the village within the AONB is avoided.
APPT and APC are keen to engage in further work with SLDC to establish a more accurate assessment of housing need within the village.
2.3. Inappropriate Land Allocations
Arnside contains currently brownfield - and other smaller sites - which SLDC has not listed in the Land Allocations. These sites could, and should, be developed both to supply affordable housing needs and to repair the detrimental affect on the character of the village caused by the derelict brownfield locations. It is argued by APPT/APC that these sites, if brought into use over the term of the Land Allocations Plan to 2025, could supply much of the specifically identified affordable housing needs of the Village.
The current SLDC Land Allocations, however, list exclusively greenfield sites for housing, two of which are currently listed as Important Open Space, and as such are important to defining the open and rural character of the village within the AONB and maintaining its long term economic sustainability.
We believe that the current allocations fail the test of supporting the economic and environmental sustainability test for the reasons set out in detail in the emerging Village Plan for Arnside (http://www.arnside.gov.uk/Warehouse/ArnsideLookingForward4.pdf).
They are also the main concern of the 550+ signature petitions raised and submitted to SLDC during this process which stressed the need to protect these greenfields and Important Open Spaces. As a result, the current Allocations do not have the support of the Arnside community, and therefore they fail the soundness test for community engagement and support.
The current Allocations also fail to meet the sequential test for the use of brownfield sites etc before allocating greenfield sites. The allocation of greenfield sites currently designated as Important Open Space within an AONB is even further up the sequential hierarchy and therefore further from meeting the soundness test.
As stated above, there are a range of smaller infill and brownfield sites which would not have as adverse an environmental impact and which could be brought into use over the plan period, especially if SLDC applied some of its other powers, or to adjust some of its current planning policies (see below), or if it took a longer view of potential availability.
The current allocations therefore fail the “exceptional circumstances” and “highest status of protection” national policy soundness test for Land Allocations within an AONB. This is because the current documents fail to demonstrate that SLDC has used its best endeavours to find alternatives over the lifetime of this planning period, and because it has not adapted its planning policies to fit the special circumstances and “highest status of protection” applying within an AONB.
2.4. Specific concerns about the soundness of local policies.
We have concerns about some of the stated policies and planning assumptions applied by SLDC within this process. If valid, they would mean that SLDC’s plan would fail the soundness tests in several regards.
• SLDC has taken a policy decision not to include sites of less than 0.3 hectares in the current Land Allocations. As a consequence it has had to resort to allocating sensitive and controversial large greenfield sites. SLDC has admitted, however, that the smaller sites could well come into play during the plan period and they would probably get planning permission. Such sites could, however, supply a substantial part of the local need for social rented housing, especially if they were developed in small increments by a housing association or similar body. We understand that a smaller threshold of 0.1ha is being applied within the Lake District National Park. We believe therefore that the soundness test will not be met because SLDC has made this policy decision without opting for an alternative approach to allocate smaller sites which could be used in the context of the exceptional circumstance test and highest status of protection applying within an AONB. The community believe that the larger and very sensitive greenfield sites should be removed from the allocations until the smaller site potential has been exhausted.
• The Local Development Plan appears also to be critically dependent on the success of the assumption that the main local need – for social rented affordable housing – will be delivered through the policy of allocating sites to commercial developers, subject to them building a 35% ratio of affordable housing within development sites. Despite considerable pressing for evidence, SLDC has not provided any data to demonstrate that this policy is viable and will succeed in the current economy and in future commercial development markets.
This is particularly important in view of major changes to financial and housing markets since 2008. SLDC needs to prove that commercial developers will be able to overcome the additional financial burden placed on these sites to pay for affordable housing and for such elements as the Community Infrastructure Levy. This has to be done against a background of a difficult credit market, very low housing turnover volumes, and falling house prices. All this in an area where the planning portfolio holder hopes and believes that this land allocation policy will reduce the price of market housing by 20%, thus increasing the pressure on the development funding model.
We have evidence locally that builders are unable to raise finance for site development and the above burdens will only aggravate these problems.
Because this is such a critical and fundamental assumption underlying the whole of SLDC’s Land Allocations, and because the future supply of affordable housing appears to depend entirely on it operating effectively, it is essential that robust and “bankable” evidence is provided by SLDC. Without it, the current Land Allocations cannot pass the deliverability test for the supply of local affordable housing and is therefore not sound.
• The 65/35 development ratio also has one further major weakness; it requires three times the amount of land which would be needed if only the local need for affordable housing is covered. This cannot be said to be meeting the test of “highest status of protection” or “exceptional circumstances” and is not sound because it does not comply with National Policy as expressed in the new version of the NPPF.
• It is much more likely that an appropriate body needs to be found which will focus specifically on building social rented housing without needing to rely on subsidies from a premium placed on commercial developments of market housing. The SLDC documents do not deal adequately with this issue and are therefore unsound because they fail to provide sufficient evidence that the Land Allocations and associated policies will deliver the specific local need for social rented housing.
• SLDC also appears to be driven by fear of the consequences of the new NPPF and their perception that developers will have unfettered access to land if sites are not allocated in a controlled process such as these Land Allocations. This is, it says, because of the “presumption in favour of development”.
We do not believe this to be true within an AONB because of the obligation to apply the “highest status of protection”, and inappropriate land allocations can continue to be resisted. There is therefore no need to rush this process. The current land allocations for Arnside should therefore be referred back for further work with the community to produce a more appropriate plan.
• SLDC appears to be over-relying on the very short term application of the “Deliverability” criteria within the Development Framework. In practise, this has led it to rely on sites where there is a clear immediate intention of the owner to make the site available for development and to capitalise on a commercial opportunity. If that commitment has not been made to date, potentially useful and less sensitive sites have been excluded, even if there is a reasonable chance that they will come into play over the longer term. The consequence of this is that derelict and previously used sites, which should be improved as part of any sensible spatial plan for any community, have been ignored. The knock-on consequence is that greenfield sites could be destroyed while derelict sites remain unused. This is not a sensible planning policy and fails even the commonsense soundness test.
• It is clear that it will take some time to bring into play some of the smaller and brownfield sites within the village but it is argued that the exceptional circumstances of the village within the AONB justify the extra effort (or time delay) that may be required. SLDC has failed to use its best endeavours to apply this extra effort by (for example) using the powers they have to bring derelict sites into use (such as Compulsory Purchase Orders). APPT are keen to work with SLDC to produce a Plan which achieves these objectives but, so far, SLDC has failed this test of soundness in meeting the exceptional circumstances criteria required within an AONB. The new Community planning regime under the Localism Act provides the opportunity to put this right by SLDC working closely with the community. The current land allocations should be deferred until this process has been completed. APPT/APC have an early draft of a community plan already in progress (http://www.arnside.gov.uk/Warehouse/ArnsideLookingForward4.pdf) and are keen to engage SLDC 's support in moving to a complete and workable version.
• We understand that the management of the Arnside & Silverdale Area of Outstanding Natural Beauty have similar and additional objections to the soundness of these Allocations. Arnside Parish Council, through Arnside Parish Plan Trust, intend to coordinate their emerging plans with this and other stakeholders for this area.
• We also understand that Lancaster City Council has a more appropriate treatment of land within the AONB in its Land Allocations policies but that SLDC has not yet coordinated its approach effectively with LCC. There may be solutions to local housing needs which could be accommodated within the neighbouring territories of LCC. SLDC will therefore fail to meet the soundness test until this process has been completed.
• Because of the above, the current Land Allocations should be referred back for revision. This revision would benefit from input from the emerging Arnside Community and Neighbourhood Plans which will address these issues.
Appendix 1
Land Allocation Development Plan Document – Calculation of Housing Need within the AONB*
There are 4 calculations of potential housing needs contained in the document for the AONB part of SLDC
CALCULATION 1
This is based on the AONB population as a % of the total Local Development Framework (LDF) area population
LDF Population 75000
AONB population 5% 3800 (Arnside 2300 and Beetham 1500)
Based on total district housing target of 400 per annum then 5% of this is 20 per annum for the AONB (12 for Arnside and 8 for Beetham)
Over the period 2003-2025 the total for the AONB is 460 (276 for Arnside and 184 for Beetham)
CALCULATION 2
This is based on the 2009 Strategic Market Assessment for Rural South Kendal. The figures for Annual Affordable Housing Requirements (See Page 63) for the period 2009-2015 were based on the 2006 Housing Needs Survey and indicates respondents aspirations.
Rural South Kendal Total 1105
AONB population 15.7% 173
(Arnside 104 and Beetham 69 based on population split shown in calculation 1)
If the above figures were projected at the same level for the whole of the plan 2009-2025 then this gives a total affordable housing need of 555 (333 for Arnside and 222 for Beetham based on population split shown in calculation 1)
CALCULATION 3
This is based on the 2011 Strategic Market Assessment for Rural South Kendal not including Milnthorpe and Kirkby Lonsdale. Again the survey appears to be aspirational. The response rate for Rural South Kendal was 30%. The calculations for the affordable housing market for 2011-2016 were based on:
• Households currently in housing which is unsuitable for their use and who are unable to afford to buy or rent in the market (backlog need)
• New household forming who cannot afford to buy or rent in the market
• Existing households expected to fall into need
• The supply of affordable housing through social renting and intermediate tenure stock
This calculation is similar to number 2
Rural South Kendal Total 435
AONB population 18.54% 225
(Arnside 133 and Beetham 89) based on population split shown in calculation 1)
CALCULATION 4
This is based on Arnside 2009 Housing Needs Survey and 2007 Beetham Housing Needs Survey to determine the need for affordable housing. This survey applied to social rented housing only and represented respondents aspirations and does not necessarily represent actual take up of affordable homes if they were offered. See Appendix Below: Analysis & Critical Review of Housing Needs
2009-14 Arnside 27 ? therefore projected number for 2009-2025 is 86
2007-12 Beetham* 17 ? therefore projected number for 2009-2025 is 61
But in order to deliver the affordable element an allowance for market housing has to be given. If affordable housing is delivered at 35% of market schemes this would bring the total need for 2009-2025 to 420 (Arnside 252 and Beetham 168)
*in the AONB part of Beetham
SUMMARY
Reference in Land Allocation Document Arnside Beetham Total Comments
3.79 Calculation 1 Total need 2003-2025 276 184 460 AONB population as a % of Local Development Area population
3.80 Calculation 2 Affordable need 2009-2025 333 222 555 AONB as a % of Rural South Kendal from an aspirational survey
3.81 Calculation 3 Affordable need 2009-2025 135 90 225 AONB as a % of Rural South Kendal LESS Milnthorpe and Kirkby Lonsdale from an aspirational survey
3.87 Calculation 4 Affordable need 2009-2025
Calculation 4 but also market allowance to achieve this 2009-2025 86
252 61
168 147
420 Arnside and Beetham aspirations for affordable housing
Market allowance figures are unrealistic because unlikely this scenario will happen
From the above 4 calculations it was concluded that the total housing need over the plan period was somewhere between 200 and 400 but because of the low housing delivery since 2003 to the present there was a need to do more per annum in the remaining period of the plan.
Because these calculations assume use of the 65/35% ration of market to affordable housing, the actual need for affordable housing is much less than the numbers stated above..
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
The objections of Arnside Parish Council and Arnside Parish Plan Trust are fundamental to the soundness of the Land Allocations DPD, particularly in the context of the Arnside & Silverdale AONB and the application of the NPPF.
The arguments are complex and have been presented in detail in our written submission but we expect further data to become available before the Examination which we would like to present.
As the points we raise are of such fundamental importance to the soundeness of the Land Allocations, it is important that we are heard and seen to be heard. As I drafted the objections document, I will represent both APC and APPT unless we decide to appoint legal representation for the hearing.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
67. Mr. Christopher Bisco (Individual) : 17 Apr 2012 15:22:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - R81 ARNSIDE REDHILLS ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Not Compliant because it does not have proper regard for "the Highest status of protection" afforded to land within an AONB and the other reasons referred to in the paper by Arnside Parish Plan Trust and Arnside Parish Council reproduced in section 2.3 below
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
SPECIFIC CONCERNS AND OBJECTIONS OF ARNSIDE PARISH PLAN TRUST (APPT) AND ARNSIDE PARISH COUNCIL REGARDING SLDC’s CURRENT LAND ALLOCATIONS.
1. SUMMARY
Arnside Parish Plan Trust and Arnside Parish Council believe that SLDC has produced a Land Allocation plan which does not pass the main tests of soundness and which;
• is not consistent with the detailed policies set out in its Core Strategy designed to apply the duty of the Council to protect the special characteristics and historic landscape of the Arnside and Silverdale Area of Outstanding Natural Beauty. In particular, its land allocations for housing propose using exclusively greenfield sites and land rated currently as "Important Open Space" which will have an adverse impact on the AONB landscape and on Arnside's settlement character.
• fails to identify how specific local needs (for affordable rented social housing) will be delivered in practise, and who will deliver that need.
• does not reconcile effectively the “highest status of protection” given to land within an AONB, as expressed in the new version of the NPPF, with delivering the local needs which qualify as “exceptional circumstances”.
• has failed to explore sufficiently all potential alternatives and to apply the appropriate land use hierarchy. Instead it defaults to allocating greenfield sites and Important Open Spaces within the AONB which currently have “the highest level of protection” and are particularly valued by the local community and by the management of the AONB.
• fails to address the need to regenerate brownfield sites in the village to repair the environmental damage they are inflicting.
• has failed to win the support of the local community (550 signed petition against) and to respond to emerging local plans. Neither does it have the support of the management of the AONB, Arnside Parish Council, Arnside Parish Plan Trust and other bodies important to the management of the specially protected environment of the AONB.
• relies on a planning policy which is not sustainable because it sets too high a site threshold of 0.3ha which could prevent a more organic approach to land use which will impose less damage than the development of large sites.
• assumes that a planning policy of relying on commercial development to provide affordable housing through a 65/35% allocation ratio is viable, without providing any evidence that this policy is workable in today’s and foreseeable market conditions.
• assumes that this 65/35% ratio (which consumes three times the amount of land needed for affordable housing) can be justified in relation to “the highest status of protection” provided by the NPPF against inappropriate development of land within an AONB.
• is not sustainable. Instead, it will damage the rural, open character of the village and its attraction to residents and visitors alike in a sensitive location within the AONB. This will undermine the economy on which the local community depends for a viable future.
APPT and APC set out in more detail below the basis of its objections. The process for filing objections is complex and difficult for lay people to use with confidence. As this document has been prepared without the benefit of advice from a planning lawyer, we hope that all our points will still be considered even if not categorised correctly.
We also reserve the right to make further submissions, and to present emerging new information, at the Inspector’s hearing.
2. AMPLIFICATION
2.1. Overview
Our principal objections to the current Land Allocations for Arnside are that SLDC has not met the standards of evidence and proof required to justify the allocation of greenfield sites against the special protections afforded to such land by the national policies contained in the new version of the NPPF, and, as a result, neither has it gained the support of the local community. The Allocations are not sound in the context of the specific circumstances of Arnside.
Apart from one brownfield site allocated for employment purposes, all sites allocated for housing are greenfield sites, and two of these are currently designated “Important Open Spaces”. Land within an AONB has the highest status of protection under the NPPF and, within this AONB, these Important Open Spaces have, over a long time, been regarded by the community as having special value to the character and sustainability of Arnside.
We assert that SLDC has a special duty to apply to these sites the highest status of protection available. We further assert that they have not demonstrated to the standard required that there are no other viable alternatives within Arnside, or in surrounding areas, to meet specific local needs for affordable housing. Market housing does not fit the criteria of "need" in this context, especially as there are consistently over 70 dwellings available for sale in all price ranges in Arnside.
The Arnside community (through Arnside Parish Council and Arnside Parish Plan Trust) believe that there are viable alternatives which could be brought into play over the extended period covered by the Land Allocations process. Under the new Community Planning and Neighbourhood Planning regimes, SLDC should therefore take the opportunity to explore these alternatives more effectively with community representatives and to establish whether a better plan could be produced.
Because of the failure of SLDC to demonstrate that it has used its best endeavours to explore all reasonable alternatives, and because of a number of weaknesses in the evidence base used as set out in more detail below, we object to SLDC’s current Land Allocations because they fail the test of soundness on a number of points.
2.2. Housing needs in Arnside
We recognise and accept that more affordable housing is needed in Arnside. The most accurate survey currently available of need in the area (dated 2009) indicates that there is a short term need for 27 affordable homes in the village. It is clear that by far the main element of that need is for social rented housing. Longer term needs are still very unclear.
There is already an adequate supply of market housing with available stock being sustained at over 70 homes for sale of all types and price ranges, so there is no “exceptional need” to allocate land for market housing.
There is also a history within the village of affordable housing being built but failing to be maintained as part of the ongoing affordable housing stock because it has been traded on as holiday homes and general market housing. This needs to be avoided in future.
We understand that, within a confined area such as Arnside, it is difficult to find sites which balance the conflicting objectives of providing needed affordable housing while at the same time preserving the character of the settlement within the AONB to the “highest status of protection” that SLDC, and we, are obliged to achieve.
We are concerned, however, that SLDC has produced a range of numbers to justify its Land Allocations. The attached Appendix illustrates the range of numbers cited in the plan. Under pressure from the local community, SLDC has reduced progressively the numbers allocated to the AONB in proportion to other areas within South Lakes District to try more effectively to minimise the adverse impact on the core characteristics of the AONB. We welcome the reduction in numbers and the attempts to address this challenge.
However, the fact that these numbers have only recently been further amended, and that they are based on proportional data drawn from the wider region rather than specific local needs, illustrates the lack of certainty and the weak evidence base for the need within Arnside.
This is important because precise allocations are required to deliver the right types of homes, and in order to avoid the allocation of inappropriate sites, and the unnecessary - and avoidable - destruction of highly valued greenfield space. We therefore believe that this element of the plan is unsound because the calculation of need requires further work to ensure the correct housing types are delivered, and to ensure that unnecessary damage to the character of the village within the AONB is avoided.
APPT and APC are keen to engage in further work with SLDC to establish a more accurate assessment of housing need within the village.
2.3. Inappropriate Land Allocations
Arnside contains currently brownfield - and other smaller sites - which SLDC has not listed in the Land Allocations. These sites could, and should, be developed both to supply affordable housing needs and to repair the detrimental affect on the character of the village caused by the derelict brownfield locations. It is argued by APPT/APC that these sites, if brought into use over the term of the Land Allocations Plan to 2025, could supply much of the specifically identified affordable housing needs of the Village.
The current SLDC Land Allocations, however, list exclusively greenfield sites for housing, two of which are currently listed as Important Open Space, and as such are important to defining the open and rural character of the village within the AONB and maintaining its long term economic sustainability.
We believe that the current allocations fail the test of supporting the economic and environmental sustainability test for the reasons set out in detail in the emerging Village Plan for Arnside (http://www.arnside.gov.uk/Warehouse/ArnsideLookingForward4.pdf).
They are also the main concern of the 550+ signature petitions raised and submitted to SLDC during this process which stressed the need to protect these greenfields and Important Open Spaces. As a result, the current Allocations do not have the support of the Arnside community, and therefore they fail the soundness test for community engagement and support.
The current Allocations also fail to meet the sequential test for the use of brownfield sites etc before allocating greenfield sites. The allocation of greenfield sites currently designated as Important Open Space within an AONB is even further up the sequential hierarchy and therefore further from meeting the soundness test.
As stated above, there are a range of smaller infill and brownfield sites which would not have as adverse an environmental impact and which could be brought into use over the plan period, especially if SLDC applied some of its other powers, or to adjust some of its current planning policies (see below), or if it took a longer view of potential availability.
The current allocations therefore fail the “exceptional circumstances” and “highest status of protection” national policy soundness test for Land Allocations within an AONB. This is because the current documents fail to demonstrate that SLDC has used its best endeavours to find alternatives over the lifetime of this planning period, and because it has not adapted its planning policies to fit the special circumstances and “highest status of protection” applying within an AONB.
2.4. Specific concerns about the soundness of local policies.
We have concerns about some of the stated policies and planning assumptions applied by SLDC within this process. If valid, they would mean that SLDC’s plan would fail the soundness tests in several regards.
• SLDC has taken a policy decision not to include sites of less than 0.3 hectares in the current Land Allocations. As a consequence it has had to resort to allocating sensitive and controversial large greenfield sites. SLDC has admitted, however, that the smaller sites could well come into play during the plan period and they would probably get planning permission. Such sites could, however, supply a substantial part of the local need for social rented housing, especially if they were developed in small increments by a housing association or similar body. We understand that a smaller threshold of 0.1ha is being applied within the Lake District National Park. We believe therefore that the soundness test will not be met because SLDC has made this policy decision without opting for an alternative approach to allocate smaller sites which could be used in the context of the exceptional circumstance test and highest status of protection applying within an AONB. The community believe that the larger and very sensitive greenfield sites should be removed from the allocations until the smaller site potential has been exhausted.
• The Local Development Plan appears also to be critically dependent on the success of the assumption that the main local need – for social rented affordable housing – will be delivered through the policy of allocating sites to commercial developers, subject to them building a 35% ratio of affordable housing within development sites. Despite considerable pressing for evidence, SLDC has not provided any data to demonstrate that this policy is viable and will succeed in the current economy and in future commercial development markets.
This is particularly important in view of major changes to financial and housing markets since 2008. SLDC needs to prove that commercial developers will be able to overcome the additional financial burden placed on these sites to pay for affordable housing and for such elements as the Community Infrastructure Levy. This has to be done against a background of a difficult credit market, very low housing turnover volumes, and falling house prices. All this in an area where the planning portfolio holder hopes and believes that this land allocation policy will reduce the price of market housing by 20%, thus increasing the pressure on the development funding model.
We have evidence locally that builders are unable to raise finance for site development and the above burdens will only aggravate these problems.
Because this is such a critical and fundamental assumption underlying the whole of SLDC’s Land Allocations, and because the future supply of affordable housing appears to depend entirely on it operating effectively, it is essential that robust and “bankable” evidence is provided by SLDC. Without it, the current Land Allocations cannot pass the deliverability test for the supply of local affordable housing and is therefore not sound.
• The 65/35 development ratio also has one further major weakness; it requires three times the amount of land which would be needed if only the local need for affordable housing is covered. This cannot be said to be meeting the test of “highest status of protection” or “exceptional circumstances” and is not sound because it does not comply with National Policy as expressed in the new version of the NPPF.
• It is much more likely that an appropriate body needs to be found which will focus specifically on building social rented housing without needing to rely on subsidies from a premium placed on commercial developments of market housing. The SLDC documents do not deal adequately with this issue and are therefore unsound because they fail to provide sufficient evidence that the Land Allocations and associated policies will deliver the specific local need for social rented housing.
• SLDC also appears to be driven by fear of the consequences of the new NPPF and their perception that developers will have unfettered access to land if sites are not allocated in a controlled process such as these Land Allocations. This is, it says, because of the “presumption in favour of development”.
We do not believe this to be true within an AONB because of the obligation to apply the “highest status of protection”, and inappropriate land allocations can continue to be resisted. There is therefore no need to rush this process. The current land allocations for Arnside should therefore be referred back for further work with the community to produce a more appropriate plan.
• SLDC appears to be over-relying on the very short term application of the “Deliverability” criteria within the Development Framework. In practise, this has led it to rely on sites where there is a clear immediate intention of the owner to make the site available for development and to capitalise on a commercial opportunity. If that commitment has not been made to date, potentially useful and less sensitive sites have been excluded, even if there is a reasonable chance that they will come into play over the longer term. The consequence of this is that derelict and previously used sites, which should be improved as part of any sensible spatial plan for any community, have been ignored. The knock-on consequence is that greenfield sites could be destroyed while derelict sites remain unused. This is not a sensible planning policy and fails even the commonsense soundness test.
• It is clear that it will take some time to bring into play some of the smaller and brownfield sites within the village but it is argued that the exceptional circumstances of the village within the AONB justify the extra effort (or time delay) that may be required. SLDC has failed to use its best endeavours to apply this extra effort by (for example) using the powers they have to bring derelict sites into use (such as Compulsory Purchase Orders). APPT are keen to work with SLDC to produce a Plan which achieves these objectives but, so far, SLDC has failed this test of soundness in meeting the exceptional circumstances criteria required within an AONB. The new Community planning regime under the Localism Act provides the opportunity to put this right by SLDC working closely with the community. The current land allocations should be deferred until this process has been completed. APPT/APC have an early draft of a community plan already in progress (http://www.arnside.gov.uk/Warehouse/ArnsideLookingForward4.pdf) and are keen to engage SLDC 's support in moving to a complete and workable version.
• We understand that the management of the Arnside & Silverdale Area of Outstanding Natural Beauty have similar and additional objections to the soundness of these Allocations. Arnside Parish Council, through Arnside Parish Plan Trust, intend to coordinate their emerging plans with this and other stakeholders for this area.
• We also understand that Lancaster City Council has a more appropriate treatment of land within the AONB in its Land Allocations policies but that SLDC has not yet coordinated its approach effectively with LCC. There may be solutions to local housing needs which could be accommodated within the neighbouring territories of LCC. SLDC will therefore fail to meet the soundness test until this process has been completed.
• Because of the above, the current Land Allocations should be referred back for revision. This revision would benefit from input from the emerging Arnside Community and Neighbourhood Plans which will address these issues.
Appendix 1
Land Allocation Development Plan Document – Calculation of Housing Need within the AONB*
There are 4 calculations of potential housing needs contained in the document for the AONB part of SLDC
CALCULATION 1
This is based on the AONB population as a % of the total Local Development Framework (LDF) area population
LDF Population 75000
AONB population 5% 3800 (Arnside 2300 and Beetham 1500)
Based on total district housing target of 400 per annum then 5% of this is 20 per annum for the AONB (12 for Arnside and 8 for Beetham)
Over the period 2003-2025 the total for the AONB is 460 (276 for Arnside and 184 for Beetham)
CALCULATION 2
This is based on the 2009 Strategic Market Assessment for Rural South Kendal. The figures for Annual Affordable Housing Requirements (See Page 63) for the period 2009-2015 were based on the 2006 Housing Needs Survey and indicates respondents aspirations.
Rural South Kendal Total 1105
AONB population 15.7% 173
(Arnside 104 and Beetham 69 based on population split shown in calculation 1)
If the above figures were projected at the same level for the whole of the plan 2009-2025 then this gives a total affordable housing need of 555 (333 for Arnside and 222 for Beetham based on population split shown in calculation 1)
CALCULATION 3
This is based on the 2011 Strategic Market Assessment for Rural South Kendal not including Milnthorpe and Kirkby Lonsdale. Again the survey appears to be aspirational. The response rate for Rural South Kendal was 30%. The calculations for the affordable housing market for 2011-2016 were based on:
• Households currently in housing which is unsuitable for their use and who are unable to afford to buy or rent in the market (backlog need)
• New household forming who cannot afford to buy or rent in the market
• Existing households expected to fall into need
• The supply of affordable housing through social renting and intermediate tenure stock
This calculation is similar to number 2
Rural South Kendal Total 435
AONB population 18.54% 225
(Arnside 133 and Beetham 89) based on population split shown in calculation 1)
CALCULATION 4
This is based on Arnside 2009 Housing Needs Survey and 2007 Beetham Housing Needs Survey to determine the need for affordable housing. This survey applied to social rented housing only and represented respondents aspirations and does not necessarily represent actual take up of affordable homes if they were offered. See Appendix Below: Analysis & Critical Review of Housing Needs
2009-14 Arnside 27 ? therefore projected number for 2009-2025 is 86
2007-12 Beetham* 17 ? therefore projected number for 2009-2025 is 61
But in order to deliver the affordable element an allowance for market housing has to be given. If affordable housing is delivered at 35% of market schemes this would bring the total need for 2009-2025 to 420 (Arnside 252 and Beetham 168)
*in the AONB part of Beetham
SUMMARY
Reference in Land Allocation Document Arnside Beetham Total Comments
3.79 Calculation 1 Total need 2003-2025 276 184 460 AONB population as a % of Local Development Area population
3.80 Calculation 2 Affordable need 2009-2025 333 222 555 AONB as a % of Rural South Kendal from an aspirational survey
3.81 Calculation 3 Affordable need 2009-2025 135 90 225 AONB as a % of Rural South Kendal LESS Milnthorpe and Kirkby Lonsdale from an aspirational survey
3.87 Calculation 4 Affordable need 2009-2025
Calculation 4 but also market allowance to achieve this 2009-2025 86
252 61
168 147
420 Arnside and Beetham aspirations for affordable housing
Market allowance figures are unrealistic because unlikely this scenario will happen
From the above 4 calculations it was concluded that the total housing need over the plan period was somewhere between 200 and 400 but because of the low housing delivery since 2003 to the present there was a need to do more per annum in the remaining period of the plan.
Because these calculations assume use of the 65/35% ration of market to affordable housing, the actual need for affordable housing is much less than the numbers stated above..
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
To ensure the arguments regarded the above objections are fully considered
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
68. Mr. Christopher Bisco (Individual) : 8 May 2012 15:30:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
1.10
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
We believe that the current allocations fail the test of supporting the economic and environmental sustainability test for the reasons set out in detail in the emerging Village Plan for Arnside (http://www.arnside.gov.uk/Warehouse/ArnsideLookingForward4.pdf).
They are also the main concern of the 550+ signature petitions raised and submitted to SLDC during this process which stressed the need to protect these greenfields and Important Open Spaces. As a result, the current Allocations do not have the support of the Arnside community, and therefore they fail the soundness test for community engagement and support.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
To ensure the arguments regarded the above objections are fully considered
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
69. Mr. Christopher Bisco (Individual) : 11 May 2012 15:00:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - M683sM-mod STORTH LAND S OF QUARRY LANE, STORTH
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
A series of changes should be made in order to comply with the NPPF and in order to deal with the lack of sound evidence in the current Land Allocations. Changes also need to be made to comply with SLDC's core strategy.
The proposed changes are listed in detail in our objections paper attached below in answer 2.3 of this form.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
SPECIFIC CONCERNS AND OBJECTIONS OF ARNSIDE PARISH PLAN TRUST (APPT) AND ARNSIDE PARISH COUNCIL (APC) REGARDING SLDC’s CURRENT LAND ALLOCATIONS.
1. SUMMARY
Arnside Parish Plan Trust and Arnside Parish Council believe that SLDC has produced a Land Allocation plan which does not pass the main tests of soundness and which;
• is not consistent with the detailed policies set out in its Core Strategy designed to apply the duty of the Council to protect the special characteristics and historic landscape of the Arnside and Silverdale Area of Outstanding Natural Beauty. In particular, its land allocations for housing propose using exclusively greenfield sites and land rated currently as "Important Open Space" which will have an adverse impact on the AONB landscape and on Arnside's settlement character.
• fails to identify how specific local needs (for affordable rented social housing) will be delivered in practise, and who will deliver that need.
• does not reconcile effectively the “highest status of protection” given to land within an AONB, as expressed in the new version of the NPPF, with delivering the local needs which qualify as “exceptional circumstances”.
• has failed to explore sufficiently all potential alternatives and to apply the appropriate land use hierarchy. Instead it defaults to allocating greenfield sites and Important Open Spaces within the AONB which currently have “the highest level of protection” and are particularly valued by the local community and by the management of the AONB.
• fails to address the need to regenerate brownfield sites in the village to repair the environmental damage they are inflicting.
• has failed to win the support of the local community (550 signed petition against) and to respond to emerging local plans. Neither does it have the support of the management of the AONB, Arnside Parish Council, Arnside Parish Plan Trust and other bodies important to the management of the specially protected environment of the AONB.
• relies on a planning policy which is not sustainable because it sets too high a site threshold of 0.3ha which could prevent a more organic approach to land use which will impose less damage than the development of large sites.
• assumes that a planning policy of relying on commercial development to provide affordable housing through a 65/35% allocation ratio is viable, without providing any evidence that this policy is workable in today’s and foreseeable market conditions.
• assumes that this 65/35% ratio (which consumes three times the amount of land needed for affordable housing) can be justified in relation to “the highest status of protection” provided by the NPPF against inappropriate development of land within an AONB.
• is not sustainable. Instead, it will damage the rural, open character of the village and its attraction to residents and visitors alike in a sensitive location within the AONB. This will undermine the economy on which the local community depends for a viable future.
APPT and APC set out in more detail below the basis of its objections. The process for filing objections is complex and difficult for lay people to use with confidence. As this document has been prepared without the benefit of advice from a planning lawyer, we hope that all our points will still be considered even if not categorised correctly.
We also reserve the right to make further submissions, and to present emerging new information, at the Inspector’s hearing.
2. AMPLIFICATION
2.1. Overview
Our principal objections to the current Land Allocations for Arnside are that SLDC has not met the standards of evidence and proof required to justify the allocation of greenfield sites against the special protections afforded to such land by the national policies contained in the new version of the NPPF, and, as a result, neither has it gained the support of the local community. The Allocations are not sound in the context of the specific circumstances of Arnside.
Apart from one brownfield site allocated for employment purposes, all sites allocated for housing are greenfield sites, and two of these are currently designated “Important Open Spaces”. Land within an AONB has the highest status of protection under the NPPF and, within this AONB, these Important Open Spaces have, over a long time, been regarded by the community as having special value to the character and sustainability of Arnside.
We assert that SLDC has a special duty to apply to these sites the highest status of protection available. We further assert that they have not demonstrated to the standard required that there are no other viable alternatives within Arnside, or in surrounding areas, to meet specific local needs for affordable housing. Market housing does not fit the criteria of "need" in this context, especially as there are consistently over 70 dwellings available for sale in all price ranges in Arnside.
The Arnside community (through Arnside Parish Council and Arnside Parish Plan Trust) believe that there are viable alternatives which could be brought into play over the extended period covered by the Land Allocations process. Under the new Community Planning and Neighbourhood Planning regimes, SLDC should therefore take the opportunity to explore these alternatives more effectively with community representatives and to establish whether a better plan could be produced.
Because of the failure of SLDC to demonstrate that it has used its best endeavours to explore all reasonable alternatives, and because of a number of weaknesses in the evidence base used as set out in more detail below, we object to SLDC’s current Land Allocations because they fail the test of soundness on a number of points.
2.2. Housing needs in Arnside
We recognise and accept that more affordable housing is needed in Arnside. The most accurate survey currently available of need in the area (dated 2009) indicates that there is a short term need for 27 affordable homes in the village. It is clear that by far the main element of that need is for social rented housing. Longer term needs are still very unclear.
There is already an adequate supply of market housing with available stock being sustained at over 70 homes for sale of all types and price ranges, so there is no “exceptional need” to allocate land for market housing.
There is also a history within the village of affordable housing being built but failing to be maintained as part of the ongoing affordable housing stock because it has been traded on as holiday homes and general market housing. This needs to be avoided in future.
We understand that, within a confined area such as Arnside, it is difficult to find sites which balance the conflicting objectives of providing needed affordable housing while at the same time preserving the character of the settlement within the AONB to the “highest status of protection” that SLDC, and we, are obliged to achieve.
We are concerned, however, that SLDC has produced a range of numbers to justify its Land Allocations. The attached Appendix illustrates the range of numbers cited in the plan. Under pressure from the local community, SLDC has reduced progressively the numbers allocated to the AONB in proportion to other areas within South Lakes District to try more effectively to minimise the adverse impact on the core characteristics of the AONB. We welcome the reduction in numbers and the attempts to address this challenge.
However, the fact that these numbers have only recently been further amended, and that they are based on proportional data drawn from the wider region rather than specific local needs, illustrates the lack of certainty and the weak evidence base for the need within Arnside.
This is important because precise allocations are required to deliver the right types of homes, and in order to avoid the allocation of inappropriate sites, and the unnecessary - and avoidable - destruction of highly valued greenfield space. We therefore believe that this element of the plan is unsound because the calculation of need requires further work to ensure the correct housing types are delivered, and to ensure that unnecessary damage to the character of the village within the AONB is avoided.
APPT and APC are keen to engage in further work with SLDC to establish a more accurate assessment of housing need within the village.
2.3. Inappropriate Land Allocations
Arnside contains currently brownfield - and other smaller sites - which SLDC has not listed in the Land Allocations. These sites could, and should, be developed both to supply affordable housing needs and to repair the detrimental affect on the character of the village caused by the derelict brownfield locations. It is argued by APPT/APC that these sites, if brought into use over the term of the Land Allocations Plan to 2025, could supply much of the specifically identified affordable housing needs of the Village.
The current SLDC Land Allocations, however, list exclusively greenfield sites for housing, two of which are currently listed as Important Open Space, and as such are important to defining the open and rural character of the village within the AONB and maintaining its long term economic sustainability.
We believe that the current allocations fail the test of supporting the economic and environmental sustainability test for the reasons set out in detail in the emerging Village Plan for Arnside (http://www.arnside.gov.uk/Warehouse/ArnsideLookingForward4.pdf).
They are also the main concern of the 550+ signature petitions raised and submitted to SLDC during this process which stressed the need to protect these greenfields and Important Open Spaces. As a result, the current Allocations do not have the support of the Arnside community, and therefore they fail the soundness test for community engagement and support.
The current Allocations also fail to meet the sequential test for the use of brownfield sites etc before allocating greenfield sites. The allocation of greenfield sites currently designated as Important Open Space within an AONB is even further up the sequential hierarchy and therefore further from meeting the soundness test.
As stated above, there are a range of smaller infill and brownfield sites which would not have as adverse an environmental impact and which could be brought into use over the plan period, especially if SLDC applied some of its other powers, or to adjust some of its current planning policies (see below), or if it took a longer view of potential availability.
The current allocations therefore fail the “exceptional circumstances” and “highest status of protection” national policy soundness test for Land Allocations within an AONB. This is because the current documents fail to demonstrate that SLDC has used its best endeavours to find alternatives over the lifetime of this planning period, and because it has not adapted its planning policies to fit the special circumstances and “highest status of protection” applying within an AONB.
2.4. Specific concerns about the soundness of local policies.
We have concerns about some of the stated policies and planning assumptions applied by SLDC within this process. If valid, they would mean that SLDC’s plan would fail the soundness tests in several regards.
• SLDC has taken a policy decision not to include sites of less than 0.3 hectares in the current Land Allocations. As a consequence it has had to resort to allocating sensitive and controversial large greenfield sites. SLDC has admitted, however, that the smaller sites could well come into play during the plan period and they would probably get planning permission. Such sites could, however, supply a substantial part of the local need for social rented housing, especially if they were developed in small increments by a housing association or similar body. We understand that a smaller threshold of 0.1ha is being applied within the Lake District National Park. We believe therefore that the soundness test will not be met because SLDC has made this policy decision without opting for an alternative approach to allocate smaller sites which could be used in the context of the exceptional circumstance test and highest status of protection applying within an AONB. The community believe that the larger and very sensitive greenfield sites should be removed from the allocations until the smaller site potential has been exhausted.
• The Local Development Plan appears also to be critically dependent on the success of the assumption that the main local need – for social rented affordable housing – will be delivered through the policy of allocating sites to commercial developers, subject to them building a 35% ratio of affordable housing within development sites. Despite considerable pressing for evidence, SLDC has not provided any data to demonstrate that this policy is viable and will succeed in the current economy and in future commercial development markets.
This is particularly important in view of major changes to financial and housing markets since 2008. SLDC needs to prove that commercial developers will be able to overcome the additional financial burden placed on these sites to pay for affordable housing and for such elements as the Community Infrastructure Levy. This has to be done against a background of a difficult credit market, very low housing turnover volumes, and falling house prices. All this in an area where the planning portfolio holder hopes and believes that this land allocation policy will reduce the price of market housing by 20%, thus increasing the pressure on the development funding model.
We have evidence locally that builders are unable to raise finance for site development and the above burdens will only aggravate these problems.
Because this is such a critical and fundamental assumption underlying the whole of SLDC’s Land Allocations, and because the future supply of affordable housing appears to depend entirely on it operating effectively, it is essential that robust and “bankable” evidence is provided by SLDC. Without it, the current Land Allocations cannot pass the deliverability test for the supply of local affordable housing and is therefore not sound.
• The 65/35 development ratio also has one further major weakness; it requires three times the amount of land which would be needed if only the local need for affordable housing is covered. This cannot be said to be meeting the test of “highest status of protection” or “exceptional circumstances” and is not sound because it does not comply with National Policy as expressed in the new version of the NPPF.
• It is much more likely that an appropriate body needs to be found which will focus specifically on building social rented housing without needing to rely on subsidies from a premium placed on commercial developments of market housing. The SLDC documents do not deal adequately with this issue and are therefore unsound because they fail to provide sufficient evidence that the Land Allocations and associated policies will deliver the specific local need for social rented housing.
• SLDC also appears to be driven by fear of the consequences of the new NPPF and their perception that developers will have unfettered access to land if sites are not allocated in a controlled process such as these Land Allocations. This is, it says, because of the “presumption in favour of development”.
We do not believe this to be true within an AONB because of the obligation to apply the “highest status of protection”, and inappropriate land allocations can continue to be resisted. There is therefore no need to rush this process. The current land allocations for Arnside should therefore be referred back for further work with the community to produce a more appropriate plan.
• SLDC appears to be over-relying on the very short term application of the “Deliverability” criteria within the Development Framework. In practise, this has led it to rely on sites where there is a clear immediate intention of the owner to make the site available for development and to capitalise on a commercial opportunity. If that commitment has not been made to date, potentially useful and less sensitive sites have been excluded, even if there is a reasonable chance that they will come into play over the longer term. The consequence of this is that derelict and previously used sites, which should be improved as part of any sensible spatial plan for any community, have been ignored. The knock-on consequence is that greenfield sites could be destroyed while derelict sites remain unused. This is not a sensible planning policy and fails even the commonsense soundness test.
• It is clear that it will take some time to bring into play some of the smaller and brownfield sites within the village but it is argued that the exceptional circumstances of the village within the AONB justify the extra effort (or time delay) that may be required. SLDC has failed to use its best endeavours to apply this extra effort by (for example) using the powers they have to bring derelict sites into use (such as Compulsory Purchase Orders). APPT are keen to work with SLDC to produce a Plan which achieves these objectives but, so far, SLDC has failed this test of soundness in meeting the exceptional circumstances criteria required within an AONB. The new Community planning regime under the Localism Act provides the opportunity to put this right by SLDC working closely with the community. The current land allocations should be deferred until this process has been completed. APPT/APC have an early draft of a community plan already in progress (http://www.arnside.gov.uk/Warehouse/ArnsideLookingForward4.pdf) and are keen to engage SLDC 's support in moving to a complete and workable version.
• We understand that the management of the Arnside & Silverdale Area of Outstanding Natural Beauty have similar and additional objections to the soundness of these Allocations. Arnside Parish Council, through Arnside Parish Plan Trust, intend to coordinate their emerging plans with this and other stakeholders for this area.
• We also understand that Lancaster City Council has a more appropriate treatment of land within the AONB in its Land Allocations policies but that SLDC has not yet coordinated its approach effectively with LCC. There may be solutions to local housing needs which could be accommodated within the neighbouring territories of LCC. SLDC will therefore fail to meet the soundness test until this process has been completed.
• Because of the above, the current Land Allocations should be referred back for revision. This revision would benefit from input from the emerging Arnside Community and Neighbourhood Plans which will address these issues.
Appendix 1
Land Allocation Development Plan Document – Calculation of Housing Need within the AONB*
There are 4 calculations of potential housing needs contained in the document for the AONB part of SLDC
CALCULATION 1
This is based on the AONB population as a % of the total Local Development Framework (LDF) area population
LDF Population 75000
AONB population 5% 3800 (Arnside 2300 and Beetham 1500)
Based on total district housing target of 400 per annum then 5% of this is 20 per annum for the AONB (12 for Arnside and 8 for Beetham)
Over the period 2003-2025 the total for the AONB is 460 (276 for Arnside and 184 for Beetham)
CALCULATION 2
This is based on the 2009 Strategic Market Assessment for Rural South Kendal. The figures for Annual Affordable Housing Requirements (See Page 63) for the period 2009-2015 were based on the 2006 Housing Needs Survey and indicates respondents aspirations.
Rural South Kendal Total 1105
AONB population 15.7% 173
(Arnside 104 and Beetham 69 based on population split shown in calculation 1)
If the above figures were projected at the same level for the whole of the plan 2009-2025 then this gives a total affordable housing need of 555 (333 for Arnside and 222 for Beetham based on population split shown in calculation 1)
CALCULATION 3
This is based on the 2011 Strategic Market Assessment for Rural South Kendal not including Milnthorpe and Kirkby Lonsdale. Again the survey appears to be aspirational. The response rate for Rural South Kendal was 30%. The calculations for the affordable housing market for 2011-2016 were based on:
• Households currently in housing which is unsuitable for their use and who are unable to afford to buy or rent in the market (backlog need)
• New household forming who cannot afford to buy or rent in the market
• Existing households expected to fall into need
• The supply of affordable housing through social renting and intermediate tenure stock
This calculation is similar to number 2
Rural South Kendal Total 435
AONB population 18.54% 225
(Arnside 133 and Beetham 89) based on population split shown in calculation 1)
CALCULATION 4
This is based on Arnside 2009 Housing Needs Survey and 2007 Beetham Housing Needs Survey to determine the need for affordable housing. This survey applied to social rented housing only and represented respondents aspirations and does not necessarily represent actual take up of affordable homes if they were offered. See Appendix Below: Analysis & Critical Review of Housing Needs
2009-14 Arnside 27 ? therefore projected number for 2009-2025 is 86
2007-12 Beetham* 17 ? therefore projected number for 2009-2025 is 61
But in order to deliver the affordable element an allowance for market housing has to be given. If affordable housing is delivered at 35% of market schemes this would bring the total need for 2009-2025 to 420 (Arnside 252 and Beetham 168)
*in the AONB part of Beetham
SUMMARY
Reference in Land Allocation Document Arnside Beetham Total Comments
3.79 Calculation 1 Total need 2003-2025 276 184 460 AONB population as a % of Local Development Area population
3.80 Calculation 2 Affordable need 2009-2025 333 222 555 AONB as a % of Rural South Kendal from an aspirational survey
3.81 Calculation 3 Affordable need 2009-2025 135 90 225 AONB as a % of Rural South Kendal LESS Milnthorpe and Kirkby Lonsdale from an aspirational survey
3.87 Calculation 4 Affordable need 2009-2025
Calculation 4 but also market allowance to achieve this 2009-2025 86
252 61
168 147
420 Arnside and Beetham aspirations for affordable housing
Market allowance figures are unrealistic because unlikely this scenario will happen
From the above 4 calculations it was concluded that the total housing need over the plan period was somewhere between 200 and 400 but because of the low housing delivery since 2003 to the present there was a need to do more per annum in the remaining period of the plan.
Because these calculations assume use of the 65/35% ration of market to affordable housing, the actual need for affordable housing is much less than the numbers stated above..
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
The objections of Arnside Parish Council and Arnside Parish Plan Trust are fundamental to the soundness of the Land Allocations DPD, particularly in the context of the Arnside & Silverdale AONB and the application of the NPPF.
The arguments are complex and have been presented in detail in our written submission but we expect further data to become available before the Examination which we would like to present.
As the points we raise are of such fundamental importance to the soundeness of the Land Allocations, it is important that we are heard and seen to be heard. As I drafted the objections document, I will represent both APC and APPT unless we decide to appoint legal representation for the hearing.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
70. Mr. Christopher Bisco (Individual) : 11 May 2012 15:10:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA2.12 Mixed Use Allocation at Sandside Road, Arnside
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Not Compliant because it does not have proper regard for "the Highest status of protection" afforded to land within an AONB and the other reasons referred to in the paper by Arnside Parish Plan Trust and Arnside Parish Council reproduced in section 2.3 below
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
SPECIFIC CONCERNS AND OBJECTIONS OF ARNSIDE PARISH PLAN TRUST (APPT) AND ARNSIDE PARISH COUNCIL REGARDING SLDC’s CURRENT LAND ALLOCATIONS.
1. SUMMARY
Arnside Parish Plan Trust and Arnside Parish Council believe that SLDC has produced a Land Allocation plan which does not pass the main tests of soundness and which;
• is not consistent with the detailed policies set out in its Core Strategy designed to apply the duty of the Council to protect the special characteristics and historic landscape of the Arnside and Silverdale Area of Outstanding Natural Beauty. In particular, its land allocations for housing propose using exclusively greenfield sites and land rated currently as "Important Open Space" which will have an adverse impact on the AONB landscape and on Arnside's settlement character.
• fails to identify how specific local needs (for affordable rented social housing) will be delivered in practise, and who will deliver that need.
• does not reconcile effectively the “highest status of protection” given to land within an AONB, as expressed in the new version of the NPPF, with delivering the local needs which qualify as “exceptional circumstances”.
• has failed to explore sufficiently all potential alternatives and to apply the appropriate land use hierarchy. Instead it defaults to allocating greenfield sites and Important Open Spaces within the AONB which currently have “the highest level of protection” and are particularly valued by the local community and by the management of the AONB.
• fails to address the need to regenerate brownfield sites in the village to repair the environmental damage they are inflicting.
• has failed to win the support of the local community (550 signed petition against) and to respond to emerging local plans. Neither does it have the support of the management of the AONB, Arnside Parish Council, Arnside Parish Plan Trust and other bodies important to the management of the specially protected environment of the AONB.
• relies on a planning policy which is not sustainable because it sets too high a site threshold of 0.3ha which could prevent a more organic approach to land use which will impose less damage than the development of large sites.
• assumes that a planning policy of relying on commercial development to provide affordable housing through a 65/35% allocation ratio is viable, without providing any evidence that this policy is workable in today’s and foreseeable market conditions.
• assumes that this 65/35% ratio (which consumes three times the amount of land needed for affordable housing) can be justified in relation to “the highest status of protection” provided by the NPPF against inappropriate development of land within an AONB.
• is not sustainable. Instead, it will damage the rural, open character of the village and its attraction to residents and visitors alike in a sensitive location within the AONB. This will undermine the economy on which the local community depends for a viable future.
APPT and APC set out in more detail below the basis of its objections. The process for filing objections is complex and difficult for lay people to use with confidence. As this document has been prepared without the benefit of advice from a planning lawyer, we hope that all our points will still be considered even if not categorised correctly.
We also reserve the right to make further submissions, and to present emerging new information, at the Inspector’s hearing.
2. AMPLIFICATION
2.1. Overview
Our principal objections to the current Land Allocations for Arnside are that SLDC has not met the standards of evidence and proof required to justify the allocation of greenfield sites against the special protections afforded to such land by the national policies contained in the new version of the NPPF, and, as a result, neither has it gained the support of the local community. The Allocations are not sound in the context of the specific circumstances of Arnside.
Apart from one brownfield site allocated for employment purposes, all sites allocated for housing are greenfield sites, and two of these are currently designated “Important Open Spaces”. Land within an AONB has the highest status of protection under the NPPF and, within this AONB, these Important Open Spaces have, over a long time, been regarded by the community as having special value to the character and sustainability of Arnside.
We assert that SLDC has a special duty to apply to these sites the highest status of protection available. We further assert that they have not demonstrated to the standard required that there are no other viable alternatives within Arnside, or in surrounding areas, to meet specific local needs for affordable housing. Market housing does not fit the criteria of "need" in this context, especially as there are consistently over 70 dwellings available for sale in all price ranges in Arnside.
The Arnside community (through Arnside Parish Council and Arnside Parish Plan Trust) believe that there are viable alternatives which could be brought into play over the extended period covered by the Land Allocations process. Under the new Community Planning and Neighbourhood Planning regimes, SLDC should therefore take the opportunity to explore these alternatives more effectively with community representatives and to establish whether a better plan could be produced.
Because of the failure of SLDC to demonstrate that it has used its best endeavours to explore all reasonable alternatives, and because of a number of weaknesses in the evidence base used as set out in more detail below, we object to SLDC’s current Land Allocations because they fail the test of soundness on a number of points.
2.2. Housing needs in Arnside
We recognise and accept that more affordable housing is needed in Arnside. The most accurate survey currently available of need in the area (dated 2009) indicates that there is a short term need for 27 affordable homes in the village. It is clear that by far the main element of that need is for social rented housing. Longer term needs are still very unclear.
There is already an adequate supply of market housing with available stock being sustained at over 70 homes for sale of all types and price ranges, so there is no “exceptional need” to allocate land for market housing.
There is also a history within the village of affordable housing being built but failing to be maintained as part of the ongoing affordable housing stock because it has been traded on as holiday homes and general market housing. This needs to be avoided in future.
We understand that, within a confined area such as Arnside, it is difficult to find sites which balance the conflicting objectives of providing needed affordable housing while at the same time preserving the character of the settlement within the AONB to the “highest status of protection” that SLDC, and we, are obliged to achieve.
We are concerned, however, that SLDC has produced a range of numbers to justify its Land Allocations. The attached Appendix illustrates the range of numbers cited in the plan. Under pressure from the local community, SLDC has reduced progressively the numbers allocated to the AONB in proportion to other areas within South Lakes District to try more effectively to minimise the adverse impact on the core characteristics of the AONB. We welcome the reduction in numbers and the attempts to address this challenge.
However, the fact that these numbers have only recently been further amended, and that they are based on proportional data drawn from the wider region rather than specific local needs, illustrates the lack of certainty and the weak evidence base for the need within Arnside.
This is important because precise allocations are required to deliver the right types of homes, and in order to avoid the allocation of inappropriate sites, and the unnecessary - and avoidable - destruction of highly valued greenfield space. We therefore believe that this element of the plan is unsound because the calculation of need requires further work to ensure the correct housing types are delivered, and to ensure that unnecessary damage to the character of the village within the AONB is avoided.
APPT and APC are keen to engage in further work with SLDC to establish a more accurate assessment of housing need within the village.
2.3. Inappropriate Land Allocations
Arnside contains currently brownfield - and other smaller sites - which SLDC has not listed in the Land Allocations. These sites could, and should, be developed both to supply affordable housing needs and to repair the detrimental affect on the character of the village caused by the derelict brownfield locations. It is argued by APPT/APC that these sites, if brought into use over the term of the Land Allocations Plan to 2025, could supply much of the specifically identified affordable housing needs of the Village.
The current SLDC Land Allocations, however, list exclusively greenfield sites for housing, two of which are currently listed as Important Open Space, and as such are important to defining the open and rural character of the village within the AONB and maintaining its long term economic sustainability.
We believe that the current allocations fail the test of supporting the economic and environmental sustainability test for the reasons set out in detail in the emerging Village Plan for Arnside (http://www.arnside.gov.uk/Warehouse/ArnsideLookingForward4.pdf).
They are also the main concern of the 550+ signature petitions raised and submitted to SLDC during this process which stressed the need to protect these greenfields and Important Open Spaces. As a result, the current Allocations do not have the support of the Arnside community, and therefore they fail the soundness test for community engagement and support.
The current Allocations also fail to meet the sequential test for the use of brownfield sites etc before allocating greenfield sites. The allocation of greenfield sites currently designated as Important Open Space within an AONB is even further up the sequential hierarchy and therefore further from meeting the soundness test.
As stated above, there are a range of smaller infill and brownfield sites which would not have as adverse an environmental impact and which could be brought into use over the plan period, especially if SLDC applied some of its other powers, or to adjust some of its current planning policies (see below), or if it took a longer view of potential availability.
The current allocations therefore fail the “exceptional circumstances” and “highest status of protection” national policy soundness test for Land Allocations within an AONB. This is because the current documents fail to demonstrate that SLDC has used its best endeavours to find alternatives over the lifetime of this planning period, and because it has not adapted its planning policies to fit the special circumstances and “highest status of protection” applying within an AONB.
2.4. Specific concerns about the soundness of local policies.
We have concerns about some of the stated policies and planning assumptions applied by SLDC within this process. If valid, they would mean that SLDC’s plan would fail the soundness tests in several regards.
• SLDC has taken a policy decision not to include sites of less than 0.3 hectares in the current Land Allocations. As a consequence it has had to resort to allocating sensitive and controversial large greenfield sites. SLDC has admitted, however, that the smaller sites could well come into play during the plan period and they would probably get planning permission. Such sites could, however, supply a substantial part of the local need for social rented housing, especially if they were developed in small increments by a housing association or similar body. We understand that a smaller threshold of 0.1ha is being applied within the Lake District National Park. We believe therefore that the soundness test will not be met because SLDC has made this policy decision without opting for an alternative approach to allocate smaller sites which could be used in the context of the exceptional circumstance test and highest status of protection applying within an AONB. The community believe that the larger and very sensitive greenfield sites should be removed from the allocations until the smaller site potential has been exhausted.
• The Local Development Plan appears also to be critically dependent on the success of the assumption that the main local need – for social rented affordable housing – will be delivered through the policy of allocating sites to commercial developers, subject to them building a 35% ratio of affordable housing within development sites. Despite considerable pressing for evidence, SLDC has not provided any data to demonstrate that this policy is viable and will succeed in the current economy and in future commercial development markets.
This is particularly important in view of major changes to financial and housing markets since 2008. SLDC needs to prove that commercial developers will be able to overcome the additional financial burden placed on these sites to pay for affordable housing and for such elements as the Community Infrastructure Levy. This has to be done against a background of a difficult credit market, very low housing turnover volumes, and falling house prices. All this in an area where the planning portfolio holder hopes and believes that this land allocation policy will reduce the price of market housing by 20%, thus increasing the pressure on the development funding model.
We have evidence locally that builders are unable to raise finance for site development and the above burdens will only aggravate these problems.
Because this is such a critical and fundamental assumption underlying the whole of SLDC’s Land Allocations, and because the future supply of affordable housing appears to depend entirely on it operating effectively, it is essential that robust and “bankable” evidence is provided by SLDC. Without it, the current Land Allocations cannot pass the deliverability test for the supply of local affordable housing and is therefore not sound.
• The 65/35 development ratio also has one further major weakness; it requires three times the amount of land which would be needed if only the local need for affordable housing is covered. This cannot be said to be meeting the test of “highest status of protection” or “exceptional circumstances” and is not sound because it does not comply with National Policy as expressed in the new version of the NPPF.
• It is much more likely that an appropriate body needs to be found which will focus specifically on building social rented housing without needing to rely on subsidies from a premium placed on commercial developments of market housing. The SLDC documents do not deal adequately with this issue and are therefore unsound because they fail to provide sufficient evidence that the Land Allocations and associated policies will deliver the specific local need for social rented housing.
• SLDC also appears to be driven by fear of the consequences of the new NPPF and their perception that developers will have unfettered access to land if sites are not allocated in a controlled process such as these Land Allocations. This is, it says, because of the “presumption in favour of development”.
We do not believe this to be true within an AONB because of the obligation to apply the “highest status of protection”, and inappropriate land allocations can continue to be resisted. There is therefore no need to rush this process. The current land allocations for Arnside should therefore be referred back for further work with the community to produce a more appropriate plan.
• SLDC appears to be over-relying on the very short term application of the “Deliverability” criteria within the Development Framework. In practise, this has led it to rely on sites where there is a clear immediate intention of the owner to make the site available for development and to capitalise on a commercial opportunity. If that commitment has not been made to date, potentially useful and less sensitive sites have been excluded, even if there is a reasonable chance that they will come into play over the longer term. The consequence of this is that derelict and previously used sites, which should be improved as part of any sensible spatial plan for any community, have been ignored. The knock-on consequence is that greenfield sites could be destroyed while derelict sites remain unused. This is not a sensible planning policy and fails even the commonsense soundness test.
• It is clear that it will take some time to bring into play some of the smaller and brownfield sites within the village but it is argued that the exceptional circumstances of the village within the AONB justify the extra effort (or time delay) that may be required. SLDC has failed to use its best endeavours to apply this extra effort by (for example) using the powers they have to bring derelict sites into use (such as Compulsory Purchase Orders). APPT are keen to work with SLDC to produce a Plan which achieves these objectives but, so far, SLDC has failed this test of soundness in meeting the exceptional circumstances criteria required within an AONB. The new Community planning regime under the Localism Act provides the opportunity to put this right by SLDC working closely with the community. The current land allocations should be deferred until this process has been completed. APPT/APC have an early draft of a community plan already in progress (http://www.arnside.gov.uk/Warehouse/ArnsideLookingForward4.pdf) and are keen to engage SLDC 's support in moving to a complete and workable version.
• We understand that the management of the Arnside & Silverdale Area of Outstanding Natural Beauty have similar and additional objections to the soundness of these Allocations. Arnside Parish Council, through Arnside Parish Plan Trust, intend to coordinate their emerging plans with this and other stakeholders for this area.
• We also understand that Lancaster City Council has a more appropriate treatment of land within the AONB in its Land Allocations policies but that SLDC has not yet coordinated its approach effectively with LCC. There may be solutions to local housing needs which could be accommodated within the neighbouring territories of LCC. SLDC will therefore fail to meet the soundness test until this process has been completed.
• Because of the above, the current Land Allocations should be referred back for revision. This revision would benefit from input from the emerging Arnside Community and Neighbourhood Plans which will address these issues.
Appendix 1
Land Allocation Development Plan Document – Calculation of Housing Need within the AONB*
There are 4 calculations of potential housing needs contained in the document for the AONB part of SLDC
CALCULATION 1
This is based on the AONB population as a % of the total Local Development Framework (LDF) area population
LDF Population 75000
AONB population 5% 3800 (Arnside 2300 and Beetham 1500)
Based on total district housing target of 400 per annum then 5% of this is 20 per annum for the AONB (12 for Arnside and 8 for Beetham)
Over the period 2003-2025 the total for the AONB is 460 (276 for Arnside and 184 for Beetham)
CALCULATION 2
This is based on the 2009 Strategic Market Assessment for Rural South Kendal. The figures for Annual Affordable Housing Requirements (See Page 63) for the period 2009-2015 were based on the 2006 Housing Needs Survey and indicates respondents aspirations.
Rural South Kendal Total 1105
AONB population 15.7% 173
(Arnside 104 and Beetham 69 based on population split shown in calculation 1)
If the above figures were projected at the same level for the whole of the plan 2009-2025 then this gives a total affordable housing need of 555 (333 for Arnside and 222 for Beetham based on population split shown in calculation 1)
CALCULATION 3
This is based on the 2011 Strategic Market Assessment for Rural South Kendal not including Milnthorpe and Kirkby Lonsdale. Again the survey appears to be aspirational. The response rate for Rural South Kendal was 30%. The calculations for the affordable housing market for 2011-2016 were based on:
• Households currently in housing which is unsuitable for their use and who are unable to afford to buy or rent in the market (backlog need)
• New household forming who cannot afford to buy or rent in the market
• Existing households expected to fall into need
• The supply of affordable housing through social renting and intermediate tenure stock
This calculation is similar to number 2
Rural South Kendal Total 435
AONB population 18.54% 225
(Arnside 133 and Beetham 89) based on population split shown in calculation 1)
CALCULATION 4
This is based on Arnside 2009 Housing Needs Survey and 2007 Beetham Housing Needs Survey to determine the need for affordable housing. This survey applied to social rented housing only and represented respondents aspirations and does not necessarily represent actual take up of affordable homes if they were offered. See Appendix Below: Analysis & Critical Review of Housing Needs
2009-14 Arnside 27 ? therefore projected number for 2009-2025 is 86
2007-12 Beetham* 17 ? therefore projected number for 2009-2025 is 61
But in order to deliver the affordable element an allowance for market housing has to be given. If affordable housing is delivered at 35% of market schemes this would bring the total need for 2009-2025 to 420 (Arnside 252 and Beetham 168)
*in the AONB part of Beetham
SUMMARY
Reference in Land Allocation Document Arnside Beetham Total Comments
3.79 Calculation 1 Total need 2003-2025 276 184 460 AONB population as a % of Local Development Area population
3.80 Calculation 2 Affordable need 2009-2025 333 222 555 AONB as a % of Rural South Kendal from an aspirational survey
3.81 Calculation 3 Affordable need 2009-2025 135 90 225 AONB as a % of Rural South Kendal LESS Milnthorpe and Kirkby Lonsdale from an aspirational survey
3.87 Calculation 4 Affordable need 2009-2025
Calculation 4 but also market allowance to achieve this 2009-2025 86
252 61
168 147
420 Arnside and Beetham aspirations for affordable housing
Market allowance figures are unrealistic because unlikely this scenario will happen
From the above 4 calculations it was concluded that the total housing need over the plan period was somewhere between 200 and 400 but because of the low housing delivery since 2003 to the present there was a need to do more per annum in the remaining period of the plan.
Because these calculations assume use of the 65/35% ration of market to affordable housing, the actual need for affordable housing is much less than the numbers stated above..
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
To ensure the arguments regarded the above objections are fully considered
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
71. Mr. Christopher Bisco (Individual) : 11 May 2012 15:14:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.8 Local Employment Allocations - EN40-mod SANDSIDE LAND SOUTH OF QUARRY LANE
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Not Compliant because it does not have proper regard for "the Highest status of protection" afforded to land within an AONB and the other reasons referred to in the paper by Arnside Parish Plan Trust and Arnside Parish Council reproduced in section 2.3 below
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
SPECIFIC CONCERNS AND OBJECTIONS OF ARNSIDE PARISH PLAN TRUST (APPT) AND ARNSIDE PARISH COUNCIL REGARDING SLDC’s CURRENT LAND ALLOCATIONS.
1. SUMMARY
Arnside Parish Plan Trust and Arnside Parish Council believe that SLDC has produced a Land Allocation plan which does not pass the main tests of soundness and which;
• is not consistent with the detailed policies set out in its Core Strategy designed to apply the duty of the Council to protect the special characteristics and historic landscape of the Arnside and Silverdale Area of Outstanding Natural Beauty. In particular, its land allocations for housing propose using exclusively greenfield sites and land rated currently as "Important Open Space" which will have an adverse impact on the AONB landscape and on Arnside's settlement character.
• fails to identify how specific local needs (for affordable rented social housing) will be delivered in practise, and who will deliver that need.
• does not reconcile effectively the “highest status of protection” given to land within an AONB, as expressed in the new version of the NPPF, with delivering the local needs which qualify as “exceptional circumstances”.
• has failed to explore sufficiently all potential alternatives and to apply the appropriate land use hierarchy. Instead it defaults to allocating greenfield sites and Important Open Spaces within the AONB which currently have “the highest level of protection” and are particularly valued by the local community and by the management of the AONB.
• fails to address the need to regenerate brownfield sites in the village to repair the environmental damage they are inflicting.
• has failed to win the support of the local community (550 signed petition against) and to respond to emerging local plans. Neither does it have the support of the management of the AONB, Arnside Parish Council, Arnside Parish Plan Trust and other bodies important to the management of the specially protected environment of the AONB.
• relies on a planning policy which is not sustainable because it sets too high a site threshold of 0.3ha which could prevent a more organic approach to land use which will impose less damage than the development of large sites.
• assumes that a planning policy of relying on commercial development to provide affordable housing through a 65/35% allocation ratio is viable, without providing any evidence that this policy is workable in today’s and foreseeable market conditions.
• assumes that this 65/35% ratio (which consumes three times the amount of land needed for affordable housing) can be justified in relation to “the highest status of protection” provided by the NPPF against inappropriate development of land within an AONB.
• is not sustainable. Instead, it will damage the rural, open character of the village and its attraction to residents and visitors alike in a sensitive location within the AONB. This will undermine the economy on which the local community depends for a viable future.
APPT and APC set out in more detail below the basis of its objections. The process for filing objections is complex and difficult for lay people to use with confidence. As this document has been prepared without the benefit of advice from a planning lawyer, we hope that all our points will still be considered even if not categorised correctly.
We also reserve the right to make further submissions, and to present emerging new information, at the Inspector’s hearing.
2. AMPLIFICATION
2.1. Overview
Our principal objections to the current Land Allocations for Arnside are that SLDC has not met the standards of evidence and proof required to justify the allocation of greenfield sites against the special protections afforded to such land by the national policies contained in the new version of the NPPF, and, as a result, neither has it gained the support of the local community. The Allocations are not sound in the context of the specific circumstances of Arnside.
Apart from one brownfield site allocated for employment purposes, all sites allocated for housing are greenfield sites, and two of these are currently designated “Important Open Spaces”. Land within an AONB has the highest status of protection under the NPPF and, within this AONB, these Important Open Spaces have, over a long time, been regarded by the community as having special value to the character and sustainability of Arnside.
We assert that SLDC has a special duty to apply to these sites the highest status of protection available. We further assert that they have not demonstrated to the standard required that there are no other viable alternatives within Arnside, or in surrounding areas, to meet specific local needs for affordable housing. Market housing does not fit the criteria of "need" in this context, especially as there are consistently over 70 dwellings available for sale in all price ranges in Arnside.
The Arnside community (through Arnside Parish Council and Arnside Parish Plan Trust) believe that there are viable alternatives which could be brought into play over the extended period covered by the Land Allocations process. Under the new Community Planning and Neighbourhood Planning regimes, SLDC should therefore take the opportunity to explore these alternatives more effectively with community representatives and to establish whether a better plan could be produced.
Because of the failure of SLDC to demonstrate that it has used its best endeavours to explore all reasonable alternatives, and because of a number of weaknesses in the evidence base used as set out in more detail below, we object to SLDC’s current Land Allocations because they fail the test of soundness on a number of points.
2.2. Housing needs in Arnside
We recognise and accept that more affordable housing is needed in Arnside. The most accurate survey currently available of need in the area (dated 2009) indicates that there is a short term need for 27 affordable homes in the village. It is clear that by far the main element of that need is for social rented housing. Longer term needs are still very unclear.
There is already an adequate supply of market housing with available stock being sustained at over 70 homes for sale of all types and price ranges, so there is no “exceptional need” to allocate land for market housing.
There is also a history within the village of affordable housing being built but failing to be maintained as part of the ongoing affordable housing stock because it has been traded on as holiday homes and general market housing. This needs to be avoided in future.
We understand that, within a confined area such as Arnside, it is difficult to find sites which balance the conflicting objectives of providing needed affordable housing while at the same time preserving the character of the settlement within the AONB to the “highest status of protection” that SLDC, and we, are obliged to achieve.
We are concerned, however, that SLDC has produced a range of numbers to justify its Land Allocations. The attached Appendix illustrates the range of numbers cited in the plan. Under pressure from the local community, SLDC has reduced progressively the numbers allocated to the AONB in proportion to other areas within South Lakes District to try more effectively to minimise the adverse impact on the core characteristics of the AONB. We welcome the reduction in numbers and the attempts to address this challenge.
However, the fact that these numbers have only recently been further amended, and that they are based on proportional data drawn from the wider region rather than specific local needs, illustrates the lack of certainty and the weak evidence base for the need within Arnside.
This is important because precise allocations are required to deliver the right types of homes, and in order to avoid the allocation of inappropriate sites, and the unnecessary - and avoidable - destruction of highly valued greenfield space. We therefore believe that this element of the plan is unsound because the calculation of need requires further work to ensure the correct housing types are delivered, and to ensure that unnecessary damage to the character of the village within the AONB is avoided.
APPT and APC are keen to engage in further work with SLDC to establish a more accurate assessment of housing need within the village.
2.3. Inappropriate Land Allocations
Arnside contains currently brownfield - and other smaller sites - which SLDC has not listed in the Land Allocations. These sites could, and should, be developed both to supply affordable housing needs and to repair the detrimental affect on the character of the village caused by the derelict brownfield locations. It is argued by APPT/APC that these sites, if brought into use over the term of the Land Allocations Plan to 2025, could supply much of the specifically identified affordable housing needs of the Village.
The current SLDC Land Allocations, however, list exclusively greenfield sites for housing, two of which are currently listed as Important Open Space, and as such are important to defining the open and rural character of the village within the AONB and maintaining its long term economic sustainability.
We believe that the current allocations fail the test of supporting the economic and environmental sustainability test for the reasons set out in detail in the emerging Village Plan for Arnside (http://www.arnside.gov.uk/Warehouse/ArnsideLookingForward4.pdf).
They are also the main concern of the 550+ signature petitions raised and submitted to SLDC during this process which stressed the need to protect these greenfields and Important Open Spaces. As a result, the current Allocations do not have the support of the Arnside community, and therefore they fail the soundness test for community engagement and support.
The current Allocations also fail to meet the sequential test for the use of brownfield sites etc before allocating greenfield sites. The allocation of greenfield sites currently designated as Important Open Space within an AONB is even further up the sequential hierarchy and therefore further from meeting the soundness test.
As stated above, there are a range of smaller infill and brownfield sites which would not have as adverse an environmental impact and which could be brought into use over the plan period, especially if SLDC applied some of its other powers, or to adjust some of its current planning policies (see below), or if it took a longer view of potential availability.
The current allocations therefore fail the “exceptional circumstances” and “highest status of protection” national policy soundness test for Land Allocations within an AONB. This is because the current documents fail to demonstrate that SLDC has used its best endeavours to find alternatives over the lifetime of this planning period, and because it has not adapted its planning policies to fit the special circumstances and “highest status of protection” applying within an AONB.
2.4. Specific concerns about the soundness of local policies.
We have concerns about some of the stated policies and planning assumptions applied by SLDC within this process. If valid, they would mean that SLDC’s plan would fail the soundness tests in several regards.
• SLDC has taken a policy decision not to include sites of less than 0.3 hectares in the current Land Allocations. As a consequence it has had to resort to allocating sensitive and controversial large greenfield sites. SLDC has admitted, however, that the smaller sites could well come into play during the plan period and they would probably get planning permission. Such sites could, however, supply a substantial part of the local need for social rented housing, especially if they were developed in small increments by a housing association or similar body. We understand that a smaller threshold of 0.1ha is being applied within the Lake District National Park. We believe therefore that the soundness test will not be met because SLDC has made this policy decision without opting for an alternative approach to allocate smaller sites which could be used in the context of the exceptional circumstance test and highest status of protection applying within an AONB. The community believe that the larger and very sensitive greenfield sites should be removed from the allocations until the smaller site potential has been exhausted.
• The Local Development Plan appears also to be critically dependent on the success of the assumption that the main local need – for social rented affordable housing – will be delivered through the policy of allocating sites to commercial developers, subject to them building a 35% ratio of affordable housing within development sites. Despite considerable pressing for evidence, SLDC has not provided any data to demonstrate that this policy is viable and will succeed in the current economy and in future commercial development markets.
This is particularly important in view of major changes to financial and housing markets since 2008. SLDC needs to prove that commercial developers will be able to overcome the additional financial burden placed on these sites to pay for affordable housing and for such elements as the Community Infrastructure Levy. This has to be done against a background of a difficult credit market, very low housing turnover volumes, and falling house prices. All this in an area where the planning portfolio holder hopes and believes that this land allocation policy will reduce the price of market housing by 20%, thus increasing the pressure on the development funding model.
We have evidence locally that builders are unable to raise finance for site development and the above burdens will only aggravate these problems.
Because this is such a critical and fundamental assumption underlying the whole of SLDC’s Land Allocations, and because the future supply of affordable housing appears to depend entirely on it operating effectively, it is essential that robust and “bankable” evidence is provided by SLDC. Without it, the current Land Allocations cannot pass the deliverability test for the supply of local affordable housing and is therefore not sound.
• The 65/35 development ratio also has one further major weakness; it requires three times the amount of land which would be needed if only the local need for affordable housing is covered. This cannot be said to be meeting the test of “highest status of protection” or “exceptional circumstances” and is not sound because it does not comply with National Policy as expressed in the new version of the NPPF.
• It is much more likely that an appropriate body needs to be found which will focus specifically on building social rented housing without needing to rely on subsidies from a premium placed on commercial developments of market housing. The SLDC documents do not deal adequately with this issue and are therefore unsound because they fail to provide sufficient evidence that the Land Allocations and associated policies will deliver the specific local need for social rented housing.
• SLDC also appears to be driven by fear of the consequences of the new NPPF and their perception that developers will have unfettered access to land if sites are not allocated in a controlled process such as these Land Allocations. This is, it says, because of the “presumption in favour of development”.
We do not believe this to be true within an AONB because of the obligation to apply the “highest status of protection”, and inappropriate land allocations can continue to be resisted. There is therefore no need to rush this process. The current land allocations for Arnside should therefore be referred back for further work with the community to produce a more appropriate plan.
• SLDC appears to be over-relying on the very short term application of the “Deliverability” criteria within the Development Framework. In practise, this has led it to rely on sites where there is a clear immediate intention of the owner to make the site available for development and to capitalise on a commercial opportunity. If that commitment has not been made to date, potentially useful and less sensitive sites have been excluded, even if there is a reasonable chance that they will come into play over the longer term. The consequence of this is that derelict and previously used sites, which should be improved as part of any sensible spatial plan for any community, have been ignored. The knock-on consequence is that greenfield sites could be destroyed while derelict sites remain unused. This is not a sensible planning policy and fails even the commonsense soundness test.
• It is clear that it will take some time to bring into play some of the smaller and brownfield sites within the village but it is argued that the exceptional circumstances of the village within the AONB justify the extra effort (or time delay) that may be required. SLDC has failed to use its best endeavours to apply this extra effort by (for example) using the powers they have to bring derelict sites into use (such as Compulsory Purchase Orders). APPT are keen to work with SLDC to produce a Plan which achieves these objectives but, so far, SLDC has failed this test of soundness in meeting the exceptional circumstances criteria required within an AONB. The new Community planning regime under the Localism Act provides the opportunity to put this right by SLDC working closely with the community. The current land allocations should be deferred until this process has been completed. APPT/APC have an early draft of a community plan already in progress (http://www.arnside.gov.uk/Warehouse/ArnsideLookingForward4.pdf) and are keen to engage SLDC 's support in moving to a complete and workable version.
• We understand that the management of the Arnside & Silverdale Area of Outstanding Natural Beauty have similar and additional objections to the soundness of these Allocations. Arnside Parish Council, through Arnside Parish Plan Trust, intend to coordinate their emerging plans with this and other stakeholders for this area.
• We also understand that Lancaster City Council has a more appropriate treatment of land within the AONB in its Land Allocations policies but that SLDC has not yet coordinated its approach effectively with LCC. There may be solutions to local housing needs which could be accommodated within the neighbouring territories of LCC. SLDC will therefore fail to meet the soundness test until this process has been completed.
• Because of the above, the current Land Allocations should be referred back for revision. This revision would benefit from input from the emerging Arnside Community and Neighbourhood Plans which will address these issues.
Appendix 1
Land Allocation Development Plan Document – Calculation of Housing Need within the AONB*
There are 4 calculations of potential housing needs contained in the document for the AONB part of SLDC
CALCULATION 1
This is based on the AONB population as a % of the total Local Development Framework (LDF) area population
LDF Population 75000
AONB population 5% 3800 (Arnside 2300 and Beetham 1500)
Based on total district housing target of 400 per annum then 5% of this is 20 per annum for the AONB (12 for Arnside and 8 for Beetham)
Over the period 2003-2025 the total for the AONB is 460 (276 for Arnside and 184 for Beetham)
CALCULATION 2
This is based on the 2009 Strategic Market Assessment for Rural South Kendal. The figures for Annual Affordable Housing Requirements (See Page 63) for the period 2009-2015 were based on the 2006 Housing Needs Survey and indicates respondents aspirations.
Rural South Kendal Total 1105
AONB population 15.7% 173
(Arnside 104 and Beetham 69 based on population split shown in calculation 1)
If the above figures were projected at the same level for the whole of the plan 2009-2025 then this gives a total affordable housing need of 555 (333 for Arnside and 222 for Beetham based on population split shown in calculation 1)
CALCULATION 3
This is based on the 2011 Strategic Market Assessment for Rural South Kendal not including Milnthorpe and Kirkby Lonsdale. Again the survey appears to be aspirational. The response rate for Rural South Kendal was 30%. The calculations for the affordable housing market for 2011-2016 were based on:
• Households currently in housing which is unsuitable for their use and who are unable to afford to buy or rent in the market (backlog need)
• New household forming who cannot afford to buy or rent in the market
• Existing households expected to fall into need
• The supply of affordable housing through social renting and intermediate tenure stock
This calculation is similar to number 2
Rural South Kendal Total 435
AONB population 18.54% 225
(Arnside 133 and Beetham 89) based on population split shown in calculation 1)
CALCULATION 4
This is based on Arnside 2009 Housing Needs Survey and 2007 Beetham Housing Needs Survey to determine the need for affordable housing. This survey applied to social rented housing only and represented respondents aspirations and does not necessarily represent actual take up of affordable homes if they were offered. See Appendix Below: Analysis & Critical Review of Housing Needs
2009-14 Arnside 27 ? therefore projected number for 2009-2025 is 86
2007-12 Beetham* 17 ? therefore projected number for 2009-2025 is 61
But in order to deliver the affordable element an allowance for market housing has to be given. If affordable housing is delivered at 35% of market schemes this would bring the total need for 2009-2025 to 420 (Arnside 252 and Beetham 168)
*in the AONB part of Beetham
SUMMARY
Reference in Land Allocation Document Arnside Beetham Total Comments
3.79 Calculation 1 Total need 2003-2025 276 184 460 AONB population as a % of Local Development Area population
3.80 Calculation 2 Affordable need 2009-2025 333 222 555 AONB as a % of Rural South Kendal from an aspirational survey
3.81 Calculation 3 Affordable need 2009-2025 135 90 225 AONB as a % of Rural South Kendal LESS Milnthorpe and Kirkby Lonsdale from an aspirational survey
3.87 Calculation 4 Affordable need 2009-2025
Calculation 4 but also market allowance to achieve this 2009-2025 86
252 61
168 147
420 Arnside and Beetham aspirations for affordable housing
Market allowance figures are unrealistic because unlikely this scenario will happen
From the above 4 calculations it was concluded that the total housing need over the plan period was somewhere between 200 and 400 but because of the low housing delivery since 2003 to the present there was a need to do more per annum in the remaining period of the plan.
Because these calculations assume use of the 65/35% ration of market to affordable housing, the actual need for affordable housing is much less than the numbers stated above..
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
To ensure the arguments regarded the above objections are fully considered
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
72. Mr Jim Bispham (Individual) : 27 Apr 2012 11:27:00
Policy/Site No.
LA1.3 Housing Allocations - M41KM KENDAL SOUTH OF LUMLEY ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Loss of green field space is detrimental to the character and heritage of the area. This is contrary to Coalition Government Sustainable Development Policy, which recognizes brown field preference above important countryside areas. The Soundness and legality of the plan is therefore challenged as being contrary to Government Planning Policy.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I wish to object to and challenge the soundness of proposed land allocation for development – to south of Lumley Rd. (M41KM) and Scroggs Wood Light Industrial Site (E4M) on the following grounds:
- The proposed developments would spoil the initial impression to Kendal visitors, being on the main access route and adjacent to the Town boundary. The Lumley road site is steeply graded and properties would impose on the existing view for Kendal visitors. The line of trees acts as a natural barrier between countryside and properties. Building to the South of this line (E4M), would fundamentally change the Kendal “Gateway to the Lakes” character as a valued landscape. This is contrary to the adopted planning Core Strategy. The Soundness of the plan is therefore challenged on visual impact grounds, contrary to planning policy.
- Loss of green field space is detrimental to the character and heritage of the area. This is contrary to Coalition Government Sustainable Development Policy, which recognizes brown field preference above important countryside areas. The Soundness and legality of the plan is therefore challenged as being contrary to Government Planning Policy.
- Milnthorpe road already backs up to the bypass at peak times and cannot accommodate the massive increase that such development, in these locations, would create. Kendal town development to attract visitors is pointless if they cannot obtain satisfactory access. The associated pollution from stationary traffic is incompatible with sustainable development objectives. The soundness of the development is challenged on the basis that there is no traffic plan to address these issues.
- The A6 is a crucial access for emergency services, particularly following the downgrading of Westmorland General Hospital. Further congestion on this route would introduce undue risk. The potential for accidents when joining the main road would also be significantly increased. The Soundness of the plan is therefore challenged on safety grounds.
- The soundness of the development is challenged on the basis that there is inadequate local infrastructure including drainage, sewerage and roads.
- The proposed development is incompatible with the character of the historic Helsington development contrary to planning policy. The Soundness of the plan is therefore challenged as being detrimental to the historical character of the area.
- The site is clearly NOT “in an accessible location or an easily developable level site” (Achievability statement P133 2 C). The Soundness of the plan is therefore challenged as being contrary to this declared planning statement.
- There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of adequate existing residential space and more suitable alternative development sites.
- The Development plan should retain the "Kendal Gateway to the Lakes" image supporting tourism and established Cumbrian employment, not destroy it with unsightly, unnecessary development and traffic jams. You don’t put your wheelie bin on your front door step! The DPD appears to have completely disregarded the massive opposition and valid objections previously made. The soundness of this planned development is challenged as disregarding local opinion contrary to Government Policy.
73. Mr Jim Bispham (Individual) : 27 Apr 2012 11:30:00
Policy/Site No.
LA1.6 Strategic Employment Sites - E4M KENDAL LAND AT SCROGGS WOOD, MILNTHORPE ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I wish to object to and challenge the soundness of proposed land allocation for development – to south of Lumley Rd. (M41KM) and Scroggs Wood Light Industrial Site (E4M) on the following grounds:
- The proposed developments would spoil the initial impression to Kendal visitors, being on the main access route and adjacent to the Town boundary. The Lumley road site is steeply graded and properties would impose on the existing view for Kendal visitors. The line of trees acts as a natural barrier between countryside and properties. Building to the South of this line (E4M), would fundamentally change the Kendal “Gateway to the Lakes” character as a valued landscape. This is contrary to the adopted planning Core Strategy. The Soundness of the plan is therefore challenged on visual impact grounds, contrary to planning policy.
- Loss of green field space is detrimental to the character and heritage of the area. This is contrary to Coalition Government Sustainable Development Policy, which recognizes brown field preference above important countryside areas. The Soundness and legality of the plan is therefore challenged as being contrary to Government Planning Policy.
- Milnthorpe road already backs up to the bypass at peak times and cannot accommodate the massive increase that such development, in these locations, would create. Kendal town development to attract visitors is pointless if they cannot obtain satisfactory access. The associated pollution from stationary traffic is incompatible with sustainable development objectives. The soundness of the development is challenged on the basis that there is no traffic plan to address these issues.
- The A6 is a crucial access for emergency services, particularly following the downgrading of Westmorland General Hospital. Further congestion on this route would introduce undue risk. The potential for accidents when joining the main road would also be significantly increased. The Soundness of the plan is therefore challenged on safety grounds.
- The soundness of the development is challenged on the basis that there is inadequate local infrastructure including drainage, sewerage and roads.
- The proposed development is incompatible with the character of the historic Helsington development contrary to planning policy. The Soundness of the plan is therefore challenged as being detrimental to the historical character of the area.
- The site is clearly NOT “in an accessible location or an easily developable level site” (Achievability statement P133 2 C). The Soundness of the plan is therefore challenged as being contrary to this declared planning statement.
- There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of adequate existing residential space and more suitable alternative development sites.
- There is spare capacity and expansion potential on existing established trading estates on Shap Road. The plan to relocate the Rugby club to Oxenholme and development of the Gilkes site are more suited to development than Scroggs Wood. The soundness of the case for such development is challenged on the basis of existing and more suitable alternative development sites compatible with planning policy.
- What and where is the business case and demand for a further speculative light industrial business park? Why would UK businesses move to such a park when financial assistance and tax breaks are available for designated City areas such as the Manchester Enterprise Zone? The soundness of this planned development is challenged on the basis of no established demand or business case.
- The Development plan should retain the "Kendal Gateway to the Lakes" image supporting tourism and established Cumbrian employment, not destroy it with unsightly, unnecessary development and traffic jams. You don’t put your wheelie bin on your front door step! The DPD appears to have completely disregarded the massive opposition and valid objections previously made. The soundness of this planned development is challenged as disregarding local opinion contrary to Government Policy.
74. Mr Jim Bispham (Individual) : 27 Apr 2012 11:33:00
Policy/Site No.
LA1.3 Housing Allocations - All Kendal sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of adequate existing residential space and more suitable alternative development sites.
75. Mr Jim Bispham (Individual) : 27 Apr 2012 11:34:00
Paragraph No.
0.0 Whole Document
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Is there a definition of “affordable housing” in the context of Kendal young person income? Or is this merely a rouse to allow land owners and builders to make massive profits, without any tangible commitment to house the low paid of Kendal? The Soundness is therefore challenged on the basis of no defined affordability test.
76. Mr Jim Bispham (Individual) : 27 Apr 2012 11:35:00
Policy/Site No.
LA1.4 - Kendal Sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of adequate existing residential space and more suitable alternative development sites
77. Mr Simon Blyth (Individual) : 8 Apr 2012 21:10:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - RN225-mod ARNSIDE HOLLINS LANE
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The National Planning Policy Framework (NPPF) states that a Councils' priority should always be to ensure that brownfield sites are brought back into use before greenfield developments are approved. The identified brownfield land at MN32 and RN269 is not being used, whilst the greenfield site at Hollins Lane is ear-marked. Therefore this has not had regard to national policy.
The NPPF states local communities should be able to identify for special protection of green areas of particular importance to them. We understand the land at Hollins Lane has been reserved for community use since its use as a village cricket ground.
The NPPF states that areas of tranquility which have remained relatively undisturbed by noise should be identified and protected - building upto 34 houses on this quiet space is not achieving this.
Given the above the DPD should firstly utilise brownfield land and respect community use land.
1.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
Support the document where brownfield sites are used.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The plan for Hollins Lane is not justified as thee are more reasonable alternatives (brownfield sites) at MN32 and RN269, plus other identified areas in the AONB.
The plan is not 'deliverable' as the pedestrian safety concerns are not addressed. There is no explanation on how access will be provided. Hollins Lane is a single track road with no pavement, there are many families with young children and elderly who live on Hollins Lane and thus the risk of accidents will increase.
The Councils' land allocations document states a key issue affecting Arnside is to focus on sites which are visually contained by topography, woodland and existing properties and do not impact on wider views. It also says there is a shortage of publically accessible space. The proposed site would impact on all the surrounding properties overlooking an darkening the properties below the fields on Hollins Lane and obstructing the views of those on Silverdale Road. The high density will not sit well within an area of low density housing.
The land should be developed for community use, for example an orchard.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
78. Mr Simon Blyth (Individual) : 11 May 2012 09:55:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - All Arnside sites
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The National Planning Policy Framework (NPPF) states that a Councils' priority should always be to ensure that brownfield sites are brought back into use before greenfield developments are approved. The identified brownfield land at MN32 and RN269 is not being used, whilst the greenfield site at Hollins Lane is ear-marked. Therefore this has not had regard to national policy.
The NPPF states local communities should be able to identify for special protection of green areas of particular importance to them. We understand the land at Hollins Lane has been reserved for community use since its use as a village cricket ground.
The NPPF states that areas of tranquility which have remained relatively undisturbed by noise should be identified and protected - building upto 34 houses on this quiet space is not achieving this.
Given the above the DPD should firstly utilise brownfield land and respect community use land.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The plan for Hollins Lane is not justified as thee are more reasonable alternatives (brownfield sites) at MN32 and RN269, plus other identified areas in the AONB.
The plan is not 'deliverable' as the pedestrian safety concerns are not addressed. There is no explanation on how access will be provided. Hollins Lane is a single track road with no pavement, there are many families with young children and elderly who live on Hollins Lane and thus the risk of accidents will increase.
The Councils' land allocations document states a key issue affecting Arnside is to focus on sites which are visually contained by topography, woodland and existing properties and do not impact on wider views. It also says there is a shortage of publically accessible space. The proposed site would impact on all the surrounding properties overlooking an darkening the properties below the fields on Hollins Lane and obstructing the views of those on Silverdale Road. The high density will not sit well within an area of low density housing.
The land should be developed for community use, for example an orchard
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
79. Mr Simon Blyth (Individual) : 11 May 2012 10:02:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - Site Omission
If you have selected a ‘Site omission’ please enter the site reference or location and relevant policy below
MN32
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The National Planning Policy Framework (NPPF) states that a Councils' priority should always be to ensure that brownfield sites are brought back into use before greenfield developments are approved. The identified brownfield land at MN32 and RN269 is not being used, whilst the greenfield site at Hollins Lane is ear-marked. Therefore this has not had regard to national policy.
The NPPF states local communities should be able to identify for special protection of green areas of particular importance to them. We understand the land at Hollins Lane has been reserved for community use since its use as a village cricket ground.
The NPPF states that areas of tranquility which have remained relatively undisturbed by noise should be identified and protected - building upto 34 houses on this quiet space is not achieving this.
Given the above the DPD should firstly utilise brownfield land and respect community use land.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The plan for Hollins Lane is not justified as thee are more reasonable alternatives (brownfield sites) at MN32 and RN269, plus other identified areas in the AONB.
The plan is not 'deliverable' as the pedestrian safety concerns are not addressed. There is no explanation on how access will be provided. Hollins Lane is a single track road with no pavement, there are many families with young children and elderly who live on Hollins Lane and thus the risk of accidents will increase.
The Councils' land allocations document states a key issue affecting Arnside is to focus on sites which are visually contained by topography, woodland and existing properties and do not impact on wider views. It also says there is a shortage of publically accessible space. The proposed site would impact on all the surrounding properties overlooking an darkening the properties below the fields on Hollins Lane and obstructing the views of those on Silverdale Road. The high density will not sit well within an area of low density housing.
The land should be developed for community use, for example an orchard
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
80. Mr Simon Blyth (Individual) : 11 May 2012 10:05:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - Site Omission
If you have selected a ‘Site omission’ please enter the site reference or location and relevant policy below
RN269
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The National Planning Policy Framework (NPPF) states that a Councils' priority should always be to ensure that brownfield sites are brought back into use before greenfield developments are approved. The identified brownfield land at MN32 and RN269 is not being used, whilst the greenfield site at Hollins Lane is ear-marked. Therefore this has not had regard to national policy.
The NPPF states local communities should be able to identify for special protection of green areas of particular importance to them. We understand the land at Hollins Lane has been reserved for community use since its use as a village cricket ground.
The NPPF states that areas of tranquility which have remained relatively undisturbed by noise should be identified and protected - building upto 34 houses on this quiet space is not achieving this.
Given the above the DPD should firstly utilise brownfield land and respect community use land.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The plan for Hollins Lane is not justified as thee are more reasonable alternatives (brownfield sites) at MN32 and RN269, plus other identified areas in the AONB.
The plan is not 'deliverable' as the pedestrian safety concerns are not addressed. There is no explanation on how access will be provided. Hollins Lane is a single track road with no pavement, there are many families with young children and elderly who live on Hollins Lane and thus the risk of accidents will increase.
The Councils' land allocations document states a key issue affecting Arnside is to focus on sites which are visually contained by topography, woodland and existing properties and do not impact on wider views. It also says there is a shortage of publically accessible space. The proposed site would impact on all the surrounding properties overlooking an darkening the properties below the fields on Hollins Lane and obstructing the views of those on Silverdale Road. The high density will not sit well within an area of low density housing.
The land should be developed for community use, for example an orchard.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
81. Mr Daniel Bold (Individual) : 27 Mar 2012 11:21:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - M41M ENDMOOR NORTH OF SYCAMORE DRIVE
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
In all stages of the process SLDC have refused to listen to the concerns of residents. More consideration should be given to the concerns of residents and their views on the scheme. It is clear that a huge degree of opposition exists to the proposed schemes. SLDC refuse to consider the views of local people and the negative environmental and landscape impact the schemes will create.
1.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
I do not support the SLDC land allocation DPD in its current form.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The proposed DPD should be reconsidered in view of the current economic climate. The entire economic situation is different now from when the DPD was formulated and the forecasts for growth and housing needs ought to be reconsidered in light of current events and situations.
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
I do not support the SLDC land allocation DPD in its current form.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
82. Mr Daniel Bold (Individual) : 15 May 2012 14:18:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
1.10
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
In all stages of the process SLDC have refused to listen to the concerns of residents. More consideration should be given to the concerns of residents and their views on the scheme. It is clear that a huge degree of opposition exists to the proposed schemes. SLDC refuse to consider the views of local people and the negative environmental and landscape impact the schemes will create.
1.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
I do not support the Land Allocation DPD in it's current form
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The proposed DPD should be reconsidered in view of the current economic climate. The entire economic situation is different now from when the DPD was formulated and the forecasts for growth and housing needs ought to be reconsidered in light of current events and situations.
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
I do not support the Land Allocation DPD in it's current form
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
83. Mr Bryan Bond (Individual) : 30 Mar 2012 09:24:00
Policy/Site No.
LA1.3 Housing Allocations - All Milnthorpe sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
Yes
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
1) Health.
At present visits to the Doctors at Milnthorpe for Burton and Holme residents is difficult due to lack of parking!
Solution,
A Doctors Surgery be located in the Burton/Holme area?.
2) Education.
The local schools have very little capacity left for new pupils should the proposed developments go ahead?
Solution,
Build bigger school
3) On Street Parking.
The villages at Burton and Holme have older properties with no off road parking this causes problems for through traffic!
Solution.
Set aside land for resident off road parking
84. Mr Bryan Bond (Individual) : 30 Mar 2012 09:52:00
Policy/Site No.
LA1.3 Housing Allocations - All Holme sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
Yes
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
1) Health.
At present visits to the Doctors at Milnthorpe for Burton and Holme residents is difficult due to lack of parking!
Solution,
A Doctors Surgery be located in the Burton/Holme area?.
2) Education.
The local schools have very little capacity left for new pupils should the proposed developments go ahead?
Solution,
Build bigger school
3) On Street Parking.
The villages at Burton and Holme have older properties with no off road parking this causes problems for through traffic!
Solution.
Set aside land for resident off road parking
85. Mr Bryan Bond (Individual) : 30 Mar 2012 09:55:00
Policy/Site No.
LA1.3 Housing Allocations - All Burton-in-Kendal sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
1) Health.
At present visits to the Doctors at Milnthorpe for Burton and Holme residents is difficult due to lack of parking!
Solution,
A Doctors Surgery be located in the Burton/Holme area?.
2) Education.
The local schools have very little capacity left for new pupils should the proposed developments go ahead?
Solution,
Build bigger school
3) On Street Parking.
The villages at Burton and Holme have older properties with no off road parking this causes problems for through traffic!
Solution.
Set aside land for resident off road parking
86. Mr David Bowler (Individual) : 16 Apr 2012 21:28:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - RN169M+ RN299# KENDAL WEST OF HIGH SPARROWMIRE
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The whole of the DPD is predicated on the fact that Kendal ‘requires’ in excess of 2,000 new homes in the forecast period, yet there has been little published detailed analysis of where these figures come from and whether they are truly still justified.
The development planned at sites RN169M and RN299# will erode the green gap between Kendal and Burneside and although there will still be a significant geographical separation between the areas of habitation there is no guarantee that it will not be further eroded with future development. The fact that the sites lie outside the present development boundary is a concern, as a stated part of the process underway is to establish new boundaries for development. This clearly has no value if current boundaries can be ignored with ease and therefore there is little value in assessing what the new boundaries should be.
Much is made of that fact that any development is sustainable, without really defining the interpretation of sustainability, but with the simple fact that valuable land used for the production of food is to be used for more housing means that this development cannot be seen as sustainable.
Great emphasis has been placed on providing affordable homes on these sites (and others), this is unlikely materialise as the costs associated with infrastructure, in particular sewers, will mean that the developer will need to maximise returns, and therefore as with elsewhere in Kendal this will mean ‘affordable’ properties are listed at 80-85% of market value, which with the distorted house prices the area suffers from, does not make them affordable to the young families and others in need of housing in the area.
With reference to utilities and infrastructure, United Utilities have stated that the investment for sewerage pipes to these sites is unlikely to happen in the timeframe of the DPD, which would make consideration of these sites irrelevant. Even if the infrastructure was to be provided, the wider issue of whether the current treatment plant can cope with expansion in the town has been raised as a genuine concern.
The northwest area of the proposed development lies within a drumlin field and would therefore be highly visible and intrusive to many points in and around Kendal, reports on site suitability prepared for SLDC actually highlight that development on the crest of the drumlin would be detrimental.
Presumably at a significant cost, a traffic report was commission from Atkins to analyse Kendal’s traffic problems. This highlighted that various junctions on Windermere Road were operating at or above full capacity in the forecast period of the report. This report did not include the proposed developments at sites RN169M and RN299 #, from which it must be concluded that the traffic problems predicted, would be further exacerbated.
Finally, while it may be claimed that the development proposals have been open to consultation, these sites in particular have been subject to significant changes at each round of consultation. The numbering of the site(s) has changed throughout the process as has the intended use and size of the site. Initially proposed for a small employment development, which then changed to a modest residential development, it is now a site for which 130-150 homes are planned. It is very difficult for members of the public to provide comments on proposals which change so dramatically in their nature; it is paying lip-service to consultation.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
These sites have been a classic example of 'drift', starting with a proposal for a modest employment development which has morphed into a large-scale residential development, which is outside of the development limits of the town. It would devalue the visual impact of one of the major routes into Kendal and would erode the valuable green gap between communities.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
87. Mr Robert Boyd (Individual) : 13 Apr 2012 16:29:00
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I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - R129M KENDAL SOUTH OF UNDERBARROW ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
The DPD has not had regard to the Sustainable Community Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
1) Only land which has been confirmed as available by landowners was considered for the allocations, so suitable land which could be made available by compulsory purchase has not been included or assessed in the plan. The plan cannot therefore be considered as complete reflection of suitable sites throughout the area.
2) Alternative suggestions such as those put forward by Kendal Town Council have been ignored.
3) The plan lacks conformity to the Core Strategy with regard to brown field site targets- now even more important with regard to the recently published National Planning Framework Document
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
1) The consultation for R129M resulted in 3 replies supporting the site and 79 responses against. It would appear the concerns of the objectors were ignored and the comments from the supporters resulted in the allocation being increased from one which had 98 houses on to one which is now has 153. So it looks like one of the objectives of the consultation was to get more landowners to put forward allocation suggestions, rather than achieve a consensus for a joined up plan for 2025.
2) The addition of R143 to R129 following the second phase of consultation now has the has the National Park boundary going abutting it, and although the document says that the environmental impact can be mitigated by screening it will take a miracle for this site not to be seen from footpaths to Scouts Scar or the A591.
3) The final Transport Assessment was not available when the plan was put to Council on 18th January , so it cannot have been taken into account when they took the decision. If it had been available, they would have learned that the overall level of congestion in the town will not be fully mitigated even with the use of the various "improvement schemes" ,which appeared from nowhere in the January version after they had not been mentioned in either of the two earlier assessments. It is obvious that traffic generated from R129, E33 and the Stainbank Green allocation will put pressure on the Town Hall Junction, Queens Rd, Glebe Rd and Vicarage Drive . In addition it will put a significant strain on Greenside Green which will become a large traffic island .
4) R129 and R103m allocations will put severe pressure on Ghyllside School which is already oversubscribed.
5) A substantial area of R129 comes within a 250 metre radius of the capped tip at Kendal Fell. The plan states that an"investigation on potential contamination may be necessary". I would of thought that at the very least a contamination survey should be included in the development brief as well as a risk assessment regarding the siting of 153 houses in the environs of a capped tip.
Summarising, the plan regarding R129M is unsound because of the above reasons and imparticularly because it does not provide a viable plan for the infrastructure of traffic, sewerage, health and education in such a way to join together the individual allocations and result in a smooth running town with a healthy future.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
88. Mr Robert Boyd (Individual) : 14 Apr 2012 13:47:00
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I have read the guidance notes
Policy/Site No.
LA1.8 Local Employment Allocations - E33 KENDAL LAND AT BOUNDARY BANK
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
E33 is a relatively small employment site allocation between 0.93 ha and 1.03 ha depending on which evidence document is used. It consists of a hived off part of a field above the existing business park/waste transfer station. This site is in such a position that any development will give adverse visual aspects from the paths leading to Scouts Scar. There are also issues with access from the Boundary Bank site.
The unsoundness of including this site in the plan is further exacebated by other proposals being suggested by Cumbria County Council and the Lake District National Park Planners; the LDNP allocating the quarry basin for waste management purposes and Cumbria with proposal SL1B suggesting the fell site for the relocation of the household waste recycling centre from canal head.
Situated above Kendal ,the quarry site is opposite the housing allocation R129M on the Underbarrow Road. It is a complicated site from the traffic point of view with vehicles over 7.5tonnes having to use private access to the A591. However smaller vehicles would access the Kendal road system and put stress on the same junctions that R129M affects ie TownHall,Queens Road etc.
I understand from council officers that the affects from proposed developments at Kendal Fell were not taken into account by any of the Kendal Traffic Assessments.
The developments at Kendal Fell are currently unsound with regard to the new National Planning Framework Document which require all local planning authorities working together collaboratively to meet infrastructure and other requirements.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
I think this is an important complicated site which could have strategic consequences for the neighbourhood, if there is not a plan developed between the three authorities involved.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
89. Mr & Mrs J & A Brakewell (Individual) : 26 Apr 2012 12:14:00
A typed or handwritten document was submitted. This has been scanned and can be downloaded below:
Policy/Site No.
LA1.3 Housing Allocations - All Endmoor sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
RE: LAND ALLOCATION DEVELOPMENT PLAN FOR ENDMOOR,KENDAL,CUMBRIA
We question parts of the Development Document on the following grounds and points, as it does not meet its own sustainable development principles.
RefCS1.2
1. This development is far too large as a survey by a local housing association found there would only be a need for between 10 to 15 new houses required by 2015,therefore the number should be based on need.
2. There are only two shops i.e. a Bakery and small General food store, both of which have been up for sale for a considerable time, and an outreach Post Office in the village hall.
3. Doctors, Dentists, Supermarkets etc 5 miles away , Hospital A&E @ Lancaster 17 miles.
4. The nearest facilities for the young i.e. Sports facilities, Entertainment ,Libraries , cafes, clubs etc are 5 miles away in Kendal which already causes problems.
Bus services are infrequent and expensive also only go to Kendal and Kirby Lonsdale.
5. Sustainability.
There are 2 local industrial sites at present, Summerlands and Gatebeck with over 10,000
square ft of empty premises , the rest are low volume employers.
Therefore considerable travel will be necessary to find employment as this is still mainly a
farming community.
6. Infrastructure
The local sewerage waste water systems @ Low Park, Crooklands and Dove Nest are already over capacity and will need renewing so will entail a large new system.
Attached is a list of local wildlife which would be affected. (attached)
90. Mrs Jill Briggs (Individual) : 20 Apr 2012 08:47:00
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I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - RN152 GREENODD LAND AT THE OLD VICARAGE
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
There is great doubt about the soundness of a proposal in the South Lakeland
Development Plan Document that does not accurately describe the site being
proposed.
This site is wrongly described in the Land Allocations Development Plan documents
as being an infill site behind the Vicarage at Oak Vale in Greenodd (5.65- page 135).
This site is in Penny Bridge. The dividing line between the villages is the stream that
runs at the side of the school. All local people know this. Also describing this
agricultural field as an infill site behind the Vicarage at Oak Vale is not an accurate
description. Oak Vale is a terrace of houses in Main St., Penny Bridge below the now closed Britannia Inn. The site RN1 :52 is not just behind the Vicarage; it is also behind the row of houses called Hill Garth and adjacent to the Penny Bridge to Arrad Foot road. It is also opposite the complex of recently built houses called Ellis Wood and crucially the field next to and below the parish church.
To choose a field merely because it rounds off the shape of the village on the map is
wrong and does not take into account local landscape contours. The church was built
on the top of the hill to create an impression. When it was built 200 plus years ago, it
was built outside the lines of the village, presumably on purpose and to make the
most of the views. In other words it was meant to be separate from the village so it
would stand out. To say in a supporting document under the heading coalescence "it
would result in the church becoming part of the community" shows a complete lack of
understanding about why our forefathers chose that place to build the church. If site
RN1 :52 is developed then the inspiring views towards Coniston from the church will
be lost and the views the village of Penny Bridge has of its church on the hill will be
lost amid the house roofs. The views from the church have a high amenity value with
sightlines across the estuary and up the Crake Valley to the Coniston Fells. There is
a need to protect landscape views of this quality. Once lost, it will be gone forever.
There is no examination of the landscape values of this site. This again is unsound.
I oppose the designation of plot RN1:52 in Egton with Newland parish for allocation
for development purposes. I live in Penny Bridge but out of sight and some 200 yards
from the proposed site. It will not affect me personally but I deplore South Lakeland
District Council's attitude in not talking to or listening to local people. I pointed out at the consultation's first stage that the site was wrongly described and no notice was taken of my comments.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
91. Mrs Jill Briggs (Individual) : 10 May 2012 11:18:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
5.62
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The Development Plan Document - point, page 135 says Greenodd and Penny
Bridge, together with smaller settlements in the parish (Egton cum Newland) have a
population of around 900. There are a number of other villages and hamlets in the
parish such as Spark Bridge, Newland, Plumpton, Next Ness, Arrad Foot and
Scathwaite. My estimate of the population of Greenodd and Penny Bridge is jointly
around 500.
I oppose the designation of plot RN1:52 in Egton with Newland parish for allocation
for development purposes. I live in Penny Bridge but out of sight and some 200 yards
from the proposed site. It will not affect me personally but I deplore South Lakeland
District Council's attitude in not talking to or listening to local people. I pointed out at the consultation's first stage that the site was wrongly described and no notice was taken of my comments.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
92. Mrs Jill Briggs (Individual) : 10 May 2012 11:27:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
2.33
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The Development Plan Document - point 2.33, page 27 under the heading
heading 'Development in small Villages and Hamlets' says that residential allocations
are not proposed in small villages and hamlets. Here development is primarily to
meet local needs and is likely to be predominantly on small sites. I would sugggest
that Greenoff and Penny Bridge are both small villages and therefore under the
Plan point 5.62 any development should be therefore to meet local need. The last
Parish Survey of 2008 did not show a need for further housing and the number of
houses for sale also reflects that. Penny Bridge (where the proposed site is) has at
present 98 properties. The proposed development site could the Plan says
accommodate around 22 dwellings. That would be a development of over 20%! The
Plan has not examined these figures at all. Again this emphasises the unsoundness
of the proposals as they have not been fully examined.
I oppose the designation of plot RN1:52 in Egton with Newland parish for allocation
for development purposes. I live in Penny Bridge but out of sight and some 200 yards
from the proposed site. It will not affect me personally but I deplore South Lakeland District Council's
attitude in not talking to or listening to local people. I pointed out at the consultation's first stage that the site was wrongly described and no notice was taken of my comments.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
93. Mrs Jill Briggs (Individual) : 10 May 2012 11:29:00
Paragraph No.
1.10
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I oppose the designation of plot RN1:52 in Egton with Newland parish for allocation
for development purposes. I live in Penny Bridge but out of sight and some 200 yards
from the proposed site. It will not affect me personally but I deplore South Lakeland District Council's attitude in not talking to or listening to local people. I pointed out at the consultation's first stage that the site was wrongly described and no notice was taken of my comments.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
94. Mr Chris Broad (Individual) : 11 Apr 2012 10:11:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
2.21
If you have selected a ‘Site omission’ please enter the site reference or location and relevant policy below
Ulverston Winton House Phase 2 R271
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
A suitable site for residential development has been excluded in Ulverston.
Winton House Phase 2 R271 ? has not been taken forward probably due to an incorrect assessment of its suitability most likely due to a perception that access is difficult.However Poplar Grove was widened at significant expense to allow access to the Willow Tree Close development AND the layout of Willow Tree Close was designed to allow access to a further parcel of land R271 with a gap between houses and an appropriate road layout . R271 now appears to have been bundled with PS49.
R271 (unlike the rest of PS49) lies within a developed area well above the flood plane AND with access . It would be suitable for further development of a similar nature to Willow Tree Close which itself is regared as very desirable in the town. Clearly the provision of allotments is an important consideration but the loss of this relativly small parcel to residential development would not be material and could be compensated for elswhere using land that has for example limited access ,or is on a flood plane or is outside the developed envelope etc . .
The develpment of R271 for residential purposes was facilitated at some expense when Willow Tree Close was built and the benefits of that expenditure should now be realised by including R271 in the Plan .
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
95. Mr Chris Broad (Individual) : 11 May 2012 12:25:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - Site Omission
If you have selected a ‘Site omission’ please enter the site reference or location and relevant policy below
Policy LA1.3 , Ulverston, site reference R271
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
A suitable site for residential development has been excluded in Ulverston.
Winton House Phase 2 R271 ? has not been taken forward probably due to an incorrect assessment of its suitability most likely due to a perception that access is difficult.However Poplar Grove was widened at significant expense to allow access to the Willow Tree Close development AND the layout of Willow Tree Close was designed to allow access to a further parcel of land R271 with a gap between houses and an appropriate road layout . R271 now appears to have been bundled with PS49.
R271 (unlike the rest of PS49) lies within a developed area well above the flood plane AND with access . It would be suitable for further development of a similar nature to Willow Tree Close which itself is regared as very desirable in the town. Clearly the provision of allotments is an important consideration but the loss of this relativly small parcel to residential development would not be material and could be compensated for elswhere using land that has for example limited access ,or is on a flood plane or is outside the developed envelope etc . .
The develpment of R271 for residential purposes was facilitated at some expense when Willow Tree Close was built and the benefits of that expenditure should now be realised by including R271 in the Plan .
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
96. Mrs Jose Brock (Individual) : 17 Apr 2012 16:09:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
0.0 Whole Document
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
1.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
We have answered "Yes" only because we do not have the legal expertise to answer otherwise.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Evidently the great majority of respondents to the previous phase of the DPD consultation were in opposition to at least some aspects of it. In reaching the present phase, this opposition appears to have been disregarded. It is therefore difficult to see how the DPD can be claimed to be "founded on a robust and credible evidence base".
Furthermore, the DPD in general proposes largely development on green field sites. This does not accord with reported recent government pronouncements.
In particular, in the previous phase of the consultation, we suggested that proposals E4M and E31M breach natural boundaries limiting southward expansion of Kendal into agricultural land. It remains our view that these boundaries should not be breached.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
97. Mrs Jose Brock (Individual) : 17 May 2012 12:06:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.8 Local Employment Allocations - E31M KENDAL LAND SOUTH OF K SHOES, NATLAND ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Evidently the great majority of respondents to the previous phase of the DPD consultation were in opposition to at least some aspects of it. In reaching the present phase, this opposition appears to have been disregarded. It is therefore difficult to see how the DPD can be claimed to be "founded on a robust and credible evidence base".
Furthermore, the DPD in general proposes largely development on green field sites. This does not accord with reported recent government pronouncements.
In particular, in the previous phase of the consultation, we suggested that proposals E4M and E31M breach natural boundaries limiting southward expansion of Kendal into agricultural land. It remains our view that these boundaries should not be breached.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
98. Mrs Jose Brock (Individual) : 17 May 2012 12:09:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.6 Strategic Employment Sites - E4M KENDAL LAND AT SCROGGS WOOD, MILNTHORPE ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Evidently the great majority of respondents to the previous phase of the DPD consultation were in opposition to at least some aspects of it. In reaching the present phase, this opposition appears to have been disregarded. It is therefore difficult to see how the DPD can be claimed to be "founded on a robust and credible evidence base".
Furthermore, the DPD in general proposes largely development on green field sites. This does not accord with reported recent government pronouncements.
In particular, in the previous phase of the consultation, we suggested that proposals E4M and E31M breach natural boundaries limiting southward expansion of Kendal into agricultural land. It remains our view that these boundaries should not be breached.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
99. Dr Robert Brown (Individual) : 4 Apr 2012 11:09:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA2.1 Land West of High Sparrowmire
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
In my view this section of the Land Allocations D.P.D. is unsound because it implies that it is possible to build 150 houses on this site without damaging the landscape of this "key gateway adjacent to the National Park". I believe the document would be improved by highlighting the size of development projected.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
100. Mrs Linda Brown (Individual) : 19 Apr 2012 14:40:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA3.2 Mixed Use Allocation at Land South of Allithwaite Road, Kent's Bank, Grange-over-Sands
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Reference: Land Allocations Development Plan Document- Publication Stage Representaion of MNI, MN16, MN2, MN25, R673, known collectively as MN25M
Test of Legal compliance: Sustainability Appraisal baseline information not used to inform the process an the outcomes of that process:
Test of Soundness: The strategy is NOT JUSTIFIED in that it is not founded on a robust and
crdible evidence base and/or is not considered the most appropriate when considered against the reasonable alternatives:
To be Legaly compliant and sound MN25M should be in the green or at least yellow on the
EVIDENCE BASED STUDIES and FACT FILE- APPENDIX 3 - SUSTAINABIL TY
APPRAISAL (colour coded).
According to the above study ofMN25M, many areas are in the:
RED - Biodiversity, Landscape Character, Greenfield site and coalescence.
ORANGE - Air Quality, Access to Educational Facilities and Built Environment.
Is this Evidence and Fact File just going to be ignored?
INFRASTRUCUTRE:
To be sound the SLDC Development Plan should have assessed the likely impact of the propsals on the Grange-over-Sands and district infrastruture; THIS HAS NOT BEEN DONE.
Major investment is needed in infrasture BEFORE any building is proposed, ie Roads, Drains,
Water supply, there is no provision for this in the SLDC Development Plan.
Why propose large building developments when there's already traffic problems ie: bottle-necks of Risedale Hill and Main Street
Surface water management needs to be carefully considered on MN25M. (Environment Agency)FACTFILEAPPENDIX lB.
Development of this size has the potential to increase Kents Bank by 40%, this will have an
adverse effect on local drainage in areas that are prone to flooding after heavy rainfall eg:
Allitbwaite Road beyond Risedale Hill, Greaves Wood Road and Kirkhead Road
MN25M is in Kents Bank not part of Grange-over-Sands as SLDC have stated Kents Bank is a seperate community with few amenities eg: shops, banks etc, car journeys will more than likely be taken to access these facilities adding to the traffic problems of Grange.
Site access would be difficult because of Protected Limestone Pavement in Greaves Wood (which has a tree preservation order) and bounded on two sides by Greaves Wood Road Bridleway, (this forms the eastern and southern boundaries), there's not a suitably access from Kirkhead road between the houses, whose back gardens form the western boundary. This leaves Allithwaite Road, which is a fast undulating road that poses sight line problems for drivers.
GREEN GAP and COALESCENCE
To be sound occording to THE CORE STRATEGY (POLICY CS8.2) states that Green Gaps will be identified on land which:
1) If developed, would cause or add to the risk of future coalescence of two or more settlements between which it is important to retain a distinction;
2) Helps to maintain a settelment's identity, setting and character;
3) Is predominantly open and maintains as open aspect;
4) Affords receational and biodiversity opportunities.
POLICY LA 1.9: GREEN GAPS states that the above should apply between Grange-over-Sands and Allithwaite.
There is NO evidence to state how large a Green Gap should be?
MN25M is a beautiful green field site with wonderful open views accross Morecambe Bay which forms the Green Gap.
The Green Gap between Grange and Allithwaite as it stands is ouly 550 meters approx.
BIODIVERSITY
MN25M is an important and sensitive wildlife area:
Bats roost in this area (protected spiecies ).
Evidence of: Water Vole, Badgers, Bats, Deer, Butterflies, Invertebrates, Breeding
Birds and various other sensitive key species (Cumbria Wildlife Trust)- FACT FILE APPENDIX IE.
Tree preservation order on mature trees and hedges rows (giving high biodiversity value) and Limestone Pavement Order with in site boundary.
It also states in the FACT FILE - APPENDIX 1E - That due to the sensitivity ofMN25M it should be excluded from allocation altogether- CUMBRIA WILDLIFE TRUST.
MN25M CANNOT BE MADE SOUND FOR THE REASONS STATED ABOVE
ALTERNATIVE SITES IN AND AROUND GRANGE-OVER-SANDS:
In the Grange-over-Sands Regeneration Study- Nov 2007 it stated:
5 priority sites had been identified for developing:
Berners pool and Berners Close car park and nursery site,
Lido, promenade (Rense existing buildings for arts/creative industries business use),
Kents Bank Road car paik (retailfresidential with basement car park),
Catholic Church field, Lindale Road (refurbish for small business units).
The above are All brown field sites which should be developed before Green field sites such as MN25M.
There seems to be no evidence that a survey has been completed to show what age group of people want to live in Grange (Grange does not need more second homes or retirement homes).
Currently there are over 120 dwellings on the market in Grange-over-Sands and a large number of these have been on the market for over two years.
*DO NOT Build a Booths supennarket in Grange, as Grange residents have repeatedly stated to SLDC they do not require one, as it would destroy the very heart of Grange's unique shops, with its award winning delicatesen. award winning bakery, Spar store, Co-op store, 2 chemists, 2 butchers, fabulous green grocers, two hardware stores where one can buy just about anything, Grange is famous for its shopping experience, destroy this and SLDC destroy tourism for Grange, this is it's lifes blood.
Don't build Booths and this would free Bateman's Garage brown field site for housing.
If the proposed bmlding was east of Grange-over-Sands this would stop daily traffic problems through Grange, particularly on Main Street and Risedale Hill.
Put the proposed industrial development on the current industrial sites on Mile End Road,
Flookbourgh, rather than building on a green field site like MN25M.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Reference: Land Allocations Development Plan Document- Publication Stage Representaion of MNI, MN16, MN2, MN25, R673, known collectively as MN25M
Test of Legal compliance: Sustainability Appraisal baseline information not used to inform the process an the outcomes of that process:
Test of Soundness: The strategy is NOT JUSTIFIED in that it is not founded on a robust and
crdible evidence base and/or is not considered the most appropriate when considered against the reasonable alternatives:
To be Legaly compliant and sound MN25M should be in the green or at least yellow on the
EVIDENCE BASED STUDIES and FACT FILE- APPENDIX 3 - SUSTAINABIL TY
APPRAISAL (colour coded).
According to the above study ofMN25M, many areas are in the:
RED - Biodiversity, Landscape Character, Greenfield site and coalescence.
ORANGE - Air Quality, Access to Educational Facilities and Built Environment.
Is this Evidence and Fact File just going to be ignored?
INFRASTRUCUTRE:
To be sound the SLDC Development Plan should have assessed the likely impact of the propsals on the Grange-over-Sands and district infrastruture; THIS HAS NOT BEEN DONE.
Major investment is needed in infrasture BEFORE any building is proposed, ie Roads, Drains,
Water supply, there is no provision for this in the SLDC Development Plan.
Why propose large building developments when there's already traffic problems ie: bottle-necks of Risedale Hill and Main Street
Surface water management needs to be carefully considered on MN25M. (Environment Agency)FACTFILEAPPENDIX lB.
Development of this size has the potential to increase Kents Bank by 40%, this will have an
adverse effect on local drainage in areas that are prone to flooding after heavy rainfall eg:
Allitbwaite Road beyond Risedale Hill, Greaves Wood Road and Kirkhead Road
MN25M is in Kents Bank not part of Grange-over-Sands as SLDC have stated Kents Bank is a seperate community with few amenities eg: shops, banks etc, car journeys will more than likely be taken to access these facilities adding to the traffic problems of Grange.
Site access would be difficult because of Protected Limestone Pavement in Greaves Wood (which has a tree preservation order) and bounded on two sides by Greaves Wood Road Bridleway, (this forms the eastern and southern boundaries), there's not a suitably access from Kirkhead road between the houses, whose back gardens form the western boundary. This leaves Allithwaite Road, which is a fast undulating road that poses sight line problems for drivers.
GREEN GAP and COALESCENCE
To be sound occording to THE CORE STRATEGY (POLICY CS8.2) states that Green Gaps will be identified on land which:
1) If developed, would cause or add to the risk of future coalescence of two or more settlements between which it is important to retain a distinction;
2) Helps to maintain a settelment's identity, setting and character;
3) Is predominantly open and maintains as open aspect;
4) Affords receational and biodiversity opportunities.
POLICY LA 1.9: GREEN GAPS states that the above should apply between Grange-over-Sands and Allithwaite.
There is NO evidence to state how large a Green Gap should be?
MN25M is a beautiful green field site with wonderful open views accross Morecambe Bay which forms the Green Gap.
The Green Gap between Grange and Allithwaite as it stands is ouly 550 meters approx.
BIODIVERSITY
MN25M is an important and sensitive wildlife area:
Bats roost in this area (protected spiecies ).
Evidence of: Water Vole, Badgers, Bats, Deer, Butterflies, Invertebrates, Breeding
Birds and various other sensitive key species (Cumbria Wildlife Trust)- FACT FILE APPENDIX IE.
Tree preservation order on mature trees and hedges rows (giving high biodiversity value) and Limestone Pavement Order with in site boundary.
It also states in the FACT FILE - APPENDIX 1E - That due to the sensitivity ofMN25M it should be excluded from allocation altogether- CUMBRIA WILDLIFE TRUST.
MN25M CANNOT BE MADE SOUND FOR THE REASONS STATED ABOVE
ALTERNATIVE SITES IN AND AROUND GRANGE-OVER-SANDS:
In the Grange-over-Sands Regeneration Study- Nov 2007 it stated:
5 priority sites had been identified for developing:
Berners pool and Berners Close car park and nursery site,
Lido, promenade (Rense existing buildings for arts/creative industries business use),
Kents Bank Road car paik (retailfresidential with basement car park),
Catholic Church field, Lindale Road (refurbish for small business units).
The above are All brown field sites which should be developed before Green field sites such as MN25M.
There seems to be no evidence that a survey has been completed to show what age group of people want to live in Grange (Grange does not need more second homes or retirement homes).
Currently there are over 120 dwellings on the market in Grange-over-Sands and a large number of these have been on the market for over two years.
*DO NOT Build a Booths supennarket in Grange, as Grange residents have repeatedly stated to SLDC they do not require one, as it would destroy the very heart of Grange's unique shops, with its award winning delicatesen. award winning bakery, Spar store, Co-op store, 2 chemists, 2 butchers, fabulous green grocers, two hardware stores where one can buy just about anything, Grange is famous for its shopping experience, destroy this and SLDC destroy tourism for Grange, this is it's lifes blood.
Don't build Booths and this would free Bateman's Garage brown field site for housing.
If the proposed bmlding was east of Grange-over-Sands this would stop daily traffic problems through Grange, particularly on Main Street and Risedale Hill.
Put the proposed industrial development on the current industrial sites on Mile End Road,
Flookbourgh, rather than building on a green field site like MN25M.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
I wish to express my views and hear others
101. Mr Roger Brown (Individual) : 26 Apr 2012 10:15:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - All Grange-over-Sands sites
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The Land Allocations Document (DPD) is not within the Local Development Scheme and the key stages have not been followed
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The plan is in conflict with SLDC's own policy, see section 4.5 of LADP document regarding coalescence, the current proposals clearly join up allithwaite and grange over sands (and 4.22) The document recognises that the road network is constrained in places yet does nothing to alleviate this but proposals will increase the problem. the road between allithwaite and flookburgh is single track at one point..
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
See Answer at 1.3
Infrastructure problems will become worse as no solution re traffic, flooding etc
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
102. Mr Roger Brown (Individual) : 26 Apr 2012 10:19:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - All Allithwaite sites
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The Land Allocations Document (DPD) is not within the Local Development Scheme and the key stages have not been followed
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The plan is in conflict with SLDC's own policy, see section 4.5 of LADP document regarding coalescence, the current proposals clearly join up allithwaite and grange over sands (and 4.22) The document recognises that the road network is constrained in places yet does nothing to alleviate this but proposals will increase the problem. the road between allithwaite and flookburgh is single track at one point..
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
See Answer at 1.3
Infrastructure problems will become worse as no solution re traffic, flooding etc
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
103. Mr Roger Brown (Individual) : 26 Apr 2012 10:21:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - All Flookburgh sites
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The Land Allocations Document (DPD) is not within the Local Development Scheme and the key stages have not been followed
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The plan is in conflict with SLDC's own policy, see section 4.5 of LADP document regarding coalescence, the current proposals clearly join up allithwaite and grange over sands (and 4.22) The document recognises that the road network is constrained in places yet does nothing to alleviate this but proposals will increase the problem. the road between allithwaite and flookburgh is single track at one point..
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
See Answer at 1.3
Infrastructure problems will become worse as no solution re traffic, flooding etc
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
104. Mr Roger Brown (Individual) : 26 Apr 2012 10:24:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA3.1 Mixed Use Allocation at Berners Pool, Grange-over-Sands
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The Land Allocations Document (DPD) is not within the Local Development Scheme and the key stages have not been followed
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The plan is in conflict with SLDC's own policy, see section 4.5 of LADP document regarding coalescence, the current proposals clearly join up allithwaite and grange over sands (and 4.22) The document recognises that the road network is constrained in places yet does nothing to alleviate this but proposals will increase the problem. the road between allithwaite and flookburgh is single track at one point..
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
See Answer at 1.3
Infrastructure problems will become worse as no solution re traffic, flooding etc
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
105. Mr Roger Brown (Individual) : 26 Apr 2012 10:26:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA3.2 Mixed Use Allocation at Land South of Allithwaite Road, Kent's Bank, Grange-over-Sands
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The Land Allocations Document (DPD) is not within the Local Development Scheme and the key stages have not been followed
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The plan is in conflict with SLDC's own policy, see section 4.5 of LADP document regarding coalescence, the current proposals clearly join up allithwaite and grange over sands (and 4.22) The document recognises that the road network is constrained in places yet does nothing to alleviate this but proposals will increase the problem. the road between allithwaite and flookburgh is single track at one point..
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
See Answer at 1.3
Infrastructure problems will become worse as no solution re traffic, flooding etc
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
106. Mr Roger Brown (Individual) : 26 Apr 2012 10:27:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA3.3 Mixed Use Allocation at Guide's Lot, Grange-over-Sands
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The Land Allocations Document (DPD) is not within the Local Development Scheme and the key stages have not been followed
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The plan is in conflict with SLDC's own policy, see section 4.5 of LADP document regarding coalescence, the current proposals clearly join up allithwaite and grange over sands (and 4.22) The document recognises that the road network is constrained in places yet does nothing to alleviate this but proposals will increase the problem. the road between allithwaite and flookburgh is single track at one point..
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
See Answer at 1.3
Infrastructure problems will become worse as no solution re traffic, flooding etc
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
107. Mr & Mrs Gareth and Joy Brown (Individual) : 9 May 2012 11:22:00
A typed or handwritten document was submitted. This has been scanned and can be downloaded below:
Policy/Site No.
LA1.1 Development Boundaries- BURTON-IN-KENDAL
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
No consultation re changes
Local Development Framework- RN319 Burton in Kendal
Further to my recent telephone conversation with a member of your Department (Alistair)
regarding that our land allocation request has been amended without prior consultation
with myself.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Re-instate RN319 building line as previously submitted
Local Development Framework- RN319 Burton in Kendal
Further to my recent telephone conversation with a member of your Department (Alistair)
regarding that our land allocation request has been amended without prior consultation
with myself.
I have just received (April 12th) the Publication Stage Representation Form that I have
been asked to submit but I feel the form is not relevant to my issue and I will explain
below what the situation is.
I submitted my Garden to be included in the LDF plan as it would provide a suitable area
to build 2/3 homes in keeping with the character of Thornleigh Drive. This was duly
given the allocation number RN 319 on the map of 2011 and inspected by several
members of the Parish Council, who agreed that my idea was sound, in keeping with the
area and raised no objections.
It was noted the area was actually too small to be part of the LDF but it was agreed that
the LDF was the ideal way to extend the present building line to encompass my land.
On publication of the 2012 map RN319 had been removed altogether and the building
line had, indeed, been moved straight through the centre of the plot! (Please see Colour
Map A and Burton in Kendal and Clawthorpe 2012 Map enclosed).
I also saw online in Appendix 8 (enclosed) that my application had changed to "agreed in
part". I have not been contacted at all regarding any of these changes so I contacted your
department. I spoke to Alistair who explained a site visit had been attempted but access
could not be gained because no one was at home at the time but I was not informed of the
proposed visit. He told me the Inspector could not see all of the site due to trees planted
so the decision was taken to put the Building line before the trees, through the centre of
the site as the trees shielded the site to the east.
The trees in question we actually planted to appease the neighbours if we ever managed
to get planning permission on the site.
The present central Building Line would leave us only the option of building right in
front of their house which is quite undesirable. I request that the building line be
reconsidered and amended .
I have completed the Publication stage form as requested and have enclosed all the details
and Maps plus a CD containing an assortment of Jpeg images of the Site along with three
short Quiclctime Videos I have made, showing the area with an audio commentary to help
the viewer understand what a mistake it would be to run the building line right through
the centre of the plot.
I feel strongly that the amendments are unnecessary and would suggest the original
development request be looked at again which I feel is in line with maintaining the
character/privacy of all the residents within Thornleigh Drive and particularly preserves
the view of my neighbours at number 6 Thornleigh Drive.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
Only if you consider this essential
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
108. Dr Robert Brown (Individual) : 18 May 2012 14:17:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - RN169M+ RN299# KENDAL WEST OF HIGH SPARROWMIRE
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
In my view this section of the Land Allocations D.P.D. is unsound because it implies that it is possible to build 150 houses on this site without damaging the landscape of this "key gateway adjacent to the National Park". I believe the document would be improved by highlighting the size of development projected.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
109. Mr John Bryers (Individual) : 21 Mar 2012 21:39:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA2.4 Land at Kendal Parks
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
1.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
The PDP does appear to be very detailed. In fact so detailed it makes it nealry impossible for the common working man to interpret or indeed read all the supplied documents. This is possibly why my council tax is higher than I would wish.
However, I accept the DPD does address the key points around noise attenuation, Great Crested Newts and flood risk.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Traffic Assessment and Travel plans do not consider current access and egress on and around Kendal Parks. Based on 28 years experience driving and parking in this area. It is a high health and Safety risk.
Green belt restrictions seem to have been ignored. Traffic access and egress around Kendal Parks estate would clearly indicate no further building to the East of Kendal Parks could possibly go ahead, hence any Traffic Assessment report is flawed for this development. There would be an issue with Blue Light Vehicles for access now, never mind when we build another 200 houses.
There are no local amenities for these new homes, so pressure on home owners would be to have a vehicle. There is no way a bus would be able to give these residents direct access to this service.
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
None
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
110. Mr John Bryers (Individual) : 18 May 2012 15:00:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - R107M mod and R150M KENDAL KENDAL PARKS
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
1.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
The PDP does appear to be very detailed. In fact so detailed it makes it nealry impossible for the common working man to interpret or indeed read all the supplied documents. This is possibly why my council tax is higher than I would wish.
However, I accept the DPD does address the key points around noise attenuation, Great Crested Newts and flood risk.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Traffic Assessment and Travel plans do not consider current access and egress on and around Kendal Parks. Based on 28 years experience driving and parking in this area. It is a high health and Safety risk.
Green belt restrictions seem to have been ignored. Traffic access and egress around Kendal Parks estate would clearly indicate no further building to the East of Kendal Parks could possibly go ahead, hence any Traffic Assessment report is flawed for this development. There would be an issue with Blue Light Vehicles for access now, never mind when we build another 200 houses.
There are no local amenities for these new homes, so pressure on home owners would be to have a vehicle. There is no way a bus would be able to give these residents direct access to this service.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
111. Mr and Mrs Philip and Sylvia Buckley (Individual) : 20 Apr 2012 10:36:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.8 Local Employment Allocations - EN20, EN33# ENDMOOR LAND NORTH OF GATEBECK LANE, GATEBECK
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
2.3 The proposed commercial site at Gatebeck Lane
I consider the proposal to be unsound for the following reasons:
1. Increase in the level of heavy traffic
(i) Gatebeck Lane already has buses ,heavy lorries( from the local quarry and Wilsons),caravans, Commercial traffic from the existing Gatebeck development and domestic traffic from Low Park estate etc. See CS7.4 which states:
Favourable consideration will be given to suitable employment-related development in rural
areas where the proposal is of a scale in keeping with its surroundings. Bullet points include:
• Does not give rise to unacceptable levels of traffic.
• Does not detract from the amenity of residential areas
(ii) As there are no footpaths in most of Gatebeck Lane and no leeway to add them in some
areas, pedestrians would be put at further risk. There have already been several accidents,
some fatal, in this lane and at the dangerous junction with the A65 road. See CS9.1 which
states:
The core strategy seeks to improve the health and well being of all residents through:
• Delivering improvements to foot and cycle paths to support active lifestyles.
I already walk or jog down this lane at my peril and there are many more elderly residents
who have to use this route whilst negotiating often speeding traffic. See SS10.2 regarding
safe access on foot etc. and addressing the needs of all including those with a disability.
(iii) Our cottage wall forms part of the boundary of Gatebeck Lane at the busy junction with
the A65. The existing traffic from Wilsons and the quarry does not always adhere to the
voluntary one way system, often coming dangerously close to this wall. We also believe that
these heavy vehicles are having a major impact on the road surface and the underlying
drainage system. The lane is constantly undergoing road repairs and we have been suffering flooding in part of our building for approximately 4 years. The Environmental Health Agency Contact No: 0845 0504434-Daniel Russell and the Highways Dept-0845 6096609 Ref No: 468948- Steve Gibson have been involved with this problem to no avail. More heavy vehicles would exacerbate the problem. See CS1.1 Point 1. Relating to addressing flood risk and CS8.8 which states:
All new development will only be permitted if it can be demonstrated that it would not have
a significant impact on the capacity of an area to store flood water.
The level of the water table in this area is already significantly affecting our property as
mentioned earlier.
2. Empty commercial units in the area.
(i) There are many existing commercial units in the area lying empty which could be
utilised ie. at Summerlands, Crooklands etc. See CS1.1 Point 8 which states:
Development should accord with the following sequential approach- first using existing
buildings. Third- the development of other land where this is well located in relation to
other services.
(ii) The new auction site near to the M6 junction 36 would surely accommodate further
development and be an excellent location for commercial units. This site is
convenient for the motorway, A65 and the By-pass; (all major roads, not small
country lanes).
3. Potential damage to Natural Habitats.
(i) Cumbria is the last stronghold in the world for white clawed crayfish. I
believe these crayfish inhabit Peasey Beck. Could the commercial development, so
near to their environment have an adverse effect on their delicate existence.
Contact-The Initiative Co-ordinator, Bekka Corrie Close at 01539 816311 or
www.scrt.co.uk/cfinns.
See CS8.4 regarding Biodiversity which states:
Proposals should particularly seek to contribute towards the UK priority habitats and species in South Lakeland.
Taking all these points into consideration and the comments I have already made I would
like to make a further suggestion. Could the proposed commercial site not be used for the
development of the waste recycling site which it is rumoured is to be sited at Low Park.
If the site at Low Park is considerably expanded to incorporate the new housing
developments it would be detrimental to the character and appearance of the beautiful
drumlin landscape .
See CS8.2 Regarding the Protection and Enhancement of Landscape and Settlement
Character.
If sited at Gatebeck Lane:
(i) It would be easier to landscape
(ii) There would be less heavy traffic accessing the site via Gate beck lane.
(ii) Three pumps would not have to be involved in pumping the sewage uphill from the
proposed housing developments.
Surely a more sound and easier sustainable proposal for the Gate beck lane site.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
112. Mr and Mrs Philip and Sylvia Buckley (Individual) : 20 Apr 2012 10:53:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.8 Local Employment Allocations - Site Omission
If you have selected a ‘Site omission’ please enter the site reference or location and relevant policy below
ES7 & M7
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
2. Empty commercial units in the area.
(i) There are many existing commercial units in the area lying empty which could be
utilised ie. at Summerlands, Crooklands etc. See CS1.1 Point 8 which states:
Development should accord with the following sequential approach- first using existing
buildings. Third- the development of other land where this is well located in relation to
other services.
(ii) The new auction site near to the M6 junction 36 would surely accommodate further
development and be an excellent location for commercial units. This site is
convenient for the motorway, A65 and the By-pass; (all major roads, not small
country lanes).
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
113. Mr and Mrs Philip and Sylvia Buckley (Individual) : 20 Apr 2012 10:58:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - All Endmoor sites
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
4. Housing Development and Village Boundary
1. The DPP would be more compliant and sound if the density and number of houses
in the proposed developments were reduced to comply with the sustainable
Development principles. See CS1.1 points 2 & 3
2. The proposed 30% increase in the village development boundary should also be
reduced.
As above; See CS1.1 points 2 & 3 which refer to the protection of the countryside for
its intrinsic beauty etc. and the need to take account of the landscape in an area which
has a role as part of the gateway to the lake District and Yorkshire Dales National Parks.
3. How would the infrastructure of a small village cope if the population was on a par with
half to two thirds of that of Milnthorpe.
Is Endmoor being asked to take more than its fair share?
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
114. Mr Simon Burdis (Individual) : 11 May 2012 17:00:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
0.0 Whole Document
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Sound if the needs of those with autism, learning disabilities, profound and multiple disabilities, complex needs have been taken into consideration.
I support the Land Allocations DPD if:
Every part, policy and site takes into consideration their suitability to meet the needs of vulnerable adults with disabilities, learning disabilities, profound and multiple disabilities, multisensory impairments, autism and other complex multiple needs through the development of specialist residential care, extra care housing and village/intentional communities of attachment combining housing, social care and therapeutic work opportunities based on the Camphill Village Community model.
Valuing People (1.) set out the need for partnership working between all statutory agencies, voluntary agencies and family carers to develop a wider range of choice and housing with care options including residential care and village / intentional (care) communities to provide for the needs of those with autism and disabilities as outlined above whose needs cannot be met through ordinary mainstream services and provision.
Family Carer representations to the Cumbria Learning Disability and Autism Partnership Boards (2.) have established the need for new housing and care provision through the development of village / intentional communities in Cumbria to meet the needs of the most vulnerable. This must be low density housing in a well designed environment with plenty of landscaping for privacy and dignity, availability of spacious housing to accommodate people with special needs, resident staff, volunteer workers, therapeutic horticulture / allotments, therapeutic craft workshops, community meeting room / hall space, etc. High density housing / apartments are not suitable for many with autism (3.) and complex multiple needs whose wellbeing may be adversely affected by lack of space and close proximity to too many other people, noisy traffic and activity.
The Strategic Housing Role of local Authorities: Powers and Duties (4.) states that LAs should:
Plan for and facilitate new housing supply;
Plan and commission housing support services which link homes and housing support services;
Ensure effective housing and neighbourhood management through partnership working;
Addressing the housing and housing related needs of vulnerable people... (e.g. disabled persons) which could be best met socially, environmentally and economically in the most sustainable way through the development of village / intentional communities in partnership with family carers and those with complex needs on suitable sites.
Increasingly, the needs of older family carers and people with complex needs will need to be considered jointly, either on the same or adjacent sites for ease of maintaining family relationships and ease of accessibility.
(1.) See Government White Paper: Valuing People, Department of Health, 2001, "Options should included small scale ordinary housing, supported living and village and intentional communities as well as residential care. None of these should be ruled out".
(2.) See the Focus Groups for adults on the autism spectrum and their families and carers Report October 20`` (updated march 2012) on the need for extending the range of housing options including the development of village / intentional communities (based on the Camphill Village Community model).
(3.) Adult Autism Strategy
(4.) The Strategic Housing Role of Local Authorities: Powers and Duties; Department for Communities and Local Government September 2008.
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115. Mr Steve Buswell (Individual) : 1 May 2012 12:15:00
Policy/Site No.
LA1.3 Housing Allocations - M41KM KENDAL SOUTH OF LUMLEY ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
We wish to object to the proposed land allocation for development – to south of Lumley Rd. (M41KM) and Scroggs Wood Light Industrial Site (E4M) .
Our main objections to the two proposals are:
The Main Road into Kendal, Milnthorpe Road cannot take any more traffic at peak times, with traffic tailed back way past Shenstone roundabout most weekday mornings. It makes it almost impossible to get out of Helsington Laithes at this time. This is a main route for the Emergency services who are taking more and more patients out of Kendal to Lancaster.
We do not think either the commercial site or the development of housing is needed in Kendal when you look around and see all the empty land where house development has started and the builders have been unable to finish and sell the properties. Many commercial units stand empty in Kendal especially in the Mintsfeet area and nothing has been done on the old K Shoe site on Natland Road. We are of the opinion that these proposals will only benefit the current land owners and Building companies.
Loss of green field space is detrimental to the character and heritage of our area, particularly the Helsington
development with it’s historic background and long history of sheep farming.
Surely the present approach is more likely to attract people to our market town rather than ugly developments which are unnecessary and harmful to the environment.
We hope you will listen to and act upon the many comments made by the objectors who know this area well and do not wish to see it spoilt by unnecessary development.
116. Mr Steve Buswell (Individual) : 1 May 2012 12:17:00
Policy/Site No.
LA1.6 Strategic Employment Sites - E4M KENDAL LAND AT SCROGGS WOOD, MILNTHORPE ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
We wish to object to the proposed land allocation for development – to south of Lumley Rd. (M41KM) and Scroggs Wood Light Industrial Site (E4M) .
Our main objections to the two proposals are:
The Main Road into Kendal, Milnthorpe Road cannot take any more traffic at peak times, with traffic tailed back way past Shenstone roundabout most weekday mornings. It makes it almost impossible to get out of Helsington Laithes at this time. This is a main route for the Emergency services who are taking more and more patients out of Kendal to Lancaster.
We do not think either the commercial site or the development of housing is needed in Kendal when you look around and see all the empty land where house development has started and the builders have been unable to finish and sell the properties. Many commercial units stand empty in Kendal especially in the Mintsfeet area and nothing has been done on the old K Shoe site on Natland Road. We are of the opinion that these proposals will only benefit the current land owners and Building companies.
Loss of green field space is detrimental to the character and heritage of our area, particularly the Helsington
development with it’s historic background and long history of sheep farming.
Surely the present approach is more likely to attract people to our market town rather than ugly developments which are unnecessary and harmful to the environment.
We hope you will listen to and act upon the many comments made by the objectors who know this area well and do not wish to see it spoilt by unnecessary development.
117. Mr Stephen Carman (Individual) : 11 May 2012 15:19:00
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Policy/Site No.
LA1.3 Housing Allocations - RN213-mod BRIGSTEER LAND OPPOSITE THE WHEATSHEAF
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The Land Allocation proposed ignores the views indicated ina survey of Brigsteer residents conducted in Feb'11. Teh DPD Aligns itself with the policies of a self-elected, undemocratic community land trust which holds a minority view and has used the voting power of its members through the Parish Council to present an unsound case.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
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118. Ms Margaret Carter (Individual) : 19 Apr 2012 09:26:00
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I have read the guidance notes
Paragraph No.
1.12
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
On your web page "Sustainability Appraisal and Strategic Envrionment Assessment", the link to "Land Allocation Sustainability Appraisal" gives the response "PAGE NOT FOUND". The relevant aptions in the "Related Links" section of the same page also give "PAGE NOTE FOUND". A search for "Sustainability Appraisal Report" gives "NOT FOUND". I therefore conclude that this Report DOES NOT EXIST, and you are not legally compliant.
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119. Ms Margaret Carter (Individual) : 19 Apr 2012 09:31:00
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I have read the guidance notes
Paragraph No.
0.0 Whole Document
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The Annual Monitoring Report is referred to in Section 2.8 of the DPD. The AMR is available for Y/E 31 March 2010 (published Dec 2010) - but there is not AMR for Y/E 31 March 2011 and we are not in April 2012! This Report is therefore NOT ANNUAL. In the Core Strategy DPD it states that the AMR will be the mechanism for assessing performance. The DPD is not effective if it is not being monitored.
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Please notify me
120. Ms Joan Cate (Individual) : 27 Apr 2012 09:27:00
Policy/Site No.
LA1.3 Housing Allocations - M41KM KENDAL SOUTH OF LUMLEY ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Loss of green field space is detrimental to the character and heritage of the area. This is contrary to Coalition Government Sustainable Development Policy, which recognizes brown field preference above important countryside areas. The Soundness and legality of the plan is therefore challenged as being contrary to Government Planning Policy.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I wish to object to and challenge the soundness of proposed land allocation for development – to south of Lumley Rd. (M41KM) and Scroggs Wood Light Industrial Site (E4M) on the following grounds:
- The proposed developments would spoil the initial impression to Kendal visitors, being on the main access route and adjacent to the Town boundary. The Lumley road site is steeply graded and properties would impose on the existing view for Kendal visitors. The line of trees acts as a natural barrier between countryside and properties. Building to the South of this line (E4M), would fundamentally change the Kendal “Gateway to the Lakes” character as a valued landscape. This is contrary to the adopted planning Core Strategy. The Soundness of the plan is therefore challenged on visual impact grounds, contrary to planning policy.
- Loss of green field space is detrimental to the character and heritage of the area. This is contrary to Coalition Government Sustainable Development Policy, which recognizes brown field preference above important countryside areas. The Soundness and legality of the plan is therefore challenged as being contrary to Government Planning Policy.
- Milnthorpe road already backs up to the bypass at peak times and cannot accommodate the massive increase that such development, in these locations, would create. Kendal town development to attract visitors is pointless if they cannot obtain satisfactory access. The associated pollution from stationary traffic is incompatible with sustainable development objectives. The soundness of the development is challenged on the basis that there is no traffic plan to address these issues.
- The A6 is a crucial access for emergency services, particularly following the downgrading of Westmorland General Hospital. Further congestion on this route would introduce undue risk. The potential for accidents when joining the main road would also be significantly increased. The Soundness of the plan is therefore challenged on safety grounds.
- The soundness of the development is challenged on the basis that there is inadequate local infrastructure including drainage, sewerage and roads.
- The proposed development is incompatible with the character of the historic Helsington development contrary to planning policy. The Soundness of the plan is therefore challenged as being detrimental to the historical character of the area.
- The site is clearly NOT “in an accessible location or an easily developable level site” (Achievability statement P133 2 C). The Soundness of the plan is therefore challenged as being contrary to this declared planning statement.
- There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of adequate existing residential space and more suitable alternative development sites.
- The Development plan should retain the "Kendal Gateway to the Lakes" image supporting tourism and established Cumbrian employment, not destroy it with unsightly, unnecessary development and traffic jams. You don’t put your wheelie bin on your front door step! The DPD appears to have completely disregarded the massive opposition and valid objections previously made. The soundness of this planned development is challenged as disregarding local opinion contrary to Government Policy.
121. Ms Joan Cate (Individual) : 27 Apr 2012 09:41:00
Policy/Site No.
LA1.6 Strategic Employment Sites - E4M KENDAL LAND AT SCROGGS WOOD, MILNTHORPE ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I wish to object to and challenge the soundness of proposed land allocation for development – to south of Lumley Rd. (M41KM) and Scroggs Wood Light Industrial Site (E4M) on the following grounds:
- The proposed developments would spoil the initial impression to Kendal visitors, being on the main access route and adjacent to the Town boundary. The Lumley road site is steeply graded and properties would impose on the existing view for Kendal visitors. The line of trees acts as a natural barrier between countryside and properties. Building to the South of this line (E4M), would fundamentally change the Kendal “Gateway to the Lakes” character as a valued landscape. This is contrary to the adopted planning Core Strategy. The Soundness of the plan is therefore challenged on visual impact grounds, contrary to planning policy.
- Loss of green field space is detrimental to the character and heritage of the area. This is contrary to Coalition Government Sustainable Development Policy, which recognizes brown field preference above important countryside areas. The Soundness and legality of the plan is therefore challenged as being contrary to Government Planning Policy.
- Milnthorpe road already backs up to the bypass at peak times and cannot accommodate the massive increase that such development, in these locations, would create. Kendal town development to attract visitors is pointless if they cannot obtain satisfactory access. The associated pollution from stationary traffic is incompatible with sustainable development objectives. The soundness of the development is challenged on the basis that there is no traffic plan to address these issues.
- The A6 is a crucial access for emergency services, particularly following the downgrading of Westmorland General Hospital. Further congestion on this route would introduce undue risk. The potential for accidents when joining the main road would also be significantly increased. The Soundness of the plan is therefore challenged on safety grounds.
- The soundness of the development is challenged on the basis that there is inadequate local infrastructure including drainage, sewerage and roads.
- The proposed development is incompatible with the character of the historic Helsington development contrary to planning policy. The Soundness of the plan is therefore challenged as being detrimental to the historical character of the area.
- The site is clearly NOT “in an accessible location or an easily developable level site” (Achievability statement P133 2 C). The Soundness of the plan is therefore challenged as being contrary to this declared planning statement.
- There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of adequate existing residential space and more suitable alternative development sites.
- There is spare capacity and expansion potential on existing established trading estates on Shap Road. The plan to relocate the Rugby club to Oxenholme and development of the Gilkes site are more suited to development than Scroggs Wood. The soundness of the case for such development is challenged on the basis of existing and more suitable alternative development sites compatible with planning policy.
- What and where is the business case and demand for a further speculative light industrial business park? Why would UK businesses move to such a park when financial assistance and tax breaks are available for designated City areas such as the Manchester Enterprise Zone? The soundness of this planned development is challenged on the basis of no established demand or business case.
- The Development plan should retain the "Kendal Gateway to the Lakes" image supporting tourism and established Cumbrian employment, not destroy it with unsightly, unnecessary development and traffic jams. You don’t put your wheelie bin on your front door step! The DPD appears to have completely disregarded the massive opposition and valid objections previously made. The soundness of this planned development is challenged as disregarding local opinion contrary to Government Policy.
122. Ms Joan Cate (Individual) : 27 Apr 2012 09:42:00
Policy/Site No.
LA1.3 Housing Allocations - All Kendal sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of adequate existing residential space and more suitable alternative development sites.
123. Ms Joan Cate (Individual) : 27 Apr 2012 09:43:00
Paragraph No.
0.0 Whole Document
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Is there a definition of “affordable housing” in the context of Kendal young person income? Or is this merely a rouse to allow land owners and builders to make massive profits, without any tangible commitment to house the low paid of Kendal? The Soundness is therefore challenged on the basis of no defined affordability test.
124. Ms Joan Cate (Individual) : 27 Apr 2012 09:45:00
Policy/Site No.
LA1.4 - Kendal Sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of adequate existing residential space and more suitable alternative development sites.
125. Dr Andrew Catley (Individual) : 5 Apr 2012 12:00:00
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I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - RN213-mod BRIGSTEER LAND OPPOSITE THE WHEATSHEAF
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Proposed site RN213 in Brigsteer should be removed from the DPD.
The Guidance Notes for Making Representations on Development Plan Documents advise that for the DPD to be sound, it should be:
“Justified
This means that the DPD should be founded on a robust and credible evidence base involving:
- Evidence of participation of the local community and others having a stake in the area
- Research/fact finding: the choices made in the plan are backed up by facts
The DPD should also provide the most appropriate strategy when considered against reasonable alternatives. These alternatives should be realistic and subject to sustainability appraisal. The DPD should show how the policies and proposals help to ensure that the social, environmental, economic and resource use objectives of sustainability will be achieved.”
My proposed change to the PDP regarding site RN213 is based on:
- Limited evidence of representative local community participation in the selection of the site, or in analysis of alternative sites
- Evidence from a survey indicating low community support for development of the site
- Limited research or fact finding to support the development of the site.
These issues are described in further detail below.
In paragraph 3.150 the DPD notes that no development land allocation proposals are being considered in small village and hamlets, with the exception of site RN-213 in Brigsteer. This exception is attributed to the apparent degree of community involvement and support for this specific proposal. The DPD further notes the involvement of the local Community Land Trust, with the implication that this involvement reflects community support.
Regarding community involvement in developing the RN-213 site, an important starting point for this appears to be the Helsington Parish Housing Needs Survey report of April 2008 produced by the Cumbria Rural Housing Trust. However,
• Although the survey response rate of 62.6% may be viewed as high relative to comparable surveys in Cumbria, this level of response is still low when viewed against good survey design and analysis more generally, and indicates systematic errors and/or biases in the survey design and administration. Clearly, the design and results of a survey need to be interpreted against the objectives of the organization which conducts the survey, and the risk of limited objectivity.
• When considering specific sites for development in the parish, only 35 survey responses were received. Of these, only 3 respondents suggested developing land near the village hall. In other words, from the total of 122 households who responded to the overall survey, only 2.5% identified this site as appropriate; of the 35 households who responded specifically to the question of suitable sites, only 8.6% identified the site as appropriate. These figures indicate low community support for developing the land opposite the Wheatsheaf.
The selection of site RN213 as the most appropriate site for development appears to be based on the views of the local Community Land Trust, with very limited wider community involvement. Points to consider are:
• The trust comprises self-nominated individuals, some of whom do not live in Brigsteer.
• Some trust members have family members who might benefit from the development of low-cost housing, indicating that the trust’s activities are not entirely altruistic.
• While the trust has analyzed the various sites in Brigsteer for potential development, their analysis is an internal qualitative/subjective analysis and is not evidence-based.
• New houses on site RN213 would be largely isolated and hidden from most of Brigsteer, and curiously, hidden from those Community Land Trust members who reside in Brigsteer. This again indicates that the process for selecting site RN213 by the trust, reflects self-interests. Strong cases could be made for developing other potential sites, such as areas to the south of the village.
• I have consulted residents opposite and adjacent to the proposed RN213 site. There is strong opposition to the development, which could be validated by independent survey or poll.
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
I do not support the DPD in relation to the development of site RN213, for the reasons described in section 2.3.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
The Guidance Notes for Making Representations on Development Plan Documents do not mention an oral examination.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
126. Dr Andrew Catley (Individual) : 17 Apr 2012 07:41:00
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I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - RN213-mod BRIGSTEER LAND OPPOSITE THE WHEATSHEAF
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
On 10th April 2012 a Helsington Parish Meeting was held to discuss the proposed development of site RN213. There were 31 votes against the development and 20 votes in favour, confirming that a majority of local people are against the development. I was unable to attend the meeting, but add a further vote against the development.
The Parish Meeting also led to a large majority of 55 votes for the Parish Council to respond to the SLDC in accordance with results of the meeting. However, the Parish Council have disregarded this position and have voted 4-2 in favour of the development of site RN213. Notably, 5 out of 7 Parish Councillors are also directors of the Helsington Community Land Trust, as a group of self-appointed individuals with interests in housing development.
The Parish Meeting vote against the development and the clear conflict of interest among Parish Councillors demonstrates that meaningful local community support for the development is not evident, in contrast to the DPD paragraph 3.150. Therefore, the proposed development of site RN213 is not sound.
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
I do not support the DPD in relation to the development of site RN213 for the reasons described above.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
127. Mr & Mrs N Cavin (Individual) : 18 Apr 2012 14:31:00
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I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - RN152 GREENODD LAND AT THE OLD VICARAGE
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I cannot imagine any builder wishing to purchase this field with a view of building 22 houses. The field has a gradient of approx 2 in 10 which is not conducive to building land. The drainage of this land is very susceptible.
There is a very large concern over traffic, to and from these buildings before and after the buildings are complete
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
128. Mr and Mrs David and Pamela Chadwick (Individual) : 12 Apr 2012 11:33:00
Policy/Site No.
LA1.3 Housing Allocations - All Allithwaite sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
We would like to object to the Land Allocations Development as 'NOT SOUND' for Allithwaite, Kents Bank, Cartmel and Grange Over Sands. The plans are completely out of scale to what is needed.
This area is special, in so much as the green fields and rural environment attract many tourists throghout the year who spend money in our community To take green field land for development is completely wrong.- Visitors do not want to come to an housing estate!
Please accept this email as our strongest objection to any building development.
129. Mr and Mrs David and Pamela Chadwick (Individual) : 12 Apr 2012 11:36:00
Policy/Site No.
LA1.3 Housing Allocations - All Cartmel sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
We would like to object to the Land Allocations Development as 'NOT SOUND' for Allithwaite, Kents Bank, Cartmel and Grange Over Sands. The plans are completely out of scale to what is needed.
This area is special, in so much as the green fields and rural environment attract many tourists throghout the year who spend money in our community To take green field land for development is completely wrong.- Visitors do not want to come to an housing estate!
Please accept this email as our strongest objection to any building development.
130. Mr and Mrs David and Pamela Chadwick (Individual) : 12 Apr 2012 11:38:00
Policy/Site No.
LA1.3 Housing Allocations - All Grange-over-Sands sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
We would like to object to the Land Allocations Development as 'NOT SOUND' for Allithwaite, Kents Bank, Cartmel and Grange Over Sands. The plans are completely out of scale to what is needed.
This area is special, in so much as the green fields and rural environment attract many tourists throghout the year who spend money in our community To take green field land for development is completely wrong.- Visitors do not want to come to an housing estate!
Please accept this email as our strongest objection to any building development.
131. Mr and Mrs David and Pamela Chadwick (Individual) : 12 Apr 2012 11:40:00
Policy/Site No.
LA3.1 Mixed Use Allocation at Berners Pool, Grange-over-Sands
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
We would like to object to the Land Allocations Development as 'NOT SOUND' for Allithwaite, Kents Bank, Cartmel and Grange Over Sands. The plans are completely out of scale to what is needed.
This area is special, in so much as the green fields and rural environment attract many tourists throghout the year who spend money in our community To take green field land for development is completely wrong.- Visitors do not want to come to an housing estate!
Please accept this email as our strongest objection to any building development.
132. Mr and Mrs David and Pamela Chadwick (Individual) : 12 Apr 2012 11:41:00
Policy/Site No.
LA3.2 Mixed Use Allocation at Land South of Allithwaite Road, Kent's Bank, Grange-over-Sands
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
We would like to object to the Land Allocations Development as 'NOT SOUND' for Allithwaite, Kents Bank, Cartmel and Grange Over Sands. The plans are completely out of scale to what is needed.
This area is special, in so much as the green fields and rural environment attract many tourists throghout the year who spend money in our community To take green field land for development is completely wrong.- Visitors do not want to come to an housing estate!
Please accept this email as our strongest objection to any building development.
133. Mr and Mrs David and Pamela Chadwick (Individual) : 12 Apr 2012 11:43:00
Policy/Site No.
LA3.3 Mixed Use Allocation at Guide's Lot, Grange-over-Sands
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
We would like to object to the Land Allocations Development as 'NOT SOUND' for Allithwaite, Kents Bank, Cartmel and Grange Over Sands. The plans are completely out of scale to what is needed.
This area is special, in so much as the green fields and rural environment attract many tourists throghout the year who spend money in our community To take green field land for development is completely wrong.- Visitors do not want to come to an housing estate!
Please accept this email as our strongest objection to any building development.
134. Mr & Mrs A Chaplow (Individual) : 27 Apr 2012 11:10:00
Policy/Site No.
LA1.3 Housing Allocations - M41KM KENDAL SOUTH OF LUMLEY ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Loss of green field space is detrimental to the character and heritage of the area. This is contrary to Coalition Government Sustainable Development Policy, which recognizes brown field preference above important countryside areas. The Soundness and legality of the plan is therefore challenged as being contrary to Government Planning Policy.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I wish to object to and challenge the soundness of proposed land allocation for development – to south of Lumley Rd. (M41KM) and Scroggs Wood Light Industrial Site (E4M) on the following grounds:
- The proposed developments would spoil the initial impression to Kendal visitors, being on the main access route and adjacent to the Town boundary. The Lumley road site is steeply graded and properties would impose on the existing view for Kendal visitors. The line of trees acts as a natural barrier between countryside and properties. Building to the South of this line (E4M), would fundamentally change the Kendal “Gateway to the Lakes” character as a valued landscape. This is contrary to the adopted planning Core Strategy. The Soundness of the plan is therefore challenged on visual impact grounds, contrary to planning policy.
- Loss of green field space is detrimental to the character and heritage of the area. This is contrary to Coalition Government Sustainable Development Policy, which recognizes brown field preference above important countryside areas. The Soundness and legality of the plan is therefore challenged as being contrary to Government Planning Policy.
- Milnthorpe road already backs up to the bypass at peak times and cannot accommodate the massive increase that such development, in these locations, would create. Kendal town development to attract visitors is pointless if they cannot obtain satisfactory access. The associated pollution from stationary traffic is incompatible with sustainable development objectives. The soundness of the development is challenged on the basis that there is no traffic plan to address these issues.
- The A6 is a crucial access for emergency services, particularly following the downgrading of Westmorland General Hospital. Further congestion on this route would introduce undue risk. The potential for accidents when joining the main road would also be significantly increased. The Soundness of the plan is therefore challenged on safety grounds.
- The soundness of the development is challenged on the basis that there is inadequate local infrastructure including drainage, sewerage and roads.
- The proposed development is incompatible with the character of the historic Helsington development contrary to planning policy. The Soundness of the plan is therefore challenged as being detrimental to the historical character of the area.
- The site is clearly NOT “in an accessible location or an easily developable level site” (Achievability statement P133 2 C). The Soundness of the plan is therefore challenged as being contrary to this declared planning statement.
- There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of adequate existing residential space and more suitable alternative development sites.
- The Development plan should retain the "Kendal Gateway to the Lakes" image supporting tourism and established Cumbrian employment, not destroy it with unsightly, unnecessary development and traffic jams. You don’t put your wheelie bin on your front door step! The DPD appears to have completely disregarded the massive opposition and valid objections previously made. The soundness of this planned development is challenged as disregarding local opinion contrary to Government Policy.
135. Mr & Mrs A Chaplow (Individual) : 27 Apr 2012 11:12:00
Policy/Site No.
LA1.6 Strategic Employment Sites - E4M KENDAL LAND AT SCROGGS WOOD, MILNTHORPE ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I wish to object to and challenge the soundness of proposed land allocation for development – to south of Lumley Rd. (M41KM) and Scroggs Wood Light Industrial Site (E4M) on the following grounds:
- The proposed developments would spoil the initial impression to Kendal visitors, being on the main access route and adjacent to the Town boundary. The Lumley road site is steeply graded and properties would impose on the existing view for Kendal visitors. The line of trees acts as a natural barrier between countryside and properties. Building to the South of this line (E4M), would fundamentally change the Kendal “Gateway to the Lakes” character as a valued landscape. This is contrary to the adopted planning Core Strategy. The Soundness of the plan is therefore challenged on visual impact grounds, contrary to planning policy.
- Loss of green field space is detrimental to the character and heritage of the area. This is contrary to Coalition Government Sustainable Development Policy, which recognizes brown field preference above important countryside areas. The Soundness and legality of the plan is therefore challenged as being contrary to Government Planning Policy.
- Milnthorpe road already backs up to the bypass at peak times and cannot accommodate the massive increase that such development, in these locations, would create. Kendal town development to attract visitors is pointless if they cannot obtain satisfactory access. The associated pollution from stationary traffic is incompatible with sustainable development objectives. The soundness of the development is challenged on the basis that there is no traffic plan to address these issues.
- The A6 is a crucial access for emergency services, particularly following the downgrading of Westmorland General Hospital. Further congestion on this route would introduce undue risk. The potential for accidents when joining the main road would also be significantly increased. The Soundness of the plan is therefore challenged on safety grounds.
- The soundness of the development is challenged on the basis that there is inadequate local infrastructure including drainage, sewerage and roads.
- The proposed development is incompatible with the character of the historic Helsington development contrary to planning policy. The Soundness of the plan is therefore challenged as being detrimental to the historical character of the area.
- The site is clearly NOT “in an accessible location or an easily developable level site” (Achievability statement P133 2 C). The Soundness of the plan is therefore challenged as being contrary to this declared planning statement.
- There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of adequate existing residential space and more suitable alternative development sites.
- There is spare capacity and expansion potential on existing established trading estates on Shap Road. The plan to relocate the Rugby club to Oxenholme and development of the Gilkes site are more suited to development than Scroggs Wood. The soundness of the case for such development is challenged on the basis of existing and more suitable alternative development sites compatible with planning policy
- What and where is the business case and demand for a further speculative light industrial business park? Why would UK businesses move to such a park when financial assistance and tax breaks are available for designated City areas such as the Manchester Enterprise Zone? The soundness of this planned development is challenged on the basis of no established demand or business case.
- The Development plan should retain the "Kendal Gateway to the Lakes" image supporting tourism and established Cumbrian employment, not destroy it with unsightly, unnecessary development and traffic jams. You don’t put your wheelie bin on your front door step! The DPD appears to have completely disregarded the massive opposition and valid objections previously made. The soundness of this planned development is challenged as disregarding local opinion contrary to Government Policy.
136. Mr & Mrs A Chaplow (Individual) : 27 Apr 2012 11:13:00
Policy/Site No.
LA1.3 Housing Allocations - All Kendal sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of adequate existing residential space and more suitable alternative development sites
137. Mr & Mrs A Chaplow (Individual) : 27 Apr 2012 11:14:00
Paragraph No.
0.0 Whole Document
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Is there a definition of “affordable housing” in the context of Kendal young person income? Or is this merely a rouse to allow land owners and builders to make massive profits, without any tangible commitment to house the low paid of Kendal? The Soundness is therefore challenged on the basis of no defined affordability test
138. Mr & Mrs A Chaplow (Individual) : 27 Apr 2012 11:14:00
Policy/Site No.
LA1.4 - Kendal Sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of adequate existing residential space and more suitable alternative development sites.
139. Mr George W Chatham (Individual) : 20 Apr 2012 08:55:00
Paragraph No.
1.10
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
this is in response to yours DH/60.12.43 dated 29 Feb 2012. Cannot but be impressed by the imense effort put into the administration of this scheme to implement governmental (!) plans to enhance housing and local employment BUT I guess the aim has gone astray in that you seem to have followed the usual thrust in asking the punters their views and then totally ignoring same. Can you really admit to green field sites being not commercially more acceptable simply because the owners thereof are more than willing to offer them, in some cases gratis, so that they can be developed over locally recognised brownfield sites? This is verging on the dictatorial in fact Joe Stalin would be impressed!
140. Mr George W Chatham (Individual) : 20 Apr 2012 09:32:00
Policy/Site No.
LA1.3 Housing Allocations - All Arnside sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
this is in response to yours DH/60.12.43 dated 29 Feb 2012. Cannot but be impressed by the imense effort put into the administration of this scheme to implement governmental (!) plans to enhance housing and local employment BUT I guess the aim has gone astray in that you seem to have followed the usual thrust in asking the punters their views and then totally ignoring same. Can you really admit to green field sites being not commercially more acceptable simply because the owners thereof are more than willing to offer them, in some cases gratis, so that they can be developed over locally recognised brownfield sites? This is verging on the dictatorial in fact Joe Stalin would be impressed!
141. Mrs Glenda Clark (Individual) : 26 Apr 2012 11:10:00
Policy/Site No.
LA1.3 Housing Allocations - All Grange-over-Sands sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I write to express my grave concern about the Land Allocation Development Plan, adopted by SLDC. If these plans were to go ahead, Grange-over-Sands would become an urban sprawl. The communities of Kents Bank & Allithwaite would be destroyed. I do not feel that the area could cope with all the extra traffic that would be generated & services that would be required for the increase in traffic & population, that would result from building 500 new houses. At present, there are over 120 houses for sale in this area, which are not selling. To accomplish this building programme would destroy the very special green field sites, local leisure facilities will be spoilt, enclosed by houses. The scenery & views of the Bay which visitors come to enjoy will not longer be there, which will affect the local economy.
I know that a lot of local residents feel as I do. I wish to register my protest at the SLDC plans.
142. Mrs Glenda Clark (Individual) : 26 Apr 2012 11:14:00
Policy/Site No.
LA1.3 Housing Allocations - All Allithwaite sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I write to express my grave concern about the Land Allocation Development Plan, adopted by SLDC. If these plans were to go ahead, Grange-over-Sands would become an urban sprawl. The communities of Kents Bank & Allithwaite would be destroyed. I do not feel that the area could cope with all the extra traffic that would be generated & services that would be required for the increase in traffic & population, that would result from building 500 new houses. At present, there are over 120 houses for sale in this area, which are not selling. To accomplish this building programme would destroy the very special green field sites, local leisure facilities will be spoilt, enclosed by houses. The scenery & views of the Bay which visitors come to enjoy will not longer be there, which will affect the local economy.
I know that a lot of local residents feel as I do. I wish to register my protest at the SLDC plans.
143. Mrs Glenda Clark (Individual) : 26 Apr 2012 11:16:00
Policy/Site No.
LA3.1 Mixed Use Allocation at Berners Pool, Grange-over-Sands
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I write to express my grave concern about the Land Allocation Development Plan, adopted by SLDC. If these plans were to go ahead, Grange-over-Sands would become an urban sprawl. The communities of Kents Bank & Allithwaite would be destroyed. I do not feel that the area could cope with all the extra traffic that would be generated & services that would be required for the increase in traffic & population, that would result from building 500 new houses. At present, there are over 120 houses for sale in this area, which are not selling. To accomplish this building programme would destroy the very special green field sites, local leisure facilities will be spoilt, enclosed by houses. The scenery & views of the Bay which visitors come to enjoy will not longer be there, which will affect the local economy.
I know that a lot of local residents feel as I do. I wish to register my protest at the SLDC plans.
144. Mrs Glenda Clark (Individual) : 26 Apr 2012 11:17:00
Policy/Site No.
LA3.2 Mixed Use Allocation at Land South of Allithwaite Road, Kent's Bank, Grange-over-Sands
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I write to express my grave concern about the Land Allocation Development Plan, adopted by SLDC. If these plans were to go ahead, Grange-over-Sands would become an urban sprawl. The communities of Kents Bank & Allithwaite would be destroyed. I do not feel that the area could cope with all the extra traffic that would be generated & services that would be required for the increase in traffic & population, that would result from building 500 new houses. At present, there are over 120 houses for sale in this area, which are not selling. To accomplish this building programme would destroy the very special green field sites, local leisure facilities will be spoilt, enclosed by houses. The scenery & views of the Bay which visitors come to enjoy will not longer be there, which will affect the local economy.
I know that a lot of local residents feel as I do. I wish to register my protest at the SLDC plans.
145. Mrs Glenda Clark (Individual) : 26 Apr 2012 11:21:00
Policy/Site No.
LA3.3 Mixed Use Allocation at Guide's Lot, Grange-over-Sands
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I write to express my grave concern about the Land Allocation Development Plan, adopted by SLDC. If these plans were to go ahead, Grange-over-Sands would become an urban sprawl. The communities of Kents Bank & Allithwaite would be destroyed. I do not feel that the area could cope with all the extra traffic that would be generated & services that would be required for the increase in traffic & population, that would result from building 500 new houses. At present, there are over 120 houses for sale in this area, which are not selling. To accomplish this building programme would destroy the very special green field sites, local leisure facilities will be spoilt, enclosed by houses. The scenery & views of the Bay which visitors come to enjoy will not longer be there, which will affect the local economy.
I know that a lot of local residents feel as I do. I wish to register my protest at the SLDC plans.
146. Mr Ian Clinton (Individual) : 11 Apr 2012 15:12:00
Policy/Site No.
LA1.3 Housing Allocations - All Endmoor sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Thank you for my copy of Lake District News Issue 19. I wish respond to the
current representation opportunity and convey my concerns about the
proposals to build 6,000 new properties within SLDC.
1. There is no evidence of private sector housing need both locally in Low
Park/Endmoor or the wider SLDC area indeed more and more
properties are now for sale with many on the market for two to three
years without a sale. It should be noted that this is despite the view of
local politicians that prices needed to drop by 20%. The recession has
ensured price decreases of 20-25% but the problem has got worse not
better.
2. There is no evidence that SLDC has addressed either economic needs
or public services. There is no evidence that the council have
considered both the need and funding for school places, hospital beds
and employment opportunities. Likewise the current economic situation
means that the public purse would not be able to provide in any case
for a likely population increase of 20-25,000 individuals.
3. Rural locations are more expensive than towns because of the impact
of expensive and limited transport and the cost of goods and services
including food and other essentials in small village shops with no
competition or economies of scale. This will lead to isolation and
therefore increase discrimination to those on low incomes.
4. I further have concerns that SLDC have failed to address or are
seeking to circumvent the proposed government planning rules that
will be published later this month. Key issues include:
a) greater protection for heritage sites and the environment
b) removing the need to identify 20% more housing land than actually
needed
c) the need to focus on a brown field first commitment
d) a requirement for councils to favour development in urban areas ahead
of rural ones
e) an 18-24 month period to prepare and consult, not six weeks
f) a need to balance equally social, environmental and economic
considerations.
Taken together I do not believe SLDC has given an appropriate level of
attention to social, environmental and economic matters and equally appears
to be seeking to circumvent government guidelines. I believe strongly that
there should be a considered pause with a full reappraisal that takes account
of the reality of the situation both in South Lakeland and nationally.
147. Mr Ian Clinton (Individual) : 11 Apr 2012 15:18:00
Paragraph No.
1.9
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I further have concerns that SLDC have failed to address or are
seeking to circumvent the proposed government planning rules that
will be published later this month. Key issues include:
e) an 18-24 month period to prepare and consult, not six weeks
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I further have concerns that SLDC have failed to address or are
seeking to circumvent the proposed government planning rules that
will be published later this month. Key issues include:
e) an 18-24 month period to prepare and consult, not six weeks
148. Mr Ian Clinton (Individual) : 11 Apr 2012 15:32:00
Paragraph No.
0.0 Whole Document
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Thank you for my copy of Lake District News Issue 19. I wish respond to the
current representation opportunity and convey my concerns about the
proposals to build 6,000 new properties within SLDC.
1. There is no evidence of private sector housing need both locally in Low
Park/Endmoor or the wider SLDC area indeed more and more
properties are now for sale with many on the market for two to three
years without a sale. It should be noted that this is despite the view of
local politicians that prices needed to drop by 20%. The recession has
ensured price decreases of 20-25% but the problem has got worse not
better.
2. There is no evidence that SLDC has addressed either economic needs
or public services. There is no evidence that the council have
considered both the need and funding for school places, hospital beds
and employment opportunities. Likewise the current economic situation
means that the public purse would not be able to provide in any case
for a likely population increase of 20-25,000 individuals.
3. Rural locations are more expensive than towns because of the impact
of expensive and limited transport and the cost of goods and services
including food and other essentials in small village shops with no
competition or economies of scale. This will lead to isolation and
therefore increase discrimination to those on low incomes.
4. I further have concerns that SLDC have failed to address or are
seeking to circumvent the proposed government planning rules that
will be published later this month. Key issues include:
a) greater protection for heritage sites and the environment
b) removing the need to identify 20% more housing land than actually
needed
c) the need to focus on a brown field first commitment
d) a requirement for councils to favour development in urban areas ahead
of rural ones
e) an 18-24 month period to prepare and consult, not six weeks
f) a need to balance equally social, environmental and economic
considerations.
Taken together I do not believe SLDC has given an appropriate level of
attention to social, environmental and economic matters and equally appears
to be seeking to circumvent government guidelines. I believe strongly that
there should be a considered pause with a full reappraisal that takes account
of the reality of the situation both in South Lakeland and nationally.
149. Mrs Gillian Cochrane (Individual) : 25 Apr 2012 08:36:00
Policy/Site No.
LA1.3 Housing Allocations - R121M-mod KENDAL EAST OF CASTLE GREEN ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I wish to register my protest at the development plan for the fields behind OAK TREE
ROAD.
There are serious issues of access- Rowan Tree Road is too narrow for two cars to
pass safely. Both Oak Tree Road & Rowan Tree Crescent were built as a cui de sac.
The underground water drainage pipe is not capable of coping with increased demand.
I would like all the empty "brown" sites in Kendal to be used for development before
destroying the green fields on the perimeter of the town.
150. Mr AW Coles (Individual) : 10 May 2012 09:15:00
Paragraph No.
7.1 General Comment
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I would like to be associated with all of the points raised by GADAC, David Core, Christine Core and the Green Spaces group and in addition add some observations of my own. I do agree with all of the above that the proposals appear unsound and quite unacceptable to local informed opinion. The whole process has further damaged the already low opinion and lack of confidence in the District Council (swimming pools, failed developments, likely closure of promenade due to washout, access to Rowanside etc.)
You must forgive me for appearing cynical but I feel it right and proper to air my views – which I am afraid you may find unpalatable but are based upon over 55 years of actively observing the operation of local government and my training in presentation.
I would stress that I am apolitical and do not belong to any party. There appears to be potentially serious political implications arising - in that only Liberal Democrat activists (and of course commercial interests) appear to be in favour of either the conclusions or indeed the way that the process has been followed. We note that rational development at Milnthorpe (- Not in My MPs back yard!)) have been rejected in favour of the development in Grange where there is a large Conservative vote.
I would also point out that the housing study included a questionnaire that highlighted key service (in bold type) lines in such a way as to appear to ‘invite’ the completion of those lines – more black arts?
I have seen much of the correspondence between David Core and SLDC and am almost shocked in the failure of competently address valid issues – raised by an experienced and Chartered Engineer.
I wish to be kept informed about the progress, or hopefully abandonment, of this ill conceived and executed project. I would hope to be fit enough to take the opportunity to examine many points in detail from the documents I have cited in front of the Inspector.
I should add that once there is a credible Town Council representing Grange I will be more than willing to give my assistance to them and others such as David Core and Richard Davies in formulating a rational and acceptable plan for Grange and hopefully with others for the Cartmel Peninsula.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
151. Mr AW Coles (Individual) : 10 May 2012 09:18:00
Policy/Site No.
LA1.3 Housing Allocations - All Grange-over-Sands sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The proportionate scale of the proposed development in Grange is similar to that of the gerrymander of the London suburbs in the mid 1900’s. The inclusion of the unacceptable Fell road site appeared to have been included merely to have something to remove as a sop to public opinion-a standard black arts technique I believe!
. Most of the points raised in respect of one site apply equally to all of the Grange Proposals. The flooding caused during the High Grange construction should have well made the points about the impermeability of the limestone sub strata.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
152. Mr AW Coles (Individual) : 10 May 2012 09:20:00
Policy/Site No.
LA3.1 Mixed Use Allocation at Berners Pool, Grange-over-Sands
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The proportionate scale of the proposed development in Grange is similar to that of the gerrymander of the London suburbs in the mid 1900’s. The inclusion of the unacceptable Fell road site appeared to have been included merely to have something to remove as a sop to public opinion-a standard black arts technique I believe!
Most of the points raised in respect of one site apply equally to all of the Grange Proposals. The flooding caused during the High Grange construction should have well made the points about the impermeability of the limestone sub strata.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
153. Mr AW Coles (Individual) : 10 May 2012 09:22:00
Policy/Site No.
LA3.2 Mixed Use Allocation at Land South of Allithwaite Road, Kent's Bank, Grange-over-Sands
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The proportionate scale of the proposed development in Grange is similar to that of the gerrymander of the London suburbs in the mid 1900’s. The inclusion of the unacceptable Fell road site appeared to have been included merely to have something to remove as a sop to public opinion-a standard black arts technique I believe!
Most of the points raised in respect of one site apply equally to all of the Grange Proposals. The flooding caused during the High Grange construction should have well made the points about the impermeability of the limestone sub strata.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
154. Mr AW Coles (Individual) : 10 May 2012 09:24:00
Policy/Site No.
LA3.3 Mixed Use Allocation at Guide's Lot, Grange-over-Sands
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
. The proportionate scale of the proposed development in Grange is similar to that of the gerrymander of the London suburbs in the mid 1900’s. The inclusion of the unacceptable Fell road site appeared to have been included merely to have something to remove as a sop to public opinion-a standard black arts technique I believe!
. Most of the points raised in respect of one site apply equally to all of the Grange Proposals. The flooding caused during the High Grange construction should have well made the points about the impermeability of the limestone sub strata.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
155. Mr AW Coles (Individual) : 10 May 2012 09:30:00
Paragraph No.
0.0 Whole Document
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
No indication is given of the only feasible route of an essential Cartmel Peninsula relief road is along the Cartmel Valley, past the residences of Lib-deem Councillors, that should clearly be constructed before any further development is made that would increase the loading of the B5277. I note that in response to an FOI enquiry CCC was unable to answer a simple question on the layout of the B5277 (number of multi property access points that did not comply with current requirement for splays!) this indicates that any comments on suitability of the B5277 for more traffic lack credibility.
It is noted that the rejection my proposals for designating the Grounds of the Cartmel Grange Nursing Home as open space appears to have been based upon an out of date map which shows the old position of the listed structure ‘Albert’ and no consideration of the rejection of polytunnel on an adjacent site was recently rejected by SLDC . This is clear indication that at least this part of the study does not appear to have been competently executed and therefore casts doubts on the rest!
I gain the impression that a very poor piece of work has been produced and adopted and that no one in SLDC is man enough to recognise that in so far Grange / Cartmel peninsula is concerned the document is quite unacceptable to local informed opinion and thus contrary to declared Government Policy.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
156. Mr AW Coles (Individual) : 10 May 2012 09:34:00
Paragraph No.
1.9
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I would comment that the documentation is not user friendly and could have been presented in a much more accessible form if SLDC really wanted to obtain local approval.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
157. Mr AW Coles (Individual) : 10 May 2012 15:37:00
Policy/Site No.
SO Site Omission
If you have selected a ‘Site omission’ please enter the site reference or location and relevant policy below
The grounds of Cartmel Grange Nursing Home should be designated as Important Open Space
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
158. Mr & Mrs A & S Colquhoun (Individual) : 26 Apr 2012 15:28:00
Policy/Site No.
LA1.3 Housing Allocations - M41KM KENDAL SOUTH OF LUMLEY ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I wish to object to the proposed developments to land to the south of Lumley Road and Scroggs Wood:-
1. This area is a main access route into Kendal and surrounding areas for locals, visitors and hoilday makers.At the moment the open fields, tree lines and blosom trees make this approach to Kendal extremely attractive and welcoming. Filling fields with industrial units and houses would ruin the approach into Kendal.
2. These sites are clearly not in an accessible location and there is inadequate local infrastructure including drainage, sewerage, water and roads.
3. There are allready large numbers of unoccupied properties in Kendal ( K Village, Burniside Road ) and new developments at former Cock and Dolphin, Kirkland and areas on existing housing estates that could be extended.
4. Why is there a demand for more industrial units?. Many of the existing industrial and business parks already have units standing empty and businesses going bust.There are already existing sites due for development ie the old Goodacres site.
5. Milnthorpe road is already extremely busy with traffic, backing up to the by-pass at peak times. It would not be able to cope with the increased traffic from these developments.
6. This is an outstanding area of Kendal and going ahead with any of these developments would spoil the character and history of the area and Kendal would loose its Gateway to the Lakes image.
159. Mr & Mrs A & S Colquhoun (Individual) : 26 Apr 2012 15:30:00
Policy/Site No.
LA1.6 Strategic Employment Sites - E4M KENDAL LAND AT SCROGGS WOOD, MILNTHORPE ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I wish to object to the proposed developments to land to the south of Lumley Road and Scroggs Wood:-
1. This area is a main access route into Kendal and surrounding areas for locals, visitors and hoilday makers.At the moment the open fields, tree lines and blosom trees make this approach to Kendal extremely attractive and welcoming. Filling fields with industrial units and houses would ruin the approach into Kendal.
2. These sites are clearly not in an accessible location and there is inadequate local infrastructure including drainage, sewerage, water and roads.
3. There are allready large numbers of unoccupied properties in Kendal ( K Village, Burniside Road ) and new developments at former Cock and Dolphin, Kirkland and areas on existing housing estates that could be extended.
4. Why is there a demand for more industrial units?. Many of the existing industrial and business parks already have units standing empty and businesses going bust.There are already existing sites due for development ie the old Goodacres site.
5. Milnthorpe road is already extremely busy with traffic, backing up to the by-pass at peak times. It would not be able to cope with the increased traffic from these developments.
6. This is an outstanding area of Kendal and going ahead with any of these developments would spoil the character and history of the area and Kendal would loose its Gateway to the Lakes image.
160. Mr Charles Cooper (Individual) : 1 May 2012 14:11:00
Policy/Site No.
LA1.3 Housing Allocations - R121M-mod KENDAL EAST OF CASTLE GREEN ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Please find some extra comments I have put together for you to
consider ....... in respect of 'R121' proposed building plot.
After E Petition
" .... A planning inspector will be appointed & will conduct an Independent
Evaluation into the Plans"
• Will this be a desk based Evaluation?
• Will He/She visit the site?
• Will SLDC provide info to the inspector; will a copy of this information be
available to the general public?
• Will the Local Objection Group be able to pass to the inspector relevant
Objective and Objection info to him?
• Could a joint site visit be arranged with yourselves and inspector?
•
• Where will you park all the cars on the narrow Oak Tree Road or Castle
Green Lane?- Castle Green Lane gets a lot of overspill from the Hotel when
there are no spaces on an exceptionally busy day.
• Will Any Person doing a survey know where they should be, and in what
field?
• The map provided by SLDC and used extensively by all, has large dots on a
page, no detail .
•
• SLDC have not used Large Scale OS map coordinates or GPS grid references.
• To make your argument clear everyone should not be relying on black dots
drawn between two points .
•
• It would be helpful to all to have some stakes in the ground, at sensible
intervals, if they can get them into the rock, with numbers on and a good
map and a list of co-ordinates to refer to.
This would make life easy for all.
• Has anyone drawn up outline or detailed plans giving size of properties they
should be building.
• No New build home in this day and age, should have a steep drive, especially
north facing properties, as in Oxenholme or on some parts of Colin Field
estate.
Some health and safety adviser should put their foot down, if not, Insurance
companies should have a say. The amount of ice we get locally, surely
common sense should be used.
• If an access road is built opposite Castle Green Close road end, it will have to
be on the level, as Oak Tree Road end is lethal in the winter.
• Just ask the present residence, oops! You don't seem to talk to them, sorry.
PREPERATION?
• Water tanks for holding excessive amounts of rain water have been
proposed, sunk in the ground within area R56.
• How deep, what capacity in litres, will you get a hole dug deep enough in the
rock- or is that another survey, how much?
• When?, how?, who decides, when to empty it, where will it flow too?
(Suck it out and sell it to 'Thames Water')
VIABILITY?
• The new road ('Sapling Road') to these extra 60 homes will presumably have
each of the main services put under it.
• Each company- Gas, electric, water, sewage, phone- will pay a percentage
of that cost, are they willing knowing that only 60 properties will be at the
other end?
The dwellings on this and any other estates being proposed, should be designed to
such a high standard that every member of the council, planning committee, SLDC
employee etc should be clambering over each other to BUY ONE.
A good test for a property is 'will it resell in ten years?' and they should not be built
if none of the above, would be willing to buy one and live in it for 10 years or more.
161. Mr D Core (Individual) : 25 Apr 2012 14:13:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
2.8
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I wish to make representation on the soundness of the proposed imposition of the current
Local Development Framework by South Lakeland District Council. There is in this
current plan numerous contradictions with the Core Strategy. Reports compiled by
Consultants for SLDC when developing the Core Strategy and eventually the
Development Plan have been used "piece meal". There are serious concerns about
locations, the magnitude of development and the omission of pertinent facts and a lack of
detailed infrastructure planning. This plan is unsound as the housing and employment land '
allocation is not based upon sound data evidence and is contradictory in many key areas. ·
1. The Imposition of the "top down" Local Development Plan
After the last general election the "top down" approach to community planning was
scrapped and the Regional Development Agency disbanded. Unfortunately in the South
Lakes area the arbitrary allocations of development across the area was accepted. This
policy is still being advocated and pursued by South Lakeland Districts Council even
though this approach is seriously flawed when demand, infrastructure criteria,
employment opportunities and the allocation of employment land is assessed.
1.1 Imposition
I would refer to the SLDC Cabinet meeting dated gth December 2010 item 5.7 Page 241
When referring to the Key Service Centres of Grange over Sands, Kirkby Lonsdale and
Milnthorpe the comment is made that, -"within the Key Service Centres, all of which are
in areas where housing need is high, new housing is distributed pro-rata by size based or
existing number of dwellings".
Firstly the ARC4 report page 9 states quite clearly that the "general market supply and
demand suggests that the open market is generally balanced at District level".
Secondly The Local Housing Need Surveys/Housing Need/TW shows that the District
Survey June 06 that expired in May 11 shows
Grange over Sands needs 75 affordable houses with in an allocation of 497
Kirkby Lonsdale needs 70 affordable houses with in an allocation of 118
Milnthorpe needs 55 affordable houses with in an allocation of 186
Thirdly on the 24th January 2011 South Lakes Housing the "housing stock manager" for
SLDC confirmed that "There are currently 79 people on the South Lakes Housing waiting
list who have Grange over Sands, as their first area of housing choice". This figure is a
"preference" and not necessarily all Grange local needs.
This pro rata split can be seen as being imbalanced, when the figures are compared to the
total allocation. The presumption that because a settlement is larger it can continue to
take more of the allocated development is not based upon sound evidence data. This
assumption does not take into account local constraints, essential services and
infrastructure limitations both existing and proposed. It also does not reflect community
VIeWS.
4. Allocation of Development between the three Service Centres Grange over Sands,
Milnthorpe and Kirkby Lonsdale
The allocation based upon access to services, infrastructure and employment is
unsound.
The criteria used is based upon the observations and recommendations in three "source"
documents these are;
The Douglas Wheeler Regeneration Study
The Core Strategy Document
ARC4report
Examining the three Key Service Centres there appears to be an imbalance of housing and
employment development across all three. The justification of this imbalance is primarily
based upon local constraints and infrastructure deficiencies. However local constraints
and infrastructure deficiencies seem to have been ignored when considering Grange over
Sands, with the flawed assumption that if the settlement is larger it can accommodate
more development. Using the source documents produced by SLDC there are a number
of contradictions, omissions and misleading information put forward to justifY the
allocation for each of the three service centres.
The figures for the total projected housing requirement (the district household survey) is
based upon a theoretical Labour Force-Led forecast. There are many local and National
influences that make this figure unreliable, non more so than the economic climate and the
lack of a manufacturing base in the Grange area. In the case of Grange there is more
housing development with minimal employment land. This is contrary to the Core y\
Strategy, the other three assessments taken from this same survey are more reliable and 1
should be considered in light of the employment development and economic environmental
sustainability of the Town. The economic driver for recovery and subsequent house
purchase (the majority of development will be for sale on the open market) will be
manufacturing, this is not a sector being developed in the immediate vicinity of Grange
over Sands and therefore the criteria for placing homes near to employment will not be
met.
However Table 4-6 POPGROUP modelling page 64 of the ARC4 report shows quite a
wide range in the estimated number of properties required. Given current employment
trends within Grange over Sands and the proposal to develop tourism, leisure and heritage
sectors the only scenarios to give a more accurate assessment are;
1. 5 year migration scenario.
2. 10 year dwelling-led scenario.
3. 10 year migration-led scenario.
There is further confirmation that these three scenarios for the District are a possible way
forward when page 9 of the ARC4 report states quite clearly that;
In summary, analysis of the general market supply and demand suggests that the
open market is generally balanced at District level, although there are some specific
imbalances which include;
An overall shortfall in Central Lakes, Dales and Kendal. Rural market area; and
across Windermere, Sedbergh, Kendal Rural and Furness rural service centres;
Shortfalls in detached properties, bungalows and properties with four or more
bedrooms across the District.
The relatively high cost of housing in relation to local wages/salaries is identified by the
District Council a result of holiday/second homes. The proposal originally of3 5% of
affordable has consistently be lowered, at the request of developers to around the 3 0%
mark with a possibility of this being much lower in certain areas. The remainder sold at
market valve will not address the holiday/second home acquisitions and subsequently will
have minimal effect on the district housing prices.
The Core Strategy Document (pl70) states as one of its primary aims that Grange will
"incorporate moderate new housing development in a way that is sensitive to local
landscape characteristics and historic assets within the surrounding of the town".
The proposed development equates to an overall increase of 30%. This certainly
cannot be described as moderate located entirely on the west side (East according to
Gilles pies) of the town in a corridor Y:. mile wide and no more the 1 %miles in
length. This inevitably requires building on green field sites with only two out of the
seven classed as brown field, one of these being a car park the other the civic amenity site.
Considering what has been highlighted in the ARC4 report in summary of the
general market supply, Grange area has not been identified as an area where there
is a significant shortage or demand, therefore the 30% allocation appears to be even
more excessive. It is worth noting at this stage SLDC have not or been unable to
answer the question or justify what is "moderate new housing development"
in relation to Grange-over-Sands.
Employment in Grange over Sands
The Core Strategy states that there will be a development of tourism, leisure and heritage
sectors. With the building of a supermarket on the "Batemans" site (not Hadwins as
stated) with care facilities proposed for the Kirkhead Road site. These will not provide
sufficient employment or the well paid jobs (in the town) to sustain the proposed number
of residents. This will inevitably lead to a continuance of the current trend, residents
having to travel for employment. This in its self, will impact significantly on the highways
infrastructure (to be addressed later). Milntborpe bas been allocated half of the
employment land 4.5ha for the three Key Service Centres with in percentage terms
considerably less than half of the housing development allocated to Grange over
Sands. Once again the description of the land allocation is "Incorporate moderate
new housing development in a way that is sensitive to the local landscape
characteristics and historic assets". In purely numeric terms Grange is allocated
59% of the three Key Service Centres housing allocation with less employment land,
whilst Milntborpe is allocated only 21% with 50% ofthe employment land
allocation. This assessment becomes more problematic when one considers
infrastructure, services and green environmental issues. There can be no doubt the LD F in
its present format will actually increase motor vehicle usage even though there may be a
policy of developing public transport. Convenience of travel and the topography of the
town will be a major consideration and therefore motor vehicle dependence for local
journeys will continue and increase. The employment trend in Grange has always been
towards self employment in services to the local community and the need to travel for well
paid jobs. This travelling is predominantly towards the east then north and south to the
larger towns and cities ofPreston, Lancaster, Kendal, Penrith and Carlisle. The
predominant form of travel for these longer distance commutes is still the private motor
vehicle because of convenience. There is an acknowledgement this trend will continue.
The other Key Service Centre within the group Kirkby Lonsdale again has the
description "Incorporate moderate new housing development in a way that is
sensitive to the local landscape characteristics and historic assets". Again in
percentage terms Kirby Lonsdale is to receive 20% of the housing allocation even
thought the town is better placed to accommodate more development when one
considers the existing infrastructure, services and green issues.
Infrastructure and Services across the three Key Service Centres
Milnthorpe
The Core Strategy states that the town "provides shopping, schools, employment, medical
and professional services".
There has been a need identified (by SLDC) for a transport assessment and travel plan
even though the town has the main A6 running north/south through the town, the A6070
giving alternative routes via Crooklands to Kendal and Lancaster (via the M6) and the
A65 to the north to travel east (via both the A6/ A590 and the A6070). The town also has
the advantage of easy motorway access to the north via the A6 and the A590 without
having to pass through other towns or villages. Milnthorpe is ideally placed on the
highway network to accommodate development without the need for significant expensive
improvement and more importantly without an adverse effect on the towns long term
economic sustainability. Water supply infrastructure whilst it will accommodate the
proposed development levels there is some concern that to increase the development
allocation the current pumping station would have insufficient capacity. United Utilities
are proposing to upgrade the water supply infrastructure to the town and are seeking
funding in 2014. This will enable Milnthorope to accommodate more housing
development in a phased way to compliment the employment development proposals. It
then begs the question why is this not being considered when the town is better placed to
accommodate development without any detrimental effects on the local economy, one
could argue it may actually support and enhance it. Furthermore if we are to consider
access to essential community services in relation to Grange over Sands we find;
Local Services. Distance from centre. Grange --distance from
Centre to service.
Secondary Schools 0m 2m
Nearest Hospitals - Kendal 6 m 15m
Lancaster 14.5m 27-30m
Railway Station (Arnside) 3m 0m
Motorway access 4.5m 14m
Trunk Road system 0m 4m (A590)
It is also worth noting from the locations of the proposed sites unlike Grange, the
development of Pedestrian and Cycleways to the town will have no physical restrictions in
preventing these being built to an acceptable standard and be cost effective. The town with
its employment land allocation (some 50% of the total for the three service centres) makes
it a more favourable option when one considers the criteria in the Core Strategy
Document. The important criteria considerations such as existing infrastructure, services
and the settlement's ability to support development in an economic sustainable way does
indicate that the allocation of development in this plan is unsound.
Kirkby Lonsdale
The town is identified as having both primary and secondary education together with
medical and professional services. This together with the A65 trunk road running west to
east from Cumbria into West Yorkshire. There is also good road access in all directions,
south to Lancaster and the M6 motorway via the A683 some 14m away and the M6
junction 36, some 6m away.
Essential community services in relation to Grange over Sands;
Local Services. Distances from centre. Grange - Distance
centre to
Secondary schools Om 2m
Nearest Hospitals--Kendal 10m 15m
Lancaster. 16.5m 27-30m
Railway Station (Oxenholme) 10m 0m
Motorway access 6m 14m
Trunk road Om 4m (A590)
The Core Strategy Document highlights in section 3.46 entitled "Local Factors", indicates
factors that influence the location of development. The third point in relation to Kirkby
Lonsdale states as a negative "The potential severance effect and difficulty of crossing the
A65 which is a major route linking West Yorkshire and Cumbria". This "potential
severance" is not insurmountable as many villages and small towns along its entire length
overcome this with pedestrian controlled crossings within speed restricted areas, the other
alterative is to provide pedestrian bridge crossings and possibly a further roundabout. It's
worth noting that Kirkby Lonsdale already has two speed cameras covering the main
section of the town on the A65 as well as a speed limit for the entire length of the
settlement, this will compliment any new development and eliminate any possibility of '
severance. Section 3.51 states "A significant part of Kirkby Lonsdale's housing and
employment land will be met in a single strategic allocation north of Kendal Road.
This site has minimal impact on the historic core of the town, can be well linked to
key facilities such as schools, supermarket, doctor's surgery and town centre'
visually contained and the employment element can be accessed directly from the
A65". This section also states "the need for suitable pedestrian and cycle links to the
town centre", this like Milnthrope is achievable.
There are in these statements an acknowledgement that the A65 forms a significant part of
the development plan in providing good access for employment traffic, it should also be
noted that this also provides residents with an excellent highway infrastructure for
personal travel.
An increase in development would not create severe traffic problems within the town
(with its associated air pollution) and will assist in the compliance of "Enhancing the
vitality and viability ofKirkby Lonsdale town centre for shopping, leisure, arts, culture,
tourism and employment" and the "need to manage biodiversity impacts".
Shopping outlets (supermarkets). .
The Core Strategy Document places great importance on the Key Service Centres having
supermarkets to service the communities. If we now compare the three Key Service
Centres and the development of supermarkets, which it seems is a requirement of the LDF
we find that ;
Milnthorpe will have two new supermarkets, Booths and Spar.
Kirkby Lonsdale already have a large Booths supermarket, which is in the process
of being enlarged.
Grange over Sands will have one small to medium supermarket, Booths, at a critical
highway pinch point within the town. Congestion at this junction is common place
now and will only become worse with the current proposals with a significant
detrimental impact on the environment.
If we then consider the impact of the development in Grange, Allithwaite and Flookburgh
together with the peninsula catchment area for this store, we can expect serious traffic
problems, and a deterioration in air quality. This will seriously effect the main tourist area
of the town. Furthermore this location is overlooked by one of the most prestigious hotels
on the peninsula, not a very attractive proposition for visitors or the proposed . .
development of tourism. 'when one considers the above its not hard to see there is no
consistent sustainable policy being applied to the allocation of development across the
three Key Service Centres.
The basic principal of providing outlets such as supermarkets in the three Service Centres
is to provide a service to the community and to limit motor vehicle travel. Its obvious
that were we have least development we have (in Milnthorpe and Kirkby Lonsdale)
the largest supermarket capacity. Similarly in Grange were there is the largest
population centre (even now) and the largest development programme we have the
smaUest supermarket capacity. This actually contradicts the Core Strategy criteria.
As the development proposals for Grange are on the West of the town (described as
east in the Gillespie report) on a high elevation, the objective of limiting motor
vehicle travel will not be achieved. It will still be considered more convenient to load
a car with shopping and drive from door to door rather than use public transport or
to negotiate the steep gradients on foot or by bicycle. The topography and gradients
within the town are an important factor to consider in line with Policies T4, T5 and
T13, this has been totally ignored by SLDC. The disregard for this important
consideration makes the plan non cohesive and ultimately unsound when viewed in
relation to the National Planning Guidelines, there is a considerable lack of detailed
information on the total deliverability package with many key components to
successful delivery aspirational. This plan is therefore unsound
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
To ensure all our concerns are addressed by the decision makers
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
162. Mr D Core (Individual) : 25 Apr 2012 14:19:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
1.9
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
2. The Consultation Process
Throughout the consultation process the Council and its officers have not answered or ,
been unable to answer pertinent questions on the development allocations for the area.
The standard answer has been we note your comments, this has not resulted in any
meaningful dialogue with communities. In the case of Grange over Sands despite
representation made by residents and the Town Council nothing has changed from its
inception. The District Council have when confronted with any fact that is not
complimentary to their current plan tended to full back on "if we do not have a plan
developers will build were they want and win on appeal if we turn down applications".
Despite the Town Council and residents agreeing a plan must be formulated to meet the
communities needs for a sustainable economic future, there has never been an alternative
discussed. A more appropriate plan involving the Town Council and residents would
satisfY local needs and stand scrutiny at appeal. The only sensible way forward is to have
community involvement using the Core Strategy as the principal guiding document.
Throughout this entire process there has never been any constructive consultation on the , .
LDF proposals. All meetings with SLDC have taken the form of presentation. Despite '
many concerns being raised about the document, we have never received any answers or
reassurances from Council Officers or Councillors. When residents have requested that
SLDC Officers and Councillors meet with the Town Council to resolve the outstanding
issues, this has occurred, but at the insistence of SLDC the meeting was classed as
informal with no official minutes, no justification or change in the proposed development
for the town. Furthermore an application by the Town Council to become a Local
Planning Group in order to allocate development within the town to ensure a sustainable
economic future for Grange was rejected. SLDC by their actions have shown that Public
Consultation was in reality presentation and the LDF will proceed, as originally conceived.
In order to justifY this to the 98% of the respondents across the district who objected,
sections of the core strategy document relating to green open spaces and infrastructure
have become less specific and more generic with balance in favour of developers and a
justification of the current proposals . Even minor alterations to the Core Strategy at this
late stage is totally unacceptable and undemocratic. This is effectively altering the
previously accepted criteria in order to justifY the councils intransigent position without
consultation. I would now refer to page 36 of the Land Allocation DPD Consultation
Statement entitled Key Service Centres Grange over Sands in which it says.
Few people supported any of the suggested housing site options, although several sites did receive some support, in particular the sites involved in the Berners proposals.
Many comments expressed concerns about the overall amount of development proposed
for Grange, in light of infrastructure constraints (highways infrastructure in particular), the
services, facilities and jobs available in Grange, the area's popularity as a tourism
destination and the wider environmental capacity of the area to sustainably accommodate
additional development on this scale, including with regards to wildlife, settlement
character and surface water flood risk.
Many people questioned the need for any additional development in Grange other than for
affordable housing. The Parish Council reiterated many of the concerns raised by
residents.
Why then has SLDC continued with the current plan in light of these comments and "feed
back". This is another example of poor consultation and the imposition of a plan on the
community that finds it unacceptable in its present form. I would now make comment on
the time allowed by SLDC for final submission on the Local Development Framework.
This has been kept to the absolute minimum of six weeks, included in this time is the
Easter Holidays, effectively reducing the time for residents to make representations. This
becomes even more relevant when one considers access to all the relevant information
located in libraries and on their web site. The amount of information cannot be fully
considered by those who are in full time employment and/ or do not have access or the
skills to use the councils web site. The minimum six weeks is not acceptable in this case,
the time allocated should have been extended to the maximum of twelve weeks given the
amount of documentation involved.
It seems rather ironic that SLDC have consulted with Developers and Estate Agents to
seek their views on the development proposals and have by and large accommodated them
whilst, the views of residents have been "noted" with no significant changes. It therefore
suggests that the "prime movers" for the acceptance of the allocation are the commercial
companies who will most benefit from the proposals. One significant change as a result of
this is that there will be no local occupancy clauses attached to the proposed new homes in
Grange over Sands.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
To ensure all our concerns are addressed by the decision makers
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
163. Mr D Core (Individual) : 25 Apr 2012 14:25:00
A typed or handwritten document was submitted. This has been scanned and can be downloaded below:
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
0.0 Whole Document
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
3. Consultants Recommendations to the Council
SLDC have over this plan period (since its inception) employed a number of consultants to
prepare plans and make recommendations on how to proceed with a Local Development
Framework Plan. I list below the Consultants concerned, the date of their reports and
recommendations that have been ignored by SLDC.
a. Douglas Wheeler Associates Regeneration Study 2007
Using the original Core Strategy Document Section 8 Green infrastructure and the
recommendations for exclusion of certain land parcels it is clear parts of the Douglas
Wheeler Report have been ignored. As an example of this land identified as R89,
north of Carter Road ( 45 dwellings) has been included for development despite the
DWA Regeneration Study concluding .. "that residential development of the Allithwaite
Road/Carter Road site is likely to be controversial because of the "Greenfield" nature o,f
the site" and "Do not include this site in their final list of preferred developments".
b. Gillespie Report dated December 2008
This report and plan acknowledges there are some parts of Grange "to the east of the
B5277 where the coastal plain is open and allows attractive views toward the estuary.
Development in this area would impact significantly on these views and no development
should be considered to the east of Grange over Sands. East Grange lies tight to the
existing railway line and estuary edge along the east shore of the estuary. There is no
room for development within this area. The majority of sites facing the water have been
occupied and fall within the existing development boundary. Only four sites were put
forward by the Gillespies Report North of Grange Road, Kents Bank Road/Cartmel
Road, Kents Bank (see plan) Some of the conclusions of the Gillespie Report compliment
the DWA Regeneration Study Report, unfortunately the outcome has remained the same,
land that is not included or recommended for exclusion now forms part of the final land
allocation document. When these points have been raised with SLDC the comment now
used is that "we use a number of consultants to help formulate the plan". There has never
been any justification for the transgressions from these reports. What is obvious is that if
consultants are continually employed, there will be eventually one who will support the
current LDF policy. Given the statement from SLDC planners this appears to be the case.
When SLDC was questioned, "Does the strategy draw on a landscape character
assessment and is this available?".
Answer
Landscape assessment undertaken as part ofthe LDF evidence base includes the
Gillespies Employment and Housing Land Search Study (Examination Library
reference HOUS5a- HOU5j), which utilised Technical Paper 5, as well as the
Countryside Commission's Countryside Character Area classifications, to assess the
potential of settlements to accommodate housing and employment development.
Although this work was undertaken primarily to identify specific sites, it has also
played an important role in helping to determine the capacity of settlements to
accommodate development in terms oflandscape character and sensitivity.
The above statement includes "it has also played an important role in helping to determine
the capacity of settlements to accommodate development in terms of landscape character
and sensitivity''. Without a supportive infrastructure plan, stating what is required, how
and when it will be delivered and by whom, this important supportive part of the plan is
purely speculative as it is not based on factual data, it is therefore unsound.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
To ensure all our concerns are addressed by the decision makers
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
164. Mr D Core (Individual) : 25 Apr 2012 14:36:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - R89 GRANGE-OVER-SANDS NORTH OF CARTER ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Furthermore this particular site satisfies seven out of the ten criteria for exclusion in the Green Infrastructure Section 8 of the Core Strategy Document when only one is required
for consideration. At present the topsoil (on top of limestone) greatly reduces localised
flooding, with more impermeable surface the risk will increase. This is of some concern as
the topsoil does prevent localised flooding as this has only occurred with torrential down
pours twice in the last eight years. Because of the nature of the site, predominantly
limestone beneath the topsoil there is a requirement to have a geological survey
undertaken prior to approval, this needless to say is never mentioned or referred to despite
bringing this to the attention of SLDC Planners. It is worth noting at this stage the Water
Company, United Utilities will not permit "run off' water to be discharged into their
sewers. The assessment of this site for flooding and the localised off site flooding due to
run off using the Environment Agency's criteria, is impractical and too course to reflect
the actual and projected theoretical problems.
We have over the last eighteen months also drawn to the attention of SLDC Planners that
this parcel of land is an important migration route for deer moving from the fells to the
foreshore and back daily. I would now refer you to this sites biodiversity survey that
states there is over "21 key species". This parcel ofland has also been given an
allocation of category 3 status, yet despite this it has been included in phase one
development in order to fulfill what is an overprovision based upon the Popgroup survey
in the ARC4 report. By including R89 in the development there is a contradiction with its
allocated category rating. There can be no doubt that to include a Category 3 site in phase
one where there is up to a 20% over provision in the LDF is unjustifiable and unsound.
There can be no doubt using this one example, Greenfield sites are being proposed that
have significant importance to local communities and not just the surrounding properties
as stated in the ARC4 report. Indeed many residents and visitors value these green open
spaces as it offers a break in the continuous urban development. There is no doubt these
green breaks are what makes the town attractive to both residents and visitors. Its worth
noting there is no distinction between privately owned green open spaces and ones that are
open to the public, both have local amenity value.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
To ensure all our concerns are addressed by the decision makers
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
165. Mr D Core (Individual) : 25 Apr 2012 14:41:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.10 Existing Green Infrastructure
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Its worth noting that the Core Strategy Document appears to have been amended in
certain sections since the original production of the LDF plan, certain contentious sections
have become more generic than specific, relating to the considerations for developing
green open spaces. The new format actually "relaxes" the more stringent criteria laid
down in the original Core Strategy Section 8. As the public consultation and comments
were based upon the original Core Strategy (from both residents and our Town Council)
one must question the amendments, the Councils motives and current policy in relation to
public consultation
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
To ensure all our concerns are addressed by the decision makers
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
166. Mr D Core (Individual) : 25 Apr 2012 14:48:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - All Grange-over-Sands sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Grange over Sands
The Core Strategy states that tourism, leisure and heritage sectors are to be developed in order to achieve a sustainable local economy. The employment this
generates is predominantly low in numbers and low in remuneration together with
"seasonal" only posts. With the development of these sectors there will inevitably be more
"visitors" and more motor vehicles. As the town is served by an inadequate "B" road the
B5277 , even with our present population the road and town suffers from congestion.
Therefore there is no sound reasoning to assume that these development proposals will not have a serious impact upon the town. Indeed when one assess the loading, with the
impact of development in Grange and the proposals for Allithwaite and Flookburgh there
can be no doubt this will cause serious traffic and environmental problems. What cannot
be stated about Grange with this current plan, quoting SLDC's own statement on
the town centre, that sites will have "minimal impact on the historic core of the
town". This is a serious consideration for Kirkby Lonsdale but not for Grange despite the
town having listed buildings and a reputation for its Edwardian/Victorian architecture,
again there is a lack of consistent application of the Core Strategy, that makes the plan in
relation to Grange unsound.
I list below some of the contributory factors to the overloading of the highways
infrastructure.
(1) The increase in resident motor vehicles. The South Lakeland LDF Sustainability
Appraisal Scoping Report states "Most households in South Lakeland own a car,
with 34.3% of households owning two or more compared to 29.5% in the UK
(2001). "Reasonable levels of bus services are provided for the towns and larger villages,
but there is less provision in rural areas, resulting in problems for some households in
accessing jobs, services and education".
This scenario is applicable to Grange as motor vehicle travel will continue as at present in
order to access well paid jobs outside the district and travelling at a time that's convenient
to the individual at a comparatively low cost.
(2) The location of the proposed Supennarket (at Batemans and not Hadwins as stated) at
a critical junction within the town.
(3) The catchment area for the supennarket (south lakes peninsula, possibly from an
8 miles radius. This being midway between the town and other established supennarkets).
( 4) The location of the development totally on the western side (noted as east in the
Gillespie Report) of the town, together with the cumulative total for Allithwaite and
Flookburgh.
(5) The development of tourism, leisure and heritage sectors is commendable. With this
one has to accept an increased motor vehicle use with a requirement for parking. The
LDF as it stands actually reduces the amount of car parking space available within the
town.
(6) The pinch points on the highway system in the town are the main tourist areas of The
Esplanade, Main St, Y ewbarrow Terrace and Kents Bank Road. These are the very points
that cannot be improved and are the areas likely to suffer with a deterioration in air quality
due to congestion. With reference to the Sustainability Appraisal Scoping Report page
29 in the Climate Change and Energy section it clearly states "Also relating to
climate change are waste generation and car journeys. South Lakeland has high
levels of waste production and car use higher than the UK average." This is not
conducive with the development of tourism.
We can liken this to the problem already highlighted in Kendal, a fact mentioned in
Section 11 of the Local Development Framework entitled "Accessibility and
Transport", it refers to the problems currently being experienced in the town and its
impact on the local economy. The text says;
"These prevailing travel patterns, coupled with high volumes of tourist traffic, have
resulted in congestion at peak times, (Grange has this most of the spring and
summer with current traffic levels and parking spaces) particularly around the
centre. As a consequence, shoppers can be discouraged from visiting the town centre
because of the difficulty and/or expense of parking". In the core strategy, concern is
expressed about the impact the private motor vehicle has on the town now, without the
inevitable increase stating that "access 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. Grange over Sands is a highly walkable and
compact town. However, it suffers from problems associated with the impact ofthe
private car on the built environment. For pedestrians, the Grange over Sands
environment is noticeably poor. In general terms, footpaths are natTow and there is
a strong sense that the car is the dominant feature on Kents Bank Road and Main
Street. Improving linlmges, infrastructure and the quality of the pedestrian
environment are key priorities. There is insufficient firm data on whether
this can or will be delivered".
The LAD PD. by placing all the emphasis on development in Grange ~,
South, ignores the Core Strategy's warning (CS5.32) that "given the
problem of town centre congestion in Grange at peak times significantly
higher traffic levels could well threaten the core economic activity of the
town, namely tourism". An increase in population, on the scale proposed
in the plan, would certainly result in at least 30% (including Allithwaite
and Flookburgh) more traffic which would challenge its ambition of
"promoting the vitality of Grange Town Centre and promoting tourism"
(LADPD4.2)
There is no detailed plan for deliverabilitv or funding of important infrastructure to
support the development proposals
Furthermore there has been concern expressed by SLDC about the deterioration in air
quality due to standing traffic in Kendal. However Kendal does have one advantage, the
existing highway infrastructure allows a good free flow of traffic around the town, (a bye
pass) this is something that Grange will not be able to achieve hence the inevitable increase
in congestion and the grave concern about the unsound development policy being imposed
bySLDC.
(7) With this current LDF, construction traffic will be passing through the town centre for
twelve years, servicing the Grange sites and those in Allithwaite and Flookburgh. This
scenario is not conducive with the development of tourism and will inevitably have a
negative impact for years with an unknown long term outcome. This is an economic
gamble with the long term sustainability of the town.
If we are now to consider the detail in the Core Strategy Document particularly in relation
to supportive infrastructure and its satisfactory deliverability.
Pavements and Cycleways
Considering the location of the proposed development for the town to the west (east
according to Gillespies) on a high elevation this will involve a steep walk or cycle back
from the town centre services. The severity of the gradient on Risedale Hill in places is
1 :6, this will mean its only suitable for relatively fit and is not conducive to those who are
not. Whilst the distance from the new sites to the town is not excessive, the topography
does not make walking or cycling an attractive proposition. The footpath is only on one
side of the road as the road its self is narrow along this section. The width of the path
makes it difficult for pedestrians to pass comfortably and safely, indeed we often see the
roadway being used when child buggies or small groups (two or more) pass each other. A
secondary problem relating to this path is that larger vehicles when passing in opposite
directions "overlap" the pavement in order to maintain speed and avoid stopping on this
steep gradient. This occurs even when pedestrians are using the pavement and has the
potential to be dangerous, this risk will increase with greater use. If we are to consider a
cycle route along this road into town one has also to consider the return journey and the
number of individuals who will want to negotiate Risedale on the return. To simply mark
either side of this narrow road with a cycle lane will be unacceptable given the width of
the highway and the risk due to increased motor vehicle use. Quite clearly the private
motor vehicle will still be the favoured method of transport for visits to the town centre
services purely for convenience.
The second route for pedestrian and cycle access to the town is making use of the existing
footpath that runs from the bottom ofKentsford Rd through to the Promenade. This route
starts with steep steps from Kentsford Rd ( not conducive with cycling) onto a section of
undulating narrow elevated footpath alongside and above the railway line. Firstly from the
proposed development areas you have to descend to the bottom ofKentsford Rd, again
this is not user friendly particularly (carrying shopping) when returning. The section of
footpath adjacent the railway line is not wide enough for two people to pass comfortably
so there is no possibility of bicycles using this safely. It is completely out of the question
given the latest design criteria that this section can be used safely without serious conflict
between the user groups. To simply make use of this to support new development is
unacceptable. There is no possibility of widening this section because on one side we have
garden walls, some of which are retaining and on the other the railway track which is at a
lower elevation. The third route would be Carter Rd down to Cart lane descending the hill
to "pick up " the now wider "railway route" onto the promenade. Carter Rd down to Cart
Lane is very steep, (in places steeper than 1 : 6) no more than a single track road without a
pavement. This is the most difficult and potentially dangerous route for vulnerable users
(pedestrians and cyclists) into town.
The final section on the route presents other problems because of the railway line and the
capital investment required to improve safety for all users. The access and egress from the
promenade at both ends involves a "blind" 90 deg turns under the track, this has the
potential for not only conflict between the different user groups but also the potential for
increasing the risk of accident particularly at the Cart Road end where the access and
egress from the promenade is extremely narrow and "blind". There is also a height
restriction, an adult on an upright commuting bike will find the railway "bridge" much to
low. If pedestrian and cycleways are a serious part of the LDF they must be constructed
to a safe acceptable standard, unfortunately this will be extremely difficult and probably
hard to justifY economically. There certaiuly has not been enough survey work carried out
on the feasibility of providing such supportive infrastructure. To state in the Core
Strategy that Grange already has cycleways in the town is not just misguided but
totally untrue. What is true is that the NCN does pass through the town from Meathop
via the golf club road through the town centre on Kents Bank Road before rejoining the
B5227 then turning right over the fells via Low Fell Gate. This route will become more
hazardous with the increased numbers of motor vehicles on narrow congested roads
within the town. There is no where in the Strategy Document that considers the impact of
topography on these proposals. Its worth noting this route currently does not ascend
Risedale Hill or Cart Lane and uses main roads through the town. This cannot be
considered as a route that will support the proposed development plans and promote
cycling to access services, given the current traffic volumes, it's inevitable increase and the
degree of safety that's acceptable to everyone the young and old a like.
I would refer you to the report of an accident in The Westmoreland Gazette dated
Thursday March 22, 2012, that occurred on Main Street in Grange over Sands.
Hit-and-run driver appeal
A hit and run driver who struck a woman in Grange over Sands is being sought by
police. The motorist failed to stop after being in coUision with the pedestrian, who
was walking along the pavement in Main Street, on Monday. Police say that a black
vehicle struck the woman's arm as it was traveUing toward the clock tower. Anyone
who witnessed the incident should contact PC Oliver at Ulverston police station on
non-emergency number 101.
This confirms the inadequate width of pavement and carriageway on the B5277.
This being the main route that serves Grange, Allithwaite and Flookburgh I would refer
once again to Section 11 of the LDF that states "access is poor, limited mainly to the
B5277 /8 looping of the A590 to run through Grange, Allithwaite and Cark (via
Flookburgh) and "For pedestrians, the Grange over Sands environment is
noticeably poor. In general terms, footpaths are narrow and there is a strong sense
that the car is the dominate feature on Kents Bank Road and Main Street".
With regard to the National Planning guidelines, there has been no assessment on "The effect of the development on highway safety and the free flow oftraffic".
Policv T4 states "all development and associated highway proposals should provide
for safe, direct, convenient and attractive means of movement on foot".
Policy T5 on cycling says "when assessing development and associated highway
proposals, safe, direct, convenient and attractive provision for cyclists will be sought
and many include (a) detailed traffic management and traffic calming schemes to
ensure both cyclist safety and priority movement".
Policy T13 on traffic management and traffic calming "seeks the safe and
convenient movement of pedestrians and cyclists as well as for people in cars".
This current plan does not address any of these issues. The development fails to
demonstrate that safe, convenient and attractive access on foot and by cycle can be
achieved for Grange over Sands. The proposal would not give sufficient
encouragement to walking and cycling as an alternative means of transport to the
car and raises serious safety concerns. Again SLDC make reassuring aspirational
statements on deliverability, but do not have the prerequisite plan to ensure that
deliverability is in line with policies T4- T5- Tl3. There has been no cumulative
assessment of the traffic, and its implications upon the settlement in terms of safety,
environment and long term economic sustainability. When this is assessed it is considered
that given the obvious limitations of the B5277 and the LADPD CSS .32 there will be
considerable problems within the town, a failure to recognise this fact is a prime example
of a flawed decision making process, being undertaken by the Council without any local
knowledge of the settlement.
This is why residents and the Town Council are key to a successful development plan for
the town and why the current policy of justification at all costs with generic statements is
unsound.
The proposed level of development will only serve to make the town less attractive to
tourists and visitors, which is contrary to long term interest and sustainable
viability, which is the stated objective of the Core Strategy. I would once again
refer you to page 10 LAPD CS5.32
A590 High Newton Bye Pass
The inclusion of this road in the plan as being beneficial to development in Grange is quite
ludicrous. To get to the A590 the narrow B5227 going through the town or the narrow
unclassified roads in the surrounding rural area will have to be used. I would refer you to
section 7 Accessibility and Transport mentioning the B5277 "looping off the A590". The
inclusion of the A590 is not based on any local rationale, indeed both Allithwaite and
Flookburgh development plans express concern about the capacity of their local roads to
accommodate development, without any mention of further potential loading on the A590.
There is no sound planning link between these concerns about local traffic and the
cumulative loading on the highways infrastructure in Grange over Sands.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
To ensure all our concerns are addressed by the decision makers
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
167. Mrs C Core (Individual) : 27 Apr 2012 07:42:00
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I have read the guidance notes
Paragraph No.
1.9
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The Consultation Process
Throughout the consultation process the Council and its officers have not answered
pertinent questions on the development allocations for each area. The standard answer
has been we note your comments, this has not resulted in any meaningful dialogue with
communities. In the case of Grange over Sands despite representation made by residents
and the Town Council nothing has changed from the LDF's inception. The District
Council have when confronted with any fact that is not complimentary to their current
plan tended to fall back on "if we do not have a plan developers will build where they want
and win on appeal if we turn down applications". Despite the Town Council and residents
agreeing a plan is needed there has never been an alternative discussed. A more
appropriate plan involving the Town Council and residents would satisfy local needs and
stand scrutiny at appeal. The only sensible way forward is to have community
involvement using the Core Strategy as the principal guiding document.
All meetings with SLDC have taken the form of presentation. Despite many concerns
being raised about the document, we have never received any answers or reassurances
from Council Officers or Councillors. The standard phrase continually used is "we will
note your questions and comments". This has never resulted in any follow up response
from SLDC. When residents have requested that SLDC Officers and Councillors meet
with our Town Council to resolve the outstanding issues, this has occurred, but at the
insistence of SLDC the meeting has been informal with no official minutes, no justification
or change in the proposed development for the town. Furthermore an application by the
Town Council to become a Local Planning Group in order to allocate development within
the town to ensure a sustainable economic future for Grange was rejected. SLDC by their
actions have shown that Public Consultation was in reality presentation and the original
LDF will proceed, as originally conceived. In order to justify this to the 98% of the 4,800
respondents across the district who objected, sections of the core strategy document
relating to green open spaces and infrastructure have become less specific and more generic with balance towards developers and a justification of the current proposals. Even
minor alterations to the Core Strategy at this late stage is totally unacceptable given that
all previous discussions and "presentations" by SLDC have been based upon the "original Core Strategy",
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
Read Notes
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
168. Mrs C Core (Individual) : 27 Apr 2012 07:46:00
A typed or handwritten document was submitted. This has been scanned and can be downloaded below:
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I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - R89 GRANGE-OVER-SANDS NORTH OF CARTER ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
1. DEALLOCATE RS9 AND DEFINE AS IMPORTANT OPEN SPACE
When this site was deallocated in Alteration 1 final proposals October 2001 for the South
Lakeland Local Plan 2006 it was stated that it would "contribute to the public amenities of
this part of the built up area of Grange over Sands" SLDC agreed with this statement and
"earmarked it as important open space".
In summary the public inquiry said "The request to designate the Berry Bank site (now
R89) as important open space is easier to justify given its landscape and amenity
qualities", this is still the case today.
National Planning Policy Framework
76. Local communities through local and neighbourhood plans should be able to
identify for special protection green areas of particular importance to them. By
designating land as Local Green Space local communities will be able to rule out
new development other than in very special circumstances. Identifying land as
Local Green Space should therefore be consistent with the local planning of
sustainable development and complement investment in sufficient homes, jobs and
other essential services. Local Green Spaces should only be designated when a plan
is prepared or reviewed, and be capable of enduring beyond the end of the plan
period.
I would also make reference to a comment made by Cumbria County Council in the
Emerging Option Document for Grange over Sands page 75 which states that the site
"could also be an important open space that contributes to the character of the
settlement" . The Core Strategy Document Section 8 of Green Infrastructure page 13
states "that a private open space should meet ONE of the following criteria in order
to be classified as important open space for amenity. In reality R89 satisfies SEVEN
out of the TEN criteria listed, whilst the green open space is compromised by a tall
hedge on the Allithwaite Road, from the Kents Bank estate it is most visible and an
important area of green open space/infrastructure as it is most visible from this widely
used local route, Carter Road.
1. Land Assessment and Consultants Recommendations to the Council
The SHLAA Final Report Assessment lists R89 as a Category 3 site
Category 3 is defined as sites that achieve low scores on assessment below 35 out of
50 and "perform least well against the assessment criteria, facing at least three
significant constraints (least developable sites) The reference document is Roger Tym
and Partners M9233 March 2009 Final Report Section 6 para 6.5 page 33. This
document should then be cross referenced with the Grange over Sands Fact File -
Febrnarv 2012 page 104 Paragraph:- justification/issues to be addressed states that
"The site scored FULL MARKS in the SHLAA assessment". This is simply a
deliberate misrepresentation of the site to ensure allocation in favour of landowners and
developers. This decision on land parcel R89 is unsound and completely unjustified. The
Fact File Document also states that the site "could be an important open space that
contributes to the character of this part of the settlement".
I would now refer to the Douglas Wheeler Associates Regeneration Study dated 2007
and the Gillespies Report and Plan dated December 2008.
The Douglas Wheeler Regeneration study stated "that residential development of the
Allithwaite Road/Carter Road site is likely to be controversial because of the "Greenfield
nature of the site" and do not include this site in their final list of preferred
development"
Gillespies Report dated December 2008 This report and plan acknowledges there are
some parts of Grange "to the east of the B5277 the coastal plain is open and allows
attractive views toward the estuary. Development in this area would impact significantly
on these views and no development should be considered to the east of Grange over
Sands. East Grange lies tight to the existing railway line and estuary edge along the east
shore of the estuary. There is no room for development within this area. The majority of
sites facing the water have been occupied and fall within the existing development
boundary. Only four sites were put forward by the Gillespies Report, North of Grange
Road, Kents Bank Road/Cartmel Road, Kents Bank (see plan). Some of the conclusions
of the Gillespies Report compliment the DWA Regeneration Study, unfortunately the
outcome has remained the same, land that is not included or recommended for
exclusion now forms part of the final land allocation document. I refer you to page
33, Southlakeland Employment and Housing Land Search Study Gillespies Dec 2008:The
eastern section includes R89 land parcel.
I would also once again make reference to the comment made by Cumbria County Council
in the Emerging Option Document for Grange over Sands page 75 which states that the
site "could also be an important open space that contributes to the character of the
settlement" .
2. Land Allocation Development Plan Document Page 195 R89 Effect on Landscape
Character
The rating is classified as neutral. Given the recommendations by Douglas Wheeler
Associates, Gillespies Report, the Green infrastructure Section 8 of the Core
Strategy, Cumbria Country Councils comments and the Category 3 rating how can
one consider the effect on the Landscape Character as being neutral. FORTY FIVE
dwellings on this important and only green open space for this part of the Kents
Bank, located on a strategic route bas MORE THAN A NEUTRAL EFFECT. THE
NEUTRAL RATING IS UNSOUND AND UNJUSTIFIED
There is no accurate or technical assessment of the increased localised flooding to
dwellings at a lower elevation. There are serious omissions in relation to biodiversity and
wild life migration. There is no mention of the limestone wall running the entire
length of the frontage on Cater Road this wall has been a characteristic of the
roadway for at least 100 years, however bushes and trees on the remainder of the
perimeter are noted. As the current LDF has an over provision of up to 20%, there is no
possible reason why this important green open space for the community and its category 3
rating should not preclude it from the development programme.
The location of the site in relation to accessing services in the town does not consider
the topography. All routes involve returning up a severe gradient that at times exceeds
1: 6. One route has a narrow footpath down one side the other is a single track road with
no footpaths so the needs of people with disabilities are not being considered. Walking
and cycling will not be safe as an alternative means of transport as this will cause conflict,
between motorised traffic, cyclists and pedestrians using these unsuitable routes. No
Transport Assessment has been carried out.
Built Environment R89
A neutral rating
There will be no potential to "improve the built environment" Refer to Dogulas Wheeler
Associates recommendation and comments. Page 14 para 3 When referring to the Kents
Bank area, it states "open outlook, becoming suburban, some large detached by villas,
open spaces important they also conclude that residential development of the
Allitbwaite Road/Carter Road site should not be on the list of preferred
development.
The Gillespies Report also excluded the site. SHLAA Rated Category 3 site.
The neutral rating for the built environment is unsound and unjustified. Therefore
the rating should be X
Water Supply/Surface Water R89
The top soil on this site greatly reduces the risk of serious localised flooding at times of
heavy down pours. Over the last four years there has been some localised property
flooding in the immediate vicinity of this site. The minimal impact has been due to the
topsoil absorption at periods of heavy rain. With the proposed development of 45
properties the hard standing will increase the run off potential, this cannot be disposed of
into the local sewerage system as the Water Company have already prohibited this. Given
the nature of the ground conditions in this area, mainly limestone with a top soil covering,
disposal of surface water run off will be a major factor to consider. SLDC have been
informed of this problem over 12 months ago, the rating should therefore be X and not
left as an open issue to be addressed later.
Greenfield or Brownfield R89
I refer you to the Category 3 rating. This designation requires that all other more suitable
sites are to be developed before this category is to be considered. It is proposed by SLDC
that R89 is now included in the phase 1 development programme. This contradicts the
Category 3 rating and SHLAA assessment.
Education and Training R89
Totally the wrong rating, rating ECI, EC3. Further Higher Education and Training is not
located within a 1-4km radius of Grange over Sands. A training facility to be rated as
positive should provide a range of training that is varied enough to meet the demands of
the local community. The nearest facilities are Kendal 24km, Barrow 42km and Ulversto
24km away. The rating using the Council's own criteria should be XX.
Access to Jobs R89
With the potential for another 500 properties in Grange over Sands it is doubtful that
tourism, heritage and leisure will cater for the increased population. I refer to SP2 "no
criteria were used to assess sites against this objective" as all housing sites will
automatically help to provide people with homes and all employment sites will support
access to homes by helping raise average incomes and provide jobs, which in tum will help
people to access housing. In order to fulfil criteria set down in the Core Strategy on
excessive travelling and the environment, employment land should be in close proximity to
housing. This is not the case for Grange over Sands, which has been allocated 8% of the
13% housing allocation for the three Key Service Centres compared with 3% for Milnthorpe and Kirkby Lonsdale (as Appendix 1 -proposed distribution of development)
(Kirkby Lonsdale had twice the amount of land required for development). The
employment land has largely been allocated to Milnthorpe and Kirkby Lonsdale, with
Milnthorpe receiving 50% of the three Key Service Centres total and approx 33% of the
housing development..
Open Space R89
The rating given to R89 when assessing the loss of this green open space is incorrect. The
Kents Bank area is and has always been accepted as a "stand alone" area within Grange by virtue of its location and the elevation above the town. Green open spaces are an
important feature and can act as a visual amenity to the settlement, and helps to
prevent the area becoming totally suburban. The importance of this site for wildlife
migration (deer) as "stepping stones Pockets of habitat that, while not necessarily
connected, facilitate the movement of species across otherwise inhospitable
landscapes". This is acknowledged in the Douglas Wheeler report were it stated, that
the open spaces are important in this area and its subsequent omission and confirmation in the Gillespies Report.
Access to Educational Facilities R89
In relation to R89 the Primary and Secondary assessments are the wrong way around.
The secondary school is just over the 3 km, therefore it falls into assessment band X and
not as indicated.
Biodiversity R89
21 species have been identified but no further information is given despite these being
identified as key species. The potential for water voles has also been identified but there is
no mention of deer or their movement across the site daily.
Surface Water Flooding R89
The assessment is not accurate SLDC have not accepted two instances of localised
flooding when there has been heavy down pours or even asked for further information
from respondents who have identified this problem. The top soils absorbent surface
manages to alleviate most of these problems at periods of heavy rain. A further factor is
that the substrata is limestone, this is not renown for its ability to provide adequate soak
away. The Water Company, United Utilities have already stated that no run off water will
be permitted to enter the public sewer. Therefore given its location to any other disposal
points, soakways would have to be considered, it will be difficult to construct these to be
effective without them "overtopping" to the road drainage and ultimately overloading the
sewerage system something the Water Company will not permit.
South Lakeland Local Development Framework Land Allocation Development Plan
Document page 223
Overall, Grange over Sands scores best in terms of access to jobs, a shop, education and
training, transport and health services. Sites also score generally well against access to a
village hall, a secondary school, recycling facilities and open spaces (although some sites
would remove provision if developed) as well as in terms of flood risk and sites' locations
in relation to the existing community. It then goes on to contradict these statements with
Grange over Sands sites score least well in terms of impact upon biodiversity and air
quality.
The mediocre scores against access to cultural and leisure facilities suggest that
Grange over Sands would benefit from more local provision of such facilities.
Mediocre scores were also given against water supply/sewerage capacity and against
the potential for the use of energy efficiency measures and renewable as well as
recycled materials in new developments.
Scores are variable against access to primary schools and impacts upon landscape
and the build environment as well as in terms of the take-up of Greenfield land and
potential for coalescence.
Care will need to be taken to ensure that use of recycled materials and energy
efficiency/renewable energy measures are encouraged as few of the sites in Grange
over Sands have any clear evidence of in-place opportunities for this.
Care will also need to be taken to ensure that impacts on the landscape, biodiversity,
air quality and built environment are avoided or minimised and that adequate
water supply/sewer capacity is in place
The sites that score best overall are R381, R378, R383, R376, R673, MN16, MN2
and MN1 score poorly overall in comparison to other.
NO REFERENCE IS MADE TO R89
There can be no doubt that what is emerging in site options document for
Grange over Sands is that developers are setting the development programme as in the
case of R89. I refer you once again to page 104 of the Grange over Sands Fact File Feb
2012 where it states in Site Availability "Russell Armer have confirmed available" and in
Justification Issues to be Addressed "The site scored full marks in the SHLAA
Assessment" This is simply untrue, misleading and stated in order to achieve the
developer/landowner/council objective of inclusion. Further more I would again draw
your attention of the Category 3 rating of the site and its limitation on potential use, it is
certainly not to be developed in the way it is currently proposed. Enclosed documents
confirm this classification and the misrepresentation of classification. All
recommendations and assessments of R89 confirm that this land parcel should be removed from the LDF and remain as important green open space for the local community. This failure to do so confirms the "unsoundness" of the Councils development proposals and a disregard of Core Strategy and SHLAA assessment in favour of landowners and
developers. This is unsound and totally unacceptable.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
Read notes
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
169. Mrs C Core (Individual) : 27 Apr 2012 07:49:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
0.0 Whole Document
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I wish to make representation on the proposed Local Development Framework by South
Lakeland District Council. There is in this current plan numerous contradictions with the
Core Strategy that make it "unsound". Reports compiled by their Consultants used to
develop the Core Strategy and eventually the Development Plan have been used "piece
meal" when serious concerns about locations and magnitude of development are raised. ·
The strategy is not justified in that it is not founded on a robust and credible evidence base
and/ or is not considered the most appropriate strategy when considered against the
reasonable alternatives.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
Read notes
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
170. Miss Rosemary Corton (Individual) : 8 May 2012 17:38:00
Policy/Site No.
LA1.3 Housing Allocations - R697 & part R242 ULVERSTON CROFTLANDS EAST
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
You can see where I live, so like many other residents I'm obviously opposed to the buildign of affordable housing on green fields behind the Croftlands Estate and beyond towards Priory Road, Ulverston.
I have been a resident since 1973, came from the London area with my mother (now passed away) looking for green fields, open spaces and a new start.
Although the estate has deteriorated considerably since (supposed to be open plan gardens now anythign goes eg fences and walls put up 'willy-nilly') my partner and I had at least a pleasant outlook to the rear of the property.
Feeling vulnerable now and no-one to fight my cause (my partner passed away last year) I, with other residents, feel I must object to having our peace shattered, our view destroyed due to unnecessary building on what is prime agricultural land.
When I lived in London in the 60s it was 'tabeoo' to build on green belt area - this is our green belt!!
Ulverston is a unique market town surrounded by natural beauty, fells, open spaces which attract tourism. The open vistas of the Bay from Priory Road will disappear if the planned build is given the go ahead; result, an urban sprawl no doubt one day to amalgamate with Barrow (or Dalton the other way) who wants another Barrow? Horrendous!
New housing development at Croftlands Estate would increas the traffic from the A590 making the junction Coast Road / Oakwood Drive a potential nightmare; (already an accident waiting to happen with shoppers at the Co-op nearby.) & Birchwood Drive an even busier thoroughfare, extra buses etc
I am sure you know the scores . Think before you act need listen to the people - please!!
Several years ago a meeting on the subject at theLancastrian pub, Mountbarow Road (the consultation period if you like) aired several problems which still have not been addressed; roads have only recently just been 'patched up', the flooding situation behind the pub and in the lanes to Kirkigg remain the same. Due to the scale of the development have all utilities been upgraded? i.e. what about the capacity of the shcools; the Health Centre too can hardly cope as it is.
There appear to be plenty of affordable properties on the market in and around Ulverston for potential buyers or to let or rent, so why build on important green gaps between communities which are needed, especially on such a large estate that too is meant to be 'affordable' housing. We already live within a huge council estate are we to have more those ugly grey properties build or private properties like at Swarthmoor built like a pack of cards, with flooding problems too I believe.
Please note we are already fighting to prevent an onslaught of supermarkets in our town. How much more can we take? This brings to mind the discussion of the one-way system in Ulverston years ago, meetings were set up, letters written, opinions asked for, only to be completely dismissed as the decision, admittedly, had previously already been made. Hopeless! Therefore are we to assume that the expansion of the children's play area on Caentral Drive Croftlands amounts to the same thing? I sincerely hope not!!!
Anyway thanking you! I await the next step in anticipation.
171. Miss Rosemary Corton (Individual) : 8 May 2012 17:39:00
Policy/Site No.
LA1.3 Housing Allocations - R690ulv, R691ULV, R126M, RN184, RN234# & part R242 ULVERSTON CROFTLANDS WEST - NOOK FARM
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
You can see where I live, so like many other residents I'm obviously opposed to the buildign of affordable housing on green fields behind the Croftlands Estate adn beyond towards Priory Road, Ulverston.
I have been a resident since 1973, came from the London area with my mother (now passed away) looking for green fields, open spaces and a new start.
Although the estae has deteriorated considerably since (supposed to be open plan gardens now anythign goes eg fences and walls put up 'willy-nilly') my partner and I had at least a pleasant outlook to the rear of the property.
Feeling vulnerable now and no-one to fight my cause (my partner passed away last year) I, aw with other residents, feel I must object to having our peace shattered, our view destroyed due to unnecessary building on what is prime agricultural land.
When I lived in London in the 60s it was 'tabeoo' to build on green belt area - this is our green belt!!
Ulverston is a unique market town surrounded by natural beauty, fells, open spaces which attract tourism. The open vistas of the Bay from Priory Road will disappear if the planned build is given the go ahead; result, an urban sprawl no doubt one day to amalgamate with Barrow (or Dalton the other way) who wants another Barrow? Horrendous!
New housing development at Croftlands Estate would increas the traffic from teh A590 making the junction Coast Raod / Oakwood Drive a potential nightmare; (already an accident waiting to happen with shoppers at the Co-op nearby.) & Birchwood Drive an even busier thoroughfare, extra buses etc
I am sure you know the scores . Think before you act adn listen to the people - please!!
Several years ago a meeting on the subject at theLancastrian pub, Mountbarow Road (the consultation period if you like) aired several problems which still have not been addressed; roads have only recently just been 'patched up', the flooding situation behind the pub and in the lanes to Kirrigg remain th seame. Due to the scale of the development have all utilities been upgraded? i.e. what about the capacity of the shcools; the Health Centre too can hardly cope as it is.
There appear to be plenty of affordable properties on the market in and around Ulverston for potential buyers or to let or rent, so why build on important green gaps between communities which are needed, especially on such a large estatethat too is meant to be 'affordable' housing. We already live within a huge council estate are we to have more those ugly grey properties build or private properties like at Swarthmoor built like a pack of cards, with flooding problems too I believe.
Please note we are already fighting to prevent an onslaught of supermarkets in our town. How much more can we take? This brings to mind the discussion of the one-way system in Ulverston years ago, meetings were set up, letters written, opinions asked for, only to be completely dismissed as the decision, admittedly, had previously already been made. Hopeless! Therefore are we to assume that the expansion of the children's play area on Caentral Drive Croftlands amounts to the same thing? I sincerely hope not!!!
Anyway thanking you! I await the next step in anticipation.
172. Miss Rosemary Corton (Individual) : 8 May 2012 17:41:00
Policy/Site No.
LA1.3 Housing Allocations - RN131M,RN141#, RN321# &RN284# Ulverston - Gascow Farm
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
You can see where I live, so like many other residents I'm obviously opposed to the buildign of affordable housing on green fields behind the Croftlands Estate adn beyond towards Priory Road, Ulverston.
I have been a resident since 1973, came from the London area with my mother (now passed away) looking for green fields, open spaces and a new start.
Although the estae has deteriorated considerably since (supposed to be open plan gardens now anythign goes eg fences and walls put up 'willy-nilly') my partner and I had at least a pleasant outlook to the rear of the property.
Feeling vulnerable now and no-one to fight my cause (my partner passed away last year) I, aw with other residents, feel I must object to having our peace shattered, our view destroyed due to unnecessary building on what is prime agricultural land.
When I lived in London in the 60s it was 'tabeoo' to build on green belt area - this is our green belt!!
Ulverston is a unique market town surrounded by natural beauty, fells, open spaces which attract tourism. The open vistas of the Bay from Priory Road will disappear if the planned build is given the go ahead; result, an urban sprawl no doubt one day to amalgamate with Barrow (or Dalton the other way) who wants another Barrow? Horrendous!
New housing development at Croftlands Estate would increas the traffic from teh A590 making the junction Coast Raod / Oakwood Drive a potential nightmare; (already an accident waiting to happen with shoppers at the Co-op nearby.) & Birchwood Drive an even busier thoroughfare, extra buses etc
I am sure you know the scores . Think before you act adn listen to the people - please!!
Several years ago a meeting on the subject at theLancastrian pub, Mountbarow Road (the consultation period if you like) aired several problems which still have not been addressed; roads have only recently just been 'patched up', the flooding situation behind the pub and in the lanes to Kirrigg remain th seame. Due to the scale of the development have all utilities been upgraded? i.e. what about the capacity of the shcools; the Health Centre too can hardly cope as it is.
There appear to be plenty of affordable properties on the market in and around Ulverston for potential buyers or to let or rent, so why build on important green gaps between communities which are needed, especially on such a large estatethat too is meant to be 'affordable' housing. We already live within a huge council estate are we to have more those ugly grey properties build or private properties like at Swarthmoor built like a pack of cards, with flooding problems too I believe.
Please note we are already fighting to prevent an onslaught of supermarkets in our town. How much more can we take? This brings to mind the discussion of the one-way system in Ulverston years ago, meetings were set up, letters written, opinions asked for, only to be completely dismissed as the decision, admittedly, had previously already been made. Hopeless! Therefore are we to assume that the expansion of the children's play area on Caentral Drive Croftlands amounts to the same thing? I sincerely hope not!!!
Anyway thanking you! I await the next step in anticipation.
173. Mr Anthony Cousins (Individual) : 26 Apr 2012 14:38:00
Policy/Site No.
LA1.3 Housing Allocations - All Kendal sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
We would like to object to SLDC's Land Allocations DPD as it applies to Kendal.
There are strong objections that could be made to specific sites but our case focuses on
worsening congestion and air quality in the town. The evidence base SLDC have
accumulated includes three reports on transport and one on air quality. All four note
serious problems and doubts about whether improvements are achievable or deliverable.
Much of this evidence has been disregarded and the policy seems to be to push forward
development in the hope that transport improvements will eventually happen. This 'build
big and hope big' policy is concentrated into only thirteen years. A more realistic and
sequenced approach involving thoroughly researched transport improvements being
introduced in tandem with development over a longer period has not been considered.
We submit that this is not a sound response to evidence or planning.
To summarise our case:
I) The evidence base demonstrates that the town already has significant and worsening
congestion and related air quality problems.
2) It recognises that the proposed developments will greatly worsen these problems.
3) It identifies as mitigation solutions that are inadequate.
4) It adopts road schemes without regard to advice as to their limitations.
5) There are gaps in the evidence base, particularly regarding costing and assessing the
consequences of this new infrastructure.
6) The infrastructure is not deliverable as it is dependent on CCC and government
funding which the consultants have indicated is not likely to be forthcoming because it
represents poor value for money.
7) There is a general incoherence and disconnection between the Core Strategy and
Land Allocations DPD in regard to transport issues.
1 Existing and worsening congestion and air quality problems
a) This is repeatedly acknowledged in the Kendal Transport Assessment, the October
2011 and January 2012 Transport Studies and LA DPD: Even in 2008 it was recognised
that a number of junctions were operating at or over-capacity (KTA p.6). It further
states: It is clear from the analysis that the local highway network within Kendal will
struggle to accommodate the forecast level of traffic in 2025 regardless of whether the
potential LDF developments go ahead (p. 64 8.54)
b) There is already a Kendal Air Quality Management Area.
2 Recognition that development will greatly worsen problems
a) It is clear from the presented results that the volume of traffic forecast to be1
generated by the potential sites for consideration in the LDF Allocations of Land DPD
put forward for assessment would lead to a deterioration in traffic conditions in Kendal,
with significant congestion and delay occurring at a large number of junctions ... it is
clear that the addition of development traffic (particularly in the Shap Road/Appleby
Road corridor), will lead to further increases in queuing and delays. (KTA p.54 8.20)
b) The 2012 study contracts the period under consideration. Nevertheless, the result is
clear: the LDF developments greatly increase congestion across the key junctions.
c) The current proposals in the Allocations document will not be deliverable with
Kendal's existing traffic capacity. The road network is already working at capacity with
the effect that N02 levels in the town centre are close to or above the Objective. (Air
Quality Progress Report)
3 Ineffective mitigation
(a) The LPD Vision for Kendal (p.52) recognises that the town centre transport network
is suffering from significant congestion and that part of the Town Centre is also an Air
Quality Management Area but claims that Cumbria County Council has put forward a
series of mitigating measures to ensure that congestion and air quality impacts are
minimised. We note that the consultants have not calculated air quality results and
expect increased congestion unless all the infrastructure schemes are adopted.
(b) The only mitigation that the KTA could definitely recommend in 2009 was the
provision of two southbound lanes on Milnthorpe Road and signalisation of a junction.
The first is only a reversion to what once existed and both can only be regarded as trivial
changes.
(c) The first of the 'series of mitigation measures' in the 2012 report are junction
improvements. This includes the proposal for traffic on Ann St to give way to Longpool
traffic - again a reversion to a situation that was abandoned not long ago. In view of the
long history of experiments with junction changes in Kendal, with traffic lights added
and subtracted at several locations and even a reversal of flow in parts of the one-way
system, it would be surprising if they could deliver much improvement. In fact, their
tables show the junction improvements to have no effect in the a.m. peak by 2022.
(d) The second mitigation measure consists of Sustainable Transport Improvements. The
policy of modal shift through cycling, walking, and public transport improvements, park
and ride schemes etc. has been in local transport plans for many years and has not
delivered results. There is certainly potential in such schemes but only if a genuine
investment is made in them. The list of schemes in the Improvement Table does not
constitute such an investment. It is noted that Workplace Travel Plans have failed
before. The assumption that what is recommended would produce a 5% reduction in car
trips is highly optimistic.
(e) The third mitigation is a park and ride scheme. This has been considered and rejected
before, is not costed or scheduled and if built and successful is not shown to achieve
more than slight incremental improvements.
4 Adoption of problematic solutions without proper justification
A series of possible road construction schemes are mentioned in the transport studies
They are there because councillors have asked them to be considered.
They are not recommended - the KTA casts doubt on the case for the IRR and KNRR
and the January 2012 study concludes that these infrastructure schemes offer marginal
benefits ... would be expensive and may not be cost-effective solution to congestion. It
also notes that even with them a large proportion of the key junctions would operate
above capacity. This is not a sound basis for recommending these major schemes yet the
DPD treats their presence in the studies as an endorsement.
5 Gaps in evidence base
a) When SLDC adopted the LDF in January the minutes stated: Cumbria County
Council are preparing a Kendal Town Centre Traffic Study which will deliver the
improvements necessary to mitigate the transport and air quality impacts of new
development. This study will form the basis of an infrastructure Delivery Plan.
This confident statement regarding work that has not yet been done is unjustified. The
transport, air quality and infrastructure documents are variously titled. One is an
Assessment, two are Studies, one is a Progress Report and one a Position Statement.
They are not action plans. They assess problems and do not pretend to demonstrate that
alleviating congestion and delivering road schemes is easily attainable.
b) No evidence is provided as to the costs of new infrastructure and there does not
appear to have been any assessment of the costs of land take or cost benefit analysis for
the Inner Relief Road, Dowker's Lane or Southern Link proposals. There are no time
scales offered for fmancing, planning or constructing all these schemes. In fact, the
reports do not pretend to be full assessments of any of these possible major schemes. It
is difficult to understand why SLDC feels able to make decisions without such
assessments.
c) I cannot discover any proper projections or assessments about the impact of the DPD
on air quality. Increased traffic and additional road space in the centre of the town do
not offer a promising recipe for dealing with this problem.
d) The calulations for congestion in the January 2012 study are restricted to 2022. There
seems to be no good reason for this when the DPD runs to 2025. Also the assessment
results do not seem to calculate the effect of Rugby Club and Canal Head schemes
together.
e) The IRR, KNRR, Southern Link and Dowker's Lane proposals have been given no
publicity and seem to appear only in schematic form buried in one map in one appendix.
One of the stated objectives of the DPD is to achieve urban edges which maintain or
enhance the character and appearance of the town. The proposed roads would transform
four of the town entrance points and enclose substantial green field areas but this is
neither referred to nor assessed.
f) The case for rapid development of housing and employment land is made without any
evaluation of potential negative economic results. Much of the prosperity of the town is
dependent on it being considered an attractive place to live and visit. Poor air quality,
increased size, thirteen years of disruption caused by construction, increased congestion
and building additional roads that would allow potential tourists to by-pass the town are
among potential downsides that do not seem to have been seriously evaluated.
6 Undeliverable infrastructure mitigation
The KNRR and IRR are listed as over £5M schemes. SLDC is not competent to deliver
them. They have not been approved by the CCC and would, in any case, require
Government funding. There are no time scales for delivery. They are major schemes
requiring four new river bridges and two new railway bridges. The KNRR has been
rejected previously and was expected to cost over £25M several years ago. The price
will not have gone down. If this and the Dowker's Lane, IRR, Southern Relief road etc.
are serious plans it must be assumed that some calculation of costs have been made.
There is good reason to suppose that the figures in this case are so large as to render
delivery improbable or so far distant as not to constitute deliverable mitigation within
the time span considered. If councillors were not given such estimates they were not in a
position to make a realistic decision.
7 Incoherence and Disconnection
Core Strategy 10.1 and10.2 focus on improving public transport and walking and
cycling, park and ride and work travel plans. Road infrastructure improvements are
mentioned once but do not mention Kendal. The criteria include the requirement that the
volume of traffic can be accommodated by the existing road network.
Summary
The Three Transport Studies do not demonstrate that the Land Allocations DPD can be
implemented without serious congestion consequences and they offer no support to the
idea that the proposed infrastructure schemes are likely to be implemented. The
proposals are on a scale that is not reconcilable with the existing capacity of the network
or probable deliverable improvements.
SLDC have not engaged with or taken seriously the problems raised in their Transport
Studies. We submit that this does not constitute good planning and suggest that the DPD
should be rejected as unsound so that SLDC can reconsider.
174. Mr Anthony Cousins (Individual) : 26 Apr 2012 14:40:00
Policy/Site No.
LA1.4 - Kendal Sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
We would like to object to SLDC's Land Allocations DPD as it applies to Kendal.
There are strong objections that could be made to specific sites but our case focuses on
worsening congestion and air quality in the town. The evidence base SLDC have
accumulated includes three reports on transport and one on air quality. All four note
serious problems and doubts about whether improvements are achievable or deliverable.
Much of this evidence has been disregarded and the policy seems to be to push forward
development in the hope that transport improvements will eventually happen. This 'build
big and hope big' policy is concentrated into only thirteen years. A more realistic and
sequenced approach involving thoroughly researched transport improvements being
introduced in tandem with development over a longer period has not been considered.
We submit that this is not a sound response to evidence or planning.
To summarise our case:
I) The evidence base demonstrates that the town already has significant and worsening
congestion and related air quality problems.
2) It recognises that the proposed developments will greatly worsen these problems.
3) It identifies as mitigation solutions that are inadequate.
4) It adopts road schemes without regard to advice as to their limitations.
5) There are gaps in the evidence base, particularly regarding costing and assessing the
consequences of this new infrastructure.
6) The infrastructure is not deliverable as it is dependent on CCC and government
funding which the consultants have indicated is not likely to be forthcoming because it
represents poor value for money.
7) There is a general incoherence and disconnection between the Core Strategy and
Land Allocations DPD in regard to transport issues.
1 Existing and worsening congestion and air quality problems
a) This is repeatedly acknowledged in the Kendal Transport Assessment, the October
2011 and January 2012 Transport Studies and LA DPD: Even in 2008 it was recognised
that a number of junctions were operating at or over-capacity (KTA p.6). It further
states: It is clear from the analysis that the local highway network within Kendal will
struggle to accommodate the forecast level of traffic in 2025 regardless of whether the
potential LDF developments go ahead (p. 64 8.54)
b) There is already a Kendal Air Quality Management Area.
2 Recognition that development will greatly worsen problems
a) It is clear from the presented results that the volume of traffic forecast to be1
generated by the potential sites for consideration in the LDF Allocations of Land DPD
put forward for assessment would lead to a deterioration in traffic conditions in Kendal,
with significant congestion and delay occurring at a large number of junctions ... it is
clear that the addition of development traffic (particularly in the Shap Road/Appleby
Road corridor), will lead to further increases in queuing and delays. (KTA p.54 8.20)
b) The 2012 study contracts the period under consideration. Nevertheless, the result is
clear: the LDF developments greatly increase congestion across the key junctions.
c) The current proposals in the Allocations document will not be deliverable with
Kendal's existing traffic capacity. The road network is already working at capacity with
the effect that N02 levels in the town centre are close to or above the Objective. (Air
Quality Progress Report)
3 Ineffective mitigation
(a) The LPD Vision for Kendal (p.52) recognises that the town centre transport network
is suffering from significant congestion and that part of the Town Centre is also an Air
Quality Management Area but claims that Cumbria County Council has put forward a
series of mitigating measures to ensure that congestion and air quality impacts are
minimised. We note that the consultants have not calculated air quality results and
expect increased congestion unless all the infrastructure schemes are adopted.
(b) The only mitigation that the KTA could definitely recommend in 2009 was the
provision of two southbound lanes on Milnthorpe Road and signalisation of a junction.
The first is only a reversion to what once existed and both can only be regarded as trivial
changes.
(c) The first of the 'series of mitigation measures' in the 2012 report are junction
improvements. This includes the proposal for traffic on Ann St to give way to Longpool
traffic - again a reversion to a situation that was abandoned not long ago. In view of the
long history of experiments with junction changes in Kendal, with traffic lights added
and subtracted at several locations and even a reversal of flow in parts of the one-way
system, it would be surprising if they could deliver much improvement. In fact, their
tables show the junction improvements to have no effect in the a.m. peak by 2022.
(d) The second mitigation measure consists of Sustainable Transport Improvements. The
policy of modal shift through cycling, walking, and public transport improvements, park
and ride schemes etc. has been in local transport plans for many years and has not
delivered results. There is certainly potential in such schemes but only if a genuine
investment is made in them. The list of schemes in the Improvement Table does not
constitute such an investment. It is noted that Workplace Travel Plans have failed
before. The assumption that what is recommended would produce a 5% reduction in car
trips is highly optimistic.
(e) The third mitigation is a park and ride scheme. This has been considered and rejected
before, is not costed or scheduled and if built and successful is not shown to achieve
more than slight incremental improvements.
4 Adoption of problematic solutions without proper justification
A series of possible road construction schemes are mentioned in the transport studies
They are there because councillors have asked them to be considered.
They are not recommended - the KTA casts doubt on the case for the IRR and KNRR
and the January 2012 study concludes that these infrastructure schemes offer marginal
benefits ... would be expensive and may not be cost-effective solution to congestion. It
also notes that even with them a large proportion of the key junctions would operate
above capacity. This is not a sound basis for recommending these major schemes yet the
DPD treats their presence in the studies as an endorsement.
5 Gaps in evidence base
a) When SLDC adopted the LDF in January the minutes stated: Cumbria County
Council are preparing a Kendal Town Centre Traffic Study which will deliver the
improvements necessary to mitigate the transport and air quality impacts of new
development. This study will form the basis of an infrastructure Delivery Plan.
This confident statement regarding work that has not yet been done is unjustified. The
transport, air quality and infrastructure documents are variously titled. One is an
Assessment, two are Studies, one is a Progress Report and one a Position Statement.
They are not action plans. They assess problems and do not pretend to demonstrate that
alleviating congestion and delivering road schemes is easily attainable.
b) No evidence is provided as to the costs of new infrastructure and there does not
appear to have been any assessment of the costs of land take or cost benefit analysis for
the Inner Relief Road, Dowker's Lane or Southern Link proposals. There are no time
scales offered for fmancing, planning or constructing all these schemes. In fact, the
reports do not pretend to be full assessments of any of these possible major schemes. It
is difficult to understand why SLDC feels able to make decisions without such
assessments.
c) I cannot discover any proper projections or assessments about the impact of the DPD
on air quality. Increased traffic and additional road space in the centre of the town do
not offer a promising recipe for dealing with this problem.
d) The calulations for congestion in the January 2012 study are restricted to 2022. There
seems to be no good reason for this when the DPD runs to 2025. Also the assessment
results do not seem to calculate the effect of Rugby Club and Canal Head schemes
together.
e) The IRR, KNRR, Southern Link and Dowker's Lane proposals have been given no
publicity and seem to appear only in schematic form buried in one map in one appendix.
One of the stated objectives of the DPD is to achieve urban edges which maintain or
enhance the character and appearance of the town. The proposed roads would transform
four of the town entrance points and enclose substantial green field areas but this is
neither referred to nor assessed.
f) The case for rapid development of housing and employment land is made without any
evaluation of potential negative economic results. Much of the prosperity of the town is
dependent on it being considered an attractive place to live and visit. Poor air quality,
increased size, thirteen years of disruption caused by construction, increased congestion
and building additional roads that would allow potential tourists to by-pass the town are
among potential downsides that do not seem to have been seriously evaluated.
6 Undeliverable infrastructure mitigation
The KNRR and IRR are listed as over £5M schemes. SLDC is not competent to deliver
them. They have not been approved by the CCC and would, in any case, require
Government funding. There are no time scales for delivery. They are major schemes
requiring four new river bridges and two new railway bridges. The KNRR has been
rejected previously and was expected to cost over £25M several years ago. The price
will not have gone down. If this and the Dowker's Lane, IRR, Southern Relief road etc.
are serious plans it must be assumed that some calculation of costs have been made.
There is good reason to suppose that the figures in this case are so large as to render
delivery improbable or so far distant as not to constitute deliverable mitigation within
the time span considered. If councillors were not given such estimates they were not in a
position to make a realistic decision.
7 Incoherence and Disconnection
Core Strategy 10.1 and10.2 focus on improving public transport and walking and
cycling, park and ride and work travel plans. Road infrastructure improvements are
mentioned once but do not mention Kendal. The criteria include the requirement that the
volume of traffic can be accommodated by the existing road network.
Summary
The Three Transport Studies do not demonstrate that the Land Allocations DPD can be
implemented without serious congestion consequences and they offer no support to the
idea that the proposed infrastructure schemes are likely to be implemented. The
proposals are on a scale that is not reconcilable with the existing capacity of the network
or probable deliverable improvements.
SLDC have not engaged with or taken seriously the problems raised in their Transport
Studies. We submit that this does not constitute good planning and suggest that the DPD
should be rejected as unsound so that SLDC can reconsider.
175. Mr Anthony Cousins (Individual) : 26 Apr 2012 14:43:00
Policy/Site No.
LA1.6 Strategic Employment Sites - E4M KENDAL LAND AT SCROGGS WOOD, MILNTHORPE ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
We would like to object to SLDC's Land Allocations DPD as it applies to Kendal.
There are strong objections that could be made to specific sites but our case focuses on
worsening congestion and air quality in the town. The evidence base SLDC have
accumulated includes three reports on transport and one on air quality. All four note
serious problems and doubts about whether improvements are achievable or deliverable.
Much of this evidence has been disregarded and the policy seems to be to push forward
development in the hope that transport improvements will eventually happen. This 'build
big and hope big' policy is concentrated into only thirteen years. A more realistic and
sequenced approach involving thoroughly researched transport improvements being
introduced in tandem with development over a longer period has not been considered.
We submit that this is not a sound response to evidence or planning.
To summarise our case:
I) The evidence base demonstrates that the town already has significant and worsening
congestion and related air quality problems.
2) It recognises that the proposed developments will greatly worsen these problems.
3) It identifies as mitigation solutions that are inadequate.
4) It adopts road schemes without regard to advice as to their limitations.
5) There are gaps in the evidence base, particularly regarding costing and assessing the
consequences of this new infrastructure.
6) The infrastructure is not deliverable as it is dependent on CCC and government
funding which the consultants have indicated is not likely to be forthcoming because it
represents poor value for money.
7) There is a general incoherence and disconnection between the Core Strategy and
Land Allocations DPD in regard to transport issues.
1 Existing and worsening congestion and air quality problems
a) This is repeatedly acknowledged in the Kendal Transport Assessment, the October
2011 and January 2012 Transport Studies and LA DPD: Even in 2008 it was recognised
that a number of junctions were operating at or over-capacity (KTA p.6). It further
states: It is clear from the analysis that the local highway network within Kendal will
struggle to accommodate the forecast level of traffic in 2025 regardless of whether the
potential LDF developments go ahead (p. 64 8.54)
b) There is already a Kendal Air Quality Management Area.
2 Recognition that development will greatly worsen problems
a) It is clear from the presented results that the volume of traffic forecast to be1
generated by the potential sites for consideration in the LDF Allocations of Land DPD
put forward for assessment would lead to a deterioration in traffic conditions in Kendal,
with significant congestion and delay occurring at a large number of junctions ... it is
clear that the addition of development traffic (particularly in the Shap Road/Appleby
Road corridor), will lead to further increases in queuing and delays. (KTA p.54 8.20)
b) The 2012 study contracts the period under consideration. Nevertheless, the result is
clear: the LDF developments greatly increase congestion across the key junctions.
c) The current proposals in the Allocations document will not be deliverable with
Kendal's existing traffic capacity. The road network is already working at capacity with
the effect that N02 levels in the town centre are close to or above the Objective. (Air
Quality Progress Report)
3 Ineffective mitigation
(a) The LPD Vision for Kendal (p.52) recognises that the town centre transport network
is suffering from significant congestion and that part of the Town Centre is also an Air
Quality Management Area but claims that Cumbria County Council has put forward a
series of mitigating measures to ensure that congestion and air quality impacts are
minimised. We note that the consultants have not calculated air quality results and
expect increased congestion unless all the infrastructure schemes are adopted.
(b) The only mitigation that the KTA could definitely recommend in 2009 was the
provision of two southbound lanes on Milnthorpe Road and signalisation of a junction.
The first is only a reversion to what once existed and both can only be regarded as trivial
changes.
(c) The first of the 'series of mitigation measures' in the 2012 report are junction
improvements. This includes the proposal for traffic on Ann St to give way to Longpool
traffic - again a reversion to a situation that was abandoned not long ago. In view of the
long history of experiments with junction changes in Kendal, with traffic lights added
and subtracted at several locations and even a reversal of flow in parts of the one-way
system, it would be surprising if they could deliver much improvement. In fact, their
tables show the junction improvements to have no effect in the a.m. peak by 2022.
(d) The second mitigation measure consists of Sustainable Transport Improvements. The
policy of modal shift through cycling, walking, and public transport improvements, park
and ride schemes etc. has been in local transport plans for many years and has not
delivered results. There is certainly potential in such schemes but only if a genuine
investment is made in them. The list of schemes in the Improvement Table does not
constitute such an investment. It is noted that Workplace Travel Plans have failed
before. The assumption that what is recommended would produce a 5% reduction in car
trips is highly optimistic.
(e) The third mitigation is a park and ride scheme. This has been considered and rejected
before, is not costed or scheduled and if built and successful is not shown to achieve
more than slight incremental improvements.
4 Adoption of problematic solutions without proper justification
A series of possible road construction schemes are mentioned in the transport studies
They are there because councillors have asked them to be considered.
They are not recommended - the KTA casts doubt on the case for the IRR and KNRR
and the January 2012 study concludes that these infrastructure schemes offer marginal
benefits ... would be expensive and may not be cost-effective solution to congestion. It
also notes that even with them a large proportion of the key junctions would operate
above capacity. This is not a sound basis for recommending these major schemes yet the
DPD treats their presence in the studies as an endorsement.
5 Gaps in evidence base
a) When SLDC adopted the LDF in January the minutes stated: Cumbria County
Council are preparing a Kendal Town Centre Traffic Study which will deliver the
improvements necessary to mitigate the transport and air quality impacts of new
development. This study will form the basis of an infrastructure Delivery Plan.
This confident statement regarding work that has not yet been done is unjustified. The
transport, air quality and infrastructure documents are variously titled. One is an
Assessment, two are Studies, one is a Progress Report and one a Position Statement.
They are not action plans. They assess problems and do not pretend to demonstrate that
alleviating congestion and delivering road schemes is easily attainable.
b) No evidence is provided as to the costs of new infrastructure and there does not
appear to have been any assessment of the costs of land take or cost benefit analysis for
the Inner Relief Road, Dowker's Lane or Southern Link proposals. There are no time
scales offered for fmancing, planning or constructing all these schemes. In fact, the
reports do not pretend to be full assessments of any of these possible major schemes. It
is difficult to understand why SLDC feels able to make decisions without such
assessments.
c) I cannot discover any proper projections or assessments about the impact of the DPD
on air quality. Increased traffic and additional road space in the centre of the town do
not offer a promising recipe for dealing with this problem.
d) The calulations for congestion in the January 2012 study are restricted to 2022. There
seems to be no good reason for this when the DPD runs to 2025. Also the assessment
results do not seem to calculate the effect of Rugby Club and Canal Head schemes
together.
e) The IRR, KNRR, Southern Link and Dowker's Lane proposals have been given no
publicity and seem to appear only in schematic form buried in one map in one appendix.
One of the stated objectives of the DPD is to achieve urban edges which maintain or
enhance the character and appearance of the town. The proposed roads would transform
four of the town entrance points and enclose substantial green field areas but this is
neither referred to nor assessed.
f) The case for rapid development of housing and employment land is made without any
evaluation of potential negative economic results. Much of the prosperity of the town is
dependent on it being considered an attractive place to live and visit. Poor air quality,
increased size, thirteen years of disruption caused by construction, increased congestion
and building additional roads that would allow potential tourists to by-pass the town are
among potential downsides that do not seem to have been seriously evaluated.
6 Undeliverable infrastructure mitigation
The KNRR and IRR are listed as over £5M schemes. SLDC is not competent to deliver
them. They have not been approved by the CCC and would, in any case, require
Government funding. There are no time scales for delivery. They are major schemes
requiring four new river bridges and two new railway bridges. The KNRR has been
rejected previously and was expected to cost over £25M several years ago. The price
will not have gone down. If this and the Dowker's Lane, IRR, Southern Relief road etc.
are serious plans it must be assumed that some calculation of costs have been made.
There is good reason to suppose that the figures in this case are so large as to render
delivery improbable or so far distant as not to constitute deliverable mitigation within
the time span considered. If councillors were not given such estimates they were not in a
position to make a realistic decision.
7 Incoherence and Disconnection
Core Strategy 10.1 and10.2 focus on improving public transport and walking and
cycling, park and ride and work travel plans. Road infrastructure improvements are
mentioned once but do not mention Kendal. The criteria include the requirement that the
volume of traffic can be accommodated by the existing road network.
Summary
The Three Transport Studies do not demonstrate that the Land Allocations DPD can be
implemented without serious congestion consequences and they offer no support to the
idea that the proposed infrastructure schemes are likely to be implemented. The
proposals are on a scale that is not reconcilable with the existing capacity of the network
or probable deliverable improvements.
SLDC have not engaged with or taken seriously the problems raised in their Transport
Studies. We submit that this does not constitute good planning and suggest that the DPD
should be rejected as unsound so that SLDC can reconsider.
176. Mr Anthony Cousins (Individual) : 26 Apr 2012 14:44:00
Policy/Site No.
LA1.7 Business and Science Park Sites - M2M-mod KENDAL LAND EAST OF BURTON ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
We would like to object to SLDC's Land Allocations DPD as it applies to Kendal.
There are strong objections that could be made to specific sites but our case focuses on
worsening congestion and air quality in the town. The evidence base SLDC have
accumulated includes three reports on transport and one on air quality. All four note
serious problems and doubts about whether improvements are achievable or deliverable.
Much of this evidence has been disregarded and the policy seems to be to push forward
development in the hope that transport improvements will eventually happen. This 'build
big and hope big' policy is concentrated into only thirteen years. A more realistic and
sequenced approach involving thoroughly researched transport improvements being
introduced in tandem with development over a longer period has not been considered.
We submit that this is not a sound response to evidence or planning.
To summarise our case:
I) The evidence base demonstrates that the town already has significant and worsening
congestion and related air quality problems.
2) It recognises that the proposed developments will greatly worsen these problems.
3) It identifies as mitigation solutions that are inadequate.
4) It adopts road schemes without regard to advice as to their limitations.
5) There are gaps in the evidence base, particularly regarding costing and assessing the
consequences of this new infrastructure.
6) The infrastructure is not deliverable as it is dependent on CCC and government
funding which the consultants have indicated is not likely to be forthcoming because it
represents poor value for money.
7) There is a general incoherence and disconnection between the Core Strategy and
Land Allocations DPD in regard to transport issues.
1 Existing and worsening congestion and air quality problems
a) This is repeatedly acknowledged in the Kendal Transport Assessment, the October
2011 and January 2012 Transport Studies and LA DPD: Even in 2008 it was recognised
that a number of junctions were operating at or over-capacity (KTA p.6). It further
states: It is clear from the analysis that the local highway network within Kendal will
struggle to accommodate the forecast level of traffic in 2025 regardless of whether the
potential LDF developments go ahead (p. 64 8.54)
b) There is already a Kendal Air Quality Management Area.
2 Recognition that development will greatly worsen problems
a) It is clear from the presented results that the volume of traffic forecast to be1
generated by the potential sites for consideration in the LDF Allocations of Land DPD
put forward for assessment would lead to a deterioration in traffic conditions in Kendal,
with significant congestion and delay occurring at a large number of junctions ... it is
clear that the addition of development traffic (particularly in the Shap Road/Appleby
Road corridor), will lead to further increases in queuing and delays. (KTA p.54 8.20)
b) The 2012 study contracts the period under consideration. Nevertheless, the result is
clear: the LDF developments greatly increase congestion across the key junctions.
c) The current proposals in the Allocations document will not be deliverable with
Kendal's existing traffic capacity. The road network is already working at capacity with
the effect that N02 levels in the town centre are close to or above the Objective. (Air
Quality Progress Report)
3 Ineffective mitigation
(a) The LPD Vision for Kendal (p.52) recognises that the town centre transport network
is suffering from significant congestion and that part of the Town Centre is also an Air
Quality Management Area but claims that Cumbria County Council has put forward a
series of mitigating measures to ensure that congestion and air quality impacts are
minimised. We note that the consultants have not calculated air quality results and
expect increased congestion unless all the infrastructure schemes are adopted.
(b) The only mitigation that the KTA could definitely recommend in 2009 was the
provision of two southbound lanes on Milnthorpe Road and signalisation of a junction.
The first is only a reversion to what once existed and both can only be regarded as trivial
changes.
(c) The first of the 'series of mitigation measures' in the 2012 report are junction
improvements. This includes the proposal for traffic on Ann St to give way to Longpool
traffic - again a reversion to a situation that was abandoned not long ago. In view of the
long history of experiments with junction changes in Kendal, with traffic lights added
and subtracted at several locations and even a reversal of flow in parts of the one-way
system, it would be surprising if they could deliver much improvement. In fact, their
tables show the junction improvements to have no effect in the a.m. peak by 2022.
(d) The second mitigation measure consists of Sustainable Transport Improvements. The
policy of modal shift through cycling, walking, and public transport improvements, park
and ride schemes etc. has been in local transport plans for many years and has not
delivered results. There is certainly potential in such schemes but only if a genuine
investment is made in them. The list of schemes in the Improvement Table does not
constitute such an investment. It is noted that Workplace Travel Plans have failed
before. The assumption that what is recommended would produce a 5% reduction in car
trips is highly optimistic.
(e) The third mitigation is a park and ride scheme. This has been considered and rejected
before, is not costed or scheduled and if built and successful is not shown to achieve
more than slight incremental improvements.
4 Adoption of problematic solutions without proper justification
A series of possible road construction schemes are mentioned in the transport studies
They are there because councillors have asked them to be considered.
They are not recommended - the KTA casts doubt on the case for the IRR and KNRR
and the January 2012 study concludes that these infrastructure schemes offer marginal
benefits ... would be expensive and may not be cost-effective solution to congestion. It
also notes that even with them a large proportion of the key junctions would operate
above capacity. This is not a sound basis for recommending these major schemes yet the
DPD treats their presence in the studies as an endorsement.
5 Gaps in evidence base
a) When SLDC adopted the LDF in January the minutes stated: Cumbria County
Council are preparing a Kendal Town Centre Traffic Study which will deliver the
improvements necessary to mitigate the transport and air quality impacts of new
development. This study will form the basis of an infrastructure Delivery Plan.
This confident statement regarding work that has not yet been done is unjustified. The
transport, air quality and infrastructure documents are variously titled. One is an
Assessment, two are Studies, one is a Progress Report and one a Position Statement.
They are not action plans. They assess problems and do not pretend to demonstrate that
alleviating congestion and delivering road schemes is easily attainable.
b) No evidence is provided as to the costs of new infrastructure and there does not
appear to have been any assessment of the costs of land take or cost benefit analysis for
the Inner Relief Road, Dowker's Lane or Southern Link proposals. There are no time
scales offered for fmancing, planning or constructing all these schemes. In fact, the
reports do not pretend to be full assessments of any of these possible major schemes. It
is difficult to understand why SLDC feels able to make decisions without such
assessments.
c) I cannot discover any proper projections or assessments about the impact of the DPD
on air quality. Increased traffic and additional road space in the centre of the town do
not offer a promising recipe for dealing with this problem.
d) The calulations for congestion in the January 2012 study are restricted to 2022. There
seems to be no good reason for this when the DPD runs to 2025. Also the assessment
results do not seem to calculate the effect of Rugby Club and Canal Head schemes
together.
e) The IRR, KNRR, Southern Link and Dowker's Lane proposals have been given no
publicity and seem to appear only in schematic form buried in one map in one appendix.
One of the stated objectives of the DPD is to achieve urban edges which maintain or
enhance the character and appearance of the town. The proposed roads would transform
four of the town entrance points and enclose substantial green field areas but this is
neither referred to nor assessed.
f) The case for rapid development of housing and employment land is made without any
evaluation of potential negative economic results. Much of the prosperity of the town is
dependent on it being considered an attractive place to live and visit. Poor air quality,
increased size, thirteen years of disruption caused by construction, increased congestion
and building additional roads that would allow potential tourists to by-pass the town are
among potential downsides that do not seem to have been seriously evaluated.
6 Undeliverable infrastructure mitigation
The KNRR and IRR are listed as over £5M schemes. SLDC is not competent to deliver
them. They have not been approved by the CCC and would, in any case, require
Government funding. There are no time scales for delivery. They are major schemes
requiring four new river bridges and two new railway bridges. The KNRR has been
rejected previously and was expected to cost over £25M several years ago. The price
will not have gone down. If this and the Dowker's Lane, IRR, Southern Relief road etc.
are serious plans it must be assumed that some calculation of costs have been made.
There is good reason to suppose that the figures in this case are so large as to render
delivery improbable or so far distant as not to constitute deliverable mitigation within
the time span considered. If councillors were not given such estimates they were not in a
position to make a realistic decision.
7 Incoherence and Disconnection
Core Strategy 10.1 and10.2 focus on improving public transport and walking and
cycling, park and ride and work travel plans. Road infrastructure improvements are
mentioned once but do not mention Kendal. The criteria include the requirement that the
volume of traffic can be accommodated by the existing road network.
Summary
The Three Transport Studies do not demonstrate that the Land Allocations DPD can be
implemented without serious congestion consequences and they offer no support to the
idea that the proposed infrastructure schemes are likely to be implemented. The
proposals are on a scale that is not reconcilable with the existing capacity of the network
or probable deliverable improvements.
SLDC have not engaged with or taken seriously the problems raised in their Transport
Studies. We submit that this does not constitute good planning and suggest that the DPD
should be rejected as unsound so that SLDC can reconsider.
177. Mr Anthony Cousins (Individual) : 26 Apr 2012 14:45:00
Policy/Site No.
LA1.8 Local Employment Sites - All Kendal sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
We would like to object to SLDC's Land Allocations DPD as it applies to Kendal.
There are strong objections that could be made to specific sites but our case focuses on
worsening congestion and air quality in the town. The evidence base SLDC have
accumulated includes three reports on transport and one on air quality. All four note
serious problems and doubts about whether improvements are achievable or deliverable.
Much of this evidence has been disregarded and the policy seems to be to push forward
development in the hope that transport improvements will eventually happen. This 'build
big and hope big' policy is concentrated into only thirteen years. A more realistic and
sequenced approach involving thoroughly researched transport improvements being
introduced in tandem with development over a longer period has not been considered.
We submit that this is not a sound response to evidence or planning.
To summarise our case:
I) The evidence base demonstrates that the town already has significant and worsening
congestion and related air quality problems.
2) It recognises that the proposed developments will greatly worsen these problems.
3) It identifies as mitigation solutions that are inadequate.
4) It adopts road schemes without regard to advice as to their limitations.
5) There are gaps in the evidence base, particularly regarding costing and assessing the
consequences of this new infrastructure.
6) The infrastructure is not deliverable as it is dependent on CCC and government
funding which the consultants have indicated is not likely to be forthcoming because it
represents poor value for money.
7) There is a general incoherence and disconnection between the Core Strategy and
Land Allocations DPD in regard to transport issues.
1 Existing and worsening congestion and air quality problems
a) This is repeatedly acknowledged in the Kendal Transport Assessment, the October
2011 and January 2012 Transport Studies and LA DPD: Even in 2008 it was recognised
that a number of junctions were operating at or over-capacity (KTA p.6). It further
states: It is clear from the analysis that the local highway network within Kendal will
struggle to accommodate the forecast level of traffic in 2025 regardless of whether the
potential LDF developments go ahead (p. 64 8.54)
b) There is already a Kendal Air Quality Management Area.
2 Recognition that development will greatly worsen problems
a) It is clear from the presented results that the volume of traffic forecast to be1
generated by the potential sites for consideration in the LDF Allocations of Land DPD
put forward for assessment would lead to a deterioration in traffic conditions in Kendal,
with significant congestion and delay occurring at a large number of junctions ... it is
clear that the addition of development traffic (particularly in the Shap Road/Appleby
Road corridor), will lead to further increases in queuing and delays. (KTA p.54 8.20)
b) The 2012 study contracts the period under consideration. Nevertheless, the result is
clear: the LDF developments greatly increase congestion across the key junctions.
c) The current proposals in the Allocations document will not be deliverable with
Kendal's existing traffic capacity. The road network is already working at capacity with
the effect that N02 levels in the town centre are close to or above the Objective. (Air
Quality Progress Report)
3 Ineffective mitigation
(a) The LPD Vision for Kendal (p.52) recognises that the town centre transport network
is suffering from significant congestion and that part of the Town Centre is also an Air
Quality Management Area but claims that Cumbria County Council has put forward a
series of mitigating measures to ensure that congestion and air quality impacts are
minimised. We note that the consultants have not calculated air quality results and
expect increased congestion unless all the infrastructure schemes are adopted.
(b) The only mitigation that the KTA could definitely recommend in 2009 was the
provision of two southbound lanes on Milnthorpe Road and signalisation of a junction.
The first is only a reversion to what once existed and both can only be regarded as trivial
changes.
(c) The first of the 'series of mitigation measures' in the 2012 report are junction
improvements. This includes the proposal for traffic on Ann St to give way to Longpool
traffic - again a reversion to a situation that was abandoned not long ago. In view of the
long history of experiments with junction changes in Kendal, with traffic lights added
and subtracted at several locations and even a reversal of flow in parts of the one-way
system, it would be surprising if they could deliver much improvement. In fact, their
tables show the junction improvements to have no effect in the a.m. peak by 2022.
(d) The second mitigation measure consists of Sustainable Transport Improvements. The
policy of modal shift through cycling, walking, and public transport improvements, park
and ride schemes etc. has been in local transport plans for many years and has not
delivered results. There is certainly potential in such schemes but only if a genuine
investment is made in them. The list of schemes in the Improvement Table does not
constitute such an investment. It is noted that Workplace Travel Plans have failed
before. The assumption that what is recommended would produce a 5% reduction in car
trips is highly optimistic.
(e) The third mitigation is a park and ride scheme. This has been considered and rejected
before, is not costed or scheduled and if built and successful is not shown to achieve
more than slight incremental improvements.
4 Adoption of problematic solutions without proper justification
A series of possible road construction schemes are mentioned in the transport studies
They are there because councillors have asked them to be considered.
They are not recommended - the KTA casts doubt on the case for the IRR and KNRR
and the January 2012 study concludes that these infrastructure schemes offer marginal
benefits ... would be expensive and may not be cost-effective solution to congestion. It
also notes that even with them a large proportion of the key junctions would operate
above capacity. This is not a sound basis for recommending these major schemes yet the
DPD treats their presence in the studies as an endorsement.
5 Gaps in evidence base
a) When SLDC adopted the LDF in January the minutes stated: Cumbria County
Council are preparing a Kendal Town Centre Traffic Study which will deliver the
improvements necessary to mitigate the transport and air quality impacts of new
development. This study will form the basis of an infrastructure Delivery Plan.
This confident statement regarding work that has not yet been done is unjustified. The
transport, air quality and infrastructure documents are variously titled. One is an
Assessment, two are Studies, one is a Progress Report and one a Position Statement.
They are not action plans. They assess problems and do not pretend to demonstrate that
alleviating congestion and delivering road schemes is easily attainable.
b) No evidence is provided as to the costs of new infrastructure and there does not
appear to have been any assessment of the costs of land take or cost benefit analysis for
the Inner Relief Road, Dowker's Lane or Southern Link proposals. There are no time
scales offered for fmancing, planning or constructing all these schemes. In fact, the
reports do not pretend to be full assessments of any of these possible major schemes. It
is difficult to understand why SLDC feels able to make decisions without such
assessments.
c) I cannot discover any proper projections or assessments about the impact of the DPD
on air quality. Increased traffic and additional road space in the centre of the town do
not offer a promising recipe for dealing with this problem.
d) The calulations for congestion in the January 2012 study are restricted to 2022. There
seems to be no good reason for this when the DPD runs to 2025. Also the assessment
results do not seem to calculate the effect of Rugby Club and Canal Head schemes
together.
e) The IRR, KNRR, Southern Link and Dowker's Lane proposals have been given no
publicity and seem to appear only in schematic form buried in one map in one appendix.
One of the stated objectives of the DPD is to achieve urban edges which maintain or
enhance the character and appearance of the town. The proposed roads would transform
four of the town entrance points and enclose substantial green field areas but this is
neither referred to nor assessed.
f) The case for rapid development of housing and employment land is made without any
evaluation of potential negative economic results. Much of the prosperity of the town is
dependent on it being considered an attractive place to live and visit. Poor air quality,
increased size, thirteen years of disruption caused by construction, increased congestion
and building additional roads that would allow potential tourists to by-pass the town are
among potential downsides that do not seem to have been seriously evaluated.
6 Undeliverable infrastructure mitigation
The KNRR and IRR are listed as over £5M schemes. SLDC is not competent to deliver
them. They have not been approved by the CCC and would, in any case, require
Government funding. There are no time scales for delivery. They are major schemes
requiring four new river bridges and two new railway bridges. The KNRR has been
rejected previously and was expected to cost over £25M several years ago. The price
will not have gone down. If this and the Dowker's Lane, IRR, Southern Relief road etc.
are serious plans it must be assumed that some calculation of costs have been made.
There is good reason to suppose that the figures in this case are so large as to render
delivery improbable or so far distant as not to constitute deliverable mitigation within
the time span considered. If councillors were not given such estimates they were not in a
position to make a realistic decision.
7 Incoherence and Disconnection
Core Strategy 10.1 and10.2 focus on improving public transport and walking and
cycling, park and ride and work travel plans. Road infrastructure improvements are
mentioned once but do not mention Kendal. The criteria include the requirement that the
volume of traffic can be accommodated by the existing road network.
Summary
The Three Transport Studies do not demonstrate that the Land Allocations DPD can be
implemented without serious congestion consequences and they offer no support to the
idea that the proposed infrastructure schemes are likely to be implemented. The
proposals are on a scale that is not reconcilable with the existing capacity of the network
or probable deliverable improvements.
SLDC have not engaged with or taken seriously the problems raised in their Transport
Studies. We submit that this does not constitute good planning and suggest that the DPD
should be rejected as unsound so that SLDC can reconsider.
178. Mr & Mrs Edward Craker (Individual) : 23 Apr 2012 15:01:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - M683sM-mod STORTH LAND S OF QUARRY LANE, STORTH
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
S.L.D.C. LOCAL DEVELOPMENT FRAMEWORK.
OBJECTION TO LAND ALLOCATIONS DEVELOPMENT PLAN
DOCUMENT (DPD) BASED ON THE WAY M683s Mod and EN40-Mod.
HAVE BEEN CONSIDERED.
1. SLDC have used an incremental or piecemeal approach to compare candidate
sites.
For example, for the sites which I am interested in, they have not considered the cost
of highway infrastructure, which will be considerable and probably not sustainable.
They have rejected other sites where highway infrastructure costs would likely be
minimal. (R111 and R 115 would appear to be such sites.)
Thus sites have not been compared on an equal basis, certainly not as far as highway
infrastructure costs are concerned ..
In email correspondence to me, SLDC have themselves said that ideally financial
feasibility for sites M683sMod and EN40-Mod should have been carried out well
before now (late February 2012). They go on to say that could be said about many
sites for one issue or another. They also say that if it (M683sMod and EN40-Mod) is
unfeasible then it should not really be in.
Thus, it is clear by SLDC's own admission that sites have not been compared on an
equal basis.
2. I commented in response to the emerging options consultation in some detail
about the problem of highway infrastructure in relation to M683sM (the
previous reference for the sites now in question).
Please see Attachment C.
In recent correspondence with SLDC I was told that my comments had not
been passed to Cumbria County Council as Highway Authority. It seems that
it was only done when I specifically requested it (late February 2012). This
fundamentally important consultation between SLDC and CCC could have
happened several months earlier.
Thus, SLDC have not carried out consultations with other bodies, namely CCC as
Highway Authority, in a timely manner. At the very least, this has frustrated a proper
consideration of key factors.
Conclusion.
I therefore object to the DPD on the grounds that key factors for sites have been
considered on an incremental and incomplete basis.
This has not allowed a proper consideration of individual sites, nor a fair comparison
between sites.
The comparison of sites, at least in Storth/Sandside and any others where significant
information has not been available, should therefore be repeated with all the
information to hand so that a proper comparison can be made.
Attachment C - objection to M683sM (March 2011)
I object to the proposed allocation on the following grounds :-
• The area is within the Arnside and Silverdale AONB. It should therefore not
be considered for development.
• The only feasible access to the site is from Quarry Lane.
Quarry Lane is not a highway maintainable at the public expense (although for
at least part of its length, it is a public footpath).
A development of 62 houses would need significant highway infrastructure in
itself. It would in fact be a MINOR ACCESS ROAD as defined in Cumbria
Design Guide. However, it could not become an adopted highway as it would only
connect to Quarry Lane which as stated above is not maintainable at the public
expense.
I question the advisability of having 62 dwellings on a private road with minimal
if any chance of adoption.
• Quarry Lane is the only feasible access to the site, and it is not possible for the
geometric standards required by the highway authority, Cumbria County Council,
to be met. These standards are set out in Cumbria Design Guide, First Edition,
December 1996, and I have confirmed with CCC that this is the case and that the
document is still in force.
There are at least three significant deficiencies as follows:-
I. Width of Quarry Lane.
As Quarry Lane is unadopted, CCC have not given it a classification.
However if it were to serve 62 housing units, it would be acting as a MINOR
ACCESS ROAD (which is defined as a road to serve up to 100 dwellings),
and in any case it already serves some commercial development. It is therefore
reasonable to consider it as a MINOR ACCESS ROAD at the least.
A MINOR ACCESS ROAD is required to have a carriageway width of 5.5m
+ two footways of 1.8m. a total width of 9 .I m. Even if only one footway was
acceptable, a total width of 7.3m would be required.
Quarry Lane at the southern end, along the frontage to EN27 and to its
junction with Storth Road is mostly only 5.4m wide "wall to wall" and only
5 .8m wide at its maximum. There are similar deficiencies at the Northern end .
Acquisition of adjoining land to enable widening, even if economically viable,
would be unlikely to be achievable.
In addition, it is questionable whether the requirements for forward visibility
can be met.
Quarry lane is therefore totally inadequate as an access to the site.
2. Junction of Quarry Lane with Storth Road.
Storth Road is classified by CCC as a MAJOR ACCESS ROAD. (A road that
serves about I 00-300 dwellings)
Taking Quarry Lane as a MINOR ACCESS ROAD with more than 30
dwellings, the visibility requirements for its junction with Storth Road are
4.5m x45m.
The current visibility is woefully less than this, and in addition, there are no
footways. This situation could not be brought up to the required standard
without land acquisition, which is unlikely to be achievable, and very
extensive civil engineering works, possibly involving partial rebuilding of an
existing brick arch bridge.
3. Lack of drainage and proper structure to the road.
There is no positive drainage, and no proper structure to the road. Its lack of
width and absence of kerbs results in vehicles "poaching" the verges resulting
in puddling, frost damage and breakdown of the structure of the road
particularly at the edges. Any increase in development and therefore use
would only exacerbate the situation.
As a final general comment regarding geometric highway standards, it is
worth noting that a recent application for one dwelling at Chapel Close, Storth,
SL/2010/0149, was recently refused by SLDC, went to appeal and was
dismissed by the Inspector, partially on highway grounds. Chapel Close is of
similar width to Quarry Lane, and although it has limited forward visibility
because of horizontal alignment deficiencies, vehicle speeds are, and can only
be, much lower than in Quarry Lane. I would argue that one additional
dwelling in Chapel Close represents much less of a potential highway danger
than 62 dwellings accessed off Quarry Lane.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I have had correspondence for some months with SLDC regarding highway access to
the site. Further comments from Cumbria County Council were promised, but they
only came to me the day before the public consultation closed.
The following attachments are relevant-
Attachment C. This is my objection to the LDF made in March 20 II where I
pointed out the impracticality of highway access to the site(s) from
Storth Road.
Attachment D. Highway comments from CCC dated March 2012.
CCC say that the preferred options for access would be via the private road
(presumably they mean from the NE end of Quarry Lane) or through the Travis
Perkins site.
However their wording suggests that access through the TP site would only be
possible ifTP vacated the site.
Is this a realistic possibility?
CCC state they would not adopt Quarry Lane whilst quarry vehicles are still using it.
For how much longer will quarry vehicles be using Quarry Lane?
Would they concede to the suggested development being accessed by a private road
or must it be made up to adoptable standards?
It would have been useful to have been able to have asked these questions of CCC
during the consultation period.
CCC say that an access from "Storth Road would be acceptable in principle if an
acceptable visibility splay could be produced due to the railway bridge. The existing
access appears to have visibility issues caused by the railway bridge - these would
have to be addressed if this access were to be used to serve the site"
I believe it would not be possible to bring the Quarry Lane/Storth Road junction up to
an acceptable geometric standard (to meet the requirements of the Cumbria Design
Guide) at a cost which could be carried by the suggested development.
In addition, Quarry Lane itself would need widening which would further add to the
costs. Also private land would need to be acquired, which may not be possible.
Please see Attachment C.
Also a site visit by the Inspector would be valuable and clearly show the difficulties
of improving this junction to the required standard.
It would be wrong to include these sites if access is unfeasible.
SLDC agree this point. In an email to me in February 2012 they said that an
assessment would have to be undertaken to assess financial feasibility which ideally
should have been done well before now, the sooner it is done the better, and if it is
unfeasible it should not really be in.
Conclusion
To include sites which will ultimately not be capable of development does not serve
the planning process well.
I therefore object to the inclusion of sites M683s Mod and EN40-Mod, for
development for residential or commercial uses, unless it can be shown that access
from the NE end of Quarry Lane, or through the Travis Perkins site is a practicable
Attachment C - objection to M683sM (March 2011)
I object to the proposed allocation on the following grounds :-
• The area is within the Arnside and Silverdale AONB. It should therefore not
be considered for development.
• The only feasible access to the site is from Quarry Lane.
Quarry Lane is not a highway maintainable at the public expense (although for
at least part of its length, it is a public footpath).
A development of 62 houses would need significant highway infrastructure in
itself. It would in fact be a MINOR ACCESS ROAD as defined in Cumbria
Design Guide. However, it could not become an adopted highway as it would only
connect to Quarry Lane which as stated above is not maintainable at the public
expense.
I question the advisability of having 62 dwellings on a private road with minimal
if any chance of adoption.
• Quarry Lane is the only feasible access to the site, and it is not possible for the
geometric standards required by the highway authority, Cumbria County Council,
to be met. These standards are set out in Cumbria Design Guide, First Edition,
December 1996, and I have confirmed with CCC that this is the case and that the
document is still in force.
There are at least three significant deficiencies as follows:-
I. Width of Quarry Lane.
As Quarry Lane is unadopted, CCC have not given it a classification.
However if it were to serve 62 housing units, it would be acting as a MINOR
ACCESS ROAD (which is defined as a road to serve up to 100 dwellings),
and in any case it already serves some commercial development. It is therefore
reasonable to consider it as a MINOR ACCESS ROAD at the least.
A MINOR ACCESS ROAD is required to have a carriageway width of 5.5m
+ two footways of 1.8m. a total width of 9 .I m. Even if only one footway was
acceptable, a total width of 7.3m would be required.
Quarry Lane at the southern end, along the frontage to EN27 and to its
junction with Storth Road is mostly only 5.4m wide "wall to wall" and only
5 .8m wide at its maximum. There are similar deficiencies at the Northern end .
Acquisition of adjoining land to enable widening, even if economically viable,
would be unlikely to be achievable.
In addition, it is questionable whether the requirements for forward visibility
can be met.
Quarry lane is therefore totally inadequate as an access to the site.
2. Junction of Quarry Lane with Storth Road.
Storth Road is classified by CCC as a MAJOR ACCESS ROAD. (A road that
serves about I 00-300 dwellings)
Taking Quarry Lane as a MINOR ACCESS ROAD with more than 30
dwellings, the visibility requirements for its junction with Storth Road are
4.5m x45m.
The current visibility is woefully less than this, and in addition, there are no
footways. This situation could not be brought up to the required standard
without land acquisition, which is unlikely to be achievable, and very
extensive civil engineering works, possibly involving partial rebuilding of an
existing brick arch bridge.
3. Lack of drainage and proper structure to the road.
There is no positive drainage, and no proper structure to the road. Its lack of
width and absence of kerbs results in vehicles "poaching" the verges resulting
in puddling, frost damage and breakdown of the structure of the road
particularly at the edges. Any increase in development and therefore use
would only exacerbate the situation.
As a final general comment regarding geometric highway standards, it is
worth noting that a recent application for one dwelling at Chapel Close, Storth,
SL/2010/0149, was recently refused by SLDC, went to appeal and was
dismissed by the Inspector, partially on highway grounds. Chapel Close is of
similar width to Quarry Lane, and although it has limited forward visibility
because of horizontal alignment deficiencies, vehicle speeds are, and can only
be, much lower than in Quarry Lane. I would argue that one additional
dwelling in Chapel Close represents much less of a potential highway danger
than 62 dwellings accessed off Quarry Lane.
Attachment D
M683sM - Storth
There are three potential accesses to this site- via Quarry Lane (a private road),
via Storth Road and via the existing Travis Perkins site should Travis Perkins vacate
the site in the future. Access via the private road and the Travis Perkins site would
be acceptable in principle and would be the preferred options. However, CCC
would not adopt the private lane whilst quarry vehicles are still using it. The use of
Storth Road would be acceptable in principle if an acceptable visibility splay could
be produced due to the railway bridge. The existing access appears to have
visibility issues caused by the railway bridge- these would have to be addressed if
this access were to be used to serve the site. Until these issues are addressed, it
could only be used as a pedestrian access to the site. There is potential for
pedestrian and cycle access to the site via the existing disused railway path which
runs alongside Quarry Lane.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
I feel i will be able to go into more depth and satisfy myself that i have made my points clearly understood
179. Mr & Mrs Edward Craker (Individual) : 23 Apr 2012 15:08:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.8 Local Employment Allocations - EN40-mod SANDSIDE LAND SOUTH OF QUARRY LANE
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
S.L.D.C. LOCAL DEVELOPMENT FRAMEWORK.
OBJECTION TO LAND ALLOCATIONS DEVELOPMENT PLAN
DOCUMENT (DPD) BASED ON THE WAY M683s Mod and EN40-Mod.
HAVE BEEN CONSIDERED.
1. SLDC have used an incremental or piecemeal approach to compare candidate
sites.
For example, for the sites which I am interested in, they have not considered the cost
of highway infrastructure, which will be considerable and probably not sustainable.
They have rejected other sites where highway infrastructure costs would likely be
minimal. (R111 and R 115 would appear to be such sites.)
Thus sites have not been compared on an equal basis, certainly not as far as highway
infrastructure costs are concerned ..
In email correspondence to me, SLDC have themselves said that ideally financial
feasibility for sites M683sMod and EN40-Mod should have been carried out well
before now (late February 2012). They go on to say that could be said about many
sites for one issue or another. They also say that if it (M683sMod and EN40-Mod) is
unfeasible then it should not really be in.
Thus, it is clear by SLDC's own admission that sites have not been compared on an
equal basis.
2. I commented in response to the emerging options consultation in some detail
about the problem of highway infrastructure in relation to M683sM (the
previous reference for the sites now in question).
Please see Attachment C.
In recent correspondence with SLDC I was told that my comments had not
been passed to Cumbria County Council as Highway Authority. It seems that
it was only done when I specifically requested it (late February 2012). This
fundamentally important consultation between SLDC and CCC could have
happened several months earlier.
Thus, SLDC have not carried out consultations with other bodies, namely CCC as
Highway Authority, in a timely manner. At the very least, this has frustrated a proper
consideration of key factors.
Conclusion.
I therefore object to the DPD on the grounds that key factors for sites have been
considered on an incremental and incomplete basis.
This has not allowed a proper consideration of individual sites, nor a fair comparison
between sites.
The comparison of sites, at least in Storth/Sandside and any others where significant
information has not been available, should therefore be repeated with all the
information to hand so that a proper comparison can be made.
Attachment C - objection to M683sM (March 2011)
I object to the proposed allocation on the following grounds :-
• The area is within the Arnside and Silverdale AONB. It should therefore not
be considered for development.
• The only feasible access to the site is from Quarry Lane.
Quarry Lane is not a highway maintainable at the public expense (although for
at least part of its length, it is a public footpath).
A development of 62 houses would need significant highway infrastructure in
itself. It would in fact be a MINOR ACCESS ROAD as defined in Cumbria
Design Guide. However, it could not become an adopted highway as it would only
connect to Quarry Lane which as stated above is not maintainable at the public
expense.
I question the advisability of having 62 dwellings on a private road with minimal
if any chance of adoption.
• Quarry Lane is the only feasible access to the site, and it is not possible for the
geometric standards required by the highway authority, Cumbria County Council,
to be met. These standards are set out in Cumbria Design Guide, First Edition,
December 1996, and I have confirmed with CCC that this is the case and that the
document is still in force.
There are at least three significant deficiencies as follows:-
I. Width of Quarry Lane.
As Quarry Lane is unadopted, CCC have not given it a classification.
However if it were to serve 62 housing units, it would be acting as a MINOR
ACCESS ROAD (which is defined as a road to serve up to 100 dwellings),
and in any case it already serves some commercial development. It is therefore
reasonable to consider it as a MINOR ACCESS ROAD at the least.
A MINOR ACCESS ROAD is required to have a carriageway width of 5.5m
+ two footways of 1.8m. a total width of 9 .I m. Even if only one footway was
acceptable, a total width of 7.3m would be required.
Quarry Lane at the southern end, along the frontage to EN27 and to its
junction with Storth Road is mostly only 5.4m wide "wall to wall" and only
5 .8m wide at its maximum. There are similar deficiencies at the Northern end .
Acquisition of adjoining land to enable widening, even if economically viable,
would be unlikely to be achievable.
In addition, it is questionable whether the requirements for forward visibility
can be met.
Quarry lane is therefore totally inadequate as an access to the site.
2. Junction of Quarry Lane with Storth Road.
Storth Road is classified by CCC as a MAJOR ACCESS ROAD. (A road that
serves about I 00-300 dwellings)
Taking Quarry Lane as a MINOR ACCESS ROAD with more than 30
dwellings, the visibility requirements for its junction with Storth Road are
4.5m x45m.
The current visibility is woefully less than this, and in addition, there are no
footways. This situation could not be brought up to the required standard
without land acquisition, which is unlikely to be achievable, and very
extensive civil engineering works, possibly involving partial rebuilding of an
existing brick arch bridge.
3. Lack of drainage and proper structure to the road.
There is no positive drainage, and no proper structure to the road. Its lack of
width and absence of kerbs results in vehicles "poaching" the verges resulting
in puddling, frost damage and breakdown of the structure of the road
particularly at the edges. Any increase in development and therefore use
would only exacerbate the situation.
As a final general comment regarding geometric highway standards, it is
worth noting that a recent application for one dwelling at Chapel Close, Storth,
SL/2010/0149, was recently refused by SLDC, went to appeal and was
dismissed by the Inspector, partially on highway grounds. Chapel Close is of
similar width to Quarry Lane, and although it has limited forward visibility
because of horizontal alignment deficiencies, vehicle speeds are, and can only
be, much lower than in Quarry Lane. I would argue that one additional
dwelling in Chapel Close represents much less of a potential highway danger
than 62 dwellings accessed off Quarry Lane.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I have had correspondence for some months with SLDC regarding highway access to
the site. Further comments from Cumbria County Council were promised, but they
only came to me the day before the public consultation closed.
The following attachments are relevant-
Attachment C. This is my objection to the LDF made in March 20 II where I
pointed out the impracticality of highway access to the site(s) from
Storth Road.
Attachment D. Highway comments from CCC dated March 2012.
CCC say that the preferred options for access would be via the private road
(presumably they mean from the NE end of Quarry Lane) or through the Travis
Perkins site.
However their wording suggests that access through the TP site would only be
possible ifTP vacated the site.
Is this a realistic possibility?
CCC state they would not adopt Quarry Lane whilst quarry vehicles are still using it.
For how much longer will quarry vehicles be using Quarry Lane?
Would they concede to the suggested development being accessed by a private road
or must it be made up to adoptable standards?
It would have been useful to have been able to have asked these questions of CCC
during the consultation period.
CCC say that an access from "Storth Road would be acceptable in principle if an
acceptable visibility splay could be produced due to the railway bridge. The existing
access appears to have visibility issues caused by the railway bridge - these would
have to be addressed if this access were to be used to serve the site"
I believe it would not be possible to bring the Quarry Lane/Storth Road junction up to
an acceptable geometric standard (to meet the requirements of the Cumbria Design
Guide) at a cost which could be carried by the suggested development.
In addition, Quarry Lane itself would need widening which would further add to the
costs. Also private land would need to be acquired, which may not be possible.
Please see Attachment C.
Also a site visit by the Inspector would be valuable and clearly show the difficulties
of improving this junction to the required standard.
It would be wrong to include these sites if access is unfeasible.
SLDC agree this point. In an email to me in February 2012 they said that an
assessment would have to be undertaken to assess financial feasibility which ideally
should have been done well before now, the sooner it is done the better, and if it is
unfeasible it should not really be in.
Conclusion
To include sites which will ultimately not be capable of development does not serve
the planning process well.
I therefore object to the inclusion of sites M683s Mod and EN40-Mod, for
development for residential or commercial uses, unless it can be shown that access
from the NE end of Quarry Lane, or through the Travis Perkins site is a practicable
Attachment C - objection to M683sM (March 2011)
I object to the proposed allocation on the following grounds :-
• The area is within the Arnside and Silverdale AONB. It should therefore not
be considered for development.
• The only feasible access to the site is from Quarry Lane.
Quarry Lane is not a highway maintainable at the public expense (although for
at least part of its length, it is a public footpath).
A development of 62 houses would need significant highway infrastructure in
itself. It would in fact be a MINOR ACCESS ROAD as defined in Cumbria
Design Guide. However, it could not become an adopted highway as it would only
connect to Quarry Lane which as stated above is not maintainable at the public
expense.
I question the advisability of having 62 dwellings on a private road with minimal
if any chance of adoption.
• Quarry Lane is the only feasible access to the site, and it is not possible for the
geometric standards required by the highway authority, Cumbria County Council,
to be met. These standards are set out in Cumbria Design Guide, First Edition,
December 1996, and I have confirmed with CCC that this is the case and that the
document is still in force.
There are at least three significant deficiencies as follows:-
I. Width of Quarry Lane.
As Quarry Lane is unadopted, CCC have not given it a classification.
However if it were to serve 62 housing units, it would be acting as a MINOR
ACCESS ROAD (which is defined as a road to serve up to 100 dwellings),
and in any case it already serves some commercial development. It is therefore
reasonable to consider it as a MINOR ACCESS ROAD at the least.
A MINOR ACCESS ROAD is required to have a carriageway width of 5.5m
+ two footways of 1.8m. a total width of 9 .I m. Even if only one footway was
acceptable, a total width of 7.3m would be required.
Quarry Lane at the southern end, along the frontage to EN27 and to its
junction with Storth Road is mostly only 5.4m wide "wall to wall" and only
5 .8m wide at its maximum. There are similar deficiencies at the Northern end .
Acquisition of adjoining land to enable widening, even if economically viable,
would be unlikely to be achievable.
In addition, it is questionable whether the requirements for forward visibility
can be met.
Quarry lane is therefore totally inadequate as an access to the site.
2. Junction of Quarry Lane with Storth Road.
Storth Road is classified by CCC as a MAJOR ACCESS ROAD. (A road that
serves about I 00-300 dwellings)
Taking Quarry Lane as a MINOR ACCESS ROAD with more than 30
dwellings, the visibility requirements for its junction with Storth Road are
4.5m x45m.
The current visibility is woefully less than this, and in addition, there are no
footways. This situation could not be brought up to the required standard
without land acquisition, which is unlikely to be achievable, and very
extensive civil engineering works, possibly involving partial rebuilding of an
existing brick arch bridge.
3. Lack of drainage and proper structure to the road.
There is no positive drainage, and no proper structure to the road. Its lack of
width and absence of kerbs results in vehicles "poaching" the verges resulting
in puddling, frost damage and breakdown of the structure of the road
particularly at the edges. Any increase in development and therefore use
would only exacerbate the situation.
As a final general comment regarding geometric highway standards, it is
worth noting that a recent application for one dwelling at Chapel Close, Storth,
SL/2010/0149, was recently refused by SLDC, went to appeal and was
dismissed by the Inspector, partially on highway grounds. Chapel Close is of
similar width to Quarry Lane, and although it has limited forward visibility
because of horizontal alignment deficiencies, vehicle speeds are, and can only
be, much lower than in Quarry Lane. I would argue that one additional
dwelling in Chapel Close represents much less of a potential highway danger
than 62 dwellings accessed off Quarry Lane.
Attachment D
M683sM - Storth
There are three potential accesses to this site- via Quarry Lane (a private road),
via Storth Road and via the existing Travis Perkins site should Travis Perkins vacate
the site in the future. Access via the private road and the Travis Perkins site would
be acceptable in principle and would be the preferred options. However, CCC
would not adopt the private lane whilst quarry vehicles are still using it. The use of
Storth Road would be acceptable in principle if an acceptable visibility splay could
be produced due to the railway bridge. The existing access appears to have
visibility issues caused by the railway bridge- these would have to be addressed if
this access were to be used to serve the site. Until these issues are addressed, it
could only be used as a pedestrian access to the site. There is potential for
pedestrian and cycle access to the site via the existing disused railway path which
runs alongside Quarry Lane.
180. Dr Roger Crawley (Individual) : 11 Apr 2012 14:48:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.6 Strategic Employment Sites - E4M KENDAL LAND AT SCROGGS WOOD, MILNTHORPE ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
1. Introduction
1.1 I submit the following comments as a coherent critique, rather than as separate statements in the formula preferred by SLDC in its Consultation Response Form, because both sites and issues in land allocation are related subjects and need to be considered in the context of the overall purpose of the South Lakeland Development Framework and its evidence base. Furthermore, these comments and observations on the Land Allocations Emerging Options of the Core Strategy of South Lakeland District Council (notably sites E31M and E4M) augment the succession of statements I have made to the local authority
since 200 I on the expansion of the Kendal urban area to the south of its existing Local Plan Development boundary. My previous statements include comments made in a paper in 2001 (your ref. 333) relating to South Lakeland Local Plan Alteration, September 2000; in May 2008 relating to Core Strategy Preferred Options; and in February 2009 relating to Preferred Options. Although certain of my previous comments were made in the context of PPS12 (2004), which has since been replaced by PPS12: Local Spatial Planning (2008), the planning issues are essentially the same. For example, there is an overriding obligation on Core Strategies 'to produce a vision [my emphasis] for the future of places', and 'to translate this vision into ... land allocations' (PPS12: 2.1), because 'Spatial planning plays a central role in the overall task of place shaping [my emphasis] ... ' (2.3), and 'provides a means of safeguarding the area's
environmental assets ... (2.6).
1.2 The substantive issue of the appropriateness of Kendal's expansion
southwards in the Kent valley, within the overall context of the shape and
setting of the Town, has been neglected, in my view, in deciding the suitability
of land allocation for development in both the Preferred and Emerging Options
planning procedures. Although options for development southwards are listed
in the SLDC Kendal Fact File, notably sites to the south of Helm Lodge (R104),
the Roman Fort at Watercrook (E31 and EN30), Scroggs Wood (E4 and EN37),
Helsington Laithes (RN132 and EN38), and Burton Road (M2M), at no stage
has the obligatory overview been taken of the implications of such expansion in
terms of place shaping and vision. Indeed, it appears from the options listed
and from the emerging choices (E31M, E4M, and M2M), that it is a foregone
conclusion that Kendal will expand its urban area southwards whatever the
consequences to the surrounding environment.
1.3 As I make my comments and observations, it will become apparent that the
options listed and subsequently chosen as emerging have been considered in
isolation, with the emphasis upon an overriding determinant - the percentage
allocation for Kendal to meet Core Strategy employment land demands - than on
an incumbent Core Strategy and Structure Plan responsibility to 'protect' and
'sustain' existing special environments, and to create 'an overall vision which
sets out how the area and the places within it should develop' (PPS 12: 4.1 ). As
a former landscape plarmer, I find it astonishing that the Emerging Options
consultation document, after stating (p.23) that among the 'Key local factors
influencing the location of new development in Kendal are;
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 from
important viewpoints such as Kendal Castle, The Helm, Kendal Fell and Scout
Scar I Brigsteer Road;'
should then proceed to select options E31M and E4M in the Kent valley as sites
for employment development. How can the selection of these two options be
consistent or sound with the following 'Main implications for the DPD' given in
the Sustainability Appraisal Scoping Report: Land Allocations (October 2012):
'Culture and Heritage' (p. 16): 'Land Allocations DPD must take account of
how the location of or type of development proposed on sites could compromise
or provide benefits to heritage, historical, cultural and archaeological features,
buildings, events and environment/settings.'
'Biodiversity and Geodiversity' (p. 17): 'Plans and strategies must not have any
significant negative impact on any sites that are protected by SAC or SPA
designation'.
'Landscape' (p. 18): 'Land allocations DPD must consider how the location and
dimensions, as well as likely development type, of sites could detract from or
improve the landscape and the setting of features and settlements.'
I hope that my comments will show that both E31M and E4M in particular
seriously compromise, and detract from, the features of their landscape,
environment and setting. The Kendal Fact File, in its preliminary assessment of
these options mentions numerous negative impacts and constraints, and the
range of associated mitigation measures. If so much negative evidence and so
much mitigation compromise the choice of these options, why were they made
and permitted to reach this stage, especially E4M which was not considered as a
preferred option. Such potential harm across a spectrum of environmental assets
is contrary to the planning obligations set out in PPS9: Biodiversity and
Geological Conservation 2005; PPS5: Planning for the Historic Environment
2010; and PPS7: Sustainable Development in Rural Areas (2004) under The
Countryside (5-131), 15: 'Planning authorities should continue to ensure that the
quality and character of the wider countryside is protected and, where possible,
enhanced etc.' The points I make below will argue that the Landscape
Character, Heritage Value, Environmental Importance, and Recreational
Significance of the countryside of the Kent valley corridor south of Kendal call
for its protection as open green field space where the spatial planning safeguards
the area's enviromnental assets. Significantly, 'The River Kent Green Corridor'
is already identified under Green Spaces and Open Spaces in Emerging
Options (p. 36).
1.4 During the course of the Core Strategy deliberations much has been made of the
status of Kendal as the Gateway to the Lakes. The majority of visitors to the
Lake District National Park, and to Kendal itself, arrive from the south, whether
by road or rail. The Kent valley countryside lying between Helsington Barrows
and Scout Scar on the west and The Helm on the east creates this gateway
entrance. If the gateway identity of Kendal is to be respected then attention
should be given to how any future development of the town on the south is
likely to affect this identity, especially negatively. This matter has yet to be
seriously discussed in the evidence-based documents. The significance of this
omission will accrue as I draw attention to other shortcomings in respect of
consideration given to the italicised headings listed above.
I. 5 Furthermore, only passing reference (Emerging Options, p. 21) has been given
in the Land Allocation process to the implications of future development to the
proposal for a southern extension to the Lake District National Park, which
is recommended in Lakes to Dales: Landscape Designation Project Consultation
Document (Natural England, 2009, pp. 16-17). The extension covers the Lyth
Valley as far as the outskirts of Levens, the karst ground of Helsington Barrows
adjacent to Scout Scar, and the Brigsteer environs south to Sizergh Fell and
Sizergh Castle. The recommendation notes that, 'The Helsington Barrows and
Sizergh Fell ridge is a key feature into the area and forms part of the southern
gateway to the Lakes.' It also emphasises that, 'This area is very sensitive to
further urban, road or large-scale development, which would adversely affect its
landscape quality and tranquillity.' Once designated, as is likely, this extension
will bring the national park boundary closer to Kendal, and give proper
recognition to the quality of the landscape on the western side of the Kent valley
corridor.
2. Landscape Character
2 .1. The landscape character of the Kent valley corridor is based on Technical Paper
5: Landscape Character of the Cumbria and Lake District Joint Structure Plan
2001-16, and on Policy E36 of the Structure Plan: Landscapes of County
Importance. In my previous comments (27/05/08 attached) on the Core
Strategy Preferred Options, I emphasised the distinctiveness of the convergence
of a number of landscape types ( 5 in all) in the corridor between The Helm and
Scout Scar (2008 / p4) and noted that an earlier study had recognised this fact1
This convergence accentuates the landscape importance of the corridor and adds
to the significance of the Drumlin Field Landscape of County Importance
designation that had previously been recognised in the Kent valley (see below).
I also emphasised the significance of what is currently a very definitive arboreal
edge to the southern margins of the town in the vicinity of the River Kent (2008
/ p.4, and enclosed map), an edge which includes the linear belt of Scroggs
Wood from the river to the A6. The gateway to Kendal, therefore, is not only
impressive for a range of landscape types set closely together but also for the
fact that development has not breached the definitive edge to the town on the
south and intruded into the visual field of the gateway countryside.
2.2. SLDC will know that E31M has a controversial history as a site for employment
development. It was rejected as such by a planning inspector in 1988 in his
review of objections to a South Westmorland Local Plan2 When it was
included again in the South Lakeland Local Plan 2006 in 2000, it was eventually
rejected after consultation, a review by another inspector, and a site visit by the
Planning Committee. In May 2001, a 'Revised Plan showing that the
employment allocation has been removed, the development boundary realigned
and the area designated as County Landscape' was issued3 It is an example of
unsoundness in planning practice that this site should resurface again after being
considered inappropriate in the past. How 'could [E31M] be considered a
logical extension of Natland Road Employment Area [Clarks]', (Emerging
Options, p. 34), with such a history of refusal? And why should the nearby area
(R49 and R536), currently designated as employment land within the
development plan boundary, and which has remained derelict for over ten years,
continue to be unused when it lies between two functioning employment zones?
My comments of 27/05/2008 refer in detail to the reasons why development at
E31M contravenes many of the clauses in Core Strategy policies CS7.4, CS8.1,
CS8.2, and CS8.6, reasons that continue to prevail and which are reiterated here.
2.3. With respect to site E4M, the South Lakeland Housing and Emplovment Land
Search recognises (p. 56) that 'Scroggs Wood forms a strong boundary to the
town and [that] development to the south of this would be highly visible in the
wider landscape and should, therefore, not be permitted.' A similar emphatic
conclusion was reached in 1988 by a planning inspector, who also recognised
the importance of Scroggs Wood as part of the definitive edge to the town;
'Open farmland and Scroggs Wood form an ideal visnal edge to the built up area
made all the more important by the open views afforded from the bypass'4 The
emergence of the huge site at E4M (17.9Ha) as a potential location for
employment shows that the advice of the land search specialists and a previous
planning inspector have been disregarded; that the Core Strategy policies cited
above in respect of E31M have not been applied with due soundness to E4M by
SLDC; that SDLC has decided to breach the definitive southern edge of the
town and extend the urban area into what the Structure Plan and the Land
Search recognise is countryside of special importance; and that the concept of a
gateway approach to Kendal is considered irrelevant by SLDC to the future
identity of the town. And yet, in the SLDC Kendal Fact File (p. 117), with
respect to the rejection of site EN38, it is unreservedlyrecognised:
'However, the key constraint is the likely impact of development for landscape
character and it is considered [that] strategic employment uses in this location
would significantly harm the landscape [my emphasis]. In view of this, it is
considered [that] any development in this location would have [a] significant
adverse impact on existing views from adjacent surrounding area and alter
the existing character of the area by introducing an urban landscape
incongruous to the rural landscape setting [my emphasis]. In this context it is
considered an inappropriate location for new development.'
Incredibly, the adjacent site at E4M across the A6, to which the same arguments
apply, is not dismissed as an 'inappropriate location'. This is manifestly
illogical and is certainly not sound planning practice. And only a biased or
incompetent assessment, such as that made by the NWDA Study, could
conclude, 'that with an appropriate landscape scheme this site [E4M] has the
capacity to absorb development without being unduly prominent within the
landscape' (p.l19 Kendal Fact File). The site will always be prominent in the
Kent valley when seen from The Helm, and in the gateway approaches to
Kendal, as the planning inspector noted in 1988. This example of inconsistency
displays a total lack of soundness of the kind I cited in my previous
communication (2008, pp.4-5).
2.4 With respect to CS7.4, development at E4M will not be 'of a scale in keeping
with its surroundings'; and will be 'detrimental to the character [and]
appearance of the landscape'. Any detailed and thorough assessment of the
prominence in the landscape of the E4M site, which consists of two large
pasture fields elevated above the flood plain of the river and which slope
upwards to the A6, should reveal that the emergence of this option is a major
visual and physical assault on the character and heritage assets of the local
landscape. Any development would sit in the landscape on elevated ground
between two high shapely drumlins that currently attract the eye in views from
the east - the one at Prizet and the one above Helsington Laithes close to the
town's urban area. The two fields are prominently visible from the whole length
of The Helm ridge, and development here would intrude starkly into views from
this ridge across the Kent valley towards the limestone scenery of Helsington
Barrows and the distant Lakeland peaks. From the Friends of the Lake District
gate mid-way along the ridge-wall until the trig-point at The Helm summit, the
views across the site are in a direct line with the distant prospect of the Langdale
Pikes. Any development would intrude markedly into the middle-distance
prospect ofHelsington Barrows, which has considerable visual integrity, notably
for its curved outline as it falls away to the Brigsteer Road. From the Helm trigpoint,
the large and impressive meander that encloses the site of the Roman Fort
at Watercrook, a Scheduled Ancient Monument (SAM), would be dominated by
any development across the river against Scroggs Wood. This is clearly an
example where a heritage site - perhaps because it does not have a visible ruin -
has been dismissed with only an apologetic 'need to carefully consider' its
relevance to the case in hand Kendal Fact File (p. 121 ), even though the
meander is a dominant feature in the landscape. The two fields adjacent to
Scroggs Wood are also visible from the east at Oxenholme railway station, and
from trains in their approach to, and departure from, the station.
2.5 A proper assessment of the visual impact in the Kent valley landscape of future
development at E4M should have noted how dramatic an intrusion this site
would be because of its size, its very open location, and particularly its raised
position above the flood plain. Such a large intrusive development would
seriously reduce, not maintain or enhance, the quality of the surrounding
landscape and its assets, and show that SLDC has contempt for its own 'key
local factor' in selecting sites quoted above (p.l ). It should also be obvious to
the local planning authority that the two large fields of E4M are visible from the
northern edge of the National Trust property on Scout Scar (the open larch
wood), and from various points along the higher stretches of Helsington
Barrows all the way to the Mushroom. The site at E31M is equally as
prominent from this westerly direction. Both sites are visible in the approach to
Kendal via the Brigsteer Road, the A591, and the A6, and if developed would
make a mockery of the concept of a gateway entrance to the town which is,
currently, a dramatic feature of its identity on its southern margin. The Core
Strategy obligation to safeguard environmental assets should attach greater
importance to a margin which consists of features that are of County Landscape
Importance (the Drumlin Field), of potential national park status (Helsington
Barrows), of heritage significance (the Roman Fort and the Sattnry), of
European Special Area of Conservation status (the River Kent), and which
includes an historical thoroughfare (the Lancaster Canal) that is programmed to
be restored as yet another impressive approach to Kendal from the south.
3. Heritage Value
3.1 The site of the Roman Fort, ALAVANA, at Watercrook (SD5190) is an English
Heritage Scheduled Ancient Monument (SAM), a heritage asset which derives
significance not only from its strategic location within a large meander of the
River Kent but also from associated field features and its setting within the
valley, notably its visual relationship with the distinctive eminence of The Helm.
To date, the position of the fort's civil settlement has not been located in the
landscape. However, a local specialist in Roman history believes that the flat
ground lying to the south of Watercrook lane between the footpath to Hawes
Bridge and the river was the fort's training area, and that the nearby low mound
(topped with a hedge), which has a symmetrical indentation, supported the
temple platform from where both training instructions were given and allegiance
to the emperor practiced. 5 A cemetery for the fort has yet to be located but may
exist between the Sattnry and the river. The fort and its associated field features
are one of the Roman heritage sites visited by students from John Moores
University, Liverpool, and from local schools, in field excursions. It is possible
that the Sattnry (SD51559029), a conical knoll , as well as the temple mound,
may have served as look-out points for the fort for views down-river. Similarly,
in Roman times there may have been a strategic connection between the fort and
The Helm. ALA V ANA, which probably housed a legionary cohort, may have
been associated with a Roman road running from Low Borrow Bridge (near
Tebay), the site of another fort, over Whinfell via Patton Bridge and Mealbank
to Kendal. The Roman associations of the fields at Watercrook between the
River Kent and the old course of the Lancaster Canal, therefore, render this
whole area a landscape of heritage and archaeological significance, a degree of
importance that has been given cursory attention in the selection of emerging
sites for development, especially in respect of Core Strategy policy CS8.6.
3.2 The inclusion of emerging options E31M and E4M in such close proximity to
the Roman fort and its heritage setting7 is, in my view, contrary to the planning
stipulations in PPS5: Planning for the Historic Environment 2010, and the Core
Strategy policies CS8. 6 and CS8.2. The evidence base of the significance of the
whole area is lacking in detail. The Local Development Framework has not
given adequate consideration to 'the character of the [historic] environment and
[the] area's sense of place' (Policy HE3 of PPS5). Development at both sites
will detract from the heritage setting and harm its sense of place.
3.3 The absence of few visual signs of the Lancaster Canal at Watercrook has also
caused the historical importance of this missing waterway to be overlooked. As
I pointed out in my statement of 2008 (p. 3), development at E31M should not
be considered in isolation when Area Action Plans for the restoration of the
canal are in the offing (Paper 2001 and Comments 2008, p. 4). PPS12: 5.5
emphasises that, 'Area Action Plans can assist in producing a consensus as to
the right strategy for an area and how it might be implemented' (a consideration
that is being compromised by the selection of E31M). If, as seems likely in due
course, the canal is restored to Canal Head in Kendal, eventually providing a
waterway entrance into the town from the south, the heritage value of the
section of landscape from Natland to Watercrook will acquire even greater
significance.
3.4 Currently, there are views of E4M and E31M from the canal towpath between
Crow Park Bridge (over the canal) near Natland and Watercrook lane. Not far
from Crow Park towards Kendal, any development on the elevated ground at
E31M will be discerned directly ahead against the poplar/cypress screen that
presently conceals Clarks' warehouses (with Kendal Castle clearly visible in the
background), and is likely to interfere with views of the castle. From this
direction, the castle is a prominent feature at the moment in the approach from
the south whether walking or (as in the future) by boat along a restored canal. In
the progress to the next canal bridge at Natland Hall, the site at E4M can be seen
against the backdrop of the Helsington Laithes drumlin. Once passed this
bridge, the canal is elevated on an embankment and E4M is starkly visible
against the drumlin with Scroggs Woods seen as the present edge to the town.
This gateway approach to Kendal is very impressive, with views ofHelsington
Barrows to the west, The Helm to the east, and Benson Knott on Hay Fell to the
north above Kendal.
3.5 Conversely, development on the elevated ground at E31M will obliterate the
impressive views towards Prizet over the Drumlin Field County Landscape for
walkers and future canal users leaving the town, a landscape that is rightly
described as 'peaceful' at the moment by the Kendal Fact File (p. 123). It
should be obvious that the course of the old Lancaster Canal between
Watercrook and Crow Park is in a landscape 'sensitive to change' and, as such,
should be 'protected' (PPS12: 5.4) in anticipation of its future Area Action Plan.
4. Environmental Importance
4.1 The River Kent SSSI, (along its entire length including its tributaries), is
protected under the European Habitats Directive (1979) as a Special Area of
Conservation (SAC), and under the European Birds Directive (1992) as a
Special Protection Area (SPA), the raison d'etre for these designations being
biodiversity. The peacefulness of the stretch of the river at Watercrook is very
evident from the clear calling of oyster catchers (Haematopus ostralegus) and
curlews (Numenius arquata) in spring and summer, both of which birds breed
locally, among numerous other birds for which the Kent is important. The
interaction between the riverine habitats and the openness of the flood-plain
landscape make this part of the Kent valley valuable, not only for breeding
biodiversity and for bird migration (notably waxwing I Bombycilla garrulous),
but also for its peaceful sense of place, a condition that is currently rural,
scenically and ecologically. Development on this south side of Kendal will
inevitably detract from this condition and harm both the scenery and the
ecology. Erosion of green-field sites by urban sprawl, especially those where
biodiversity is recognised to exist, should not be countenanced lightly- if it is to
be countenance at all within such close proximity to a SAC and SPA. Even
Policy E35 of the Structure Plan: 'Areas and Features of nature conservation
interests other than those of national and international importance' recognises
the significance of 'Landscape features of major importance for fauna and flora,
which are essential for migration dispersal and genetic exchange'. Scroggs
Wood would fall into this category without its international status, for it contains
Spindle (Euonymus europaeus), an ancient woodland arboreal indicator species,
as well as being an integral feature for bird migration in the Kent valley. Its
specific inclusion within the River Kent SAC and SPA enhances the wood's
importance to such a high level that even with the requisite buffer zone of 100
metres called for in the legislation, the intrusion of noise, lighting, and increased
human activity associated with employment development at the huge E4M site
would seriously undermine the existing environmental integrity of the wood,
and the quietude of the nearby weir. Mitigation measures will not alleviate the
harm that development will cause, and will not be consistent with Core Strategy
policy CS8.4.
4.2. Neither the ecological, nor the structural, significance of arboreal edges at
Watercrook seems to have been adequately appreciated in the consideration of
E4M and E31M as sites for development. Once arboreal edges are established,
as is the case with the belt of trees extending from Helm Lodge (mature beech),
down Watercrook lane between its ancient hedge and Clarks warehouse
(poplar/cypress screen), along the steeply incised river-bank (oak/ash), and then
across the river against the treatment works with its planted screen and the bankside
trees (willow/alder/ash/sycamore), linking with the riverine section of
Scroggs Wood, the part they play in local ecology is often under-valued. For
example, the old beech trees opposite Clarks, and the broadleaves beside the
river Kent between Natland Mill Beck and Watercrook Lane, may be the bat
roost referred to by SLDC in Core Strategy: Preferred Options (Table 3, p. 134).
E31M and its associated utilities will affect this habitat. 8 Currently, these
arboreal edges, as habitats, are open on the south to the ecology of the Kendal
gateway entrance countryside, an openness that is scenically as well as
ecologically critical, and also of recreational importance to the local community.
The significance of these open edges against impressive countryside has not
received the close attention it deserves, as in the case of Core Strategy policies
CS8.1 and CS8.2.
4.3 The importance of Ancient Woodland and of Networks of Natural Habitats is
stressed in PPS9: Biodiversity and Geological Conservation 2005. Together, the
habitats of Scroggs Wood, the River Kent and its flood plain, the course of the
Lancaster Canal, and the arboreal edges make the Watercrook area one of
considerable ecological importance. This importance, as I have emphasised, has
not been given the attention called for by PPS9 in the selection of options E31M
and E4M. The European Habitats Directive, under which the River Kent SAC
and SPA are protected, attaches particular emphasis on the need to safeguard the
integrity of such areas. It is incumbent on both national and local authorities to
ensure that an 'appropriate assessment' is made to determine that development
will not have a negative impact upon this 'integrity'. The European legislation
has consistently set the bar for 'appropriate assessment' extremely high - that is
to say, very small impacts can damage the 'integrity' of European sites of
conservation. I contend that E4M, in particular, will cause deterioration in
'integrity' if allowed to proceed.
5. Recreational Significance
5.1 Both sides of the River Kent flood plain at Watercrook are enjoyed by the
public. The river is a favourite fishing ground for the Kent Anglers Association.
The vicinity of the weir is a popular location for families to engage with the
bird-life of the river, to experience the vicissitudes of its flow, and to enjoy the
impressive surrounding scenery. Kayak clubs and trainee groups use this
location regularly as a launch-place for trips downstream to Hawes Bridge.
Development at E4M will transform completely the current open character of
this experience. Footpaths follow either bank of the river, into and out of
Kendal, the weir location and the lay-by on Watercrook lane being popular
parking places for walkers. Development at E4M and at E31M will completely
diminish the sense of detachment from the Kendal urban area currently enjoyed
by these recreationists. This is enjoyment of the local landscape and its heritage
assets at the micro-level which, when linked with that at the macro-level of The
Helm, Scout Scar and Helsington Barrows, and the gateway entrance, points up
the varied importance of the Watercrook countryside and that of the Kent valley
corridor to the community of Kendal and its visiting tourists. Both E4M and
E31M will be visible to walkers from the riverside and canal footpaths, as well
as from the higher paths that descend into the valley from Briggs House Farm
and High House, the Brigsteer Road, and Helsington Barrows. I contend that
the omission of a proper assessment of this recreational significance is another
example of a lack of sound planning in the selection of emerging options E31M
and E4M. Perhaps SLDC has forgotten the commitment it made in the Local
Plan of2006 (Section 1.54):
'The Local Planning Authority recognises the crucial importance of building
substantial green "lungs" and open spaces into a strategic plan for the area. It
would protect a broad swathe of the riverside at Watercrook and the site of
the old Roman fort and expect these areas to be dedicated for public use
[my emphases].'
Core Strategy policy CS8.1 shonld allow for this earlier commitment to be
respected.
6. Conclusion
6.1 As in the Local Plan of 2006, Policy CS8.2 of the Core Strategy addresses the
importance of Green Gaps, especially where they: 'Contribute to maintaining a
settlement's identity, landscape setting and character; Comprise predominantly
open land maintaining an "open" aspect; [and] Where possible afford
recreational and biodiversity opportunities.' The existing countryside of the
Kent valley corridor due south of Kendal contributes to both the identities and
settings of the town and of Natland. The wider Kent valley corridor itself, as I
have discussed, affords both recreational and biodiversity opportunities. Once
the green aspect and the heritage assets of this countryside are encroached upon,
and the southern edge of Kendal breached, where will development end? What
is the planning vision for this currently 'open space', 'green-field space', and
'green corridor'? These two vital questions have yet to be addressed in the Core
Strategy, an omission that is not only serious but unsound in planning terms. As
I have emphasised, PPS12 places critical importance upon the concept of vision
in spatial planning and Core Strategies. PPS12: 4.14 also recognises that, 'Core
Strategies represent [or should if the evidence base is sound and credible] a
considerable body of work and are intended to endure and give a degree of
certainty to communities and investors'. Without a clear and justifiable vision
for the future of the countryside on the edge of south Kendal 'certainty' is, as
yet, far from being clarified. The Inspector's Report 2010 of the Core Strategy
emphasises the special need for a 'Clarification of [the] site appraisal process
and [the] criteria for employment land selection'9 In particular, the Inspector's
Report notes the 'reservations [which exist] about the possible landscape impact
of new development of scale on the setting of the town .... '. 10 In my view, these
reservations remain valid for the Watercrook area.
6.3 The emerging options E4M and E31M give cause for concern because they
have tacitly been given clearance as acceptable, despite the glaring
inconsistency in the arguments that select the former when EN38 is considered
'an inappropriate location for new development', and the lengthy history of
refusal for the latter. It should be understood and stated by SLDC in its Core
Strategy Land Allocations that these two employment sites set a precedent for
expansion of the Kendal urban area on the south of its existing development
plan boundary, a precedent that has profound planning implications for the
future place-shaping and identity of the town, as well as the integrity of the
'The River Kent Green Corridor'.
6.3 It has come to my notice that Environmental Impact Assessments have not yet
been carried out for any of the emerging options. My comments should have
argued successfully that both E4M and E31M are inappropriate locations for
new development. If these options progress any further, both should come
within The Town and Country Planning (Environmental Impact Assessment)
Regulations 1999 (currently under revision) and will require the completion of
an environmental statement. When complete, I am sure that the statements will,
in each case, justifY and uphold the comments I have made here.
6.4 Lastly, as the derelict brown-field site on Natland Road, bordered by the River
Kent and Natland Mill Beck, reveals, certain unused land already zoned for
employment functions remains vacant. There is no reference in the Core
Strategy evidence-based documents to a recent survey of the number, size and
location of vacant units in the existing industrial and business estates in Kendal.
My occasional visits to these estates, even before the current economic
downturn, made it obvious to me that a considerable number of units are unused.
This factor should have been taken into account in determining: a) the current
employment capacity; b) the current spare employment capacity; and c) the
demand for futnre employment capacity. This information should be critical to
any planning decisions about where to locate future employment development.
With respect to the evidence base for employment land needs, the Inspector's
Report 2010 notes that, 'The tension between evidence and policy intent is
regrettable'. 12
6.4 It is a prerequisite of Local Development Framework proposals that when land
allocations have been confirmed they will be scrutinised by a planning
inspector. Now that E4M and E31M have been selected (2012) as sites for
futnre development, I am sure that an inspector will be severely critical of the
planning judgements and the evidence base that has allowed these two sites to
be included as emerging options. I hope that the failures in Soundness which I
have identified in each case will provide sufficient grounds for their exclusion
from the Land Allocations DPD.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
To provide further information if necessary
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
181. Dr Roger Crawley (Individual) : 11 Apr 2012 14:52:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.8 Local Employment Allocations - E31M KENDAL LAND SOUTH OF K SHOES, NATLAND ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
1. Introduction
1.1 I submit the following comments as a coherent critique, rather than as separate statements in the formula preferred by SLDC in its Consultation Response Form, because both sites and issues in land allocation are related subjects and need to be considered in the context of the overall purpose of the South Lakeland Development Framework and its evidence base. Furthermore, these comments and observations on the Land Allocations Emerging Options of the Core Strategy of South Lakeland District Council (notably sites E31M and E4M) augment the succession of statements I have made to the local authority
since 200 I on the expansion of the Kendal urban area to the south of its existing Local Plan Development boundary. My previous statements include comments made in a paper in 2001 (your ref. 333) relating to South Lakeland Local Plan Alteration, September 2000; in May 2008 relating to Core Strategy Preferred Options; and in February 2009 relating to Preferred Options. Although certain of my previous comments were made in the context of PPS12 (2004), which has since been replaced by PPS12: Local Spatial Planning (2008), the planning issues are essentially the same. For example, there is an overriding obligation on Core Strategies 'to produce a vision [my emphasis] for the future of places', and 'to translate this vision into ... land allocations' (PPS12: 2.1), because 'Spatial planning plays a central role in the overall task of place shaping [my emphasis] ... ' (2.3), and 'provides a means of safeguarding the area's
environmental assets ... (2.6).
1.2 The substantive issue of the appropriateness of Kendal's expansion
southwards in the Kent valley, within the overall context of the shape and
setting of the Town, has been neglected, in my view, in deciding the suitability
of land allocation for development in both the Preferred and Emerging Options
planning procedures. Although options for development southwards are listed
in the SLDC Kendal Fact File, notably sites to the south of Helm Lodge (R104),
the Roman Fort at Watercrook (E31 and EN30), Scroggs Wood (E4 and EN37),
Helsington Laithes (RN132 and EN38), and Burton Road (M2M), at no stage
has the obligatory overview been taken of the implications of such expansion in
terms of place shaping and vision. Indeed, it appears from the options listed
and from the emerging choices (E31M, E4M, and M2M), that it is a foregone
conclusion that Kendal will expand its urban area southwards whatever the
consequences to the surrounding environment.
1.3 As I make my comments and observations, it will become apparent that the
options listed and subsequently chosen as emerging have been considered in
isolation, with the emphasis upon an overriding determinant - the percentage
allocation for Kendal to meet Core Strategy employment land demands - than on
an incumbent Core Strategy and Structure Plan responsibility to 'protect' and
'sustain' existing special environments, and to create 'an overall vision which
sets out how the area and the places within it should develop' (PPS 12: 4.1 ). As
a former landscape plarmer, I find it astonishing that the Emerging Options
consultation document, after stating (p.23) that among the 'Key local factors
influencing the location of new development in Kendal are;
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 from
important viewpoints such as Kendal Castle, The Helm, Kendal Fell and Scout
Scar I Brigsteer Road;'
should then proceed to select options E31M and E4M in the Kent valley as sites
for employment development. How can the selection of these two options be
consistent or sound with the following 'Main implications for the DPD' given in
the Sustainability Appraisal Scoping Report: Land Allocations (October 2012):
'Culture and Heritage' (p. 16): 'Land Allocations DPD must take account of
how the location of or type of development proposed on sites could compromise
or provide benefits to heritage, historical, cultural and archaeological features,
buildings, events and environment/settings.'
'Biodiversity and Geodiversity' (p. 17): 'Plans and strategies must not have any
significant negative impact on any sites that are protected by SAC or SPA
designation'.
'Landscape' (p. 18): 'Land allocations DPD must consider how the location and
dimensions, as well as likely development type, of sites could detract from or
improve the landscape and the setting of features and settlements.'
I hope that my comments will show that both E31M and E4M in particular
seriously compromise, and detract from, the features of their landscape,
environment and setting. The Kendal Fact File, in its preliminary assessment of
these options mentions numerous negative impacts and constraints, and the
range of associated mitigation measures. If so much negative evidence and so
much mitigation compromise the choice of these options, why were they made
and permitted to reach this stage, especially E4M which was not considered as a
preferred option. Such potential harm across a spectrum of environmental assets
is contrary to the planning obligations set out in PPS9: Biodiversity and
Geological Conservation 2005; PPS5: Planning for the Historic Environment
2010; and PPS7: Sustainable Development in Rural Areas (2004) under The
Countryside (5-131), 15: 'Planning authorities should continue to ensure that the
quality and character of the wider countryside is protected and, where possible,
enhanced etc.' The points I make below will argue that the Landscape
Character, Heritage Value, Environmental Importance, and Recreational
Significance of the countryside of the Kent valley corridor south of Kendal call
for its protection as open green field space where the spatial planning safeguards
the area's enviromnental assets. Significantly, 'The River Kent Green Corridor'
is already identified under Green Spaces and Open Spaces in Emerging
Options (p. 36).
1.4 During the course of the Core Strategy deliberations much has been made of the
status of Kendal as the Gateway to the Lakes. The majority of visitors to the
Lake District National Park, and to Kendal itself, arrive from the south, whether
by road or rail. The Kent valley countryside lying between Helsington Barrows
and Scout Scar on the west and The Helm on the east creates this gateway
entrance. If the gateway identity of Kendal is to be respected then attention
should be given to how any future development of the town on the south is
likely to affect this identity, especially negatively. This matter has yet to be
seriously discussed in the evidence-based documents. The significance of this
omission will accrue as I draw attention to other shortcomings in respect of
consideration given to the italicised headings listed above.
I. 5 Furthermore, only passing reference (Emerging Options, p. 21) has been given
in the Land Allocation process to the implications of future development to the
proposal for a southern extension to the Lake District National Park, which
is recommended in Lakes to Dales: Landscape Designation Project Consultation
Document (Natural England, 2009, pp. 16-17). The extension covers the Lyth
Valley as far as the outskirts of Levens, the karst ground of Helsington Barrows
adjacent to Scout Scar, and the Brigsteer environs south to Sizergh Fell and
Sizergh Castle. The recommendation notes that, 'The Helsington Barrows and
Sizergh Fell ridge is a key feature into the area and forms part of the southern
gateway to the Lakes.' It also emphasises that, 'This area is very sensitive to
further urban, road or large-scale development, which would adversely affect its
landscape quality and tranquillity.' Once designated, as is likely, this extension
will bring the national park boundary closer to Kendal, and give proper
recognition to the quality of the landscape on the western side of the Kent valley
corridor.
2. Landscape Character
2 .1. The landscape character of the Kent valley corridor is based on Technical Paper
5: Landscape Character of the Cumbria and Lake District Joint Structure Plan
2001-16, and on Policy E36 of the Structure Plan: Landscapes of County
Importance. In my previous comments (27/05/08 attached) on the Core
Strategy Preferred Options, I emphasised the distinctiveness of the convergence
of a number of landscape types ( 5 in all) in the corridor between The Helm and
Scout Scar (2008 / p4) and noted that an earlier study had recognised this fact1
This convergence accentuates the landscape importance of the corridor and adds
to the significance of the Drumlin Field Landscape of County Importance
designation that had previously been recognised in the Kent valley (see below).
I also emphasised the significance of what is currently a very definitive arboreal
edge to the southern margins of the town in the vicinity of the River Kent (2008
/ p.4, and enclosed map), an edge which includes the linear belt of Scroggs
Wood from the river to the A6. The gateway to Kendal, therefore, is not only
impressive for a range of landscape types set closely together but also for the
fact that development has not breached the definitive edge to the town on the
south and intruded into the visual field of the gateway countryside.
2.2. SLDC will know that E31M has a controversial history as a site for employment
development. It was rejected as such by a planning inspector in 1988 in his
review of objections to a South Westmorland Local Plan2 When it was
included again in the South Lakeland Local Plan 2006 in 2000, it was eventually
rejected after consultation, a review by another inspector, and a site visit by the
Planning Committee. In May 2001, a 'Revised Plan showing that the
employment allocation has been removed, the development boundary realigned
and the area designated as County Landscape' was issued3 It is an example of
unsoundness in planning practice that this site should resurface again after being
considered inappropriate in the past. How 'could [E31M] be considered a
logical extension of Natland Road Employment Area [Clarks]', (Emerging
Options, p. 34), with such a history of refusal? And why should the nearby area
(R49 and R536), currently designated as employment land within the
development plan boundary, and which has remained derelict for over ten years,
continue to be unused when it lies between two functioning employment zones?
My comments of 27/05/2008 refer in detail to the reasons why development at
E31M contravenes many of the clauses in Core Strategy policies CS7.4, CS8.1,
CS8.2, and CS8.6, reasons that continue to prevail and which are reiterated here.
2.3. With respect to site E4M, the South Lakeland Housing and Emplovment Land
Search recognises (p. 56) that 'Scroggs Wood forms a strong boundary to the
town and [that] development to the south of this would be highly visible in the
wider landscape and should, therefore, not be permitted.' A similar emphatic
conclusion was reached in 1988 by a planning inspector, who also recognised
the importance of Scroggs Wood as part of the definitive edge to the town;
'Open farmland and Scroggs Wood form an ideal visnal edge to the built up area
made all the more important by the open views afforded from the bypass'4 The
emergence of the huge site at E4M (17.9Ha) as a potential location for
employment shows that the advice of the land search specialists and a previous
planning inspector have been disregarded; that the Core Strategy policies cited
above in respect of E31M have not been applied with due soundness to E4M by
SLDC; that SDLC has decided to breach the definitive southern edge of the
town and extend the urban area into what the Structure Plan and the Land
Search recognise is countryside of special importance; and that the concept of a
gateway approach to Kendal is considered irrelevant by SLDC to the future
identity of the town. And yet, in the SLDC Kendal Fact File (p. 117), with
respect to the rejection of site EN38, it is unreservedlyrecognised:
'However, the key constraint is the likely impact of development for landscape
character and it is considered [that] strategic employment uses in this location
would significantly harm the landscape [my emphasis]. In view of this, it is
considered [that] any development in this location would have [a] significant
adverse impact on existing views from adjacent surrounding area and alter
the existing character of the area by introducing an urban landscape
incongruous to the rural landscape setting [my emphasis]. In this context it is
considered an inappropriate location for new development.'
Incredibly, the adjacent site at E4M across the A6, to which the same arguments
apply, is not dismissed as an 'inappropriate location'. This is manifestly
illogical and is certainly not sound planning practice. And only a biased or
incompetent assessment, such as that made by the NWDA Study, could
conclude, 'that with an appropriate landscape scheme this site [E4M] has the
capacity to absorb development without being unduly prominent within the
landscape' (p.l19 Kendal Fact File). The site will always be prominent in the
Kent valley when seen from The Helm, and in the gateway approaches to
Kendal, as the planning inspector noted in 1988. This example of inconsistency
displays a total lack of soundness of the kind I cited in my previous
communication (2008, pp.4-5).
2.4 With respect to CS7.4, development at E4M will not be 'of a scale in keeping
with its surroundings'; and will be 'detrimental to the character [and]
appearance of the landscape'. Any detailed and thorough assessment of the
prominence in the landscape of the E4M site, which consists of two large
pasture fields elevated above the flood plain of the river and which slope
upwards to the A6, should reveal that the emergence of this option is a major
visual and physical assault on the character and heritage assets of the local
landscape. Any development would sit in the landscape on elevated ground
between two high shapely drumlins that currently attract the eye in views from
the east - the one at Prizet and the one above Helsington Laithes close to the
town's urban area. The two fields are prominently visible from the whole length
of The Helm ridge, and development here would intrude starkly into views from
this ridge across the Kent valley towards the limestone scenery of Helsington
Barrows and the distant Lakeland peaks. From the Friends of the Lake District
gate mid-way along the ridge-wall until the trig-point at The Helm summit, the
views across the site are in a direct line with the distant prospect of the Langdale
Pikes. Any development would intrude markedly into the middle-distance
prospect ofHelsington Barrows, which has considerable visual integrity, notably
for its curved outline as it falls away to the Brigsteer Road. From the Helm trigpoint,
the large and impressive meander that encloses the site of the Roman Fort
at Watercrook, a Scheduled Ancient Monument (SAM), would be dominated by
any development across the river against Scroggs Wood. This is clearly an
example where a heritage site - perhaps because it does not have a visible ruin -
has been dismissed with only an apologetic 'need to carefully consider' its
relevance to the case in hand Kendal Fact File (p. 121 ), even though the
meander is a dominant feature in the landscape. The two fields adjacent to
Scroggs Wood are also visible from the east at Oxenholme railway station, and
from trains in their approach to, and departure from, the station.
2.5 A proper assessment of the visual impact in the Kent valley landscape of future
development at E4M should have noted how dramatic an intrusion this site
would be because of its size, its very open location, and particularly its raised
position above the flood plain. Such a large intrusive development would
seriously reduce, not maintain or enhance, the quality of the surrounding
landscape and its assets, and show that SLDC has contempt for its own 'key
local factor' in selecting sites quoted above (p.l ). It should also be obvious to
the local planning authority that the two large fields of E4M are visible from the
northern edge of the National Trust property on Scout Scar (the open larch
wood), and from various points along the higher stretches of Helsington
Barrows all the way to the Mushroom. The site at E31M is equally as
prominent from this westerly direction. Both sites are visible in the approach to
Kendal via the Brigsteer Road, the A591, and the A6, and if developed would
make a mockery of the concept of a gateway entrance to the town which is,
currently, a dramatic feature of its identity on its southern margin. The Core
Strategy obligation to safeguard environmental assets should attach greater
importance to a margin which consists of features that are of County Landscape
Importance (the Drumlin Field), of potential national park status (Helsington
Barrows), of heritage significance (the Roman Fort and the Sattnry), of
European Special Area of Conservation status (the River Kent), and which
includes an historical thoroughfare (the Lancaster Canal) that is programmed to
be restored as yet another impressive approach to Kendal from the south.
3. Heritage Value
3.1 The site of the Roman Fort, ALAVANA, at Watercrook (SD5190) is an English
Heritage Scheduled Ancient Monument (SAM), a heritage asset which derives
significance not only from its strategic location within a large meander of the
River Kent but also from associated field features and its setting within the
valley, notably its visual relationship with the distinctive eminence of The Helm.
To date, the position of the fort's civil settlement has not been located in the
landscape. However, a local specialist in Roman history believes that the flat
ground lying to the south of Watercrook lane between the footpath to Hawes
Bridge and the river was the fort's training area, and that the nearby low mound
(topped with a hedge), which has a symmetrical indentation, supported the
temple platform from where both training instructions were given and allegiance
to the emperor practiced. 5 A cemetery for the fort has yet to be located but may
exist between the Sattnry and the river. The fort and its associated field features
are one of the Roman heritage sites visited by students from John Moores
University, Liverpool, and from local schools, in field excursions. It is possible
that the Sattnry (SD51559029), a conical knoll , as well as the temple mound,
may have served as look-out points for the fort for views down-river. Similarly,
in Roman times there may have been a strategic connection between the fort and
The Helm. ALA V ANA, which probably housed a legionary cohort, may have
been associated with a Roman road running from Low Borrow Bridge (near
Tebay), the site of another fort, over Whinfell via Patton Bridge and Mealbank
to Kendal. The Roman associations of the fields at Watercrook between the
River Kent and the old course of the Lancaster Canal, therefore, render this
whole area a landscape of heritage and archaeological significance, a degree of
importance that has been given cursory attention in the selection of emerging
sites for development, especially in respect of Core Strategy policy CS8.6.
3.2 The inclusion of emerging options E31M and E4M in such close proximity to
the Roman fort and its heritage setting7 is, in my view, contrary to the planning
stipulations in PPS5: Planning for the Historic Environment 2010, and the Core
Strategy policies CS8. 6 and CS8.2. The evidence base of the significance of the
whole area is lacking in detail. The Local Development Framework has not
given adequate consideration to 'the character of the [historic] environment and
[the] area's sense of place' (Policy HE3 of PPS5). Development at both sites
will detract from the heritage setting and harm its sense of place.
3.3 The absence of few visual signs of the Lancaster Canal at Watercrook has also
caused the historical importance of this missing waterway to be overlooked. As
I pointed out in my statement of 2008 (p. 3), development at E31M should not
be considered in isolation when Area Action Plans for the restoration of the
canal are in the offing (Paper 2001 and Comments 2008, p. 4). PPS12: 5.5
emphasises that, 'Area Action Plans can assist in producing a consensus as to
the right strategy for an area and how it might be implemented' (a consideration
that is being compromised by the selection of E31M). If, as seems likely in due
course, the canal is restored to Canal Head in Kendal, eventually providing a
waterway entrance into the town from the south, the heritage value of the
section of landscape from Natland to Watercrook will acquire even greater
significance.
3.4 Currently, there are views of E4M and E31M from the canal towpath between
Crow Park Bridge (over the canal) near Natland and Watercrook lane. Not far
from Crow Park towards Kendal, any development on the elevated ground at
E31M will be discerned directly ahead against the poplar/cypress screen that
presently conceals Clarks' warehouses (with Kendal Castle clearly visible in the
background), and is likely to interfere with views of the castle. From this
direction, the castle is a prominent feature at the moment in the approach from
the south whether walking or (as in the future) by boat along a restored canal. In
the progress to the next canal bridge at Natland Hall, the site at E4M can be seen
against the backdrop of the Helsington Laithes drumlin. Once passed this
bridge, the canal is elevated on an embankment and E4M is starkly visible
against the drumlin with Scroggs Woods seen as the present edge to the town.
This gateway approach to Kendal is very impressive, with views ofHelsington
Barrows to the west, The Helm to the east, and Benson Knott on Hay Fell to the
north above Kendal.
3.5 Conversely, development on the elevated ground at E31M will obliterate the
impressive views towards Prizet over the Drumlin Field County Landscape for
walkers and future canal users leaving the town, a landscape that is rightly
described as 'peaceful' at the moment by the Kendal Fact File (p. 123). It
should be obvious that the course of the old Lancaster Canal between
Watercrook and Crow Park is in a landscape 'sensitive to change' and, as such,
should be 'protected' (PPS12: 5.4) in anticipation of its future Area Action Plan.
4. Environmental Importance
4.1 The River Kent SSSI, (along its entire length including its tributaries), is
protected under the European Habitats Directive (1979) as a Special Area of
Conservation (SAC), and under the European Birds Directive (1992) as a
Special Protection Area (SPA), the raison d'etre for these designations being
biodiversity. The peacefulness of the stretch of the river at Watercrook is very
evident from the clear calling of oyster catchers (Haematopus ostralegus) and
curlews (Numenius arquata) in spring and summer, both of which birds breed
locally, among numerous other birds for which the Kent is important. The
interaction between the riverine habitats and the openness of the flood-plain
landscape make this part of the Kent valley valuable, not only for breeding
biodiversity and for bird migration (notably waxwing I Bombycilla garrulous),
but also for its peaceful sense of place, a condition that is currently rural,
scenically and ecologically. Development on this south side of Kendal will
inevitably detract from this condition and harm both the scenery and the
ecology. Erosion of green-field sites by urban sprawl, especially those where
biodiversity is recognised to exist, should not be countenanced lightly- if it is to
be countenance at all within such close proximity to a SAC and SPA. Even
Policy E35 of the Structure Plan: 'Areas and Features of nature conservation
interests other than those of national and international importance' recognises
the significance of 'Landscape features of major importance for fauna and flora,
which are essential for migration dispersal and genetic exchange'. Scroggs
Wood would fall into this category without its international status, for it contains
Spindle (Euonymus europaeus), an ancient woodland arboreal indicator species,
as well as being an integral feature for bird migration in the Kent valley. Its
specific inclusion within the River Kent SAC and SPA enhances the wood's
importance to such a high level that even with the requisite buffer zone of 100
metres called for in the legislation, the intrusion of noise, lighting, and increased
human activity associated with employment development at the huge E4M site
would seriously undermine the existing environmental integrity of the wood,
and the quietude of the nearby weir. Mitigation measures will not alleviate the
harm that development will cause, and will not be consistent with Core Strategy
policy CS8.4.
4.2. Neither the ecological, nor the structural, significance of arboreal edges at
Watercrook seems to have been adequately appreciated in the consideration of
E4M and E31M as sites for development. Once arboreal edges are established,
as is the case with the belt of trees extending from Helm Lodge (mature beech),
down Watercrook lane between its ancient hedge and Clarks warehouse
(poplar/cypress screen), along the steeply incised river-bank (oak/ash), and then
across the river against the treatment works with its planted screen and the bankside
trees (willow/alder/ash/sycamore), linking with the riverine section of
Scroggs Wood, the part they play in local ecology is often under-valued. For
example, the old beech trees opposite Clarks, and the broadleaves beside the
river Kent between Natland Mill Beck and Watercrook Lane, may be the bat
roost referred to by SLDC in Core Strategy: Preferred Options (Table 3, p. 134).
E31M and its associated utilities will affect this habitat. 8 Currently, these
arboreal edges, as habitats, are open on the south to the ecology of the Kendal
gateway entrance countryside, an openness that is scenically as well as
ecologically critical, and also of recreational importance to the local community.
The significance of these open edges against impressive countryside has not
received the close attention it deserves, as in the case of Core Strategy policies
CS8.1 and CS8.2.
4.3 The importance of Ancient Woodland and of Networks of Natural Habitats is
stressed in PPS9: Biodiversity and Geological Conservation 2005. Together, the
habitats of Scroggs Wood, the River Kent and its flood plain, the course of the
Lancaster Canal, and the arboreal edges make the Watercrook area one of
considerable ecological importance. This importance, as I have emphasised, has
not been given the attention called for by PPS9 in the selection of options E31M
and E4M. The European Habitats Directive, under which the River Kent SAC
and SPA are protected, attaches particular emphasis on the need to safeguard the
integrity of such areas. It is incumbent on both national and local authorities to
ensure that an 'appropriate assessment' is made to determine that development
will not have a negative impact upon this 'integrity'. The European legislation
has consistently set the bar for 'appropriate assessment' extremely high - that is
to say, very small impacts can damage the 'integrity' of European sites of
conservation. I contend that E4M, in particular, will cause deterioration in
'integrity' if allowed to proceed.
5. Recreational Significance
5.1 Both sides of the River Kent flood plain at Watercrook are enjoyed by the
public. The river is a favourite fishing ground for the Kent Anglers Association.
The vicinity of the weir is a popular location for families to engage with the
bird-life of the river, to experience the vicissitudes of its flow, and to enjoy the
impressive surrounding scenery. Kayak clubs and trainee groups use this
location regularly as a launch-place for trips downstream to Hawes Bridge.
Development at E4M will transform completely the current open character of
this experience. Footpaths follow either bank of the river, into and out of
Kendal, the weir location and the lay-by on Watercrook lane being popular
parking places for walkers. Development at E4M and at E31M will completely
diminish the sense of detachment from the Kendal urban area currently enjoyed
by these recreationists. This is enjoyment of the local landscape and its heritage
assets at the micro-level which, when linked with that at the macro-level of The
Helm, Scout Scar and Helsington Barrows, and the gateway entrance, points up
the varied importance of the Watercrook countryside and that of the Kent valley
corridor to the community of Kendal and its visiting tourists. Both E4M and
E31M will be visible to walkers from the riverside and canal footpaths, as well
as from the higher paths that descend into the valley from Briggs House Farm
and High House, the Brigsteer Road, and Helsington Barrows. I contend that
the omission of a proper assessment of this recreational significance is another
example of a lack of sound planning in the selection of emerging options E31M
and E4M. Perhaps SLDC has forgotten the commitment it made in the Local
Plan of2006 (Section 1.54):
'The Local Planning Authority recognises the crucial importance of building
substantial green "lungs" and open spaces into a strategic plan for the area. It
would protect a broad swathe of the riverside at Watercrook and the site of
the old Roman fort and expect these areas to be dedicated for public use
[my emphases].'
Core Strategy policy CS8.1 shonld allow for this earlier commitment to be
respected.
6. Conclusion
6.1 As in the Local Plan of 2006, Policy CS8.2 of the Core Strategy addresses the
importance of Green Gaps, especially where they: 'Contribute to maintaining a
settlement's identity, landscape setting and character; Comprise predominantly
open land maintaining an "open" aspect; [and] Where possible afford
recreational and biodiversity opportunities.' The existing countryside of the
Kent valley corridor due south of Kendal contributes to both the identities and
settings of the town and of Natland. The wider Kent valley corridor itself, as I
have discussed, affords both recreational and biodiversity opportunities. Once
the green aspect and the heritage assets of this countryside are encroached upon,
and the southern edge of Kendal breached, where will development end? What
is the planning vision for this currently 'open space', 'green-field space', and
'green corridor'? These two vital questions have yet to be addressed in the Core
Strategy, an omission that is not only serious but unsound in planning terms. As
I have emphasised, PPS12 places critical importance upon the concept of vision
in spatial planning and Core Strategies. PPS12: 4.14 also recognises that, 'Core
Strategies represent [or should if the evidence base is sound and credible] a
considerable body of work and are intended to endure and give a degree of
certainty to communities and investors'. Without a clear and justifiable vision
for the future of the countryside on the edge of south Kendal 'certainty' is, as
yet, far from being clarified. The Inspector's Report 2010 of the Core Strategy
emphasises the special need for a 'Clarification of [the] site appraisal process
and [the] criteria for employment land selection'9 In particular, the Inspector's
Report notes the 'reservations [which exist] about the possible landscape impact
of new development of scale on the setting of the town .... '. 10 In my view, these
reservations remain valid for the Watercrook area.
6.3 The emerging options E4M and E31M give cause for concern because they
have tacitly been given clearance as acceptable, despite the glaring
inconsistency in the arguments that select the former when EN38 is considered
'an inappropriate location for new development', and the lengthy history of
refusal for the latter. It should be understood and stated by SLDC in its Core
Strategy Land Allocations that these two employment sites set a precedent for
expansion of the Kendal urban area on the south of its existing development
plan boundary, a precedent that has profound planning implications for the
future place-shaping and identity of the town, as well as the integrity of the
'The River Kent Green Corridor'.
6.3 It has come to my notice that Environmental Impact Assessments have not yet
been carried out for any of the emerging options. My comments should have
argued successfully that both E4M and E31M are inappropriate locations for
new development. If these options progress any further, both should come
within The Town and Country Planning (Environmental Impact Assessment)
Regulations 1999 (currently under revision) and will require the completion of
an environmental statement. When complete, I am sure that the statements will,
in each case, justifY and uphold the comments I have made here.
6.4 Lastly, as the derelict brown-field site on Natland Road, bordered by the River
Kent and Natland Mill Beck, reveals, certain unused land already zoned for
employment functions remains vacant. There is no reference in the Core
Strategy evidence-based documents to a recent survey of the number, size and
location of vacant units in the existing industrial and business estates in Kendal.
My occasional visits to these estates, even before the current economic
downturn, made it obvious to me that a considerable number of units are unused.
This factor should have been taken into account in determining: a) the current
employment capacity; b) the current spare employment capacity; and c) the
demand for futnre employment capacity. This information should be critical to
any planning decisions about where to locate future employment development.
With respect to the evidence base for employment land needs, the Inspector's
Report 2010 notes that, 'The tension between evidence and policy intent is
regrettable'. 12
6.4 It is a prerequisite of Local Development Framework proposals that when land
allocations have been confirmed they will be scrutinised by a planning
inspector. Now that E4M and E31M have been selected (2012) as sites for
futnre development, I am sure that an inspector will be severely critical of the
planning judgements and the evidence base that has allowed these two sites to
be included as emerging options. I hope that the failures in Soundness which I
have identified in each case will provide sufficient grounds for their exclusion
from the Land Allocations DPD.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
To provide further information if necessary
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
182. Mr and Mrs V Curwen (Individual) : 24 Apr 2012 16:43:00
Policy/Site No.
LA1.3 Housing Allocations - R76M BURTON-in-KENDAL EAST OF HUTTON CLOSE
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I wish to record my objections to the proposed LDF for Burton.
The government White Paper stating that Burton is not sustainable still applies i.e. The village amenities are insufficient, lack of car parks and local schools already full.
Land REF R76M (behind Church Bank)
The reasons this site was refused planning have not changed since it was turned down on appeal in July 2006.
1) The vehicle access to this site is totally unsuitable i.e. part of the access road is unfinished
2) There is no safe pedestrian access to the village, wheel-chairs or parents with prams would find there is no suitable pavements. The bridleway from Vicarage Lane does not lead onto this site.
3) The public viewpoint paid for in part by public collection and erected by the Parish Council on Slape Lane for the benefit of all, will become irrelevant because some views indicated will be obliterated by any development.
183. Mr John Daffern (Individual) : 19 Apr 2012 10:08:00
Policy/Site No.
LA1.3 Housing Allocations - All Grange-over-Sands sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I am opposed to the development plans for South Lakeland. I would say a resounding "no" to any green field development. Particularly in Grange over Sands the plan would mean a huge percentage increase in population, on top of the large amount of building already seen over the past few years.
It appears that the Government has made a blanket order for so many new homes in all parts of the country. If this is so then the order should be thrown back.
There are other ways to settle any housing problem... For example, substantially reduce the great number of empty properties, including second homes, by Government legislation, an unpopular but necessary move.
184. Mr John Daffern (Individual) : 10 May 2012 12:48:00
Policy/Site No.
LA3.1 Mixed Use Allocation at Berners Pool, Grange-over-Sands
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I am opposed to the development plans for South Lakeland. I would say a resounding "no" to any green field development. Particularly in Grange over Sands the plan would mean a huge percentage increase in population, on top of the large amount of building already seen over the past few years.
It appears that the Government has made a blanket order for so many new homes in all parts of the country. If this is so then the order should be thrown back.
There are other ways to settle any housing problem... For example, substantially reduce the great number of empty properties, including second homes, by Government legislation, an unpopular but necessary move.
185. Mr John Daffern (Individual) : 10 May 2012 12:52:00
Policy/Site No.
LA3.2 Mixed Use Allocation at Land South of Allithwaite Road, Kent's Bank, Grange-over-Sands
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I am opposed to the development plans for South Lakeland. I would say a resounding "no" to any green field development. Particularly in Grange over Sands the plan would mean a huge percentage increase in population, on top of the large amount of building already seen over the past few years.
It appears that the Government has made a blanket order for so many new homes in all parts of the country. If this is so then the order should be thrown back.
There are other ways to settle any housing problem... For example, substantially reduce the great number of empty properties, including second homes, by Government legislation, an unpopular but necessary move.
186. Mr John Daffern (Individual) : 10 May 2012 13:10:00
Policy/Site No.
LA3.3 Mixed Use Allocation at Guide's Lot, Grange-over-Sands
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I am opposed to the development plans for South Lakeland. I would say a resounding "no" to any green field development. Particularly in Grange over Sands the plan would mean a huge percentage increase in population, on top of the large amount of building already seen over the past few years.
It appears that the Government has made a blanket order for so many new homes in all parts of the country. If this is so then the order should be thrown back.
There are other ways to settle any housing problem... For example, substantially reduce the great number of empty properties, including second homes, by Government legislation, an unpopular but necessary move.
187. Mr Richard Daly (Individual) : 21 Mar 2012 20:50:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - M683sM-mod STORTH LAND S OF QUARRY LANE, STORTH
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
1.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
I was pleased to see that the document recognises the special and protected status of the parishes of Arnside and Beetham, as part of the Arnside / Silverdale AONB; and it rightly recognises that this area therefore cannot make a pro rata contribution to the housing needs of the District as a whole.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
With regard to the proposed site for housing in Storth (M683sM-mod on the plan) it would be wrong for a greenfield site in a protected area to be built on for housing. Since there are few jobs in the village, most of this housing would accommodate people who work outside the parish.
The site is also detached from the main body of housing in the village, and would form a rather isolated enclave. Although physically close to Dallam Drive, it is entirely separated from it by the former railway cutting, with its thick screen of trees.
If this site is developed for housing – despite the above points – it would be essential that access is gained to it from the north, and not via the junction of Storth Road and Quarry Lane, which has poor visibility and speeding traffic (despite the nominal 20mph restriction, which many drivers ignore). Routing traffic via Storth Road would also increase traffic at the dangerous junction between Storth Road and the B5282.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
188. Mr Alan Davies (Individual) : 2 Mar 2012 17:35:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - RN213-mod BRIGSTEER LAND OPPOSITE THE WHEATSHEAF
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
This site is wrongly identified above as RN214. It is actually RN213, and it is RN213 on which I am commenting.
1) Brigsteer was not included in SLDC's original development plan, and RN213 was only added because it was "volunteered" by the CLT, a small unelected group, some of whose members are also Parish Councillors. The Parish Council declined to test public opinion on the proposed development, so a poll was carried out by local residents, and the findings were presented at a public meeting attended by officials of SLDC. This showed a large majority opposed to the development, as recorded in your "Brigsteer Fact File".
2) The "Brigsteer Fact File" also records many factual reasons why this development is not desirable.
3) Brigsteer has no employment opportunities and no infrastructure, so there is no need for any additional housing.
In spite of all the above, the DPD continues to recommend development of RN213 even though this flies in the face of the findings of the "Brigsteer Fact File". In my opinion this fails the test of soundness, ie it is not justified and it is not effective.
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
I do not support the SLDC Land Allocations DPD
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
189. Ms Patricia Davies (Individual) : 7 Apr 2012 17:53:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - R103M-mod KENDAL STAINBANK GREEN
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The DPD as it stands does not recognise the intrinsic character and beauty of the countryside around the town. The Land at Stainbank Green (R103m), in its current state as farmland contributes greatly to maintaining Kendal’s identity, landscape setting and character. Building on this site and blocking the view from the dual carriageway across the town to the fells will have a profound detrimental effect on the environment and will damage the tourist industry both for the town and the Lakes.
There is a need to beware of speculative building when there are unsold new properties such as the KVillage development. In addition there are town centre sites that are more suitable for affordable housing development, eg the Kendal Bowman site. Use of such sites would be more sustainable as travel to amenties would be greatly reduced in comparison to an out of town development.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
190. Ms Patricia Davies (Individual) : 7 Apr 2012 18:11:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.6 Strategic Employment Sites - E4M KENDAL LAND AT SCROGGS WOOD, MILNTHORPE ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I do not consider the current strategy to be the most appropriate in relation to site E4M. The need for more economic growth must be balanced against the value of rural, economic and social nature of any development. The DPD as it stands does not recognise the intrinsic character and beauty of the countryside around the town. The Land at Scroggs Wood (E4m) in its current state as farmland contributes greatly to maintaining Kendal’s identity, landscape setting and character. Building on this site at the approach to the town will have a profound detrimental effect on the environment and will damage the tourist industry both for the town and the Lakes. Development of this land will also disturb wildlife both in Scrogg’s Wood and on the river, both of which are havens and corridors for wildlife including otters, deer and kingfishers. The lower part of the site is part of a flood plain and should be maintained as such. It should not be necessary to recite the reasons why in a debate about planning!
191. Ms Patricia Davies (Individual) : 7 Apr 2012 18:27:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA2.7 Land at Stainbank Green
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I do not consider the current strategy to be the most appropriate in relation to site LA2.7 ( Stonecross but also referred to as Stainbank Green ) The DPD as it stands does not recognise the intrinsic character and beauty of the countryside around the town. The land at Stonecross LA2.7, in its current state as farmland contributes greatly to maintaining Kendal’s identity, landscape setting and character. Building on this site and blocking the view from the dual carriageway across the town to the fells will have a profound detrimental effect on the environment and will damage the tourist industry both for the town and the Lakes.
There is a need to beware of speculative building when there are unsold new properties such as the KVillage development. In addition there are town centre sites that are more suitable for affordable housing development, eg the Kendal Bowman site. Use of such sites would be more sustainable as travel to amenties would be greatly reduced in comparison to an out of town development.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
192. Ms Patricia Davies (Individual) : 16 Apr 2012 14:48:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
0.0 Whole Document
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The SLDC website, in particular the Local Development Framework Consultation part of the site is very difficult to navigate; it is not easy to find the response section; the referencing between the documents, the maps and the 'Policy/Site No'drop down box is very poor and confusing.
All these points create difficulties for anyone wishing to respond to the DPD and therefore disenfranchises considerable sections of the community.
It is for this reason that I think that the DPD is not legally compliant.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
193. Ms Patricia Davies (Individual) : 18 May 2012 15:15:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
1.9
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The SLDC website, in particular the Local Development Framework Consultation part of the site is very difficult to navigate; it is not easy to find the response section; the referencing between the documents, the maps and the 'Policy/Site No'drop down box is very poor and confusing.
All these points create difficulties for anyone wishing to respond to the DPD and therefore disenfranchises considerable sections of the community.
It is for this reason that I think that the DPD is not legally compliant.
194. Mr and Mrs J Day (Individual) : 26 Apr 2012 14:09:00
Paragraph No.
1.9
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not been prepared in accordance with the Town & County Planning Regulations 2004 (as amended)
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I wish to submit that the above plan does not satisfy the Test of Legal
Compliance on the grounds that
1. The involvement of the community has not been taken into account
because the views of Kendal town Council have
not been taken on board or been given due consideration and an
appropriate response and explanation for such given.
2. The recommendations made do not comply with the Town and country
Planning Regulations in respect of road width,number of emergency
vehicle access points etc in respect of Rl21M .Furthermore,the
planners had not carried out any site visits to this site until well
after it was included in the document.
3. Regard to national policy in respect of flood prevention etc has been
disregarded as the views of the Environment agency have not been
fully sought with regard to flooding into the Stock Beck scheme in
Kendal and the capacity of the relief reservoir in respect of development
at Rl21M
In general it is my opinion the majority of the proposals have been
made to fit a predetermined model and that the views expressed by the
vast
majority have not been taken into consideration. The hefty tome that
contains this strategy is almost beyond comprehension and my view is that
the elected
representatives who voted on it (only two thirds) probably understand
it as little as I did.I have therefore consented to specialist
representative speaking on my behalf at the hearing
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I wish to submit that the above plan does not satisfy the Test of Legal
Compliance on the grounds that
1. The involvement of the community has not been taken into account
because the views of Kendal town Council have
not been taken on board or been given due consideration and an
appropriate response and explanation for such given.
2. The recommendations made do not comply with the Town and country
Planning Regulations in respect of road width, number of emergency
vehicle access points etc in respect of Rl21M .Furthermore, the
planners had not carried out any site visits to this site until well
after it was included in the document.
3. Regard to national policy in respect of flood prevention etc has been
disregarded as the views of the Environment agency have not been
fully sought with regard to flooding into the Stock Beck scheme in
Kendal and the capacity of the relief reservoir in respect of development
at Rl21M
In general it is my opinion the majority of the proposals have been
made to fit a predetermined model and that the views expressed by the
vast majority have not been taken into consideration. The hefty tome that
contains this strategy is almost beyond comprehension and my view is that
the elected representatives who voted on it (only two thirds) probably understand
it as little as I did. I have therefore consented to specialist
representative speaking on my behalf at the hearing
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
195. Mr and Mrs J Day (Individual) : 26 Apr 2012 14:11:00
Paragraph No.
1.10
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not been prepared in accordance with the Town & County Planning Regulations 2004 (as amended)
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I wish to submit that the above plan does not satisfy the Test of Legal
Compliance on the grounds that
1. The involvement of the community has not been taken into account
because the views of Kendal town Council have
not been taken on board or been given due consideration and an
appropriate response and explanation for such given.
2. The recommendations made do not comply with the Town and country
Planning Regulations in respect of road width, number of emergency
vehicle access points etc in respect of Rl21M .Furthermore, the
planners had not carried out any site visits to this site until well
after it was included in the document.
3. Regard to national policy in respect of flood prevention etc has been
disregarded as the views of the Environment agency have not been
fully sought with regard to flooding into the Stock Beck scheme in
Kendal and the capacity of the relief reservoir in respect of development
at Rl21M
In general it is my opinion the majority of the proposals have been
made to fit a predetermined model and that the views expressed by the
vast majority have not been taken into consideration. The hefty tome that
contains this strategy is almost beyond comprehension and my view is that
the elected representatives who voted on it (only two thirds) probably understand
it as little as I did. I have therefore consented to specialist
representative speaking on my behalf at the hearing
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I wish to submit that the above plan does not satisfy the Test of Legal
Compliance on the grounds that
1. The involvement of the community has not been taken into account
because the views of Kendal town Council have
not been taken on board or been given due consideration and an
appropriate response and explanation for such given.
2. The recommendations made do not comply with the Town and country
Planning Regulations in respect of road width, number of emergency
vehicle access points etc in respect of Rl21M .Furthermore, the
planners had not carried out any site visits to this site until well
after it was included in the document.
3. Regard to national policy in respect of flood prevention etc has been
disregarded as the views of the Environment agency have not been
fully sought with regard to flooding into the Stock Beck scheme in
Kendal and the capacity of the relief reservoir in respect of development
at Rl21M
In general it is my opinion the majority of the proposals have been
made to fit a predetermined model and that the views expressed by the
vast majority have not been taken into consideration. The hefty tome that
contains this strategy is almost beyond comprehension and my view is that
the elected representatives who voted on it (only two thirds) probably understand
it as little as I did. I have therefore consented to specialist
representative speaking on my behalf at the hearing
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
196. Mr and Mrs J Day (Individual) : 26 Apr 2012 14:14:00
Policy/Site No.
LA1.3 Housing Allocations - R121M-mod KENDAL EAST OF CASTLE GREEN ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not been prepared in accordance with the Town & County Planning Regulations 2004 (as amended)
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I wish to submit that the above plan does not satisfy the Test of Legal
Compliance on the grounds that
1. The involvement of the community has not been taken into account
because the views of Kendal town Council have
not been taken on board or been given due consideration and an
appropriate response and explanation for such given.
2. The recommendations made do not comply with the Town and country
Planning Regulations in respect of road width, number of emergency
vehicle access points etc in respect of Rl21M .Furthermore, the
planners had not carried out any site visits to this site until well
after it was included in the document.
3. Regard to national policy in respect of flood prevention etc has been
disregarded as the views of the Environment agency have not been
fully sought with regard to flooding into the Stock Beck scheme in
Kendal and the capacity of the relief reservoir in respect of development
at Rl21M
In general it is my opinion the majority of the proposals have been
made to fit a predetermined model and that the views expressed by the
vast majority have not been taken into consideration. The hefty tome that
contains this strategy is almost beyond comprehension and my view is that
the elected representatives who voted on it (only two thirds) probably understand
it as little as I did. I have therefore consented to specialist
representative speaking on my behalf at the hearing
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I wish to submit that the above plan does not satisfy the Test of Legal
Compliance on the grounds that
1. The involvement of the community has not been taken into account
because the views of Kendal town Council have
not been taken on board or been given due consideration and an
appropriate response and explanation for such given.
2. The recommendations made do not comply with the Town and country
Planning Regulations in respect of road width, number of emergency
vehicle access points etc in respect of Rl21M .Furthermore, the
planners had not carried out any site visits to this site until well
after it was included in the document.
3. Regard to national policy in respect of flood prevention etc has been
disregarded as the views of the Environment agency have not been
fully sought with regard to flooding into the Stock Beck scheme in
Kendal and the capacity of the relief reservoir in respect of development
at Rl21M
In general it is my opinion the majority of the proposals have been
made to fit a predetermined model and that the views expressed by the
vast majority have not been taken into consideration. The hefty tome that
contains this strategy is almost beyond comprehension and my view is that
the elected representatives who voted on it (only two thirds) probably understand
it as little as I did. I have therefore consented to specialist
representative speaking on my behalf at the hearing
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
197. Mr & Mrs Mike and Susan Denison (Individual) : 18 May 2012 08:54:00
Policy/Site No.
LA1.3 Housing Allocations - RN152 GREENODD LAND AT THE OLD VICARAGE
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Mike and I are oppose to the church field RN152 at Pennybridge being developed and to leave it as it is an agricultural field. 22 dwellings completely overlooking our property, no privacy inside or out, taking light. Concerns over on-going sewage problems down to the new treatment plant which is not working properly at present because of these problems it is a worry to us.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
There are currently 9 houses and 1 pub for sale within Penny Bridge / Greenodd as well as a number of uncooupied houses which have been up for sale or to let for a long time. So if you can't get them occupied that means people are not moving into the countryside.
- Loss of landscape and amenity
- Topography
- Impact on church, graveyard etc. and impact on funerals, weddings, grave visits
- Loss of agricultural land / greenfield site and potential impact on agricultural employment
- Known issues such as drainage / ground water / surface water in the field
- Concern over existing sewage problems upstraim of the new sewage treatment plant (which is not working properly at present because of these problems)
- The primary school is presently full / at capacity with little scope for expansion
- Major concerns over access / traffic both during construction and thereafter
- The likely devaluation of existing neighbouring properties, impact on light etc. for those properties and the fact that they will be overlooked by any development
- The LDF document refers to the site as being an 'infill site', which is inaccurate as there is no existing development to the south of the field and it can easily be argued that development would not constitue 'rounding off' and that it would not be 'well located in relation to existing services and facilities'
- There are relatively few mature trees bordering two sides 'shielding the Church and existing dwellings on R291': in fact, the beech trees to the south of the field represent a significant danger to any future development
- The reference to the document that development would 'safeguard the Crakeside Business Park and Crakeside Works as local employment areas' is tenuous at best because of the close proximity of housing in nearby Ulverston, Lowick Parish and Backbarrow and Haverthwaite.
We have current issues with drainage, under ground water and surface water
in the field.
The impact the dwellings would have on us and the church would be
horrendous. 22 homes with 2 or more cars, additional traffic raising concerns
for the villager's safety. Parking and additional traffic is already a concern
surrounding school start & finishing times. With additional housing this would
inevitably get worse.
If Glaxo is developing then would people not want to live in Ulverston to avoid
the access issues through the Winter in and out of Penny Bridge & Greenodd
villages, as unfortunately when it snows the access is extremely
compromised. Also with increasing fuel prices people purchasing homes in
Ulverston would be a better decision.
We feel there would be a negative impact on the church, which currently has
a surrounding landscape of natural beauty. People visit the gravesides of their
loved ones and take great solace of the peace and tranquillity surrounding
although this would be lost with a new housing estate metres away.
The avenue of beech trees that are 150 years old would be damaged and the
roots of these trees pose a danger to the development. We already have Ellis
wood housing estate, some of which are used as second homes. We want to
keep our village a village and not turn it into a town and this is the feeling of
the majority of villagers.
[Note: objections supported by petition containing 135 signatures]
198. Mr & Mrs Mike and Susan Denison (Individual) : 18 May 2012 10:50:00
Policy/Site No.
LA1.3 Housing Allocations - RN152 GREENODD LAND AT THE OLD VICARAGE
If you have selected a ‘Site omission’ please enter the site reference or location and relevant policy below
Settlement-wide issues
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Mike and I are oppose to the church field RN152 at Pennybridge being developed and to leave it as it is an agricultural field. 22 dwellings completely overlooking our property, no privacy inside or out, taking light. Concerns over on-going sewage problems down to the new treatment plant which is not working properly at present because of these problems it is a worry to us.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
There are currently 9 houses and 1 pub for sale within Penny Bridge / Greenodd as well as a number of uncooupied houses which have been up for sale or to let for a long time. So if you can't get them occupied that means people are not moving into the countryside.
- There are presently at least thirteenproperties in Greenodd and Penny Bridge either for sale, for let or empty, suggesting lack of demand for additional residential housing
- The primary school is presently full / at capacity with little scope for expansion
There will only be one outcome for the residents of High Garth and that is our properties would suffer therefore devaluing our homes.
We want to keep our village tranquil. Keep our green acres safe.
[Note: objections supported by petition containing 135 signatures]
199. Mrs J.E. Dickinson (Individual) : 26 Apr 2012 10:14:00
Policy/Site No.
LA1.3 Housing Allocations - R121M-mod KENDAL EAST OF CASTLE GREEN ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I am writing to object to the development of dwellings at the site of Castle Green Lane, Oaktree Road, Rowan Tree Crescent and the Old Sedbergh Road, for which previous planning applications have already been refused.
My family have lived locally for generations, both as business-men (my Great Grandfather owned Rishton's Iron Foundry in the heart of Kendal) and as farmers, in the Oxenholme, Old Hutton area.
Kendal used to be a lovely old market town, but previous councils demolished most of our old yards, (along with their history) and took the "heart and soul" out of the town centre, so, please do not destroy our green pastures surrounding Kendal, and bury them under concrete, because once they have gone, they have gone for ever. As a farmer's daughter I think it is sacrilage to build on green fields, expecially in this "day & age" as we have so little left. It is the duty of everyone to protect our landscape and our wildlife which inhabits it.
I believe te area is a habitat for the rare Great Crested Newts which are a protected species. All flora and fauna are very special, especially today. Our landscape around the Lake District National Park is, also, very precious.
I know there are other reasons, such as traffic, (a primary school nearby) and Kendal cannot cope with any more traffic - pollution & sewage etc, but I know that the threat of flooding is a great concern. There are continued concerns for the effectiveness of Stock Beck Flood Alleviation Scheme.
Drainage & runoff over the whole area is a problem. Water has a "mind of its own"! Our weather patterns are changing, and the Cockermouth disaster is a reminder of what constant heavy rainfall can do, in a short period of time.
I'm sure, you have a duty to protect existing residential properties, especially up Oaktree Road and Rowan Tree Crescent, which has a profound drainage problem already, and, also to protect our surrounding "green" area, too.
200. John and Alyson Dickson (Individual) : 24 Apr 2012 15:56:00
Policy/Site No.
LA1.1 Development Boundaries- ULVERSTON
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I wish to make representation for the inclusion of a small plot of land within the permitted development area in Ulverston.
The plot of land is situated on Daltongate immediately to the left of the driveway to Stockbridge House. My husband and I jointly own this triangular plot of land which we currently let out as a garden/allotment (to a resident on Soutergate). The dotted line indicating permitted development bounds the plot on two sides (Daltongate and Stonecross) and I have been unable to find within the plan a rationale for the exclusion of our plot from the permitted development area. I am also unclear what implications the exclusion of the plot has for potential future development on the site (it was an original question re this that led to our inclusion in mailings re the DPD).
Our request is that consideration be given to including the plot in the permitted development area or provision of a clear rationale for its exclusion.
201. Ms Susan Dixon (Individual) : 23 Apr 2012 10:21:00
Policy/Site No.
LA1.3 Housing Allocations - R121M-mod KENDAL EAST OF CASTLE GREEN ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I understand that at this stage you seek to determine whether the proposal to build
on Rl21 is legal and based on evidence that it is deliverable. Since I last wrote to you I
have discovered much more about the unsoundness of the proposal.
On many previous occasions planners have pronounced upon the aesthetic value
of this site, yet now all this history is being ignored.
There has been no consideration of the implications for access. Oak Tree Road is
far too narrow, and access from Castle Green Lane involves ruining a field which
planners have now agreed should not be built upon. Oak Tree A venue access is
impossible and Castle Green Lane access is an ill-conceived alternative.
Traffic and infrastructure issues which apply to all new developments are
especially critical for this site. They render development here even more illogical than
elsewhere in town.
At the bottom of my garden lives a population of Great Crested Newts. You will
be unable to build on R121 without spending a considerable extra sum on trying to
minimise damage to their habitat in R121, RN302 and R56.
Finally, the previously agreed Development Boundary excludes R121, so I
imagine the proposal is illegal as well.
This plan is thoroughly impractical
202. Ms Susan Dixon (Individual) : 23 Apr 2012 10:24:00
Paragraph No.
1.10
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The Town Council has invested much time and money into making
reccommendations. They did not favour developing this field for several good reasons
but SLDC has ignored their views. They did favour developing some other sites in
town.It is improper to disregard their carefully balanced view.
203. Mr & Mrs Richard, Ruth, & Alan Dixon (Individual) : 26 Apr 2012 16:49:00
Policy/Site No.
LA1.3 Housing Allocations - M41KM KENDAL SOUTH OF LUMLEY ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Loss of green field space is detrimental to the character and heritage of the area. This is contrary to Coalition Government Sustainable Development Policy, which recognizes brown field preference above important countryside areas. The Soundness and legality of the plan is therefore challenged as being contrary to Government Planning Policy.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I wish to object to and challenge the soundness of proposed land allocation for development – to south of Lumley Rd. (M41KM) and Scroggs Wood Light Industrial Site (E4M) on the following grounds:
- The proposed developments would spoil the initial impression to Kendal visitors, being on the main access route and adjacent to the Town boundary. The Lumley road site is steeply graded and properties would impose on the existing view for Kendal visitors. The line of trees acts as a natural barrier between countryside and properties. Building to the South of this line (E4M), would fundamentally change the Kendal “Gateway to the Lakes” character as a valued landscape. This is contrary to the adopted planning Core Strategy. The Soundness of the plan is therefore challenged on visual impact grounds, contrary to planning policy.
- Loss of green field space is detrimental to the character and heritage of the area. This is contrary to Coalition Government Sustainable Development Policy, which recognizes brown field preference above important countryside areas. The Soundness and legality of the plan is therefore challenged as being contrary to Government Planning Policy.
- Milnthorpe road already backs up to the bypass at peak times and cannot accommodate the massive increase that such development, in these locations, would create. Kendal town development to attract visitors is pointless if they cannot obtain satisfactory access. The associated pollution from stationary traffic is incompatible with sustainable development objectives. The soundness of the development is challenged on the basis that there is no traffic plan to address these issues.
- The A6 is a crucial access for emergency services, particularly following the downgrading of Westmorland General Hospital. Further congestion on this route would introduce undue risk. The potential for accidents when joining the main road would also be significantly increased. The Soundness of the plan is therefore challenged on safety grounds.
- The soundness of the development is challenged on the basis that there is inadequate local infrastructure including drainage, sewerage and roads.
- The proposed development is incompatible with the character of the historic Helsington development contrary to planning policy. The Soundness of the plan is therefore challenged as being detrimental to the historical character of the area.
-The site is clearly NOT “in an accessible location or an easily developable level site” (Achievability statement P133 2 C). The Soundness of the plan is therefore challenged as being contrary to this declared planning statement.
- There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of adequate existing residential space and more suitable alternative development sites.
- The Development plan should retain the "Kendal Gateway to the Lakes" image supporting tourism and established Cumbrian employment, not destroy it with unsightly, unnecessary development and traffic jams. You don’t put your wheelie bin on your front door step! The DPD appears to have completely disregarded the massive opposition and valid objections previously made. The soundness of this planned development is challenged as disregarding local opinion contrary to Government Policy.
204. Mr & Mrs Richard, Ruth, & Alan Dixon (Individual) : 26 Apr 2012 16:53:00
Policy/Site No.
LA1.6 Strategic Employment Sites - E4M KENDAL LAND AT SCROGGS WOOD, MILNTHORPE ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I wish to object to and challenge the soundness of proposed land allocation for development – to south of Lumley Rd. (M41KM) and Scroggs Wood Light Industrial Site (E4M) on the following grounds:
- The proposed developments would spoil the initial impression to Kendal visitors, being on the main access route and adjacent to the Town boundary. The Lumley road site is steeply graded and properties would impose on the existing view for Kendal visitors. The line of trees acts as a natural barrier between countryside and properties. Building to the South of this line (E4M), would fundamentally change the Kendal “Gateway to the Lakes” character as a valued landscape. This is contrary to the adopted planning Core Strategy. The Soundness of the plan is therefore challenged on visual impact grounds, contrary to planning policy.
- Loss of green field space is detrimental to the character and heritage of the area. This is contrary to Coalition Government Sustainable Development Policy, which recognizes brown field preference above important countryside areas. The Soundness and legality of the plan is therefore challenged as being contrary to Government Planning Policy.
- Milnthorpe road already backs up to the bypass at peak times and cannot accommodate the massive increase that such development, in these locations, would create. Kendal town development to attract visitors is pointless if they cannot obtain satisfactory access. The associated pollution from stationary traffic is incompatible with sustainable development objectives. The soundness of the development is challenged on the basis that there is no traffic plan to address these issues.
- The A6 is a crucial access for emergency services, particularly following the downgrading of Westmorland General Hospital. Further congestion on this route would introduce undue risk. The potential for accidents when joining the main road would also be significantly increased. The Soundness of the plan is therefore challenged on safety grounds.
- The soundness of the development is challenged on the basis that there is inadequate local infrastructure including drainage, sewerage and roads.
- The proposed development is incompatible with the character of the historic Helsington development contrary to planning policy. The Soundness of the plan is therefore challenged as being detrimental to the historical character of the area.
- The site is clearly NOT “in an accessible location or an easily developable level site” (Achievability statement P133 2 C). The Soundness of the plan is therefore challenged as being contrary to this declared planning statement.
- There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of adequate existing residential space and more suitable alternative development sites.
- There is spare capacity and expansion potential on existing established trading estates on Shap Road. The plan to relocate the Rugby club to Oxenholme and development of the Gilkes site are more suited to development than Scroggs Wood. The soundness of the case for such development is challenged on the basis of existing and more suitable alternative development sites compatible with planning policy.
- What and where is the business case and demand for a further speculative light industrial business park? Why would UK businesses move to such a park when financial assistance and tax breaks are available for designated City areas such as the Manchester Enterprise Zone? The soundness of this planned development is challenged on the basis of no established demand or business case.
- The Development plan should retain the "Kendal Gateway to the Lakes" image supporting tourism and established Cumbrian employment, not destroy it with unsightly, unnecessary development and traffic jams. You don’t put your wheelie bin on your front door step! The DPD appears to have completely disregarded the massive opposition and valid objections previously made. The soundness of this planned development is challenged as disregarding local opinion contrary to Government Policy.
205. Mr & Mrs Richard, Ruth, & Alan Dixon (Individual) : 26 Apr 2012 16:54:00
Policy/Site No.
LA1.3 Housing Allocations - All Kendal sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of adequate existing residential space and more suitable alternative development sites.
206. Mr & Mrs Richard, Ruth, & Alan Dixon (Individual) : 26 Apr 2012 16:56:00
Paragraph No.
0.0 Whole Document
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Is there a definition of “affordable housing” in the context of Kendal young person income? Or is this merely a rouse to allow land owners and builders to make massive profits, without any tangible commitment to house the low paid of Kendal? The Soundness is therefore challenged on the basis of no defined affordability test.
207. Mr & Mrs Richard, Ruth, & Alan Dixon (Individual) : 26 Apr 2012 16:57:00
Policy/Site No.
LA1.4 - Kendal Sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of adequate existing residential space and more suitable alternative development sites.
208. Mr Phil Doherty (Individual) : 16 Apr 2012 16:20:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - All Ulverston sites
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
1.There have been various consultation exercises in Ulverston and the community response to the large proposed expansion of Ulverston by 1200 homes has been universally negative. There has been no attempt to take account of the views of the community and the consultation has just been a box ticking exercise. They have come but they were not listening.
2. The proposals for for Ulverston involve a population increase of 22-25% and such a large change in the size and character of the town should have had the broad support of the population of the town .
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The Council think Ulverston needs 1200 extra homes (22% increase assuming 5500 existing). The Council have not demonstrated why so many extra homes are needed in the town .
1. To support 1200 home we will need some 1800-2000 extra jobs in Ulverston and nothing approaching this is projected. Even though the largest employer Glaxo is proposing to increase employment in the future the numbers employed there will not reach half the numbers that Glaxo employed 15 or 20 years ago so this is no justification.
2. The SLDC must be assuming people will commute from Ulverston. People in Ulverston do not commute to other areas of South Lakeland due to the distances and poor roads. They either work in Ulverston or commute to Barrow -outside the South Lakeland area. The SLDC plan to build on greenfield sites in Ulverston so that people who work in Barrow can move to Ulverston and commute . This in turn will prevent the many brownfield sites around Barrow being developed and lead to more car use and the attendant pollution and congestion issues . The policy is therefore not based on principles of sustainability and green development.
3. For a population increase of this size it is clear that Ulverston will need another Infant/Junior school and the existing secondary school will have to be expanded. No land seems to have been set aside for this and this is a major failing.
I propose that the population and employment data suggest that Ulverston only needs a limited number of extra houses over the next 15 years-about 200. The policy should only put new housing where employment suggests it is needed. Commuting large distances should not be encouraged by development.
I also propose that as Ulverston is part of the Barrow travel to work area the housing needs of the Furness area should be jointly assesed by SLDC and the council in Barrow.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
209. Mrs Margaret Doherty (Individual) : 16 Apr 2012 18:25:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - All Ulverston sites
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I believe previous reponses have not been properly addressed / listened too. There was alot of opposition, this seems to have been ignored.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Where is the evidence of need for such a large number of new houses? There are not the jobs to support this number of new people coming in to the area, If it is thought it would be people commuting to Barrow to work, why not build houses there on brown field sites. There are already a large number of houses for sale in Ulverston.
Ulverston is a character Market town, the character of the town will be destroyed by another huge housing estate which, together with croftlands will dominate the town, this will surely detract from any tourist trade the town might be hoping to attract. The town should not be extended out towards Birkrigg, any new houses should infill, so protecting the valuble countryside around birkrigg.
The town is traditionally a farming community, it makes no sense to loose farming land to houses.
There seems to be no plans for the extra schools that will be needed to accomodate the large number of new people living in the town. It has been shown recently that schools are at capacity in many years, at times when there are cut backs on funding in schools who will pay for the expense of new schools and increasing the size of Ulverston Victoria High School, and is there room for this, has this been addressed at all? I have seen no evidence of this, it is inconceivable to make plans for so many houses and not address the basic needs of the community, schools and health care.
I have concerns regarding the safety of the roads with the large increase in traffic which would be inevitable. Has there been any thought in to how traffic will be directed? The junctions on to the A590 are already too busy and dangerous.
Basically, there may well be a need to have some increase in housing in the area, but the number proposed is unrealistic and dissproportionate to the size of the town, Is Ulverston taking the load from Kendal? which would be unjust. Or from Barrow? Why??
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
210. Mrs Christine Donn (Individual) : 6 Apr 2012 17:18:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - M9M2-mod MILNTHORPE NORTH WEST OF MILNTHORPE
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
During a recent regional poll 98% of peoples responses were against the continued building up of the area which has a continued negative impact on the wildlife and over all view of the landscape which helps to bring in tourism during the summer months.
The Booths development and the proposed industrial estate next to Houghtons coachworks already detract from the appearance of this corner of the village and further development would only serve to erode the character of the village and by extension have an adverse effect on house prices.
Access into any estate at the proposed location is limited and will be used by traffic for the industrial estate as well, putting too much pressure on the small road of Grisleymires Lane and effecting those residents that already use it for Dallam Chase.
In short, the proposed estate is neither wanted or needed by the voting people of Milnthorpe.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
211. Mr Stephen Downham (Individual) : 26 Apr 2012 13:38:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.8 Local Employment Allocations - E31M KENDAL LAND SOUTH OF K SHOES, NATLAND ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
We have previously detailed the company's objection to the proposed development of E31 M
for industrial use.
We are now questioning the soundness of its inclusion in the Land Allocations Development
Plan Document (DPD) on the following grounds.
Not Justified
The DPD enjoys very little support within the local community with many residents and
pressure groups openly questioning the need for such large scale developments. There is
widespread resentment that the allocation is being imposed on the community and the many
representations made in the consultation process have been ignored.
E31 M is in a rural setting adjacent to the River Kent and a much appreciated walking area
accessible to town residents.
It is the only suitable location for a canal marina and is an integral part of the plan for the
restoration of the canaL This is an important proposed amenity which has been SLDC policy
for many years and cannot be ignored.
The importance of this site for a canal marina has already been highlighted by the Canal
Trust. If the site was used for industrial development, the only suitable site for a canal marina
in Kendal would be lost.
Not consistent with national policy
The E31 M site is a prime example of green belt and its inclusion in the plan will go against
the principles and intent of the new planning regulations that were announced on 27 March
2012. It would be much better to develop the many brown field sites in Kendal and not
contribute to urban sprawl and destroy this much loved rural area on the edge of the town.
I make this submission on behalf of the Board of Directors of Helme Lodge Homes &
Gardens Ltd. The board of directors is an elected body that represents the views of
all the residents that live in the 33 dwellings on the estate.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
212. Mr Stephen Downham (Individual) : 26 Apr 2012 13:54:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - R97 /MN34# KENDAL SOUTH OF NATLAND BECK FARM
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
This objection is site specific and we question the soundness of its inclusion in the
Land Allocations Development Plan Document (DPD) on the grounds of it not being
justified, not being effective and not being consistent with national policy. We have
previously objected to the proposed housing development to the south of Natland
Mill Beck Farm on the grounds of the hugely negative impact it would have on a
popular and much loved amenity area enjoyed by many walkers and cyclists. We
have also objected to the accompanying destruction of the parkland setting to the
grade 2 listed Helme Lodge.
Any site inclusion in the DPD must clearly be commercially viable for the proposed
development to be effective. There are difficult and highly expensive access issues
associated with the development of this site, which question its viability.
Access onto Natland Road would require a new road bridge and slip road in order to
preserve the line of the Kendal to Lancaster canal for redevelopment. The restoration of the
canal as an important new amenity has been SLDC policy for many years and cannot be
ignored. The development would also affect a magnificent line of beech trees that follow the
route of the canal. The alternative access from Natland Mill Beck Lane also presents significant problems. Any vehicle access from the lane would require an expensive road widening scheme, probably with a footpath. The serious environmental and safety issues and the loss of amenity value of a popular route for walkers and cyclists associated with such a scheme have already been highlighted by many residents supported by Kendal Civic Society and others.
Both access options would necessitate an extremely expensive infrastructure investment
and would be a serious handicap to any developer before finally committing to a
development scheme when there are far less expensive and easier sites available for
building. We therefore question its commercial viability. There are already examples of other developments within Kendal, where developers have misjudged the commercial viability and have been unable to complete projects. We believe this may be another such case but if the development work starts it will destroy a precious rural setting.
Not consistent with national policy
The R97M site is a prime example of green belt and its inclusion in the plan will go against
the principles and intent of the new planning regulations that were announced on 27 March
2012. It would be much better to develop the many brown field sites in Kendal and not
contribute to urban sprawl and destroy this much loved rural area on the edge of the town.
Approval for the development of R97M would also represent a departure from the
Sustainable Development Principles as detailed in Paragraphs 2-4 on page 15 of the Core
Strategy Document adopted on 201
h November 2010. In particular Paragraph 4 states "There
is a need to safeguard the essential character and appearance of those buildings and sites
that make a positive contribution to the special architectural or historic interest of the area,
including the numerous conservation areas and listed buildings, whilst encouraging the
appropriate re-use of buildings or sites which are causing harm". Further consideration
should be given to the associated destruction of the original parkland setting to the Grade 2
Listed Helm Lodge that this development would necessitate ..
Paragraph 2 on Page 15 is equally relevant given the hugely negative impact the
development would have a much loved and popular amenity area enjoyed by many walkers
and cyclists. This states "It is vital to protect the countryside for its intrinsic beauty, diversity
and natural resources and also for its ecological, geographical, cultural and historical,
economic, agricultural, recreational and social value".
I make this submission on behalf of the Board of Directors of Helme Lodge Homes &
Gardens Ltd. The board of directors is an elected body that represents the views of
all the residents that live in the 33 dwellings on the estate.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
213. Mr Stephen Downham (Individual) : 26 Apr 2012 13:56:00
Paragraph No.
1.10
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
This objection is site specific and we question the soundness of its inclusion in the
Land Allocations Development Plan Document (DPD) on the grounds of it not being
justified, not being effective and not being consistent with national policy. We have
previously objected to the proposed housing development to the south of Natland
Mill Beck Farm on the grounds of the hugely negative impact it would have on a
popular and much loved amenity area enjoyed by many walkers and cyclists. We
have also objected to the accompanying destruction of the parkland setting to the
grade 2 listed Helme Lodge.
Not Justified
The DPD enjoys very little support within the local community with many residents
and pressure groups questioning the need for such large scale developments. There
is widespread resentment that the allocation is being imposed on the community and
the many representations made in the consultation process have been ignored
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
214. Mrs Patricia Dracup (Individual) : 23 Apr 2012 12:21:00
Policy/Site No.
LA1.3 Housing Allocations - RN225-mod ARNSIDE HOLLINS LANE
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
REPRESENTATION ON BEHALF OF THE RESIDENTS OF HOLLINS LANE,
ARNSIDE, GIVING OBJECTIONS TO THE PROPOSED DEVELOPMENT OF
SITE NO : RN22S MAP NO : 7
1 am taking up your invitation to write to you giving my objections regarding the
proposed allocation of land for development at Hollins Lane, Arnside ref: RN225.
This is, in spite of the fact that in the 'so-called' democracy of SLDC, thousands of
objections ( including my own ) over a period of years, have been completely
ignored. These objections have been merely 'noted' whilst an outdated and
unnecessary plan formulated in pre- recession 2004 is still going ahead. Are
developers already standing by, bulldozers at the ready?
People are realising that those in authority do not want to co-operate with the
wishes of the Council Tax payers. YOU ARE NOT LISTENING.
I note that, according to the 'Development Sites Under Consideration· Map of 2007-
2008, the Hollins Lane site was not included.
Development plans for six houses on RN225 were scrapped because of access &
drainage problems. It was proved to be an unworkable site. In 2011, a housing
association again looked at building six houses, but had to abandon the scheme
because of the site's problems.
Unbelievably, on the 2011 map- twenty one houses were proposed. Obviously,
someone seated at a desk put this number on a map. This person obviously had no
understanding or knowledge of the site and its problems . The site may well be made
available by it's owner- but this does not mean that it is suitable.
Then, on the revised map of 2012, a figure of thirty four appeared . What madness
is this ? If you would care to leave your offices for a couple of hours and view the site
you would see that this number of houses is impossible.
Are you making up numbers of houses to fulfil quotas ?
The Parish Council has proposed small brownfield sites in Arnside which would fulfil
local housing need . Regenerating these sites would afford some protection of
important open spaces . Why, then, build on this sensitive greenfield site within
the AONB? Are large greenfield sites easier to develop and therefore more attractive
to developers?
Do you care about the countryside ? I think not. You are making local people very
upset and angry. Any large development on Hollins Lane would conflict with
European Union requirements of the Human Rights Act 1998. You would take away
both the privacy and light of a number of householders, the propose site being
higher than existing dwellings, and sloping down towards them.
Taking all of these facts into consideration, the proposed land allocation at Hollins
lane is both unlawful and unsound.
This site, therefore, should be removed from any land Allocation Document
215. Mrs Eileen Drinkall (Individual) : 17 May 2012 11:38:00
Policy/Site No.
LA1.3 Housing Allocations - R339# ALLITHWAITE LAND SOUTH OF GREEN LANE
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I have fought to keep this field green for over forty year and again I will try again to
keep this green field.
This field is the only green field here; over the past forty years the village has grown
too big to be a village. Templand Park, Greendales, High cliff drive, Mayshelles
orchard, uplands fellside, Jack hill, Hazledene, plus in fill. Farm buildings and shops
have been converted to dwellings and shops. In Allithithwaite we have one shop/post
office which services this area.
The proposed dwellings on filed number R319, between Green lane and boarbank
lane, would increase traffic and parking, which there are already problems with on
these 2 roads, the sewerage system is old and would be inadequate for another 22
dwellings.By building on this land would be taking away residents on Green lane
and Boarbank roads only green field.
We are asking that other land be considered on the right hand side of Holme lane
fields NO RN230 AND RN65, the reason we ask for this land to be considered is
there is better access for cars it would mean traffic would not be brought threw the
centre of the village passed the school reducing the risk of accidents.
My final point is the village has already expanded and is now bigger than a village
yet it has no business to offer employment to people from the village, so to increase
housing without the facilities such as jobs would be of no benefit to the village.
I do understand there is a shortage of housing within this area, and many others in
the country, but rather than just build housing for the sake of building I would ask that
they be built on suitable sites with the least impact on the present residents.
216. Mrs Eileen Drinkall (Individual) : 17 May 2012 11:39:00
Policy/Site No.
LA1.3 Housing Allocations - Site Omission
If you have selected a ‘Site omission’ please enter the site reference or location and relevant policy below
Site omission - Ref RN230
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I have fought to keep this field green for over forty year and again I will try again to
keep this green field.
This field is the only green field here; over the past forty years the village has grown
too big to be a village. Templand Park, Greendales, High cliff drive, Mayshelles
orchard, uplands fellside, Jack hill, Hazledene, plus in fill. Farm buildings and shops
have been converted to dwellings and shops. In Allithithwaite we have one shop/post
office which services this area.
The proposed dwellings on filed number R319, between Green lane and boarbank
lane, would increase traffic and parking, which there are already problems with on
these 2 roads, the sewerage system is old and would be inadequate for another 22
dwellings.By building on this land would be taking away residents on Green lane
and Boarbank roads only green field.
We are asking that other land be considered on the right hand side of Holme lane
fields NO RN230 AND RN65, the reason we ask for this land to be considered is
there is better access for cars it would mean traffic would not be brought threw the
centre of the village passed the school reducing the risk of accidents.
My final point is the village has already expanded and is now bigger than a village
yet it has no business to offer employment to people from the village, so to increase
housing without the facilities such as jobs would be of no benefit to the village.
I do understand there is a shortage of housing within this area, and many others in
the country, but rather than just build housing for the sake of building I would ask that
they be built on suitable sites with the least impact on the present residents.
217. Mrs Eileen Drinkall (Individual) : 17 May 2012 11:40:00
Policy/Site No.
LA1.3 Housing Allocations - Site Omission
If you have selected a ‘Site omission’ please enter the site reference or location and relevant policy below
Site omission - Ref RN65
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I have fought to keep this field green for over forty year and again I will try again to
keep this green field.
This field is the only green field here; over the past forty years the village has grown
too big to be a village. Templand Park, Greendales, High cliff drive, Mayshelles
orchard, uplands fellside, Jack hill, Hazledene, plus in fill. Farm buildings and shops
have been converted to dwellings and shops. In Allithithwaite we have one shop/post
office which services this area.
The proposed dwellings on filed number R319, between Green lane and boarbank
lane, would increase traffic and parking, which there are already problems with on
these 2 roads, the sewerage system is old and would be inadequate for another 22
dwellings.By building on this land would be taking away residents on Green lane
and Boarbank roads only green field.
We are asking that other land be considered on the right hand side of Holme lane
fields NO RN230 AND RN65, the reason we ask for this land to be considered is
there is better access for cars it would mean traffic would not be brought threw the
centre of the village passed the school reducing the risk of accidents.
My final point is the village has already expanded and is now bigger than a village
yet it has no business to offer employment to people from the village, so to increase
housing without the facilities such as jobs would be of no benefit to the village.
I do understand there is a shortage of housing within this area, and many others in
the country, but rather than just build housing for the sake of building I would ask that
they be built on suitable sites with the least impact on the present residents.
218. Mrs Ann Dudley (Individual) : 16 Apr 2012 13:16:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - All Arnside sites
If you have selected a ‘Site omission’ please enter the site reference or location and relevant policy below
Alternative sites listed in APPT/APCs submission shown in "Soundness" section below below
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
The DPD has not had regard to the Sustainable Community Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
A series of changes should be made in order to comply with the NPPF and in order to deal with the lack of sound evidence in the current Land Allocations. Changes also need to be made to comply with SLDC's core strategy.
The proposed changes are listed in detail in our objections paper attached below in answer 2.3 of this form.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
SPECIFIC CONCERNS AND OBJECTIONS OF ARNSIDE PARISH PLAN TRUST (APPT) AND ARNSIDE PARISH COUNCIL (APC) REGARDING SLDC’s CURRENT LAND ALLOCATIONS.
1. SUMMARY
Arnside Parish Plan Trust and Arnside Parish Council believe that SLDC has produced a Land Allocation plan which does not pass the main tests of soundness and which;
• is not consistent with the detailed policies set out in its Core Strategy designed to apply the duty of the Council to protect the special characteristics and historic landscape of the Arnside and Silverdale Area of Outstanding Natural Beauty. In particular, its land allocations for housing propose using exclusively greenfield sites and land rated currently as "Important Open Space" which will have an adverse impact on the AONB landscape and on Arnside's settlement character.
• fails to identify how specific local needs (for affordable rented social housing) will be delivered in practise, and who will deliver that need.
• does not reconcile effectively the “highest status of protection” given to land within an AONB, as expressed in the new version of the NPPF, with delivering the local needs which qualify as “exceptional circumstances”.
• has failed to explore sufficiently all potential alternatives and to apply the appropriate land use hierarchy. Instead it defaults to allocating greenfield sites and Important Open Spaces within the AONB which currently have “the highest level of protection” and are particularly valued by the local community and by the management of the AONB.
• fails to address the need to regenerate brownfield sites in the village to repair the environmental damage they are inflicting.
• has failed to win the support of the local community (550 signed petition against) and to respond to emerging local plans. Neither does it have the support of the management of the AONB, Arnside Parish Council, Arnside Parish Plan Trust and other bodies important to the management of the specially protected environment of the AONB.
• relies on a planning policy which is not sustainable because it sets too high a site threshold of 0.3ha which could prevent a more organic approach to land use which will impose less damage than the development of large sites.
• assumes that a planning policy of relying on commercial development to provide affordable housing through a 65/35% allocation ratio is viable, without providing any evidence that this policy is workable in today’s and foreseeable market conditions.
• assumes that this 65/35% ratio (which consumes three times the amount of land needed for affordable housing) can be justified in relation to “the highest status of protection” provided by the NPPF against inappropriate development of land within an AONB.
• is not sustainable. Instead, it will damage the rural, open character of the village and its attraction to residents and visitors alike in a sensitive location within the AONB. This will undermine the economy on which the local community depends for a viable future.
APPT and APC set out in more detail below the basis of its objections. The process for filing objections is complex and difficult for lay people to use with confidence. As this document has been prepared without the benefit of advice from a planning lawyer, we hope that all our points will still be considered even if not categorised correctly.
We also reserve the right to make further submissions, and to present emerging new information, at the Inspector’s hearing.
2. AMPLIFICATION
2.1. Overview
Our principal objections to the current Land Allocations for Arnside are that SLDC has not met the standards of evidence and proof required to justify the allocation of greenfield sites against the special protections afforded to such land by the national policies contained in the new version of the NPPF, and, as a result, neither has it gained the support of the local community. The Allocations are not sound in the context of the specific circumstances of Arnside.
Apart from one brownfield site allocated for employment purposes, all sites allocated for housing are greenfield sites, and two of these are currently designated “Important Open Spaces”. Land within an AONB has the highest status of protection under the NPPF and, within this AONB, these Important Open Spaces have, over a long time, been regarded by the community as having special value to the character and sustainability of Arnside.
We assert that SLDC has a special duty to apply to these sites the highest status of protection available. We further assert that they have not demonstrated to the standard required that there are no other viable alternatives within Arnside, or in surrounding areas, to meet specific local needs for affordable housing. Market housing does not fit the criteria of "need" in this context, especially as there are consistently over 70 dwellings available for sale in all price ranges in Arnside.
The Arnside community (through Arnside Parish Council and Arnside Parish Plan Trust) believe that there are viable alternatives which could be brought into play over the extended period covered by the Land Allocations process. Under the new Community Planning and Neighbourhood Planning regimes, SLDC should therefore take the opportunity to explore these alternatives more effectively with community representatives and to establish whether a better plan could be produced.
Because of the failure of SLDC to demonstrate that it has used its best endeavours to explore all reasonable alternatives, and because of a number of weaknesses in the evidence base used as set out in more detail below, we object to SLDC’s current Land Allocations because they fail the test of soundness on a number of points.
2.2. Housing needs in Arnside
We recognise and accept that more affordable housing is needed in Arnside. The most accurate survey currently available of need in the area (dated 2009) indicates that there is a short term need for 27 affordable homes in the village. It is clear that by far the main element of that need is for social rented housing. Longer term needs are still very unclear.
There is already an adequate supply of market housing with available stock being sustained at over 70 homes for sale of all types and price ranges, so there is no “exceptional need” to allocate land for market housing.
There is also a history within the village of affordable housing being built but failing to be maintained as part of the ongoing affordable housing stock because it has been traded on as holiday homes and general market housing. This needs to be avoided in future.
We understand that, within a confined area such as Arnside, it is difficult to find sites which balance the conflicting objectives of providing needed affordable housing while at the same time preserving the character of the settlement within the AONB to the “highest status of protection” that SLDC, and we, are obliged to achieve.
We are concerned, however, that SLDC has produced a range of numbers to justify its Land Allocations. The attached Appendix illustrates the range of numbers cited in the plan. Under pressure from the local community, SLDC has reduced progressively the numbers allocated to the AONB in proportion to other areas within South Lakes District to try more effectively to minimise the adverse impact on the core characteristics of the AONB. We welcome the reduction in numbers and the attempts to address this challenge.
However, the fact that these numbers have only recently been further amended, and that they are based on proportional data drawn from the wider region rather than specific local needs, illustrates the lack of certainty and the weak evidence base for the need within Arnside.
This is important because precise allocations are required to deliver the right types of homes, and in order to avoid the allocation of inappropriate sites, and the unnecessary - and avoidable - destruction of highly valued greenfield space. We therefore believe that this element of the plan is unsound because the calculation of need requires further work to ensure the correct housing types are delivered, and to ensure that unnecessary damage to the character of the village within the AONB is avoided.
APPT and APC are keen to engage in further work with SLDC to establish a more accurate assessment of housing need within the village.
2.3. Inappropriate Land Allocations
Arnside contains currently brownfield - and other smaller sites - which SLDC has not listed in the Land Allocations. These sites could, and should, be developed both to supply affordable housing needs and to repair the detrimental affect on the character of the village caused by the derelict brownfield locations. It is argued by APPT/APC that these sites, if brought into use over the term of the Land Allocations Plan to 2025, could supply much of the specifically identified affordable housing needs of the Village.
The current SLDC Land Allocations, however, list exclusively greenfield sites for housing, two of which are currently listed as Important Open Space, and as such are important to defining the open and rural character of the village within the AONB and maintaining its long term economic sustainability.
We believe that the current allocations fail the test of supporting the economic and environmental sustainability test for the reasons set out in detail in the emerging Village Plan for Arnside (http://www.arnside.gov.uk/Warehouse/ArnsideLookingForward4.pdf).
They are also the main concern of the 550+ signature petitions raised and submitted to SLDC during this process which stressed the need to protect these greenfields and Important Open Spaces. As a result, the current Allocations do not have the support of the Arnside community, and therefore they fail the soundness test for community engagement and support.
The current Allocations also fail to meet the sequential test for the use of brownfield sites etc before allocating greenfield sites. The allocation of greenfield sites currently designated as Important Open Space within an AONB is even further up the sequential hierarchy and therefore further from meeting the soundness test.
As stated above, there are a range of smaller infill and brownfield sites which would not have as adverse an environmental impact and which could be brought into use over the plan period, especially if SLDC applied some of its other powers, or to adjust some of its current planning policies (see below), or if it took a longer view of potential availability.
The current allocations therefore fail the “exceptional circumstances” and “highest status of protection” national policy soundness test for Land Allocations within an AONB. This is because the current documents fail to demonstrate that SLDC has used its best endeavours to find alternatives over the lifetime of this planning period, and because it has not adapted its planning policies to fit the special circumstances and “highest status of protection” applying within an AONB.
2.4. Specific concerns about the soundness of local policies.
We have concerns about some of the stated policies and planning assumptions applied by SLDC within this process. If valid, they would mean that SLDC’s plan would fail the soundness tests in several regards.
• SLDC has taken a policy decision not to include sites of less than 0.3 hectares in the current Land Allocations. As a consequence it has had to resort to allocating sensitive and controversial large greenfield sites. SLDC has admitted, however, that the smaller sites could well come into play during the plan period and they would probably get planning permission. Such sites could, however, supply a substantial part of the local need for social rented housing, especially if they were developed in small increments by a housing association or similar body. We understand that a smaller threshold of 0.1ha is being applied within the Lake District National Park. We believe therefore that the soundness test will not be met because SLDC has made this policy decision without opting for an alternative approach to allocate smaller sites which could be used in the context of the exceptional circumstance test and highest status of protection applying within an AONB. The community believe that the larger and very sensitive greenfield sites should be removed from the allocations until the smaller site potential has been exhausted.
• The Local Development Plan appears also to be critically dependent on the success of the assumption that the main local need – for social rented affordable housing – will be delivered through the policy of allocating sites to commercial developers, subject to them building a 35% ratio of affordable housing within development sites. Despite considerable pressing for evidence, SLDC has not provided any data to demonstrate that this policy is viable and will succeed in the current economy and in future commercial development markets.
This is particularly important in view of major changes to financial and housing markets since 2008. SLDC needs to prove that commercial developers will be able to overcome the additional financial burden placed on these sites to pay for affordable housing and for such elements as the Community Infrastructure Levy. This has to be done against a background of a difficult credit market, very low housing turnover volumes, and falling house prices. All this in an area where the planning portfolio holder hopes and believes that this land allocation policy will reduce the price of market housing by 20%, thus increasing the pressure on the development funding model.
We have evidence locally that builders are unable to raise finance for site development and the above burdens will only aggravate these problems.
Because this is such a critical and fundamental assumption underlying the whole of SLDC’s Land Allocations, and because the future supply of affordable housing appears to depend entirely on it operating effectively, it is essential that robust and “bankable” evidence is provided by SLDC. Without it, the current Land Allocations cannot pass the deliverability test for the supply of local affordable housing and is therefore not sound.
• The 65/35 development ratio also has one further major weakness; it requires three times the amount of land which would be needed if only the local need for affordable housing is covered. This cannot be said to be meeting the test of “highest status of protection” or “exceptional circumstances” and is not sound because it does not comply with National Policy as expressed in the new version of the NPPF.
• It is much more likely that an appropriate body needs to be found which will focus specifically on building social rented housing without needing to rely on subsidies from a premium placed on commercial developments of market housing. The SLDC documents do not deal adequately with this issue and are therefore unsound because they fail to provide sufficient evidence that the Land Allocations and associated policies will deliver the specific local need for social rented housing.
• SLDC also appears to be driven by fear of the consequences of the new NPPF and their perception that developers will have unfettered access to land if sites are not allocated in a controlled process such as these Land Allocations. This is, it says, because of the “presumption in favour of development”.
We do not believe this to be true within an AONB because of the obligation to apply the “highest status of protection”, and inappropriate land allocations can continue to be resisted. There is therefore no need to rush this process. The current land allocations for Arnside should therefore be referred back for further work with the community to produce a more appropriate plan.
• SLDC appears to be over-relying on the very short term application of the “Deliverability” criteria within the Development Framework. In practise, this has led it to rely on sites where there is a clear immediate intention of the owner to make the site available for development and to capitalise on a commercial opportunity. If that commitment has not been made to date, potentially useful and less sensitive sites have been excluded, even if there is a reasonable chance that they will come into play over the longer term. The consequence of this is that derelict and previously used sites, which should be improved as part of any sensible spatial plan for any community, have been ignored. The knock-on consequence is that greenfield sites could be destroyed while derelict sites remain unused. This is not a sensible planning policy and fails even the commonsense soundness test.
• It is clear that it will take some time to bring into play some of the smaller and brownfield sites within the village but it is argued that the exceptional circumstances of the village within the AONB justify the extra effort (or time delay) that may be required. SLDC has failed to use its best endeavours to apply this extra effort by (for example) using the powers they have to bring derelict sites into use (such as Compulsory Purchase Orders). APPT are keen to work with SLDC to produce a Plan which achieves these objectives but, so far, SLDC has failed this test of soundness in meeting the exceptional circumstances criteria required within an AONB. The new Community planning regime under the Localism Act provides the opportunity to put this right by SLDC working closely with the community. The current land allocations should be deferred until this process has been completed. APPT/APC have an early draft of a community plan already in progress (http://www.arnside.gov.uk/Warehouse/ArnsideLookingForward4.pdf) and are keen to engage SLDC 's support in moving to a complete and workable version.
• We understand that the management of the Arnside & Silverdale Area of Outstanding Natural Beauty have similar and additional objections to the soundness of these Allocations. Arnside Parish Council, through Arnside Parish Plan Trust, intend to coordinate their emerging plans with this and other stakeholders for this area.
• We also understand that Lancaster City Council has a more appropriate treatment of land within the AONB in its Land Allocations policies but that SLDC has not yet coordinated its approach effectively with LCC. There may be solutions to local housing needs which could be accommodated within the neighbouring territories of LCC. SLDC will therefore fail to meet the soundness test until this process has been completed.
• Because of the above, the current Land Allocations should be referred back for revision. This revision would benefit from input from the emerging Arnside Community and Neighbourhood Plans which will address these issues.
Appendix 1
Land Allocation Development Plan Document – Calculation of Housing Need within the AONB*
There are 4 calculations of potential housing needs contained in the document for the AONB part of SLDC
CALCULATION 1
This is based on the AONB population as a % of the total Local Development Framework (LDF) area population
LDF Population 75000
AONB population 5% 3800 (Arnside 2300 and Beetham 1500)
Based on total district housing target of 400 per annum then 5% of this is 20 per annum for the AONB (12 for Arnside and 8 for Beetham)
Over the period 2003-2025 the total for the AONB is 460 (276 for Arnside and 184 for Beetham)
CALCULATION 2
This is based on the 2009 Strategic Market Assessment for Rural South Kendal. The figures for Annual Affordable Housing Requirements (See Page 63) for the period 2009-2015 were based on the 2006 Housing Needs Survey and indicates respondents aspirations.
Rural South Kendal Total 1105
AONB population 15.7% 173
(Arnside 104 and Beetham 69 based on population split shown in calculation 1)
If the above figures were projected at the same level for the whole of the plan 2009-2025 then this gives a total affordable housing need of 555 (333 for Arnside and 222 for Beetham based on population split shown in calculation 1)
CALCULATION 3
This is based on the 2011 Strategic Market Assessment for Rural South Kendal not including Milnthorpe and Kirkby Lonsdale. Again the survey appears to be aspirational. The response rate for Rural South Kendal was 30%. The calculations for the affordable housing market for 2011-2016 were based on:
• Households currently in housing which is unsuitable for their use and who are unable to afford to buy or rent in the market (backlog need)
• New household forming who cannot afford to buy or rent in the market
• Existing households expected to fall into need
• The supply of affordable housing through social renting and intermediate tenure stock
This calculation is similar to number 2
Rural South Kendal Total 435
AONB population 18.54% 225
(Arnside 133 and Beetham 89) based on population split shown in calculation 1)
CALCULATION 4
This is based on Arnside 2009 Housing Needs Survey and 2007 Beetham Housing Needs Survey to determine the need for affordable housing. This survey applied to social rented housing only and represented respondents aspirations and does not necessarily represent actual take up of affordable homes if they were offered. See Appendix Below: Analysis & Critical Review of Housing Needs
2009-14 Arnside 27 ? therefore projected number for 2009-2025 is 86
2007-12 Beetham* 17 ? therefore projected number for 2009-2025 is 61
But in order to deliver the affordable element an allowance for market housing has to be given. If affordable housing is delivered at 35% of market schemes this would bring the total need for 2009-2025 to 420 (Arnside 252 and Beetham 168)
*in the AONB part of Beetham
SUMMARY
Reference in Land Allocation Document Arnside Beetham Total Comments
3.79 Calculation 1 Total need 2003-2025 276 184 460 AONB population as a % of Local Development Area population
3.80 Calculation 2 Affordable need 2009-2025 333 222 555 AONB as a % of Rural South Kendal from an aspirational survey
3.81 Calculation 3 Affordable need 2009-2025 135 90 225 AONB as a % of Rural South Kendal LESS Milnthorpe and Kirkby Lonsdale from an aspirational survey
3.87 Calculation 4 Affordable need 2009-2025
Calculation 4 but also market allowance to achieve this 2009-2025 86
252 61
168 147
420 Arnside and Beetham aspirations for affordable housing
Market allowance figures are unrealistic because unlikely this scenario will happen
From the above 4 calculations it was concluded that the total housing need over the plan period was somewhere between 200 and 400 but because of the low housing delivery since 2003 to the present there was a need to do more per annum in the remaining period of the plan.
Because these calculations assume use of the 65/35% ration of market to affordable housing, the actual need for affordable housing is much less than the numbers stated above..
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
219. Mr Ian Dudley (Individual) : 16 Apr 2012 13:36:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - All Arnside sites
If you have selected a ‘Site omission’ please enter the site reference or location and relevant policy below
Alternative sites listed in APPT/APCs submission shown in "Soundness" section below.
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
The DPD has not had regard to the Sustainable Community Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
A series of changes should be made in order to comply with the NPPF and in order to deal with the lack of sound evidence in the current Land Allocations. Changes also need to be made to comply with SLDC's core strategy.
The proposed changes are listed in detail in our objections paper attached below in answer 2.3 of this form.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I fully support the following:
SPECIFIC CONCERNS AND OBJECTIONS OF ARNSIDE PARISH PLAN TRUST (APPT) AND ARNSIDE PARISH COUNCIL (APC) REGARDING SLDC’s CURRENT LAND ALLOCATIONS.
1. SUMMARY
Arnside Parish Plan Trust and Arnside Parish Council believe that SLDC has produced a Land Allocation plan which does not pass the main tests of soundness and which;
• is not consistent with the detailed policies set out in its Core Strategy designed to apply the duty of the Council to protect the special characteristics and historic landscape of the Arnside and Silverdale Area of Outstanding Natural Beauty. In particular, its land allocations for housing propose using exclusively greenfield sites and land rated currently as "Important Open Space" which will have an adverse impact on the AONB landscape and on Arnside's settlement character.
• fails to identify how specific local needs (for affordable rented social housing) will be delivered in practise, and who will deliver that need.
• does not reconcile effectively the “highest status of protection” given to land within an AONB, as expressed in the new version of the NPPF, with delivering the local needs which qualify as “exceptional circumstances”.
• has failed to explore sufficiently all potential alternatives and to apply the appropriate land use hierarchy. Instead it defaults to allocating greenfield sites and Important Open Spaces within the AONB which currently have “the highest level of protection” and are particularly valued by the local community and by the management of the AONB.
• fails to address the need to regenerate brownfield sites in the village to repair the environmental damage they are inflicting.
• has failed to win the support of the local community (550 signed petition against) and to respond to emerging local plans. Neither does it have the support of the management of the AONB, Arnside Parish Council, Arnside Parish Plan Trust and other bodies important to the management of the specially protected environment of the AONB.
• relies on a planning policy which is not sustainable because it sets too high a site threshold of 0.3ha which could prevent a more organic approach to land use which will impose less damage than the development of large sites.
• assumes that a planning policy of relying on commercial development to provide affordable housing through a 65/35% allocation ratio is viable, without providing any evidence that this policy is workable in today’s and foreseeable market conditions.
• assumes that this 65/35% ratio (which consumes three times the amount of land needed for affordable housing) can be justified in relation to “the highest status of protection” provided by the NPPF against inappropriate development of land within an AONB.
• is not sustainable. Instead, it will damage the rural, open character of the village and its attraction to residents and visitors alike in a sensitive location within the AONB. This will undermine the economy on which the local community depends for a viable future.
APPT and APC set out in more detail below the basis of its objections. The process for filing objections is complex and difficult for lay people to use with confidence. As this document has been prepared without the benefit of advice from a planning lawyer, we hope that all our points will still be considered even if not categorised correctly.
We also reserve the right to make further submissions, and to present emerging new information, at the Inspector’s hearing.
2. AMPLIFICATION
2.1. Overview
Our principal objections to the current Land Allocations for Arnside are that SLDC has not met the standards of evidence and proof required to justify the allocation of greenfield sites against the special protections afforded to such land by the national policies contained in the new version of the NPPF, and, as a result, neither has it gained the support of the local community. The Allocations are not sound in the context of the specific circumstances of Arnside.
Apart from one brownfield site allocated for employment purposes, all sites allocated for housing are greenfield sites, and two of these are currently designated “Important Open Spaces”. Land within an AONB has the highest status of protection under the NPPF and, within this AONB, these Important Open Spaces have, over a long time, been regarded by the community as having special value to the character and sustainability of Arnside.
We assert that SLDC has a special duty to apply to these sites the highest status of protection available. We further assert that they have not demonstrated to the standard required that there are no other viable alternatives within Arnside, or in surrounding areas, to meet specific local needs for affordable housing. Market housing does not fit the criteria of "need" in this context, especially as there are consistently over 70 dwellings available for sale in all price ranges in Arnside.
The Arnside community (through Arnside Parish Council and Arnside Parish Plan Trust) believe that there are viable alternatives which could be brought into play over the extended period covered by the Land Allocations process. Under the new Community Planning and Neighbourhood Planning regimes, SLDC should therefore take the opportunity to explore these alternatives more effectively with community representatives and to establish whether a better plan could be produced.
Because of the failure of SLDC to demonstrate that it has used its best endeavours to explore all reasonable alternatives, and because of a number of weaknesses in the evidence base used as set out in more detail below, we object to SLDC’s current Land Allocations because they fail the test of soundness on a number of points.
2.2. Housing needs in Arnside
We recognise and accept that more affordable housing is needed in Arnside. The most accurate survey currently available of need in the area (dated 2009) indicates that there is a short term need for 27 affordable homes in the village. It is clear that by far the main element of that need is for social rented housing. Longer term needs are still very unclear.
There is already an adequate supply of market housing with available stock being sustained at over 70 homes for sale of all types and price ranges, so there is no “exceptional need” to allocate land for market housing.
There is also a history within the village of affordable housing being built but failing to be maintained as part of the ongoing affordable housing stock because it has been traded on as holiday homes and general market housing. This needs to be avoided in future.
We understand that, within a confined area such as Arnside, it is difficult to find sites which balance the conflicting objectives of providing needed affordable housing while at the same time preserving the character of the settlement within the AONB to the “highest status of protection” that SLDC, and we, are obliged to achieve.
We are concerned, however, that SLDC has produced a range of numbers to justify its Land Allocations. The attached Appendix illustrates the range of numbers cited in the plan. Under pressure from the local community, SLDC has reduced progressively the numbers allocated to the AONB in proportion to other areas within South Lakes District to try more effectively to minimise the adverse impact on the core characteristics of the AONB. We welcome the reduction in numbers and the attempts to address this challenge.
However, the fact that these numbers have only recently been further amended, and that they are based on proportional data drawn from the wider region rather than specific local needs, illustrates the lack of certainty and the weak evidence base for the need within Arnside.
This is important because precise allocations are required to deliver the right types of homes, and in order to avoid the allocation of inappropriate sites, and the unnecessary - and avoidable - destruction of highly valued greenfield space. We therefore believe that this element of the plan is unsound because the calculation of need requires further work to ensure the correct housing types are delivered, and to ensure that unnecessary damage to the character of the village within the AONB is avoided.
APPT and APC are keen to engage in further work with SLDC to establish a more accurate assessment of housing need within the village.
2.3. Inappropriate Land Allocations
Arnside contains currently brownfield - and other smaller sites - which SLDC has not listed in the Land Allocations. These sites could, and should, be developed both to supply affordable housing needs and to repair the detrimental affect on the character of the village caused by the derelict brownfield locations. It is argued by APPT/APC that these sites, if brought into use over the term of the Land Allocations Plan to 2025, could supply much of the specifically identified affordable housing needs of the Village.
The current SLDC Land Allocations, however, list exclusively greenfield sites for housing, two of which are currently listed as Important Open Space, and as such are important to defining the open and rural character of the village within the AONB and maintaining its long term economic sustainability.
We believe that the current allocations fail the test of supporting the economic and environmental sustainability test for the reasons set out in detail in the emerging Village Plan for Arnside (http://www.arnside.gov.uk/Warehouse/ArnsideLookingForward4.pdf).
They are also the main concern of the 550+ signature petitions raised and submitted to SLDC during this process which stressed the need to protect these greenfields and Important Open Spaces. As a result, the current Allocations do not have the support of the Arnside community, and therefore they fail the soundness test for community engagement and support.
The current Allocations also fail to meet the sequential test for the use of brownfield sites etc before allocating greenfield sites. The allocation of greenfield sites currently designated as Important Open Space within an AONB is even further up the sequential hierarchy and therefore further from meeting the soundness test.
As stated above, there are a range of smaller infill and brownfield sites which would not have as adverse an environmental impact and which could be brought into use over the plan period, especially if SLDC applied some of its other powers, or to adjust some of its current planning policies (see below), or if it took a longer view of potential availability.
The current allocations therefore fail the “exceptional circumstances” and “highest status of protection” national policy soundness test for Land Allocations within an AONB. This is because the current documents fail to demonstrate that SLDC has used its best endeavours to find alternatives over the lifetime of this planning period, and because it has not adapted its planning policies to fit the special circumstances and “highest status of protection” applying within an AONB.
2.4. Specific concerns about the soundness of local policies.
We have concerns about some of the stated policies and planning assumptions applied by SLDC within this process. If valid, they would mean that SLDC’s plan would fail the soundness tests in several regards.
• SLDC has taken a policy decision not to include sites of less than 0.3 hectares in the current Land Allocations. As a consequence it has had to resort to allocating sensitive and controversial large greenfield sites. SLDC has admitted, however, that the smaller sites could well come into play during the plan period and they would probably get planning permission. Such sites could, however, supply a substantial part of the local need for social rented housing, especially if they were developed in small increments by a housing association or similar body. We understand that a smaller threshold of 0.1ha is being applied within the Lake District National Park. We believe therefore that the soundness test will not be met because SLDC has made this policy decision without opting for an alternative approach to allocate smaller sites which could be used in the context of the exceptional circumstance test and highest status of protection applying within an AONB. The community believe that the larger and very sensitive greenfield sites should be removed from the allocations until the smaller site potential has been exhausted.
• The Local Development Plan appears also to be critically dependent on the success of the assumption that the main local need – for social rented affordable housing – will be delivered through the policy of allocating sites to commercial developers, subject to them building a 35% ratio of affordable housing within development sites. Despite considerable pressing for evidence, SLDC has not provided any data to demonstrate that this policy is viable and will succeed in the current economy and in future commercial development markets.
This is particularly important in view of major changes to financial and housing markets since 2008. SLDC needs to prove that commercial developers will be able to overcome the additional financial burden placed on these sites to pay for affordable housing and for such elements as the Community Infrastructure Levy. This has to be done against a background of a difficult credit market, very low housing turnover volumes, and falling house prices. All this in an area where the planning portfolio holder hopes and believes that this land allocation policy will reduce the price of market housing by 20%, thus increasing the pressure on the development funding model.
We have evidence locally that builders are unable to raise finance for site development and the above burdens will only aggravate these problems.
Because this is such a critical and fundamental assumption underlying the whole of SLDC’s Land Allocations, and because the future supply of affordable housing appears to depend entirely on it operating effectively, it is essential that robust and “bankable” evidence is provided by SLDC. Without it, the current Land Allocations cannot pass the deliverability test for the supply of local affordable housing and is therefore not sound.
• The 65/35 development ratio also has one further major weakness; it requires three times the amount of land which would be needed if only the local need for affordable housing is covered. This cannot be said to be meeting the test of “highest status of protection” or “exceptional circumstances” and is not sound because it does not comply with National Policy as expressed in the new version of the NPPF.
• It is much more likely that an appropriate body needs to be found which will focus specifically on building social rented housing without needing to rely on subsidies from a premium placed on commercial developments of market housing. The SLDC documents do not deal adequately with this issue and are therefore unsound because they fail to provide sufficient evidence that the Land Allocations and associated policies will deliver the specific local need for social rented housing.
• SLDC also appears to be driven by fear of the consequences of the new NPPF and their perception that developers will have unfettered access to land if sites are not allocated in a controlled process such as these Land Allocations. This is, it says, because of the “presumption in favour of development”.
We do not believe this to be true within an AONB because of the obligation to apply the “highest status of protection”, and inappropriate land allocations can continue to be resisted. There is therefore no need to rush this process. The current land allocations for Arnside should therefore be referred back for further work with the community to produce a more appropriate plan.
• SLDC appears to be over-relying on the very short term application of the “Deliverability” criteria within the Development Framework. In practise, this has led it to rely on sites where there is a clear immediate intention of the owner to make the site available for development and to capitalise on a commercial opportunity. If that commitment has not been made to date, potentially useful and less sensitive sites have been excluded, even if there is a reasonable chance that they will come into play over the longer term. The consequence of this is that derelict and previously used sites, which should be improved as part of any sensible spatial plan for any community, have been ignored. The knock-on consequence is that greenfield sites could be destroyed while derelict sites remain unused. This is not a sensible planning policy and fails even the commonsense soundness test.
• It is clear that it will take some time to bring into play some of the smaller and brownfield sites within the village but it is argued that the exceptional circumstances of the village within the AONB justify the extra effort (or time delay) that may be required. SLDC has failed to use its best endeavours to apply this extra effort by (for example) using the powers they have to bring derelict sites into use (such as Compulsory Purchase Orders). APPT are keen to work with SLDC to produce a Plan which achieves these objectives but, so far, SLDC has failed this test of soundness in meeting the exceptional circumstances criteria required within an AONB. The new Community planning regime under the Localism Act provides the opportunity to put this right by SLDC working closely with the community. The current land allocations should be deferred until this process has been completed. APPT/APC have an early draft of a community plan already in progress (http://www.arnside.gov.uk/Warehouse/ArnsideLookingForward4.pdf) and are keen to engage SLDC 's support in moving to a complete and workable version.
• We understand that the management of the Arnside & Silverdale Area of Outstanding Natural Beauty have similar and additional objections to the soundness of these Allocations. Arnside Parish Council, through Arnside Parish Plan Trust, intend to coordinate their emerging plans with this and other stakeholders for this area.
• We also understand that Lancaster City Council has a more appropriate treatment of land within the AONB in its Land Allocations policies but that SLDC has not yet coordinated its approach effectively with LCC. There may be solutions to local housing needs which could be accommodated within the neighbouring territories of LCC. SLDC will therefore fail to meet the soundness test until this process has been completed.
• Because of the above, the current Land Allocations should be referred back for revision. This revision would benefit from input from the emerging Arnside Community and Neighbourhood Plans which will address these issues.
Appendix 1
Land Allocation Development Plan Document – Calculation of Housing Need within the AONB*
There are 4 calculations of potential housing needs contained in the document for the AONB part of SLDC
CALCULATION 1
This is based on the AONB population as a % of the total Local Development Framework (LDF) area population
LDF Population 75000
AONB population 5% 3800 (Arnside 2300 and Beetham 1500)
Based on total district housing target of 400 per annum then 5% of this is 20 per annum for the AONB (12 for Arnside and 8 for Beetham)
Over the period 2003-2025 the total for the AONB is 460 (276 for Arnside and 184 for Beetham)
CALCULATION 2
This is based on the 2009 Strategic Market Assessment for Rural South Kendal. The figures for Annual Affordable Housing Requirements (See Page 63) for the period 2009-2015 were based on the 2006 Housing Needs Survey and indicates respondents aspirations.
Rural South Kendal Total 1105
AONB population 15.7% 173
(Arnside 104 and Beetham 69 based on population split shown in calculation 1)
If the above figures were projected at the same level for the whole of the plan 2009-2025 then this gives a total affordable housing need of 555 (333 for Arnside and 222 for Beetham based on population split shown in calculation 1)
CALCULATION 3
This is based on the 2011 Strategic Market Assessment for Rural South Kendal not including Milnthorpe and Kirkby Lonsdale. Again the survey appears to be aspirational. The response rate for Rural South Kendal was 30%. The calculations for the affordable housing market for 2011-2016 were based on:
• Households currently in housing which is unsuitable for their use and who are unable to afford to buy or rent in the market (backlog need)
• New household forming who cannot afford to buy or rent in the market
• Existing households expected to fall into need
• The supply of affordable housing through social renting and intermediate tenure stock
This calculation is similar to number 2
Rural South Kendal Total 435
AONB population 18.54% 225
(Arnside 133 and Beetham 89) based on population split shown in calculation 1)
CALCULATION 4
This is based on Arnside 2009 Housing Needs Survey and 2007 Beetham Housing Needs Survey to determine the need for affordable housing. This survey applied to social rented housing only and represented respondents aspirations and does not necessarily represent actual take up of affordable homes if they were offered. See Appendix Below: Analysis & Critical Review of Housing Needs
2009-14 Arnside 27 ? therefore projected number for 2009-2025 is 86
2007-12 Beetham* 17 ? therefore projected number for 2009-2025 is 61
But in order to deliver the affordable element an allowance for market housing has to be given. If affordable housing is delivered at 35% of market schemes this would bring the total need for 2009-2025 to 420 (Arnside 252 and Beetham 168)
*in the AONB part of Beetham
SUMMARY
Reference in Land Allocation Document Arnside Beetham Total Comments
3.79 Calculation 1 Total need 2003-2025 276 184 460 AONB population as a % of Local Development Area population
3.80 Calculation 2 Affordable need 2009-2025 333 222 555 AONB as a % of Rural South Kendal from an aspirational survey
3.81 Calculation 3 Affordable need 2009-2025 135 90 225 AONB as a % of Rural South Kendal LESS Milnthorpe and Kirkby Lonsdale from an aspirational survey
3.87 Calculation 4 Affordable need 2009-2025
Calculation 4 but also market allowance to achieve this 2009-2025 86
252 61
168 147
420 Arnside and Beetham aspirations for affordable housing
Market allowance figures are unrealistic because unlikely this scenario will happen
From the above 4 calculations it was concluded that the total housing need over the plan period was somewhere between 200 and 400 but because of the low housing delivery since 2003 to the present there was a need to do more per annum in the remaining period of the plan.
Because these calculations assume use of the 65/35% ration of market to affordable housing, the actual need for affordable housing is much less than the numbers stated above.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
220. Mrs Ann Dudley (Individual) : 8 May 2012 12:09:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
1.9
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
The DPD has not had regard to the Sustainable Community Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The process for filing objections is complex and difficult for lay people to use with confidence.
We believe that the current allocations fail the test of supporting the economic and environmental sustainability test for the reasons set out in detail in the emerging Village Plan for Arnside (http://www.arnside.gov.uk/Warehouse/ArnsideLookingForward4.pdf).
They are also the main concern of the 550+ signature petitions raised and submitted to SLDC during this process which stressed the need to protect these greenfields and Important Open Spaces. As a result, the current Allocations do not have the support of the Arnside community, and therefore they fail the soundness test for community engagement and support.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The process for filing objections is complex and difficult for lay people to use with confidence.
We believe that the current allocations fail the test of supporting the economic and environmental sustainability test for the reasons set out in detail in the emerging Village Plan for Arnside (http://www.arnside.gov.uk/Warehouse/ArnsideLookingForward4.pdf).
They are also the main concern of the 550+ signature petitions raised and submitted to SLDC during this process which stressed the need to protect these greenfields and Important Open Spaces. As a result, the current Allocations do not have the support of the Arnside community, and therefore they fail the soundness test for community engagement and support.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
221. Mr Ian Dudley (Individual) : 8 May 2012 12:12:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
1.9
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
The DPD has not had regard to the Sustainable Community Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The process for filing objections is complex and difficult for lay people to use with confidence.
We believe that the current allocations fail the test of supporting the economic and environmental sustainability test for the reasons set out in detail in the emerging Village Plan for Arnside (http://www.arnside.gov.uk/Warehouse/ArnsideLookingForward4.pdf).
They are also the main concern of the 550+ signature petitions raised and submitted to SLDC during this process which stressed the need to protect these greenfields and Important Open Spaces. As a result, the current Allocations do not have the support of the Arnside community, and therefore they fail the soundness test for community engagement and support.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The process for filing objections is complex and difficult for lay people to use with confidence.
We believe that the current allocations fail the test of supporting the economic and environmental sustainability test for the reasons set out in detail in the emerging Village Plan for Arnside (http://www.arnside.gov.uk/Warehouse/ArnsideLookingForward4.pdf).
They are also the main concern of the 550+ signature petitions raised and submitted to SLDC during this process which stressed the need to protect these greenfields and Important Open Spaces. As a result, the current Allocations do not have the support of the Arnside community, and therefore they fail the soundness test for community engagement and support.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
222. Mr Michael Dyer (Individual) : 9 May 2012 09:02:00
Policy/Site No.
LA1.3 Housing Allocations - All Levens sites
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
We have read the form we have been asked to complete and find it very restricting, not least the manner in which it is worded. In view of this we have merely completed our personal details on the form and would refer you to the Levens Residents Group representation which was handed to you last Friday and we fully support the arguments presented therein.
223. Mr Alan Easton (Individual) : 9 May 2012 17:31:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - All Grange-over-Sands sites
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
The DPD has not had regard to the Sustainable Community Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
There is no way SLDC has any right to arbitrarily take over green field sites, where they are clearly green belt. All land from the 30mph derestriction on Allithwaite Road to Allithwaite is Green Belt - leave it alone.Allithwaite and Grange are separate. It cannot be right for proper planning to join them together by building of any kind. It is a disgraceful proposal put forward as usual with local councillors who are incompetent and generally ignorant of the first principals of planning. The major one of these is from time immemorial, is NEED. Do we need more houses here in Grange: the answer is patently obvious. NO. Leave us alone.
I will appeal against any arbitrary behaviour by the LPA @ SLDC to the Government.
Stop treating us like morons that know nothing.
We do not need 386 new dwellings on the green belt land and least of all Kents Bank. the site by the deregistration sign, just past Cardrona Road belongs to the last house on the main road on the west side. Lloyd Sanders is a builder and just wants money, which he does not need. That is agricultural land, a green belt, the same as all land to Allithwaite.
Reference: I have been involved with planners in local government all my life. In the oil industry seeking sites for petrol stations. In ??? on all major developments including housing.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Nothing in these proposals is right for Grange-over-Sands. This is a town that has had its maximum develpment inside the green belts.
Not consistent with national green belt policy.
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
Hearing verbal argument is always better than "paper".
224. Mr Alan Easton (Individual) : 10 May 2012 11:21:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA3.1 Mixed Use Allocation at Berners Pool, Grange-over-Sands
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
The DPD has not had regard to the Sustainable Community Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
There is no way SLDC has any right to arbitrarily take over green field sites, where they are clearly green belt. All land from the 30mph derestriction on Allithwaite Road to Allithwaite is Green Belt - leave it alone.Allithwaite and Grange are separate. It cannot be right for proper planning to join them together by building of any kind. It is a disgraceful proposal put forward as usual with local councillors who are incompetent and generally ignorant of the first principals of planning. The major one of these is from time immemorial, is NEED. Do we need more houses here in Grange: the answer is patently obvious. NO. Leave us alone.
I will appeal against any arbitrary behaviour by the LPA @ SLDC to the Government.
Stop treating us like morons that know nothing.
We do not need 386 new dwellings on the green belt land and least of all Kents Bank. the site by the deregistration sign, just past Cardrona Road belongs to the last house on the main road on the west side. Lloyd Sanders is a builder and just wants money, which he does not need. That is agricultural land, a green belt, the same as all land to Allithwaite.
Reference: I have been involved with planners in local government all my life. In the oil industry seeking sites for petrol stations. In ??? on all major developments including housing.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Nothing in these proposals is right for Grange-over-Sands. This is a town that has had its maximum develpment inside the green belts.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
Hearing verbal argument is always better than "paper".
225. Mr Alan Easton (Individual) : 10 May 2012 11:24:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA3.2 Mixed Use Allocation at Land South of Allithwaite Road, Kent's Bank, Grange-over-Sands
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
The DPD has not had regard to the Sustainable Community Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
There is no way SLDC has any right to arbitrarily take over green field sites, where they are clearly green belt. All land from the 30mph derestriction on Allithwaite Road to Allithwaite is Green Belt - leave it alone.Allithwaite and Grange are separate. It cannot be right for proper planning to join them together by building of any kind. It is a disgraceful proposal put forward as usual with local councillors who are incompetent and generally ignorant of the first principals of planning. The major one of these is from time immemorial, is NEED. Do we need more houses here in Grange: the answer is patently obvious. NO. Leave us alone.
I will appeal against any arbitrary behaviour by the LPA @ SLDC to the Government.
Stop treating us like morons that know nothing.
We do not need 386 new dwellings on the green belt land and least of all Kents Bank. the site by the deregistration sign, just past Cardrona Road belongs to the last house on the main road on the west side. Lloyd Sanders is a builder and just wants money, which he does not need. That is agricultural land, a green belt, the same as all land to Allithwaite.
Reference: I have been involved with planners in local government all my life. In the oil industry seeking sites for petrol stations. In ??? on all major developments including housing.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Nothing in these proposals is right for Grange-over-Sands. This is a town that has had its maximum develpment inside the green belts.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
Hearing verbal argument is always better than "paper".
226. Mr Alan Easton (Individual) : 10 May 2012 11:25:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA3.3 Mixed Use Allocation at Guide's Lot, Grange-over-Sands
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
The DPD has not had regard to the Sustainable Community Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
There is no way SLDC has any right to arbitrarily take over green field sites, where they are clearly green belt. All land from the 30mph derestriction on Allithwaite Road to Allithwaite is Green Belt - leave it alone.Allithwaite and Grange are separate. It cannot be right for proper planning to join them together by building of any kind. It is a disgraceful proposal put forward as usual with local councillors who are incompetent and generally ignorant of the first principals of planning. The major one of these is from time immemorial, is NEED. Do we need more houses here in Grange: the answer is patently obvious. NO. Leave us alone.
I will appeal against any arbitrary behaviour by the LPA @ SLDC to the Government.
Stop treating us like morons that know nothing.
We do not need 386 new dwellings on the green belt land and least of all Kents Bank. the site by the deregistration sign, just past Cardrona Road belongs to the last house on the main road on the west side. Lloyd Sanders is a builder and just wants money, which he does not need. That is agricultural land, a green belt, the same as all land to Allithwaite.
Reference: I have been involved with planners in local government all my life. In the oil industry seeking sites for petrol stations. In ??? on all major developments including housing.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Nothing in these proposals is right for Grange-over-Sands. This is a town that has had its maximum develpment inside the green belts.
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
Hearing verbal argument is always better than "paper".
227. Mr Alan Easton (Individual) : 14 May 2012 09:06:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - R672M GRANGE-OVER-SANDS WEST OF CARDRONA ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
The DPD has not had regard to the Sustainable Community Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
There is no way SLDC has any right to arbitrarily take over green field sites, where they are clearly green belt. All land from the 30mph derestriction on Allithwaite Road to Allithwaite is Green Belt - leave it alone.Allithwaite and Grange are separate. It cannot be right for proper planning to join them together by building of any kind. It is a disgraceful proposal put forward as usual with local councillors who are incompetent and generally ignorant of the first principals of planning. The major one of these is from time immemorial, is NEED. Do we need more houses here in Grange: the answer is patently obvious. NO. Leave us alone.
I will appeal against any arbitrary behaviour by the LPA @ SLDC to the Government.
Stop treating us like morons that know nothing.
We do not need 386 new dwellings on the green belt land and least of all Kents Bank. the site by the deregistration sign, just past Cardrona Road belongs to the last house on the main road on the west side. Lloyd Sanders is a builder and just wants money, which he does not need. That is agricultural land, a green belt, the same as all land to Allithwaite.
Reference: I have been involved with planners in local government all my life. In the oil industry seeking sites for petrol stations. In ??? on all major developments including housing.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Nothing in these proposals is right for Grange-over-Sands. This is a town that has had its maximum develpment inside the green belts.
Not consistent with national green belt policy.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
Hearing verbal argument is always better than "paper".
228. Mr Christopher Eckersley (Individual) : 19 Apr 2012 12:16:00
Paragraph No.
0.0 Whole Document
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
There are many and varied flaws in this plan however in this letter I wish to concentrate attention on the soundness of the DPD.
My objections to the soundness of the Land Allocation DPD can be summarised as follows:
1. Elements of the plan do not comply with SLDC's own Core Strategy Document 2010 in
relation to the need to maintain green gaps and distinctions between existing settlements
2. The Land Allocation DPD is based on population growth estimates which are not
credible.
3. Public consultation has not been adequate and serious concerns raised by residents in
relation to specific developments (e.g. Allithwaite Road in Grange) have been ignored.
4. The plan does not .consider the impact on the largely tourism-based economy of the South Lakes in general and Grange-over-Sands in particular
5. The plan does not explore alternative options for the supposed need for 'affordable'
housing other than that provided by private sector development on green field sites. For example there are existing council-owned brown field sites which could be developed
before there is any need to develop green gaps.
I have many other objections to SLDC's plans for the development of housing in South Lakeland and Grange-over-Sands, so the above list is far from exhaustive, however, as stated I wish to limit my points in this letter to those objections which are based on failure in procedure by SLDC and as such warrant further, adequate, public consultation.
229. Mr Christopher Eckersley (Individual) : 19 Apr 2012 12:22:00
Policy/Site No.
LA1.3 Housing Allocations - All Grange-over-Sands sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
My objections to the soundness of the Land Allocation DPD can be summarised as follows:
1. Elements of the plan do not comply with SLDC's own Core Strategy Document 2010 in
relation to the need to maintain green gaps and distinctions between existing settlements.
2. The Land Allocation DPD is based on population growth estimates which are not
credible.
3. Public consultation has not been adequate and serious concerns raised by residents in
relation to specific developments (e.g. Allithwaite Road in Grange) have been ignored.
4. The plan does not consider the impact on the largely tourism-based economy of the South Lakes in general and Grange-over-Sands in particular
Contrary to SLDC's stated policy there has not been sufficient sustainability analysis for
the proposed sites in Grange-over-Sands and allocations do not comply with SLDC' s
stated policy.
230. Mr Christopher Eckersley (Individual) : 19 Apr 2012 12:24:00
Policy/Site No.
LA3.1 Mixed Use Allocation at Berners Pool, Grange-over-Sands
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
My objections to the soundness of the Land Allocation DPD can be summarised as follows:
1. Elements of the plan do not comply with SLDC's own Core Strategy Document 2010 in
relation to the need to maintain green gaps and distinctions between existing settlements.
2. The Land Allocation DPD is based on population growth estimates which are not
credible.
3. Public consultation has not been adequate and serious concerns raised by residents in
relation to specific developments (e.g. Allithwaite Road in Grange) have been ignored.
4. The plan does not consider the impact on the largely tourism-based economy of the South Lakes in general and Grange-over-Sands in particular
Contrary to SLDC's stated policy there has not been sufficient sustainability analysis for
the proposed sites in Grange-over-Sands and allocations do not comply with SLDC' s
stated policy.
231. Mr Christopher Eckersley (Individual) : 19 Apr 2012 12:26:00
Policy/Site No.
LA3.2 Mixed Use Allocation at Land South of Allithwaite Road, Kent's Bank, Grange-over-Sands
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
My objections to the soundness of the Land Allocation DPD can be summarised as follows:
1. Elements of the plan do not comply with SLDC's own Core Strategy Document 2010 in
relation to the need to maintain green gaps and distinctions between existing settlements.
2. The Land Allocation DPD is based on population growth estimates which are not
credible.
3. Public consultation has not been adequate and serious concerns raised by residents in
relation to specific developments (e.g. Allithwaite Road in Grange) have been ignored.
4. The plan does not consider the impact on the largely tourism-based economy of the South Lakes in general and Grange-over-Sands in particular
Contrary to SLDC's stated policy there has not been sufficient sustainability analysis for
the proposed sites in Grange-over-Sands and allocations do not comply with SLDC' s
stated policy.
232. Mr Christopher Eckersley (Individual) : 19 Apr 2012 12:27:00
Policy/Site No.
LA3.3 Mixed Use Allocation at Guide's Lot, Grange-over-Sands
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
My objections to the soundness of the Land Allocation DPD can be summarised as follows:
1. Elements of the plan do not comply with SLDC's own Core Strategy Document 2010 in
relation to the need to maintain green gaps and distinctions between existing settlements.
2. The Land Allocation DPD is based on population growth estimates which are not
credible.
3. Public consultation has not been adequate and serious concerns raised by residents in
relation to specific developments (e.g. Allithwaite Road in Grange) have been ignored.
4. The plan does not consider the impact on the largely tourism-based economy of the South Lakes in general and Grange-over-Sands in particular
Contrary to SLDC's stated policy there has not been sufficient sustainability analysis for
the proposed sites in Grange-over-Sands and allocations do not comply with SLDC' s
stated policy.
233. Mr Christopher Eckersley (Individual) : 9 May 2012 11:16:00
Paragraph No.
1.9
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Public consultation has not been adequate and serious concerns raised by residents in
relation to specific developments (e.g. Allithwaite Road in Grange) have been ignored.
234. Mr Christopher Eckersley (Individual) : 9 May 2012 11:17:00
Paragraph No.
1.10
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Public consultation has not been adequate and serious concerns raised by residents in
relation to specific developments (e.g. Allithwaite Road in Grange) have been ignored.
235. Ms Elaine Eggleston (Individual) : 27 Apr 2012 10:33:00
Policy/Site No.
LA1.3 Housing Allocations - M41KM KENDAL SOUTH OF LUMLEY ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Loss of green field space is detrimental to the character and heritage of the area. This is contrary to Coalition Government Sustainable Development Policy, which recognizes brown field preference above important countryside areas. The Soundness and legality of the plan is therefore challenged as being contrary to Government Planning Policy.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I wish to object to and challenge the soundness of proposed land allocation for development – to south of Lumley Rd. (M41KM) and Scroggs Wood Light Industrial Site (E4M) on the following grounds:
- The proposed developments would spoil the initial impression to Kendal visitors, being on the main access route and adjacent to the Town boundary. The Lumley road site is steeply graded and properties would impose on the existing view for Kendal visitors. The line of trees acts as a natural barrier between countryside and properties. Building to the South of this line (E4M), would fundamentally change the Kendal “Gateway to the Lakes” character as a valued landscape. This is contrary to the adopted planning Core Strategy. The Soundness of the plan is therefore challenged on visual impact grounds, contrary to planning policy.
- Loss of green field space is detrimental to the character and heritage of the area. This is contrary to Coalition Government Sustainable Development Policy, which recognizes brown field preference above important countryside areas. The Soundness and legality of the plan is therefore challenged as being contrary to Government Planning Policy.
- Milnthorpe road already backs up to the bypass at peak times and cannot accommodate the massive increase that such development, in these locations, would create. Kendal town development to attract visitors is pointless if they cannot obtain satisfactory access. The associated pollution from stationary traffic is incompatible with sustainable development objectives. The soundness of the development is challenged on the basis that there is no traffic plan to address these issues.
- The A6 is a crucial access for emergency services, particularly following the downgrading of Westmorland General Hospital. Further congestion on this route would introduce undue risk. The potential for accidents when joining the main road would also be significantly increased. The Soundness of the plan is therefore challenged on safety grounds.
- The soundness of the development is challenged on the basis that there is inadequate local infrastructure including drainage, sewerage and roads.
- The proposed development is incompatible with the character of the historic Helsington development contrary to planning policy. The Soundness of the plan is therefore challenged as being detrimental to the historical character of the area.
- The site is clearly NOT “in an accessible location or an easily developable level site” (Achievability statement P133 2 C). The Soundness of the plan is therefore challenged as being contrary to this declared planning statement.
- There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of adequate existing residential space and more suitable alternative development sites
- The Development plan should retain the "Kendal Gateway to the Lakes" image supporting tourism and established Cumbrian employment, not destroy it with unsightly, unnecessary development and traffic jams. You don’t put your wheelie bin on your front door step! The DPD appears to have completely disregarded the massive opposition and valid objections previously made. The soundness of this planned development is challenged as disregarding local opinion contrary to Government Policy.
236. Ms Elaine Eggleston (Individual) : 27 Apr 2012 10:37:00
Policy/Site No.
LA1.6 Strategic Employment Sites - E4M KENDAL LAND AT SCROGGS WOOD, MILNTHORPE ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I wish to object to and challenge the soundness of proposed land allocation for development – to south of Lumley Rd. (M41KM) and Scroggs Wood Light Industrial Site (E4M) on the following grounds:
- The proposed developments would spoil the initial impression to Kendal visitors, being on the main access route and adjacent to the Town boundary. The Lumley road site is steeply graded and properties would impose on the existing view for Kendal visitors. The line of trees acts as a natural barrier between countryside and properties. Building to the South of this line (E4M), would fundamentally change the Kendal “Gateway to the Lakes” character as a valued landscape. This is contrary to the adopted planning Core Strategy. The Soundness of the plan is therefore challenged on visual impact grounds, contrary to planning policy.
- Loss of green field space is detrimental to the character and heritage of the area. This is contrary to Coalition Government Sustainable Development Policy, which recognizes brown field preference above important countryside areas. The Soundness and legality of the plan is therefore challenged as being contrary to Government Planning Policy.
- Milnthorpe road already backs up to the bypass at peak times and cannot accommodate the massive increase that such development, in these locations, would create. Kendal town development to attract visitors is pointless if they cannot obtain satisfactory access. The associated pollution from stationary traffic is incompatible with sustainable development objectives. The soundness of the development is challenged on the basis that there is no traffic plan to address these issues.
- The A6 is a crucial access for emergency services, particularly following the downgrading of Westmorland General Hospital. Further congestion on this route would introduce undue risk. The potential for accidents when joining the main road would also be significantly increased. The Soundness of the plan is therefore challenged on safety grounds.
- The soundness of the development is challenged on the basis that there is inadequate local infrastructure including drainage, sewerage and roads.
- The proposed development is incompatible with the character of the historic Helsington development contrary to planning policy. The Soundness of the plan is therefore challenged as being detrimental to the historical character of the area.
- The site is clearly NOT “in an accessible location or an easily developable level site” (Achievability statement P133 2 C). The Soundness of the plan is therefore challenged as being contrary to this declared planning statement.
- There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of adequate existing residential space and more suitable alternative development sites.
- There is spare capacity and expansion potential on existing established trading estates on Shap Road. The plan to relocate the Rugby club to Oxenholme and development of the Gilkes site are more suited to development than Scroggs Wood. The soundness of the case for such development is challenged on the basis of existing and more suitable alternative development sites compatible with planning policy.
- The Development plan should retain the "Kendal Gateway to the Lakes" image supporting tourism and established Cumbrian employment, not destroy it with unsightly, unnecessary development and traffic jams. You don’t put your wheelie bin on your front door step! The DPD appears to have completely disregarded the massive opposition and valid objections previously made. The soundness of this planned development is challenged as disregarding local opinion contrary to Government Policy.
237. Ms Elaine Eggleston (Individual) : 27 Apr 2012 10:38:00
Policy/Site No.
LA1.3 Housing Allocations - All Kendal sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of adequate existing residential space and more suitable alternative development sites.
238. Ms Elaine Eggleston (Individual) : 27 Apr 2012 10:39:00
Paragraph No.
0.0 Whole Document
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Is there a definition of “affordable housing” in the context of Kendal young person income? Or is this merely a rouse to allow land owners and builders to make massive profits, without any tangible commitment to house the low paid of Kendal? The Soundness is therefore challenged on the basis of no defined affordability test.
239. Ms Elaine Eggleston (Individual) : 27 Apr 2012 10:40:00
Policy/Site No.
LA1.4 - Kendal Sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of adequate existing residential space and more suitable alternative development sites.
240. Mr Quentin Elliott (Individual) : 4 Apr 2012 16:26:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - RN152 GREENODD LAND AT THE OLD VICARAGE
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
1.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
I do not feel myself qualified to determine the legality of the DPD.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I am not sure that the writer of the DPD is even sure which plot RN152 is. The DPD describes it as Oak Vale and the drop down list above describes it as Old Vicarage, both of which are incorrect.
Paragraph 5.65 of DPD wrongly describes RN152 as an 'infill site'. There is no housing outside of this site, only the churchyard.
Paragraph 5.65 of DPD wrongly describes RN152 as 'well located in relation to existing services'. The existing wastewater services are of inadequate capacity, which results in regular blockages and localised flooding of raw sewerage, particularly around Roughlea LA12 7RQ. Also about 1/3rd of the plot is below the level of the highway sewer. The new waste water treatment plant cannot handle the volume after heavy rainfall and would see increased flow if the soakaway effect of RN152 was lost.
Paragraph 5.65 of DPD falsely states that 'mature trees border two sides shielding ... existing dwellings on R291'. The trees end adjacent to the first of the three properties on R291, meaning the development on the hill above them will have a severe impact. The new vicarage is already a gloomy house, without further light deprivation and the Old Stables upper windows will lie below ground level of even the lowest property on RN152. The privacy of householders along High Garth will also be greatly affected. When the Old Vicarage and the Old Stables on R291 were purchased from the Diocese, restrictive covenants were imposed upon the new owners by the Diocese solicitors. These covered not doing anything that would devalue the new vicarage or causing noise that affects the vicarage occupants or services within the church and grounds. How can these conditions be met by a development of 22 houses on RN152.
Paragraph 5.66 of DPD falsely suggests that building on RN152 will 'safeguard the Crakeside Business Park and Crakeside Works as local employment areas'. If businesses on these sites are viable, then they will not fail through lack of housing in Greenodd/Penny Bridge when the 12000 population of Ulverston is only 3 miles away.
I do not believe that there is a need for additional housing in Greenodd/Penny Bridge. There are currently about 13 houses for sale, several empty and others to let, covering all price ranges. A housing survey carried out by the Parish Council only 4 years ago did not identify a need for further homes and gave consideration to the need for affordable homes. The village has already undergone significant expansion in recent years with the building of small housing estates at Ellis Wood and opposite the Ship Inn in Greenodd.
Building in RN152 would cause the loss of the lovely view from the Churchyard across the Crake valley and north to the Coniston hills. The views and the peace and quiet of the Churchyard makes it a special place, not just for Church related activities but also a popular through walking route for the villagers. As such, I believe that RN152 is an asset of community value as described in the Localism Act 2011 and I will encourage the Parish Council to have it listed.
Other factors make RN152 unsuitable as a building plot :
RN152 itself has a soft area at the highest point where underground water comes to the surface. After heavy rainfall water collects at the lowest part of the plot NE corner). With the loss of soakaway, caused by all the resultant hard paved areas of a new development, the potential for flooding of the R291 houses will be significant. Indeed, when the new vicarage was built in this area in 1990, the foundations had to be taken down about 3 metres to reach hard ground.
The Church has a soakaway toilet that drains into RN152. This would require alteration.
Since the houses at Ellis Wood were built (across the road from RN152) there has been continual road subsidence, thought to be caused by underground aquifers. This would require fault investigation and correction before any further building work could proceed.
Building on this farmland would contribute to potential loss of local employment. The land has been tenant farmed by the same family for about 80 years. The farm is not large, reducing the acreage further could make it unviable.
The Churchyard has a magnificent avenue of mature Beech trees that run alongside the southern boundary of RN152. It would be unsafe to build under these large trees as the prevailing wind direction means a fall would land in RN152. There are further random mature trees along this boundary. Excavation works in RN152 would have great potential to damage the root systems, causing their premature demise or making them unsafe. To avoid the graves within the churchyard and the roots of the Beech avenue, the church heating oil supply runs underground through RN152. This would not be easy to relocate.
Access and parking within the village is poor, frequently with both sides of the roads nose to tail with parked cars, such that a large vehicle such as a fire engine could not get through. Development of 22 houses on RN152 would significantly increase this vehicle load on the village. The road adjacent to RN152 is also used for parking for church services. On occasions such as weddings and funerals with a large congregation there would be severe problems.
The number of pupils on roll at the village school has exceeded its nominal capacity for about the last 10 years. There is not a need to build additional housing to provide support against falling pupil numbers, as is the case in some other villages e.g. Coniston.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
241. Mr Quentin Elliott (Individual) : 11 May 2012 16:50:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
5.65
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
1.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
I do not feel myself qualified to determine the legality of the DPD.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I am not sure that the writer of the DPD is even sure which plot RN152 is. The DPD describes it as Oak Vale and the drop down list above describes it as Old Vicarage, both of which are incorrect.
Paragraph 5.65 of DPD wrongly describes RN152 as an 'infill site'. There is no housing outside of this site, only the churchyard.
Paragraph 5.65 of DPD wrongly describes RN152 as 'well located in relation to existing services'. The existing wastewater services are of inadequate capacity, which results in regular blockages and localised flooding of raw sewerage, particularly around Roughlea LA12 7RQ. Also about 1/3rd of the plot is below the level of the highway sewer. The new waste water treatment plant cannot handle the volume after heavy rainfall and would see increased flow if the soakaway effect of RN152 was lost.
Paragraph 5.65 of DPD falsely states that 'mature trees border two sides shielding ... existing dwellings on R291'. The trees end adjacent to the first of the three properties on R291, meaning the development on the hill above them will have a severe impact. The new vicarage is already a gloomy house, without further light deprivation and the Old Stables upper windows will lie below ground level of even the lowest property on RN152. The privacy of householders along High Garth will also be greatly affected. When the Old Vicarage and the Old Stables on R291 were purchased from the Diocese, restrictive covenants were imposed upon the new owners by the Diocese solicitors. These covered not doing anything that would devalue the new vicarage or causing noise that affects the vicarage occupants or services within the church and grounds. How can these conditions be met by a development of 22 houses on RN152.
Paragraph 5.66 of DPD falsely suggests that building on RN152 will 'safeguard the Crakeside Business Park and Crakeside Works as local employment areas'. If businesses on these sites are viable, then they will not fail through lack of housing in Greenodd/Penny Bridge when the 12000 population of Ulverston is only 3 miles away.
I do not believe that there is a need for additional housing in Greenodd/Penny Bridge. There are currently about 13 houses for sale, several empty and others to let, covering all price ranges. A housing survey carried out by the Parish Council only 4 years ago did not identify a need for further homes and gave consideration to the need for affordable homes. The village has already undergone significant expansion in recent years with the building of small housing estates at Ellis Wood and opposite the Ship Inn in Greenodd.
Building in RN152 would cause the loss of the lovely view from the Churchyard across the Crake valley and north to the Coniston hills. The views and the peace and quiet of the Churchyard makes it a special place, not just for Church related activities but also a popular through walking route for the villagers. As such, I believe that RN152 is an asset of community value as described in the Localism Act 2011 and I will encourage the Parish Council to have it listed.
Other factors make RN152 unsuitable as a building plot :
RN152 itself has a soft area at the highest point where underground water comes to the surface. After heavy rainfall water collects at the lowest part of the plot NE corner). With the loss of soakaway, caused by all the resultant hard paved areas of a new development, the potential for flooding of the R291 houses will be significant. Indeed, when the new vicarage was built in this area in 1990, the foundations had to be taken down about 3 metres to reach hard ground.
The Church has a soakaway toilet that drains into RN152. This would require alteration.
Since the houses at Ellis Wood were built (across the road from RN152) there has been continual road subsidence, thought to be caused by underground aquifers. This would require fault investigation and correction before any further building work could proceed.
Building on this farmland would contribute to potential loss of local employment. The land has been tenant farmed by the same family for about 80 years. The farm is not large, reducing the acreage further could make it unviable.
The Churchyard has a magnificent avenue of mature Beech trees that run alongside the southern boundary of RN152. It would be unsafe to build under these large trees as the prevailing wind direction means a fall would land in RN152. There are further random mature trees along this boundary. Excavation works in RN152 would have great potential to damage the root systems, causing their premature demise or making them unsafe. To avoid the graves within the churchyard and the roots of the Beech avenue, the church heating oil supply runs underground through RN152. This would not be easy to relocate.
Access and parking within the village is poor, frequently with both sides of the roads nose to tail with parked cars, such that a large vehicle such as a fire engine could not get through. Development of 22 houses on RN152 would significantly increase this vehicle load on the village. The road adjacent to RN152 is also used for parking for church services. On occasions such as weddings and funerals with a large congregation there would be severe problems.
The number of pupils on roll at the village school has exceeded its nominal capacity for about the last 10 years. There is not a need to build additional housing to provide support against falling pupil numbers, as is the case in some other villages e.g. Coniston.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
242. Mr Quentin Elliott (Individual) : 11 May 2012 16:52:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
5.66
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
1.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
I do not feel myself qualified to determine the legality of the DPD.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I am not sure that the writer of the DPD is even sure which plot RN152 is. The DPD describes it as Oak Vale and the drop down list above describes it as Old Vicarage, both of which are incorrect.
Paragraph 5.65 of DPD wrongly describes RN152 as an 'infill site'. There is no housing outside of this site, only the churchyard.
Paragraph 5.65 of DPD wrongly describes RN152 as 'well located in relation to existing services'. The existing wastewater services are of inadequate capacity, which results in regular blockages and localised flooding of raw sewerage, particularly around Roughlea LA12 7RQ. Also about 1/3rd of the plot is below the level of the highway sewer. The new waste water treatment plant cannot handle the volume after heavy rainfall and would see increased flow if the soakaway effect of RN152 was lost.
Paragraph 5.65 of DPD falsely states that 'mature trees border two sides shielding ... existing dwellings on R291'. The trees end adjacent to the first of the three properties on R291, meaning the development on the hill above them will have a severe impact. The new vicarage is already a gloomy house, without further light deprivation and the Old Stables upper windows will lie below ground level of even the lowest property on RN152. The privacy of householders along High Garth will also be greatly affected. When the Old Vicarage and the Old Stables on R291 were purchased from the Diocese, restrictive covenants were imposed upon the new owners by the Diocese solicitors. These covered not doing anything that would devalue the new vicarage or causing noise that affects the vicarage occupants or services within the church and grounds. How can these conditions be met by a development of 22 houses on RN152.
Paragraph 5.66 of DPD falsely suggests that building on RN152 will 'safeguard the Crakeside Business Park and Crakeside Works as local employment areas'. If businesses on these sites are viable, then they will not fail through lack of housing in Greenodd/Penny Bridge when the 12000 population of Ulverston is only 3 miles away.
I do not believe that there is a need for additional housing in Greenodd/Penny Bridge. There are currently about 13 houses for sale, several empty and others to let, covering all price ranges. A housing survey carried out by the Parish Council only 4 years ago did not identify a need for further homes and gave consideration to the need for affordable homes. The village has already undergone significant expansion in recent years with the building of small housing estates at Ellis Wood and opposite the Ship Inn in Greenodd.
Building in RN152 would cause the loss of the lovely view from the Churchyard across the Crake valley and north to the Coniston hills. The views and the peace and quiet of the Churchyard makes it a special place, not just for Church related activities but also a popular through walking route for the villagers. As such, I believe that RN152 is an asset of community value as described in the Localism Act 2011 and I will encourage the Parish Council to have it listed.
Other factors make RN152 unsuitable as a building plot :
RN152 itself has a soft area at the highest point where underground water comes to the surface. After heavy rainfall water collects at the lowest part of the plot NE corner). With the loss of soakaway, caused by all the resultant hard paved areas of a new development, the potential for flooding of the R291 houses will be significant. Indeed, when the new vicarage was built in this area in 1990, the foundations had to be taken down about 3 metres to reach hard ground.
The Church has a soakaway toilet that drains into RN152. This would require alteration.
Since the houses at Ellis Wood were built (across the road from RN152) there has been continual road subsidence, thought to be caused by underground aquifers. This would require fault investigation and correction before any further building work could proceed.
Building on this farmland would contribute to potential loss of local employment. The land has been tenant farmed by the same family for about 80 years. The farm is not large, reducing the acreage further could make it unviable.
The Churchyard has a magnificent avenue of mature Beech trees that run alongside the southern boundary of RN152. It would be unsafe to build under these large trees as the prevailing wind direction means a fall would land in RN152. There are further random mature trees along this boundary. Excavation works in RN152 would have great potential to damage the root systems, causing their premature demise or making them unsafe. To avoid the graves within the churchyard and the roots of the Beech avenue, the church heating oil supply runs underground through RN152. This would not be easy to relocate.
Access and parking within the village is poor, frequently with both sides of the roads nose to tail with parked cars, such that a large vehicle such as a fire engine could not get through. Development of 22 houses on RN152 would significantly increase this vehicle load on the village. The road adjacent to RN152 is also used for parking for church services. On occasions such as weddings and funerals with a large congregation there would be severe problems.
The number of pupils on roll at the village school has exceeded its nominal capacity for about the last 10 years. There is not a need to build additional housing to provide support against falling pupil numbers, as is the case in some other villages e.g. Coniston.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
243. Mrs Julia Evans (Individual) : 9 Apr 2012 13:06:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - RN117M KENDAL WEST OF VALLEY DRIVE
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
SLDC have not listened to residents concerns. The huge opposition to take away important open space and pasture land speak's for itself.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Brown sites should be used first.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
244. Mr Ian Evans (Individual) : 9 Apr 2012 18:45:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - RN117M KENDAL WEST OF VALLEY DRIVE
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The Land Allocations Document (DPD) is not within the Local Development Scheme and the key stages have not been followed
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
fill in brown sites with affordable housing first,then look to viable alternatives, listen to the people who elected you to office,that should be your priority, not the price of fame.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
listen to the people.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
245. Mr David Evans (Individual) : 15 Apr 2012 20:06:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - M9M2-mod MILNTHORPE NORTH WEST OF MILNTHORPE
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The scale of proposed development is grossly disproportionate to the size of the site in question and would cause unacceptable negative impact on the village landscape.
As an elevated site, the buildings would be highly visible not only from the neighbouring Dallam Chase and Grisleymires Lane but also from Church Street, Kirkgate and the area to the north and west of the village and from Dallam Tower Estate and the area to the south, meaning that the impact would be highly visually intrusive on a wide scale.
The nearby Booths development and the commercial sites next to Houghton's coachworks already detract from the appearance of this corner of the village and more development would only serve to further destroy the character of the village. This area is now over developed! with shops, industrial and commercial buildings and houses.
Access to this site is already a safety issue due to the business traffic via Grisleymires Lane, that includes many large articulated lorries, delivery vehicles to both the coachworks and Booths and nearly completed business park and finally the houses on Dallam Chase. Further development here would serve to exacerbate the problem.
SLDC have already carried out a survey and reported that Grisleymires Lane is NOT CAPABLE of taking any more traffic whether Domestic or Commercial following the recent introduction of a Housing Estate, Industrial Park, new shopping supermarket, existing Factory and farm traffic.
Drainage and sewerage systems are already highly temperamental and placing any number of houses on this site would add further unnecessary pressure.
This greenfield site is also in constant farming use (for the grazing of both cows and sheep and for silage, cut here several times throughout the year) so is already an active working part of the village and necessary to the essential village character of Milnthorpe.
The hedgerows are full of wildlife and are essential for the bats and birds, which nest and feed. It is vital that they remain in place. Surely there are alternative places and empty buildings available for housing without using vital farmland and wildlife habitat.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
246. Mr Ian Evans (Individual) : 18 May 2012 15:07:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
1.10
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The Land Allocations Document (DPD) is not within the Local Development Scheme and the key stages have not been followed
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
fill in brown sites with affordable housing first,then look to viable alternatives, listen to the people who elected you to office,that should be your priority, not the price of fame.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Listen to people.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
247. Mr Richard Evans. (Individual) : 14 Apr 2012 10:16:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA2.3 Land East of Castle Green Road
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The Land Allocations Document (DPD) is not within the Local Development Scheme and the key stages have not been followed
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Site R121M (modified) is not within the development plan boundary as specified on the plans drwn up after the last review about ten year ago. There has been no community approval of plans to develop land outside this boundary. There is no evidence of a need to build 40 unaffordable homes on such a site. There may well be some evidence of a need to build 20 affordable homes but to build three times as many homes as are needed is wholly illogical and unjustified. Building on this site is unsustainable and impractical,
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Kendal does not need that many new homes. It is unreasonable to build three times a s many houses as may be needed. Given that one third of homes are to be affordable, the implication is that you are to spoil three times as much landscape as necessary to fulfil the need. That is totally unsound and illogical. The DRD needs to address the issue of funding to build affordable homes only, without inadvertently developing unaffordable homes.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
We are assured that this Inspection and Planning Decision will be independent of the vested interests of the officers of SLDC. I regret to have to confirm that I do not trust these officers to reflect the wishes of the residents.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
248. Mr Richard Evans. (Individual) : 14 Apr 2012 10:33:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA2.3 Land East of Castle Green Road
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The DPD has not been prepared in accordance with the Town & County Planning Regulations 2004 (as amended)
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
High quality and sustainable development requires that development preserves a clear landscape framework. The DPD has not taken into consideration the fact that site R121 is above the 60m contour in a highly visible location. The green rolling landscape can be seen from the whole of the West side of Kendal, from the main road A684, from the main railway line, from the branch line which conveys thousands of visitors to Windermere and from Castle Green Hotel which is the single most used visitor accommodation in Kendal. It is impossible to build on R121 without destroying this prominent landscape.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
National policy is that developments safeguard landscape. This particular site R121 is so highly visible that it cannot be destroyed. The DPD needs to reflect this fact and to be edited to eliminate such a disastrous proposal. Even a single storey development here would be seen from all over the valley. To build 60 homes on this site would certainly require two storey development, if not three. It is completely unviable.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
I do not trust SLDC to represent the majority view.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
249. Mr Richard Evans. (Individual) : 14 Apr 2012 10:44:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA2.3 Land East of Castle Green Road
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Site R121 cannot legally be developed because it is the habitat of a legally protected species, namely the Great Crested Newt. To include it in the DPD is therefore unsound.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The only way around this would be to apply for a licence to damage and destroy the habitat. This application to English Nature would if successful permit such damage and destruction, which would otherwise be illegal. If the licence were to be granted, there would be a number of conditions attached and these would all have cost implications for the develoopment. Given that the prime objective of the exercise is to build affordable homes, the proposal is unsound.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
I want to be sure that due regard is given to the wishes of the majority.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
250. Mr Richard Evans. (Individual) : 25 Apr 2012 09:12:00
A typed or handwritten document was submitted. This has been scanned and can be downloaded below:
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Policy/Site No.
LA1.3 Housing Allocations - R121M-mod KENDAL EAST OF CASTLE GREEN ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The Land Allocations Document (DPD) is not within the Local Development Scheme and the key stages have not been followed
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
A) the land R121 is outside the development boundary. A new development boundary needs to be democratically agreed.
B) the proposal will not be permitted under the wildlife and countryside act because of great crested newts
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The Great Crested Newt is a remarkable and unusual amphibian which is why it is
protected in law. It is an offence to do anything which damages its chances of successful
breeding. Two surveys have demonstrated a population of newts which inhabit land
identified as Rl21, Rl41, R56 and R677 in the Local Development Plan.
Newts are totally dependent for their survival on wetland for 7 months of the year,
and dry stone territory for 5 months. They inhabit the dry stone walls around the fields
specified above. Consequently it is impossible to develop habitation without either
committing an offence or possessing a licence from DEFRA. Such a licence can permit
activities which would otherwise be unlawful. Licences are only issued when there is an
over-riding justification on the grounds of public safety, public interest and no
alternative.
To propose building on Rl21 and R56 is not enhancing public safety or the public
interest. Furthermore there are many alternative sites for development. Consequently the
proposal is thoroughly undeliverable.
The process of obtaining a licence is also protracted. English Nature publishes
documents detailing the Mitigation Guidelines for Developers. If an application to
develop Rl21 and R56 were made, the law requires satisfactory alternative habitats to be
established in the locality. This is unfeasible. In some locations alternative ponds and
drystone walls can be constructed nearby, but not here in Kendal. There are very few
ponds in Kendal. The fact that this population exists at all is because the pond is well
suited to newts, although isolated from other ponds. It does not have any fish or large
numbers of ducks, unlike many others. Again, it is apparent that the proposal to develop
is illogical and faulty.
I attach your map modified to indicate the extent of the wetland and the wals
which are used by the newts. The wet area is larger than shown on your published maps.
The Development Plan Document omits to consider the implications for this land. The
law rightly exists to protect a vulnerable species and to proceed here is illegal.
This proposal to develop ,Rl21 and R56 is unsound.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
I do not trust SLDC planners to take due account of the majority view
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
251. Mr Richard Evans. (Individual) : 25 Apr 2012 09:19:00
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Paragraph No.
1.10
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The Land Allocations Document (DPD) is not within the Local Development Scheme and the key stages have not been followed
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
A) The land R121 is outside the development boundary. A new development boundary needs to be democratically agreed.
B) The proposal will not be permitted under the wildlife and countryside act because of the great crested newts.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The proposal is undeliverable, unfeasible, illogical and faulty. I attach a letter.
Unsound democracy around R121 Land Allocation
Central government and local government officers tell us that as a society we
need to build ever more houses despite the fact that many existing properties are unused
or underused. In a small community like Kendal the residents are decent people with a
conscience about injustice and disadvantage. Despite this, 95% of those residents believe
there is a right place and a wrong place to build new houses and for some of the more
beautiful locations that means that all but the one or two who seek to gain monetary
advantage object to such building.
So we have a situation where public servants are paid to facilitate the building of
new houses against the wishes of the vast majority who have to live with the
consequences of their endeavours. This is not democracy. As a democratic process it is
completely unrepresentative.
Despite continual objections the SLDC promote such unpopular proposals
through first one, then two, then three phases of "consultation". We the consultants have
expressed our views in no uncertain terms, and still the attack persists. The only defence
we have is to repeatedly reiterate our views. Ultimately it comes down to a decision taken
by an inspector of planning who liaises closely with local authority officials and that is a
further demonstration of an unfair bias.
I do not trust SLDC officers. They are untrustworthy. Councillors are more
likely to make democracy work. Any inspector is faced with a huge volume of objections
for a site such as Rl21, being such a high profile location above the 60m contour on the
extreme edge of town. Please do be sure to inspect all the objections thoroughly,
especially at this, the final stage of a long process.
This letter is not in the format specified for responses but I still expect it to be
studied by the man who makes the final decision.
If you do not undertake an inspection of all the thousands of such objections the
whole process will have been flawed from start to finish. Please do not permit the ship of democracy to be wrecked against the rocks of vested interest.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
I do not trust the SLDC planners to take due account of the majority view.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
252. Mr Richard Evans. (Individual) : 9 May 2012 12:53:00
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I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - R121M-mod KENDAL EAST OF CASTLE GREEN ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The Land Allocations Document (DPD) is not within the Local Development Scheme and the key stages have not been followed
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Site R121M (modified) is not within the development plan boundary as specified on the plans drwn up after the last review about ten year ago. There has been no community approval of plans to develop land outside this boundary. There is no evidence of a need to build 40 unaffordable homes on such a site. There may well be some evidence of a need to build 20 affordable homes but to build three times as many homes as are needed is wholly illogical and unjustified. Building on this site is unsustainable and impractical,
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Kendal does not need that many new homes. It is unreasonable to build three times a s many houses as may be needed. Given that one third of homes are to be affordable, the implication is that you are to spoil three times as much landscape as necessary to fulfil the need. That is totally unsound and illogical. The DRD needs to address the issue of funding to build affordable homes only, without inadvertently developing unaffordable homes.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
We are assured that this Inspection and Planning Decision will be independent of the vested interests of the officers of SLDC. I regret to have to confirm that I do not trust these officers to reflect the wishes of the residents.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
253. Mr Richard Evans. (Individual) : 9 May 2012 12:58:00
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I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - R121M-mod KENDAL EAST OF CASTLE GREEN ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The DPD has not been prepared in accordance with the Town & County Planning Regulations 2004 (as amended)
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
High quality and sustainable development requires that development preserves a clear landscape framework. The DPD has not taken into consideration the fact that site R121 is above the 60m contour in a highly visible location. The green rolling landscape can be seen from the whole of the West side of Kendal, from the main road A684, from the main railway line, from the branch line which conveys thousands of visitors to Windermere and from Castle Green Hotel which is the single most used visitor accommodation in Kendal. It is impossible to build on R121 without destroying this prominent landscape.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
National policy is that developments safeguard landscape. This particular site R121 is so highly visible that it cannot be destroyed. The DPD needs to reflect this fact and to be edited to eliminate such a disastrous proposal. Even a single storey development here would be seen from all over the valley. To build 60 homes on this site would certainly require two storey development, if not three. It is completely unviable.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
I do not trust SLDC to represent the majority view.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
254. Mr Richard Evans. (Individual) : 9 May 2012 13:01:00
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I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - R121M-mod KENDAL EAST OF CASTLE GREEN ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Site R121 cannot legally be developed because it is the habitat of a legally protected species, namely the Great Crested Newt. To include it in the DPD is therefore unsound.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The only way around this would be to apply for a licence to damage and destroy the habitat. This application to English Nature would if successful permit such damage and destruction, which would otherwise be illegal. If the licence were to be granted, there would be a number of conditions attached and these would all have cost implications for the develoopment. Given that the prime objective of the exercise is to build affordable homes, the proposal is unsound.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
I want to be sure that due regard is given to the wishes of the majority.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
255. Mrs Maria Fabrizio (Individual) : 16 Apr 2012 17:49:00
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I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - RN117M KENDAL WEST OF VALLEY DRIVE
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
The DPD has not had regard to the Sustainable Community Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The views of the residents on Valley Drive have not been taken into account during the consultation stages. Our responses to the original consultation on the SLDC web site display an incorrect number of responses received!
RN117M site has not be assessed correctly and there are far too many unknowns for this site to be put forward A full site survey should be have been undertaken and insufficient information has been noted in the emerging options consultation therefore the DPD is not passing the soundness test.
No adequate consideration for the brownfield sites which were originally proposed.
No infrastructure plans have been put in place to deal with the high level of development for such a small site. These include the poor restricted road access from Valley Drive via the cul-de-sacs. There is no transport plan in place.
Sewerage/Surface Water Issues. No information on future investment available.
Electricity North West. No information on future investment available.
Visual Amenity. Response within the emerging option document Appendix 8 (Final Version) state Noted
as a response for loss of open public space. The current properties situated to the EAST of this site and in very close proximity to the proposed development. This would have a serious impact from both a visual/privacy perspective on these properties which would have their living quarters and gardens overlooked by any proposed new development.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
My issues are with the following areas which have not been addressed
No transport delivery plan is in place. Access to this site would be unacceptable as it would have to enter via proposed cul-de-sacs off the main Valley Drive road. These access roads are not large enough to cope with the sheer level of traffic which would enter these small areas. Residents currently have problems trying to get out of these access roads due to the heavy traffic on this road! An accident waiting to happen.
Noise and pollution issues would also be a major factor.
No certainty over the future investment by United Utilities. In respect to the sewerage/flood issues which relate to the site.
No information available from Electricity North West with regards to the Pylons/Telegraph poles that are currently situated on this proposed site.
This site is not flat in nature as described in the emerging options fact file. It is steep and sloping and would be difficult to access as there is a public footpath which crosses the proposed site. There is also a bridleway which crosses though the middle of this site. The stone walls would have to be removed and the loss of recreational land which is used by many to enjoy in this built up area due to over development over the last two decades. The last piece of green space between the Castle and Oxenholme! The loss of visual amenity would be drastic to this area and would be seen from the castle and other places of interest. The properties to the EAST would be overlooked and their loss of visual impact/privacy would be a major factor.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
Further clarification is required on the number of issues which are outstanding. There are too many areas within Appendix 8 Emerging options document which have not been addressed and have been passed off with a NOTED comment.
The DPD is not sound and should not be approved until a viable infrastructure plan is put in place.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
256. Mr David Fairs (Individual) : 26 Apr 2012 13:27:00
Policy/Site No.
LA1.3 Housing Allocations - M41KM KENDAL SOUTH OF LUMLEY ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I wish to object to and challenge the soundness of proposal 2C – Land to south of Lumley Rd. and Scroggs Wood Light industrial Site on the following grounds:
- Inadequate local infrastructure including schools, health care, sewerage and roads.
- Milnthorpe road already backs up to the bypass at peak times and cannot accommodate the massive increase that such development, in these locations, would create. Kendal town development to attract visitors is pointless if they cannot obtain satisfactory access. The associated pollution from stationary traffic is incompatible with sustainable development objectives. The soundness of the development is challenged on the basis that there is no traffic plan to address these issues.
- The A6 is a crucial access for emergency services, particularly following the downgrading of Westmorland General Hospital. Further congestion on this route would introduce undue risk. The Soundness of the plan is therefore challenged on safety grounds. To South Lakeland District Council, Development Strategy Team, South Lakeland House, Lowther Street, Kendal, LA9 4UD
- The proposed 2C developments would spoil the initial impression to Kendal visitors, being on the main access route and adjacent to the Town boundary. The Lumley road site is steeply graded and properties would impose on the existing views for existing residents and visitors. The line of trees acts as a natural barrier to the Bellingham Estate. Building to the South of this line would fundamentally change the Kendal “Gateway to the Lakes” character. The Soundness of the plan is therefore challenged on visual impact grounds.
- Loss of green field space is detrimental to the character of the area and contrary to Coalition Government Sustainable Development Policy, which recognizes brown field preference. The Soundness of the plan is therefore challenged as being contrary to Government Planning Policy.
- The proposed mixed use development is incompatible with the character of the historic Helsington development and other existing properties. The Soundness of the plan is therefore challenged as being detrimental to the historical character of the area.
- The site is clearly NOT “in an accessible location or an easily developable level site” (Achievability statement P133 2 C). The Soundness of the plan is therefore challenged as being contrary to this declared planning statement.
- There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of existing residential space and more suitable alternative development sites.
- The Development plan should retain the "Kendal Gateway to the Lakes" image supporting tourism and established Cumbrian employment, not destroy it with unsightly, unnecessary development and traffic jams. You don’t put your wheelie bin on your front door step. I have an alternative suggestion for this site – why not continue its use as sheep farming land?
257. Mr David Fairs (Individual) : 26 Apr 2012 14:44:00
Policy/Site No.
LA1.6 Strategic Employment Sites - E4M KENDAL LAND AT SCROGGS WOOD, MILNTHORPE ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I wish to object to and challenge the soundness of proposal 2C – Land to south of Lumley Rd. and Scroggs Wood Light industrial Site on the following grounds:
- Inadequate local infrastructure including schools, health care, sewerage and roads.
- Milnthorpe road already backs up to the bypass at peak times and cannot accommodate the massive increase that such development, in these locations, would create. Kendal town development to attract visitors is pointless if they cannot obtain satisfactory access. The associated pollution from stationary traffic is incompatible with sustainable development objectives. The soundness of the development is challenged on the basis that there is no traffic plan to address these issues.
- The A6 is a crucial access for emergency services, particularly following the downgrading of Westmorland General Hospital. Further congestion on this route would introduce undue risk. The Soundness of the plan is therefore challenged on safety grounds. To South Lakeland District Council, Development Strategy Team, South Lakeland House, Lowther Street, Kendal, LA9 4UD
- The proposed 2C developments would spoil the initial impression to Kendal visitors, being on the main access route and adjacent to the Town boundary. The Lumley road site is steeply graded and properties would impose on the existing views for existing residents and visitors. The line of trees acts as a natural barrier to the Bellingham Estate. Building to the South of this line would fundamentally change the Kendal “Gateway to the Lakes” character. The Soundness of the plan is therefore challenged on visual impact grounds.
- Loss of green field space is detrimental to the character of the area and contrary to Coalition Government Sustainable Development Policy, which recognizes brown field preference. The Soundness of the plan is therefore challenged as being contrary to Government Planning Policy.
- The proposed mixed use development is incompatible with the character of the historic Helsington development and other existing properties. The Soundness of the plan is therefore challenged as being detrimental to the historical character of the area.
- The site is clearly NOT “in an accessible location or an easily developable level site” (Achievability statement P133 2 C). The Soundness of the plan is therefore challenged as being contrary to this declared planning statement.
- There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of existing residential space and more suitable alternative development sites.
- There is spare capacity and expansion potential on existing established trading estates on Shap Road. The plan to relocate the Rugby club to Oxenholme and development of the Gilkes site are more suited to development than Scroggs Wood. The soundness of the case for such development is challenged on the basis of existing and more suitable alternative development sites.
- What and where is the business case and demand for a further speculative light industrial business park? Why would UK businesses move to such a park when financial assistance and tax breaks are available for designated City areas such as the Manchester Enterprise Zone? The soundness of this planned development is challenged on the basis of no demand or business case.
- The Development plan should retain the "Kendal Gateway to the Lakes" image supporting tourism and established Cumbrian employment, not destroy it with unsightly, unnecessary development and traffic jams. You don’t put your wheelie bin on your front door step. I have an alternative suggestion for this site – why not continue its use as sheep farming land?
258. Mr David Fairs (Individual) : 26 Apr 2012 14:47:00
Policy/Site No.
LA1.3 Housing Allocations - All Kendal sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of existing residential space and more suitable alternative development sites.
259. Mr David Fairs (Individual) : 26 Apr 2012 14:48:00
Paragraph No.
0.0 Whole Document
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Is there a definition of “affordable housing” in the context of Kendal young person income? Or is this merely a rouse to allow land owners and builders to make massive profits, without any tangible commitment to house the low paid of Kendal? The Soundness is therefore challenged on the basis of no defined affordability test.
260. Mr David Fairs (Individual) : 26 Apr 2012 14:50:00
Policy/Site No.
LA1.4 - Kendal Sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
- There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of existing residential space and more suitable alternative development sites.
261. Mr Michael Fennell (Individual) : 27 Apr 2012 14:57:00
A typed or handwritten document was submitted. This has been scanned and can be downloaded below:
Policy/Site No.
LA1.3 Housing Allocations - R121M-mod KENDAL EAST OF CASTLE GREEN ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
May i begin by saying that I am very disappointed that the Government Inspector will not be reading my earlier submissions, as (like many other residents) I have spent a lot of time and effort in preparing them. I feel it necessary to refuse to fill in the latest SLDC form because of its impenetrable jargon and many residents feel that it is totally baffling.
I have already pointed out in my earlier submissions the devastating impact that this
development would have on such a beautiful landscape, on the Great Crested Newts' terrestrial
habitats, on the biodiversity of the area, the serious impact of flooding, and the increase of traffic
and air pollution. I believe that SDLC's land allocations plan is 'unsound ' for various reasons:
It is important to remind you that Great Crested Newts are strictly protected under the Wildlife &
Countryside Act 1981. It is currently an offence under both UK and European Legislation to
intentionally or recklessly kill, injure, take, or recklessly damage, destroy or obstruct access to
places of shelter or protection used by them, this includes their breeding ponds as well as
terrestrial habitats. Eight months of the year adult Great Crested Newts live out of the pond
and live in the landscape and its surrounds. They range over a wide area in search of shelter,
prey, and new breeding sites. They have been spotted in gardens on Oak Tree Road and
Rowan Tree Crescent indicating a wildlife corridor which covers a wide area.
In certain circumstances the presence of Great Crested Newts within 500 metres of a
proposed development can result in severe planning constraints and considerable
expense to progress building projects. The impact of a housing development would mean a
loss of the terrestrial habitat, particularly those close to the breeding pond can be very
damaging. The main effect of habitat loss is reduction in population size, through reduced
refuge opportunities leading to exposure to predators or harsh conditions, and unsuccessful
hibernating populations may go extinct where there is a major loss of terrestrial habitat.
The OS map that SDLC are currently working with is wrong and unreliable as it shows the
pond as much smaller than in reality (see photograph 1). The pond runs along the length of the
field {R677) and is much larger than on the OS map (see Goog!e Earth photograph 2}. This soft
marsh area from the pond overspills into fields R56 and particularly R141. R141, in particular,
has a soft marsh area which extends from the pond in the north end, well into R141 (see
photographs 3 and 4). This soft marsh area is an extension of the pond and is used by the
Great Crested Newts as an Emergence Zone, and is vital to their survival and existence. The
pond has long been established and is shown on an 1867 Kendal map, making it 145 years old,
and is likely to be older.
Before applying for planning permission, an appraisal of the impact of development on the Great
Crested Newt population is required. The Inspector should request a correct map from the LPA,
correctly labelled plan/diagram, (including also the old established orchard at the top of R56).
The LPA should also provide the Inspector with a supplementary map showing the extent of the
original site, R56, R141, R121, R677K, R676KE (with contours).
In the South Lakeland Core Strategy DPD, Inspector's Report August 2010, he stated:
Biodiversity and Geodiversity. The aims of policy CS8.4 to protect
the extensive and wide ranging Biodiversity and Geodiversity value of
the area are widely supported. However, Cumbria County Council
pointed to the need for policy to refer explicitly to the evolving
Cumbria Biodiversity Action Plan. The latter includes the need to
protect but also to restore and enhance valued habitats and
features. The District Council agreed and a series of agreed changes
are proposed. This would be consistent with National Policy and
International obligations.
R56 has a group of mature fruit trees that must have been an orchard at one time; it is still a
significant landscape feature, especially in Spring when the trees are in blossom. There is still
vestiges of a stone wall surrounding this orchard suggesting that it must have been protected
(see photograph 5). The beauty of the site is unquestionable (see photographs 6 & 7). It is
there for everyone to enjoy whether walking or driving in or out of town. We need green spaces
like this for our sense of well-being and for our sense of being uplifted by what we visually see.
Historically, Kendal is a market town nestled in a valley with surrounding fells, agricultural land
and woodlands, which makes it extremely attractive for its inhabitants and visitors alike. It is
important that Kendal does not lose areas of natural beauty like this, that it retains its classical
rural 'market town' character without endless housing sprawl
SLDC also accepted the Gillespie Report as sound, but it was unsound due to the fact that
certain gardens on Sedbergh Road were included and put forward as proposals/allocations for
consultation, as was the field with the pond (R677K).
The first time that the Planner responsible for developments in Kendal set foot on the site, was
on 22nd July 2011 and that was because I telephoned Damian Law to invite him to meet Solek
committee members and show him around the site. Astonishingly, as I have stated, this was the
first time that he had walked and looked at the landscape in detail. He had viewed the site from
the road previously. This beggars belief! How can a planner make such a major decision (that
will destroy a beautiful site forever), in such a cavalier fashion. This is in direct opposition to
what is stated in the DPD dated 30th September, 2008:
Policy EM 1: Integrated Enhancement and Protection of the Region's Assets
The Region's environmental assets should be identified, protected, enhanced and
managed. Recognises the need to deliver an integrated approach to conserving
and enhancing the landscape, natural environment, historic environment and
woodlands of the region.
Plans and strategies should define spatial objectives and priorities for conservation
restoration and enhancement as appropriate, and provide area-based guidelines
to direct decisions and. target resources. These will be founded on a sound
understanding of the diversity, distinctiveness, significance and sensitivity of the
region's environmental assets, and informed by sub-regional environmental
frameworks.
This all sounds very worthy and well thought out. But in reality SLDC is clearly making
uninformed and unsound decisions as they are blatantly unfamiliar with the R121 M site.
SLDC choose to ignore previous planning history, advice given by the Government Inspector in
1997, to ignore SOLEK members, to ignore what the local residents wish, and to ignore the
Report from Friends of the Lake District (CPRE) as part of their evidence base (March/April
2011). The Friends of the Lake District stated that R121M should not be developed, that being
in conflict with RSS Policy Em1, saved Structure Plan Policy E37, Core Strategy Policy 8.2 and
PPS7. And again SLDC choose to ignore the Kendal level Local Landscape Report
commissioned by Kendal Town Council as further evidence base.
The site has been put forward by the strategy team but has not been put before the relevant
planning committees for assessment (common to all sites). Indeed R121M was judged so
negatively for development in SLDC's original site notes that it was astounding to see "it put
forward for development (Land Allocations Development Plan Document).
In recent correspondence with the Right Honourable Greg Clark MP (Planning Minister),
regarding the draft National Planning Policy Framework he states:
In the draft, the Coalition Government is totally committed to protecting our natural
and historic environment. Planning decisions should not only protect, but,
wherever possible, enhance biodiversity and improve people's access to our
natural heritage. The framework explicitly attaches great importance to Green Belts
in safeguarding the countryside from encroachment and checking the
unrestricted sprawl of large built-up areas. It also directly states that local plans
should minimise adverse effects on the local or natural environment. Further, it
safeguards national protection such as Areas of Outstanding Natural Beauty and
Sites of Special Scientific Interest, as well as ensuring measures which protect
wildlife, biodiversity, cultural heritage and which tackle light pollution. It also
proposes a new designation for communities to protect local green areas of
particular importance to them.
Before the last election, the Conservatives promised to empower local people to "specify what
kind of development and use of land they want to see in their areas". From the high volume of
opposition letters to house building on green-field sites on SLDC's website, it is crystal clear what
the local community want. Approximately 400 people were against the development of R 121M
and 2 in favour. According to the Westmorland Gazette, the official line expressed by SLDC is
that they disregard objections from residents who are affected by the developments. This
admission is quite extraordinary. Why ask us to send in submissions if they are going to ignore
us? Surely community involvement means listening, debating and even modifying plans. The
overall majority want to save our green-field sites because they are so special, environmentally,
historically and culturally, as well as of intrinsic value to our health and wellbeing. As Greg Clark
MP states in his letter "National Planning Policy will help ensure that planning decisions reflect
local communities' vision of their future".
May I draw your attention to the Inspector's Report written in 1997, and referring to this area,
made clear points that are just as valid today. He stated that:
The allocation site has a visual quality of some importance in the local
landscape which outweighs the very small contribution which it can make
to the housing land need.
Any argument that there is already existing developments at Oak Tree Road/Rowan Tree
Crescent with landfill between the farmstead conversions at Castle Green Lane (formally Castle
Green Farm), the Inspector finds unconvincing. The older traditional buildings with rural
character blend into the landscape, but the houses at Oak Tree Road appear a "visually
intrusive -element in the rising landscape".
Subsequently he concludes:
The allocation site (R56) provides an important visual buffer between these
distinct locations and that the sites’ value in landscape terms is sufficient
to outweigh its value as a housing allocation.
Taking the past findings into consideration further possible development into the fields beyond
would be even more visually intrusive for an Inspector with concerns. But SLDC have refused
to take into account the previous planning history and landscape designations of the site. Their
Core Strategy policies on green infrastructure, green corridors, watercourses and open spaces
(CS8.1) and landscape settlement character (CS8.2) are not being adhered to.
SLDC's Local Plan 2006 stated that 'development of higher hillsides further east (of R56} w01.1\d
be unduly prominent' Section 6.3 Visual Amenity. And R121 and R141 were deemed worthy
of County Landscape designation in 1999. The Kendal Local Level Landscape Character
Assessment commissioned by Kendal Town Council on 4th April 2011, corroborates all the
points I have made above. K.T.C. has supported the view that R121M should not be developed.
R121M was identified as of medium/high sensitivity due to its biodiversity and rural environment,
and that it would be adversely affected by development. Again SLDC did not accept as part of
their evidence base the independent Landscape Character Assessment (Galpin Landscape
Architect). The brief was looked at and approved by the Strategy Team Manager. Galpin stated
that of the 19 possible development sites in Kendal R 121M was the most sensitive (high) in
landscape terms and with low capacity for development .
Another glaring example of SLDC's insensitive and erratic approach to planning of R121M is
their indecisiveness as to where the road should be built. The road (with lighting etc.) will come
from Oak Tree Road or from Castle Green Road, which will scar this most highly sensitive area
(R56 and R 141) in order to allow access to R 121, which was worthy of County Landscape
designation in 1999. A road through here would have a devastating impact on the Great
Crested Newts' terrestrial habitats . SLDC would be acting illegally as this would contravene
the 1981 Wildlife and Countryside Act and the Conservation (Natural Habitats &c.) Regulations
1994 (as amended). Also Oak Tree Road was their preferred option as regards access to the
site (Highways access/safety (Appendix 8 page 11 0), but unbelievably no-one had measured the
width of Oak Tree Road. The last survey of Castle Green Road was done three years ago.
Traffic on Castle Green Road in the last three years has changed dramatically and for the
worse, as it is heavily congested. How can SLDC allow this development to go ahead when
they are also breaking the law regarding air quality? Air pollution is a major problem in Kendal
and monitoring has shown that there are high levels of Nitrogen Dioxide across the town due to
road traffic emissions. Air pollution from road vehicles causes the most damage to health.
Nitrogen dioxide affects asthmatics and reduces the lung defences against infection.
Rachel Shaw (Environmental Protection Officer, SDLC) informed the Kendal Town Council on
the 5th September, 2011, that there was an action plan in place, but it was more like a wish list.
Surely this is a contradiction in terms and clearly suggests that nothing is being done to reduce
air pollution. This admission shows that SDLC are acting illegally and have not been sufficiently
robust in tackling this major problem. They have failed miserably to reduce levels of Nitrogen
Dioxide, in fact, in the last three years it has got much worse. Rachel Shaw also admitted that
150 households located in the most polluted areas of Kendal are at serious risk. SDLC have
failed to consider the well-being and health of existing residents
In the light of this exposure, SLDC must seriously reconsider this development at R1 M1, which
potentially means 60 cars, possibly 1 00 plus. The increase of cars along Castle Green Lane
and Parkside Road will significantly exacerbate the already high levels of Nitrogen Dioxide. This
development of housing will also significantly alter flows or speeds on already busy, congested
roads and increase the volume of traffic, causing bottlenecks and tailbacks. An extract from
SDLC document "Kendal Transport Study (Jan 15) pdf
"6.1.6 Furthermore, even with the implementation of these improvement
schemes, it is important to note that a large proportion of the key junctions
would continue to operate above capacity, and therefore experience
congestion and extensive queuing in the 2022 base situation. This
situation would be compounded by the LDF development traffic".
The Council has failed to implement an infrastructure delivery plan, a transport plan or an air
quality plan to meet the scale of developments proposed. The vision (South Lakeland Core
Strategy) states that in "2025 Kendal will.. .. was a pipe-dream in 2010 and 2 years later still is a
pipe-dream and we have no concrete ideas as to how we will get there.
SLDC summarily dismissed the Town Council's views about the importance of the approaches
to Kendal (2009). They also dismissed the Town Council's submission (Sustainable
Development in Kendal) based (2011) on the Taylor Review. The Planner whom we met on
22nd July 2011 to show around the site, had not heard of Taylor. The Greater Norwich
Development Plan Partnership has serious legal difficulties because they had failed to look
at/assess properly alternative approaches/strategies. SLOG's response is unsound, and
illustrates poor or little strategic thinking, and the land allocations were originally done before the
Core Strategy was in place. The CCC Local Area Committee recommended, (with no votes
against) that SLDC adopt an approach similar to that of Taylor and The Town Council. In their
strategy document back in April 2008, SLDC did not indicate the land between Castle Green
Road and the Sedbergh Road area for development.
It is also important to point out that that the number of houses needed in South Lakeland is now
running annually at 205 and not 400 (Strategic Housing Market Assessment - October 2011 ),
and there has been no appropriate adjustment to this fact. Councillor Peter Thornton (Portfolio
Holder for Housing) mentioned in his 'webchat' with the Westmorland Gazette (22nd March ~
2011 ), the non-availability of sites in this area, but surely the opposite is true -that there is an 2-
over-availability of sites. As Portfolio Holder for Housing, Mr. Thornton was asked if it was true
that there are 1,000 properties lying empty in Kendal, to which he replied:
" I don't have the exact figures with me but I know that there are too
many empty homes in our area ... but the large number of empty
homes at present is due to the slump in the housing market and
limited availability of finance".
And when asked if the new K Village apartments were lying empty, he stated:
" (I am) not sure of the situation with the new K Village apartments but
if some are empty it will be because the market is flat at the
moment."
Considering this new complex cost a staggering one hundred million pounds and has proved to
be a white elephant, you would expect Mr. Thornton to have found out exactly how many empty
properties are lying empty in Kendal. By his own admissions, he does not know or at the very
least uncertain. This is another example of the unsoundness of SLOG's development plan. The
DPD is not justified because it is not founded on a credible evidence base. Before they begin
to allow developers to build on green-field sites, they need to do proper research. There are
enough empty houses and brownfield sites to satisfy much of the demand.
Because of the huge outcry nationally against building on green-field sites the Government has
beaten a remarkable retreat from its attempt to dismantle the planning system. The protection
for the countryside is back. Planning is to 'encourage' the use of brownfield land as one of its
'core principles'. I would like to know what other options SLDC have explored to meet the
considerable affordable housing needs. This approach will not deliver the numbers, which are
dependent on the total number of houses built. What sustainability strategies are in place to
accommodate 2,000 proposed dwellings just in Kendal over the next 15 years?
In the new planning law there are also measures included such as protection for the 'historic
environment' and sites of special scientific interest and stronger provisions against building on
flood-prone land. House-builders and supermarkets already hold large land banks. ln fact,
there is no 'need' to build on green-field sites anywhere in Britain. There is merely a 'demand'
from those wishing to profit from it. It is environmental and cultural insanity to open up our
green-field sites to developers.
But it would appear that SLDC are more interested in promoting the private interests of
developers. Added to this, the Localism Bill will for the first time allow Councils to give weight to
financial incentives for development, including money the Government is now offering them for
building new homes. How can we build more homes when we have one of the worst recessions
since the 1930's, and in particular, the lack of credit for mortgages (as Mr. Thornton
corroborated in his webchat).
Are SLDC prepared to take on board the impact of flooding if this development goes ahead?
This development will cause a tremendous amount of run-off as well as an impact on the Stock
Beck Flood Alleviation Scheme. Why is the flooding status within the evidence sections of the
consultation documentation inaccurate, giving same status on land known to flood as land that
doesn't? The R121M flood status is completely inaccurate and assessment of the Stock Beck
Flood Scheme impact is not included as part of flood assessment. How can residents make
informed decisions with this type of inaccuracy? The Environment Agency in July 2010
expressed their concern that drainage and flooding was an issue here.
As The Westmorland Gazette reported on 6th February, 2006:
Back in 2004, river and watercourse levels rocketed leading to standing
water and roads into Kendal became paralysed with gridlocked traffic,
while many minor roads were impassable. Riverside areas of Kendal
were minutes away from being declared a Severe Flooding Risk the
second highest state of alert. The Environment Agency admitted it was
the closest they had ever come to evacuation. Flooding in Kendal nearly
reached the point of "imminent danger to life and properties". And who
could forget the devastating floods in Cockermouth.
All other land potentially flowing into the Stock Beck Flood Alleviation system has been
removed, so why not this one? The residents of Oak Tree Road, Rowan Tree Crescent and
Sedbergh Road know only too well the flooding of water housed in and coming off the fields (see
photographs 8 & 9, flooding from R56 on to Castle Green Lane). Winter rainfall predictions up
to 2080 show a marked increase. It is vitally important that before this site can be approved on
flooding grounds the LPA should be required to carry out the recommendations contained in the
Preliminary Expert Report made by Professor Robert Jackson CEng CWEM FICE FCIWEM
MAE, who is a leading hydrology expert.
In conclusion, I formally oppose the development of R121M because SLDC has not provided
itself with enough detailed, costed and co-ordinated information to put it forward seriously for
development. SLOG's development plan is totally unsound, unjustified and unsustainable.
They are guilty of non-involvement and non-engagement with the local community who feel that
there has been a lack of meaningful dialogue as far as Kendal is concerned. All sorts of
obstacles have been put in place to confuse and frustrate residents, e.g. initial insistence on
computer use, the difficulty of forms, the need to keep an eye on the website, the difficulty to
understand the technical language of the latest form etc. '
Finally, I refer to Greg Clark's (Planning Minister) approach to reform of planning laws:
To empower communities to have more say in how their areas
are developed. Our reforms to the planning system take on this
challenge. They enshrine the local plan produced by local people
as the keystone of the planning system.
As far as SLDC are concerned they have failed to communicate and engage with the local
community. I personally have had no feedback .or dialoue with them, nor with Damian Law the
planning officer I took around the site. Questions I have raised abouf the landscape, the bio
diversity (especially the Great Crested Newts' terrestrial habitats), flooding, air pollution, traffic
and highways have not been addressed. I doubt that even my latest submission will be read or
shown to the Government Inspector, as I have been informed that SLDC will show the Inspector
submissions that they choose. This is blatantly unfair and undemocratic and for that reason I
would like to speak at the next round of this consultation.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
262. Mr Michael Fennell (Individual) : 27 Apr 2012 15:00:00
Policy/Site No.
LA1.3 Housing Allocations - All Kendal sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
SLDC summarily dismissed the Town Council's views about the importance of the approaches
to Kendal (2009). They also dismissed the Town Council's submission (Sustainable
Development in Kendal) based (2011) on the Taylor Review. The Planner whom we met on
22nd July 2011 to show around the site, had not heard of Taylor. The Greater Norwich
Development Plan Partnership has serious legal difficulties because they had failed to look
at/assess properly alternative approaches/strategies. SLOG's response is unsound, and
illustrates poor or little strategic thinking, and the land allocations were originally done before the
Core Strategy was in place. The CCC Local Area Committee recommended, (with no votes
against) that SLDC adopt an approach similar to that of Taylor and The Town Council. In their
strategy document back in April 2008, SLDC did not indicate the land between Castle Green
Road and the Sedbergh Road area for development.
It is also important to point out that that the number of houses needed in South Lakeland is now
running annually at 205 and not 400 (Strategic Housing Market Assessment - October 2011 ),
and there has been no appropriate adjustment to this fact. Councillor Peter Thornton (Portfolio
Holder for Housing) mentioned in his 'webchat' with the Westmorland Gazette (22nd March ~
2011 ), the non-availability of sites in this area, but surely the opposite is true -that there is an 2-
over-availability of sites. As Portfolio Holder for Housing, Mr. Thornton was asked if it was true
that there are 1,000 properties lying empty in Kendal, to which he replied:
" I don't have the exact figures with me but I know that there are too
many empty homes in our area ... but the large number of empty
homes at present is due to the slump in the housing market and
limited availability of finance".
And when asked if the new K Village apartments were lying empty, he stated:
" (I am) not sure of the situation with the new K Village apartments but
if some are empty it will be because the market is flat at the
moment."
Considering this new complex cost a staggering one hundred million pounds and has proved to
be a white elephant, you would expect Mr. Thornton to have found out exactly how many empty
properties are lying empty in Kendal. By his own admissions, he does not know or at the very
least uncertain. This is another example of the unsoundness of SLOG's development plan. The
DPD is not justified because it is not founded on a credible evidence base. Before they begin
to allow developers to build on green-field sites, they need to do proper research. There are
enough empty houses and brownfield sites to satisfy much of the demand.
Because of the huge outcry nationally against building on green-field sites the Government has
beaten a remarkable retreat from its attempt to dismantle the planning system. The protection
for the countryside is back. Planning is to 'encourage' the use of brownfield land as one of its
'core principles'. I would like to know what other options SLDC have explored to meet the
considerable affordable housing needs. This approach will not deliver the numbers, which are
dependent on the total number of houses built. What sustainability strategies are in place to
accommodate 2,000 proposed dwellings just in Kendal over the next 15 years?
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
263. Mr Michael Fennell (Individual) : 27 Apr 2012 15:01:00
Policy/Site No.
LA1.4 Broad Locations for New Housing
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
SLDC summarily dismissed the Town Council's views about the importance of the approaches
to Kendal (2009). They also dismissed the Town Council's submission (Sustainable
Development in Kendal) based (2011) on the Taylor Review. The Planner whom we met on
22nd July 2011 to show around the site, had not heard of Taylor. The Greater Norwich
Development Plan Partnership has serious legal difficulties because they had failed to look
at/assess properly alternative approaches/strategies. SLOG's response is unsound, and
illustrates poor or little strategic thinking, and the land allocations were originally done before the
Core Strategy was in place. The CCC Local Area Committee recommended, (with no votes
against) that SLDC adopt an approach similar to that of Taylor and The Town Council. In their
strategy document back in April 2008, SLDC did not indicate the land between Castle Green
Road and the Sedbergh Road area for development.
It is also important to point out that that the number of houses needed in South Lakeland is now
running annually at 205 and not 400 (Strategic Housing Market Assessment - October 2011 ),
and there has been no appropriate adjustment to this fact. Councillor Peter Thornton (Portfolio
Holder for Housing) mentioned in his 'webchat' with the Westmorland Gazette (22nd March ~
2011 ), the non-availability of sites in this area, but surely the opposite is true -that there is an 2-
over-availability of sites. As Portfolio Holder for Housing, Mr. Thornton was asked if it was true
that there are 1,000 properties lying empty in Kendal, to which he replied:
" I don't have the exact figures with me but I know that there are too
many empty homes in our area ... but the large number of empty
homes at present is due to the slump in the housing market and
limited availability of finance".
And when asked if the new K Village apartments were lying empty, he stated:
" (I am) not sure of the situation with the new K Village apartments but
if some are empty it will be because the market is flat at the
moment."
Considering this new complex cost a staggering one hundred million pounds and has proved to
be a white elephant, you would expect Mr. Thornton to have found out exactly how many empty
properties are lying empty in Kendal. By his own admissions, he does not know or at the very
least uncertain. This is another example of the unsoundness of SLOG's development plan. The
DPD is not justified because it is not founded on a credible evidence base. Before they begin
to allow developers to build on green-field sites, they need to do proper research. There are
enough empty houses and brownfield sites to satisfy much of the demand.
Because of the huge outcry nationally against building on green-field sites the Government has
beaten a remarkable retreat from its attempt to dismantle the planning system. The protection
for the countryside is back. Planning is to 'encourage' the use of brownfield land as one of its
'core principles'. I would like to know what other options SLDC have explored to meet the
considerable affordable housing needs. This approach will not deliver the numbers, which are
dependent on the total number of houses built. What sustainability strategies are in place to
accommodate 2,000 proposed dwellings just in Kendal over the next 15 years?
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
264. Mr Michael Fennell (Individual) : 27 Apr 2012 15:02:00
Policy/Site No.
LA1.6 Strategic Employment Sites - E4M KENDAL LAND AT SCROGGS WOOD, MILNTHORPE ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
SLDC summarily dismissed the Town Council's views about the importance of the approaches
to Kendal (2009). They also dismissed the Town Council's submission (Sustainable
Development in Kendal) based (2011) on the Taylor Review. The Planner whom we met on
22nd July 2011 to show around the site, had not heard of Taylor. The Greater Norwich
Development Plan Partnership has serious legal difficulties because they had failed to look
at/assess properly alternative approaches/strategies. SLOG's response is unsound, and
illustrates poor or little strategic thinking, and the land allocations were originally done before the
Core Strategy was in place. The CCC Local Area Committee recommended, (with no votes
against) that SLDC adopt an approach similar to that of Taylor and The Town Council. In their
strategy document back in April 2008, SLDC did not indicate the land between Castle Green
Road and the Sedbergh Road area for development.
It is also important to point out that that the number of houses needed in South Lakeland is now
running annually at 205 and not 400 (Strategic Housing Market Assessment - October 2011 ),
and there has been no appropriate adjustment to this fact. Councillor Peter Thornton (Portfolio
Holder for Housing) mentioned in his 'webchat' with the Westmorland Gazette (22nd March ~
2011 ), the non-availability of sites in this area, but surely the opposite is true -that there is an 2-
over-availability of sites. As Portfolio Holder for Housing, Mr. Thornton was asked if it was true
that there are 1,000 properties lying empty in Kendal, to which he replied:
" I don't have the exact figures with me but I know that there are too
many empty homes in our area ... but the large number of empty
homes at present is due to the slump in the housing market and
limited availability of finance".
And when asked if the new K Village apartments were lying empty, he stated:
" (I am) not sure of the situation with the new K Village apartments but
if some are empty it will be because the market is flat at the
moment."
Considering this new complex cost a staggering one hundred million pounds and has proved to
be a white elephant, you would expect Mr. Thornton to have found out exactly how many empty
properties are lying empty in Kendal. By his own admissions, he does not know or at the very
least uncertain. This is another example of the unsoundness of SLOG's development plan. The
DPD is not justified because it is not founded on a credible evidence base. Before they begin
to allow developers to build on green-field sites, they need to do proper research. There are
enough empty houses and brownfield sites to satisfy much of the demand.
Because of the huge outcry nationally against building on green-field sites the Government has
beaten a remarkable retreat from its attempt to dismantle the planning system. The protection
for the countryside is back. Planning is to 'encourage' the use of brownfield land as one of its
'core principles'. I would like to know what other options SLDC have explored to meet the
considerable affordable housing needs. This approach will not deliver the numbers, which are
dependent on the total number of houses built. What sustainability strategies are in place to
accommodate 2,000 proposed dwellings just in Kendal over the next 15 years?
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
265. Mr Michael Fennell (Individual) : 27 Apr 2012 15:03:00
Policy/Site No.
LA1.7 Business and Science Park Sites - M2M-mod KENDAL LAND EAST OF BURTON ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
SLDC summarily dismissed the Town Council's views about the importance of the approaches
to Kendal (2009). They also dismissed the Town Council's submission (Sustainable
Development in Kendal) based (2011) on the Taylor Review. The Planner whom we met on
22nd July 2011 to show around the site, had not heard of Taylor. The Greater Norwich
Development Plan Partnership has serious legal difficulties because they had failed to look
at/assess properly alternative approaches/strategies. SLOG's response is unsound, and
illustrates poor or little strategic thinking, and the land allocations were originally done before the
Core Strategy was in place. The CCC Local Area Committee recommended, (with no votes
against) that SLDC adopt an approach similar to that of Taylor and The Town Council. In their
strategy document back in April 2008, SLDC did not indicate the land between Castle Green
Road and the Sedbergh Road area for development.
It is also important to point out that that the number of houses needed in South Lakeland is now
running annually at 205 and not 400 (Strategic Housing Market Assessment - October 2011 ),
and there has been no appropriate adjustment to this fact. Councillor Peter Thornton (Portfolio
Holder for Housing) mentioned in his 'webchat' with the Westmorland Gazette (22nd March ~
2011 ), the non-availability of sites in this area, but surely the opposite is true -that there is an 2-
over-availability of sites. As Portfolio Holder for Housing, Mr. Thornton was asked if it was true
that there are 1,000 properties lying empty in Kendal, to which he replied:
" I don't have the exact figures with me but I know that there are too
many empty homes in our area ... but the large number of empty
homes at present is due to the slump in the housing market and
limited availability of finance".
And when asked if the new K Village apartments were lying empty, he stated:
" (I am) not sure of the situation with the new K Village apartments but
if some are empty it will be because the market is flat at the
moment."
Considering this new complex cost a staggering one hundred million pounds and has proved to
be a white elephant, you would expect Mr. Thornton to have found out exactly how many empty
properties are lying empty in Kendal. By his own admissions, he does not know or at the very
least uncertain. This is another example of the unsoundness of SLOG's development plan. The
DPD is not justified because it is not founded on a credible evidence base. Before they begin
to allow developers to build on green-field sites, they need to do proper research. There are
enough empty houses and brownfield sites to satisfy much of the demand.
Because of the huge outcry nationally against building on green-field sites the Government has
beaten a remarkable retreat from its attempt to dismantle the planning system. The protection
for the countryside is back. Planning is to 'encourage' the use of brownfield land as one of its
'core principles'. I would like to know what other options SLDC have explored to meet the
considerable affordable housing needs. This approach will not deliver the numbers, which are
dependent on the total number of houses built. What sustainability strategies are in place to
accommodate 2,000 proposed dwellings just in Kendal over the next 15 years?
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
266. Mr Michael Fennell (Individual) : 27 Apr 2012 15:05:00
Policy/Site No.
LA1.8 Local Employment Sites - All Kendal sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
SLDC summarily dismissed the Town Council's views about the importance of the approaches
to Kendal (2009). They also dismissed the Town Council's submission (Sustainable
Development in Kendal) based (2011) on the Taylor Review. The Planner whom we met on
22nd July 2011 to show around the site, had not heard of Taylor. The Greater Norwich
Development Plan Partnership has serious legal difficulties because they had failed to look
at/assess properly alternative approaches/strategies. SLOG's response is unsound, and
illustrates poor or little strategic thinking, and the land allocations were originally done before the
Core Strategy was in place. The CCC Local Area Committee recommended, (with no votes
against) that SLDC adopt an approach similar to that of Taylor and The Town Council. In their
strategy document back in April 2008, SLDC did not indicate the land between Castle Green
Road and the Sedbergh Road area for development.
It is also important to point out that that the number of houses needed in South Lakeland is now
running annually at 205 and not 400 (Strategic Housing Market Assessment - October 2011 ),
and there has been no appropriate adjustment to this fact. Councillor Peter Thornton (Portfolio
Holder for Housing) mentioned in his 'webchat' with the Westmorland Gazette (22nd March ~
2011 ), the non-availability of sites in this area, but surely the opposite is true -that there is an 2-
over-availability of sites. As Portfolio Holder for Housing, Mr. Thornton was asked if it was true
that there are 1,000 properties lying empty in Kendal, to which he replied:
" I don't have the exact figures with me but I know that there are too
many empty homes in our area ... but the large number of empty
homes at present is due to the slump in the housing market and
limited availability of finance".
And when asked if the new K Village apartments were lying empty, he stated:
" (I am) not sure of the situation with the new K Village apartments but
if some are empty it will be because the market is flat at the
moment."
Considering this new complex cost a staggering one hundred million pounds and has proved to
be a white elephant, you would expect Mr. Thornton to have found out exactly how many empty
properties are lying empty in Kendal. By his own admissions, he does not know or at the very
least uncertain. This is another example of the unsoundness of SLOG's development plan. The
DPD is not justified because it is not founded on a credible evidence base. Before they begin
to allow developers to build on green-field sites, they need to do proper research. There are
enough empty houses and brownfield sites to satisfy much of the demand.
Because of the huge outcry nationally against building on green-field sites the Government has
beaten a remarkable retreat from its attempt to dismantle the planning system. The protection
for the countryside is back. Planning is to 'encourage' the use of brownfield land as one of its
'core principles'. I would like to know what other options SLDC have explored to meet the
considerable affordable housing needs. This approach will not deliver the numbers, which are
dependent on the total number of houses built. What sustainability strategies are in place to
accommodate 2,000 proposed dwellings just in Kendal over the next 15 years?
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
267. Mr Michael Fennell (Individual) : 27 Apr 2012 15:07:00
Paragraph No.
1.9
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
All sorts of
obstacles have been put in place to confuse and frustrate residents, e.g. initial insistence on
computer use, the difficulty of forms, the need to keep an eye on the website, the difficulty to
understand the technical language of the latest form etc. '
Finally, I refer to Greg Clark's (Planning Minister) approach to reform of planning laws:
To empower communities to have more say in how their areas
are developed. Our reforms to the planning system take on this
challenge. They enshrine the local plan produced by local people
as the keystone of the planning system.
As far as SLDC are concerned they have failed to communicate and engage with the local
community. I personally have had no feedback .or dialoue with them, nor with Damian Law the
planning officer I took around the site.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
268. Mr Michael Fennell (Individual) : 27 Apr 2012 15:09:00
Paragraph No.
1.10
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
All sorts of
obstacles have been put in place to confuse and frustrate residents, e.g. initial insistence on
computer use, the difficulty of forms, the need to keep an eye on the website, the difficulty to
understand the technical language of the latest form etc. '
Finally, I refer to Greg Clark's (Planning Minister) approach to reform of planning laws:
To empower communities to have more say in how their areas
are developed. Our reforms to the planning system take on this
challenge. They enshrine the local plan produced by local people
as the keystone of the planning system.
As far as SLDC are concerned they have failed to communicate and engage with the local
community. I personally have had no feedback .or dialoue with them, nor with Damian Law the
planning officer I took around the site.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
269. Dr John Fenwick (Individual) : 23 Apr 2012 16:02:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA5.2 Land at Croftlands
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Would need to avoid developing grenfield sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Removal of Croftlands west proposal because:
Insufficient infrastructure consideration, insufficient consideration of environmental impact(hedges, waterflow etc), insufficient consideration of neighbouring authority provision
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
270. Dr John Fenwick (Individual) : 23 Apr 2012 16:05:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
1.9
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Removal of croftlands west proposal because:
Insufficient local consultation
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
271. Mr Stuart Fisher (Individual) : 17 Apr 2012 14:48:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - All Arnside sites
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
The DPD has not had regard to the Sustainable Community Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
SLDC ought to listen to the local community and take on board their efforts to create a viable plan for the village
SLDC should ensure that the DPD is compliant with the NPPF's requirements to give AONBs the highest level of protection and that no major development will be allowed.
It should provide clear evidence, as required by the NPPF, of close cooperation with Lancaster City Council. A joint approach to the whole of the AONB ought to have been a given.
Changes also need to be made to comply with SLDC's Core strategy bearing in mind that it has to have "due regard" to the Arnside/Silverdale AONB's designation - which is "to enhance and protect".
The sequential use of sites should be a primary objective in accordance with the Core Strategy.
1.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
Where is the space to explain that I disagree with SLDC's Land Allocations? Leading questions should not be included in an exercise like this.
This last part of the consultation process has been very complicated. I have struggled with it and know of several people who have given up.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not consistent with national policy.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I support the Arnside Parich Plan Trust in its efforts to deal with the problems facing Arnsied and its solutions to create a viable village.
In addition I would like to point to the discrepancy between the minimum site size of 0.3ha and Policy H3 of the Local Plan "The Council will give preference to proposals for development on previously developed sites in sustainable locations, whether such sites are allocated or not".
The first allows the Council to ignore all proposed brownfield sites in Arnside, while the second allows it to bring these sites back at a later date thereby increasing the number of houses well above the allocated 81+11 outstanding planning permissions.
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
I do not, but will repeat my support for the Arnside Parish Plan Trust
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
272. Mr Stuart Fisher (Individual) : 15 May 2012 12:47:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
1.9
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
The DPD has not had regard to the Sustainable Community Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Where is the space to explain that I disagree with SLDC's Land Allocations? Leading questions should not be included in an exercise like this.
This last part of the consultation process has been very complicated. I have struggled with it and know of several people who have given up.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
273. Mr Stuart Fisher (Individual) : 15 May 2012 12:49:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
1.10
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
The DPD has not had regard to the Sustainable Community Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
SLDC ought to listen to the local community and take on board their efforts to create a viable plan for the village
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
274. Mr John Fitch (Individual) : 15 Apr 2012 17:39:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - RN121M-mod LEVENS FORMER POULTRY SHEDS, BRIGSTEER ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The Land Allocations Document (DPD) is not within the Local Development Scheme and the key stages have not been followed
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not been prepared in accordance with the Town & County Planning Regulations 2004 (as amended)
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Housing proposals in respect of RN121M-MOD should be removed for the following reasons:
1. SLDC proposals for housing on RN121M-MOD were not formally published until some four months after the end of the last public consultation period so we have been given no opportunity to comment on them.
2. There was no specific consultation with those who live to the north of the village by SLDC, the Parish Council or any of the individuals who proposed housing on the site either individually or through the Levens Residents Group’s survey. Surely, therefore, the SLDC proposals are flawed.
3. SLDC failed to make any contact with one of the landowners affected and he has indicated subsequently that his land is not available for sale under any circumstances. This reduces the size of the site by approximately one third and probably makes the development proposal un-deliverable.
1.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
No support given.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Housing proposals in respect of RN121M-MOD should be removed for the following reasons:
1. Reasons 1-3 as stated in 1.3 above.
2. Extra traffic though the very restricted centre of the village - SLDC proposals for "mitigation measures" are not specific, meaningless and probably undeliverable from a development of this size.
3. Serious concerns about biodiversity on the site by Cumbria Wildlife Trust and the National Trust are largely dismissed by SLDC with proposals for "mitigation measures" which are not specific, meaningless and probably undeliverable from a development of this size. Difficult to see how legislation covering bats and great crested newts can be overcome.
4. Highway Authority concerns that “Access would not be suitable for residential use - issues with gradient and poor visibility" are simply dismissed by SLDC.
5. Concerns from individuals and the National Trust about adverse impact on the landscape are again covered by non-specific "mitigation measures" by SLDC.
6. The effect of the proposed extension of the National Park has not been considered.
7. Housing on this site was refused by SLDC in 1982 and the decision was upheld on appeal in 1983. Many of the points made in the Decision Letter dated 15 April 1983 are relevant today and the Inspector concluded that “any form of residential development on this site would be unduly prominent from the open valley floor to the west”.
8. It would increase the likelihood of future in-fill development to the south, removing green spaces and open views from the village (a reason why other sites in the village were rejected during the SLDC consultations).
9.The high density of development proposed would be totally out of keeping with the established adjacent development, including a large Victorian villa.
10.Residential development would be likely to include the introduction of street lighting which would ruin the night-time quality of the area and be seen clearly from the National Park (whether extended or not).
11.SLDC have been made aware of significant foul drainage problems in Levens. Any residential development of the site would be likely to add to this problem by increasing flow from the top end of the village.
12.Due to the difficulties involved, any development of this relatively small site (now reduced further in size) is extremely unlikely to be economic and hence the aspiration in the SLDC document is probably undeliverable.
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
No support given.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
1. To ensure that the Inspector is made aware of the full facts surrounding RN121M-MOD and the strength of feeling locally against the SLDC proposal for the site.
2. To ensure that there is an opportunity to cross-examine any SLDC Officers or Expert Witnesses on their evidence in respect of the site.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
275. Mrs Ann Fitch (Individual) : 15 Apr 2012 17:47:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - RN121M-mod LEVENS FORMER POULTRY SHEDS, BRIGSTEER ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not been prepared in accordance with the Town & County Planning Regulations 2004 (as amended)
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Housing proposals in respect of RN121M-MOD should be removed for the following reasons:
1. SLDC proposals for housing on RN121M-MOD were not formally published until some four months after the end of the last public consultation period so we have been given no opportunity to comment on them.
2. There was no specific consultation with those who live to the north of the village by SLDC, the Parish Council or any of the individuals who proposed housing on the site either individually or through the Levens Residents Group’s survey. Surely, therefore, the SLDC proposals are flawed.
3. SLDC failed to make any contact with one of the landowners affected and he has indicated subsequently that his land is not available for sale under any circumstances. This reduces the size of the site by approximately one third and probably makes the development proposal un-deliverable.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Housing proposals in respect of RN121M-MOD should be removed for the following reasons:
1. Reasons 1-3 as stated in 1.3 above.
2. Extra traffic though the very restricted centre of the village - SLDC proposals for "mitigation measures" are not specific, meaningless and probably undeliverable from a development of this size.
3. Serious concerns about biodiversity on the site by Cumbria Wildlife Trust and the National Trust are largely dismissed by SLDC with proposals for "mitigation measures" which are not specific, meaningless and probably undeliverable from a development of this size. Difficult to see how legislation covering bats and great crested newts can be overcome.
4. Highway Authority concerns that “Access would not be suitable for residential use - issues with gradient and poor visibility" are simply dismissed by SLDC.
5. Concerns from individuals and the National Trust about adverse impact on the landscape are again covered by non-specific "mitigation measures" by SLDC.
6. The effect of the proposed extension of the National Park has not been considered.
7. Housing on this site was refused by SLDC in 1982 and the decision was upheld on appeal in 1983. Many of the points made in the Decision Letter dated 15 April 1983 are relevant today and the Inspector concluded that “any form of residential development on this site would be unduly prominent from the open valley floor to the west”.
8. It would increase the likelihood of future in-fill development to the south, removing green spaces and open views from the village (a reason why other sites in the village were rejected during the SLDC consultations).
9.The high density of development proposed would be totally out of keeping with the established adjacent development, including a large Victorian villa.
10.Residential development would be likely to include the introduction of street lighting which would ruin the night-time quality of the area and be seen clearly from the National Park (whether extended or not).
11.SLDC have been made aware of significant foul drainage problems in Levens. Any residential development of the site would be likely to add to this problem by increasing flow from the top end of the village.
12.Due to the difficulties involved, any development of this relatively small site (now reduced further in size) is extremely unlikely to be economic and hence the aspiration in the SLDC document is probably undeliverable.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
276. Mr John Fitch (Individual) : 16 May 2012 10:12:00
A typed or handwritten document was submitted. This has been scanned and can be downloaded below:
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - RN121M-mod LEVENS FORMER POULTRY SHEDS, BRIGSTEER ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not been prepared in accordance with the Town & County Planning Regulations 2004 (as amended)
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
LAND ALLOCATIONS DEVELOPMENT PLAN DOCUMENT
REPRESENTATION IN RESPECT OF SITE RN121M-MOD
13 April2012
1. I am writing to you on behalf of a number of residents who live to the north of the
main village development of Levens. Over eighty of us have signed the attached
petition in respect of our conviction that the inclusion of the proposed site for housing
RN121M-MOD in the Development Plan Documents represents both a noncompliance
with the legal and the soundness requirements of the 2004 Act. As a
Planning Inspector said previously, "the proposed scheme would form an isolated
pocket of development within attractive countryside outside the core of the village. " I
am aware that a number of us are also submitting personal representations. Section 2
of this letter is headed "LEGAL NON-COMPLIANCE" and section 3 is headed
"SOUNDNESS". We are a group of local residents, not planning experts, and it may
be that points made in one section would best be made in another. Similarly it may be
that points made in one section do in fact overlap and relate to both sections.
2. LEGAL NON-COMPLIANCE
2.1 It is made clear in your Statement of Community Involvement (2006) that you are
committed to certain principles (Paragraph 2.4). Specifically:
• an opportunity for early and on-going input, at stages where responses can make a
difference.
• selecting methods, techniques and venues which maximise the opportunity for all
groups to take part and respond- including 'hard-to-reach' groups.
• identifying and targeting communities and stakeholders with relevant interests,
while ensuring everyone has a chance to input.
2.2 The site has been through various incarnations during the consultation process. It was
originally known as RN121. In the consultation commencing in January 2011 it had
become RN121M and was proposed as an employment site. In the consultation
commencing in July 2011 it had transformed in to RN295# as a proposed housing site
which had apparently been put forward by respondents to the earlier consultation.
Now it has become RN121M-MOD with 23 dwellings proposed.
2.3 As made clear in the letter (Ref AMcN/60.12.43) dated 25 January 2012 from Mr
McNeill, of your office, to Mr Biddle of "The Crossings", the proposed change to
residential use was not formally made public until 11 January 2012, with the Land
Allocations Documents being approved for publication by the Council on 18 January
2012. Clearly therefore, the proposals for housing on RN121M-MOD did not become
the Planning Authority's published proposal until some four months after the end of
the last public consultation period and so we have been given no opportunity to
comment on your proposals for the site.
2.4 In addition, it is clear that you failed to make any contact with one of the landowners
affected by RN121M-MOD and he has indicated subsequently that his land is not
available for sale under any circumstances. This reduces the size of the site by
approximately one third (see Plan at Appendix 1) and so your proposal fails the
"delivery mechanisms" test under Section 27 of the Soundness Tool published by the
Planning Advisory Service.
2.5 A cursory look at a map of the village of Levens will clearly indicate why a
significant number of residents proposed housing on this site. Bluntly, it is simply the
furthest site away from the main village development and those of us close to the
proposed site could never win in the "numbers game". There was no specific
consultation with those of us who live to the north of the village by the Parish Council
or any of the individuals who proposed housing on the site either individually or
through the Levens Residents Group's survey. A copy of correspondence in this
respect between myself and the P'arish Council is at Appendix 2.
2.6 In paragraph 3.139 of the Land Allocations DPD, you refer to the former poultry
sheds in Brigsteer Road and state that "Key issues include the need for the removal of
all derelict buildings from the site (including those outside the site itself) the retention
of woodlands, investigation of potential contamination and a design/safety audit to
ensure that the site could be safely accessed. " Section 79 of the Building Act 1984
empowers a Local Authority to take certain actions to achieve the repair or demolition
of a building or structure if its condition is seriously detrimental to the amenities of
the neighbourhood. We consider that the issue of the derelict buildings would be best
addressed by the Local Authority exercising its powers under the 84 Act. It does seem
perverse to cite a reason for the proposed development as being local support, when
that support arises from the fact that the Local Authority has chosen not to exercise its
powers.
2.7 The Soundness Tool has as its first question "Has the consultation process allowed
for effective engagement of all interested parties?" The answer is no. It is our view
that these factors demonstrate a failure to comply with both the word and the
spirit of your Statement of Community Involvement.
[See also attached appendices]
Note: Response also supported by petition with 80 signatories.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
LAND ALLOCATIONS DEVELOPMENT PLAN DOCUMENT
REPRESENTATION IN RESPECT OF SITE RN121M-MOD
13 April2012
1. I am writing to you on behalf of a number of residents who live to the north of the
main village development of Levens. Over eighty of us have signed the attached
petition in respect of our conviction that the inclusion of the proposed site for housing
RN121M-MOD in the Development Plan Documents represents both a noncompliance
with the legal and the soundness requirements of the 2004 Act. As a
Planning Inspector said previously, "the proposed scheme would form an isolated
pocket of development within attractive countryside outside the core of the village. " I
am aware that a number of us are also submitting personal representations. Section 2
of this letter is headed "LEGAL NON-COMPLIANCE" and section 3 is headed
"SOUNDNESS". We are a group of local residents, not planning experts, and it may
be that points made in one section would best be made in another. Similarly it may be
that points made in one section do in fact overlap and relate to both sections.
SOUNDNESS
3.1 The "Soundness" of the Land Allocations Development Plan Document in respect of
RN121M-MOD is also challenged by the points raised in paragraphs 2.1 to 2.6 above
and there is little point in repeating them here. However, the following paragraphs
also challenge the soundness of your proposals for this site:
3.2 The top side of the steeply sloping site (approximately 1 in 5) is heavily wooded with
native ash, sycamore, beech and occasional birch and gean (also called wild cherry a
white-flowered rosaceous tree). Many are semi mature being above 18 metres in
height. In addition there are a number of Yews, some of which are at least 100 years
old proving that this woodland is of ancient origin. The lower (western) side of the
site is a woodland of Norway spruce and beech some 40 years old which was planted
as a screen to the sheds as a requirement of the Planning Authority. See Plan at
Appendix 1.
3.3 On 17 January 2012 Natural England made Orders which would vary the boundaries
of the Lake District and the Yorkshire Dales National Parks. These Orders will take
effect if they are confrrmed by the Secretary of State for Enviromnent, Food and
Rural Affairs. If confirmed, the boundary of the Lake District National Park will be
moved to around 85 metres to the north of the site and around 155 metres to its west.
3.4 Within Appendix 8 to the Consultation Statement, concern is expressed about the
potential of extra traffic though the very restricted centre of the village. This is
"noted" by SLDC, who go on to say that "Mitigation measures will be a requirement
to offset any potential adverse impact. " While recognising that this is a "stock phrase"
used by Planning Authorities and the like, we would contend that it is simply a
surrogate for saying that they "have no answer to this point at the present time." We
consider that to proceed with a residential development proposal under such
circumstances is un-sound as it implies an unfounded supposition that an appropriate
answer will be found and that the proposed relatively small development could
support the cost of this. Further, we consider that Sections 26, 28 and 30 of the
Soundness Tool suggest that rather more than "mitigation measures" are required for
DPD proposals to be sound.
3.5 Appendix 8 also records serious concerns about biodiversity on the site by Cumbria
Wildlife Trust and the National Trust. Their concern extends to habitat within the site
for invertebrates, great crested newts and bats. The latter two are European Protected
Species which fall under the Wildlife and Countryside Act 1981 and are covered by
the Conservation of Habitats and Species Regulations 2010 Regulation 41.
These concerns have been largely dismissed by SLDC with the offer of more
nebulous "Mitigation Measures" which we consider are unlikely to be deliverable,
particularly on such a small site.
3.6 Significant concerns are expressed about access by the Highways Authority (Cumbria
CC) in Appendix 9 to the Consultation Statement. Officer comments in November
2011 were: "Access would not be suitable for residential use - issues with gradient
and poor visibility. Design Safoty Audit would be required Possibly more suitable for
low intensity employment use subject to resolution of issues above. " This is again
recorded as "noted" by SLDC, who have subsequently proposed residential
development on the site.
3.7 Appendix 9 also records concerns of the National Trust and individuals over the effect
of the proposed development on landscape and on the local environment generally.
The National Trust considers that "the development could adversely impact upon the
settlement pattern and the village envelope" (the site is outside the recognised
boundary of the village and is, therefore, effectively in open countryside). They go on
to say that "due to the topography of the site and its prominence, the proposed
development would adversely impact upon the landscape character of this part of the
district". Also that "there is ecologically sensitive land close by at Lane End corner."
Again, we are offered non-specific "Mitigation Measures".
3.8 In 1983 the DoE and Department of Transport inspector, Mr R E Watson, was
appointed to determine against the decision of SLDC to refuse planning permission
for "residential development at Scarbrae Poultry Farm, Levens and the removal of a
condition limiting occupation of the dwelling known as Scarbrae". The appeal was by
Mr J Wilkinson (Application No 5/82/0833/0834). Although now approaching 30
years old, many of the points made in Mr Watson's Decision Letter dated 15 April
1983 are relevant today. He said that "the proposed scheme would form an isolated
pocket of development within attractive countryside outside the core of the village. "
He also took the view that "unless strict control is exercised over future development
there is a significant danger that the scenic quality of the area will be seriously
damaged" and he concluded that "any form of residential development on this site
would be unduly prominent from the open valley floor to the west. " He dismissed the
appeals.
3.9 We consider that other important concerns which mitigate against residential
development on this site include:
It would increase the likelihood of future in-fill development to the south,
removing green spaces and open views from the village (a reason why other
sites in the village were rejected during the SLDC consultations).
• The high density of development proposed would be totally out of keeping
with the established adjacent development, including a large Victorian villa.
• Residential development would be likely to include the introduction of street
lighting which would ruin the night-time quality of the area and be seen
clearly from the National Park (whether extended or not).
• SLDC have been made aware of significant foul drainage problems in Levens
(although United Utilities seem reluctant to formally acknowledge this). Any
residential development of the site would be likely to add to this problem by
increasing flow from the top end of the village.
• Due to the difficulties involved, any development of this relatively small site
(now reduced further in size) is extremely unlikely to be economic and hence
the aspiration in the SLDC document is probably undeliverable.
4. CONCLUSION
4.1 We are convinced that your proposals in respect of RN121M-MOD are legally
flawed, unjustified, ineffective, undeliverable and therefore un-sound. We would wish
to make personal representations to the Inspector (when appointed) in these respects if
SLDC continue to promote the residential development of this site in their Land
Allocations Development Plan Document.
4.2 We would prefer to see the land in question remain in agricultural use. However, if
the Land Allocations Development Plan Document was amended to show the site as
designated for employment use as you originally proposed we would probably be
content, providing use was limited to Class B 1 and the screening of the site by
woodland was maintained.
[See also attached appendices]
Note: Response also supported by petition with 80 signatories.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
To ensure that the views of the northern end of the village of Levens are properly represented.
277. Mr Mike Fleetwood (Individual) : 5 Mar 2012 13:05:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - RN213-mod BRIGSTEER LAND OPPOSITE THE WHEATSHEAF
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The site has been proposed by the Community Land Trust but that body does not yet have members or elected directors, nor has it taken any steps to ensure it truly represents community opinion in Brigsteer. It is asserted that the Parish Council supports the LDF proposal, yet no response from the Parish Council appears in the responses listed for Brigsteer. It would be much better to remove Site 213 mod from the LD DPD and allow development in Brigsteer to proceed as in other villages via a Neighbourhood Development Plan under the Localism Act.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
In a questionnaire, a large majority of Brigsteer residents expressed the view that small sites distributed through the village would be preferable to concentrating affordable housing on one site on the periphery. That option has not been explored by SLDC. Nor does the evidence put forward appear accurate. For example, it is incorrect to state that there is no problem with flooding from run off - there is already a problem with storm water running off the road onto existing properties on the south side.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
278. Mr Mike Fleetwood (Individual) : 12 Apr 2012 20:55:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - RN213-mod BRIGSTEER LAND OPPOSITE THE WHEATSHEAF
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The DPD has selectively cited support from Helsington Community Land Trust and Parish Council but has ignored the evidence of results of the survey of residents of Brigsteer in February 2011, in which 66% of those on the electoral roll participated. That survey showed that 73% disageed that up to 13 houses, at least 35% affordable, should be built on site RN213 and at 95% preferred affordable housing should be integrated into the community on smaller sites. In a specially convened meeting on 10 April 2012, electors of the parish again rejected the proposal to build on RN213 (amended in the DPD to 7 houses) by 31 votes to 20. The DPD is unsound because it has not taken into account the declared opposition of electors of Brigsteer to building on site RN213.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
279. Mrs Jacqueline Fleetwood (Individual) : 12 Apr 2012 21:53:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - RN213-mod BRIGSTEER LAND OPPOSITE THE WHEATSHEAF
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The DPD does not include evidence submitted during the consultation that the electors of Brigsteer do not support the building of houses on site RN213, namely that in a survey of Brigsteer residents conducted in February 2011 to which 95 residents responded (about 66% of the number on the electoral roll), 73% opposed the building of up to 13 houses on RN213 and 95% considered affordable housing should be integrated into the community on small sites, not segregated on one site and should be developed gradually and not all in Phase 1. Those facts should be included in the DPD as evidence that the electors of Brigsteer oppose building on site RN213. That situation was confirmed at a Parish Meeting on 10 April at which 31 electors voted against the development of RN213 and 20 voted for the development.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
280. Mr D Flower (Individual) : 26 Apr 2012 15:06:00
Policy/Site No.
LA1.3 Housing Allocations - R121M-mod KENDAL EAST OF CASTLE GREEN ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Re Land Allocation Proposals Rl21M re Land of Castle Green Lane and behind
Rowan Tree Crescent and Oak Tree Road
I refer to your letter of the 29 February 2012 in connection with the above and
formally write to declare my opposition to planning consent being granted in
connection with the above.
In my view the building of further houses on this land will compound the drainage
problem in the area and may result in flooding to other properties that already exist.
I therefore believe that the proposals put forward are not sound for the reasons
already mentioned in earlier correspondence.
281. Mrs Isobel Fraser (Individual) : 26 Apr 2012 15:20:00
Policy/Site No.
LA1.3 Housing Allocations - R121M-mod KENDAL EAST OF CASTLE GREEN ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
1. It would be necessary to make wider and stronger road access which would make the site unviablefrom the cost point of view
2. Drainage is also an expensive item. The stock beck scheme is already complete.
3. Although the site has been modified it remains a small estate linked to another small estate - no public transport no retail outlet - sustainable ?
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
282. Mr Peter Gates (Individual) : 11 Apr 2012 15:40:00
Policy/Site No.
LA3.2 Mixed Use Allocation at Land South of Allithwaite Road, Kent's Bank, Grange-over-Sands
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The proposed land allocation is unacceptable on a number of points.
The development of this scale is totally out of keeping with the local environment and is far bigger than the original, equally unacceptable proposal. The development sites proposed in the Kents Bank area are now going to concentrate 66% of the total allocated housing for Grange Over Sands in this one area.
In general the roads throughout the Cartmel Peninsular are already inadequate for residents, delivery vehicles and tourists, the bottle-neck on Risedale Hill and on the Main Street in Grange cannot be easily by-passed. Likewise there are bottle-necks in Allithwaite and Flookburgh. The proposed housing within the Kents Bank area will only make congestion worse in general, and particularly at commuter times. And if the employment units that have been identified go ahead the road problem will become untenable without some relief road scheme being considered, ideally being inplemented before any housing development takes place.
The concentration also will have a detrimental effect on the local wildlife taking away valuable corridors of green land.
It infers at best the council have not given due thought or consideration of how this will impact on the daily lives of existing Kent Banks residents and at worst being pressurised by landowners business interests.
We have all, even Councillors, chosen to live in this area to live for it's natural beauty. please keep it that way.
283. Mr Peter Gates (Individual) : 25 Apr 2012 08:07:00
Policy/Site No.
LA1.3 Housing Allocations - R672M GRANGE-OVER-SANDS WEST OF CARDRONA ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The proposed land allocation is unacceptable on a number of points.
The development of this scale is totally out of keeping with the local environment and is far bigger than the original, equally unacceptable proposal. The development sites proposed in the Kents Bank area are now going to concentrate 66% of the total allocated housing for Grange Over Sands in this one area.
In general the roads throughout the Cartmel Peninsular are already inadequate for residents, delivery vehicles and tourists, the bottle-neck on Risedale Hill and on the Main Street in Grange cannot be easily by-passed. Likewise there are bottle-necks in Allithwaite and Flookburgh. The proposed housing within the Kents Bank area will only make congestion worse in general, and particularly at commuter times. And if the employment units that have been identified go ahead the road problem will become untenable without some relief road scheme being considered, ideally being inplemented before any housing development takes place.
The concentration also will have a detrimental effect on the local wildlife taking away valuable corridors of green land.
It infers at best the council have not given due thought or consideration of how this will impact on the daily lives of existing Kent Banks residents and at worst being pressurised by landowners business interests.
We have all, even councillors chosen this area to live for its natural beauty. Please keep it that way.
284. Ms Lorraine Gibbard (Individual) : 26 Apr 2012 15:00:00
Policy/Site No.
LA1.6 Strategic Employment Sites - E4M KENDAL LAND AT SCROGGS WOOD, MILNTHORPE ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Comments on soundness of submission in relation to Strategic Emoloyment Site
at Scroggs Wood, Milnthoroe Road, Kendal Ref E4M
Document referred to:-
South Lakeland Local Development Framework
Land Allocations Development Plan Document
Proposed Submission Edition March 2012
Strategic Employment site able to accommodate Bl Light Industrial, B2 General
Industrial and B8 Storage and Distribution and ancillary B1 (a) uses.
Site area 17.9 hectares
Point 1 Landscape Character
The document states that acceptable uses for the site are B 1 (b,c) , B2 and B8 plus
B1a ancillary. Page 3 7 refers
It also states that "Strategic Employment Sites are large sites of 5 ha or more" and
"aimed at larger businesses" Paragraph 2.45 Page 36 refers
The document then goes on to say that the land adjacent to Scroggs Woods should
conserve 'important site features' including the 'protection of drumlin
characteristics'. Table Page 68 refers
Surely this is a contradiction. The only way you can economically develop an
undulating site with drumlin characteristics using a mixture of industrial units and
storage facilities is to flatten areas of it so that the construction of distributor roads,
industrial units and the like are easily constructed with the minimum of financial
outlay.
It is not sound reasoning to suggest that drumlin characteristics can be preserved in a
site that has been allocated for industry and storage. Otherwise the site would be
uneconomic to develop and unattractive to potential businesses.
The document also states that there should be 'landscaping along the perimeter of the
site' and 'retained hedgerows' Page 37 refers. It also goes on to say that there should
be 'significant structural landscaping and robust boundary treatment along the
southern and eastern edges to ensure development is sympathetic to the existing
landscape character and views from the A6 (Milnthorpe Road) and A591. Paragraph
3.35 Page 67 refers.
Surely if the submission is to be considered sound, screening of the site from the A591
and A6 should be along the western boundary as there are no A roads on the eastern
boundary.
The site is also clearly visible from the residential areas acijacent and some form of
landscape/acoustic screening will be required to protect the properties from noise
and air pollution. No mention is made of light pollution and how this will be kept in
check in a farmed rural landscape.
Also it is not clear how screening of any significance can be effictive when the A591
,is elevated above the site by at least 30 metres and all of the site is clearly visible
from both the east and west.
The site is of County Significance and acijoins a river with SSI status (Otters are
returning to the area, significant numbers of migratory sea trout and salmon, also
white clawed crayfish). No mention is made as to how developing rural green belt
land along the river Kent valley can be seen as sound in an area that has significant
landscape value adjoining a river of major ecological importance.
Point 2 Sustainability
Sustainable development statements made about the site contradict statements about
unconstrained strategic employment sites aimed at larger businesses of which the
proposed Scroggs Woods site is one. The document refers to the "provision for the
relocation and developing of existing firms" Paragraph 2.45 Page 36 refers.
On the same page of the document reference is made to "the South Kendal Corridor
and M6 Jn 36"
What evidence has been provided to support the view that local businesses will
relocate to south Kendal? Common sense suggests that businesses in the north of the
town in the Shap Road industrial estates for example may well find the southern
employment site more attractive and relocate. More so when you consider that the
document ignores proposals to create a new road through Burneside connecting the
A591 to the northern employment sites. Have businesses been consulted on what
effict an employment site to the south would have on their own business and whether
they would consider relocation? Surely an employment site in the South of the town
would create redundant unattractive brown field sites to the north of the town as
businesses relocate to the south and the development continues unconstrained along
"the South Kendal Corridor? The unconstrained development of a new significant
employment site cannot be regarded as sustainable if employment areas to the north
of the town are abandoned in favour of the more favourable south.
Surely a better option would be to provide a new road through Burneside to serve the
northern employment sites and continue to service these areas. For this reason the
argument for sustainable development along the south Kendal corridor is not sound
as it would be detrimental to Kendal as a whole, and effectively make businesses in
the northern part of the town unsustainable. In order for the proposal in the south to
be considered sound, consultation should have taken place on the efficts it would
have on the northern employment areas.
Point 3 Flooding
The document refers to the possible need for "flooding mitigation measures to reduce
the risk of flooding from a watercourse to the north of the site". Paragraph 3.35 Page
67 refers.
What evidence has been gathered to determine the extent of flooding and its potential
effect on development and surrounding areas? Surely if the land allocation proposal
is to be considered sound there should be supporting evidence as to the degree of risk
of flooding either from the watercourse or the river Kent before submitting the site for
consideration and that this evidence should be complete and comprehensive prior to
its submission to the inspector.
Point 4 Delivery of Infrastructure
There is no evidence within the document to suggest that any agency (e.g. providers
of highways, gas, water, electricity, sewers, communications, public transport) will be
in a position to deliver the infrastructure required and enable development to take
place within the proposed timescales.
Policy CS7.2 of the adopted Core Strategy states that there is a requirement for a 9
hectare Strategic Employment Site by 2025. The proposal at Scroggs Wood is for
17.9 hectares with no evidence that there would be take-up of a site on this scale (it is
comparable in size with the Westmorland Business Park or Shap Road Industrial
Estate to the north of the town) or evidence that the resources would be available to
provide the necessary infrastructure not only for the 9.0 hectares referred to, but also
for a development or series of developments that nearly doubles the scale of the
proposed development.
As the document is inconsistent with regard to the size of development proposed and
with scant evidence that there will be sufficient infrastructure to support any scale of
development within the proposed timescale, then the proposal for an employment site
at Scroggs Woods can not be considered sound.
In conclusion I urge the inspector to reconsider the land allocation at Scroggs Woods
on the grounds that the proposal is not sound for the reasons stated above.
285. Mr Kenneth Gibson (Individual) : 30 Mar 2012 10:52:00
Policy/Site No.
LA1.3 Housing Allocations - All Kendal sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The market town of Kendal like many other UK market towns has developed over many hundreds of years from a combination of commerce and the need to house workers involved in that commerce. The process may not have had a master plan but has resulted
in a unique heritage which is much admired by locals and visitors alike. It should be our
task to m!ik:e sure that this heritage is passed on, for future generations to cherish.
The process of attracting new commerce to Kendal needs to be continuous and ongoing
and we need to accommodate those workers involved in that commerce using brownfield
and other inter spaces for houses within the historically defined existing town boundaries.
Green field sites outside the already established town boundaries should not be used for
the purposes of housing or commercial development. Following this philosophy the unique character of the market town of Kendal can be preserved for all to enjoy.
2. Visual Impact
SLDC's proposals for large scale housing developments on the outer edges of the town is , unsound as it will change forever the pleasing character that the market town of Kendal I
offers to visitors and residents alike. One example is the proposal for housing development on land marked as M41KM on a raised hillside facing south east. This raised area ofland dominates the important southern entrance to Kendal from the A591 (The Lakes Southern Gateway). The impact ;· of modern housing on this land would severely detract from the unique markettown character ofKendal for both visitors and residents alike. The raised land is clearly visible from both the A6 to the south and east and the A591 to the west. The visitor's first impression is an important consideration and development on this site would adversely effect tourism in the town.
4. Motor vehicle Traffic
The traffic flow in Kendal is mainly South to North and vice versa. The current volume
of traffic raises concerns in a number of important areas:
• Air Quality The town centre air quality is adversely affected by vehicular traffic and especially particulate discharge from heavy goods vehicles traversing the town to make deliveries.
• Safety One example is that the volume of standing traffic causes extensive tailbacks on the A6 southern approach into Kendal. On occasions, the standing traffic extends to the A591 dual carriageway. This is a real road safety issue which needs to be addressed before there is a fatality.
• Journey Time The time spent in Kendal town centre traffic jams is damaging to town centre shopping conunerce and to industry based on the northern side of the town. Whilst the demise of Kendal town centre shopping is complex, one of the reasons must be ease of access and easy parking. The time required to traverse the town (around 3 0 mins at peak times) is so prohibitive that many south Kendal residents use the M6 junction 36 for journeys north to Penrith or Carlisle. This detour adds additional mileage to the alternative route of the A6 north to Shap and is environmentally not the best option.
SLDC have to some extent recognised this problem and have invested in improving cycle
ways through the town. The facilities provided for various reasons (probably poor design/planning) are under used, with cyclists preferring to continue using those roads
occupied by vehicular traffic.
The addition of 2000 houses to the Kendal area and the extra cars they will bring will only compound and exacerbate the problems listed.
SLDC have failed to adequately address the problem of traffic flow through Kendal in
their proposals for the allocation of land in South Lakeland. Therefore in this important
area, their proposals are unsound.
286. Mr Kenneth Gibson (Individual) : 30 Mar 2012 11:00:00
Policy/Site No.
LA1.6 Strategic Employment Sites - E4M KENDAL LAND AT SCROGGS WOOD, MILNTHORPE ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Green field sites outside the already established town boundaries should not be used for
the purposes ofhousing or commercial development. Following this philosophy the unique character of the market town of Kendal can be preserved for all to enjoy.
287. Mr Kenneth Gibson (Individual) : 30 Mar 2012 11:02:00
Policy/Site No.
LA1.7 Business and Science Park Sites - M2M-mod KENDAL LAND EAST OF BURTON ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Green field sites outside the already established town boundaries should not be used for
the purposes ofhousing or commercial development. Following this philosophy the unique character of the market town of Kendal can be preserved for all to enjoy.
288. Mr Kenneth Gibson (Individual) : 30 Mar 2012 11:18:00
Policy/Site No.
LA1.8 Local Employment Allocations - E31M KENDAL LAND SOUTH OF K SHOES, NATLAND ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Green field sites outside the already established town boundaries should not be used for
the purposes ofhousing or commercial development. Following this philosophy the unique character of the market town of Kendal can be preserved for all to enjoy.
289. Mr Kenneth Gibson (Individual) : 30 Mar 2012 11:52:00
Policy/Site No.
LA1.8 Local Employment Allocations - E23K# KENDAL LAND NORTH OF MEADOWBANK BUSINESS PARK
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Green field sites outside the already established town boundaries should not be used for
the purposes ofhousing or commercial development. Following this philosophy the unique character of the market town of Kendal can be preserved for all to enjoy.
290. Mr Kenneth Gibson (Individual) : 30 Mar 2012 12:24:00
Paragraph No.
1.10
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
1. Consultation
SLDC have widely publicised the consultation process concerning plans for the allocation ofland in South Lakeland. They have quoted in excess of 4000 respondents who have made comments concerning their plans. Many of the submissions have been published and from the samples we have checked it would appear that the vast majority of the local population are opposed to the plans as published. Further evidence of this opposition is now emerging with petitions calling for SLDC to hold a referendum on their proposals. It would appear that SLDC have engaged in the consultation process to satisfy the 'due process of consultation' but have simply ignored the vast majority of commentssubmitted. This brings into question the soundness of the consultation process which now can only be satisfied by holding a referendum concerning the acceptance ofthe Proposals for Allocations of Land in South Lakeland.
291. Mr Kenneth Gibson (Individual) : 30 Mar 2012 12:26:00
Paragraph No.
0.0 Whole Document
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
3. Low Cost Housing.
SLDC have effectively mounted a crusade concerning the need for low cost housing in South Lakeland. The cost of housing in the SLDC district is little above the national average however the average wage for South Lakeland workers is significantly less than the national average. The problem is therefore not the cost of housing but the low wage
economy.
In the South Lakeland area there is a severe shortage of high technology jobs. To obtain a
reasonable salary many of our qualified young people are forced to move outside the area
to pursue a career or commute. If we are to retain a balanced community, South Lakeland
needs to attract jobs to the area where the salary is above the national average. Building
low cost houses with high levels of dependency does not address this issue but rather
tends to stifle the positive effects of enterprise and investment.
SLDC have failed to address adequately the problem of attracting higher paid jobs to the
district. They have instead concentrated their efforts on the provision oflow cost housing.
SLDC have failed in this most important area of economic development and their proposals and arguments concerning the long term need for low cost housing are
fundamentally flawed and are unsound.
292. Mr Kenneth Gibson (Individual) : 20 Apr 2012 11:33:00
Policy/Site No.
LA1.4 - Kendal Sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Green field sites outside the already established town boundaries should not be used for
the purposes of housing or commercial development. Following this philosophy the unique character of the market town of Kendal can be preserved for all to enjoy.
293. Mr John Gill (Individual) : 14 Apr 2012 22:16:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.1 Development Boundaries- ENDMOOR
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
1 Density of houses on the site should be greatly reduced
2 A recent survey by the parish council showed a need for 10 houses, your proposal of 100 is not
acceptable and would show an increase of 48% of the village
3 Little thought of the sewerage system in and around Endmoor which is already running about its
capacity . Do we take this, that the new site would be having its own sewerage system.
4 Endmoor and district with its narrow roads and country lanes infrastructure would be stretched
beyond possibility.
5 Regarding another industrial site, we just do not need one. Summerlands and Gatebeck sites have
many sites vacant.
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
The village of Endmoor with a shop and an outreach Post office is no place for a development of this
size. I am not against any development, but its got to fit in with the area, to be in proportion.
The 100 houses and the pressures it would bring would cause the fragile infrastructure to collapse,
and the lack of consultation brings the soundness in to very much doubt.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
294. Mr John Gill (Individual) : 18 May 2012 14:05:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - M41M ENDMOOR NORTH OF SYCAMORE DRIVE
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
1 Density of houses on the site should be greatly reduced
2 A recent survey by the parish council showed a need for 10 houses, your proposal of 100 is not
acceptable and would show an increase of 48% of the village
3 Little thought of the sewerage system in and around Endmoor which is already running about its
capacity . Do we take this, that the new site would be having its own sewerage system.
4 Endmoor and district with its narrow roads and country lanes infrastructure would be stretched
beyond possibility.
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
The village of Endmoor with a shop and an outreach Post office is no place for a development of this
size. I am not against any development, but its got to fit in with the area, to be in proportion.
The 100 houses and the pressures it would bring would cause the fragile infrastructure to collapse,
and the lack of consultation brings the soundness in to very much doubt.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
295. Mr John Gill (Individual) : 18 May 2012 14:11:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.8 Local Employment Allocations - EN20, EN33# ENDMOOR LAND NORTH OF GATEBECK LANE, GATEBECK
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
5 Regarding another industrial site, we just do not need one. Summerlands and Gatebeck sites have many sites vacant.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
296. Mr Steven Gilyatt (Individual) : 9 May 2012 09:27:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - R151M-mod MILNTHORPE SOUTH OF MILNTHORPE
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Representation is made on behalf of myself and a number of other local residents/families who
previously authorised me to speak on their behalf at the SLDC Special Council meeting held on
18th January 2012 (copy of evidence attached containing 10 addresses and signatures). As a result
of the Council's approval to the LDF, which ignored our protests, the same group of people have
given me an extended mandate to represent them through public consultation and any subsequent examination by the Inspector.
Representation is made with regard to the "Soundness" of the DPD in the parts set out below, and I confirm that I have read the Guidance Notes for Making A Representation.
1.0 Development of Site,.R151M South of Milnthorpe is considered inappropriate, lacking
in justification, and inconsistent with the objectives of the Core Strategy
The approved DPD prop'osal is to build 70 dwellings on this site in 3 phases.
The frontal portion of the site sits directly on the A6, one of the prime routes into Cumbria
and the National Park, and currently provides a highly visible and historic boundary to the
village. Many of the properties along this definitive boundary are at least one hundred years
old, and a fine old Edwardian house with a turret sits in the centre. On the other (western)
side of the A6, the village edge is considerably enhanced by a fine stretch of the River Bela
and Dallam Park, part of the Arnside Silverdale Area of Outstanding Natural Beauty (AONB)
and an area of land that must be treated with extreme care and sensitivity.
The entire edge provides a fusion of views that may be described in a number of ways ranging
from beautiful to pleasing and comfortable, and what is important to note is that they stand in
the public domain and are available to all who enter and leave the village, the hub of which
sits around an old market square with a charter for a public market dating back to 1334. The
village is defined as a Key Service Centre for the region and is the first significant settlement
seen by visitors entering Cumbria.
As a further preamble I now draw upon several references taken from the Core Strategy
adopted by the SLDC on 20th October 2010:
• Section 2 CS1.1 Sustainable Development Principles (page 15) - 3 "There is a need to take
account of and enhance landscape character and features of those buildings and sites that
make a positive contribution to the special architectural or historic interest of the area ... "
• Section 2 CS1.1 Sustainable Development Principles (page 15) - 5 "It must be ensured
that a high quality, localised and appropriate design is incorporated into all developments
to retain distinctive character/sense of place and enhance the existing built environment."
• Section 6 Key issues .. 6.26 (page 69) "The area strategy aims to address the following
challenges: Maintaining and enhancing the natural, historic and other distinctive features
that contribute to the character of the local landscape and settlements ... and Recognising
the importance of the special qualities of the environment associated with the .. AONB and
its setting and character."
These references are but a few of many that have been drafted in a manner to recognise and sympathetically control the style and location of new development. Totally in keeping the DPD then contains the following:
• Section 3 Kendal and Surrounding Area (page 46) 3.2 "Factors influencing the location of
development in this area include: The Quality of the Built Heritage - long established
towns and villages with well defined character and form including ... Milnthorpe ... "
• Section 3 Kendal and Surrounding Area (page 76) 3.61 "Key local factors influencing the
location of new development in Milnthorpe are: Respecting the setting of the AONB and
Dallam Park in particular" and "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 such as the A6 ... "
Furthermore, whilst the thrust of 3.65 is not in favour of protecting Site R151M from
development, it does confirm that:
• "Key issues for this site include mitigating landscape impacts, particularly around the
frontage of the site with the A6 where it forms the entry point to the village and
secondly lies opposite very high quality landscape in the form of Dallam Park in the
Arnside Silverdale AONB.
In addition, Policy IA2.11 Land South of Milnthorpe - states that development requirements
should:
• "make provision for ... a substantial, high quality landscaped frontage to the A6"
From all this, it is evident that the SLDC recognises both the historic and environmental
importance of this site and the strong need to mitigate the (detrimental) impact of their
approval to develop it. However, by applying the rational objectives and intended controls of
the Core and DPD strategy, I am of the strong opinion that with particular reference to the
criterion cited above, development of the site cannot be soundly justified. It is my sincere
view that the choice of this site reflects its convenience and availability to the SLDC as
opposed to its total suitability. In essence:
1. Development would not "maintain or enhance" the historic village boundary, but would
screen and cause visual harm to a pleasing elevation that has stood intact for over one
hundred years, and is appreciated by all who enter and leave the village along a key
approach to the South Lakes and the National Park.
2. Development would obscure an important part of the village's intrinsic and "well defined
character and form"
3. The challenge to "maintain or enhance ... distinctive features that contribute to the
character of the local landscape and settlements" has not been sympathetically recognised
or pursued.
4. High quality landscaping is merely a cosmetic attempt to conceal the true reality, the loss
of another slice of local character.
5. New housing including a proportion of the affordable type would be totally incompatible
with either the natural or the existing built environment; i.e. it would neither respect the
immediate proximity and setting of the adjacent AONB or the existing characterful and
mature village edge.
6. Removing a clear view of this (arguably) single prime boundary would further dilute the
historic nature of the village and a sense of place for its residents. I represent a number of
people who are at least second generation residents of Milnthorpe and they fully endorse
these feelings.
7. Approval would set a potentially harmful precedent for future ribbon development along
the same valley side facing the Arnside Silverdale AONB, representing further
encroachment on open land.
8. Development would result in the loss of high quality grazing land for both sheep and cattle that has been farmed for centuries, and I understan that the tenant farmer, not the
landowner, would be most unhappy about its loss!
9. The conclusion quoted in the Settlement Fact Files that "high quality development would
not have a detrimental impact on the AONB" is an opinion shared only by those with a
determined interest in developing the site. In my view it is subjective and unrepresentative
of the public's view point. The SLDC is bent on developing this site whatever objections
may be raised.
3.0 The DPD is not effective or deliverable, citing examples in Milnthorpe
Even if we agreed with the proposed development of Site R151M, we believe it necessary to
flag a case of flawed timing. Within the SLDC's Consultation Statement it is confirmed by
United Utilities (UU) "that improvements are required to the Strand Pumping Station before
development can proceed" or in slightly more specific terms " ... investment and modelling is
required before any development could take place." In this respect it is understand that UU will
apply for funds in 2014 for the budget period 2015 - 2020, and thereafter, if approved, a set
of programme priorities will be established.
By comparison, the DPD sets a clear target of 20 dwellings to be completed on this site in
Phase 1 by 2017 (71 dwellings in total for all Milnthorpe sites) regardless of the fact that even
assuming funding is obtained, UU may not even have started their infrastructure upgrade by
this date.
The same absence of proper detailed planning is reflected in the educational sector, and I am
not aware of any Cumbria County Council plans to accommodate the additional school places
that will certainly be required in Milnthorpe.
Taking a broader view, the DPD is required to be deliverable across the entire region and yet
the general consensus amongst those who have read the documentation in some detail is that
infrastructure planning remains, at best, a "position statement" that outlines the needs and
challenges without the certainty or glue of any coordinated commitments from delivery
partners."
Therefore, my conclusion on this point is that the DPD is not effective, sound infrastructure
delivery planning is absent and cannot be shown on any plausible critical path for development of sites in Milnthorpe. To enter into such a scale of high profile development on a presumption
that "everything will be fine on the night" reflects "scary" unsound principles.
Conclusion
In general I consider many aspects of the DPD to be unsound, but my particular concerns are
centred on Milnthorpe village and its southern edge where I live. I further endorse the separate
"Green Spaces" Representations on the soundness of the DPD.
Having devoted much time and energy to opposing the development of Site R151M including
representation at the Special Council Meeting on behalf of a South Milnthorpe Residents Group, I
consider it appropriate for me to complete my opposition by participating in an oral examination
with the planning inspector. I now respectfully request such an opportunity
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
Having devoted much time and energy to opposing the development of Site R151M including
representation at the Special Council Meeting on behalf of a South Milnthorpe Residents Group, I
consider it appropriate for me to complete my opposition by participating in an oral examination
with the planning inspector. I now respectfully request such an opportunity.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
297. Mr Steven Gilyatt (Individual) : 9 May 2012 09:33:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - All Milnthorpe sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Representation is made on behalf of myself and a number of other local residents/families who
previously authorised me to speak on their behalf at the SLDC Special Council meeting held on
18th January 2012 (copy of evidence attached containing 10 addresses and signatures). As a result
of the Council's approval to the LDF, which ignored our protests, the same group of people have
given me an extended mandate to represent them through public consultation and any subsequent
examination by the Inspector.
2.0 The continuing development of Milnthorpe village due to its designation as a Key
Service Centre cannot be "indefinitely" justified
Further comment is added here in respect of Milnthorpe being designated as a Key Service
Centre, and I wish to reiterate objections cited by a senior member of the community within
The Planning Inspectorate's Report of 1996 under the head "South Lakeland Local Plan 2006"
page 6. The extracts I quote are:
• "No account is taken of the need to maintain the local character and distinctive sense
of locality when promoting Mi/nthorpe for development," and
• "... there has been a failure to protect Milnthorpe from a destabilising /eve/ of
development over a very long period and a halt should be called."
At the time, these objections were not upheld as it was decided "that development should
continue to be concentrated in the towns and villages" and the Council was "right to identify
larger settlements for the promotion of development." However, a further proviso indicated ''a
need to approach future developments ... cautiously, with the development boundary identified
as an important mechanism to retain ... character."
In the light of the SLDC returning to Milnthorpe, I would now argue more strongly than before
that the village has reached an optimum size and accommodating additional housing, traffic,
social services, education and the like should not be enforced. The DPD lacks a robust and
persuasive evidence base and a sustainable policy to counter the following:
1. The small and easily overcrowded village hub. Traffic from R151M and other sites having
to use the A6 would further congest the traffic lights and narrow village cross-roads,
particularly at peak times of day. Also bear in mind that a new village Spar with petrol
pumps on the A6, around one hundred yards south of the lights, and a new Booths
supermarket accessed off the very narrow Park Road, a similar distance from the lights,
will add yet more traffic problems. The entrance/exit to Booths is located at one of the
narrowest points of Park Road and between here and the traffic lights the road is only able
to accommodate one large HGV type of vehicle driving in a single direction. As a result of
this the traffic lights can be blocked to free flowing traffic.
2. In addition to housing, further industrial expansion is planned just off-centre of the village
along Park Road to the west, and then east of the village at The Mainline Business Park.
Both sites will need to use the narrow B road which intersects the A6 at the same traffic
lights in the heart of the village. For the 7 years I have lived in the village, large amounts
of space have always been available for rent in the existing industrial parks, and I would
seriously query the need for more. The South Lakes and the National Park are by their
special nature, primarily suited to tourism and leisure, and all forms of industrial expansion
should be carefully monitored.
3. Existing parking for the post office, dental and doctor's surgeries, and the pharmacy is
virtually non-existent, and in certain parts hazardous. Along with shoppers and other
casual visitors to the village, the only alternative to using the very restrictive and
invariably full village square car park is to use the off-centre pay and display car parks,
which charge typically high South Lakeland fees. This scenario discourages tourists and
locals alike and proof of this may be seen in the many letters of complaint that have been
published in the Westmorland Gazette over the years. On market days, cars often park in
the lay-by on the southern A6 edge of the village and the occupants then walk into the village to do their shopping.
4. The DPD acknowledges that the local primary school is at or near capacity, but no solution
has been tabled. Likewise, I believe that the Dallam secondary school is in a similar
position and the school has already expanded to the boundary with Ackenthwaite, contrary
to the Core Strategy principle that Milnthorpe and Ackenthwaite should not coalesce!
5. The fact that Milnthorpe services other nearby villages, some of which are also scheduled
for expansion.
6. The village sits in a valley and the general topography is not suited to further serious or
economic development. The retention of ridgelines and important views remain a major
issue and their protection is essential for the village to retain its character and sense of
location.
7. No brown field sites have been identified in Milnthorpe contrary to Core Strategy CS6. 6
"seeking to ensure that at least 28% of housing development takes place on previously
developed land and buildings" To my knowledge little if nothing has been adequately
pursued to meet this commitment as such space in Milnthorpe appears conveniently
"limited. H
As a consequence, I would respectfully request the SLDC to at least pause and reconsider far
more thoroughly all of the key issues affecting the village and its quality of life.
Moreover, the new National Planning Policy Framework (NPPF) has just been issued, out of
which I understand that Councils will be given further time to consider, Identify and protect
green spaces. I would also encourage the SLDC to abide by the spirit and intent of the recent
Localism Act, which promotes neighbourhood planning. The essence being that local
communities should be constructively engaged in the planning process on the basis that they
should possess a clearer and more sympathetic understanding of what they consider best for
their own towns and villages.
The SLDC should look beyond Milnthorpe for development and reconsider the Taylor Review
proposed by the Kendal Town Council (KTC), but rejected by the SLDC in respect of planning
around historic market towns/villages. I consider it prudent that the SLDC takes a longer term
view and commits now rather than later to the wiser "hub and spoke" form of planning
proposed by Taylor and the KTC. The NPPF would appear to provide the vehicle for pause and
reflection on what I and many others consider to be a flawed LDF/DPD.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
Having devoted much time and energy to opposing the development of Site R151M including
representation at the Special Council Meeting on behalf of a South Milnthorpe Residents Group, I
consider it appropriate for me to complete my opposition by participating in an oral examination
with the planning inspector. I now respectfully request such an opportunity.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
298. Mr Steven Gilyatt (Individual) : 9 May 2012 09:36:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
0.0 Whole Document
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Representation is made on behalf of myself and a number of other local residents/families who
previously authorised me to speak on their behalf at the SLDC Special Council meeting held on
18th January 2012 (copy of evidence attached containing 10 addresses and signatures). As a result
of the Council's approval to the LDF, which ignored our protests, the same group of people have
given me an extended mandate to represent them through public consultation and any subsequent
examination by the Inspector.
4.0 Strategy re affordable housing lacks a plausible evidence base
The chronic need in the South Lakes is for affordable, not open market housing, and to
address this cardinal requirement roughly one third of all housing has to be "affordable." To
overcome funding shortfalls, the method proposed by the SLDC is for developers to build both,
thus necessitating the acquisition of three times the amount of land - mainly green field sites -
realistically required. This will produce a potentially devastating and irreversible impact on the
environment, and to provide the number of affordable dwellings so urgently required, all 6,000
plus homes approved by the LDF will have to be completed.
The overall housing programme is phased through until 2025 and yet affordable homes are
immediately required! Concurrent with this scenario is the fact that the volume of open-market
housing proposed is not required in the current climate, existing and new houses are not
selling in the area, mortgages are difficult to come by, and even the affordable housing
currently under construction by developers is beyond the means and/or circumstance of those
in need; e.g. The Cock and Dolphin development in Kendal, 20 minutes drive from Milnthorpe.
A professional colleague of mine who works in the construction industry in the London area
and has knowledge of single scheme developments similar to those proposed by the SLDC
states that they are very difficult to operate effectively, and so what is the answer? My opinion
is that the SLDC should acknowledge the realities that abound in the economic climate,
continue to actively seek and encourage partnerships with housing associations and the like,
think creatively as to how appropriate funding may be obtained, and source suitable small
sites, brown or green, upon which to build affordable housing. Accept that traditionally
affordable homes fall within the remit of housing associations and concentrate efforts in this
field. To proceed otherwise would not be plausible.
At the Special Council Meeting held on 18'h January 2012, the senior PD member present
stated that insufficient smaller sites were available. This is incomprehensible given the amount
of land that appears available for large scale development, and suggests to me that the SLDC
is totally subject to the dictates of local landowners who are only willing to offer acreage that
turns in a more handsome profit. Are we as local residents to permit such greed at the
expense of our countryside, and accept the potentially ruinous nature of associated policies?
This is an extensive topic and for the sake. of brevity I have restricted my comments and
concerns. It is possible that whilst recognising the nationwide need for affordable housing, the
lack of central government funding to support its principles is encouraging councils to promote
flawed planning solutions.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
Having devoted much time and energy to opposing the development of Site R151M including
representation at the Special Council Meeting on behalf of a South Milnthorpe Residents Group, I
consider it appropriate for me to complete my opposition by participating in an oral examination
with the planning inspector. I now respectfully request such an opportunity.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
299. Mr Steven Gilyatt (Individual) : 9 May 2012 09:40:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
1.10
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Representation is made on behalf of myself and a number of other local residents/families who
previously authorised me to speak on their behalf at the SLDC Special Council meeting held on
18th January 2012 (copy of evidence attached containing 10 addresses and signatures). As a result
of the Council's approval to the LDF, which ignored our protests, the same group of people have
given me an extended mandate to represent them through public consultation and any subsequent
examination by the Inspector.
5.0 Public Consultation has not been effectively promoted and impartially evaluated
This may be expressed as follows:
The response of our local community has largely been ignored and consultation has been
minimal:
1. At the only parish council meeting held to engage with the public, the majority of those
present raised objections to the proposed sites, but more worryingly, at the same meeting
I overheard an invited representative from the SLDC remark that regardless of public
opinion, development of the scale proposed would go ahead.
2. From conversations with many in the local community, the SLDC/Pianning Department
received numerous objections to its proposed sites during open days held in the village.
3. The Parish Council's "unanimous" decision to approve the allocation of sites in Milnthorpe
cannot be considered a valid representative opinion. Wlth the exception of what i have cited above, no other forms of wider community polling were conducted and the decision
reflects the views of a small minority, those lay persons holding seats on the Council.
4. A potential conflict of interest lies within the system as some parish councillors live in the
adjacent village of Ackenthwaite where proposed development is minimal..!
5. Secondary consultation with the SLDC/Pianning Department on alternative sites proved to
be a cynical waste of time. Interested members of the public were issued with area maps
showing sites marked by the Planning Department (PD) as potential alternatives,
particularly in Ackenthwaite. However, these sites were then readily dismissed raising the
question of why they were promoted by the PD in the first instance? Perhaps to complete
the "box ticking" exercise! This raises the question, has the PD met the criteria " ...
appropriate strategy when considered against reasonable alternatives .. '?
At the Special Council Meeting on 1B'h January 2012, local councillors voted to approve the
LDF along party political lines - refer to the resultant voting - and those members who were
requested to help their constituents singularly failed to do so, either during earlier public
consultation or during the meeting itself.
For example, I quote a response received from my local councillor in Milnthorpe, after I had
expressed my disappointment at his lack of support in the said meeting: "Last Wednesday's
meeting was a necessary formality as the outcome was never in doubt. It was an opportunity
for speech making for those who like to, but the real work had been done before the meeting
.. " I do not possess the statistics for Milnthorpe, but in the Kendal area I presume that some
of the "real work" of the SLDC was to ignore the fact that over 98% of responders opposed the
DPD as written!
Documentation supporting the DPD is extensive and complex containing many thousands of
pages. I do not consider the format to be user-friendly, and to find information relating to a
particular settlement it is necessary to read or "skim" through excessive amounts of paperwork
taking up considerable time.
For these reasons, I consider individual members of the public to be seriously disadvantaged
when attempting, mainly in their spare time, to search for and evaluate evidence and the like
assembled by a full time body of professional staff over many months and years. And what of
those members of the public without computers, who would need to spend many hours and
days in their local libraries, and whose subsequent representation would then need to be
painstakingly handwritten?
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
Having devoted much time and energy to opposing the development of Site R151M including
representation at the Special Council Meeting on behalf of a South Milnthorpe Residents Group, I
consider it appropriate for me to complete my opposition by participating in an oral examination
with the planning inspector. I now respectfully request such an opportunity.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
300. Mrs Ann Gough (Individual) : 2 Apr 2012 18:22:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
SO Site Omission
If you have selected a ‘Site omission’ please enter the site reference or location and relevant policy below
We wish to question the justification of parts of the proposals contained within the above document for the following reasons :
A) Housing:
Sycamore Close site (M41M/R670 on map)
- Housing has been increased to 100 houses although only 62 houses were agreed after
consultation. 62 new homes seemed to meet the accepted need, including
affordable housing.
- 100 houses, is 30 houses per hectare, this is contrary to the South Lakeland
District Council Development Framework and too intensive.
- It is vital to protect the local landscape and valuable features, such as the 2 drumlins. This was one reason for the rejection of the showground proposal. 62 houses may be able to retain these features and include some open space.
- Sewerage is a concern as the present system is overloaded and United Utilities do not propose new sewerage facilities at Low Park for 5 years.
Bowling Green site, Doves Nest Lane (R670)
- 25 houses proposed would need to be in keeping with area.
- Concern regarding the traffic this will generate around small lanes and the junction with the roads up to the main A65.
- Where would cars park, especially if the bowling club was in use?
- Present sewerage facilities are already at full capacity.
This increased housing would be a 48% increase in the number of houses which is a 145% increase for a rural village. The village does not have the necessary infrastructure, such as sewerage, suitable roads, lighting or footpaths, so would this be deliverable?
It is a working village not full of holiday homes and the local landscape, environment and character should be maintained.
Gatebeck Lane site (EN20 & EN33) commercial development for storage,
distribution or warehousing.
- All these uses are reliant on transport and the crematorium was partly turned down because of the Highways concerns that Gatebeck Lane is narrow and already has traffic from the quarry, Wilsons and Industrial sites in Gateback.
- There are no footpaths or lighting, but there are bends and blind summits
- Cars from Low Park already have difficulty with visibility in accessing Gatebeck Lane.
- Is such development justified when there is already spare capacity at Gateback Industrial site and Summerlands (Off opposite side of A65)?
We have lived in this area for over 20 years and we are concerned that the character is maintained of a working village but with important rural landscape and surrounding area.
We hope that our concerns will be taken into account.
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Rectification in respect of comments made in Representstion above...
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
301. Lady Anne Graham (Individual) : 19 Apr 2012 10:31:00
Policy/Site No.
LA1.3 Housing Allocations - All Grange-over-Sands sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I wish to object in the strongest terms to the adoption of the above plan.
There are few remaining greenfield sites between Grange-over-Sands and Kents Bank. It is crucial that these should be retained in order to spearate these communities and thus avoid an undesirable urban sprawl. The same point applies equally to Kents Bank and Allithwaite and to Cartmel, Cark and Flookburgh. These are all SEPARATE communities and should remain so.
If the SLDC consider that a large number of 'affordable' homes are needed in the District, then the SLDC should provide them on 'brown' field sites, together with the necessary infrastructure, and with the necessary financial help from the government (possibly in conjunction with housing associations).
302. Lady Anne Graham (Individual) : 19 Apr 2012 10:39:00
Policy/Site No.
LA1.3 Housing Allocations - All Cartmel sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I wish to object in the strongest terms to the adoption of the above plan.
There are few remaining greenfield sites between Grange-over-Sands and Kents Bank. It is crucial that these should be retained in order to spearate these communities and thus avoid an undesirable urban sprawl. The same point applies equally to Kents Bank and Allithwaite and to Cartmel, Cark and Flookburgh. These are all SEPARATE communities and should remain so.
If the SLDC consider that a large number of 'affordable' homes are needed in the District, then the SLDC should provide them on 'brown' field sites, together with the necessary infrastructure, and with the necessary financial help from the government (possibly in conjunction with housing associations).
303. Lady Anne Graham (Individual) : 19 Apr 2012 10:44:00
Policy/Site No.
LA1.3 Housing Allocations - All Flookburgh sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I wish to object in the strongest terms to the adoption of the above plan.
There are few remaining greenfield sites between Grange-over-Sands and Kents Bank. It is crucial that these should be retained in order to spearate these communities and thus avoid an undesirable urban sprawl. The same point applies equally to Kents Bank and Allithwaite and to Cartmel, Cark and Flookburgh. These are all SEPARATE communities and should remain so.
If the SLDC consider that a large number of 'affordable' homes are needed in the District, then the SLDC should provide them on 'brown' field sites, together with the necessary infrastructure, and with the necessary financial help from the government (possibly in conjunction with housing associations).
304. Lady Anne Graham (Individual) : 19 Apr 2012 10:45:00
Policy/Site No.
LA1.3 Housing Allocations - All Allithwaite sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I wish to object in the strongest terms to the adoption of the above plan.
There are few remaining greenfield sites between Grange-over-Sands and Kents Bank. It is crucial that these should be retained in order to spearate these communities and thus avoid an undesirable urban sprawl. The same point applies equally to Kents Bank and Allithwaite and to Cartmel, Cark and Flookburgh. These are all SEPARATE communities and should remain so.
If the SLDC consider that a large number of 'affordable' homes are needed in the District, then the SLDC should provide them on 'brown' field sites, together with the necessary infrastructure, and with the necessary financial help from the government (possibly in conjunction with housing associations).
305. Lady Anne Graham (Individual) : 30 Apr 2012 14:25:00
Policy/Site No.
LA3.1 Mixed Use Allocation at Berners Pool, Grange-over-Sands
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I wish to object in the strongest terms to the adoption of the above plan.
There are few remaining greenfield sites between Grange-over-Sands and Kents Bank. It is crucial that these should be retained in order to spearate these communities and thus avoid an undesirable urban sprawl. The same point applies equally to Kents Bank and Allithwaite and to Cartmel, Cark and Flookburgh. These are all SEPARATE communities and should remain so.
If the SLDC consider that a large number of 'affordable' homes are needed in the District, then the SLDC should provide them on 'brown' field sites, together with the necessary infrastructure, and with the necessary financial help from the government (possibly in conjunction with housing associations).
306. Lady Anne Graham (Individual) : 30 Apr 2012 14:29:00
Policy/Site No.
LA3.2 Mixed Use Allocation at Land South of Allithwaite Road, Kent's Bank, Grange-over-Sands
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I wish to object in the strongest terms to the adoption of the above plan.
There are few remaining greenfield sites between Grange-over-Sands and Kents Bank. It is crucial that these should be retained in order to spearate these communities and thus avoid an undesirable urban sprawl. The same point applies equally to Kents Bank and Allithwaite and to Cartmel, Cark and Flookburgh. These are all SEPARATE communities and should remain so.
If the SLDC consider that a large number of 'affordable' homes are needed in the District, then the SLDC should provide them on 'brown' field sites, together with the necessary infrastructure, and with the necessary financial help from the government (possibly in conjunction with housing associations).
307. Lady Anne Graham (Individual) : 30 Apr 2012 14:34:00
Policy/Site No.
LA3.3 Mixed Use Allocation at Guide's Lot, Grange-over-Sands
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I wish to object in the strongest terms to the adoption of the above plan.
There are few remaining greenfield sites between Grange-over-Sands and Kents Bank. It is crucial that these should be retained in order to spearate these communities and thus avoid an undesirable urban sprawl. The same point applies equally to Kents Bank and Allithwaite and to Cartmel, Cark and Flookburgh. These are all SEPARATE communities and should remain so.
If the SLDC consider that a large number of 'affordable' homes are needed in the District, then the SLDC should provide them on 'brown' field sites, together with the necessary infrastructure, and with the necessary financial help from the government (possibly in conjunction with housing associations).
308. Lady Anne Graham (Individual) : 30 Apr 2012 14:35:00
Policy/Site No.
LA1.8 Local Employment Allocations - EN42# CARK STATION YARD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I wish to object in the strongest terms to the adoption of the above plan.
There are few remaining greenfield sites between Grange-over-Sands and Kents Bank. It is crucial that these should be retained in order to spearate these communities and thus avoid an undesirable urban sprawl. The same point applies equally to Kents Bank and Allithwaite and to Cartmel, Cark and Flookburgh. These are all SEPARATE communities and should remain so.
If the SLDC consider that a large number of 'affordable' homes are needed in the District, then the SLDC should provide them on 'brown' field sites, together with the necessary infrastructure, and with the necessary financial help from the government (possibly in conjunction with housing associations).
309. Mr Christopher Graves (Individual) : 15 Apr 2012 22:58:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - R675M-mod HOLME WEST OF BURTON ROAD
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I do not consider myself qualified to pass comment against this section
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I consider the overall “Soundness” of the proposed development of R675M questionable. My comments follow: (these refer to sections from the Holme Fact File (Ref 1 “South Lakeland Local Development Framework – Land Allocations Plan Document Holme Fact File - February 2012 Version”)
“Soundness”
"Justified"
"Evidence of participation of the local community and others having a stake in the area"
Local community has had some engagement in the process. An exhibition/display was held in the parish hall where the original proposals were shown.
Some scaling back of the developments has since occurred but many still consider the scale of the developments beyond those which a village with limited infrastructure (or suitable space to develop such necessary infrastructure) can sustain. Considerable development has taken place in the village with some 238 dwellings being added between 1991 & 2009 (Ref 1 “Key Characteristics - Housing”)
"Research/fact finding: the choices made in the plan are backed up by facts"
Some effort has been invested to develop the Holme Fact File (Ref 1), though this seems to understate the consequences of building a large number of new dwellings in an already quite built up village. Holme village risks losing more of its character as it becomes closer to a commuting suburb for people who commute to work – particularly in Lancaster or Kendal - though longer distance commutes are already a feature of life.
"Effective"
"Sound infrastructure delivery planning"
Holme General
There have been 238 dwellings built in Holme in the period 1991 to 2009 (with 119 of these built since 2003 - data from Ref 1 “Key Characteristics - Housing”). This increase in housing has not been matched by any commensurate increase in the village facilities.
The main access roads in the village (Station Road, North Road, Burton Road and Milnthorpe Road) have areas which are regularly double parked as existing residents have nowhere else to leave their vehicles. Additional traffic generated by new housing developments would need to utilise these main thoroughfares. The Parish Plan identifies parking and speeding (Ref 1 “Accessibility”) as dangers and the addition of more housing will not improve the parking issue.
Since the data was collected for the “Holme Fact File” (Ref 1 ‘Key Characteristics’ –The Economy”) the former Methodist chapel has now closed, and there is only the Parish Church (Holy Trinity).
There are business facilities in units at Dalton Hall, Levens Hall, Clawthorpe Hall and the new auction mart complex near Crooklands all within easy reach by car, though public transport is poor with buses at approximately hour intervals through the day through Burton to Lancaster and through Milnthorpe to Kendal and beyond.
Site R675M (proposed allocation)
Access to housing proposed on R675M is restricted to the opening between two dwellings onto Burton Road. This junction has poor sight lines in both directions:
Towards Burton the road rises to the listed humpbacked canal bridge a short distance away with very poor visibility of oncoming traffic.
Towards Milnthorpe the road is rising from the village centre and visibility is often obscured by parked vehicles
Access is referred to in the “Assessment Process” in a number of areas – generally relating to the much larger originally proposed R675 where there were a number of possible, though far from ideal, access possibilities. Site R675M does not have access to these other possible routes in/out and consequently “Highways Issues” including ‘Transport Assessment’ and ‘Transport Statement’(Ref 1) will need to be carried out and satisfactory conclusions reached by Cumbria County Highways. (Note Appendix 1E refers to access as “problematic”)
Pedestrian access to the site will be from the same point on Burton Road as vehicular access. This will mean that properties within the development will be sufficiently far from the village centre facilities to generate further local traffic journeys to service the new resident’s needs.
The “Assessment Process” (Ref 1) refers to the “Sustainability Appraisal” ‘negatively scoring issues including biodiversity interest and impact on listed buildings and structures canal bridges re site R675 and Pinders Farm re site RN94’. No mention is made of Bridge House – also listed – which adjoins R675M and which would be adversely affected by developments on site R675M.
Landscape issues raise a number of concerns (Ref 1 “Landscape Issues” ’The Cumbria Landscape Character Guidance’). The site is not flat and consequently their advice on developments “…of high quality and well related to the distinctive grain and scale of this landscape” and “avoiding siting development on prominent hill tops or cutting across slopes” should be adhered to so that future residents of Holme can enjoy the quality of life enjoyed by today’s residents. Any development is likely to “…disrupt the long held pattern” of farming as the current land use will be lost forever when the development commences.
It is a point of interest that the ‘open spaces such as orchards and gardens’ (are somewhat protected) whereas amenity enjoyed by many villagers of open fields is considered less important.
The owners of Bridge House face the prospective further irony prospect of being significantly overlooked by the proposed development R675M and yet unable to develop their ‘orchards and gardens’ to take advantage of the general relaxation of planning laws currently being rolled out should they or future owners wish to.
Although having no pond or other water feature the garden at Bridge House has frequently been visited by a variety of amphibians including toads, frogs and newts (supporting the comment of ‘’………..the site look to be rough grassland may have reptile and invertebrate interest’ Ref 1 “Biodiversity/Geodiversity”)
Flooding has been an issue in the past (as evidenced by Ref 1 “Flooding”), the more rapid run off of surface water from roofs and paved/tarmaced roads of the development will need to be carefully considered. The garden of Bridge House rises towards the site and the owners are concerned about this issue.
"Having no regulatory or national barriers to delivery"
Not qualified to make comment against this area
"Delivery partners who are signed up to it"
The Delivery Partners will inevitably have a vested interest in the proposed developments, where are the appropriate checks and balances? The consultation process has a democratic basis but many have failed to become engaged.
"Coherence with the strategies of neighbouring authorities"
Not qualified to make comment against this area
310. Mr Norman Green (Individual) : 17 Apr 2012 15:58:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - All Grange-over-Sands sites
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I have insufficient knowledge of how the whole process has been conducted to challenge its legality so have clicked 'yes' for that reason. I appreciate that others with a greater involvement do not accept its legality.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
As far as Grange is considered, start again? That may sound sarcastic but I have spent some time today reading your documents on Grange and then looking at the proposed sites. The description of what you want for this town do not seem to tally with the planned building.
I found the submission at no. 268 on this response site and the leaflet by The Grange and District Action Group both accurately challenged your approach strongly.
My own observations are as follows:
1. The Grange Town Mayor has more than once raised the issue of the physical layout of the town in relation to further development. i.e. the main road in and out is narrow, with many bends and in parts steep. There is already a high level of car ownership in this town. The issue of hundreds of extra houses generating not only more cars but more delivery traffic has not been properly addressed in the document. The roads are already congested and parking restricted. There seems little scope for road improvements given the town layout.
2. Kents Bank. This has a very distinctive peaceful semi-rural quality. At a presentation in Grange's Victoria Hall some time ago an S.L.D.C. representative referred to a mix of housing and industrial units in the Greaves Wood area. When he showed me the map he could not be specific about what industry he meant. Your document talks of 'employment opportunities'. If what you propose involves industrial units in or near Kents Bank it would be totally out of place here. Using words such as '...there will be a need for great sensitivity in locating here...' just sidesteps the issue.
3. Again, fine words about 'preserving green gaps' are contradicted by the actual plans to locate buildings so as to narrow existing settlements to within a couple of hundred metres of each other. Anyone who has spent any time in Kents Bank with its narrow quiet residential roads next to the bay could not seriously think that this environment is suitable for nearby industry or large amounts of extra housing. There are places such as the existing set of industrial units outside Lindale where industry and housing work well near (but not too near) to each other. The layout of Kents Bank does not make it one of them.
4. It has already been pointed out that there are many unsold houses in Grange, many at the lower price end. We all know that we need more housing in appropriate places. Appropriate being the operative word. This is not a case of nimbyism. It should also not be a case of the Council fulfilling pre-determined quotas, building in inappropriate places whatever the transport and environmental cost and just hoping for the best.
Finally, in the light of extensive growth, how exactly will ongoing infrastructure, environment and quality-of-life issues be reviewed and addressed? I don't see any convincing plans in your documents. Will a gradual degrading of these things be accepted as a price that has to be paid for development?
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
311. Ms Denise Green (Individual) : 27 Apr 2012 10:20:00
Policy/Site No.
LA1.3 Housing Allocations - M41KM KENDAL SOUTH OF LUMLEY ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Loss of green field space is detrimental to the character and heritage of the area. This is contrary to Coalition Government Sustainable Development Policy, which recognizes brown field preference above important countryside areas. The Soundness and legality of the plan is therefore challenged as being contrary to Government Planning Policy.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I wish to object to and challenge the soundness of proposed land allocation for development – to south of Lumley Rd. (M41KM) and Scroggs Wood Light Industrial Site (E4M) on the following grounds:
- The proposed developments would spoil the initial impression to Kendal visitors, being on the main access route and adjacent to the Town boundary. The Lumley road site is steeply graded and properties would impose on the existing view for Kendal visitors. The line of trees acts as a natural barrier between countryside and properties. Building to the South of this line (E4M), would fundamentally change the Kendal “Gateway to the Lakes” character as a valued landscape. This is contrary to the adopted planning Core Strategy. The Soundness of the plan is therefore challenged on visual impact grounds, contrary to planning policy.
- Loss of green field space is detrimental to the character and heritage of the area. This is contrary to Coalition Government Sustainable Development Policy, which recognizes brown field preference above important countryside areas. The Soundness and legality of the plan is therefore challenged as being contrary to Government Planning Policy.
- Milnthorpe road already backs up to the bypass at peak times and cannot accommodate the massive increase that such development, in these locations, would create. Kendal town development to attract visitors is pointless if they cannot obtain satisfactory access. The associated pollution from stationary traffic is incompatible with sustainable development objectives. The soundness of the development is challenged on the basis that there is no traffic plan to address these issues.
- The A6 is a crucial access for emergency services, particularly following the downgrading of Westmorland General Hospital. Further congestion on this route would introduce undue risk. The potential for accidents when joining the main road would also be significantly increased. The Soundness of the plan is therefore challenged on safety grounds.
- The soundness of the development is challenged on the basis that there is inadequate local infrastructure including drainage, sewerage and roads.
- The proposed development is incompatible with the character of the historic Helsington development contrary to planning policy. The Soundness of the plan is therefore challenged as being detrimental to the historical character of the area.
- The site is clearly NOT “in an accessible location or an easily developable level site” (Achievability statement P133 2 C). The Soundness of the plan is therefore challenged as being contrary to this declared planning statement.
- There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of adequate existing residential space and more suitable alternative development sites.
The Development plan should retain the "Kendal Gateway to the Lakes" image supporting tourism and established Cumbrian employment, not destroy it with unsightly, unnecessary development and traffic jams. You don’t put your wheelie bin on your front door step! The DPD appears to have completely disregarded the massive opposition and valid objections previously made. The soundness of this planned development is challenged as disregarding local opinion contrary to Government Policy.
312. Ms Denise Green (Individual) : 27 Apr 2012 10:22:00
Policy/Site No.
LA1.6 Strategic Employment Sites - E4M KENDAL LAND AT SCROGGS WOOD, MILNTHORPE ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I wish to object to and challenge the soundness of proposed land allocation for development – to south of Lumley Rd. (M41KM) and Scroggs Wood Light Industrial Site (E4M) on the following grounds:
- The proposed developments would spoil the initial impression to Kendal visitors, being on the main access route and adjacent to the Town boundary. The Lumley road site is steeply graded and properties would impose on the existing view for Kendal visitors. The line of trees acts as a natural barrier between countryside and properties. Building to the South of this line (E4M), would fundamentally change the Kendal “Gateway to the Lakes” character as a valued landscape. This is contrary to the adopted planning Core Strategy. The Soundness of the plan is therefore challenged on visual impact grounds, contrary to planning policy.
- Loss of green field space is detrimental to the character and heritage of the area. This is contrary to Coalition Government Sustainable Development Policy, which recognizes brown field preference above important countryside areas. The Soundness and legality of the plan is therefore challenged as being contrary to Government Planning Policy.
- Milnthorpe road already backs up to the bypass at peak times and cannot accommodate the massive increase that such development, in these locations, would create. Kendal town development to attract visitors is pointless if they cannot obtain satisfactory access. The associated pollution from stationary traffic is incompatible with sustainable development objectives. The soundness of the development is challenged on the basis that there is no traffic plan to address these issues.
- The A6 is a crucial access for emergency services, particularly following the downgrading of Westmorland General Hospital. Further congestion on this route would introduce undue risk. The potential for accidents when joining the main road would also be significantly increased. The Soundness of the plan is therefore challenged on safety grounds.
- The soundness of the development is challenged on the basis that there is inadequate local infrastructure including drainage, sewerage and roads.
- The proposed development is incompatible with the character of the historic Helsington development contrary to planning policy. The Soundness of the plan is therefore challenged as being detrimental to the historical character of the area.
- The site is clearly NOT “in an accessible location or an easily developable level site” (Achievability statement P133 2 C). The Soundness of the plan is therefore challenged as being contrary to this declared planning statement.
- There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of adequate existing residential space and more suitable alternative development sites.
- There is spare capacity and expansion potential on existing established trading estates on Shap Road. The plan to relocate the Rugby club to Oxenholme and development of the Gilkes site are more suited to development than Scroggs Wood. The soundness of the case for such development is challenged on the basis of existing and more suitable alternative development sites compatible with planning policy.
- What and where is the business case and demand for a further speculative light industrial business park? Why would UK businesses move to such a park when financial assistance and tax breaks are available for designated City areas such as the Manchester Enterprise Zone? The soundness of this planned development is challenged on the basis of no established demand or business case.
- The Development plan should retain the "Kendal Gateway to the Lakes" image supporting tourism and established Cumbrian employment, not destroy it with unsightly, unnecessary development and traffic jams. You don’t put your wheelie bin on your front door step! The DPD appears to have completely disregarded the massive opposition and valid objections previously made. The soundness of this planned development is challenged as disregarding local opinion contrary to Government Policy.
313. Ms Denise Green (Individual) : 27 Apr 2012 10:24:00
Policy/Site No.
LA1.3 Housing Allocations - All Kendal sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of adequate existing residential space and more suitable alternative development sites.
314. Ms Denise Green (Individual) : 27 Apr 2012 10:27:00
Paragraph No.
0.0 Whole Document
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Is there a definition of “affordable housing” in the context of Kendal young person income? Or is this merely a rouse to allow land owners and builders to make massive profits, without any tangible commitment to house the low paid of Kendal? The Soundness is therefore challenged on the basis of no defined affordability test.
315. Ms Denise Green (Individual) : 27 Apr 2012 10:28:00
Policy/Site No.
LA1.4 - Kendal Sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of adequate existing residential space and more suitable alternative development sites.
316. Mr Norman Green (Individual) : 11 May 2012 15:49:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA3.1 Mixed Use Allocation at Berners Pool, Grange-over-Sands
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I have insufficient knowledge of how the whole process has been conducted to challenge its legality so have clicked 'yes' for that reason. I appreciate that others with a greater involvement do not accept its legality.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
As far as Grange is considered, start again? That may sound sarcastic but I have spent some time today reading your documents on Grange and then looking at the proposed sites. The description of what you want for this town do not seem to tally with the planned building.
I found the submission at no. 268 on this response site and the leaflet by The Grange and District Action Group both accurately challenged your approach strongly.
My own observations are as follows:
1. The Grange Town Mayor has more than once raised the issue of the physical layout of the town in relation to further development. i.e. the main road in and out is narrow, with many bends and in parts steep. There is already a high level of car ownership in this town. The issue of hundreds of extra houses generating not only more cars but more delivery traffic has not been properly addressed in the document. The roads are already congested and parking restricted. There seems little scope for road improvements given the town layout.
2. Kents Bank. This has a very distinctive peaceful semi-rural quality. At a presentation in Grange's Victoria Hall some time ago an S.L.D.C. representative referred to a mix of housing and industrial units in the Greaves Wood area. When he showed me the map he could not be specific about what industry he meant. Your document talks of 'employment opportunities'. If what you propose involves industrial units in or near Kents Bank it would be totally out of place here. Using words such as '...there will be a need for great sensitivity in locating here...' just sidesteps the issue.
3. Again, fine words about 'preserving green gaps' are contradicted by the actual plans to locate buildings so as to narrow existing settlements to within a couple of hundred metres of each other. Anyone who has spent any time in Kents Bank with its narrow quiet residential roads next to the bay could not seriously think that this environment is suitable for nearby industry or large amounts of extra housing. There are places such as the existing set of industrial units outside Lindale where industry and housing work well near (but not too near) to each other. The layout of Kents Bank does not make it one of them.
4. It has already been pointed out that there are many unsold houses in Grange, many at the lower price end. We all know that we need more housing in appropriate places. Appropriate being the operative word. This is not a case of nimbyism. It should also not be a case of the Council fulfilling pre-determined quotas, building in inappropriate places whatever the transport and environmental cost and just hoping for the best.
Finally, in the light of extensive growth, how exactly will ongoing infrastructure, environment and quality-of-life issues be reviewed and addressed? I don't see any convincing plans in your documents. Will a gradual degrading of these things be accepted as a price that has to be paid for development?
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
317. Mr Norman Green (Individual) : 11 May 2012 15:51:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA3.2 Mixed Use Allocation at Land South of Allithwaite Road, Kent's Bank, Grange-over-Sands
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I have insufficient knowledge of how the whole process has been conducted to challenge its legality so have clicked 'yes' for that reason. I appreciate that others with a greater involvement do not accept its legality.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
As far as Grange is considered, start again? That may sound sarcastic but I have spent some time today reading your documents on Grange and then looking at the proposed sites. The description of what you want for this town do not seem to tally with the planned building.
I found the submission at no. 268 on this response site and the leaflet by The Grange and District Action Group both accurately challenged your approach strongly.
My own observations are as follows:
1. The Grange Town Mayor has more than once raised the issue of the physical layout of the town in relation to further development. i.e. the main road in and out is narrow, with many bends and in parts steep. There is already a high level of car ownership in this town. The issue of hundreds of extra houses generating not only more cars but more delivery traffic has not been properly addressed in the document. The roads are already congested and parking restricted. There seems little scope for road improvements given the town layout.
2. Kents Bank. This has a very distinctive peaceful semi-rural quality. At a presentation in Grange's Victoria Hall some time ago an S.L.D.C. representative referred to a mix of housing and industrial units in the Greaves Wood area. When he showed me the map he could not be specific about what industry he meant. Your document talks of 'employment opportunities'. If what you propose involves industrial units in or near Kents Bank it would be totally out of place here. Using words such as '...there will be a need for great sensitivity in locating here...' just sidesteps the issue.
3. Again, fine words about 'preserving green gaps' are contradicted by the actual plans to locate buildings so as to narrow existing settlements to within a couple of hundred metres of each other. Anyone who has spent any time in Kents Bank with its narrow quiet residential roads next to the bay could not seriously think that this environment is suitable for nearby industry or large amounts of extra housing. There are places such as the existing set of industrial units outside Lindale where industry and housing work well near (but not too near) to each other. The layout of Kents Bank does not make it one of them.
4. It has already been pointed out that there are many unsold houses in Grange, many at the lower price end. We all know that we need more housing in appropriate places. Appropriate being the operative word. This is not a case of nimbyism. It should also not be a case of the Council fulfilling pre-determined quotas, building in inappropriate places whatever the transport and environmental cost and just hoping for the best.
Finally, in the light of extensive growth, how exactly will ongoing infrastructure, environment and quality-of-life issues be reviewed and addressed? I don't see any convincing plans in your documents. Will a gradual degrading of these things be accepted as a price that has to be paid for development?
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
318. Mr Norman Green (Individual) : 11 May 2012 15:54:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA3.3 Mixed Use Allocation at Guide's Lot, Grange-over-Sands
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I have insufficient knowledge of how the whole process has been conducted to challenge its legality so have clicked 'yes' for that reason. I appreciate that others with a greater involvement do not accept its legality.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
As far as Grange is considered, start again? That may sound sarcastic but I have spent some time today reading your documents on Grange and then looking at the proposed sites. The description of what you want for this town do not seem to tally with the planned building.
I found the submission at no. 268 on this response site and the leaflet by The Grange and District Action Group both accurately challenged your approach strongly.
My own observations are as follows:
1. The Grange Town Mayor has more than once raised the issue of the physical layout of the town in relation to further development. i.e. the main road in and out is narrow, with many bends and in parts steep. There is already a high level of car ownership in this town. The issue of hundreds of extra houses generating not only more cars but more delivery traffic has not been properly addressed in the document. The roads are already congested and parking restricted. There seems little scope for road improvements given the town layout.
2. Kents Bank. This has a very distinctive peaceful semi-rural quality. At a presentation in Grange's Victoria Hall some time ago an S.L.D.C. representative referred to a mix of housing and industrial units in the Greaves Wood area. When he showed me the map he could not be specific about what industry he meant. Your document talks of 'employment opportunities'. If what you propose involves industrial units in or near Kents Bank it would be totally out of place here. Using words such as '...there will be a need for great sensitivity in locating here...' just sidesteps the issue.
3. Again, fine words about 'preserving green gaps' are contradicted by the actual plans to locate buildings so as to narrow existing settlements to within a couple of hundred metres of each other. Anyone who has spent any time in Kents Bank with its narrow quiet residential roads next to the bay could not seriously think that this environment is suitable for nearby industry or large amounts of extra housing. There are places such as the existing set of industrial units outside Lindale where industry and housing work well near (but not too near) to each other. The layout of Kents Bank does not make it one of them.
4. It has already been pointed out that there are many unsold houses in Grange, many at the lower price end. We all know that we need more housing in appropriate places. Appropriate being the operative word. This is not a case of nimbyism. It should also not be a case of the Council fulfilling pre-determined quotas, building in inappropriate places whatever the transport and environmental cost and just hoping for the best.
Finally, in the light of extensive growth, how exactly will ongoing infrastructure, environment and quality-of-life issues be reviewed and addressed? I don't see any convincing plans in your documents. Will a gradual degrading of these things be accepted as a price that has to be paid for development?
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
319. Mr and Mrs Chris and Deb Greenwood (Individual) : 10 Apr 2012 20:38:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.1 Development Boundaries- KENDAL
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I submit that development of sites RN169M and RN299# would be unsustainable by being harmful to landscape character and quality and therefore contrary to the central principle of the Local Development Framework and Core Strategy and a number of policies contained therein.
Landscape Setting
The sites lie within an area of rolling farmland at the boundary between the carboniferous limestone of the Morecambe Bay Limestones Joint Character Area and the Coniston group of slates of the Cumbria Low Fells JCA of the Character Map of England. The area is a good representative sample of both leaning perhaps more towards limestone scenery immediately surrounding the site.
At the more local scale the site is classified as being within Landscape Character Type 7 – Drumlins, Sub-type 7b - Drumlin Field. This is not a common landscape type either locally, regionally or even nationally but is well represented in this locality. The combination of drumlin landforms overlain by a geometric net of fields gives this landscape a strong identity and a sense of both our natural and cultural history. This is high quality landscape in a highly visible and accessible location providing a unique setting to the town which nestles in the Kent valley. At the northwest boundary to the town development finishes abruptly with a well defined edge. This gives way to the rolling topography of the drumlin filled valley with the field pattern of pale coloured limestone walls picked out against the bright green improved pasture. Outwith the town boundary there is a dispersed settlement pattern with small, tight groupings of farm (or converted farm) buildings before the next significant settlement of Burneside further along the valley. This makes for an attractive landscape.
The closest building to the existing development boundary is Lane Foot Farm now a residential development of barn conversions converted in the mid 1990s. The farm is of some historic interest (the National Trust has a restrictive covenant on the farm buildings and this may also apply to the farmland) and is classed as a ‘single ancient farm’ in the Cumbria Historic Landscape Classification. The pattern of enclosure predates the enclosure acts and is of some historic interest also.
The elevated nature of sites ensures a wide zone of theoretical visibility and development would affect the view to the town from a wide area. Development would also seriously affect distant views north and west across the sites to the Whinfell Ridge, Shap, Longsleddale and Kentmere fells from Windermere Road. The bellmouth where the access road to Lane Foot Farm leaves the A5284 Windermere Road provides a viewpoint for many photographers.
The site is prominent from a number of housing areas, public roads and public rights of way. The footpath between Hallgarth and Hollins Lane/Burneside runs through the valley and closely adjacent to the site and it is prominent in the view from public rights of way on Kendal Fell. People using these paths are sensitive receptors out walking in the countryside specifically to enjoy the landscape.
The area including the site is the gateway to the Lakes when heading north/west and the setting for Kendal when heading south/east.
Policy context
The Land Allocations DPD outlines key local factors influencing the location of development (para 3.5). These include:
• Respecting the setting of the existing and potential future extent of the Lake District National Park which is close to the town;
Site E65 is within 50m of the National Park boundary juxtaposed with Kendal Fell and an important part of the setting from a wide range of viewpoints and an important approach to (and exit from) 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;
Windermere Road is obviously a key approach to the town through the attractive landscape of Kendal Fell rising out of the patchwork of improved pasture overlying the distinctive rolling drumlin field portraying Kentdales glacial past. The quality of the landscape setting to this approach to the town can be judged by the number of visitors photographing the landscape from the viewpoint at the bellmouth to the access lane to Lane Foot Farm.
• Avoiding coalescence between Kendal, Oxenholme, Burneside and Natland and maintaining the separate identities of these settlements;
Whilst a considerable physical separation would be retained between the two settlements the elevation and perspective of the sites would result in a disproportionate visual and perceptive closing of the gap between them.
• Safeguarding and enhancing the River Kent Special Area of Conservation an internationally important habitat, particularly for the seriously threatened White Clawed Crayfish;
Sites E65, RN 169, R674K and R46 are within 170-250m from an open water course containing White Clawed Crayfish and closer still to underground water courses which feed it, all within the River Kent SAC.
In the Core Strategy:
Policy CS1.1 - Sustainable Development Principles, states that:
2. It is vital to protect the countryside for its intrinsic beauty, diversity and natural resources and also for its ecological, geological, cultural and historical, economic, agricultura,l recreational and social value;
If each of these assets is evaluated in turn it becomes obvious that development of these sites would degrade the value of every single one.
Intrinsic beauty – interesting landform, sense of history, open views etc etc
Diversity – a major contributor to the variety of landscape in the area
Natural resources – Delivers eco-system services (water, food, sense of place etc)
Ecological, - river Kent SAC
Geological – good example of drumlin field
Cultural – field pattern, single ancient farm
Historical – as above
Economic – food production and contributor to areas main economic driver (landscape tourism)
Agricultural – good quality farmland (sheep & cattle grazing)
Recreational – visual amenity and rights of way
Social value – all of the above.
3. There is a need to take account of and enhance landscape character and features particularly the AONB and coastal areas. The whole area’s role as a setting for and gateway to the Lake District and Yorkshire Dales National Parks should be developed.
This part of Kendal is closest to the Lake District National Park and an important part of its setting, just as the National Park is an important part of the setting for Kendal. Development of these sites threatens to degrade the setting of both.
Policy CS2 – Kendal Strategy, states that:
• Ensure that Greenfield development is sympathetic to the landscape character of Kendal and to the historic character and setting of Kendal and may also need to address archaeological impacts.
As outlined above I believe that the landscape character, historic character and setting of Kendal will all be harmed by development of these sites.
• Ensure that new development safeguards and enhances the natural environment and local biodiversity – notably SSSIs and SACs within the area, including the River Kent and its tributaries – and opportunities to create new habitats.
As outlined above I believe that there is potential for damage to the SAC and the White Clawed Crayfish habitat in particular.
Policy CS8.1 Green Infrastructure states that the Core Strategy will seek to:
• Protect the countryside from inappropriate development whilst supporting its positive use for agriculture, recreation, biodiversity, health, education and tourism;
For all the reasons stated above I believe that development of these sites can only be construed as inappropriate and will have a negative effect on all these elements.
Conclusion
I do not believe that development of these sites stands up to scrutiny in the context of the Local Development Framework and would urge you to rule them out for the reasons stated above and which I can summarise as:
• The location of the sites at the interface between town and open countryside, their elevated nature and the extensive zone of theoretical visibility means that there would be significant harm to the character and quality of the landscape and the setting of Kendal were these sites to be developed.
• The northwest boundary of Kendal, particularly to the south of the railway line, is well defined. On the approach to the town from the northwest it is framed by the interesting, attractive and distinctive landscape described above. These sites extend this settlement edge into high quality landscape. This is not sustainable development.
• Development would erode the separation between Burneside and Kendal, adversely affect the existing settlement pattern and would damage the historic setting of Lane Foot Farm.
• Development would be contrary to a number of policies in the Core Strategy of the LDF.
• Development would be contrary to advice contained in the Sustainability Appraisal Scoping Report.
• Development would be contrary to Policy E36 of the Cumbria and Lake District Joint Structure Plan.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
I wish to participate in the oral examination as I believe for the proposals to develop this land to have got this far in the process the importance of this land in landscape terms is not being taken seriously enough. Its significance to to the valley, the setting of Kendal and the setting of the Lake District National Park should not be underestimated. This is high quality landscape and unsustainable development and this needs to be made clear at examination.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
320. Mr and Mrs Chris and Deb Greenwood (Individual) : 18 May 2012 14:30:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - RN169M+ RN299# KENDAL WEST OF HIGH SPARROWMIRE
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I submit that development of sites RN169M and RN299# would be unsustainable by being harmful to landscape character and quality and therefore contrary to the central principle of the Local Development Framework and Core Strategy and a number of policies contained therein.
Landscape Setting
The sites lie within an area of rolling farmland at the boundary between the carboniferous limestone of the Morecambe Bay Limestones Joint Character Area and the Coniston group of slates of the Cumbria Low Fells JCA of the Character Map of England. The area is a good representative sample of both leaning perhaps more towards limestone scenery immediately surrounding the site.
At the more local scale the site is classified as being within Landscape Character Type 7 – Drumlins, Sub-type 7b - Drumlin Field. This is not a common landscape type either locally, regionally or even nationally but is well represented in this locality. The combination of drumlin landforms overlain by a geometric net of fields gives this landscape a strong identity and a sense of both our natural and cultural history. This is high quality landscape in a highly visible and accessible location providing a unique setting to the town which nestles in the Kent valley. At the northwest boundary to the town development finishes abruptly with a well defined edge. This gives way to the rolling topography of the drumlin filled valley with the field pattern of pale coloured limestone walls picked out against the bright green improved pasture. Outwith the town boundary there is a dispersed settlement pattern with small, tight groupings of farm (or converted farm) buildings before the next significant settlement of Burneside further along the valley. This makes for an attractive landscape.
The closest building to the existing development boundary is Lane Foot Farm now a residential development of barn conversions converted in the mid 1990s. The farm is of some historic interest (the National Trust has a restrictive covenant on the farm buildings and this may also apply to the farmland) and is classed as a ‘single ancient farm’ in the Cumbria Historic Landscape Classification. The pattern of enclosure predates the enclosure acts and is of some historic interest also.
The elevated nature of sites ensures a wide zone of theoretical visibility and development would affect the view to the town from a wide area. Development would also seriously affect distant views north and west across the sites to the Whinfell Ridge, Shap, Longsleddale and Kentmere fells from Windermere Road. The bellmouth where the access road to Lane Foot Farm leaves the A5284 Windermere Road provides a viewpoint for many photographers.
The site is prominent from a number of housing areas, public roads and public rights of way. The footpath between Hallgarth and Hollins Lane/Burneside runs through the valley and closely adjacent to the site and it is prominent in the view from public rights of way on Kendal Fell. People using these paths are sensitive receptors out walking in the countryside specifically to enjoy the landscape.
The area including the site is the gateway to the Lakes when heading north/west and the setting for Kendal when heading south/east.
Policy context
The Land Allocations DPD outlines key local factors influencing the location of development (para 3.5). These include:
• Respecting the setting of the existing and potential future extent of the Lake District National Park which is close to the town;
Site E65 is within 50m of the National Park boundary juxtaposed with Kendal Fell and an important part of the setting from a wide range of viewpoints and an important approach to (and exit from) 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;
Windermere Road is obviously a key approach to the town through the attractive landscape of Kendal Fell rising out of the patchwork of improved pasture overlying the distinctive rolling drumlin field portraying Kentdales glacial past. The quality of the landscape setting to this approach to the town can be judged by the number of visitors photographing the landscape from the viewpoint at the bellmouth to the access lane to Lane Foot Farm.
• Avoiding coalescence between Kendal, Oxenholme, Burneside and Natland and maintaining the separate identities of these settlements;
Whilst a considerable physical separation would be retained between the two settlements the elevation and perspective of the sites would result in a disproportionate visual and perceptive closing of the gap between them.
• Safeguarding and enhancing the River Kent Special Area of Conservation an internationally important habitat, particularly for the seriously threatened White Clawed Crayfish;
Sites E65, RN 169, R674K and R46 are within 170-250m from an open water course containing White Clawed Crayfish and closer still to underground water courses which feed it, all within the River Kent SAC.
In the Core Strategy:
Policy CS1.1 - Sustainable Development Principles, states that:
2. It is vital to protect the countryside for its intrinsic beauty, diversity and natural resources and also for its ecological, geological, cultural and historical, economic, agricultura,l recreational and social value;
If each of these assets is evaluated in turn it becomes obvious that development of these sites would degrade the value of every single one.
Intrinsic beauty – interesting landform, sense of history, open views etc etc
Diversity – a major contributor to the variety of landscape in the area
Natural resources – Delivers eco-system services (water, food, sense of place etc)
Ecological, - river Kent SAC
Geological – good example of drumlin field
Cultural – field pattern, single ancient farm
Historical – as above
Economic – food production and contributor to areas main economic driver (landscape tourism)
Agricultural – good quality farmland (sheep & cattle grazing)
Recreational – visual amenity and rights of way
Social value – all of the above.
3. There is a need to take account of and enhance landscape character and features particularly the AONB and coastal areas. The whole area’s role as a setting for and gateway to the Lake District and Yorkshire Dales National Parks should be developed.
This part of Kendal is closest to the Lake District National Park and an important part of its setting, just as the National Park is an important part of the setting for Kendal. Development of these sites threatens to degrade the setting of both.
Policy CS2 – Kendal Strategy, states that:
• Ensure that Greenfield development is sympathetic to the landscape character of Kendal and to the historic character and setting of Kendal and may also need to address archaeological impacts.
As outlined above I believe that the landscape character, historic character and setting of Kendal will all be harmed by development of these sites.
• Ensure that new development safeguards and enhances the natural environment and local biodiversity – notably SSSIs and SACs within the area, including the River Kent and its tributaries – and opportunities to create new habitats.
As outlined above I believe that there is potential for damage to the SAC and the White Clawed Crayfish habitat in particular.
Policy CS8.1 Green Infrastructure states that the Core Strategy will seek to:
• Protect the countryside from inappropriate development whilst supporting its positive use for agriculture, recreation, biodiversity, health, education and tourism;
For all the reasons stated above I believe that development of these sites can only be construed as inappropriate and will have a negative effect on all these elements.
Conclusion
I do not believe that development of these sites stands up to scrutiny in the context of the Local Development Framework and would urge you to rule them out for the reasons stated above and which I can summarise as:
• The location of the sites at the interface between town and open countryside, their elevated nature and the extensive zone of theoretical visibility means that there would be significant harm to the character and quality of the landscape and the setting of Kendal were these sites to be developed.
• The northwest boundary of Kendal, particularly to the south of the railway line, is well defined. On the approach to the town from the northwest it is framed by the interesting, attractive and distinctive landscape described above. These sites extend this settlement edge into high quality landscape. This is not sustainable development.
• Development would erode the separation between Burneside and Kendal, adversely affect the existing settlement pattern and would damage the historic setting of Lane Foot Farm.
• Development would be contrary to a number of policies in the Core Strategy of the LDF.
• Development would be contrary to advice contained in the Sustainability Appraisal Scoping Report.
• Development would be contrary to Policy E36 of the Cumbria and Lake District Joint Structure Plan.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
I wish to participate in the oral examination as I believe for the proposals to develop this land to have got this far in the process the importance of this land in landscape terms is not being taken seriously enough. Its significance to to the valley, the setting of Kendal and the setting of the Lake District National Park should not be underestimated. This is high quality landscape and unsustainable development and this needs to be made clear at examination.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
321. Mr David Hague (Individual) : 26 Apr 2012 14:58:00
Policy/Site No.
LA1.3 Housing Allocations - M41KM KENDAL SOUTH OF LUMLEY ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I wish to object to and challenge the soundness of proposal 2C – Land to south of Lumley Rd. and Scroggs Wood Light industrial Site on the following grounds:
- Inadequate local infrastructure including schools, health care, sewerage and roads.
- Milnthorpe road already backs up to the bypass at peak times and cannot accommodate the massive increase that such development, in these locations, would create. Kendal town development to attract visitors is pointless if they cannot obtain satisfactory access. The associated pollution from stationary traffic is incompatible with sustainable development objectives. The soundness of the development is challenged on the basis that there is no traffic plan to address these issues.
- The A6 is a crucial access for emergency services, particularly following the downgrading of Westmorland General Hospital. Further congestion on this route would introduce undue risk. The Soundness of the plan is therefore challenged on safety grounds. To South Lakeland District Council, Development Strategy Team, South Lakeland House, Lowther Street, Kendal, LA9 4UD
- The proposed 2C developments would spoil the initial impression to Kendal visitors, being on the main access route and adjacent to the Town boundary. The Lumley road site is steeply graded and properties would impose on the existing views for existing residents and visitors. The line of trees acts as a natural barrier to the Bellingham Estate. Building to the South of this line would fundamentally change the Kendal “Gateway to the Lakes” character. The Soundness of the plan is therefore challenged on visual impact grounds.
- Loss of green field space is detrimental to the character of the area and contrary to Coalition Government Sustainable Development Policy, which recognizes brown field preference. The Soundness of the plan is therefore challenged as being contrary to Government Planning Policy.
- The proposed mixed use development is incompatible with the character of the historic Helsington development and other existing properties. The Soundness of the plan is therefore challenged as being detrimental to the historical character of the area.
- The site is clearly NOT “in an accessible location or an easily developable level site” (Achievability statement P133 2 C). The Soundness of the plan is therefore challenged as being contrary to this declared planning statement.
- There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of existing residential space and more suitable alternative development sites.
- The Development plan should retain the "Kendal Gateway to the Lakes" image supporting tourism and established Cumbrian employment, not destroy it with unsightly, unnecessary development and traffic jams. You don’t put your wheelie bin on your front door step. I have an alternative suggestion for this site – why not continue its use as sheep farming land?
322. Mr David Hague (Individual) : 26 Apr 2012 15:02:00
Policy/Site No.
LA1.6 Strategic Employment Sites - E4M KENDAL LAND AT SCROGGS WOOD, MILNTHORPE ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I wish to object to and challenge the soundness of proposal 2C – Land to south of Lumley Rd. and Scroggs Wood Light industrial Site on the following grounds:
- Inadequate local infrastructure including schools, health care, sewerage and roads.
- Milnthorpe road already backs up to the bypass at peak times and cannot accommodate the massive increase that such development, in these locations, would create. Kendal town development to attract visitors is pointless if they cannot obtain satisfactory access. The associated pollution from stationary traffic is incompatible with sustainable development objectives. The soundness of the development is challenged on the basis that there is no traffic plan to address these issues.
- The A6 is a crucial access for emergency services, particularly following the downgrading of Westmorland General Hospital. Further congestion on this route would introduce undue risk. The Soundness of the plan is therefore challenged on safety grounds. To South Lakeland District Council, Development Strategy Team, South Lakeland House, Lowther Street, Kendal, LA9 4UD
- The proposed 2C developments would spoil the initial impression to Kendal visitors, being on the main access route and adjacent to the Town boundary. The Lumley road site is steeply graded and properties would impose on the existing views for existing residents and visitors. The line of trees acts as a natural barrier to the Bellingham Estate. Building to the South of this line would fundamentally change the Kendal “Gateway to the Lakes” character. The Soundness of the plan is therefore challenged on visual impact grounds.
- Loss of green field space is detrimental to the character of the area and contrary to Coalition Government Sustainable Development Policy, which recognizes brown field preference. The Soundness of the plan is therefore challenged as being contrary to Government Planning Policy.
- The proposed mixed use development is incompatible with the character of the historic Helsington development and other existing properties. The Soundness of the plan is therefore challenged as being detrimental to the historical character of the area.
- The site is clearly NOT “in an accessible location or an easily developable level site” (Achievability statement P133 2 C). The Soundness of the plan is therefore challenged as being contrary to this declared planning statement.
- There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of existing residential space and more suitable alternative development sites.
- There is spare capacity and expansion potential on existing established trading estates on Shap Road. The plan to relocate the Rugby club to Oxenholme and development of the Gilkes site are more suited to development than Scroggs Wood. The soundness of the case for such development is challenged on the basis of existing and more suitable alternative development sites.
- What and where is the business case and demand for a further speculative light industrial business park? Why would UK businesses move to such a park when financial assistance and tax breaks are available for designated City areas such as the Manchester Enterprise Zone? The soundness of this planned development is challenged on the basis of no demand or business case.
- The Development plan should retain the "Kendal Gateway to the Lakes" image supporting tourism and established Cumbrian employment, not destroy it with unsightly, unnecessary development and traffic jams. You don’t put your wheelie bin on your front door step. I have an alternative suggestion for this site – why not continue its use as sheep farming land?
323. Mr David Hague (Individual) : 26 Apr 2012 15:04:00
Policy/Site No.
LA1.3 Housing Allocations - All Kendal sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of existing residential space and more suitable alternative development sites.
324. Mr David Hague (Individual) : 26 Apr 2012 15:05:00
Paragraph No.
0.0 Whole Document
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Is there a definition of “affordable housing” in the context of Kendal young person income? Or is this merely a rouse to allow land owners and builders to make massive profits, without any tangible commitment to house the low paid of Kendal? The Soundness is therefore challenged on the basis of no defined affordability test.
325. Mr David Hague (Individual) : 26 Apr 2012 15:07:00
Policy/Site No.
LA1.4 - Kendal Sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of existing residential space and more suitable alternative development sites.
326. Mr Joe Hague (Individual) : 27 Apr 2012 08:52:00
Policy/Site No.
LA1.3 Housing Allocations - M41KM KENDAL SOUTH OF LUMLEY ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Loss of green field space is detrimental to the character and heritage of the area. This is contrary to Coalition Government Sustainable Development Policy, which recognizes brown field preference above important countryside areas. The Soundness and legality of the plan is therefore challenged as being contrary to Government Planning Policy.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I wish to object to and challenge the soundness of proposed land allocation for development – to south of Lumley Rd. (M41KM) and Scroggs Wood Light Industrial Site (E4M) on the following grounds:
- The proposed developments would spoil the initial impression to Kendal visitors, being on the main access route and adjacent to the Town boundary. The Lumley road site is steeply graded and properties would impose on the existing view for Kendal visitors. The line of trees acts as a natural barrier between countryside and properties. Building to the South of this line (E4M), would fundamentally change the Kendal “Gateway to the Lakes” character as a valued landscape. This is contrary to the adopted planning Core Strategy. The Soundness of the plan is therefore challenged on visual impact grounds, contrary to planning policy.
- Loss of green field space is detrimental to the character and heritage of the area. This is contrary to Coalition Government Sustainable Development Policy, which recognizes brown field preference above important countryside areas. The Soundness and legality of the plan is therefore challenged as being contrary to Government Planning Policy.
- Milnthorpe road already backs up to the bypass at peak times and cannot accommodate the massive increase that such development, in these locations, would create. Kendal town development to attract visitors is pointless if they cannot obtain satisfactory access. The associated pollution from stationary traffic is incompatible with sustainable development objectives. The soundness of the development is challenged on the basis that there is no traffic plan to address these issues.
- The A6 is a crucial access for emergency services, particularly following the downgrading of Westmorland General Hospital. Further congestion on this route would introduce undue risk. The potential for accidents when joining the main road would also be significantly increased. The Soundness of the plan is therefore challenged on safety grounds.
- The soundness of the development is challenged on the basis that there is inadequate local infrastructure including drainage, sewerage and roads.
- The proposed development is incompatible with the character of the historic Helsington development contrary to planning policy. The Soundness of the plan is therefore challenged as being detrimental to the historical character of the area.
- The site is clearly NOT “in an accessible location or an easily developable level site” (Achievability statement P133 2 C). The Soundness of the plan is therefore challenged as being contrary to this declared planning statement.
- There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of adequate existing residential space and more suitable alternative development sites.
- What and where is the business case and demand for a further speculative light industrial business park? Why would UK businesses move to such a park when financial assistance and tax breaks are available for designated City areas such as the Manchester Enterprise Zone? The soundness of this planned development is challenged on the basis of no established demand or business case.
- The Development plan should retain the "Kendal Gateway to the Lakes" image supporting tourism and established Cumbrian employment, not destroy it with unsightly, unnecessary development and traffic jams. You don’t put your wheelie bin on your front door step! The DPD appears to have completely disregarded the massive opposition and valid objections previously made. The soundness of this planned development is challenged as disregarding local opinion contrary to Government Policy.
327. Mr Joe Hague (Individual) : 27 Apr 2012 08:57:00
Policy/Site No.
LA1.6 Strategic Employment Sites - E4M KENDAL LAND AT SCROGGS WOOD, MILNTHORPE ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I wish to object to and challenge the soundness of proposed land allocation for development – to south of Lumley Rd. (M41KM) and Scroggs Wood Light Industrial Site (E4M) on the following grounds:
-The proposed developments would spoil the initial impression to Kendal visitors, being on the main access route and adjacent to the Town boundary. The Lumley road site is steeply graded and properties would impose on the existing view for Kendal visitors. The line of trees acts as a natural barrier between countryside and properties. Building to the South of this line (E4M), would fundamentally change the Kendal “Gateway to the Lakes” character as a valued landscape. This is contrary to the adopted planning Core Strategy. The Soundness of the plan is therefore challenged on visual impact grounds, contrary to planning policy.
- Loss of green field space is detrimental to the character and heritage of the area. This is contrary to Coalition Government Sustainable Development Policy, which recognizes brown field preference above important countryside areas. The Soundness and legality of the plan is therefore challenged as being contrary to Government Planning Policy.
- Milnthorpe road already backs up to the bypass at peak times and cannot accommodate the massive increase that such development, in these locations, would create. Kendal town development to attract visitors is pointless if they cannot obtain satisfactory access. The associated pollution from stationary traffic is incompatible with sustainable development objectives. The soundness of the development is challenged on the basis that there is no traffic plan to address these issues.
- The A6 is a crucial access for emergency services, particularly following the downgrading of Westmorland General Hospital. Further congestion on this route would introduce undue risk. The potential for accidents when joining the main road would also be significantly increased. The Soundness of the plan is therefore challenged on safety grounds.
- The soundness of the development is challenged on the basis that there is inadequate local infrastructure including drainage, sewerage and roads.
- The proposed development is incompatible with the character of the historic Helsington development contrary to planning policy. The Soundness of the plan is therefore challenged as being detrimental to the historical character of the area.
- The site is clearly NOT “in an accessible location or an easily developable level site” (Achievability statement P133 2 C). The Soundness of the plan is therefore challenged as being contrary to this declared planning statement.
- There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of adequate existing residential space and more suitable alternative development sites.
- There is spare capacity and expansion potential on existing established trading estates on Shap Road. The plan to relocate the Rugby club to Oxenholme and development of the Gilkes site are more suited to development than Scroggs Wood. The soundness of the case for such development is challenged on the basis of existing and more suitable alternative development sites compatible with planning policy.
- What and where is the business case and demand for a further speculative light industrial business park? Why would UK businesses move to such a park when financial assistance and tax breaks are available for designated City areas such as the Manchester Enterprise Zone? The soundness of this planned development is challenged on the basis of no established demand or business case.
- The Development plan should retain the "Kendal Gateway to the Lakes" image supporting tourism and established Cumbrian employment, not destroy it with unsightly, unnecessary development and traffic jams. You don’t put your wheelie bin on your front door step! The DPD appears to have completely disregarded the massive opposition and valid objections previously made. The soundness of this planned development is challenged as disregarding local opinion contrary to Government Policy.
328. Mr Joe Hague (Individual) : 27 Apr 2012 08:58:00
Policy/Site No.
LA1.3 Housing Allocations - All Kendal sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of adequate existing residential space and more suitable alternative development sites.
329. Mr Joe Hague (Individual) : 27 Apr 2012 09:00:00
Paragraph No.
0.0 Whole Document
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Is there a definition of “affordable housing” in the context of Kendal young person income? Or is this merely a rouse to allow land owners and builders to make massive profits, without any tangible commitment to house the low paid of Kendal? The Soundness is therefore challenged on the basis of no defined affordability test.
330. Mr Joe Hague (Individual) : 27 Apr 2012 09:01:00
Policy/Site No.
LA1.4 - Kendal Sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of adequate existing residential space and more suitable alternative development sites.
331. Mrs Tracey Hague (Individual) : 27 Apr 2012 10:57:00
Policy/Site No.
LA1.3 Housing Allocations - M41KM KENDAL SOUTH OF LUMLEY ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Loss of green field space is detrimental to the character and heritage of the area. This is contrary to Coalition Government Sustainable Development Policy, which recognizes brown field preference above important countryside areas. The Soundness and legality of the plan is therefore challenged as being contrary to Government Planning Policy.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I wish to object to and challenge the soundness of proposed land allocation for development – to south of Lumley Rd. (M41KM) and Scroggs Wood Light Industrial Site (E4M) on the following grounds:
The proposed developments would spoil the initial impression to Kendal visitors, being on the main access route and adjacent to the Town boundary. The Lumley road site is steeply graded and properties would impose on the existing view for Kendal visitors. The line of trees acts as a natural barrier between countryside and properties. Building to the South of this line (E4M), would fundamentally change the Kendal “Gateway to the Lakes” character as a valued landscape. This is contrary to the adopted planning Core Strategy. The Soundness of the plan is therefore challenged on visual impact grounds, contrary to planning policy.
Loss of green field space is detrimental to the character and heritage of the area. This is contrary to Coalition Government Sustainable Development Policy, which recognizes brown field preference above important countryside areas. The Soundness and legality of the plan is therefore challenged as being contrary to Government Planning Policy.
Milnthorpe road already backs up to the bypass at peak times and cannot accommodate the massive increase that such development, in these locations, would create. Kendal town development to attract visitors is pointless if they cannot obtain satisfactory access. The associated pollution from stationary traffic is incompatible with sustainable development objectives. The soundness of the development is challenged on the basis that there is no traffic plan to address these issues.
The A6 is a crucial access for emergency services, particularly following the downgrading of Westmorland General Hospital. Further congestion on this route would introduce undue risk. The potential for accidents when joining the main road would also be significantly increased. The Soundness of the plan is therefore challenged on safety grounds.
The soundness of the development is challenged on the basis that there is inadequate local infrastructure including drainage, sewerage and roads.
The proposed development is incompatible with the character of the historic Helsington development contrary to planning policy. The Soundness of the plan is therefore challenged as being detrimental to the historical character of the area.
- The site is clearly NOT “in an accessible location or an easily developable level site” (Achievability statement P133 2 C). The Soundness of the plan is therefore challenged as being contrary to this declared planning statement.
- There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of adequate existing residential space and more suitable alternative development sites.
- The Development plan should retain the "Kendal Gateway to the Lakes" image supporting tourism and established Cumbrian employment, not destroy it with unsightly, unnecessary development and traffic jams. You don’t put your wheelie bin on your front door step! The DPD appears to have completely disregarded the massive opposition and valid objections previously made. The soundness of this planned development is challenged as disregarding local opinion contrary to Government Policy.
332. Mrs Tracey Hague (Individual) : 27 Apr 2012 10:59:00
Policy/Site No.
LA1.6 Strategic Employment Sites - E4M KENDAL LAND AT SCROGGS WOOD, MILNTHORPE ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I wish to object to and challenge the soundness of proposed land allocation for development – to south of Lumley Rd. (M41KM) and Scroggs Wood Light Industrial Site (E4M) on the following grounds:
- The proposed developments would spoil the initial impression to Kendal visitors, being on the main access route and adjacent to the Town boundary. The Lumley road site is steeply graded and properties would impose on the existing view for Kendal visitors. The line of trees acts as a natural barrier between countryside and properties. Building to the South of this line (E4M), would fundamentally change the Kendal “Gateway to the Lakes” character as a valued landscape. This is contrary to the adopted planning Core Strategy. The Soundness of the plan is therefore challenged on visual impact grounds, contrary to planning policy.
- Loss of green field space is detrimental to the character and heritage of the area. This is contrary to Coalition Government Sustainable Development Policy, which recognizes brown field preference above important countryside areas. The Soundness and legality of the plan is therefore challenged as being contrary to Government Planning Policy.
- Milnthorpe road already backs up to the bypass at peak times and cannot accommodate the massive increase that such development, in these locations, would create. Kendal town development to attract visitors is pointless if they cannot obtain satisfactory access. The associated pollution from stationary traffic is incompatible with sustainable development objectives. The soundness of the development is challenged on the basis that there is no traffic plan to address these issues.
- The A6 is a crucial access for emergency services, particularly following the downgrading of Westmorland General Hospital. Further congestion on this route would introduce undue risk. The potential for accidents when joining the main road would also be significantly increased. The Soundness of the plan is therefore challenged on safety grounds.
- The soundness of the development is challenged on the basis that there is inadequate local infrastructure including drainage, sewerage and roads.
- The proposed development is incompatible with the character of the historic Helsington development contrary to planning policy. The Soundness of the plan is therefore challenged as being detrimental to the historical character of the area.
- The site is clearly NOT “in an accessible location or an easily developable level site” (Achievability statement P133 2 C). The Soundness of the plan is therefore challenged as being contrary to this declared planning statement.
- There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of adequate existing residential space and more suitable alternative development sites.
- There is spare capacity and expansion potential on existing established trading estates on Shap Road. The plan to relocate the Rugby club to Oxenholme and development of the Gilkes site are more suited to development than Scroggs Wood. The soundness of the case for such development is challenged on the basis of existing and more suitable alternative development sites compatible with planning policy.
- What and where is the business case and demand for a further speculative light industrial business park? Why would UK businesses move to such a park when financial assistance and tax breaks are available for designated City areas such as the Manchester Enterprise Zone? The soundness of this planned development is challenged on the basis of no established demand or business case.
- The Development plan should retain the "Kendal Gateway to the Lakes" image supporting tourism and established Cumbrian employment, not destroy it with unsightly, unnecessary development and traffic jams. You don’t put your wheelie bin on your front door step! The DPD appears to have completely disregarded the massive opposition and valid objections previously made. The soundness of this planned development is challenged as disregarding local opinion contrary to Government Policy.
333. Mrs Tracey Hague (Individual) : 27 Apr 2012 11:00:00
Policy/Site No.
LA1.3 Housing Allocations - All Kendal sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of adequate existing residential space and more suitable alternative development sites.
334. Mrs Tracey Hague (Individual) : 27 Apr 2012 11:03:00
Paragraph No.
0.0 Whole Document
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Is there a definition of “affordable housing” in the context of Kendal young person income? Or is this merely a rouse to allow land owners and builders to make massive profits, without any tangible commitment to house the low paid of Kendal? The Soundness is therefore challenged on the basis of no defined affordability test.
335. Mrs Tracey Hague (Individual) : 27 Apr 2012 11:04:00
Policy/Site No.
LA1.4 - Kendal Sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of adequate existing residential space and more suitable alternative development sites.
336. Miss Shelby Halliday (Individual) : 17 Apr 2012 16:33:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
0.0 Whole Document
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
Yes
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
I support the South Lakeland District Council Land Allocations DPD because I see the desperate demand for housing in this area. I have lived here all my life and know of many young and middle aged people who are desperately seeking for housing. By allowing this Land Allocation I am hoping that it will put less pressure on the housing that is already here and allow more people to stay in the area that they have grown up in and love so dearly.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
337. Mr and Mrs R.H. Hampson (Individual) : 8 May 2012 11:27:00
Policy/Site No.
LA1.3 Housing Allocations - RN213-mod BRIGSTEER LAND OPPOSITE THE WHEATSHEAF
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
These are the views of both my husband and myself.
Certain members of the Helsington Parish Council (HPC) are also directors of the recently formed Helsington Community Land Trust (HCLT) and they have unfairly obstructed or distorted the views of the HPC from being made known properly to the SLDC Planning Authority.
HCLT claim to have being formed by the community and for the benefit of the community, but in fact all the directors appear to be self appointed and not responsible to the electorate at all. I believe the HCLT in its present form to be an undemocratic body.
SLDC appear to have been unduly influenced and encouraged by HCLT to declare Site RN213 at Brigsteer to be a special case for low cost housing development, this being an exception to the general policy being applied to all other small villages and hamlets in the South Lakes area.
Should development of this site RN213 be allowed to proceed, it would be in direct opposition to the majority view of the electorate which has been repeatedly expressed in recent polls held on this subject and I would therefore request that this site be removed from the list of esites to be developed and that Brigsteer be treated in the same manner as all other small villages and hamlets in South Lakeland.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
338. Mrs Fiona Hanlon (Individual) : 14 Apr 2012 13:05:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA2.3 Land East of Castle Green Road
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The Land Allocations Document (DPD) is not within the Local Development Scheme and the key stages have not been followed
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not been prepared in accordance with the Town & County Planning Regulations 2004 (as amended)
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
1. The process of Community Involvement is flawed. The significant number of sound and evidence based objections to development on this particular site R121M including the significant evidence based objections of Kendal Town Council, Friends of The Earth, Solek, CPRE, local site knowledge and findings of previous planning inspectors and reports have been disregarded. This is not legally compliant.
2.SLDC have NOT carried out evidence based studies, measurements or technical surveys to support their allocation yet they ignore those that have already been carried out by experts. Only representations selected by SLDC will be placed before the inspector - they can choose again to omit any or all of the evidence based objections. This is flawed and therefore makes the decision process unsound and not legally compliant.
2. The Core Strategy, which was adopted in October 2010, states that sites are excluded from allocation if their development would be a clear breach of its policies, or would harm a protected site or species. R121M is such a site. Developing this site would be a breach of the Core Strategy and is therefore unsound and not legally compliant.
3. This site has been hitherto protected because of its unique rural landscape which gives Kendal its character. Development legally is supposed to take account of locally distinctive natural or built features, visual intrusion or impact, scale in relation to the landscape and features, the character of the built environment, public access and community value of the landscape, historic patterns and attributes, biodiversity features, ecological networks and semi-natural habitats, and openness, remoteness and tranquillity. This site has rightly been protected until now because all of the above apply to R121M. In the recent Kendal Town Council evidence based report this particular site came out as the least appropriate to develop because of its high sensitivity with regard to all of the above and the significant harm that would be caused to the landscape setting of Kendal with insufficient benefit to the housing need the development is supposed to address. The allocation of this site would conflict with the provisions of the Core Strategy, and is therefore not legally compliant.
4. R121M contains one of only two breeding and habitation sites in the area for Great Crested Newts which are protected by the UK. An access road through this territory to housing is proposterous and will significantly damage the colony which needs 500m emergence zone. The study completed by Netwok rail commented on the quality of this particular colony which also contains significant numbers of palmate newts along with a thriving Great Crested Newt population. The area of Newt habitation and emergence zone has been misrepresented on the maps presented by SLDC and they have failed to complete accurate surveys of the colony prior to submitting the site in order to mislead the inspector. The core strategy states that building on sites that are considered to have geological and biodiversity value, will not be permitted unless the benefits of the development clearly outweigh the impacts on the features of the site and the wider network of natural habitats. This is a clear breach of the Core Strategy. Development here is not legally compliant.
5. Building here will also fall foul of the Town and County Planning regulations. Flooding and drainage issues on this site and the surrounding roads and dwellings are well documented. The flooding in this area has increased to such an extent in recent years that the wetlands misrepresented by SLDC in R121M and the surrounding previously proposed sites have extended enough to supoort new iris and marsh and newt habitation. Any building on this land along with any proposal to solve the flooding problem, especially construction of a road and associated drainage will destroy the flora fauna and wildlife which thrives in this flooded land. Solving flooding issues would breach the core strategy relating to the wetland habitat. This pays no regard to the national policy and core strategy and is therefore not legally compliant.
6. I would also argue that the key stages have not been followed if the inspector is only shown submissions selected by SLDC. This is akin to the defence relying on the prosecution to state their case. The inspector and his team should have access to ALL SUBMISSIONS and OBJECTIONS so that they are fully informed. By SLDC selecting the material to be put before the inspector I submit that the process is flawed and therefore unsound and not legally compliant.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The significant number of sound and evidence based objections to development on this particular site R121M including the significant evidence based objections of Kendal Town Council, Friends of The Earth, Solek, CPRE, local site knowledge and findings of previous planning inspectors and reports have been disregarded. SLDC have NOT carried out evidence based studies, measurements or technical surveys to support their allocation yet they ignore those that have already been carried out by experts. The site will involve difficulties with addressing landscape protection, biodiversity, flooding and access making the cost prohibitive. None of the costs involved have been investigated by SLDC before proposing this site.The amount of proposed housing has been reduced because SLDC is beginning to accept there are significant issues but SLDC should accept that ANY building and access to that building on this particular site will not meet the demands of the core strategy or affordable housing and will irretrievably destroy hitherto protected landscape and biodiversity.
I would also argue that the key stages have not been followed if the inspector is only shown submissions selected by SLDC. This is akin to the defence relying on the prosecution to state their case. I propose that to improve this process the inspector and his team should have access to ALL SUBMISSIONS and OBJECTIONS so that they are fully informed. By SLDC selecting the material to be put before the inspector I submit that the process is flawed and therefore unsound and not legally compliant.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
Local groups I hope will be represented but it is important, if SLDC is to fulfil their obligation of true public consultation, that the inspector hears objections and submissions directly in person from local individuals/residents with sound objections. The process will not be seen to be fair or just if SLDC are not publicly opposed before the inspector by local individuals, with valid evidence based objections, who will have to watch and live with the resulting desecration of protected sites.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
339. Mrs Fiona Hanlon (Individual) : 18 May 2012 14:39:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
1.9
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The Land Allocations Document (DPD) is not within the Local Development Scheme and the key stages have not been followed
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not been prepared in accordance with the Town & County Planning Regulations 2004 (as amended)
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
1. The process of Community Involvement is flawed. The significant number of sound and evidence based objections to development on this particular site R121M including the significant evidence based objections of Kendal Town Council, Friends of The Earth, Solek, CPRE, local site knowledge and findings of previous planning inspectors and reports have been disregarded. This is not legally compliant.
2.SLDC have NOT carried out evidence based studies, measurements or technical surveys to support their allocation yet they ignore those that have already been carried out by experts. Only representations selected by SLDC will be placed before the inspector - they can choose again to omit any or all of the evidence based objections. This is flawed and therefore makes the decision process unsound and not legally compliant.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
Local groups I hope will be represented but it is important, if SLDC is to fulfil their obligation of true public consultation, that the inspector hears objections and submissions directly in person from local individuals/residents with sound objections. The process will not be seen to be fair or just if SLDC are not publicly opposed before the inspector by local individuals, with valid evidence based objections, who will have to watch and live with the resulting desecration of protected sites.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
340. Mrs Fiona Hanlon (Individual) : 18 May 2012 14:42:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - R121M-mod KENDAL EAST OF CASTLE GREEN ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The Land Allocations Document (DPD) is not within the Local Development Scheme and the key stages have not been followed
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not been prepared in accordance with the Town & County Planning Regulations 2004 (as amended)
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
2. The Core Strategy, which was adopted in October 2010, states that sites are excluded from allocation if their development would be a clear breach of its policies, or would harm a protected site or species. R121M is such a site. Developing this site would be a breach of the Core Strategy and is therefore unsound and not legally compliant.
3. This site has been hitherto protected because of its unique rural landscape which gives Kendal its character. Development legally is supposed to take account of locally distinctive natural or built features, visual intrusion or impact, scale in relation to the landscape and features, the character of the built environment, public access and community value of the landscape, historic patterns and attributes, biodiversity features, ecological networks and semi-natural habitats, and openness, remoteness and tranquillity. This site has rightly been protected until now because all of the above apply to R121M. In the recent Kendal Town Council evidence based report this particular site came out as the least appropriate to develop because of its high sensitivity with regard to all of the above and the significant harm that would be caused to the landscape setting of Kendal with insufficient benefit to the housing need the development is supposed to address. The allocation of this site would conflict with the provisions of the Core Strategy, and is therefore not legally compliant.
4. R121M contains one of only two breeding and habitation sites in the area for Great Crested Newts which are protected by the UK. An access road through this territory to housing is proposterous and will significantly damage the colony which needs 500m emergence zone. The study completed by Netwok rail commented on the quality of this particular colony which also contains significant numbers of palmate newts along with a thriving Great Crested Newt population. The area of Newt habitation and emergence zone has been misrepresented on the maps presented by SLDC and they have failed to complete accurate surveys of the colony prior to submitting the site in order to mislead the inspector. The core strategy states that building on sites that are considered to have geological and biodiversity value, will not be permitted unless the benefits of the development clearly outweigh the impacts on the features of the site and the wider network of natural habitats. This is a clear breach of the Core Strategy. Development here is not legally compliant.
5. Building here will also fall foul of the Town and County Planning regulations. Flooding and drainage issues on this site and the surrounding roads and dwellings are well documented. The flooding in this area has increased to such an extent in recent years that the wetlands misrepresented by SLDC in R121M and the surrounding previously proposed sites have extended enough to supoort new iris and marsh and newt habitation. Any building on this land along with any proposal to solve the flooding problem, especially construction of a road and associated drainage will destroy the flora fauna and wildlife which thrives in this flooded land. Solving flooding issues would breach the core strategy relating to the wetland habitat. This pays no regard to the national policy and core strategy and is therefore not legally compliant.
6. I would also argue that the key stages have not been followed if the inspector is only shown submissions selected by SLDC. This is akin to the defence relying on the prosecution to state their case. The inspector and his team should have access to ALL SUBMISSIONS and OBJECTIONS so that they are fully informed. By SLDC selecting the material to be put before the inspector I submit that the process is flawed and therefore unsound and not legally compliant.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The significant number of sound and evidence based objections to development on this particular site R121M including the significant evidence based objections of Kendal Town Council, Friends of The Earth, Solek, CPRE, local site knowledge and findings of previous planning inspectors and reports have been disregarded. SLDC have NOT carried out evidence based studies, measurements or technical surveys to support their allocation yet they ignore those that have already been carried out by experts. The site will involve difficulties with addressing landscape protection, biodiversity, flooding and access making the cost prohibitive. None of the costs involved have been investigated by SLDC before proposing this site.The amount of proposed housing has been reduced because SLDC is beginning to accept there are significant issues but SLDC should accept that ANY building and access to that building on this particular site will not meet the demands of the core strategy or affordable housing and will irretrievably destroy hitherto protected landscape and biodiversity.
I would also argue that the key stages have not been followed if the inspector is only shown submissions selected by SLDC. This is akin to the defence relying on the prosecution to state their case. I propose that to improve this process the inspector and his team should have access to ALL SUBMISSIONS and OBJECTIONS so that they are fully informed. By SLDC selecting the material to be put before the inspector I submit that the process is flawed and therefore unsound and not legally compliant.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
Local groups I hope will be represented but it is important, if SLDC is to fulfil their obligation of true public consultation, that the inspector hears objections and submissions directly in person from local individuals/residents with sound objections. The process will not be seen to be fair or just if SLDC are not publicly opposed before the inspector by local individuals, with valid evidence based objections, who will have to watch and live with the resulting desecration of protected sites.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
341. Mr and Mrs E W and M Harris (Individual) : 25 Apr 2012 11:21:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - RN337# ARNSIDE STATION RD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
The DPD has not had regard to the Sustainable Community Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The arnside community and neighbourhood plans should be considered
The new version of the national planning policy framework provide special protection for grenfield sites and AONB, these should be observed.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
R81 and R88 greenfield sites designated as "important open space" must be given 'the highest status of protection in relation to landscape and scenic beauty'. Commercial development (ratio 35/65) requiring 3 times the amount of land necessary for affordable housing cannot be justified (currently 70 houses for sale) It would damage the rural character of the AONB
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
342. Mr and Mrs E W and M Harris (Individual) : 1 May 2012 11:57:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - R81 ARNSIDE REDHILLS ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
The DPD has not had regard to the Sustainable Community Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The arnside community and neighbourhood plans should be considered
The new version of the national planning policy framework provide special protection for grenfield sites and AONB, these should be observed.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
R81 and R88 greenfield sites designated as "important open space" must be given 'the highest status of protection in relation to landscape and scenic beauty'. Commercial development (ratio 35/65) requiring 3 times the amount of land necessary for affordable housing cannot be justified (currently 70 houses for sale) It would damage the rural character of the AONB
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
343. Mr Richard J Harvey (Individual) : 25 Apr 2012 09:47:00
Paragraph No.
1.9
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
In my opinion. despite its protracted nature, the consultation process has not effectively engaged all sections of the community. It is now particularly disconcerting that the public are invited to make brief and concise comment, in a short consultation period, on a vast amount of text, which has proved very contentious. SLDC appear to have conducted the exercise with a degree of cynicism and contrary to the true spirit of genuine consultation.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
344. Mr Richard J Harvey (Individual) : 25 Apr 2012 09:51:00
Policy/Site No.
LA1.3 Housing Allocations - RN57M MILNTHORPE ADJ. TO ST ANTHONY'S CLOSE
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
My representations focus on proposed allocation of RN57 at Milnthorpe, which I
consider to be neither sound, justified, nor effective.
In maintaining opposition to the allocation of RN57 on access and safety grounds, I am
supported by at least 51 adult residents from the 53 dwellings on the existing St Anthony's
Hill housing development.
We do, of course, accept the need for an adequate supply of affordable housing to meet
the legitimate needs of the local community, but we are not persuaded that, having regard to
the form and character of Milnthorpe, this justifies an arbitrary allocation of 186 dwellings, far.
more than are necessary to satisfy the actual need for affordable houses. This would appear
to have been a simplistic, top-down calculation rather than one based on the environmental
capacity of Milnthorpe to satisfactorily accommodate such a large number.
There cannot, of course be any guarantee that the suppliers of private open-market
housing, who are presumably expected to provide the required affordable housing, can and
will do so. Unfortunately, no alternative mechanisms are put forward should this approach
fail. There is a danger that Milnthorpe could face a large increase in the number of houses
without meeting the basic need for affordable housing.
Incidentally, we are not satisfied that the infrastructure implications of the
various land allocations in Milnthorpe have been properly considered and that
the agencies involved in their provision are fully committed to their solution within the
timescale required and the resources available to them.
During earlier phases of the consultation process, particularly ill-considered proposals for
development on M6; R79 and part of R93, which encroached on the setting of St Anthony's
Tower, were understandably abandoned.
However we strongly maintain that all of R93 (including the residual part now
identified as RN57), should have been excluded.
This is particularly pertinent since RN57 might be developed in such a way as to open up,
for subsequent development, the land hitherto excluded. Indeed the very shape and
disposition of RN57 would suggest that it is indeed intended to open up more land to the
East and North. If this happened, the existing blatantly obvious access problem on the
inadequate and potentially dangerous spine road serving the St Anthony's Hill housing
development would be. greatly exacerbated.
This road is narrow, tortuous, lacks adequate footways; has steep blind bends and is
regularly obstructed by parked vehicles, which effectively reduce it to a single lane.
Collisions between cars have already occurred and there have been a number of very near
misses. Emergency vehicles face access difficulties and to improve the road would be very
difficult and might be impossible without compulsory purchase.
Moreover, the road has a very poor and potentially dangerous junction with the A6. If the
Highway Authority has indeed been consulted (we have been unable to obtain any
categorical assurances that this has happened) ,we would be amazed if they considered the
sight-lines for traffic joining the A6 were adequate, especially since traffic on this section of
the A6 frequently disregards the 30mph speed limit with apparent immunity from prosecution.
In short, we would urge that RN57 be removed from the land allocation. That
it has not already been removed suggests that SLDC have given inadequate
consideration to earlier reasoned objections.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
345. Mr & Mrs R Harvey (Individual) : 4 May 2012 11:12:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
0.0 Whole Document
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
The DPD has not had regard to the Sustainable Community Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
It is remarkable that the opposition, by the electorate, of this plan has not had a corresponding result for its outcome. The evidence and costings and detail needed to allocate land for large scale development is remarkably absent. The infrastructure growth to cope with 6000 new homes and their occupants etc is remarkably absent.
1. A Special Case for South Lakeland District(SLD)
1.1 Two different National Park Authorities (NPs) have control of two large sectors of South Lakeland, and if we consider the AONBs and SSSis and other protected areas within SLD's landscape, then there is little room for development left on the scale apparently demanded by National and Local Government.
1.2 Why should SLD outside of the NPs become overdeveloped to its detriment, compared with SLD within NPs, when there is as much need for housing and employment in the valleys of National Parks? The monoculture of Tourism, and that as many as 4 in I 0 houses in some cases are second or holiday homes, within a National Park, is unsustainable. Many of those who live in NPs travel outside its boundary for work. Whither the daffodils? they grow on both sides of the line.
1.3 Any legislation driving this LDF and DPD should take these administrative and landscape constraints, and their effects
upon local communities within a single District Council's area, into account as a special case and exception.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Have any alternatives (other than differant sites) been considered at all? is large scale greenfield development most appropriate in the landscape? in order to build 2000 affordable homes is it necessary to build 5000 more for profit?
SOUNDNESS comments
2. More specifically commenting upon this DPD (for SLD outside of National Parks), and in particular for Kendal town.
We find this DPD Unsound because:-
2.1 There is no costed, reasoned, evidence for social, environmental and economic sustainability, beyond the length of a "housing list".
2.2 The infrastructure of water and energy supplies, drainage and sewerage system, schools and health and emergency care will not be sufficient for daily needs with this level of proposed development, and there is no evidence that any has been planned or costed.
2.3 The landscape character will be changed irreparably. The impact on the local community will cause significant harm. It does not protect the open countryside, nor does it prevent sprawl or safeguard an historic landscape, especially on the Underbarrow Road.
2.4 The majority of people will probably find employment outside of Kendal.
2.5 There is no evidence of the impact on air quality or of a suitable new transport plan.
2.6 There is little evidence that the local electorate support this Plan. In fact more seem to be against it.
The actual housing demand is as likely to be half what is proposed. This is exacerbated by the need to build, say, 65 houses for every 35 affordable ones, to attract the developers.
2.7 The LPA is being railroaded into approving large-scale developments on greenfield sites with very little evidence but rather more conjecture.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
The issue is too important to be left to planners and politicians only. I care about the landscape of SLDC
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
346. Mr & Mrs R Harvey (Individual) : 4 May 2012 11:36:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - All Kendal sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
SOUNDNESS comments
2. More specifically commenting upon this DPD (for SLD outside of National Parks), and in particular for Kendal town.
We find this DPD Unsound because:-
2.1 There is no costed, reasoned, evidence for social, environmental and economic sustainability, beyond the length of a "housing list".
2.2 The infrastructure of water and energy supplies, drainage and sewerage system, schools and health and emergency care will not be sufficient for daily needs with this level of proposed development, and there is no evidence that any has been planned or costed.
2.3 The landscape character will be changed irreparably. The impact on the local community will cause significant harm. It does not protect the open countryside, nor does it prevent sprawl or safeguard an historic landscape, especially on the Underbarrow Road.
2.4 The majority of people will probably find employment outside of Kendal.
2.5 There is no evidence of the impact on air quality or of a suitable new transport plan.
2.6 There is little evidence that the local electorate support this Plan. In fact more seem to be against it.
The actual housing demand is as likely to be half what is proposed. This is exacerbated by the need to build, say, 65 houses for every 35 affordable ones, to attract the developers.
2.7 The LPA is being railroaded into approving large-scale developments on greenfield sites with very little evidence but rather more conjecture.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
see rep 1
347. Mr & Mrs R Harvey (Individual) : 4 May 2012 11:38:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.4 - Kendal Sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
SOUNDNESS comments
2. More specifically commenting upon this DPD (for SLD outside of National Parks), and in particular for Kendal town.
We find this DPD Unsound because:-
2.1 There is no costed, reasoned, evidence for social, environmental and economic sustainability, beyond the length of a "housing list".
2.2 The infrastructure of water and energy supplies, drainage and sewerage system, schools and health and emergency care will not be sufficient for daily needs with this level of proposed development, and there is no evidence that any has been planned or costed.
2.3 The landscape character will be changed irreparably. The impact on the local community will cause significant harm. It does not protect the open countryside, nor does it prevent sprawl or safeguard an historic landscape, especially on the Underbarrow Road.
2.4 The majority of people will probably find employment outside of Kendal.
2.5 There is no evidence of the impact on air quality or of a suitable new transport plan.
2.6 There is little evidence that the local electorate support this Plan. In fact more seem to be against it.
The actual housing demand is as likely to be half what is proposed. This is exacerbated by the need to build, say, 65 houses for every 35 affordable ones, to attract the developers.
2.7 The LPA is being railroaded into approving large-scale developments on greenfield sites with very little evidence but rather more conjecture.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
see rep 1
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
348. Mr & Mrs R Harvey (Individual) : 4 May 2012 11:39:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.6 Strategic Employment Sites - E4M KENDAL LAND AT SCROGGS WOOD, MILNTHORPE ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
SOUNDNESS comments
2. More specifically commenting upon this DPD (for SLD outside of National Parks), and in particular for Kendal town.
We find this DPD Unsound because:-
2.1 There is no costed, reasoned, evidence for social, environmental and economic sustainability, beyond the length of a "housing list".
2.2 The infrastructure of water and energy supplies, drainage and sewerage system, schools and health and emergency care will not be sufficient for daily needs with this level of proposed development, and there is no evidence that any has been planned or costed.
2.3 The landscape character will be changed irreparably. The impact on the local community will cause significant harm. It does not protect the open countryside, nor does it prevent sprawl or safeguard an historic landscape, especially on the Underbarrow Road.
2.4 The majority of people will probably find employment outside of Kendal.
2.5 There is no evidence of the impact on air quality or of a suitable new transport plan.
2.6 There is little evidence that the local electorate support this Plan. In fact more seem to be against it.
The actual housing demand is as likely to be half what is proposed. This is exacerbated by the need to build, say, 65 houses for every 35 affordable ones, to attract the developers.
2.7 The LPA is being railroaded into approving large-scale developments on greenfield sites with very little evidence but rather more conjecture.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
see rep 1
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
349. Mr & Mrs R Harvey (Individual) : 4 May 2012 11:41:00
Policy/Site No.
LA1.7 Business and Science Park Sites - M2M-mod KENDAL LAND EAST OF BURTON ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
SOUNDNESS comments
2. More specifically commenting upon this DPD (for SLD outside of National Parks), and in particular for Kendal town.
We find this DPD Unsound because:-
2.1 There is no costed, reasoned, evidence for social, environmental and economic sustainability, beyond the length of a "housing list".
2.2 The infrastructure of water and energy supplies, drainage and sewerage system, schools and health and emergency care will not be sufficient for daily needs with this level of proposed development, and there is no evidence that any has been planned or costed.
2.3 The landscape character will be changed irreparably. The impact on the local community will cause significant harm. It does not protect the open countryside, nor does it prevent sprawl or safeguard an historic landscape, especially on the Underbarrow Road.
2.4 The majority of people will probably find employment outside of Kendal.
2.5 There is no evidence of the impact on air quality or of a suitable new transport plan.
2.6 There is little evidence that the local electorate support this Plan. In fact more seem to be against it.
The actual housing demand is as likely to be half what is proposed. This is exacerbated by the need to build, say, 65 houses for every 35 affordable ones, to attract the developers.
2.7 The LPA is being railroaded into approving large-scale developments on greenfield sites with very little evidence but rather more conjecture.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
see rep 1
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
350. Mr & Mrs R Harvey (Individual) : 4 May 2012 11:42:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.8 Local Employment Sites - All Kendal sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
SOUNDNESS comments
2. More specifically commenting upon this DPD (for SLD outside of National Parks), and in particular for Kendal town.
We find this DPD Unsound because:-
2.1 There is no costed, reasoned, evidence for social, environmental and economic sustainability, beyond the length of a "housing list".
2.2 The infrastructure of water and energy supplies, drainage and sewerage system, schools and health and emergency care will not be sufficient for daily needs with this level of proposed development, and there is no evidence that any has been planned or costed.
2.3 The landscape character will be changed irreparably. The impact on the local community will cause significant harm. It does not protect the open countryside, nor does it prevent sprawl or safeguard an historic landscape, especially on the Underbarrow Road.
2.4 The majority of people will probably find employment outside of Kendal.
2.5 There is no evidence of the impact on air quality or of a suitable new transport plan.
2.6 There is little evidence that the local electorate support this Plan. In fact more seem to be against it.
The actual housing demand is as likely to be half what is proposed. This is exacerbated by the need to build, say, 65 houses for every 35 affordable ones, to attract the developers.
2.7 The LPA is being railroaded into approving large-scale developments on greenfield sites with very little evidence but rather more conjecture.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
see rep 1
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
351. Mr & Mrs R Harvey (Individual) : 4 May 2012 11:44:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - R121M-mod KENDAL EAST OF CASTLE GREEN ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
SOUNDNESS: JUSTIFIED, EFFECTIVE comments
3. With particular reference to modified site R121M (lncluding parts of exR56 and exR141)
We fid Rl21M of this DPD Unsound because:
3.1 It disregards Kendal Town Council's preferences. We say it is not deliverable, not sustainable and there is no evidence base to support its inclusion in the DPD.
3.2 It is not the best location in sustainability and planning terms. The northern two fields make a land-locked site that is totally dependent upon access to a road via sites previously called R56 and Rl41. Without those pieces of land there can be no site access. If the triangle of land made up of exR56 and exR141 is removed then the whole site fails.
3.3 ExR56 and exR141 were previously marked as possible sites for housing, but they have now been deemed to be unsuitable far housing and are included in Rl21M purely to facilitate access. On the one hand there is the implied admission that that land cannot be suitable or damaged for houses, but may be suitable and damaged merely for a road and utility services.
3.4 The cost per unit length of road, lighting, water, electricity and gas, and Sustainable Urban Drainage System, before the proposed site for houses is reached, would probably take up a large proportion of the costs of such services over the whole site. The site is probably uneconomic.
3.5 ExR56 has been refused planning permission in the past and although circumstances may have changed the reasons and principles that informed that earlier decision probably have not To say that those Inspector's reasons "may no longer be relevant" could equally well be wrong. Reasons for giving planning permission, or not, surely are consistent over time?
3.6 ExR56 and exR141 are the most visible, and potentially most damaging to biodiversity, of the amended Rl21M. Street lighting alone will light up hitherto dark fields and woods and pond to the detriment of the landscape and the wildlife, especially Triturus cristatus. Local Environmental Groups have characterised this site as Sensitive. The proposed development is insensitive.
3. 7 The additional waste of 60 houses per year could amount to ( 60x507kg) =30420kg The additional water requirements per year for 60 houses could be (365x60xl55litres) =3,394,500litres. There is no evidence showing how these will be managed or who will pay.
3.8 Rl21M has apparently recognised flooding issues and the resilience of the water and waste services for this site is critical. No evidence or studies have yet been produced to say how these will be met and at what cost.
3.9 The agricultural landscape character will be harmed by such a development. There is the added implication that were an access road to be built, then at a later stage more building alongside that road could be threatened.
3.10 Alarmingly, very little consideration has been given to pedestrian or cycle links to the site. If pedestrians are to access the Old Sedbergh Road from the NW comer, then there are no pavement sidewalks on much of that road. If they are to use Castle Green Lane then there is no pavement sidewalk on the NE side of that 40mph road. It is clear It has been considered only in terms of the use of cars which will put added pressure and N02(etc) air pollution on three pinch points into or around Kendal; Parkside Road, Anne Street!Longpool, and Sandylands and their junctions with the A684.
3.11 Under Policy LA2.3 of the DPD there are so many constraints and provisions for the site that this proves the site is unsustainable and not the best site for development. The number of features that will require mitigation, or assessment and approval, prove that the site is uneconomic and unsuitable for development as housing and for road and utility access. The evidence needed has not yet been gathered. It is all to happen at some future date. That is not Planning for Development but rather planning to have a plan later, maybe, provided the evidence does not contradict or prove to be uneconomic. The site
therefore is not immediately developable.
3.12 The tests and toolkits and appraisal questions have not been adequately applied or answered over the amended site. The fact that policy LA2.3 exists at all is evidence of this.
We urge the Inspector to visit tbe site.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
see rep 1
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
352. Mr & Mrs R Harvey (Individual) : 4 May 2012 11:45:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA2.3 Land East of Castle Green Road
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
SOUNDNESS: JUSTIFIED, EFFECTIVE comments
3. With particular reference to modified site R121M (lncluding parts of exR56 and exR141)
We fid Rl21M of this DPD Unsound because:
3.1 It disregards Kendal Town Council's preferences. We say it is not deliverable, not sustainable and there is no evidence base to support its inclusion in the DPD.
3.2 It is not the best location in sustainability and planning terms. The northern two fields make a land-locked site that is totally dependent upon access to a road via sites previously called R56 and Rl41. Without those pieces of land there can be no site access. If the triangle of land made up of exR56 and exR141 is removed then the whole site fails.
3.3 ExR56 and exR141 were previously marked as possible sites for housing, but they have now been deemed to be unsuitable far housing and are included in Rl21M purely to facilitate access. On the one hand there is the implied admission that that land cannot be suitable or damaged for houses, but may be suitable and damaged merely for a road and utility services.
3.4 The cost per unit length of road, lighting, water, electricity and gas, and Sustainable Urban Drainage System, before the proposed site for houses is reached, would probably take up a large proportion of the costs of such services over the whole site. The site is probably uneconomic.
3.5 ExR56 has been refused planning permission in the past and although circumstances may have changed the reasons and principles that informed that earlier decision probably have not To say that those Inspector's reasons "may no longer be relevant" could equally well be wrong. Reasons for giving planning permission, or not, surely are consistent over time?
3.6 ExR56 and exR141 are the most visible, and potentially most damaging to biodiversity, of the amended Rl21M. Street lighting alone will light up hitherto dark fields and woods and pond to the detriment of the landscape and the wildlife, especially Triturus cristatus. Local Environmental Groups have characterised this site as Sensitive. The proposed development is insensitive.
3. 7 The additional waste of 60 houses per year could amount to ( 60x507kg) =30420kg The additional water requirements per year for 60 houses could be (365x60xl55litres) =3,394,500litres. There is no evidence showing how these will be managed or who will pay.
3.8 Rl21M has apparently recognised flooding issues and the resilience of the water and waste services for this site is critical. No evidence or studies have yet been produced to say how these will be met and at what cost.
3.9 The agricultural landscape character will be harmed by such a development. There is the added implication that were an access road to be built, then at a later stage more building alongside that road could be threatened.
3.10 Alarmingly, very little consideration has been given to pedestrian or cycle links to the site. If pedestrians are to access the Old Sedbergh Road from the NW comer, then there are no pavement sidewalks on much of that road. If they are to use Castle Green Lane then there is no pavement sidewalk on the NE side of that 40mph road. It is clear It has been considered only in terms of the use of cars which will put added pressure and N02(etc) air pollution on three pinch points into or around Kendal; Parkside Road, Anne Street!Longpool, and Sandylands and their junctions with the A684.
3.11 Under Policy LA2.3 of the DPD there are so many constraints and provisions for the site that this proves the site is unsustainable and not the best site for development. The number of features that will require mitigation, or assessment and approval, prove that the site is uneconomic and unsuitable for development as housing and for road and utility access. The evidence needed has not yet been gathered. It is all to happen at some future date. That is not Planning for Development but rather planning to have a plan later, maybe, provided the evidence does not contradict or prove to be uneconomic. The site
therefore is not immediately developable.
3.12 The tests and toolkits and appraisal questions have not been adequately applied or answered over the amended site. The fact that policy LA2.3 exists at all is evidence of this.
We urge the Inspector to visit tbe site.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
see rep 1
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
353. Mr Ian Hatwell (Individual) : 9 Apr 2012 11:27:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
We consider that the process has been unsound for the following reasons
A) Certain relevant documents and facts appear not to have been considered:
A document prepared by Kendal Town Council advocating an alternative approach has not been considered and is nowhere referred to in the document or elsewhere. No appraisal or critique of this document has been issued.
An overwhelmingly negative and/or critical public response has resulted in very little change to the draft plan and some contentious sites have actually been expanded.
An excessively high forecast for population growth has been adopted, which does not accord either with current population trends or with the specific age profile of the area, which has a preponderance of older people.
The acknowledged problem of excessively high air pollution in Lowther Street has not been addressed, other than in a vague reference to traffic management. The expanded proposal R129M will significantly increase rush-hour congestion in this area.
There is no adequate consideration of brown field sites.
B) The proposed allocation for housing is utterly out of balance with the allocation for employment. This will encourage commuting out of the area, which is at odds with the criterion of environmental sustainability. It is also likely to increase second home ownership, which is a major problem in the area.
C) The process itself has been unsound in our judgment since:
In the second phase of consultation, extra land allocation has been made (e.g. an addition to R129M) which had previously been ruled out on environmental and amenity grounds. It appears to have been added simply because the owner is willing to sell it. The document states that the environmental impact will be 'mitigated by screening', which is hardly adequate and ignores the fact that the lie of the land makes this a near-impossibility. This land borders the Lake District National Park.
Public participation has been hindered because the design of the SLDC web-site, the council's preferred means of communication, is unwieldy and difficult to navigate, and posting representations to it has proved unreliable. This discourages participation. Errors in the documentation have misled residents about where development is proposed; site R129M was initially referred to as 'land south of Brigsteer Road' when it lies to the north.
CONCLUSION
We contend that :
i) undue emphasis has been placed on whether land is available for sale, rather than where development would be most appropriate
ii) once an outline approach had been defined, the council failed to consider alternative approaches or review its initial conclusions
iii) where obstacles have been identified, an inadequate reference to 'mitigation' has frequently been made, without any attempt to address the underlying issues.
These are serious deficiencies which cannot be corrected by tinkering with the text. The document should be withdrawn and fully re-appraised.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
354. Mr Ian Hatwell (Individual) : 18 May 2012 14:58:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
0.0 Whole Document
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
An overwhelmingly negative and/or critical public response has resulted in very little change to the draft plan and some contentious sites have actually been expanded.
An excessively high forecast for population growth has been adopted, which does not accord either with current population trends or with the specific age profile of the area, which has a preponderance of older people.
CONCLUSION
We contend that :
i) undue emphasis has been placed on whether land is available for sale, rather than where development would be most appropriate
ii) once an outline approach had been defined, the council failed to consider alternative approaches or review its initial conclusions
iii) where obstacles have been identified, an inadequate reference to 'mitigation' has frequently been made, without any attempt to address the underlying issues.
These are serious deficiencies which cannot be corrected by tinkering with the text. The document should be withdrawn and fully re-appraised.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
355. Mr Ian Hatwell (Individual) : 18 May 2012 15:02:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - All Kendal sites
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
We consider that the process has been unsound for the following reasons
A) Certain relevant documents and facts appear not to have been considered:
A document prepared by Kendal Town Council advocating an alternative approach has not been considered and is nowhere referred to in the document or elsewhere. No appraisal or critique of this document has been issued.
There is no adequate consideration of brown field sites.
B) The proposed allocation for housing is utterly out of balance with the allocation for employment. This will encourage commuting out of the area, which is at odds with the criterion of environmental sustainability. It is also likely to increase second home ownership, which is a major problem in the area.
CONCLUSION
We contend that :
i) undue emphasis has been placed on whether land is available for sale, rather than where development would be most appropriate
ii) once an outline approach had been defined, the council failed to consider alternative approaches or review its initial conclusions
iii) where obstacles have been identified, an inadequate reference to 'mitigation' has frequently been made, without any attempt to address the underlying issues.
These are serious deficiencies which cannot be corrected by tinkering with the text. The document should be withdrawn and fully re-appraised.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
356. Mr Ian Hatwell (Individual) : 18 May 2012 15:06:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - R129M KENDAL SOUTH OF UNDERBARROW ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The acknowledged problem of excessively high air pollution in Lowther Street has not been addressed, other than in a vague reference to traffic management. The expanded proposal R129M will significantly increase rush-hour congestion in this area.
There is no adequate consideration of brown field sites.
C) The process itself has been unsound in our judgment since:
In the second phase of consultation, extra land allocation has been made (e.g. an addition to R129M) which had previously been ruled out on environmental and amenity grounds. It appears to have been added simply because the owner is willing to sell it. The document states that the environmental impact will be 'mitigated by screening', which is hardly adequate and ignores the fact that the lie of the land makes this a near-impossibility. This land borders the Lake District National Park.
CONCLUSION
We contend that :
i) undue emphasis has been placed on whether land is available for sale, rather than where development would be most appropriate
ii) once an outline approach had been defined, the council failed to consider alternative approaches or review its initial conclusions
iii) where obstacles have been identified, an inadequate reference to 'mitigation' has frequently been made, without any attempt to address the underlying issues.
These are serious deficiencies which cannot be corrected by tinkering with the text. The document should be withdrawn and fully re-appraised.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
357. Mr Ian Hatwell (Individual) : 18 May 2012 15:10:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
1.9
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Public participation has been hindered because the design of the SLDC web-site, the council's preferred means of communication, is unwieldy and difficult to navigate, and posting representations to it has proved unreliable. This discourages participation. Errors in the documentation have misled residents about where development is proposed; site R129M was initially referred to as 'land south of Brigsteer Road' when it lies to the north.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
358. M & A Hawthorn (Individual) : 27 Apr 2012 14:19:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
1.10
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Of nearly 3000 responses to the land allocations document (DPD) consultation in the
Kendal area, 98% opposed the sites included in the document. Therefore these
proposals cannot be considered 'sound'. True sustainability, when considering an
application, gives equal weight to the interests of people, prosperity and places. The
views of the local residents and the huge environmental impact appear to have been
totally ignored.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
359. M & A Hawthorn (Individual) : 27 Apr 2012 14:21:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - RN169M+ RN299# KENDAL WEST OF HIGH SPARROWMIRE
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
There are many issues of concern for Site RN1 69M and RN2991\:
It boasts glorious views across to the Lakeland Fells and is widely visible from the
surrounding hills of the National Park and many other vantage points both North and
East as well as providing an essential Green Gap between Kendal and neighbouring
Burneside. This green field site, like so many others that have been proposed, gives
Kendal much of its charm. It is irreplaceable. Once built on they will be gone forever.
The increase of traffic flow both along Windermere Road and also through the Hallgarth
estate are of serious concern. The estate wasn't built with so much traffic in mind and is
already coping with large amounts of traffic - often racing through at high speed in spite
of speed control measures having been put in place. An increase in traffic on the estate
would increase the danger for residents, not to mention the major road works that would
be necessary in order to facilitate appropriate access. This would swallow up even more
vital green field sites and crucial wildlife habitats in the process.
There is currently no provision for mains gas, sewage and I presume, other amenities
too, for this site. Installing a sewage network would increase pressure on the existing
sewage network that may lead to overload and pollution of the River Kent. This could be
an environmental disaster and be very costly.
Drainage of this site is currently very poor. Some sort of drainage would therefore be
imperative in order to avert problems with flooding. This, however, would certainly affect
the delicate ecosystem of the area, for which I have grave concerns.
And where are the new schools and places of employment?
I support the need for more affordable housing in the district but there are alternative
ways of meeting this need rather than through this Developers' Charter. The DPD, if it is
approved, will lead to housing sprawl around our towns and villages, worse traffic, air
quality and flooding problems and the destruction of important animal and bird habitats.
With the current global constraints regarding oil and food production and with our
increased awareness and need for sustainable living, we must consider very carefully the
overall cost of exploiting our fragile landscape.
We must first make creative use of brown field sites that are dotted around Kendal,
currently unused, as well as making use of the unused housing stock to meet this
housing need. Through proper consultation with local people and proper application of
the principles of sustainability, well informed decisions can be made.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
360. M & A Hawthorn (Individual) : 27 Apr 2012 14:24:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
3.14
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
There are many issues of concern for Site RN1 69M and RN2991\:
It boasts glorious views across to the Lakeland Fells and is widely visible from the
surrounding hills of the National Park and many other vantage points both North and
East as well as providing an essential Green Gap between Kendal and neighbouring
Burneside. This green field site, like so many others that have been proposed, gives
Kendal much of its charm. It is irreplaceable. Once built on they will be gone forever.
The increase of traffic flow both along Windermere Road and also through the Hallgarth
estate are of serious concern. The estate wasn't built with so much traffic in mind and is
already coping with large amounts of traffic - often racing through at high speed in spite
of speed control measures having been put in place. An increase in traffic on the estate
would increase the danger for residents, not to mention the major road works that would
be necessary in order to facilitate appropriate access. This would swallow up even more
vital green field sites and crucial wildlife habitats in the process.
There is currently no provision for mains gas, sewage and I presume, other amenities
too, for this site. Installing a sewage network would increase pressure on the existing
sewage network that may lead to overload and pollution of the River Kent. This could be
an environmental disaster and be very costly.
Drainage of this site is currently very poor. Some sort of drainage would therefore be
imperative in order to avert problems with flooding. This, however, would certainly affect
the delicate ecosystem of the area, for which I have grave concerns.
And where are the new schools and places of employment?
I support the need for more affordable housing in the district but there are alternative
ways of meeting this need rather than through this Developers' Charter. The DPD, if it is
approved, will lead to housing sprawl around our towns and villages, worse traffic, air
quality and flooding problems and the destruction of important animal and bird habitats.
With the current global constraints regarding oil and food production and with our
increased awareness and need for sustainable living, we must consider very carefully the
overall cost of exploiting our fragile landscape.
We must first make creative use of brown field sites that are dotted around Kendal,
currently unused, as well as making use of the unused housing stock to meet this
housing need. Through proper consultation with local people and proper application of
the principles of sustainability, well informed decisions can be made.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
361. Mr Michael Haygarth (Individual) : 16 Apr 2012 09:15:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
0.0 Whole Document
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The views/responses of the residents of Valley Drive have not been taken into account.
All responses for RN117M on the original documentation were completely ignored. Several of these responses were not even listed/noted on the website so the number of responses reflected on the site are not correct!
There is no adequate consideration of the brownfield sites that were alternatively proposed.
Transport Study. Currently a work in progress with no actual facts in place.
The DPD should not be approved until a viable infrastructure delivery plan is in place.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I believe that RN117M should be withdrawn from the plan because due consideration has not been given to the effect that this development would have on this area of green space. There has been limited consultation feedback about this site.
Previous site history confirms that this site has been withdrawn on two separate occasions in the past due to access and the impact on visual amenity within the area.
a) May 1979 Application Reference Number 5/79/0237.
b) May 1988 Application Reference Number 5/87/1717
Despite the facts issued that the land at the top of the field which is adjacent to Millennium Wood would not spoil the visual effect from the castle. The lower section of the field on the proposed land would still be visible from the castle and would have a disastrous effect on all the houses situated in close proximity to the EAST of this field.
Issues that have not been addressed and further clarification are required as follows:-
Proximity of overhead cables which cross the proposed site. Further investigation required.
Sewerage/Drainage Issues
Sewerage facilities are running at maximum levels.
Drainage issues on the proposed site have been noted within the fact file extract detailed below:
Sewage and water issues. Flood Zone 1
LA DPD Appendix 1B Page 119 states surface water issues only.
Contra to these findings this site does flood on a regular occurrence and residents gardens to the EAST hold a lot of water after heavy rainfall. However, there is no certainty over the future investment by United Utilities on water/sewerage challenges.
Inadequate road infrastructure.
Kendal Transport Plan review should be in place now with actual facts and nothing has been clearly defined.
Traffic Issues
Very poor restricted road access/traffic generation
Access to site via existing cul-de-sacs. Transport Statement required. Cumbria County Council (Officer Comments November 2011).
Access to this site would be an absolute nightmare for the residents who live in close proximity and also the entrance to this site which would have to be accessed via the cul-de-sacs on Valley Drive. This would cause serious traffic issues on the fast road which is currently used as a rat run to avoid the town centre.
Extract taken from Kendal LDF Transport Study – Jan 2012
4.2.2 In total 13 junctions are indicated to have a maximum RFC greater than or equal to 90% in the 2010 base year, in either the AM or PM peak period. One of these junctions is within the Valley Drive area.
Junction 22: Parkside Road / Valley Drive priority junction
Extract taken from Kendal Fact File - February 2012
Page 166
Highways Issues:
No information.
Highways access/safety
Appendix 8 Page 178 Emerging Options (Final Version)
Mitigation measures will be required
Based on the above information these issues have not been properly assessed. Therefore, I have to say that this important issue of safety must be deemed as UNSOUND!
General Overivew of the site RN117M
This land is designated as "Public Open Space". There is bridleway and a public footpath which is in constant use by locals and tourists alike. A very popular recreational land away from the busy road that Valley drive has become. Road access would have to cross third party land to enter the site incidentally owned by (Russell Armer Developments)! Comments within the DPD have simply stated rerouted and access over TP land has been noted within the DPD. However there is no actual plan in place on how this would be implemented.
Intrusion of privacy to the many adjoining properties to the EAST of this site. The potential for visual/privacy intrusion not to mention the extra noise and pollution that this would have over the area.
The land is not flat as described in the fact file but is steep and sloping in nature incorporating drumlins which may constrain development or require unsightly retaining structures. Local elevation of the land provides potential for development to intrude into existing views.
Currently used as farmland for cattle and sheep
Over subscribed facilities
There are currently no school places, doctors and dental surgeries within close proximity of this site are running at full capacity. Information must be backed up with correct facts.
CONCLUSION: Based on all the above findings, this area has not been properly assessed. It has been earmarked as an easy option with no thought to the overall issues and the damage that this will cause to the surrounding landscape. SLDC are not consulting or responding adequately.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
In practice this suggested site does not lend itself to the additional development and the heavy traffic increase that this will bring. Where is the justification or soundness in this plan? I feel that no thought has been made with regard to the infrastructure problems in general and therefore feel in addition to the lack of consultation and insufficient information the soundness is brought into question.
I do hope the Inspector will take time to visit this site. This will enable this person to clarify the uncertainty surrounding the unrealistic comments which have been stated within the DPD with reference to this site.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
362. Mr Michael Haygarth (Individual) : 16 Apr 2012 10:19:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - RN117M KENDAL WEST OF VALLEY DRIVE
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The views/responses of the residents of Valley Drive have not been taken into account.
All responses for RN117M on the original documentation were completely ignored. Several of these responses were not even listed/noted on the website so the number of responses reflected on the site are not correct!
There is no adequate consideration of the brownfield sites that were alternatively proposed.
Transport Study. Currently a work in progress with no actual facts in place.
United Utilities. No certainty over future investment.
The DPD should not be approved until a viable infrastructure delivery plan is in place.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I believe that RN117M should be withdrawn from the plan because due consideration has not been given to the effect that this development would have on this area of green space. There has been limited consultation feedback about this site.
Previous site history confirms that this site has been withdrawn on two separate occasions in the past due to access and the impact on visual amenity within the area.
a) May 1979 Application Reference Number 5/79/0237.
b) May 1988 Application Reference Number 5/87/1717
Despite the facts issued that the land at the top of the field which is adjacent to Millennium Wood would not spoil the visual effect from the castle. The lower section of the field on the proposed land would still be visible from the castle and would have a disastrous effect on all the houses situated in close proximity to the EAST of this field.
Issues that have not been addressed and further clarification are required as follows:-
Proximity of overhead cables which cross the proposed site. Further investigation required.
Sewerage/Drainage Issues
Sewerage facilities are running at maximum levels.
Drainage issues on the proposed site have been noted within the fact file extract detailed below:
Sewage and water issues. Flood Zone 1
LA DPD Appendix 1B Page 119 states surface water issues only.
Contra to these findings this site does flood on a regular occurrence and residents gardens to the EAST hold a lot of water after heavy rainfall. However, there is no certainty over the future investment by United Utilities on water/sewerage challenges.
Inadequate road infrastructure.
Kendal Transport Plan review should be in place now with actual facts and nothing has been clearly defined.
Traffic Issues
Very poor restricted road access/traffic generation
Access to site via existing cul-de-sacs. Transport Statement required. Cumbria County Council (Officer Comments November 2011).
Access to this site would be an absolute nightmare for the residents who live in close proximity and also the entrance to this site which would have to be accessed via the cul-de-sacs on Valley Drive. This would cause serious traffic issues on the fast road which is currently used as a rat run to avoid the town centre.
Extract taken from Kendal LDF Transport Study – Jan 2012
4.2.2 In total 13 junctions are indicated to have a maximum RFC greater than or equal to 90% in the 2010 base year, in either the AM or PM peak period. One of these junctions is within the Valley Drive area.
Junction 22: Parkside Road / Valley Drive priority junction
Extract taken from Kendal Fact File - February 2012
Page 166
Highways Issues:
No information.
Highways access/safety
Appendix 8 Page 178 Emerging Options (Final Version)
Mitigation measures will be required
Based on the above information these issues have not been properly assessed. Therefore, I have to say that this important issue of safety must be deemed as UNSOUND!
General Overivew of the site RN117M
This land is designated as "Public Open Space". There is bridleway and a public footpath which is in constant use by locals and tourists alike. A very popular recreational land away from the busy road that Valley drive has become. Road access would have to cross third party land to enter the site incidentally owned by (Russell Armer Developments)! Comments within the DPD have simply stated rerouted and access over TP land has been noted within the DPD. However there is no actual plan in place on how this would be implemented.
Intrusion of privacy to the many adjoining properties to the EAST of this site. The potential for visual/privacy intrusion not to mention the extra noise and pollution that this would have over the area.
The land is not flat as described in the fact file but is steep and sloping in nature incorporating drumlins which may constrain development or require unsightly retaining structures. Local elevation of the land provides potential for development to intrude into existing views.
Currently used as farmland for cattle and sheep
Over subscribed facilities
There are currently no school places, doctors and dental surgeries within close proximity of this site are running at full capacity. Information must be backed up with correct facts.
CONCLUSION: Based on all the above findings, this area has not been properly assessed. It has been earmarked as an easy option with no thought to the overall issues and the damage that this will cause to the surrounding landscape. SLDC are not consulting or responding adequately
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
In practice this suggested site does not lend itself to the additional development and the heavy traffic increase that this will bring. Where is the justification or soundness in this plan? I feel that no thought has been made with regard to the infrastructure problems in general and therefore feel in addition to the lack of consultation and insufficient information the soundness is brought into question.
I do hope the Inspector will take time to visit this site. This will enable this person to clarify the uncertainty surrounding the unrealistic comments which have been stated within the DPD with reference to this site.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
363. Miss Cathryn Hayhurst (Individual) : 8 Apr 2012 15:15:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - RN152 GREENODD LAND AT THE OLD VICARAGE
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Overall my objection is the use of a green agricultural field site when not all brown field sites have been considered.
Paragraph 5.65 of DPD wrongly describes RN152 as an 'infill site'. There is no housing outside of this site, only the churchyard.
Paragraph 5.65 of DPD wrongly describes RN152 as 'well located in relation to existing services'. The existing wastewater services are of inadequate capacity, which results in blockages and localised flooding. Also about 1/3rd of the plot is below the level of the highway sewer. The new waste water treatment plant cannot handle the volume after heavy rainfall and would see increased flow if the soakaway effect of RN152 was lost.
Paragraph 5.65 of DPD falsely states that 'mature trees border two sides shielding ... existing dwellings on R291'. The trees end adjacent to the first of the three properties on R291, meaning the development on the hill above them will have a severe impact.
Paragraph 5.66 of DPD falsely suggests that building on RN152 will 'safeguard the Crakeside Business Park and Crakeside Works as local employment areas'. With the population of c12,000 in Ulverston 3 miles away there are adequate transport links for employees to live in Ulverston.
There is no need for additional housing in Greenodd/Penny Bridge. There are currently about 13 houses for sale, several empty and others to let, covering all price ranges. A housing survey carried out by the Parish Council only 4 years ago did not identify a need for further homes and gave consideration to the need for affordable homes.
Building in RN152 would cause the loss of the lovely view from the Churchyard across the Crake valley and north to the Coniston hills. The views and the peace and quiet of the Churchyard makes it a special place, not just for Church related activities but also a popular walking route. As such, I believe that RN152 is an asset of community value as described in the Localism Act 2011 and I will encourage the Parish Council to have it listed.
Other factors make RN152 unsuitable as a building plot :
RN152 itself has a soft area at the highest point where underground water comes to the surface. After heavy rainfall water collects at the lowest part of the plot NE corner). With the loss of soakaway, caused by all the resultant hard paved areas of a new development, the potential for flooding of the R291 houses will be significant.
Building on this farmland would contribute to potential loss of local employment. The land has been tenant farmed by the same family for about 80 years. The farm is not large, reducing the acreage further could make it unviable.
The Churchyard has a magnificent avenue of mature Beech trees that run alongside the southern boundary of RN152. Excavation works in RN152 would have great potential to damage the root systems, causing their demise or making them unsafe.
Access and parking within the village is poor, frequently with both sides of the roads filled with parked cars, such that a large vehicle such as a fire engine could not get through. Development of houses on RN152 would significantly increase this vehicle load on the village. The road adjacent to RN152 is also used for parking for church services. On occasions such as weddings and funerals with a large congregation there would be severe problems.
The number of pupils at the village school has exceeded its capacity for about the last 10 years. There is not a need to build additional housing to provide support against falling pupil numbers, as is the case in some other villages.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
364. Miss Cathryn Hayhurst (Individual) : 15 May 2012 15:34:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - RN152 GREENODD LAND AT THE OLD VICARAGE
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Overall my objection is the use of a green agricultural field site when not all brown field sites have been considered.
Paragraph 5.65 of DPD wrongly describes RN152 as an 'infill site'. There is no housing outside of this site, only the churchyard.
Paragraph 5.65 of DPD wrongly describes RN152 as 'well located in relation to existing services'. The existing wastewater services are of inadequate capacity, which results in blockages and localised flooding. Also about 1/3rd of the plot is below the level of the highway sewer. The new waste water treatment plant cannot handle the volume after heavy rainfall and would see increased flow if the soakaway effect of RN152 was lost.
Paragraph 5.65 of DPD falsely states that 'mature trees border two sides shielding ... existing dwellings on R291'. The trees end adjacent to the first of the three properties on R291, meaning the development on the hill above them will have a severe impact.
Paragraph 5.66 of DPD falsely suggests that building on RN152 will 'safeguard the Crakeside Business Park and Crakeside Works as local employment areas'. With the population of c12,000 in Ulverston 3 miles away there are adequate transport links for employees to live in Ulverston.
There is no need for additional housing in Greenodd/Penny Bridge. There are currently about 13 houses for sale, several empty and others to let, covering all price ranges. A housing survey carried out by the Parish Council only 4 years ago did not identify a need for further homes and gave consideration to the need for affordable homes.
Building in RN152 would cause the loss of the lovely view from the Churchyard across the Crake valley and north to the Coniston hills. The views and the peace and quiet of the Churchyard makes it a special place, not just for Church related activities but also a popular walking route. As such, I believe that RN152 is an asset of community value as described in the Localism Act 2011 and I will encourage the Parish Council to have it listed.
Other factors make RN152 unsuitable as a building plot :
RN152 itself has a soft area at the highest point where underground water comes to the surface. After heavy rainfall water collects at the lowest part of the plot NE corner). With the loss of soakaway, caused by all the resultant hard paved areas of a new development, the potential for flooding of the R291 houses will be significant.
Building on this farmland would contribute to potential loss of local employment. The land has been tenant farmed by the same family for about 80 years. The farm is not large, reducing the acreage further could make it unviable.
The Churchyard has a magnificent avenue of mature Beech trees that run alongside the southern boundary of RN152. Excavation works in RN152 would have great potential to damage the root systems, causing their demise or making them unsafe.
Access and parking within the village is poor, frequently with both sides of the roads filled with parked cars, such that a large vehicle such as a fire engine could not get through. Development of houses on RN152 would significantly increase this vehicle load on the village. The road adjacent to RN152 is also used for parking for church services. On occasions such as weddings and funerals with a large congregation there would be severe problems.
The number of pupils at the village school has exceeded its capacity for about the last 10 years. There is not a need to build additional housing to provide support against falling pupil numbers, as is the case in some other villages.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
365. Dr and Mrs Cyril & R.O. Henderson (Individual) : 8 Apr 2012 13:54:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - M41KM KENDAL SOUTH OF LUMLEY ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The process of identification of development sites was influenced by a draft National Policy Framework parts of which have since been radically altered. The allocations were thereby skewed to over development.
A selection based on a false premise can in no way be deemed sound.
In particular the greenfield site of this response which presently and for past years been used for the pasturing of sheep demands review.
A further apparent lack of soundness is in council decisions whereby party political bickering excludes the rational outcome that these serious matters require. See for example a letter to the Westmorland Gazette of Feb. 12th 2012 by Peter Thornton, SLDC Cabinet member for Housing and Development.
The necessary change is the removal of this site from the allocations.
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
No support
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
366. Mr Peter Hickson (Individual) : 25 Apr 2012 11:51:00
Policy/Site No.
SO Site Omission
If you have selected a ‘Site omission’ please enter the site reference or location and relevant policy below
RN87 Allithwaite
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
In the map and other documentation published in January 2011 relating to Emerging Sites, ref RN87 and RN 37 relate to part of Allithwaite Lodge Field. We were very happy for this land which is owned by us but was. also put forward by others to be included as an option for consideration.
Developments on some or all of these two sections would provide pleasant rural aspect for the householders but would not obscure views for others because of the levels of the sites in question.
We understand that the sites were struck off from further consideration on the basis only of access.
Clearly road access onto Flookburgh Road Allithwaite is an issue. A major development would increase traffic volumes perhaps to dangerous or unacceptable levels. However we feel two points require further consideration
• Traffic produced by a small scale development say 3 to 8 properties would be unlikely to
create a major hazard
• If a larger development in the mid to longer term went forward there would be scope for
redevelopment of the junction to embrace appropriate current safety standards.
Accordingly we feel the decision to exclude sections RN 87 and RN 37 from the plan is not sound and should be reviewed. We ask that you submit this view to the appropriate authorities as part of the next stage of the planning process .
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
367. Mr Peter Hickson (Individual) : 25 Apr 2012 11:54:00
Policy/Site No.
SO Site Omission
If you have selected a ‘Site omission’ please enter the site reference or location and relevant policy below
RN37 Allithwaite
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
In the map and other documentation published in January 2011 relating to Emerging Sites, ref RN87 and RN 37 relate to part of Allithwaite Lodge Field. We were very happy for this land which is owned by us but was. also put forward by others to be included as an option for consideration.
Developments on some or all of these two sections would provide pleasant rural aspect for the householders but would not obscure views for others because of the levels of the sites in question.
We understand that the sites were struck off from further consideration on the basis only of access. Clearly road access onto Flookburgh Road Allithwaite is an issue. A major development would increase traffic volumes perhaps to dangerous or unacceptable levels. However we feel two points require further consideration
• Traffic produced by a small scale development say 3 to 8 properties would be unlikely to
create a major hazard
• If a larger development in the mid to longer term went forward there would be scope for
redevelopment of the junction to embrace appropriate current safety standards.
Accordingly we feel the decision to exclude sections RN 87 and RN 37 from the plan is not sound and should be reviewed. We ask that you submit this view to the appropriate authorities as part of the next stage of the planning process .
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
368. Mr Keith Hildrew (Individual) : 27 Apr 2012 14:06:00
Policy/Site No.
LA1.3 Housing Allocations - R121M-mod KENDAL EAST OF CASTLE GREEN ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I am writing with reference to the above document and the process by which this
was completed. It is my belief that the process was unsound on a variety of points
and in view of the unsoundness the DPD should be withdrawn and reconsidered.
My reasons for claiming that the process was unsound are as follows:
1. When attempts to develop such areas have been proposed in the past, they
have been rejected, and development of higher hillsides round Kendal was
considered to be 'unduly prominent'. Although SLDC claim that
circumstances may have changed, it is not sound planning criteria to ignore
previous rulings based on sound principles. In particular previous site notes
by SLDC showed R121M to be unsuitable for development, which was also the
consistent view of Kendal Town Council over the past 3 years. It is not sound
practice to ignore the views of locally elected councillors on the importance
of maintaining green spaces around Kendal.
2. There were mistakes in the Gillespies Report despite this having been
accepted as sound by SLDC, which means that insufficient attention had
been paid to this process, therefore indicating unsound practice.
3. It is clear that insufficient attention had also been paid by the planner
responsible by not visiting the site in detail and assessing the nature of the
terrain as well as the full impact of such development. This is further
evidence of unsound practice. Also questions raised concerning the impact on
landscape, biodiversity and flooding have not been answered.
4. It would appear that core strategy policies have not been adhered to in this
document, especially on green infrastructure, maintaining green corridors,
watercourses and open spaces, in addition to landscape and settlement
character. This is particularly true of proposals to build roads - presumably
with street lighting etc- across the most sensitive areas (eg R56 and R141)
in order to gain access to R121. It is unreasonable and not sound practice not
to adhere to established core strategies.
5. Insufficient preparation and consideration has been given to specific
proposals - again evidence of unsound practice. For example, a stated
preferred option to allow access to R121 through Oak Tree Road was made
without even visiting the site to measure the width of the road, which would
have shown how unsuitable such a proposal was. Another example is not
giving full consideration to the flooding risk of such land and the effect this
might have on the Stock Beck Flood Alleviation Scheme. The volume of water
coming off the 3 fields in question has not been fully assessed - and this
means that the process of adopting such development is inherently
unreliable.
6. Further evidence provided to SLDC has not been taken into account when
reaching a decision. The Friends of the Lake District have given clear
indications of why R121M should not be developed in the report provided as
part of their evidence in March 2011. The independent Landscape Character
Assessment by Galpin stated that R121M was the most sensitive of all the
proposed development sites in terms of impact on the landscape. It seems
' unjustifiable and inflexible of SLDC not to take into account such findings.
7. There is little evidence that SLDC has seriously looked at any alternative
strategy for the area, or has in place a considered strategic plan to deal with
the problems that such development in Kendal will bring in terms of increased
traffic, air quality, sewerage and effect on general well-being. This makes
the process unsound and its proposals unjustified.
It cannot be sound practice to push ahead with development proposals which have
not been based on robust and credible evidence as shown above. I urge the
Inspector to take these views into account and rule the DPD to be unsound.
369. Mr Keith Hildrew (Individual) : 27 Apr 2012 14:16:00
Paragraph No.
1.10
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Finally, there is no evidence that SLDC has taken into consideration the
views of the community directly affected by these proposals. There has been
hardly any noticeable change in general since the first set of land allocations
was published, despite the overwhelming opposition of local residents and
objections from respected local organisations.
370. Mr & Mrs John & Mavis Hill (Individual) : 30 Mar 2012 10:25:00
Policy/Site No.
LA1.3 Housing Allocations - All Holme sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Holme is an exceptionally friendly village where people look out for each other.Over the years it has absorbed many new residents but at its heart is a network of multi-generational families who bring up children in a safe environment and learning a respect for people and surroundings.We fear that something precious could be lost through further expansion and that to satisfy a perceived need for more houses without the added resources we are storing up social problems for the future.
371. Mr Andrew Hodgson (Individual) : 13 Mar 2012 20:53:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - RN109M RN315# SWARTHMOOR OFF CROSS-a-MOOR
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The proposal to build more housing anywhere in Ulverston is not understood or justified by local people. Where is the demand for housing coming from? I have been searching Internet websites for jobs regularly for the past 10 years as Ulverston has been badly hit by downsizing at local companies. There are hardly any jobs available in the Ulverston or Barrow area - as of 13 March the Evening Mail website has 5 jobs in Ulverston (3 of which are repeated – they are the same role advertised three times), Barrow has 3 jobs, whilst Kendal has 22 jobs and Lancaster has 45 jobs advertised. On the jobs in Cumbria website there are 23 jobs advertised in Ulverston (more than 12 are actually at hotels outside Ulverston and 2 in Barrow, whilst there are 76 jobs advertised in Kendal). This means if the proposals for the current amount of housing in Ulverston goes ahead, there will be even more people commuting on the notoriously dangerous A590. Statistics compiled by Cumbria Constabulary have revealed that 30 people have been killed on the A590 between the end of 2000 and the end of 2010. I understand the Highways Agency are currently working on proposals to improve this road. However, I am sure the plans do not include an increase associated with extra vehicles which will result from all the extra housing. Any road death is too many for loved ones left behind and this kind of death toll means safety improvements are clearly needed on the A590. Anyone doing a traffic assessment needs to fully monitor the road at Cross-o-Moor, Swarthmoor at all times of the day during the week (with traffic at peak times from 7.00-9.00 am, 2.30 pm- 3.30 pm and 4.00 pm – 6.00 pm and not just when the traffic appears to be less busy ). Only two weeks ago, there was an accident at Cross-o-Moor involving a motorcyclist and a car, this junction cannot cope with traffic to the existing estate/local villages, never mind 160 houses on yet another estate. There are high traffic safety risks taken by individuals to get onto and leave the A590 at Cross-o-Moor and there is often a build up of traffic in both directions – this area cannot stand any further traffic. Therefore on the above grounds, this development is not sound. There must be better areas to support the council’s ambitions for additional housing.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
372. Miss Caroline Hodgson (Individual) : 15 Apr 2012 19:48:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
0.0 Whole Document
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The views/responses of the resident's have not been taken into account.
All responses for RN117M on the original documentation were completely ignored. Several of these responses were not even listed/noted on the website so the number of responses reflected on the site are not correct!
Kendal Town Council's assessment and comments in the main have been ignored.
There is no adequate consideration of the brown field sites that were alternatively proposed.
There have been too many political issues which have impacted on the overall strategic plans.
The DPD should not be approved until a viable infrastructure delivery plan is in place.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The resident's of Valley Drive consider that the process has been UNSOUND for the following reasons and would like this site to be removed.
The proposed build at RN117M is not sustainable and will put a huge strain on resources that are already an issue in this built up area. Valley Drive is already used as an access route to avoid the town centre for people living in other areas of town and through to Oxenholme. The increase in traffic that any new development will bring will have a serious affect on the quality of life of the people who already live here.
If only these plans were for the benefit of those who actually already live in this vicinity and not about other people making money i.e. Cumbria County Council (land owners) and developers (Russell Armer access rights)! This site has been selected as an easy option with not much thought put into the constraints and issues surrounding the proposed space. There are a lot of undocumented issues which have not been thought through.
The land in question site reference RN117M West of Valley Drive is the only green space left between the Castle Estate and Kendal Parks (Oxenholme) it is classed as Public Open Space. I am astounded that this site has been put forward as a proposed site for the building of initially 72 houses and then revised to incorporate 60 houses (far too many for such a small area). This site has been previously rejected on two separate occasions as noted below.
Site History
Site RN117M has a history of previously being proposed on two separate occasions neither of which came to fruition.
a) May 1979 Application Reference Number 5/79/0237.
Reason Refused on a number of criteria
Petition raised over 140 objections. (This was the majority of all home owners at the time this Valley Drive development was in its infancy.
b) May 1988 Application Reference Number 5/87/1717
Withdrawn by Cumbria County Council
Access issues and the loss of Green Space were listed as the reasons for the removal of this site. These factors are still the same today so why is this site being proposed yet again? There are alternative brownfield sites in and around Kendal which are much more suitable and do not impose on the visual amenity of the surrounding area.
Traffic Issues
No infrastructure plans have been devised to deal with this level of development (e.g. tackling traffic congestion,
Very poor restricted road access/traffic generation
Access to site via existing cul-de-sacs. Transport Statement required. Cumbria County Council (Officer Comments November 2011).
Extract taken from Kendal LDF Transport Study – Jan 2012
4.2.2 In total 13 junctions are indicated to have a maximum RFC greater than or equal to 90% in the 2010 base year, in either the AM or PM peak period. One of these junctions is within the Valley Drive area.
Junction 22: Parkside Road / Valley Drive priority junction
Extract taken from Kendal Fact File - February 2012
Page 166
Highways Issues:
No information.
Sewage and water issues. Flood Zone 1
LA DPD Appendix 1B Page 119 states surface water issues only.
Contra to these findings this site does flood on a regular occurrence and residents gardens to the EAST hold a lot of water after heavy rainfall.
Proximity of overhead electric power cables which cross the proposed site. Further investigation required.
The council has failed to come up with an infrastructure delivery plan, a transport plan or an air quality plan to meet the scale of the development proposed. Based on the above information issues have not been properly assessed and do not pass the SOUNDNESS test!
Visual Amenity
The response from SLDC in the Emerging Options is generally answered as “Taken into Account or Noted”. This type of response is not justified and further clarification is required.
Issues were that development on this elevated site would be prominent to the local residents whose homes and gardens face the proposed site. Also, it would be prominent in the landscape and the loss of visual amenity would apply.
As an elevated site, the buildings would be highly visible not only from the neighboring properties to the EAST which back onto the proposed site but also from properties on the edge of the Castle Estate and Parkside road. The impact would be visually intrusive on a much wider scale then originally documented. This does need to be taken into account and has been completely ignored.
In particular distinctive drumlin landform.
Only one drumlin has been mentioned within the site survey and is noted in the fact file as follows: Protect the distinctive character of the drumlin and avoid the siting of development on its crest/flanks but instead utilise it as open space.
In respect to any future development on this proposed land the description of the land in the DPD in incorrect.
The land is not flat and is steep in nature incorporating drumlins which may constrain development or require unsightly retaining structures. This would have a significant impact on the visual amenity/privacy issues of the residents to the EAST of this land.
This green space has been and still is used by the local farming community for decades (for the grazing of both cows and sheep). Silage is cut here several times throughout the year) so it is already an active working part of the town.
Public Footpath/Bridleway crosses the land
The fact that there is a public footpath and a bridleway that run through this site has simply been brushed aside with comments like rerouted and noted. Friends of the Lake District have also noted issues on this subject which have been largely ignored.
Over subscribed schools and doctors surgeries
There are currently no school places or patient/dentist places available within the immediate vicinity. To say that this area is close to all amenities must be backed up by correct figures. The comments are not justified in the fact files and do not reflect the correct numbers.
CONCLUSION: Considering that there is insufficient information in the public domain which allows estimates of the impact of this development on the existing infrastructure one must conclude that this development proposal must be judged UNSOUND!
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
The residents of Valley Drive need further clarification on the current outstanding issues that have not been fully addressed with the LA DPD.
There are too many examples of particular concerns being dismissed as “noted or taken into account”, without any explanation of the reason for dismissal.
The DPD should not be approved until a viable infrastructure delivery plan is in place together with a transport plan, and an air quality plan to meet the scale of the development proposed.
Based on the above information the issues have not been properly assessed and do not pass the SOUNDNESS test!
I do hope the Inspector will take time to visit this site. This will enable this person to clarify the uncertainty surrounding the unrealistic comments which have been stated within the DPD with reference to this site.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
373. Miss Caroline Hodgson (Individual) : 16 Apr 2012 10:12:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - RN117M KENDAL WEST OF VALLEY DRIVE
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The views/responses of the resident's have not been taken into account. All responses for RN117M on the original documentation were completely ignored. Several of these responses were not even listed/noted on the website so the number of responses reflected on the SLDC website are not correct!
There is no adequate consideration of the brown field sites that were alternatively proposed.
Kendal Town Council's assessment and comments in the main have been ignored.
There have been too many political issues which have impacted on the overall strategic plans.
The DPD should not be approved until a viable infrastructure delivery plan is in place.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The resident's of Valley Drive consider that the process has been UNSOUND for the following reasons and would like this site to be removed.
The proposed build at RN117M is not sustainable and will put a huge strain on resources that are already an issue in this built up area. Valley Drive is already used as an access route to avoid the town centre for people living in other areas of town and through to Oxenholme. The increase in traffic that any new development will bring will have a serious affect on the quality of life of the people who already live here.
If only these plans were for the benefit of those who actually already live in this vicinity and not about other people making money i.e. Cumbria County Council (land owners) and developers (Russell Armer access rights)! This site has been selected as an easy option with not much thought put into the constraints and issues surrounding the proposed space. There are a lot of undocumented issues which have not been thought through.
The land in question site reference RN117M West of Valley Drive is the only green space left between the Castle Estate and Kendal Parks (Oxenholme) it is classed as Public Open Space. I am astounded that this site has been put forward as a proposed site for the building of initially 72 houses and then revised to incorporate 60 houses (far too many for such a small area). This site has been previously rejected on two separate occasions as noted below.
Site History
Site RN117M has a history of previously being proposed on two separate occasions neither of which came to fruition.
a) May 1979 Application Reference Number 5/79/0237.
Reason Refused on a number of criteria
Petition raised over 140 objections. (This was the majority of all home owners at the time this Valley Drive development was in its infancy.
b) May 1988 Application Reference Number 5/87/1717
Withdrawn by Cumbria County Council
Access issues and the loss of Green Space were listed as the reasons for the removal of this site. These factors are still the same today so why is this site being proposed yet again? There are alternative brownfield sites in and around Kendal which are much more suitable and do not impose on the visual amenity of the surrounding area.
Traffic Issues
No infrastructure plans have been devised to deal with this level of development (e.g. tackling traffic congestion,
Very poor restricted road access/traffic generation
Access to site via existing cul-de-sacs. Transport Statement required. Cumbria County Council (Officer Comments November 2011).
Extract taken from Kendal LDF Transport Study – Jan 2012
4.2.2 In total 13 junctions are indicated to have a maximum RFC greater than or equal to 90% in the 2010 base year, in either the AM or PM peak period. One of these junctions is within the Valley Drive area.
Junction 22: Parkside Road / Valley Drive priority junction
Extract taken from Kendal Fact File - February 2012
Page 166
Highways Issues:
No information.
Sewage and water issues. Flood Zone 1
LA DPD Appendix 1B Page 119 states surface water issues only.
Contra to these findings this site does flood on a regular occurrence and residents gardens to the EAST hold a lot of water after heavy rainfall.
Proximity of overhead electric power cables which cross the proposed site. Further investigation required.
The council has failed to come up with an infrastructure delivery plan, a transport plan or an air quality plan to meet the scale of the development proposed. Based on the above information issues have not been properly assessed and do not pass the SOUNDNESS test!
Visual Amenity
The response from SLDC in the Emerging Options is generally answered as “Taken into Account or Noted”. This type of response is not justified and further clarification is required.
Issues were that development on this elevated site would be prominent to the local residents whose homes and gardens face the proposed site. Also, it would be prominent in the landscape and the loss of visual amenity would apply.
As an elevated site, the buildings would be highly visible not only from the neighboring properties to the EAST which back onto the proposed site but also from properties on the edge of the Castle Estate and Parkside road. The impact would be visually intrusive on a much wider scale then originally documented. This does need to be taken into account and has been completely ignored.
In particular distinctive drumlin landform.
Only one drumlin has been mentioned within the site survey and is noted in the fact file as follows: Protect the distinctive character of the drumlin and avoid the siting of development on its crest/flanks but instead utilise it as open space.
In respect to any future development on this proposed land the description of the land in the DPD is incorrect.
The land is not flat and is steep in nature incorporating drumlins which may constrain development or require unsightly retaining structures. This would have a significant impact on the visual amenity/privacy issues of the residents to the EAST of this land.
This green space has been and still is used by the local farming community for decades (for the grazing of both cows and sheep). Silage is cut here several times throughout the year) so it is already an active working part of the town.
Public Footpath/Bridleway crosses the land
The fact that there is a public footpath and a bridleway that run through this site has simply been brushed aside with comments like rerouted and noted. Friends of the Lake District have also noted issues on this subject which have been largely ignored.
Over subscribed schools and doctors surgeries
There are currently no school places or patient/dentist places available within the immediate vicinity. To say that this area is close to all amenities must be backed up by correct figures. The comments are not justified in the fact files and do not reflect the correct numbers.
CONCLUSION: Considering that there is insufficient information in the public domain which allows estimates of the impact of this development on the existing infrastructure one must conclude that this development proposal must be judged UNSOUND!
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
The residents of Valley Drive need further clarification on the current outstanding issues that have not been fully addressed with the LA DPD.
There are too many examples of particular concerns being dismissed as “noted or taken into account”, without any explanation of the reason for dismissal.
The DPD should not be approved until a viable infrastructure delivery plan is in place together with a transport plan, and an air quality plan to meet the scale of the development proposed.
Based on the above information the issues have not been properly assessed and do not pass the SOUNDNESS test!
I do hope the Inspector will take time to visit this site. This will enable this person to clarify the uncertainty surrounding the unrealistic comments which have been stated within the DPD with reference to this site.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
374. Mr Ray Hodgson (Individual) : 16 Apr 2012 10:32:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.7 Business and Science Park Sites - Site Omission
If you have selected a ‘Site omission’ please enter the site reference or location and relevant policy below
Site MN6
Policy LA1.7
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The 'reasons' for not including this area for development into the larger M11M site do not stand up to examination.
These include,
1. Land Levels: From a visual perspective it is obvious that M11M has a greater height differential than MN6. Ordanance survey maps of the area confirm this.
2. Screening: The Dykelands building is already so well screened by walls and trees that most people are not even aware of its existance. This screening was no doubt put in place to block the view and noise of the railway that runs between Dykelands and MN6.
3. Orientation of the Beehive Cottages: This row of cottages are orientated such that the windows of the properties look over M11M rather than MN6. No windows are overlooking site MN6 from any of the properties in this row.
4. Development Potential: This area is available and deliverable for development. If the interest already shown in the development of this site is taken into concideration, there is both a need and a desire for this to be included in the development area.
5. Natural Boundary: The railway and tha A590 form a natural boundary to the development site, hence, the decision not to include MN6, which is within that boundary, does not stand up to scrutiny.
A look at Google earth and Ordanance survey maps of the area and from the information given above, it is obvious that the grounds you have given for excluding MN6 from development are unsound. They do not stand up to scrutiny.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
375. Mr Andrew Hodgson (Individual) : 15 May 2012 13:34:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - All Ulverston sites
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The proposal to build more housing anywhere in Ulverston is not understood or justified by local people. Where is the demand for housing coming from? I have been searching Internet websites for jobs regularly for the past 10 years as Ulverston has been badly hit by downsizing at local companies. There are hardly any jobs available in the Ulverston or Barrow area - as of 13 March the Evening Mail website has 5 jobs in Ulverston (3 of which are repeated – they are the same role advertised three times), Barrow has 3 jobs, whilst Kendal has 22 jobs and Lancaster has 45 jobs advertised. On the jobs in Cumbria website there are 23 jobs advertised in Ulverston (more than 12 are actually at hotels outside Ulverston and 2 in Barrow, whilst there are 76 jobs advertised in Kendal). This means if the proposals for the current amount of housing in Ulverston goes ahead, there will be even more people commuting on the notoriously dangerous A590. Statistics compiled by Cumbria Constabulary have revealed that 30 people have been killed on the A590 between the end of 2000 and the end of 2010. I understand the Highways Agency are currently working on proposals to improve this road. However, I am sure the plans do not include an increase associated with extra vehicles which will result from all the extra housing. Any road death is too many for loved ones left behind and this kind of death toll means safety improvements are clearly needed on the A590. Anyone doing a traffic assessment needs to fully monitor the road at Cross-o-Moor, Swarthmoor at all times of the day during the week (with traffic at peak times from 7.00-9.00 am, 2.30 pm- 3.30 pm and 4.00 pm – 6.00 pm and not just when the traffic appears to be less busy ). Only two weeks ago, there was an accident at Cross-o-Moor involving a motorcyclist and a car, this junction cannot cope with traffic to the existing estate/local villages, never mind 160 houses on yet another estate. There are high traffic safety risks taken by individuals to get onto and leave the A590 at Cross-o-Moor and there is often a build up of traffic in both directions – this area cannot stand any further traffic. Therefore on the above grounds, this development is not sound. There must be better areas to support the council’s ambitions for additional housing.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
376. Mr Ray Hodgson (Individual) : 15 May 2012 16:04:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.7 Business and Science Park Sites - Site Omission
If you have selected a ‘Site omission’ please enter the site reference or location and relevant policy below
MN6#
Policy LA1.7
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The 'reasons' for not including this area for development into the larger M11M site do not stand up to examination.
These include,
1. Land Levels: From a visual perspective it is obvious that M11M has a greater height differential than MN6. Ordanance survey maps of the area confirm this.
2. Screening: The Dykelands building is already so well screened by walls and trees that most people are not even aware of its existance. This screening was no doubt put in place to block the view and noise of the railway that runs between Dykelands and MN6.
3. Orientation of the Beehive Cottages: This row of cottages are orientated such that the windows of the properties look over M11M rather than MN6. No windows are overlooking site MN6 from any of the properties in this row.
4. Development Potential: This area is available and deliverable for development. If the interest already shown in the development of this site is taken into concideration, there is both a need and a desire for this to be included in the development area.
5. Natural Boundary: The railway and tha A590 form a natural boundary to the development site, hence, the decision not to include MN6, which is within that boundary, does not stand up to scrutiny.
A look at Google earth and Ordanance survey maps of the area and from the information given above, it is obvious that the grounds you have given for excluding MN6 from development are unsound. They do not stand up to scrutiny.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
377. Dr John Hodkinson (Individual) : 25 Apr 2012 12:26:00
Policy/Site No.
LA1.1 Development Boundaries- GREAT AND LITTLE URSWICK
If you have selected a ‘Site omission’ please enter the site reference or location and relevant policy below
Settlement development boundary change omission
Great Urswick settlement development boundary. SLDC ref. ON15
Policy LA1.1 - Development Boundaries - Great Urswick
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
You have already received several communications concerning the proposed development boundaries of the bordering land adjacent to Urswick Tarn ,Great Urswick .As you are aware the Tarn and its shore are the property of the Crown and are part of common land rights of the Parishioners .It has always been the nesting ground of swans , coots and other wildlife . Although several developments in the 1950-1960 's are present all of the recent proposals for building on land to the north tarn between Church view road and the tarn shore have been turned down and local opposition has been supported at appeal by the Secretary of State For the Environment.
It is clear from your proposed development boundaries that these previous actions have been ignored and you are including the above mentioned land within the development category of the proposed Framework thus ignoring the local issue of public amenity and the loss of visual access to Urswick Tarn by the Local Population.
The SLDC policy of not allowing new developments on the Tarn Shore was eroded by the granting of Planning Proposals for the Coot Development against total local opposition . This does not have to set a precedent for the decline of environmental standards and I would strongly advise that the boundaries be revised to exclude the existing tarn shore properties and bring the boundary perimeter to the road rather than the Tarn shore .Failure to do so will ultimately lead to great expense in that every new proposal will be met by strong local opposition.
378. Mr Paul A. Holland (Individual) : 12 Apr 2012 12:27:00
Policy/Site No.
LA1.3 Housing Allocations - All Grange-over-Sands sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Obviously I must object to the proposed development in and around Grange-over-Sands. Anyone in his right senses would as it will change the whole character of the area. I would like to ask two basic questions:
1. What is affordable?
2. Who are they for?
Any work in Grange seems to be taken up by foreign immigrants, not by local youngsters. Will we therefore have to bring people in from other areas?
The council tax in Grange is the highest in the area. Will it be reduced once Grange ceases to be a desirable place in which to live in and retire to?
379. Mr Paul A. Holland (Individual) : 12 Apr 2012 12:29:00
Policy/Site No.
LA3.1 Mixed Use Allocation at Berners Pool, Grange-over-Sands
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Obviously I must object to the proposed development in and around Grange-over-Sands. Anyone in his right senses would as it will change the whole character of the area. I would like to ask two basic questions:
1. What is affordable?
2. Who are they for?
Any work in Grange seems to be taken up by foreign immigrants, not by local youngsters. Will we therefore have to bring people in from other areas?
The council tax in Grange is the highest in the area. Will it be reduced once Grange ceases to be a desirable place in which to live in and retire to?
380. Mr Paul A. Holland (Individual) : 12 Apr 2012 12:31:00
Policy/Site No.
LA3.2 Mixed Use Allocation at Land South of Allithwaite Road, Kent's Bank, Grange-over-Sands
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Obviously I must object to the proposed development in and around Grange-over-Sands. Anyone in his right senses would as it will change the whole character of the area. I would like to ask two basic questions:
1. What is affordable?
2. Who are they for?
Any work in Grange seems to be taken up by foreign immigrants, not by local youngsters. Will we therefore have to bring people in from other areas?
The council tax in Grange is the highest in the area. Will it be reduced once Grange ceases to be a desirable place in which to live in and retire to?
381. Mr Paul A. Holland (Individual) : 12 Apr 2012 12:33:00
Policy/Site No.
LA3.3 Mixed Use Allocation at Guide's Lot, Grange-over-Sands
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Obviously I must object to the proposed development in and around Grange-over-Sands. Anyone in his right senses would as it will change the whole character of the area. I would like to ask two basic questions:
1. What is affordable?
2. Who are they for?
Any work in Grange seems to be taken up by foreign immigrants, not by local youngsters. Will we therefore have to bring people in from other areas?
The council tax in Grange is the highest in the area. Will it be reduced once Grange ceases to be a desirable place in which to live in and retire to?
382. Mrs Jennifer Holland (Individual) : 12 Apr 2012 14:31:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - RN121M-mod LEVENS FORMER POULTRY SHEDS, BRIGSTEER ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not been prepared in accordance with the Town & County Planning Regulations 2004 (as amended)
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I strongly oppose the development of this site. House Building in this particular area is totally inappropriate. The access to the development is along narrow country lanes from all directions, which already creates problems for traffic where the road is only one car's width. This site is situated away from the main village and bordering the National Park and would be stand out right across the Lyth Valley.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The proposed site is on the top side of a steep sloping site in a heavily wooded area.
The extra traffic generated through the centre of Levens village would cause more congestion.
The high density of the proposed development would be totally out of keeping to the area.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
383. Mr & Mrs David & Val Holland (Individual) : 22 May 2012 13:42:00
Policy/Site No.
LA1.3 Housing Allocations - All Burton-in-Kendal sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Response by Mrs V Holland
I wish to voice my concerns regarding the Land Allocations Development Plan for
Burton-in-Kendal
I consider the suggestion that there should be another 146 dwellings built to be more
than excessive.
In fact I do not think that it is necessary for any more to be built as it has been stated in
the past that Burton is unsnstainable .
We have lost yet another shop and it is now a round trip of I 0 miles to the nearest
Chemist, Bank, Butchers and Supermarket
This number of houses would also exacerbate the parking problems at school start and
finish times. I have on one occasion counted in excess of 40 cars parked in and around
the school area. More houses would mean more cars at that time. It is an accident just
waiting to happen. Also would the school have to be extended yet again to make room
for more pupils.
There is a lot of discussion regarding affordable houses. If these are urgently needed I
cannot understand why some enterprising builder has not purchased the Royal Hotel site
to build there.
Perhaps it is because you could presume that the people who could afford these houses
cannot afford the ever rising fuel costs to get to work in places such as Lancaster and
Kendal.
Also with the Lib Dems planning to remove free parking on the New Road in Kendal
there is even less incentive to live out of the working area.
There is only one bns per hour but the times are not compatible to working hours yet
another reason why it makes travelling to work difficult from the outlying villages.
I would urge the SLDC to reconsider and leave our village as a village and not allow it
to become one third larger.
384. Mr & Mrs David & Val Holland (Individual) : 22 May 2012 13:46:00
Policy/Site No.
LA1.3 Housing Allocations - R76M BURTON-in-KENDAL EAST OF HUTTON CLOSE
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Response by Mr D Holland
I wish to record my objections to the SOUTH LAKELAND LOCAL DEVELOPMENT FRAMEWORK,
LAND ALLOCATIONS DEVELOPMENT PLAND DOCUMENT (DPD).
INCORPORATING PROPOSED CHANGES TO THE PROPOSALS MAP PROPOSED SUBMISSION
DOCUMENTS.
Nothing has changed since I sent my letter of objection on the llth April20ll re outline
planning of the land Ret; R76M {part ofR76) I therefore object the above on the following
grounds;
l. The land lies outside the area of the present Local Plan.
2. A government 'W'hite Paper siated that Burton is not sustainable.
Indicating that the local school and the village amenities are insufficient
3. The gradient onto the main road is steep where the road meets the highway and is
therefore an unsafe access onto a busy road.
4. The land is mairJy surrounded by bungalows and a development of many houses on a
sloping site would create a false urban impression and destroy the feathered approach
from the north. ·
5. After a village collection for the Queen's Jubilee the Parish Council erected a
viewpoint at tl1e entrance to Slape Lane. This viewpoint lias a panorama plaque
showing and naming the mountains, also the village church and its' frontage. If the
development is passed the church would no longer be seen and the viewpoipt made
incorrect.
6. The pedestrian access to the viiiage is toially inadequate. A mother with a pram has to
leave the pavement at certain places and frequently enter onto the road to gain access
to the village.
7. The proposed pedestrian access to the village via the Bridleway is fraught with
danger. Vehicles pass along Vicarage Lane at great speed, many of them huge tractors
and heavy farm machinery.
8. The area is designated as County Landscape and outline planning has been refused as
per reference; SL/2005/1243.
9. Over development will ruin the rural nature of our community and spoil the
landscape. Our local roads, sewerage, drains, parking and other services will not cope
and as for banks and surgeries, there are none.
We me all being urged to help save the planet by reducing our "carbon footprint" but by
ruining our villages with extra housing will only enlarge the footprint as most families will
have to have at least one car for work purposes and many will have two cars also for work,
shopping, school runs etc. A couple living in Burton with both working, one say in Lancaster
and the other one in Kendal, will iravei 200 miles each week just going to and from work
alone.
Is this going to help the planet?
With fuel prices such as they are this is not affordable for the families with low income.
Surely it is better to build houses nearer to the towns so that public transport can be used
instead of cars.
I also concur with the report in the Burton in Kendal Parish Council Quarterly News Letter
Spring2012. See page 2.
The proposed growth of Bumm-in-Kendal village by a tlilrd
runs counter to the policies established in the Core Strategy and
the DPD. The Core Strategy paragraph 2.24 states that:
"Extensions to Local Service Centres will be pursued only when
there is clear local need for development and significant
environmental impacts can be avoided, and once previously
developed land has been utilised. The amount of development
in each of the Local Service Centres will be dependent on the
environmental capacity, ~isting siu, role and infrastructure
provision of the seulement, and supporting identified local need
(utilising the findings of ltlrish Plans and Local Housing
Needs Surveys)."
The proposed developments in Burton-in-Kendal far exceed
any needs identified in the Parish Plan or tile Cumbria Rural
Housing Trust Survey both of which identified a need for a
limited amount of affordable lwusing for local occupancy. The
2004 Housing Needs Survey found a requirement for 12
affordable homes and the 2009 survey found a need for 14
affordable llomes.
TIU! DPD lias been through a lengthy development which has
considered alternative sites but tile plan lias relied on
encouraging demand led development to fitnd affordable
housing need. No alternatives to tl1is tnodel have been seriously
considered for Burton-in-Kendal.
Even allowing for this development model, an indicative figure
of 146 new houses, to wllich must be added the 16 houses
whiclt have been given planning permissum aJ tiU! Royal Hotel
site. would result in over 50 affordable /tomes which is far
greater than the measured housing med for the village. The ltlrish
Council suspect that the DPD has been developed on the basis of
how many houses can be built in Burton-in-Kendal to help meet
the District Cou11cil's perceived overallmed, rather than a proper
approach to planning in tile village based on local need as required
by tile Core Strategy.
The ltlrisll Com~eil propose tl1at to meet the measured local
affordable housing tU!ed a phased development of the southern half
of site MN26 supported by limited infilling at smaller sites sr~ell as
already approved at the old Royal Hotel tiJould more tllan meet the
requirement a11d would be more in keeping with the existing scale
atul needs of the village. Importantly, this would mea11 that site
RN226/227 wllicli has very poor access and R76M wlticlt has a
very adverse visual impact, poor access to t/U! village facilities and
is strongly opposed by residents, could botlt be removed from the
plan.
385. Mrs Kathryn Hooker (Individual) : 27 Apr 2012 13:53:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - R121M-mod KENDAL EAST OF CASTLE GREEN ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The Land Allocations Document (DPD) is not within the Local Development Scheme and the key stages have not been followed
The DPD has not had regard to the Sustainable Community Strategy
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I am writing to object to the allocation of land for housing between Castle Green Road and
Sedbergh Road in the Land Allocations Development Plan Document (DPD).
In my view the allocation of this land for housing means that South Lakeland District
Councils' Land allocation is not legally compliant. This is because it goes against the
Core Strategy. It is noted that the South Lakeland Local Development Framework- Core
Strategy Preferred Options in suggesting possible 'alternative directions of growth for
Kendal' figure 20 did not identify the Castle Green Lane/Sedbergh Road area as a
potential area for expansion.
Further Core Strategy Policy CS8.2 (Protection and Enhancement of Landscape and
Settlement Character) states that proposals for development should be informed by, and
be sympathetic to, the distinctive character landscape types identified in relevant
settlement studies and local evidence, and should demonstrate that their location, scale,
design and materials will protect, conserve and, where possible, enhance the special
qualities and local distinctiveness of the area ... Site R121M-Mod is a visually prominent
site, and can be seen from western parts of Kendal, such as Queens Road. The site
strongly contributes to the landscape setting of the town. As such any development of this
site will undermine the landscape character of the area. Fundamentally, highway access
to this site has yet to be considered and agreed. Access from Castle Green Lane and any
associated traffic management scheme (likely to be traffic lights or mini roundabout on the
junction or similar), will lead to degradation of the visual amenity of the area. Specifically
the rural feel and transition from the town to countryside associated with this part of Kendal
will be lost. Access from Oak Tree Road would not be appropriate because of the width,
and steep access of the road from Castle Green Lane. It is noted that the Core Strategy
did, however, identify other much less visible locations around the edge of the town, as
possible areas for expansion.
In my view the DPD is not sound because it is not founded on a robust and credible
evidence base and/or is not considered the most appropriate strategy when considered
against the reasonable alternatives. Kendal Town Council commissioned Galpin
Landscape Architects to undertake a Kendal Local Level Landscape Character
Assessment ("LCA"). The LCA defines the character and potential significance of the
open spaces being promoted through the DPD on the basis of their "functionality". The
LCA concludes that this site, R 121M - Mod, is of medium/high sensitivity due to its
biodiversity and rural environment, and that it has limited scope for development. I am
dismayed that SLOG have chosen to ignore the findings of the Gilpin report in putting
together the DPD, and I am not aware of SLOG having undertaken any detailed landscape
assessment themselves. The lack of a detailed landscape assessment is contrary to
SLOG's own Core Strategy policy CS8.2.
This site was taken out of the last Local Plan, in 1997, on landscape grounds. It was also
considered by the County's Landscape and Countryside Officer, in 2000, as being of
similar character to land adjacent within the County landscape character designation, and
suggested that this land in question should be included within this designation. Whilst this
is some time ago, the demand for housing has increased, but the site has not changed in
character, and its importance in landscape terms to the visual envelope of Kendal has not
diminished.
Development of R121M- Mod will cause a great deal of landscape harm which is not
outweighed by the need for development of this site. As such Site R 121M-Mod should be
taken out of the DPD. Due weight needs to be given to maintaining the environmental
quality, particularly the landscape character of the town, as it is this that makes Kendal
such a special and attractive place to live and work, and upon which its continued
economic prosperity depends.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
386. Mrs Kathryn Hooker (Individual) : 27 Apr 2012 13:56:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA2.3 Land East of Castle Green Road
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The Land Allocations Document (DPD) is not within the Local Development Scheme and the key stages have not been followed
The DPD has not had regard to the Sustainable Community Strategy
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I am writing to object to the allocation of land for housing between Castle Green Road and
Sedbergh Road in the Land Allocations Development Plan Document (DPD).
In my view the allocation of this land for housing means that South Lakeland District
Councils' Land allocation is not legally compliant. This is because it goes against the
Core Strategy. It is noted that the South Lakeland Local Development Framework- Core
Strategy Preferred Options in suggesting possible 'alternative directions of growth for
Kendal' figure 20 did not identify the Castle Green Lane/Sedbergh Road area as a
potential area for expansion.
Further Core Strategy Policy CS8.2 (Protection and Enhancement of Landscape and
Settlement Character) states that proposals for development should be informed by, and
be sympathetic to, the distinctive character landscape types identified in relevant
settlement studies and local evidence, and should demonstrate that their location, scale,
design and materials will protect, conserve and, where possible, enhance the special
qualities and local distinctiveness of the area ... Site R121M-Mod is a visually prominent
site, and can be seen from western parts of Kendal, such as Queens Road. The site
strongly contributes to the landscape setting of the town. As such any development of this
site will undermine the landscape character of the area. Fundamentally, highway access
to this site has yet to be considered and agreed. Access from Castle Green Lane and any
associated traffic management scheme (likely to be traffic lights or mini roundabout on the
junction or similar), will lead to degradation of the visual amenity of the area. Specifically
the rural feel and transition from the town to countryside associated with this part of Kendal
will be lost. Access from Oak Tree Road would not be appropriate because of the width,
and steep access of the road from Castle Green Lane. It is noted that the Core Strategy
did, however, identify other much less visible locations around the edge of the town, as
possible areas for expansion.
In my view the DPD is not sound because it is not founded on a robust and credible
evidence base and/or is not considered the most appropriate strategy when considered
against the reasonable alternatives. Kendal Town Council commissioned Galpin
Landscape Architects to undertake a Kendal Local Level Landscape Character
Assessment ("LCA"). The LCA defines the character and potential significance of the
open spaces being promoted through the DPD on the basis of their "functionality". The
LCA concludes that this site, R 121M - Mod, is of medium/high sensitivity due to its
biodiversity and rural environment, and that it has limited scope for development. I am
dismayed that SLOG have chosen to ignore the findings of the Gilpin report in putting
together the DPD, and I am not aware of SLOG having undertaken any detailed landscape
assessment themselves. The lack of a detailed landscape assessment is contrary to
SLOG's own Core Strategy policy CS8.2.
This site was taken out of the last Local Plan, in 1997, on landscape grounds. It was also
considered by the County's Landscape and Countryside Officer, in 2000, as being of
similar character to land adjacent within the County landscape character designation, and
suggested that this land in question should be included within this designation. Whilst this
is some time ago, the demand for housing has increased, but the site has not changed in
character, and its importance in landscape terms to the visual envelope of Kendal has not
diminished.
Development of R121M- Mod will cause a great deal of landscape harm which is not
outweighed by the need for development of this site. As such Site R 121M-Mod should be
taken out of the DPD. Due weight needs to be given to maintaining the environmental
quality, particularly the landscape character of the town, as it is this that makes Kendal
such a special and attractive place to live and work, and upon which its continued
economic prosperity depends.
387. Mr & Mrs Brian & Heather Hornby (Individual) : 26 Apr 2012 16:17:00
Policy/Site No.
LA1.3 Housing Allocations - M41KM KENDAL SOUTH OF LUMLEY ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Loss of green field space is detrimental to the character and heritage of the area. This is contrary to Coalition Government Sustainable Development Policy, which recognizes brown field preference above important countryside areas. The Soundness and legality of the plan is therefore challenged as being contrary to Government Planning Policy.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I wish to object to and challenge the soundness of proposed land allocation for development – to south of Lumley Rd. (M41KM) and Scroggs Wood Light Industrial Site (E4M) on the following grounds:
- The proposed developments would spoil the initial impression to Kendal visitors, being on the main access route and adjacent to the Town boundary. The Lumley road site is steeply graded and properties would impose on the existing view for Kendal visitors. The line of trees acts as a natural barrier between countryside and properties. Building to the South of this line (E4M), would fundamentally change the Kendal “Gateway to the Lakes” character as a valued landscape. This is contrary to the adopted planning Core Strategy. The Soundness of the plan is therefore challenged on visual impact grounds, contrary to planning policy.
- Loss of green field space is detrimental to the character and heritage of the area. This is contrary to Coalition Government Sustainable Development Policy, which recognizes brown field preference above important countryside areas. The Soundness and legality of the plan is therefore challenged as being contrary to Government Planning Policy.
- Milnthorpe road already backs up to the bypass at peak times and cannot accommodate the massive increase that such development, in these locations, would create. Kendal town development to attract visitors is pointless if they cannot obtain satisfactory access. The associated pollution from stationary traffic is incompatible with sustainable development objectives. The soundness of the development is challenged on the basis that there is no traffic plan to address these issues.
- The A6 is a crucial access for emergency services, particularly following the downgrading of Westmorland General Hospital. Further congestion on this route would introduce undue risk. The potential for accidents when joining the main road would also be significantly increased. The Soundness of the plan is therefore challenged on safety grounds.
- The soundness of the development is challenged on the basis that there is inadequate local infrastructure including drainage, sewerage and roads.
- The proposed development is incompatible with the character of the historic Helsington development contrary to planning policy. The Soundness of the plan is therefore challenged as being detrimental to the historical character of the area.
- The site is clearly NOT “in an accessible location or an easily developable level site” (Achievability statement P133 2 C). The Soundness of the plan is therefore challenged as being contrary to this declared planning statement.
- There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of adequate existing residential space and more suitable alternative development sites.
- The Development plan should retain the "Kendal Gateway to the Lakes" image supporting tourism and established Cumbrian employment, not destroy it with unsightly, unnecessary development and traffic jams. You don’t put your wheelie bin on your front door step! The DPD appears to have completely disregarded the massive opposition and valid objections previously made. The soundness of this planned development is challenged as disregarding local opinion contrary to Government Policy.
388. Mr & Mrs Brian & Heather Hornby (Individual) : 26 Apr 2012 16:21:00
Policy/Site No.
LA1.6 Strategic Employment Sites - E4M KENDAL LAND AT SCROGGS WOOD, MILNTHORPE ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I wish to object to and challenge the soundness of proposed land allocation for development – to south of Lumley Rd. (M41KM) and Scroggs Wood Light Industrial Site (E4M) on the following grounds:
- The proposed developments would spoil the initial impression to Kendal visitors, being on the main access route and adjacent to the Town boundary. The Lumley road site is steeply graded and properties would impose on the existing view for Kendal visitors. The line of trees acts as a natural barrier between countryside and properties. Building to the South of this line (E4M), would fundamentally change the Kendal “Gateway to the Lakes” character as a valued landscape. This is contrary to the adopted planning Core Strategy. The Soundness of the plan is therefore challenged on visual impact grounds, contrary to planning policy.
- Loss of green field space is detrimental to the character and heritage of the area. This is contrary to Coalition Government Sustainable Development Policy, which recognizes brown field preference above important countryside areas. The Soundness and legality of the plan is therefore challenged as being contrary to Government Planning Policy.
- Milnthorpe road already backs up to the bypass at peak times and cannot accommodate the massive increase that such development, in these locations, would create. Kendal town development to attract visitors is pointless if they cannot obtain satisfactory access. The associated pollution from stationary traffic is incompatible with sustainable development objectives. The soundness of the development is challenged on the basis that there is no traffic plan to address these issues.
- The A6 is a crucial access for emergency services, particularly following the downgrading of Westmorland General Hospital. Further congestion on this route would introduce undue risk. The potential for accidents when joining the main road would also be significantly increased. The Soundness of the plan is therefore challenged on safety grounds.
- The soundness of the development is challenged on the basis that there is inadequate local infrastructure including drainage, sewerage and roads.
- The proposed development is incompatible with the character of the historic Helsington development contrary to planning policy. The Soundness of the plan is therefore challenged as being detrimental to the historical character of the area.
- The site is clearly NOT “in an accessible location or an easily developable level site” (Achievability statement P133 2 C). The Soundness of the plan is therefore challenged as being contrary to this declared planning statement.
- There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of adequate existing residential space and more suitable alternative development sites.
- There is spare capacity and expansion potential on existing established trading estates on Shap Road. The plan to relocate the Rugby club to Oxenholme and development of the Gilkes site are more suited to development than Scroggs Wood. The soundness of the case for such development is challenged on the basis of existing and more suitable alternative development sites compatible with planning policy.
- What and where is the business case and demand for a further speculative light industrial business park? Why would UK businesses move to such a park when financial assistance and tax breaks are available for designated City areas such as the Manchester Enterprise Zone? The soundness of this planned development is challenged on the basis of no established demand or business case.
- The Development plan should retain the "Kendal Gateway to the Lakes" image supporting tourism and established Cumbrian employment, not destroy it with unsightly, unnecessary development and traffic jams. You don’t put your wheelie bin on your front door step! The DPD appears to have completely disregarded the massive opposition and valid objections previously made. The soundness of this planned development is challenged as disregarding local opinion contrary to Government Policy.
389. Mr & Mrs Brian & Heather Hornby (Individual) : 26 Apr 2012 16:22:00
Policy/Site No.
LA1.3 Housing Allocations - All Kendal sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of adequate existing residential space and more suitable alternative development sites.
390. Mr & Mrs Brian & Heather Hornby (Individual) : 26 Apr 2012 16:23:00
Paragraph No.
0.0 Whole Document
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Is there a definition of “affordable housing” in the context of Kendal young person income? Or is this merely a rouse to allow land owners and builders to make massive profits, without any tangible commitment to house the low paid of Kendal? The Soundness is therefore challenged on the basis of no defined affordability test.
391. Mr & Mrs Brian & Heather Hornby (Individual) : 26 Apr 2012 16:25:00
Policy/Site No.
LA1.4 - Kendal Sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of adequate existing residential space and more suitable alternative development sites.
392. Mrs Debra Horrocks (Individual) : 15 Apr 2012 12:16:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - M9M2-mod MILNTHORPE NORTH WEST OF MILNTHORPE
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Consideration of the increased level of traffic has to be taken into account. Currently the small road of Grisleymires Lane is used by residents of Dallam Chase and employees of the coachworks, and in the near future will be used for Booths deliveries and future commercial/retail units. Currently, this road would be insubstantial to accommodate the traffic to and from the proposed housing allocations. This part of Milnthorpe is already over-developed with the building of the new Booths supermarket, proposed parking areas and the retail/commercial units planned. The plan for 85 houses on this allocated site appears disproportionate to the size of land available,and being situated on an elevated site would have a negative impact on a unique & beautiful village landscape. This planned increase in development would also ensure a decline in the habitat of wildlife in an area already in abundance of estuary/marshland birds, field mice,bats and hedgehogs.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
393. Mrs Carol Houghton (Individual) : 30 Mar 2012 10:41:00
Policy/Site No.
LA1.3 Housing Allocations - All Burton-in-Kendal sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Proposed LDF for Burton
With reference to a leaflet I received recently outlining the proposed building development in Burton-in-Kendal I wish to submit the following comments. I have lived in Burton for 45 years and have seen it grow in that time quite considerably. However I feel the village at the moment, whilst it has had a steady increase in houses, just about copes with the infrastructure as it stands. I feel, however, that a development of 146 houses in this small village would completely alter and change things.
I. The drainage and sewerage would be insufficient under the additional strain. It is already subject to numerous Dyno-rod/drainage type call outs.
2. The main road through Burton barely copes with the volume of traffic through its narrow main road. Indeed, when the M6 is blocked (and we have had many occasions of this type), the diverted traffic through Burton Main Street is thoroughly unacceptable and dangerous to existing residents. At certain times of the day, maybe 6-8 cars park along the Main Street in a particularly narrow part and it allows only one car through, so its necessary to wait at the end of the line of cars until the traffic has passed through.
3. Pavements are very narrow, particularly in the centre of the village where traffic still travels far too fast, so a development of the number of houses proposed would pose an even greater risk for extra pedestrians especially incoming schoolchildren. Already parents have to accompany their children to the school as pavements are not a feature in many parts of Main Street.
4. Burton Morewood Primary School and QES in Kirkby Lonsdale are both excellent schools but are already fully subscribed.
5. There is only one combined general shop/newsagent!post office which is in a particularly difficult pedestrian location, a blind comer. Some cars park outside the shop causing a hazard to other drivers. There is one butchers shop also in a bad location as meat delivery vans park outside the shop causing congestion. Surely the houses that are planned can only make matters worse, particularly around 9arn and 3pm when the village is full of cars dropping off and picking up children from school. Perhaps some building is necessary, but the volume proposed is far too extensive for the area and alternative sites should be considered for all the reasons I have stated.
394. Mr & Mrs JT & DM Howard (Individual) : 23 Apr 2012 10:00:00
Policy/Site No.
LA1.3 Housing Allocations - R121M-mod KENDAL EAST OF CASTLE GREEN ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Subject: Invitation to m!tke representations on the SLDC Land Allocations DPD
proposed submission documents. Ref: R121M (Land behind Rowan Tree Crescent and
Oak Tree Road)
Thank you for the opportunity to offer feedback on the DPD. I have chosen to address
my concerns in a personal letter to the inspector rather than complete the designated
form, which I fmd rather restrictive. Also, I have some concerns that of the (hopefully
many) people who do complete the form a summary will be drafted for the inspector,
which may not incorporate the true strength of feeling against the planned development.
I will try to be succinct and express my views in layman's terms rather than refer to the
many and detailed documents that have been prepared by others. Hence the bullet point
format:
• The most important issue in any project is clarity of objective. This has not been
clearly articulated. Is the objective to provide low cost housing for local residents or
to bUild executive homes for those who can afford to buy them? ;The proposed
development is on prime land and the houses will not be built and sold cost
effectively for local residents. Is the objective to build houses to attract high-salaried
incomers?
• Flood prevention is a potential problem. My understanding is that the stock beck
scheme is at full capacity and there is no assurance that additional building will not
have an adverse effect.
• There are to my knowledge 51 houses on Oak Tree Road. This area appears to be
about the same size as the planned development of 60 houses. This would indicate
that even at the reduced proposal of 60 houses the area would be over developed.
How many houses of the 60 will be low cost housing, and what guarantee is there,
that after project approval the number of low cost houses will not be reduced by the
builder.
Will any of the houses be subject to 'Local Occupancy Clauses' to enable young
couples in Kendal to get onto the housing ladder.
Access to the proposed development will be difficult to achieve without traffic
congestion and noise pollution. If traffic is fed through Orchard Road there will be
real safety issues as the road is hardly wide enough for two cars to pass at present.
The proposed development is not sustainable. People occupying low cost housing
need public transport and local facilities much closer to their doorstep.
The proposed development is on prime, Greenfield land rising above Kendal town. It
will impact adversely in a visual sense on the whole surrounding community.
Wildlife and in particular the great Crested Newt need their ponds and habitats to
survive and the experts appear to believe this proposed development will destroy their habitat
395. Mr & Mrs JT & DM Howard (Individual) : 23 Apr 2012 10:03:00
Paragraph No.
1.10
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
SLDC appear to have acted arbitrarily in dismissing and/or not considering the views
of the Town Council, the Friends of the Lake District or the independent Landscape
Character Assessment.
• SLDC disregard objections from residents who are affected by the developments.
Can this be true? If so, this suggests that SLDC considers that local residents are
driven by 'nimbyism'. This would be a cynical and wrong view. It is the local
residents who understand most of all the consequences of any development. Their
views through the (SOLEK) Save our landscape East Kendal forum should be
listened to.
To sum up the above points, I would say that to date SLDC has failed in clarity of
objectives, engaging the community, making evidence based decisions, ignoring expert
opinion and in integrating the proposed development into strategic policies that benefit
our community.
396. H, C, J L & A Howson (Individual) : 27 Apr 2012 13:47:00
Policy/Site No.
LA1.3 Housing Allocations - R121M-mod KENDAL EAST OF CASTLE GREEN ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I wish to register my objections to the council's proposals for residential development of the above parcel of land which I consider to be unsound based on the level and quality of work undertaken to establish its suitability.
• At the public meeting on 3 March 2011 it was clear from the comments of SLDC
Development Strategy Manager that very little detailed preparation had been carried out into the suitability the site. In answer to virtually every concern his reply was 'We've looked into this and don't see it as a problem'. No detailed or factual explanations were offered and it appeared that any green space was considered suitable and issues would be tackled as they arose.
• In 1997 a Planning Inspector rejected an appeal to develop R56 and in 2006 SLDC Local plan stating that 'development of higher hillsides further east (of R56) would be unduly prominent' (Section 6.3 Visual Amenity) but this time has chosen to ignore these findings without explanation.
Nothing has changed with the sites to make them less prominent.
• In recent years we have seen an increase in the amount and severity of rainfall in the area
and to allow any building on the land between Sedbergh Rd and Castle Green Lane (R121M) would increase the risk of flooding in the whole area (including the effectiveness of the Stock Beck flood alleviation scheme) by reducing the amount of natural surface run off. Rainfall predictions for the next 70 years or so show a marked increase. For the council to ignore these facts figures again demonstrates the unreliability of the proposals.
• I am also concerned about the failure of the council to carry out any feasibility studies into
the issue of flooding. In recent years we have experienced severe flooding of the lower part of our garden from the two streams which flow through the field immediately behind our home in field R56. One of the streams flows through R121M into a culvert which runs along the back of houses on Oak Tree Road, through the corner of our garden and discharges into R56. The council is aware of the problems we have experienced.
The preferred access to the site is from the junction of Castle Green Lane and Oak Tree
Road. Oak Tree Road rises immediately and has a blind bend within a few yards of the junction and, as the road progresses it narrows and there is much on street parking. Cumbria County Council has yet to survey the road and SLDC clearly does not see any potential safety issues nor has concerns with increased pollution.
• SLDC in agreement with Kendal Town Council commissioned an independent Landscape Character Assessment (Galpin) to be carried out but SLDC refused to accept the findings which found that of the 19 possible development sites in Kendal R121M was most sensitive in landscape terms and with low capacity for development.
• Likewise a similar report from the Friends of the Lake District was also not accepted.
• SLDC will not consider objections from residents who are affected by proposed
developments- so much for community involvement. Local people's concerns are just a valid as anybody else's including those of land owners and developers. Approximately 400 residents were against the development yet there were only two in favour- the owner of the land and a developer.
• An established colony of great crested newts exists in the pond in field R677K and is known to have also established themselves in Oak Tree Road and Rowan Tree Crescent .. Whist I can't claim they have also established themselves in my garden I have found one which proves they are moving away from the pond and could be colonising a much larger area.
I trust my concerns will be passed onto the inspector appointed to review Land Allocations
397. Mr Philip Hoyle (Individual) : 26 Apr 2012 11:09:00
Paragraph No.
1.10
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
We wrote to you by email on 7 April (copy attached) to put forward our objections to the
above proposals. We have received no response and can find no material change in
formulating.the Land Allocation Proposals for the South of Kendal to be submitted for
Inspection as shown under the above plan references. As far as we can see, our
objections, which we know are shared by numerous local residents, have been set
aside and not heeded in carrying out the 'consultation' exercise.
It is our understanding that, under the revised planning regulations recently published,
the views of local residents should to be fully taken into account in determining planning
strategy. As local residents, we have had great difficulty in finding anyone to whom we
have spoken in Kendal who supports South Lakeland District Council's current Land
Allocations policy for the town -we venture to guess that the number and strength of
the objections received by the Council similarly demonstrates a lack of local support.
In our view, the only sound way in which the Council can satisfy itself that it has fully
taken into account the views of local residents is by means of a referendum. In the
absence of such an exercise, and given the level of objections and general disquiet, in
our view the proposals are fundamentally unsound.
Together with a number of other residents Iwrote to you some short time ago, as part of
the previous 'consultation exercise', to express opposition to the Council's proposals for
the development of the south side of Kendal. I would appear our concerns have been
substantially ignored and the Council appears to be pressing ahead with its original
plans in this regard with little or no change. I am also very surprised that the Council has
chosen to keep to a path which, seemingly, ignores the recommondation of the
independent inspector who ruled against similar development plans for the south side of
Kendal some years ago.
You refer to 'consultations' being undertaken at the present time( However, everyone I
have spoken to in my locality of the town has expressed either concern
and/or opposition to the Council's proposals. I fail to understand how the wishes of the
majority of local residents and council taxpayers can be properly taken into account and
respected in the absence any plan to hold an inclusive local plebiscite. Indeed, I can
find no proposals for conducting such an exercise. Wrthout a clear expression of
views in favour of these proposals from the people of Kendal, I am opposed to you
proposals and strongly object to their imposition.
398. Mr Philip Hoyle (Individual) : 26 Apr 2012 11:17:00
Policy/Site No.
LA1.3 Housing Allocations - M41KM KENDAL SOUTH OF LUMLEY ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
We share the generally expressed view that.SLDC has failed toplace sufficient
emphasis on the development ofbrown field and other. more suitable land in the town in
preference to .unspoiled green field sites, especially those set beyond the historic .
boundaries of the town.
We will try to be brief as we can in stating our strong objections to the Land Allocations
Policy for the South of Kendal:
• Detrimental Visual Impact on the Southern Approach to the Town
The pleasing visual appearance of the southern approach to Kendal affirms the
qualities and amenities that it provides as an historic, pleasant market town of
character. This is of great importance in maintaining the town's attraction to
tourists (the foremost industry in Lakeland) and also to suitable prospective new
employers. (This view was, as we understand it, upheld in 1996 when plans for
the development of the land in question were rejected by the Independent
Inspector appointed at that time to review the proposals).
It is, we suggest, incumbent upon SLDC to explain why this ruling is no longer
valid. In our view, the Council has failed to do so and, in this respect, the present
proposals are unsound ..
Short Term ism Preferred to Sound Strategic Planning
Provision for business growth is currently concentrated in the business parks and
areas in the area of Shap Road where there is room for expansion without the
need to designate a green field site. The proposed Land Allocation to the South
of Kendal is green field and situated in a wider area that is, apart from a couple of
hotels and a garage, exclusively residential. In planning terms, a more sound
approach would have been to concentrate on extending the orbital by-pass road
from Plumgarths to Shap Road, thus relieving an over-congested town already
suffering from poor access and unacceptable levels of air pollution, especially in
Lowther Street at the centre (SLDC should be able to provide the data in support
this conclusion).
It would appear that in selecting the southern side of Kendal for concentrated
housing and commercial development, SLDC may have been influenced by short
term cost implications and expediency, rather than sound strategic long term
planning considerations.
Detrimental Effect of Poor Traffic Management Proposals
Residents to the south of Kendal already suffer as a consequence of difficult and
potentially dangerous traffic flows on the main Milnthorpe Road entering and
leaving the town. Mobile safety cameras are regularly sited in this area in
recognition of a growing and concerning problem. With the increasing frequency
and prolonged nature of the traffic queues, the build up (particularly a peak
commuting times) often stretches back to the A591 dual carriageway, thus
heightening safety concerns. When the near side of the main road is congested
and the other far side is less so, cars from adjoining roads can only gain access
to the far side with the consideration of other motorists already on the main road.
However, upon moving forward across the main road, the site lines of the joining
motorists are impaired -the dangers are self-evident and the subject of
increasing concern.
The proposals to enable further intense development, without any clear traffic
impact and management plan to provide safe access and relieve an already
congested main road are unsound and should not be approved.
In summary, we consider the current Land Allocations Proposals to be
unsound for the reasons explained above. We object to the proposals and
request that our objections be put before the Inspector to be appointed to
review their soundness.
Much more care should be taken, in my view, to respect the integrity of existing
residential areas so as to retain their existing character and to avoid an unsuitable mix
of high density residences and/or commercial development. In addition, the southern
approach to the town is one of its most attractive features and the plans to develop the
area between Lumley Road and Hellsington Laithes, in the manner proposed, would
have a deleterious effect on the amenities for all the reasons explained later in this
email
Turning now to my specific objections to the proposals to develop the south side of Kendal,
these can be state as follows:
• the currently attractiveness of the southern approach to Kedal will not be enhanced
by the Council's proposals, rather it will be rendered less attractive, house values will
diminish, and this will lead to less people choosing Kendal as their location of choice
• the mix of commercial property, and inclusion of high density housing, will have a
particularly deleterious effect on the area and its existing residents
• the rising elevation of the site will contribute the unsuitability of development with the
new buildings overlooking existing properties
1 • the traffic flow into Kendal along Milnthorpe road is already:congested, especially at
commuting times, and the proposed development will exacerbate an already difficult
and dangerous situation
I intend to monitor further announcements by the Council closely\ and with a great deal of
concern. I trust, on further consideration, the present proposal to develop the south side of
Kendal will either be abandoned or substantially amended to take account fully the
concerns and objections of a great many of the residents of the town, including those of
myself and my wife as expressed in this email.
399. Mr Philip Hoyle (Individual) : 26 Apr 2012 11:26:00
Policy/Site No.
LA1.6 Strategic Employment Sites - E4M KENDAL LAND AT SCROGGS WOOD, MILNTHORPE ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
We share the generally expressed view that.SLDC has failed toplace sufficient
emphasis on the development ofbrown field and other. more suitable land in the town in
preference to .unspoiled green field sites, especially those set beyond the historic .
boundaries of the town.
We will try to be brief as we can in stating our strong objections to the Land Allocations
Policy for the South of Kendal:
• Detrimental Visual Impact on the Southern Approach to the Town
The pleasing visual appearance of the southern approach to Kendal affirms the
qualities and amenities that it provides as an historic, pleasant market town of
character. This is of great importance in maintaining the town's attraction to
tourists (the foremost industry in Lakeland) and also to suitable prospective new
employers. (This view was, as we understand it, upheld in 1996 when plans for
the development of the land in question were rejected by the Independent
Inspector appointed at that time to review the proposals).
It is, we suggest, incumbent upon SLDC to explain why this ruling is no longer
valid. In our view, the Council has failed to do so and, in this respect, the present
proposals are unsound ..
Short Term ism Preferred to Sound Strategic Planning
Provision for business growth is currently concentrated in the business parks and
areas in the area of Shap Road where there is room for expansion without the
need to designate a green field site. The proposed Land Allocation to the South
of Kendal is green field and situated in a wider area that is, apart from a couple of
hotels and a garage, exclusively residential. In planning terms, a more sound
approach would have been to concentrate on extending the orbital by-pass road
from Plumgarths to Shap Road, thus relieving an over-congested town already
suffering from poor access and unacceptable levels of air pollution, especially in
Lowther Street at the centre (SLDC should be able to provide the data in support
this conclusion).
It would appear that in selecting the southern side of Kendal for concentrated
housing and commercial development, SLDC may have been influenced by short
term cost implications and expediency, rather than sound strategic long term
planning considerations.
Detrimental Effect of Poor Traffic Management Proposals
Residents to the south of Kendal already suffer as a consequence of difficult and
potentially dangerous traffic flows on the main Milnthorpe Road entering and
leaving the town. Mobile safety cameras are regularly sited in this area in
recognition of a growing and concerning problem. With the increasing frequency
and prolonged nature of the traffic queues, the build up (particularly a peak
commuting times) often stretches back to the A591 dual carriageway, thus
heightening safety concerns. When the near side of the main road is congested
and the other far side is less so, cars from adjoining roads can only gain access
to the far side with the consideration of other motorists already on the main road.
However, upon moving forward across the main road, the site lines of the joining
motorists are impaired -the dangers are self-evident and the subject of
increasing concern.
The proposals to enable further intense development, without any clear traffic
impact and management plan to provide safe access and relieve an already
congested main road are unsound and should not be approved.
In summary, we consider the current Land Allocations Proposals to be
unsound for the reasons explained above. We object to the proposals and
request that our objections be put before the Inspector to be appointed to
review their soundness.
Let me say, at the outset, that I have the greatest misgivings in regard to these
proposals which, as it seems to me, have the capacity to change the unique 'Character
of Kendal for the worse and to impact adversely on the attractiveness of the town to
those of us who live here now and others who may wish to consider living in the town in
thefuture.
Much more care should be taken, in my view, to respect the integrity of existing
residential areas so as to retain their existing character and to avoid an unsuitable mix
of high density residences and/or commercial development. In addition, the southern
approach to the town is one of its most attractive features and the plans to develop the
area between Lumley Road and Hellsington Laithes, in the manner proposed, would
have a deleterious effect on the amenities for all the reasons explained later in this
email.
Strategically, the response, for a town such as Kendal, to additioal land allocation should, I believe, firstly, to ensure additional land for commercial development is located
in areas where such development already exists and secondly, to ensure residential
development is not mixed unnecessary with commercial development and thirdly, to ensure
residential development is in keeping and harmony with existing housing stock. These
principles do not appear to have been adopted and followed in the current proposals.
Turning now to my specific objections to the proposals to develop the south side of Kendal,
these can be state as follows:
• the currently attractiveness of the southern approach to Kedal will not be enhanced
by the Council's proposals, rather it will be rendered less attractive, house values will
diminish, and this will lead to less people choosing Kendal as their location of choice
• the mix of commercial property, and inclusion of high density housing, will have a
particularly deleterious effect on the area and its existing residents
• the rising elevation of the site will contribute the unsuitability of development with the
new buildings overlooking existing properties
1 • the traffic flow into Kendal along Milnthorpe road is already:congested, especially at
commuting times, and the proposed development will exacerbate an already difficult
and dangerous situation
I intend to monitor further announcements by the Council closely\ and with a great deal of
concern. I trust, on further consideration, the present proposal to develop the south side of
Kendal will either be abandoned or substantially amended to take account fully the
concerns and objections of a great many of the residents of the town, including those of
myself and my wife as expressed in this email.
400. Mr Philip Hoyle (Individual) : 26 Apr 2012 11:31:00
Policy/Site No.
LA1.3 Housing Allocations - All Kendal sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Let me say, at the outset, that I have the greatest misgivings in regard to these
proposals which, as it seems to me, have the capacity to change the unique 'Character
of Kendal for the worse and to impact adversely on the attractiveness of the town to
those of us who live here now and others who may wish to consider living in the town in
thefuture.
Much more care should be taken, in my view, to respect the integrity of existing
residential areas so as to retain their existing character and to avoid an unsuitable mix
of high density residences and/or commercial development. In addition, the southern
approach to the town is one of its most attractive features and the plans to develop the
area between Lumley Road and Hellsington Laithes, in the manner proposed, would
have a deleterious effect on the amenities for all the reasons explained later in this
email.
Strategically, the response, for a town such as Kendal, to additional land allocation should, I believe, firstly, to ensure additional land for commercial development is located
in areas where such development already exists and secondly, to ensure residential
development is not mixed unnecessary with commercial development and thirdly, to ensure
residential development is in keeping and harmony with existing housing stock. These
principles do not appear to have been adopted and followed in the current proposals.
401. Mr Philip Hoyle (Individual) : 26 Apr 2012 11:42:00
Policy/Site No.
LA1.7 Business and Science Park Sites - M2M-mod KENDAL LAND EAST OF BURTON ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Let me say, at the outset, that I have the greatest misgivings in regard to these
proposals which, as it seems to me, have the capacity to change the unique 'Character
of Kendal for the worse and to impact adversely on the attractiveness of the town to
those of us who live here now and others who may wish to consider living in the town in
thefuture.
Strategically, the response, for a town such as Kendal, to additioal land allocation should, I believe, firstly, to ensure additional land for commercial development is located
in areas where such development already exists and secondly, to ensure residential
development is not mixed unnecessary with commercial development and thirdly, to ensure
residential development is in keeping and harmony with existing housing stock. These
principles do not appear to have been adopted and followed in the current proposals.
402. Mr Philip Hoyle (Individual) : 26 Apr 2012 11:44:00
Policy/Site No.
LA1.8 Local Employment Sites - All Kendal sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Let me say, at the outset, that I have the greatest misgivings in regard to these
proposals which, as it seems to me, have the capacity to change the unique 'Character
of Kendal for the worse and to impact adversely on the attractiveness of the town to
those of us who live here now and others who may wish to consider living in the town in
thefuture.
Strategically, the response, for a town such as Kendal, to additioal land allocation should, I believe, firstly, to ensure additional land for commercial development is located
in areas where such development already exists and secondly, to ensure residential
development is not mixed unnecessary with commercial development and thirdly, to ensure
residential development is in keeping and harmony with existing housing stock. These
principles do not appear to have been adopted and followed in the current proposals.
403. Mr Philip Hoyle (Individual) : 26 Apr 2012 11:48:00
Paragraph No.
0.0 Whole Document
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I would find it helpful to know when the assumptions in the localldevelopment plan
which inform the proposal for land allocations were formulated. Have these assumptions
been revised and reassessed since the economic events of Octbber 2008 to take
account fully of the much more subdued outlook for growth facing the world economy in
general and the UK economy in particular? The assumptions in regards to housing
demand in the area appear to me to have been overstated in current economic
climate. Moreover, the allocation of land is insufficiently sensitive to the needs and
preferences of existing residents.
404. Mr Philip Hoyle (Individual) : 15 May 2012 12:21:00
Policy/Site No.
LA1.4 Broad Locations for New Housing
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Let me say, at the outset, that I have the greatest misgivings in regard to these proposals which, as it seems to me, have the capacity to change the unique character of Kendal for the worse and to impact adversely on the attractiveness of the town to those of us who live here now and others who may wish to consider living in the town in the future.
Much more care should be taken, in my view, to respect the integrity of existing residential areas so as to retain their existing character and to avoid an unsuitable mix of high density residences and/or commercial development. In addition, the southern approach to the town is one of its most attractive features and the plans to develop the area between Lumley Road and Hellsington Laithes, in the manner proposed, would have a deleterious effect on the amenities for all the reasons explained later in this email.
Strategically, the response, for town such as Kendal, to additional land allocation should, I believe, firstly, to ensure additional land for commercial development is located in areas where such development already exists and secondly, to ensure residential development is not mixed unnecessary with commercial development and thirdly, to ensure residential development is in keeping and harmony with existing housing stock. These principles do not appear to have been adopted and followed in the current proposals.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
405. Mr David Hudson (Individual) : 24 Apr 2012 08:49:00
Policy/Site No.
LA1.3 Housing Allocations - RN152 GREENODD LAND AT THE OLD VICARAGE
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
the land known as church field in penny bridge should not be developed as we have serious problems with the water table here. in heavy rain a river of water runs down penny bridge hill. any development is only likely to make matters worse.
the field is also used by farmers for sheep grazing and dog owners to exercise their pets (when the sheep are not there) loss of this amenity would be detrimental to the village.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
406. Mr David Hudson (Individual) : 24 Apr 2012 08:57:00
Policy/Site No.
LA1.3 Housing Allocations
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I do not believe Penny Bridge needs any new housing, there are already numerous properties on the market that are unsold and have been for some time.
finally, new housing would only exacerbate the sewage issue we have(even with the new treatment works)
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
407. Mr Michael Hughes (Individual) : 11 May 2012 16:00:00
Policy/Site No.
LA1.3 Housing Allocations - RN57M MILNTHORPE ADJ. TO ST ANTHONY'S CLOSE
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I consider the DPD should be scrapped. The community involvement has been a farce. Any representations made to our representatives or Planning Department have been ignored. The forms of involvement so complicated, the average member of the public cannot understand. I have been told that my original objection letter was not acceptable at the time I thought I should submit it. A petition from almost 100% of people affected was returned because it didn't have their printed names on. I therefore submit it again as reasons why St Anthony's Close land should not be included in this DPD.
When the DPD was considered by SLDC voting appeared to take place along party lines and not what the public had asked as reported on their feelings to Council Members
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The land R93 & R79 & M6 should be removed from the DPD because access to extremerly difficult if not impossible without causing road dangers, structure of road problems, parking problems. Destruction of views - the filling in of the area between Milnthorpe and Ackenthwaite (see letter of objection - text provided below):
South Lakeland Local Development Framework
Allocation of Land Development Plan Document
Areas of Land R93, R79, and M6
It has recently come to the notice of the occupiers of all houses on the St. Anthony's
Hill area that three plots of land viz fields R93, R79, and M6 which were not shown
on the Roadshow of Spring 2008, have been added to the Development Plan
Document as possible areas for housing development.
I wish to object to those particular proposals as they are totally unsuitable for
development of any kind for numerous reasons which I give below.
I understand that it is anticipated that in July a formal consultation document will be
published alongside consultation of the next stage of the core strategy.
If these two strategies are published together it will be difficult for the public to
differentiate between them.
The Core Strategy Preferred Option document states that there should be open gaps
which will comprise open areas around, between parts of settlements which maintain
the distinction between countryside and built up areas presenting the merging of
adjacent places (page 14). It envisages green gaps between Milnthorpe and
Ackenthwaite. The inclusion of land R93, R79 goes against this advice.
In addition they protrude into agricultural land and do nothing to retain a regular
boundary around Milnthorpe. The plan also states that development to the North of
Milnthorpe should be limited because of the views of St. Anthony' Tower.
There are no obvious existing approaches to the land and in particular if it envisaged
to use St. Anthony's Hill this will present an extremely dangerous road situation for
the following reasons.
1) The access from the A6 trunk road is already difficult due to continuous heavy
speeding traffic and the considerable limited vision line to drivers getting out of
St. Anthony's Hill.
2) St Anthony's Hill is a very steep hill being approximately 1 in 6 and 1 in 4
gradients.
3) It was not constructed as a through road and is already showing signs of
movement and wear.
4) It is not wide enough to accommodate lorries and large vans passing and
manoeuvring.
5) On entering St. Anthony's Hill from the A6 there is an immediate incline of
1 in 6 for twenty yards then a left hand bend of 90 degrees which is blind. In a
further 100 yards of 1 in 6 is a blind right hand bend on an incline of 1 in 4, this
is already hazardous. In a further 30 yards of a 1 in 6 gradiant is yet another
left hand 90 degrees bend with the additional hazard of an entrance to garages
for 1 to 5 St. Anthony's Close, with lines of view blocked by the garages.
6) The parking area at the head of S. Anthony's Close will be lost adding to an
existing parking problem in the Close.
7) Parking already causes considerable difficulties for any large lorries/vans/
emergency vehicles, an example of which is that the Refuse Lorries consistently
cannot turn, reverse etc. without going onto the pavements.
It is further considered that the views and the surrounding countryside from the end of
St. Anthony's Close is an important visual amenity.
I would also call for the Development Plan Team to consult the Highways Authority,
the Police, The Fire Authority's and Bay National Health Authority on the danger
and access availability for their vehicles and suitability of the existing road structure.
The only other existing access to this land is via Haverflats Lane which not only
dimishes down to one car width but leads traffic to and from Milnthorpe village
centre adding more congestion. This lane is just as hazardous as was highlighted by
past controversy concerning bus access to Dallam School and their eventual rerouting
to another access.
As stated initially I object to these areas of land being included in any development
plans now or in the future.
408. Mr Chris Hunter (Individual) : 12 Apr 2012 18:41:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
0.0 Whole Document
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
The DPD has not had regard to the Sustainable Community Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
SUMMARY
The comments below relate in particular to the Arnside and Silverdale AONB and demonstrate how the DPD is neither legally compliant nor sound with regard to the AONB. Prior to the last round of objections the DPD had no apparent regard for the AONB and it still only pays lip-service to it's protected status. Given the location of the AONB any development beyond affordable housing for villagers cannot in any sense be considered sustainable. The DPD fails to meet the requirements of the NPPF and is in direct contravention of the Council's own core strategy. The Area of OUTSTANDING Natural Beauty needs to be protected, building any of the proposed market housing irrevocably destroys precious green spaces which will never be retrieved.
COMMUNITY INVOLVEMENT
I am aware that several responses by myself and others have not been referenced under community involvement. There is no point in consulting the community if responses are ignored, the document should include a way of tracing community responses through to either amendments in the document or a clear rebuttal.
SUSTAINABILITY
The NPPF section 30 states "Encouragement should be given to solutions which support reductions in greenhouse gas emissions and reduce congestion" and section 95 states "plan for new development in locations and ways which reduce greenhouse gas emissions". Arnside is out-on-a-limb geographically being over 3 miles from the nearest A road, banks and NHS dentist. Building market housing in Arnside simply means more car journeys which means more greenhouse gas emissions. Arnside is designated as an Area of Outstanding Natural Beauty and therefore needs a specific sustainability assessment, it is distinct from much of the surrounding landscape. The DPD should demonstrate that Great Weight has been given to the AONB status as required by the NPPF.
The Sustainability Appraisal Report recognises the need to consider the cumulative effect of the plan under the Strategic Environmental Assessment Directive, however there is no evidence that this has been done across multiple sites in a given area. For specifically protected areas such as the AONB it is essential that a detailed assessment of the cumulative effect of the proposed developments is prepared and used to inform the DPD. This must be coordinated with Lancaster City Council since they have responsibility for the southern part of the AONB. This should also consider the cumulative effects that building now will have on future demand.
NATIONAL POLICY
The NPPF section 115 states "Great weight should be given to conserving landscape and scenic beauty in ... Areas of Outstanding Natural Beauty, which have the highest status of protection". The DPD has not had sufficient regard to this requirement. For example the AONB Landscape assessment states "small pastures backing on to woodland have survived ... in the vicinity of Blackdyke and Redhills. These provide an attractive transition between the built development and the open countryside". The DPD is proposing to build on one of these – site R81. Site R81 also is alongside a popular foot path, the NPPF section 75 states "Planning policies should protect and enhance public rights of way and access". Site R81 should be removed from the DPD. Furthermore site R81 was protected under core strategy policy S4 at the start of this process but seems to have been conveniently removed from the list of sites protected by policy S4 without justification.
Policy CS6.1 in the Adopted Core Strategy 2010 states that sites will be allocated in the Land Allocation DPD using the sequential approach to housing development identified in PPS 3 (now replaced) and Spatial Strategy Policies CS1.1. Policy CS1.1 states that existing buildings will be used first , followed by in fill and finally by other land where this is well located in relation to housing, jobs other services and infrastructure. The DPD fails to demonstrate any adherence to this core strategy.
Policy CS8.2 in the Adopted Core Strategy specifically deals with the AONB Management Plan and Landscape assessment. The proposed developments within the AONB on Greenfield, open spaces within the village clearly does not accord with this Policy.
SUSTAINABLE COMMUNITIIES
The sustainable community strategy talks of “access to services“, "better services for young people", "housing for local need provided in a suitable way" and "Managing our natural resources prudently". The current DPD rides rough-shod over these aims in Arnside. Past experience clearly demonstrates that market housing within the AONB is largely purchased by people who are 50+ and probably retiring to the area, a significant number will be from outwith South Lakes District. The community within the AONB is already heavily skewed towards the elderly and more market housing just exacerbates this and waters-down the proportion of families with children in the AONB. A sustainable community must have a good demographic mix. The doctors surgery is at capacity and since the service is shared with Silverdale it is often necessary to travel to Silverdale to see a doctor. The nearest NHS dentist and opticians is over 3 miles away in Milnthorpe. Building market housing creates demand for future exponential growth – SLDC allocate housing by proportion and since the village is already large (after previous waves of house building) SLDC argue it must have yet more houses. The AONB is a precious natural resource enjoyed by people from all over South Lakes and further afield and brings tourism into the area. A line must be drawn; it is not sustainable to build more market housing within the AONB which will fuel future growth demand. The proposals for market housing within the AONB should be removed from the DPD and the sites protected.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
EVIDENCE BASE
Initially the DPD was based on a very flawed economic study which suggested, inter alia, that there were over 80 banking jobs in Arnside (there isn't even a bank in Arnside). SLDC have now withdrawn the reference to this but have not conducted further economic assessments and do not seem to have amended the DPD to reflect the economic realities of the AONB area. Here again it must be pointed out that the AONB has special status and therefore economic, social and environmental statistics cannot be inferred based on studies of other areas. To meet a test of "great weight being given to conserving landscape and scenic beauty" the DPD must demonstrate that the AONB area has been treated as unique and precious resource.
A further point on credible evidence is that several of the SLDC responses on landscape character selectively quote from an AONB management Plan policy. SLDC quote 'the AONB Management Plan also states (BE2.1) "Support infill and village edge development…."' but this policy actually says "Support infill and village edge development that avoids 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 impacts of development on the site, village and surroundings"
NATIONAL POLICY
In section 110 the NPPF states "Plans should allocate land with the least environmental or amenity value". There is significant brown field and infill land available in Arnside and there is also land on the periphery of the village which is not specifically mentioned in the AONB Landscape Assessment (as Site R81 is, for example). This land would be sufficient for affordable and local need housing. The DPD does not clearly demonstrate that these options have been fully pursued.
The Arnside and Silverdale AONB is spread across SLDC and Lancaster District. The NPPF requires councils to work with neighbouring councils, the DPD does not demonstrate a consistency of approach across council boundaries within the AONB.
Section 76 of the NPPF states "Local communities through local and neighbourhood plans should be able to identify for special protection green areas of particular importance to them". A number of representations have been made regarding the green spaces in Arnside, these should therefore be removed from the DPD pending adoption of the Arnside neighbourhood Plan.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
409. Mr Chris Hunter (Individual) : 11 May 2012 10:41:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - All Arnside sites
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
The DPD has not had regard to the Sustainable Community Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
SUMMARY
The comments below relate in particular to the Arnside and Silverdale AONB and demonstrate how the DPD is neither legally compliant nor sound with regard to the AONB. Prior to the last round of objections the DPD had no apparent regard for the AONB and it still only pays lip-service to it's protected status. Given the location of the AONB any development beyond affordable housing for villagers cannot in any sense be considered sustainable. The DPD fails to meet the requirements of the NPPF and is in direct contravention of the Council's own core strategy. The Area of OUTSTANDING Natural Beauty needs to be protected, building any of the proposed market housing irrevocably destroys precious green spaces which will never be retrieved.
COMMUNITY INVOLVEMENT
I am aware that several responses by myself and others have not been referenced under community involvement. There is no point in consulting the community if responses are ignored, the document should include a way of tracing community responses through to either amendments in the document or a clear rebuttal.
SUSTAINABILITY
The NPPF section 30 states "Encouragement should be given to solutions which support reductions in greenhouse gas emissions and reduce congestion" and section 95 states "plan for new development in locations and ways which reduce greenhouse gas emissions". Arnside is out-on-a-limb geographically being over 3 miles from the nearest A road, banks and NHS dentist. Building market housing in Arnside simply means more car journeys which means more greenhouse gas emissions. Arnside is designated as an Area of Outstanding Natural Beauty and therefore needs a specific sustainability assessment, it is distinct from much of the surrounding landscape. The DPD should demonstrate that Great Weight has been given to the AONB status as required by the NPPF.
The Sustainability Appraisal Report recognises the need to consider the cumulative effect of the plan under the Strategic Environmental Assessment Directive, however there is no evidence that this has been done across multiple sites in a given area. For specifically protected areas such as the AONB it is essential that a detailed assessment of the cumulative effect of the proposed developments is prepared and used to inform the DPD. This must be coordinated with Lancaster City Council since they have responsibility for the southern part of the AONB. This should also consider the cumulative effects that building now will have on future demand.
NATIONAL POLICY
The NPPF section 115 states "Great weight should be given to conserving landscape and scenic beauty in ... Areas of Outstanding Natural Beauty, which have the highest status of protection". The DPD has not had sufficient regard to this requirement. For example the AONB Landscape assessment states "small pastures backing on to woodland have survived ... in the vicinity of Blackdyke and Redhills. These provide an attractive transition between the built development and the open countryside". The DPD is proposing to build on one of these – site R81. Site R81 also is alongside a popular foot path, the NPPF section 75 states "Planning policies should protect and enhance public rights of way and access". Site R81 should be removed from the DPD. Furthermore site R81 was protected under core strategy policy S4 at the start of this process but seems to have been conveniently removed from the list of sites protected by policy S4 without justification.
Policy CS6.1 in the Adopted Core Strategy 2010 states that sites will be allocated in the Land Allocation DPD using the sequential approach to housing development identified in PPS 3 (now replaced) and Spatial Strategy Policies CS1.1. Policy CS1.1 states that existing buildings will be used first , followed by in fill and finally by other land where this is well located in relation to housing, jobs other services and infrastructure. The DPD fails to demonstrate any adherence to this core strategy.
Policy CS8.2 in the Adopted Core Strategy specifically deals with the AONB Management Plan and Landscape assessment. The proposed developments within the AONB on Greenfield, open spaces within the village clearly does not accord with this Policy.
SUSTAINABLE COMMUNITIIES
The sustainable community strategy talks of “access to services“, "better services for young people", "housing for local need provided in a suitable way" and "Managing our natural resources prudently". The current DPD rides rough-shod over these aims in Arnside. Past experience clearly demonstrates that market housing within the AONB is largely purchased by people who are 50+ and probably retiring to the area, a significant number will be from outwith South Lakes District. The community within the AONB is already heavily skewed towards the elderly and more market housing just exacerbates this and waters-down the proportion of families with children in the AONB. A sustainable community must have a good demographic mix. The doctors surgery is at capacity and since the service is shared with Silverdale it is often necessary to travel to Silverdale to see a doctor. The nearest NHS dentist and opticians is over 3 miles away in Milnthorpe. Building market housing creates demand for future exponential growth – SLDC allocate housing by proportion and since the village is already large (after previous waves of house building) SLDC argue it must have yet more houses. The AONB is a precious natural resource enjoyed by people from all over South Lakes and further afield and brings tourism into the area. A line must be drawn; it is not sustainable to build more market housing within the AONB which will fuel future growth demand. The proposals for market housing within the AONB should be removed from the DPD and the sites protected.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
EVIDENCE BASE
Initially the DPD was based on a very flawed economic study which suggested, inter alia, that there were over 80 banking jobs in Arnside (there isn't even a bank in Arnside). SLDC have now withdrawn the reference to this but have not conducted further economic assessments and do not seem to have amended the DPD to reflect the economic realities of the AONB area. Here again it must be pointed out that the AONB has special status and therefore economic, social and environmental statistics cannot be inferred based on studies of other areas. To meet a test of "great weight being given to conserving landscape and scenic beauty" the DPD must demonstrate that the AONB area has been treated as unique and precious resource.
A further point on credible evidence is that several of the SLDC responses on landscape character selectively quote from an AONB management Plan policy. SLDC quote 'the AONB Management Plan also states (BE2.1) "Support infill and village edge development…."' but this policy actually says "Support infill and village edge development that avoids 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 impacts of development on the site, village and surroundings"
NATIONAL POLICY
In section 110 the NPPF states "Plans should allocate land with the least environmental or amenity value". There is significant brown field and infill land available in Arnside and there is also land on the periphery of the village which is not specifically mentioned in the AONB Landscape Assessment (as Site R81 is, for example). This land would be sufficient for affordable and local need housing. The DPD does not clearly demonstrate that these options have been fully pursued.
The Arnside and Silverdale AONB is spread across SLDC and Lancaster District. The NPPF requires councils to work with neighbouring councils, the DPD does not demonstrate a consistency of approach across council boundaries within the AONB.
Section 76 of the NPPF states "Local communities through local and neighbourhood plans should be able to identify for special protection green areas of particular importance to them". A number of representations have been made regarding the green spaces in Arnside, these should therefore be removed from the DPD pending adoption of the Arnside neighbourhood Plan.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
410. Mr Chris Hunter (Individual) : 11 May 2012 10:43:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA2.12 Mixed Use Allocation at Sandside Road, Arnside
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
The DPD has not had regard to the Sustainable Community Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
SUMMARY
The comments below relate in particular to the Arnside and Silverdale AONB and demonstrate how the DPD is neither legally compliant nor sound with regard to the AONB. Prior to the last round of objections the DPD had no apparent regard for the AONB and it still only pays lip-service to it's protected status. Given the location of the AONB any development beyond affordable housing for villagers cannot in any sense be considered sustainable. The DPD fails to meet the requirements of the NPPF and is in direct contravention of the Council's own core strategy. The Area of OUTSTANDING Natural Beauty needs to be protected, building any of the proposed market housing irrevocably destroys precious green spaces which will never be retrieved.
COMMUNITY INVOLVEMENT
I am aware that several responses by myself and others have not been referenced under community involvement. There is no point in consulting the community if responses are ignored, the document should include a way of tracing community responses through to either amendments in the document or a clear rebuttal.
SUSTAINABILITY
The NPPF section 30 states "Encouragement should be given to solutions which support reductions in greenhouse gas emissions and reduce congestion" and section 95 states "plan for new development in locations and ways which reduce greenhouse gas emissions". Arnside is out-on-a-limb geographically being over 3 miles from the nearest A road, banks and NHS dentist. Building market housing in Arnside simply means more car journeys which means more greenhouse gas emissions. Arnside is designated as an Area of Outstanding Natural Beauty and therefore needs a specific sustainability assessment, it is distinct from much of the surrounding landscape. The DPD should demonstrate that Great Weight has been given to the AONB status as required by the NPPF.
The Sustainability Appraisal Report recognises the need to consider the cumulative effect of the plan under the Strategic Environmental Assessment Directive, however there is no evidence that this has been done across multiple sites in a given area. For specifically protected areas such as the AONB it is essential that a detailed assessment of the cumulative effect of the proposed developments is prepared and used to inform the DPD. This must be coordinated with Lancaster City Council since they have responsibility for the southern part of the AONB. This should also consider the cumulative effects that building now will have on future demand.
NATIONAL POLICY
The NPPF section 115 states "Great weight should be given to conserving landscape and scenic beauty in ... Areas of Outstanding Natural Beauty, which have the highest status of protection". The DPD has not had sufficient regard to this requirement. For example the AONB Landscape assessment states "small pastures backing on to woodland have survived ... in the vicinity of Blackdyke and Redhills. These provide an attractive transition between the built development and the open countryside". The DPD is proposing to build on one of these – site R81. Site R81 also is alongside a popular foot path, the NPPF section 75 states "Planning policies should protect and enhance public rights of way and access". Site R81 should be removed from the DPD. Furthermore site R81 was protected under core strategy policy S4 at the start of this process but seems to have been conveniently removed from the list of sites protected by policy S4 without justification.
Policy CS6.1 in the Adopted Core Strategy 2010 states that sites will be allocated in the Land Allocation DPD using the sequential approach to housing development identified in PPS 3 (now replaced) and Spatial Strategy Policies CS1.1. Policy CS1.1 states that existing buildings will be used first , followed by in fill and finally by other land where this is well located in relation to housing, jobs other services and infrastructure. The DPD fails to demonstrate any adherence to this core strategy.
Policy CS8.2 in the Adopted Core Strategy specifically deals with the AONB Management Plan and Landscape assessment. The proposed developments within the AONB on Greenfield, open spaces within the village clearly does not accord with this Policy.
SUSTAINABLE COMMUNITIIES
The sustainable community strategy talks of “access to services“, "better services for young people", "housing for local need provided in a suitable way" and "Managing our natural resources prudently". The current DPD rides rough-shod over these aims in Arnside. Past experience clearly demonstrates that market housing within the AONB is largely purchased by people who are 50+ and probably retiring to the area, a significant number will be from outwith South Lakes District. The community within the AONB is already heavily skewed towards the elderly and more market housing just exacerbates this and waters-down the proportion of families with children in the AONB. A sustainable community must have a good demographic mix. The doctors surgery is at capacity and since the service is shared with Silverdale it is often necessary to travel to Silverdale to see a doctor. The nearest NHS dentist and opticians is over 3 miles away in Milnthorpe. Building market housing creates demand for future exponential growth – SLDC allocate housing by proportion and since the village is already large (after previous waves of house building) SLDC argue it must have yet more houses. The AONB is a precious natural resource enjoyed by people from all over South Lakes and further afield and brings tourism into the area. A line must be drawn; it is not sustainable to build more market housing within the AONB which will fuel future growth demand. The proposals for market housing within the AONB should be removed from the DPD and the sites protected.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
EVIDENCE BASE
Initially the DPD was based on a very flawed economic study which suggested, inter alia, that there were over 80 banking jobs in Arnside (there isn't even a bank in Arnside). SLDC have now withdrawn the reference to this but have not conducted further economic assessments and do not seem to have amended the DPD to reflect the economic realities of the AONB area. Here again it must be pointed out that the AONB has special status and therefore economic, social and environmental statistics cannot be inferred based on studies of other areas. To meet a test of "great weight being given to conserving landscape and scenic beauty" the DPD must demonstrate that the AONB area has been treated as unique and precious resource.
A further point on credible evidence is that several of the SLDC responses on landscape character selectively quote from an AONB management Plan policy. SLDC quote 'the AONB Management Plan also states (BE2.1) "Support infill and village edge development…."' but this policy actually says "Support infill and village edge development that avoids 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 impacts of development on the site, village and surroundings"
NATIONAL POLICY
In section 110 the NPPF states "Plans should allocate land with the least environmental or amenity value". There is significant brown field and infill land available in Arnside and there is also land on the periphery of the village which is not specifically mentioned in the AONB Landscape Assessment (as Site R81 is, for example). This land would be sufficient for affordable and local need housing. The DPD does not clearly demonstrate that these options have been fully pursued.
The Arnside and Silverdale AONB is spread across SLDC and Lancaster District. The NPPF requires councils to work with neighbouring councils, the DPD does not demonstrate a consistency of approach across council boundaries within the AONB.
Section 76 of the NPPF states "Local communities through local and neighbourhood plans should be able to identify for special protection green areas of particular importance to them". A number of representations have been made regarding the green spaces in Arnside, these should therefore be removed from the DPD pending adoption of the Arnside neighbourhood Plan.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
411. Mr Chris Hunter (Individual) : 11 May 2012 10:46:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.8 Local Employment Allocations - EN40-mod SANDSIDE LAND SOUTH OF QUARRY LANE
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
The DPD has not had regard to the Sustainable Community Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
SUMMARY
The comments below relate in particular to the Arnside and Silverdale AONB and demonstrate how the DPD is neither legally compliant nor sound with regard to the AONB. Prior to the last round of objections the DPD had no apparent regard for the AONB and it still only pays lip-service to it's protected status. Given the location of the AONB any development beyond affordable housing for villagers cannot in any sense be considered sustainable. The DPD fails to meet the requirements of the NPPF and is in direct contravention of the Council's own core strategy. The Area of OUTSTANDING Natural Beauty needs to be protected, building any of the proposed market housing irrevocably destroys precious green spaces which will never be retrieved.
COMMUNITY INVOLVEMENT
I am aware that several responses by myself and others have not been referenced under community involvement. There is no point in consulting the community if responses are ignored, the document should include a way of tracing community responses through to either amendments in the document or a clear rebuttal.
SUSTAINABILITY
The NPPF section 30 states "Encouragement should be given to solutions which support reductions in greenhouse gas emissions and reduce congestion" and section 95 states "plan for new development in locations and ways which reduce greenhouse gas emissions". Arnside is out-on-a-limb geographically being over 3 miles from the nearest A road, banks and NHS dentist. Building market housing in Arnside simply means more car journeys which means more greenhouse gas emissions. Arnside is designated as an Area of Outstanding Natural Beauty and therefore needs a specific sustainability assessment, it is distinct from much of the surrounding landscape. The DPD should demonstrate that Great Weight has been given to the AONB status as required by the NPPF.
The Sustainability Appraisal Report recognises the need to consider the cumulative effect of the plan under the Strategic Environmental Assessment Directive, however there is no evidence that this has been done across multiple sites in a given area. For specifically protected areas such as the AONB it is essential that a detailed assessment of the cumulative effect of the proposed developments is prepared and used to inform the DPD. This must be coordinated with Lancaster City Council since they have responsibility for the southern part of the AONB. This should also consider the cumulative effects that building now will have on future demand.
NATIONAL POLICY
The NPPF section 115 states "Great weight should be given to conserving landscape and scenic beauty in ... Areas of Outstanding Natural Beauty, which have the highest status of protection". The DPD has not had sufficient regard to this requirement. For example the AONB Landscape assessment states "small pastures backing on to woodland have survived ... in the vicinity of Blackdyke and Redhills. These provide an attractive transition between the built development and the open countryside". The DPD is proposing to build on one of these – site R81. Site R81 also is alongside a popular foot path, the NPPF section 75 states "Planning policies should protect and enhance public rights of way and access". Site R81 should be removed from the DPD. Furthermore site R81 was protected under core strategy policy S4 at the start of this process but seems to have been conveniently removed from the list of sites protected by policy S4 without justification.
Policy CS6.1 in the Adopted Core Strategy 2010 states that sites will be allocated in the Land Allocation DPD using the sequential approach to housing development identified in PPS 3 (now replaced) and Spatial Strategy Policies CS1.1. Policy CS1.1 states that existing buildings will be used first , followed by in fill and finally by other land where this is well located in relation to housing, jobs other services and infrastructure. The DPD fails to demonstrate any adherence to this core strategy.
Policy CS8.2 in the Adopted Core Strategy specifically deals with the AONB Management Plan and Landscape assessment. The proposed developments within the AONB on Greenfield, open spaces within the village clearly does not accord with this Policy.
SUSTAINABLE COMMUNITIIES
The sustainable community strategy talks of “access to services“, "better services for young people", "housing for local need provided in a suitable way" and "Managing our natural resources prudently". The current DPD rides rough-shod over these aims in Arnside. Past experience clearly demonstrates that market housing within the AONB is largely purchased by people who are 50+ and probably retiring to the area, a significant number will be from outwith South Lakes District. The community within the AONB is already heavily skewed towards the elderly and more market housing just exacerbates this and waters-down the proportion of families with children in the AONB. A sustainable community must have a good demographic mix. The doctors surgery is at capacity and since the service is shared with Silverdale it is often necessary to travel to Silverdale to see a doctor. The nearest NHS dentist and opticians is over 3 miles away in Milnthorpe. Building market housing creates demand for future exponential growth – SLDC allocate housing by proportion and since the village is already large (after previous waves of house building) SLDC argue it must have yet more houses. The AONB is a precious natural resource enjoyed by people from all over South Lakes and further afield and brings tourism into the area. A line must be drawn; it is not sustainable to build more market housing within the AONB which will fuel future growth demand. The proposals for market housing within the AONB should be removed from the DPD and the sites protected.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
EVIDENCE BASE
Initially the DPD was based on a very flawed economic study which suggested, inter alia, that there were over 80 banking jobs in Arnside (there isn't even a bank in Arnside). SLDC have now withdrawn the reference to this but have not conducted further economic assessments and do not seem to have amended the DPD to reflect the economic realities of the AONB area. Here again it must be pointed out that the AONB has special status and therefore economic, social and environmental statistics cannot be inferred based on studies of other areas. To meet a test of "great weight being given to conserving landscape and scenic beauty" the DPD must demonstrate that the AONB area has been treated as unique and precious resource.
A further point on credible evidence is that several of the SLDC responses on landscape character selectively quote from an AONB management Plan policy. SLDC quote 'the AONB Management Plan also states (BE2.1) "Support infill and village edge development…."' but this policy actually says "Support infill and village edge development that avoids 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 impacts of development on the site, village and surroundings"
NATIONAL POLICY
In section 110 the NPPF states "Plans should allocate land with the least environmental or amenity value". There is significant brown field and infill land available in Arnside and there is also land on the periphery of the village which is not specifically mentioned in the AONB Landscape Assessment (as Site R81 is, for example). This land would be sufficient for affordable and local need housing. The DPD does not clearly demonstrate that these options have been fully pursued.
The Arnside and Silverdale AONB is spread across SLDC and Lancaster District. The NPPF requires councils to work with neighbouring councils, the DPD does not demonstrate a consistency of approach across council boundaries within the AONB.
Section 76 of the NPPF states "Local communities through local and neighbourhood plans should be able to identify for special protection green areas of particular importance to them". A number of representations have been made regarding the green spaces in Arnside, these should therefore be removed from the DPD pending adoption of the Arnside neighbourhood Plan.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
412. Mr Chris Hunter (Individual) : 11 May 2012 10:49:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - M683sM-mod STORTH LAND S OF QUARRY LANE, STORTH
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
The DPD has not had regard to the Sustainable Community Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
SUMMARY
The comments below relate in particular to the Arnside and Silverdale AONB and demonstrate how the DPD is neither legally compliant nor sound with regard to the AONB. Prior to the last round of objections the DPD had no apparent regard for the AONB and it still only pays lip-service to it's protected status. Given the location of the AONB any development beyond affordable housing for villagers cannot in any sense be considered sustainable. The DPD fails to meet the requirements of the NPPF and is in direct contravention of the Council's own core strategy. The Area of OUTSTANDING Natural Beauty needs to be protected, building any of the proposed market housing irrevocably destroys precious green spaces which will never be retrieved.
COMMUNITY INVOLVEMENT
I am aware that several responses by myself and others have not been referenced under community involvement. There is no point in consulting the community if responses are ignored, the document should include a way of tracing community responses through to either amendments in the document or a clear rebuttal.
SUSTAINABILITY
The NPPF section 30 states "Encouragement should be given to solutions which support reductions in greenhouse gas emissions and reduce congestion" and section 95 states "plan for new development in locations and ways which reduce greenhouse gas emissions". Arnside is out-on-a-limb geographically being over 3 miles from the nearest A road, banks and NHS dentist. Building market housing in Arnside simply means more car journeys which means more greenhouse gas emissions. Arnside is designated as an Area of Outstanding Natural Beauty and therefore needs a specific sustainability assessment, it is distinct from much of the surrounding landscape. The DPD should demonstrate that Great Weight has been given to the AONB status as required by the NPPF.
The Sustainability Appraisal Report recognises the need to consider the cumulative effect of the plan under the Strategic Environmental Assessment Directive, however there is no evidence that this has been done across multiple sites in a given area. For specifically protected areas such as the AONB it is essential that a detailed assessment of the cumulative effect of the proposed developments is prepared and used to inform the DPD. This must be coordinated with Lancaster City Council since they have responsibility for the southern part of the AONB. This should also consider the cumulative effects that building now will have on future demand.
NATIONAL POLICY
The NPPF section 115 states "Great weight should be given to conserving landscape and scenic beauty in ... Areas of Outstanding Natural Beauty, which have the highest status of protection". The DPD has not had sufficient regard to this requirement. For example the AONB Landscape assessment states "small pastures backing on to woodland have survived ... in the vicinity of Blackdyke and Redhills. These provide an attractive transition between the built development and the open countryside". The DPD is proposing to build on one of these – site R81. Site R81 also is alongside a popular foot path, the NPPF section 75 states "Planning policies should protect and enhance public rights of way and access". Site R81 should be removed from the DPD. Furthermore site R81 was protected under core strategy policy S4 at the start of this process but seems to have been conveniently removed from the list of sites protected by policy S4 without justification.
Policy CS6.1 in the Adopted Core Strategy 2010 states that sites will be allocated in the Land Allocation DPD using the sequential approach to housing development identified in PPS 3 (now replaced) and Spatial Strategy Policies CS1.1. Policy CS1.1 states that existing buildings will be used first , followed by in fill and finally by other land where this is well located in relation to housing, jobs other services and infrastructure. The DPD fails to demonstrate any adherence to this core strategy.
Policy CS8.2 in the Adopted Core Strategy specifically deals with the AONB Management Plan and Landscape assessment. The proposed developments within the AONB on Greenfield, open spaces within the village clearly does not accord with this Policy.
SUSTAINABLE COMMUNITIIES
The sustainable community strategy talks of “access to services“, "better services for young people", "housing for local need provided in a suitable way" and "Managing our natural resources prudently". The current DPD rides rough-shod over these aims in Arnside. Past experience clearly demonstrates that market housing within the AONB is largely purchased by people who are 50+ and probably retiring to the area, a significant number will be from outwith South Lakes District. The community within the AONB is already heavily skewed towards the elderly and more market housing just exacerbates this and waters-down the proportion of families with children in the AONB. A sustainable community must have a good demographic mix. The doctors surgery is at capacity and since the service is shared with Silverdale it is often necessary to travel to Silverdale to see a doctor. The nearest NHS dentist and opticians is over 3 miles away in Milnthorpe. Building market housing creates demand for future exponential growth – SLDC allocate housing by proportion and since the village is already large (after previous waves of house building) SLDC argue it must have yet more houses. The AONB is a precious natural resource enjoyed by people from all over South Lakes and further afield and brings tourism into the area. A line must be drawn; it is not sustainable to build more market housing within the AONB which will fuel future growth demand. The proposals for market housing within the AONB should be removed from the DPD and the sites protected.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not consistent with national policy.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
EVIDENCE BASE
Initially the DPD was based on a very flawed economic study which suggested, inter alia, that there were over 80 banking jobs in Arnside (there isn't even a bank in Arnside). SLDC have now withdrawn the reference to this but have not conducted further economic assessments and do not seem to have amended the DPD to reflect the economic realities of the AONB area. Here again it must be pointed out that the AONB has special status and therefore economic, social and environmental statistics cannot be inferred based on studies of other areas. To meet a test of "great weight being given to conserving landscape and scenic beauty" the DPD must demonstrate that the AONB area has been treated as unique and precious resource.
A further point on credible evidence is that several of the SLDC responses on landscape character selectively quote from an AONB management Plan policy. SLDC quote 'the AONB Management Plan also states (BE2.1) "Support infill and village edge development…."' but this policy actually says "Support infill and village edge development that avoids 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 impacts of development on the site, village and surroundings"
NATIONAL POLICY
In section 110 the NPPF states "Plans should allocate land with the least environmental or amenity value". There is significant brown field and infill land available in Arnside and there is also land on the periphery of the village which is not specifically mentioned in the AONB Landscape Assessment (as Site R81 is, for example). This land would be sufficient for affordable and local need housing. The DPD does not clearly demonstrate that these options have been fully pursued.
The Arnside and Silverdale AONB is spread across SLDC and Lancaster District. The NPPF requires councils to work with neighbouring councils, the DPD does not demonstrate a consistency of approach across council boundaries within the AONB.
Section 76 of the NPPF states "Local communities through local and neighbourhood plans should be able to identify for special protection green areas of particular importance to them". A number of representations have been made regarding the green spaces in Arnside, these should therefore be removed from the DPD pending adoption of the Arnside neighbourhood Plan.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
413. Mr Peter Jackson (Individual) : 13 Apr 2012 20:01:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
0.0 Whole Document
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
In December 2008 Levens Village Plan was published with a very high return rate which SLDC has a copy.This plan identified 'small developments' not a single site for 50 houses ( site R51M) in a parish of 525 dwellings.
In 2008 a Rural Housing Needs Survey was conducted, identifying the need for TWELVE affordable homes for young people in the next 5 years. Why is this information being ignored?
The village has only one bus service which does not allow for commuting to full time employment even to the local town of Kendal.Other buses do not enter the village and there is no safe pedestrian access to these bus stops.
All access roads into the village are narrow with single width pinch points and therefore unsuitable for increased density of traffic.
We question the status of Levens as an LSC as there are no links to a GP or the nearest hospital. The criteria seems to be the fact that Levens has a shop.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
This DPD is based on out of date and unreliable evidence in the following areas;
The SHMA is based on old studies and the 2011 housing survey received only 9.5 response.
The SHMA says there are 1024 empty homes but a recent local election leaflet says there are 2029.
There is no evidence to show how those in need of affordable housing would actually be able to afford or rent the planned (affordable) homes.
The DPD is not deliverable because of inadequate infrastructure eg. electricity, water,sewerage.
Many of the services are working to capacity now and there is no evidence that the utility providers have the funding to provide increased facilities.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
414. Mr. Tom Jackson (Individual) : 23 Apr 2012 14:31:00
Paragraph No.
1.10
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
You state the DPD has been developed based on extensive feedback, but I have found very little support for the Development Plan, except for the applicants and yourselves. You may well have extensive feedback and had meetings and consultations, but what is the point when you just ignore the opinion of the masses, how can this be legal.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
415. Mr. Tom Jackson (Individual) : 23 Apr 2012 14:33:00
A typed or handwritten document was submitted. This has been scanned and can be downloaded below:
Policy/Site No.
LA1.3 Housing Allocations - R690ulv, R691ULV, R126M, RN184, RN234# & part R242 ULVERSTON CROFTLANDS WEST - NOOK FARM
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
RE: LAND ALLOCATIONS DEVELOPMENT PLAN DOCUMENT
Thank you for giving the public the opportunity to voice their opinion and comment on the L.A.D. Plan, unfortunately I very much doubt that any public opinion will be taken into account, it certainly hasn’t up to now.
Projected mass development with no guarantee of additional employment will always be a dangerous combination but I am concerned about the mass development in all areas, but my immediate concern is Ulverston South.
Having read some but not all of your policies and documentation I cannot find much that you have actually adhered to.
Brownfield Sites:- ST3. Your earlier documentation states a target of 50% of new properties should be on Brownfield site, but that % has now been reduced, but Ulverstons LAD Plan is showing approximately 93% of new housing development on Greenfields sites, which is a long way off your target.
After Brownfields Sites your plan states ‘ensure agricultural lands of poorer quality is used for development in preference to the best and more versatile agricultural land’. But yet Ulverston south shows fields R156, R126, R242 and R690ULV included in the Development Plan which are of prime versatile agricultural land. You appear to have ignored your own policies and public opinion, by approving the plan, again in direct conflict with your own policies.
Sustainability:- ST2.6 ‘The structure plan provides a framework to ensure that any adverse impact of development is minimised and that development promotes sustainability’. By developing on Ulverston South which is prime versatile agricultural land you are denying our sustainability for the future. Greenfields are needed to ensure and sustain our future, development on prime agricultural land has to be in direct conflict with your policies.
Flooding:- ST3 reduce the risk of flooding within the development in the following priority.
a). Site with little or no flood risk,
b). Site with lower or medium flood risk, and only then
c). Site in area of high flood risk.
Again I find you have ignored your own policies in particular.
R156 (Part of R126m) - Flood Risk
Zone 2. See photograph showing severe flooding
R126 (Part of R126m) - No Flood Risk
See photograph showing severe flooding
R242 – No Flood Risk
See photograph showing severe flooding
R690 ULV – No Flood Risk
Severe flooding – No Photo
Three of these areas are not designated as any flood risk, but you can see from the photographs that you are allowing development on site in areas of high flood risk that yourselves don’t even know about.
416. Mr Peter Jackson (Individual) : 30 Apr 2012 13:54:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - All Levens sites
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
In December 2008 Levens Village Plan was published with a very high return rate which SLDC has a copy.This plan identified 'small developments' not a single site for 50 houses ( site R51M) in a parish of 525 dwellings.
In 2008 a Rural Housing Needs Survey was conducted, identifying the need for TWELVE affordable homes for young people in the next 5 years. Why is this information being ignored?
The village has only one bus service which does not allow for commuting to full time employment even to the local town of Kendal.Other buses do not enter the village and there is no safe pedestrian access to these bus stops.
All access roads into the village are narrow with single width pinch points and therefore unsuitable for increased density of traffic.
We question the status of Levens as an LSC as there are no links to a GP or the nearest hospital. The criteria seems to be the fact that Levens has a shop.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
This DPD is based on out of date and unreliable evidence in the following areas;
The SHMA is based on old studies and the 2011 housing survey received only 9.5 response.
The SHMA says there are 1024 empty homes but a recent local election leaflet says there are 2029.
There is no evidence to show how those in need of affordable housing would actually be able to afford or rent the planned (affordable) homes.
The DPD is not deliverable because of inadequate infrastructure eg. electricity, water,sewerage.
Many of the services are working to capacity now and there is no evidence that the utility providers have the funding to provide increased facilities.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
417. Mr Geoffrey James (Individual) : 25 Apr 2012 12:22:00
Policy/Site No.
LA1.1 Development Boundaries- GREAT AND LITTLE URSWICK
If you have selected a ‘Site omission’ please enter the site reference or location and relevant policy below
Settlement development boundary change omission
Great Urswick settlement development boundary. SLDC ref. ON15
Policy LA1.1 - Development Boundaries - Great Urswick.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
You have already received several communications concerning the proposed development boundaries of the bordering land adjacent to Urswick Tarn ,Great Urswick .As you are aware the Tarn and its shore are the property of the Crown and are part of common land rights of the Parishioners .It has always been the nesting ground of swans , coots and other wildlife . Although several developments in the 1950-1960 's are present all of the recent proposals for building on land to the north tarn between Church view road and the tarn shore have been turned down and local opposition has been supported at appeal by the Secretary of State For the Environment.
It is clear from your proposed development boundaries that these previous actions have been ignored and you are including the above mentioned land within the development category of the proposed Framework thus ignoring the local issue of public amenity and the loss of visual access to Urswick Tarn by the Local Population.
The SLDC policy of not allowing new developments on the Tarn Shore was eroded by the granting of Planning Proposals for the Coot Development against total local opposition . This does not have to set a precedent for the decline of environmental standards and I would strongly advise that the boundaries be revised to exclude the existing tarn shore properties and bring the boundary perimeter to the road rather than the Tarn shore .Failure to do so will ultimately lead to great expense in that every new proposal will be met by strong local opposition.
418. Mr & Mrs Colin and Rhoda James (Individual) : 26 Apr 2012 11:34:00
A typed or handwritten document was submitted. This has been scanned and can be downloaded below:
Policy/Site No.
LA1.3 Housing Allocations - All Grange-over-Sands sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
As you can see, we have given our thoughts to the enclosed leaflet (see attached document), letting you know how we feel affordable housing for 'LOCALS' should be obtained without a great influx of other areas residents. Less green field development, and use brown field sites and infill first.
Your proposals will ruin the tranquility and views of the area. All its charm and character will be lost.
Allithwaite, Grange and Kents Bank cannot sustain 500 new houses. Houses for locals only. (Refer to attached document)
419. Mr & Mrs Colin and Rhoda James (Individual) : 26 Apr 2012 12:26:00
A typed or handwritten document was submitted. This has been scanned and can be downloaded below:
Policy/Site No.
LA1.3 Housing Allocations - All Allithwaite sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
As you can see, we have given our thoughts to the enclosed leaflet (see attached document), letting you know how we feel affordable housing for 'LOCALS' should be obtained without a great influx of other areas residents. Less green field development, and use brown field sites and infill first.
Your proposals will ruin the tranquility and views of the area. All its charm and character will be lost.
Allithwaite, Grange and Kents Bank cannot sustain 500 new houses. Houses for locals only. (Refer to attached document)
420. Mr & Mrs Colin and Rhoda James (Individual) : 26 Apr 2012 12:29:00
A typed or handwritten document was submitted. This has been scanned and can be downloaded below:
Policy/Site No.
LA3.1 Mixed Use Allocation at Berners Pool, Grange-over-Sands
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
As you can see, we have given our thoughts to the enclosed leaflet (see attached document), letting you know how we feel affordable housing for 'LOCALS' should be obtained without a great influx of other areas residents. Less green field development, and use brown field sites and infill first.
Your proposals will ruin the tranquility and views of the area. All its charm and character will be lost.
Allithwaite, Grange and Kents Bank cannot sustain 500 new houses. Houses for locals only. (Refer to attached document)
421. Mr & Mrs Colin and Rhoda James (Individual) : 26 Apr 2012 12:31:00
A typed or handwritten document was submitted. This has been scanned and can be downloaded below:
Policy/Site No.
LA3.2 Mixed Use Allocation at Land South of Allithwaite Road, Kent's Bank, Grange-over-Sands
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
As you can see, we have given our thoughts to the enclosed leaflet (see attached document), letting you know how we feel affordable housing for 'LOCALS' should be obtained without a great influx of other areas residents. Less green field development, and use brown field sites and infill first.
Your proposals will ruin the tranquility and views of the area. All its charm and character will be lost.
Allithwaite, Grange and Kents Bank cannot sustain 500 new houses. Houses for locals only. (Refer to attached document)
422. Mr & Mrs Colin and Rhoda James (Individual) : 26 Apr 2012 12:33:00
A typed or handwritten document was submitted. This has been scanned and can be downloaded below:
Policy/Site No.
LA3.3 Mixed Use Allocation at Guide's Lot, Grange-over-Sands
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
As you can see, we have given our thoughts to the enclosed leaflet (see attached document), letting you know how we feel affordable housing for 'LOCALS' should be obtained without a great influx of other areas residents. Less green field development, and use brown field sites and infill first.
Your proposals will ruin the tranquility and views of the area. All its charm and character will be lost.
Allithwaite, Grange and Kents Bank cannot sustain 500 new houses. Houses for locals only. (Refer to attached document)
423. Revd and Mrs Martin & Elspeth Jayne (Individual) : 17 Apr 2012 00:20:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - R108M OXENHOLME LAND S OF FELL CLOSE
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I propose the removal of the site from the DPD as the LPA has not demonstrated that its allocation complies with its policies with regard to Landscape and Settlement Character. Observation of the site will show that its predominant feature is that it is the side and crest of a drumlin. In addition the whole of the site is allocated for development and yet the detailed reference is for development on only part of the site, The details are left to planning application stage. This is unsound in that the site is expected to contribute over 60 dwellings towards the district target yet an unspecified number may be "shaved off" at application stage. This ambiguity is unsound. The Cumbria Landscape Character Guidance and Toolkit is an excellent broad survey of the geography of part of the county and its general principles are in the main good, but there is no demonstration for this particular site that the toolkit has been soundly applied. Guidance on P92 of the toolkit has reference to areas of drumlins such as this, inter alia, as "Village expansion, barn conversions, and sporadic development that don’t re?ect the local vernacular or traditional siting of development at the foot of the drumlins could weaken local identity." Furthermore consideration should be given to designating the land as a green gap reinforcing that to the west of the railway line bordering on Natland since in the words of policy CS8.2 since the Green Gap would
"• Contribute to maintaining a settlement’s identity, landscape setting and character;
• Comprise predominantly open land maintaining an ‘open’ aspect; "
The Council's view that a green gap function is solely to prevent coalescence as stated in its consideration of my earlier objection is an unsound and partial reading of its own policy. "The Council considers that the land does or does not function as
a green gap in context of Adopted Core Strategy Policy CS8.2. It is considered development in this location would not result in the coalescence of Oxenholme and Natland. " In light of this statement the green gap between the railway line and Natland is superfluous since the railway line itself prevents coalescence more effectively than any landscape designation since there are no crossings and at this point it is partially embanked. The Council fails to refer to the role of the green gap as maintaining settlement character.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
I will then be satisfied that proper consideration has been given to the inclusion or exclusion of this site from the DPD
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
424. Mr David Johnson (Individual) : 19 Apr 2012 11:58:00
Policy/Site No.
LA1.3 Housing Allocations - RN224 RN86# RN195 ALLITHWAITE LAND REAR OF BARN HEY
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Dear Sir it is with concern that l note the potential development of 30 dwellings to the rear of Barn Hey Allithwaite. Having lived in Barn Hey cottage for a number of years l have objections on both aesthetic and technical grounds. I would be only to pleased to discuss my concerns if given the opportunity.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
425. Mr John Terence Johnson (Individual) : 4 May 2012 12:13:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - R121M-mod KENDAL EAST OF CASTLE GREEN ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Recommend removal of site R121M from any land allocations document in the belief that SLDC's DPD in unsound in respect of the site for reasons stated below:
I would like to question the soundness of South Lakeland District Council's Land Allocations
Development Plan Document in proposing land to the east of Castle Green Road (Site Reference
Rl21M) as being suitable for housing development in spite of substantial public opposition to the
proposal. Given that the visual impact of this high hillside agricultural site had previously been
considered by the Council to be worthy of County Landscape Designation and that the Council
fully acknowledges the site has complex flood issues due to substantial sheet water runoff and
underground watercourses which could see development severely impact on the recent Stock Beck
Flood Alleviation Scheme, it is very difficult to reconcile and justify the Council's criteria in
allocating the site for proposed development.
My understanding of "SOUNDNESS" of the DPD is that it be justified- founded on a robust and
credible evidence base, and yet right from the start of the Council's Land Allocations process Site
Rl21M was judged so negatively for development in SLDC's Fact File site notes that I fail to see
the justification for its continued inclusion as an allocated site. The flooding issue, together with
the substantial infrastructure issues to provide utility services, road access and deal with existing on
site bio-diversity issues which have all been acknowledged by the Council, have not been put to a
RISK/COST ASSESMENT to determine if proposed development of site Rl21M is viable,
sustainable, deliverable or just plain illogical. When and who will conduct a flood risk assessment.
I understand Cumbria County Council has recently become the Lead Local Flood Authority (LLFA)
in Cumbria. If Oak Tree Drive/ Rowan Crescent has an undersized and substandard culvert running
under them I would wish to know answers to the following as it has direct bearing on proposals for
SiteR121M:
1) Why is the culvert inadequate?
2) Who is responsible?
3) Why did SLDC planning not pick up the problem at the planning stage of these
developments?
4) Did the inadequate culvert contribute to the 1999 flooding of Lowther Park I Silverdale
Drive area- we locals remember seeing floodwaters. bursting through garden walls onto
Castle Green Road
5) Does it then really make sense to allow further development behind Oak Tree Road (site
Rl21M) where drainage waters would run into Stockbeck? All other eastern hillside land
draining into the Stock Beck Flood Alleviation Scheme have for good reason been removed
from SLDCs' Land Allocations so why not Site Rl21M?
The fact is that Site Rl21M was never robustly, physically examined at an early stage of the LDFLAND
ALLOCATIONS process to establish or contest sound local knowledge of the site provided
by well meaning individuals with yean of day to day knowledge of the vagaries of the site which is
known to act like an enormous sponge to absorb large amounts of rainfall and therefore assist the
slowdown of its progress to the lower level reaches of the town. Much of the
information/observations provided under the public consultation exercise was disregarded as
objections from residents who are affected by the proposed developments making community
involvement and engagement seem meaningless. The Council requested participation in its Land
Allocations exercise from the local Community/Stakeholders as required of them, but then
seemingly blinded by their desire to achieve targeted housing figures throughout the district, have
chosen to ignore all its own previous sound planning briefs! decisions. regarding Site R 121M,
Kendal Town Council's view that the site should not be developed, reports from Friends of the Lake
District that Rl21M should not be developed and the many residents whose alternative proposals
were just ignored. I attended consultation 'drop in' days with SLDC planning staff in attendance but
attempts to discuss objectively, concerns regarding land allocations were fended off with the
answer "We need to come up with the numbers" - at all cost it would appear!
I understand the present Government is on record as saying it is opposed to top-down targets and
has axed Labour's regional spatial strategies which set development plans for English regions over
15 to 20 years, preferring 'local neighbourhood' input on development strategy.
I fully understand the need to plan for the Town's housing needs but cannot condone the Council's
knee-jerk grab for highly sensitive hillside landscape such as SiteR121M to the ultimate detriment
of the Town's unique quality when other alternative brownfield sites have been proved to be
available and I understood were always a preferred option if available. I appreciate brownfield sites
will not accommodate all the Town's future housing needs but I am being site specific when I state
I am unable to believe a robust and credible evidence base has been established to justify Site
Rl21M 's inclusion for development to provide 60 dwellings, when it is clearly not the most
appropriate strategy to pursue when considered against reasonable alternatives - 60 dwellings
provided by the "Cock & Dolphin" and DSG redevelopment in Kirkland, not to mention the 90+
properties proposed for the redundant Kendal Auction Mart premises, clearly support my view that
much needed viable/sustainable affordable housing can be provided by the continued availability of
brownfield sites within the district. SLDC continue to maintain that Kendal's housing needs can
only be accommodated on green field sites!
The DPD cannot be considered sound as regards Site Rl21M when words like 'may include
railway drainage' are used (how can reliable decisions be taken on unsubstantiated information) and
'Given the constraint& on the site, it is e:.timated that the site could accommodate around 60
dwellings' (no evidence to suggest SLDC provided itself with sufficient detailed, cos ted and
co-ordinated information to support this statement).
I apologize for the somewhat protracted content of my letter and feel a visit to Site Rl21M by
yourself followed by discussion on its merits over a cup of tea may well have been a more
productive process. Nevertheless. I trust you will give my comments (representation) due
consideration in the hope you may agree that SLDC's DPD in regard to Site Rl21M is unsound and
the site should be removed from any Land Allocations Document as other less sensitive more viable
alternatives exist.
I confirm I have read the DPC Representation Guidance Notes.
I do not wish to participate at the oral examination but have given SOLEK authorisation to represent me at the oral stage of independent evaluation
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
426. Mr John Terence Johnson (Individual) : 4 May 2012 12:14:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA2.3 Land East of Castle Green Road
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Recommend removal of site R121M from any land allocations document in the belief that SLDC's DPD in unsound in respect of the site for reasons stated below:
I would like to question the soundness of South Lakeland District Council's Land Allocations
Development Plan Document in proposing land to the east of Castle Green Road (Site Reference
Rl21M) as being suitable for housing development in spite of substantial public opposition to the
proposal. Given that the visual impact of this high hillside agricultural site had previously been
considered by the Council to be worthy of County Landscape Designation and that the Council
fully acknowledges the site has complex flood issues due to substantial sheet water runoff and
underground watercourses which could see development severely impact on the recent Stock Beck
Flood Alleviation Scheme, it is very difficult to reconcile and justify the Council's criteria in
allocating the site for proposed development.
My understanding of "SOUNDNESS" of the DPD is that it be justified- founded on a robust and
credible evidence base, and yet right from the start of the Council's Land Allocations process Site
Rl21M was judged so negatively for development in SLDC's Fact File site notes that I fail to see
the justification for its continued inclusion as an allocated site. The flooding issue, together with
the substantial infrastructure issues to provide utility services, road access and deal with existing on
site bio-diversity issues which have all been acknowledged by the Council, have not been put to a
RISK/COST ASSESMENT to determine if proposed development of site Rl21M is viable,
sustainable, deliverable or just plain illogical. When and who will conduct a flood risk assessment.
I understand Cumbria County Council has recently become the Lead Local Flood Authority (LLFA)
in Cumbria. If Oak Tree Drive/ Rowan Crescent has an undersized and substandard culvert running
under them I would wish to know answers to the following as it has direct bearing on proposals for
SiteR121M:
1) Why is the culvert inadequate?
2) Who is responsible?
3) Why did SLDC planning not pick up the problem at the planning stage of these
developments?
4) Did the inadequate culvert contribute to the 1999 flooding of Lowther Park I Silverdale
Drive area- we locals remember seeing floodwaters. bursting through garden walls onto
Castle Green Road
5) Does it then really make sense to allow further development behind Oak Tree Road (site
Rl21M) where drainage waters would run into Stockbeck? All other eastern hillside land
draining into the Stock Beck Flood Alleviation Scheme have for good reason been removed
from SLDCs' Land Allocations so why not Site Rl21M?
The fact is that Site Rl21M was never robustly, physically examined at an early stage of the LDFLAND
ALLOCATIONS process to establish or contest sound local knowledge of the site provided
by well meaning individuals with yean of day to day knowledge of the vagaries of the site which is
known to act like an enormous sponge to absorb large amounts of rainfall and therefore assist the
slowdown of its progress to the lower level reaches of the town. Much of the
information/observations provided under the public consultation exercise was disregarded as
objections from residents who are affected by the proposed developments making community
involvement and engagement seem meaningless. The Council requested participation in its Land
Allocations exercise from the local Community/Stakeholders as required of them, but then
seemingly blinded by their desire to achieve targeted housing figures throughout the district, have
chosen to ignore all its own previous sound planning briefs! decisions. regarding Site R 121M,
Kendal Town Council's view that the site should not be developed, reports from Friends of the Lake
District that Rl21M should not be developed and the many residents whose alternative proposals
were just ignored. I attended consultation 'drop in' days with SLDC planning staff in attendance but
attempts to discuss objectively, concerns regarding land allocations were fended off with the
answer "We need to come up with the numbers" - at all cost it would appear!
I understand the present Government is on record as saying it is opposed to top-down targets and
has axed Labour's regional spatial strategies which set development plans for English regions over
15 to 20 years, preferring 'local neighbourhood' input on development strategy.
I fully understand the need to plan for the Town's housing needs but cannot condone the Council's
knee-jerk grab for highly sensitive hillside landscape such as SiteR121M to the ultimate detriment
of the Town's unique quality when other alternative brownfield sites have been proved to be
available and I understood were always a preferred option if available. I appreciate brownfield sites
will not accommodate all the Town's future housing needs but I am being site specific when I state
I am unable to believe a robust and credible evidence base has been established to justify Site
Rl21M 's inclusion for development to provide 60 dwellings, when it is clearly not the most
appropriate strategy to pursue when considered against reasonable alternatives - 60 dwellings
provided by the "Cock & Dolphin" and DSG redevelopment in Kirkland, not to mention the 90+
properties proposed for the redundant Kendal Auction Mart premises, clearly support my view that
much needed viable/sustainable affordable housing can be provided by the continued availability of
brownfield sites within the district. SLDC continue to maintain that Kendal's housing needs can
only be accommodated on green field sites!
The DPD cannot be considered sound as regards Site Rl21M when words like 'may include
railway drainage' are used (how can reliable decisions be taken on unsubstantiated information) and
'Given the constraint& on the site, it is e:.timated that the site could accommodate around 60
dwellings' (no evidence to suggest SLDC provided itself with sufficient detailed, cos ted and
co-ordinated information to support this statement).
I apologize for the somewhat protracted content of my letter and feel a visit to Site Rl21M by
yourself followed by discussion on its merits over a cup of tea may well have been a more
productive process. Nevertheless. I trust you will give my comments (representation) due
consideration in the hope you may agree that SLDC's DPD in regard to Site Rl21M is unsound and
the site should be removed from any Land Allocations Document as other less sensitive more viable
alternatives exist.
I confirm I have read the DPC Representation Guidance Notes.
I do not wish to participate at the oral examination but have given SOLEK authorisation to represent me at the oral stage of independent evaluation
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
427. Mr Richard Johnston (Individual) : 20 Mar 2012 10:37:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - Site Omission
If you have selected a ‘Site omission’ please enter the site reference or location and relevant policy below
Site R209
East of Lindal in Furness (adjacent the A590T)
Policy LA1.3
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The Land Allocations Document (DPD) is not within the Local Development Scheme and the key stages have not been followed
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
There was no public consultation in regard to land allocation prior to the adoption of the core strategy. In particular the draft document allowed for a 'Local Service Centre' at Lindal in Furness and this was excluded from the final document without proper consultation
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Lindal in Furness - I am aware that site R209 was put forward as an alternative site by a number of residents of Swarthmoor and Cross - a - Moor etc. during the latest round of public consultation. Whilst searching on Google for Ore Mill Sidings Lindal, I came across a report dated February 2012 by SLDC www.southlakeland.gov.uk/.../LINDAL%2010%20 FURNESS.pdf The report entitled 'South Lakeland Local Development Framework Land Allocations Development Plan Document' Lindal in Furness Fact File is probably available on SLDC's normal website but I have been unable to find it by this method.
The report acknowledges that the site was regarded as category 1 for sustainability and deliverability in the study commissioned by SLDC. That same study also stated that the site was brown field (it has had a history of industrial use from 1850 to 1962). Previousl;y the Council described the site as derelict with nil use. In the 2012 report the designation has now changed to a green field site. My understanding of the term green field is land that has no history of development whatsoever and this is clearly not the case. I submit that the Council are seeking to mislead the inspector and the general public as well as making it more difficult to obtain planning permission in the future in line with the new NPPF policy.
The comments of the CPRE are contrary to those of the consultants appointed by the SLDC and I doubt if the CPRE have ever visited the site unlike the consultants. The site clearly lies within the confines of the existing village with speed limits, village signing and housing adjacent on two sides, East View and Bank Terrace. I feel that the CPRE comments are generic once they have been provided with certain information by SLDC and the site was not considered by the CPRE in isolation.
With particular regard to site R209, Land at Ulverston Road, Lindal in Furness, the early documents proposed a combination of 89 houses and employment land with the site having been identified as a 'local service centre' and with the site being described as A1, by external consultants, with regard to developability and sustainability. The site is 'brown field' having previously been railway sidings and a crushing mill etc.
In a planning appeal against the refusal for a disabled person's bungalow the council gave as one of their reasons for refusal was that the land had been identified for development in the forthcoming LDF plan.
I considered that the core strategy document in its draft form was sound and that the development of various 'local service centres' was an excellent idea which could meet the needs of local housing, including low cost, and local employment thereby removing the need to travel to work.
Whilst the majority of sites in the draft document are to go ahead, Lindal in Furness, has been excluded.
The reason given by SLDC for the sites exclusion was that it was as a result of objections by the neighbouring authority, Barrow Borough Council, on the basis that it would conflict with their proposed dock development scheme. I have found no evidence of this objection and I am aware that Lindal Parish Council were not consulted.
With regard to the proposed development to the west of Ulverston on green field sites, I am aware that there are major objections from local residents over the loss of farming land and that a number of them put forward the brown field site at Lindal in Furness as one alternative site. The council do not appear to have taken on board the concerns or proposals of residents raised at public consultations.
The question as to the green field sites being available went unanswered at the public consulation and it is my understanding that the land has to be available before it can be identified. No evidence of a willingness to 'sell' was provided by the council with the residents being of the opinion that it was not available.
I am concerned that the planners attending the public consulation held the view that the land they had identified was to to the south of Ulverston when 'South Ulverston' is a totally different area.
This demonstrated a lack of local knowledge and it should be made clear that they meant to develop to the west.
In particular the document does not allow for sufficient low cost housing and I propose that the whole of the site at Lindal in Furness be reinstated as a Local Service Centre in view of local support and the consultants favourable comments
In my own case, my land at Lindal in Furness, an avaialble 6 acre brown field site R209, was identified as category A1 with regard to sustainability by the Council's expert but the SLDC chose to delete it from their options prior to any public consultation. I was content to have the whole site be used for affordable homes (89 houses put forward by consultants) especially as the adjoining 4 acre site had been ientified as employment land. A s the Borough of Barrow in Furness have no development plans for Lindal in Furness and the SLDC have made no provision then the village will continue to decline, which is of course contrary to the National Planning Policy Framework.
The current requirement is for affordable homes and employment. Given that the Councils proposed plans have taken seven years to get to this stage they are not relevant to current needs or Central Governments evolving policies with regard to husing and local development.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
To hear first hand the comments made by SLDC and the reasons for their decisions.
As I have now been diagnosed with Parkinsons and my wife has advanced MS this will be my LAST CHANCE to find a suitable use for the site having tried for the past 25 years.
My two sons have no interest in the site not living locally and no use can be found then it will remain derelict.
Having lived in the area all my life I have a strong local knowledge
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
428. Mr Richard Johnston (Individual) : 20 Mar 2012 15:11:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
1.9
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The Land Allocations Document (DPD) is not within the Local Development Scheme and the key stages have not been followed
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not had regard to the Sustainable Community Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
There was no public consultation in regard to land allocation prior to the adoption of the Core Strategy. In particular the draft document allowed for a 'Local Service Centre' at Lindal in Furness and this was excluded from the final document without proper consultation.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
There was no public consultation in regard to land allocation prior to the adoption of the Core Strategy. In particular the draft document allowed for a 'Local Service Centre' at Lindal in Furness and this was excluded from the final document without proper consultation.
The reason given by SLDC for the sites exclusion was that it was as a result of objections by the neighbouring authority, Barrow Borough Council, on the basis that it would conflict with their proposed dock development scheme. I have found no evidence of this objection and I am aware that Lindal Parish Council were not consulted.
With regard to the proposed development to the west of Ulverston on green field sites, I am aware that there are major objections from local residents over the loss of farming land and that a number of them put forward the brown field site at Lindal in Furness as one alternative site. The council do not appear to have taken on board the concerns or proposals of residents raised at public consultations.
The question as to the green field sites being available went unanswered at the public consulation and it is my understanding that the land has to be available before it can be identified. No evidence of a willingness to 'sell' was provided by the council with the residents being of the opinion that it was not available.
The site numbers M31 and R209 located at Ulverston Road, Lindal in Furness, Cumbria were identified in the draft Core Strategy as part of the 'Local Service Centre' for Lindal in Furness. As originally proposed I considered the proposal to be sound and wrongly assumed that it would proceed through to the allocation of land process.
The sites were removed prior to any public consultation despite being identified as A1 for developability and sustainabiity by independent planning consultants.
At no stage were the public able to comment on this site or the adjoining site R209 as both were removed from the adopted Core Strategy document and all relevant documentation removed or buried in the web site archives.
In the original Core Strategy the site M31 was identified as employment land and would have provided much needed opportuities for local residents.
The sites are brown field having previously been used as railway sidings, a gas works,a wagon repair works, an ore crushing mill and a farm known as Lowfield House.
The Councils officers have missed the opportunity to use a very suitable and more imoprtantly available brown field site and have opted to identify unavailable green field sites and have not given the relevant residents the opportunity to comment at the public consultation days as the sites had already been removed.
The Council have stated that the site was excluded by them due to objections from Barrow Borough Council and that the Council's concerns regarding possible effects on their much delayed docks development. I can find no evidence to support this claim.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
As a local resident for the past 67 years I have knowledge of the local area and current local needs
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
429. Mr Richard Johnston (Individual) : 29 Mar 2012 09:26:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
0.0 Whole Document
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
The DPD has not had regard to the Sustainable Community Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Extract from introduction to NATIONAL PLANNING POLICY FRAMEWORK:
2 ‘Planning law requires that applications for planning permission must be determined in accordance with the development plan,2 unless material considerations indicate otherwise.3 The National Planning Policy Framework must be taken into account in the preparation of local and neighbourhood plans, and is a material consideration in planning decisions.4 Planning policies and decisions must reflect and where appropriate promote relevant EU obligations and statutory requirements’.
If the SLDC’s proposed Development Plan is adopted it will mean that only sites that they have previously identified will be considered for planning approval.
Given that the publication of the National Planning Policy Framework was on the 27th March 2012, reflecting the current governments thinking, how can it be possible that the SLDC’s Development Plan and Local Development Framework Plan, having taken seven years to evolve, be relevant or ‘take into account’ the current National Policy?
Extract from introduction to NATIONAL PLANNING POLICY FRAMEWORK:
7. There are three dimensions to sustainable development: economic, social and environmental. These dimensions give rise to the need for the planning system to perform a number of roles:
an economic role – contributing to building a strong, responsive and competitive economy, by ensuring that sufficient land of the right type is available in the right places and at the right time to support growth and innovation; and by identifying and coordinating development requirements, including the provision of infrastructure;
a social role – supporting strong, vibrant and healthy communities, by providing the supply of housing required to meet the needs of present and future generations; and by creating a high quality built environment, with accessible local services that reflect the community’s needs and support its health, social and cultural well-being; and
environmental role – contributing to protecting and enhancing our natural, built and historic environment; and, as part of this, helping to improve biodiversity, use natural resources prudently, minimise waste and pollution, and mitigate and adapt to climate change including moving to a low carbon economy.
The NPPF states that there should be a presumption in favour of sustainable development but this becomes irrelevant if the SLDC development plan is adopted and only sites that they have identified prior to the LPPF publication will be considered.
In my own case, my land at Lindal in Furness, an available 6 acre brown field site-R209, was identified as category A1 with regard to sustainability by the council’s expert consultants but the SLDC chose to delete it from their options prior to any public consultation. I was content to have the whole site be used for affordable homes (89 houses put forward by consultants) especially as the adjoining 4 acre site had been identified as employment land.
As the Borough of Barrow in Furness have no development plans for Lindal-in-Furness and the SLDC have made no provision then the village will continue to decline, which is of course contrary to the National Planning Policy Framework.
With regard to the economic role element, it would help if the government and/or local councils suspended planning fees, which can run to many thousands of pounds and with no guarantee of approval. As things stands the fees are a deterrent to any applicant irrespective of the size of development.
I suggest that the SLDC plan be scrapped or at least delayed and revised to take account of the current National Planning Policy Framework.
The whole of the plan should be reviewed to take account of the current financial situation, current housing needs and the new NATIONAL PLANNING POLICY FRAMEWORK. A clear policy needs to be developed for sites excluded / not covered by the evolving structure plan especially any that would provide employment opportunities and low cost housing for locals in the very near future. I have no doubt that a lot of good work has been done by the Planning Officers over the past seven years and it should not be necessary to scrap the whole document considering the expense to date.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
For the reasons stated above (at Question 1.3)
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
To hear the evidence put forward by SLDC
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
430. Mr Richard Johnston (Individual) : 14 Apr 2012 09:49:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.8 Local Employment Allocations - Site Omission
If you have selected a ‘Site omission’ please enter the site reference or location and relevant policy below
Site number M31
East of Lindal in Furness, adjacent the A590T
Policy LA1.8 - Local Employment
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The whole of the plan should be reviewed to take account of the current financial situation, current housing needs and the new NATIONAL PLANNING POLICY FRAMEWORK.
A clear policy needs to be developed for sites excluded/not covered by the evolving structure plan especially any that would provide employment opportunities and low cost housing for locals in the very near future.
I have no doubt that a lot of good work has been done by the planning officers over the past seven years and it should not be neccessary to scrap the whole document considering the expence to date.
The site numbers M31 and R209 located at Ulverston Road, Lindal in Furness, Cumbria were identiifed in the draft core strategy as part of a Local Service Centre for Lindal in Furness. As originally proposed I considered the proposal to be sound and wrongly assumed that it would proceed through to the allocation of land process.
The sites were removed prior to any public consultation despite being identified as A1 for developability and sustainabiity by independent planning consultants.
At no stage were the public able to comment on this site or the adjoining site R209 as both were removed from the adopted Core Strategy document and all relevant documentation removed or buried in the web site archives.
In the original Core Strategy the site M31 was identified as employment land and would have provided much needed opportuities for local residents.
The sites are brown field having previously been used as railway sidings, a gas works,a wagon repair works, an ore crushing mill and a farm known as Lowfield House.
The Council's policy of concentrating employment employment and housing in the main settlement areas of Kendal, Ulverston and although not in the SLDC area, Barrow in Furness, does not allow any choice for the numerous residents of the many surrounding villages with the majority of residents required to travel considerable distances to work. The policy does nothing to address the cost of travel either financially or environmentally and does not address rural or agricultural specific needs which are not pertinent to the main settlements.
The Council's Officers have missed the opportunity to use a very suitable and more importantly available brown field site and have opted to identify unavaialble green field sites and have not given the relevant residents the opportunity to comment at the public consultation days as the sites had already been removed.
The Council have stated that the site was excluded by them due to objections from Barrow Borough Council and that Councils concerns regarding possible effects on their much delayed docks development. I can find no evidence to support this claim.
I am aware that some residents of Ulverston, Swarthmoor and Cross - a - Moor objected to the use of their surrounding green fields and nominated the brown field site at Lindal as one alternative, this being due to local knowledge and not the LDF documents. I can find no evidence that the Council have considered the residents proposal. I propose that the relevant sites are reinstated.
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Lindal in Furness
The whole of the plan should be reviewed to take account of the current financial situation, current housing needs and the new NATIONAL PLANNING POLICY FRAMEWORK.
A clear policy needs to be developed for sites excluded/not covered by the evolving structure plan especially any that would provide employment opportunities and low cost housing for locals in the very near future.
I have no doubt that a lot of good work has been done by the planning officers over the past seven years and it should not be neccessary to scrap the whole document considering the expence to date.
The site numbers M31 and R209 located at Ulverston Road, Lindal in Furness, Cumbria were identiifed in the draft core strategy as part of a Local Service Centre for Lindal in Furness. As originally proposed I considered the proposal to be sound and wrongly assumed that it would proceed through to the allocation of land process.
The sites were removed prior to any public consultation despite being identified as A1 for developability and sustainabiity by independent planning consultants.
At no stage were the public able to comment on this site or the adjoining site R209 as both were removed from the adopted Core Strategy document and all relevant documentation removed or buried in the web site archives.
In the original Core Strategy the site M31 was identified as employment land and would have provided much needed opportuities for local residents.
The sites are brown field having previously been used as railway sidings, a gas works,a wagon repair works, an ore crushing mill and a farm known as Lowfield House.
The Council's policy of concentrating employment employment and housing in the main settlement areas of Kendal, Ulverston and although not in the SLDC area, Barrow in Furness, does not allow any choice for the numerous residents of the many surrounding villages with the majority of residents required to travel considerable distances to work. The policy does nothing to address the cost of travel either financially or environmentally and does not address rural or agricultural specific needs which are not pertinent to the main settlements.
The Council's Officers have missed the opportunity to use a very suitable and more importantly available brown field site and have opted to identify unavaialble green field sites and have not given the relevant residents the opportunity to comment at the public consultation days as the sites had already been removed.
The Council have stated that the site was excluded by them due to objections from Barrow Borough Council and that Councils concerns regarding possible effects on their much delayed docks development. I can find no evidence to support this claim.
I am aware that some residents of Ulverston, Swarthmoor and Cross - a - Moor objected to the use of their surrounding green fields and nominated the brown field site at Lindal as one alternative, this being due to local knowledge and not the LDF documents. I can find no evidence that the Council have considered the residents proposal. I propose that the relevant sites are reinstated.
I am aware that site R209 was put forward as an alternative site by a number of residents of Swarthmoor and Cross-a-Moor etc. during the latest round of public consultation.
Whilst searching on Google for Ore Mill Sidings Lindal, I came across a report dated February 2012 by SLDC www.southlakeland.gov.uk/.../LINDAL%20IN%20FURNESS.pdf The report entitled ‘South Lakeland Local Development Framework Land Allocations Development Plan Document’ Lindal in Furness Fact File is probably available on SLDC’s normal website but I have been unable to find it by this method.
The report acknowledges that the site was regarded as category 1 for sustainability and deliverability in the study commissioned by SLDC. That same study also stated that the site was ‘brownfield’ (it has had a history of industrial use from 1850 to 1962). Previously the council described the site as ‘derelict with nil use’
In the 2012 report the designation has now changed to a ‘greenfield’ site. My understanding of the term ‘greenfield’ is land that has no history of development whatsoever and this is clearly not the case. I submit that the council are seeking to mislead the inspector and the general public as well as making it more difficult to obtain planning permission in the future in line with the new NPPF policy.
The comments by the CPRE are contrary to those of the consultants appointed by the SLDC and I doubt if the CPRE have ever visited the site unlike the consultants. The site clearly lies within the confines of the existing village with speed limits, village signing and housing adjacent on two sides, East View and Bank Terrace. I feel that the CPRE comments are generic once they have been provided with certain information by SLDC and the site was not considered by the CPRE in isolation.
The Borough of Barrow in Furness currently have no plans for the village and I am not aware of any suitable sites being available in the part of the village covered by that authority, but I am sure SLDC will already know this. I understand that Barrow wish to concentrate on their proposed dock development scheme and already have enough sites for their purposes. I have also received confirmation that the Barrow Borough Council raised no objections to any proposed development at the Ore Mill Sidings, Lindal
The report also states that site ‘M31 will is also considered as a strategic employment site’ but I am not sure what this means. I think that at some stage R209 formed part of M31 and it maybe that the council are still considering the site for employment.
From my point of view and given the post 2008 financial situation I would welcome any commercial operation that provided the opportunity of employment for local residents with a number of low cost houses.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
To hear the comments of the planning department first hand
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
431. Mr Peter Johnston (Individual) : 26 Apr 2012 10:36:00
A typed or handwritten document was submitted. This has been scanned and can be downloaded below:
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.6 Strategic Employment Sites - E4M KENDAL LAND AT SCROGGS WOOD, MILNTHORPE ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Fails to adequately consider the need for detailed investigation into the impact of noise and visual impairment on adjoining residential area (Bellingham Road) - inadequate baseline information, see text below:
The document makes reference to 'Landscaping and Buffering' but gives no details.
The document makes no reference (that I can find) to the likely effect of noise pollution or visual impact on local residents.
Print of area in winter (see attached photograph) clearly shows that Scroggs Wood itself is totally inadequate as a screen (visual) for 6 months of the year.
The statement in 3.34 - that Scroggs Wood screens the site is incorrect.
A visit to SLDC offices was NOT helpful - I was told that no detail regarding the type or distance of buffering / screening has yet to be drawn up. Therefore how can residents assess the plan - it is flawed in soundness - in that decisions are to be made without residents being satisfied regarding this element.
3.35 suggests that the main consideration is screening to the south & east edges but as before Scroggs Wood itself is inadequate.
To the best of my knowledge the document makes no reference to a study on noise pollution to the local residential area, and therefore fails to show any sustainability or soundness.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Fails to explain 'other than reference to' sidnificant landscaping and robust buffering requirements - any details regarding the proposal (see text below and attached photograph).
The document makes reference to 'Landscaping and Buffering' but gives no details.
The document makes no reference (that I can find) to the likely effect of noise pollution or visual impact on local residents.
Print of area in winter (see attached photograph) clearly shows that Scroggs Wood itself is totally inadequate as a screen (visual) for 6 months of the year.
The statement in 3.34 - that Scroggs Wood screens the site is incorrect.
A visit to SLDC offices was NOT helpful - I was told that no detail regarding the type or distance of buffering / screening has yet to be drawn up. Therefore how can residents assess the plan - it is flawed in soundness - in that decisions are to be made without residents being satisfied regarding this element.
3.35 suggests that the main consideration is screening to the south & east edges but as before Scroggs Wood itself is inadequate.
To the best of my knowledge the document makes no reference to a study on noise pollution to the local residential area, and therefore fails to show any sustainability or soundness.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
432. Mr Richard Johnston (Individual) : 22 May 2012 15:48:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
1.10
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The Land Allocations Document (DPD) is not within the Local Development Scheme and the key stages have not been followed
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not had regard to the Sustainable Community Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
There was no public consultation in regard to land allocation prior to the adoption of the Core Strategy. In particular the draft document allowed for a 'Local Service Centre' at Lindal in Furness and this was excluded from the final document without proper consultation.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The reason given by SLDC for the sites exclusion was that it was as a result of objections by the neighbouring authority, Barrow Borough Council, on the basis that it would conflict with their proposed dock development scheme. I have found no evidence of this objection and I am aware that Lindal Parish Council were not consulted.
With regard to the proposed development to the west of Ulverston on green field sites, I am aware that there are major objections from local residents over the loss of farming land and that a number of them put forward the brown field site at Lindal in Furness as one alternative site. The council do not appear to have taken on board the concerns or proposals of residents raised at public consultations.
The question as to the green field sites being available went unanswered at the public consulation and it is my understanding that the land has to be available before it can be identified. No evidence of a willingness to 'sell' was provided by the council with the residents being of the opinion that it was not available.
I am concerned that the planners attending the public consulation held the view that the land they had identified was to to the south of Ulverston when 'South Ulverston' is a totally different area.
This demonstrated a lack of local knowledge and it should be made clear that they meant to develop to the west.
In particular the document does not allow for sufficient low cost housing and I propose that the whole of the site at Lindal in Furness be reinstated as a Local Service Centre in view of local support and the consultants favourable comments
I am aware that some residents of Ulverston, Swarthmoor and Cross - a - Moor objected to the use of their surrounding green fields and nominated the brown field site at Lindal as one alternative, this being due to local knowledge and not the LDF documents. I can find no evidence that the Council have considered the residents proposal. I propose that the relevant sites are reinstated.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
To hear the comments of the planning department first hand.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
433. Mrs Joan Jolly (Individual) : 4 May 2012 15:24:00
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I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - M41M ENDMOOR NORTH OF SYCAMORE DRIVE
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
M41M:
The number & density of properties proposed in one field alone are 55 (30/ha), far too many. There should be plenty space; car parking; landscaping, etc. There are 34 homes in Sycamore Close on the same size of land & lessons should be learned re congestion & the mistakes made. Properties too close together; small gardens; parking facilities atrocious - no room for two cars, therefore cars are parking on the roadway, half on pavement & in some cases in front of other residents homes. Cars are needed to travel to work - very little work locally. Public transport facilities/ routes are very limited & nowhere near sufficient now! There would be far more traffic, it would be a lot busier & would make the word 'estate' more prevalent.
There are no amenities locally - no post office, Dr., dentist, etc. just one little shop & bakery.
Access would also be a big issue & particular care should be taken as to any risk to the drumlins. If some properties are going to be smaller & with no garages, parking would be a major problem.
The impact on the area would be less presentable from all aspects & it would lower the district's appeal to tourists.
We need open spaces between villages as against developing into urban sprawl.
There is difficulty selling property now! Who are going to want to move, especially where there are no facilities?
Lack of services in village do not match needs. Proper thought out planning is of major importance in such a development from a village aspect. The village will lose what attracted us here - its appeal. I would not be a village any more.
No development should be allowed to take place until an agreed infrastructure plan with united utilities, to cope with increase capacity of sewage, has taken place.
To retain the character of the village & maintain landscaping areas, the new property should be in comparison to the rest of the village with bungalows & single storey affordable homes which, from a recent housing needs survey, only ten of these are required.
R83: Allegedly, the DPD has left out original proposals on Birchfield & Birchfield scored better than other sites.
R670: Dovenest's proposed numbers have been reduced, when this site is well placed to retain a village appearance.
100 homes in total - this needs to be reduced; impact on greenfield land & aspects of landscape.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
434. Mrs Joan Jolly (Individual) : 4 May 2012 15:25:00
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I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - All Endmoor sites
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
M41M:
The number & density of properties proposed in one field alone are 55 (30/ha), far too many. There should be plenty space; car parking; landscaping, etc. There are 34 homes in Sycamore Close on the same size of land & lessons should be learned re congestion & the mistakes made. Properties too close together; small gardens; parking facilities atrocious - no room for two cars, therefore cars are parking on the roadway, half on pavement & in some cases in front of other residents homes. Cars are needed to travel to work - very little work locally. Public transport facilities/ routes are very limited & nowhere near sufficient now! There would be far more traffic, it would be a lot busier & would make the word 'estate' more prevalent.
There are no amenities locally - no post office, Dr., dentist, etc. just one little shop & bakery.
Access would also be a big issue & particular care should be taken as to any risk to the drumlins. If some properties are going to be smaller & with no garages, parking would be a major problem.
The impact on the area would be less presentable from all aspects & it would lower the district's appeal to tourists.
We need open spaces between villages as against developing into urban sprawl.
There is difficulty selling property now! Who are going to want to move, especially where there are no facilities?
Lack of services in village do not match needs. Proper thought out planning is of major importance in such a development from a village aspect. The village will lose what attracted us here - its appeal. I would not be a village any more.
No development should be allowed to take place until an agreed infrastructure plan with united utilities, to cope with increase capacity of sewage, has taken place.
To retain the character of the village & maintain landscaping areas, the new property should be in comparison to the rest of the village with bungalows & single storey affordable homes which, from a recent housing needs survey, only ten of these are required.
R83: Allegedly, the DPD has left out original proposals on Birchfield & Birchfield scored better than other sites.
R670: Dovenest's proposed numbers have been reduced, when this site is well placed to retain a village appearance.
100 homes in total - this needs to be reduced; impact on greenfield land & aspects of landscape.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
435. Mr Alan Jones (Individual) : 5 Apr 2012 10:30:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
0.0 Whole Document
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
The DPD has not had regard to the Sustainable Community Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The SCI failed to deliver effective and adequate consultation with the community resulting in real and meaningful dialogue. Points raised by residents were noted but then largely ignored. Alternative approaches not in line with the SLDC preferred options were not seriously addressed. The final allocations of land in Grange-over-Sands and Allithwaite as selected by SLDC, pay no regard to the wishes of the community. It ignores provision for neighbourhood planning in the allocation process which could have delivered a community wide acceptance of a plan.
SLDC have engendered opposition and resentment by riding rough shod over the wishes of the community. People feel detached from what is proposed and feel plans for their community are being imposed from on high. This is not consultation and is not consistent with national policy on 'Localism'.
The sustainability statement is not based on hard evidence. There has not been effective collaboration at county and district level and sound evidence on which to base the appraisal has not been forthcoming. The natural and man made environment of Grange-over-Sands, Kents Bank and Allithwaite has not been systematically nor scientifically assessed and SLDC proposals would destroy many of the features cherished by residents and visitors. The report is silent on accepted reference standards and how this area measures against them.
The SCS points up the importance of the natural environment, its attractions and the area's heritage yet the DPD makes proposals which will destroy or damage these in the case of Grange-over-Sands, Kents Bank and Allithwaite. Tourism is a major income provider yet who would come to the area if green spaces are destroyed, valued vistas blocked from view and significantly increased traffic channeled through what is currently a pleasant Victorian town.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
In the case of Grange-over-Sands the needs figures do not accord with past experience. The presumptions made are questionable and based on out of date figures. The area is evolving as older premises are redeveloped and small sites within the community become available for housing. Brown field sites within the community have not all been used. There is not a demonstrable case for building on greenfield sites in the area. 15/25 residences per year will produce up to 500 dwellings in 20 years and the past suggests this rate of renewal might be expected. Green field sites should be removed from the DPD for Grange and Kents Bank.
The plans do not retain significant and appropriate green gaps between Kents Bank and Allithwaite contrary to CS4.
The plans are not deliverable without major changes to the infrastructure - water, electricity, sewerage, roads, transport etc. The report is silent on how these essentials would be met. Grange-over-Sands could not withstand throughput of extra traffic without destruction of the essential character of the town and residential areas to wit Main Street and Risedale. The plans if implemented would be contrary to the Environmental Objectives in the Sustainability Appraisal Report.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
436. Mr Peter Jones (Individual) : 10 Apr 2012 13:52:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
0.0 Whole Document
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The Statement of Community Involvement adopted on 13th September 2006, promised to inform the community throughout negotiations,allowing for early and on-going input at stages where responses can make a difference and selecting methods/techniques and venues which maximise the opportunity for all groups to take part and respond including the "hard to reach" groups. Community involvement has been negligible in our part of the village. The proposal put forward to include land marked M32#Mod which forms a boundary to our property only came to our attention on Monday 25th March 2012. We learnt this information by way of a single A4 piece of paper entitled Lower Allithwaite Parish Council Issue no.28 newsletter which was posted through our letterbox. This form of communication with regards to a hugely important matter is not acceptable. We understand that the parcel of land (M32) was submitted in September 2011 and was highlighted as being suitable for mixed residential/employment. However, it was later withdrawn, modified and re-submitted half its original size in January 2012 as being suitable for residential land. When we had the opportunity of looking at the draft copy on Sunday 1st April 2012, no mention was given to land behind Almond Bank (M32). This was because the draft copy referred to the land incorrectly as being land at Lane End which results in confusion! We also understand that of the many sites examined for these proposals, Allithwaite Parish Council had a strong preference for a piece of land marked RN230 but this was overruled by the SLDC. Understanding that the Government is committed to decision making at local level I find it inconceivable that after 3 years of research that we have not been directly invited to participate in these proposals.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Brown field sites within the community have not been used. There is not a demonstrable case for building on greenfield sites in ths area. The plans are not deliverable without major changes to the infrastructure - water, electricity, sewerage, transport and most importantly roads. M32#Mod is situated on a twisty piece of road with its entrance being on the a-pex of a blind corner. This is an extremely busy road forming the major route between Grange-Over-Sands, Flookburgh, Cark and Ravenstown and has both narrows to negotiate and no pedestrian footpath possibilities. With regards to the access, we cannot understand how the Highways Authority could have considered this access as being suitable for 11 dwellings when planning permission was turned down for dwellings on the opposite side of the road to the field M32 on the grounds as dangerous access!! An important factor is the suitability of the site M32 for families when there is no pavement running through this part of the village.
We also understand that there may well be historical archeological significance with regard to this land.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
437. Miss Victoria Jones (Individual) : 13 Apr 2012 15:34:00
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I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - RN131M,RN141#, RN321# &RN284# Ulverston - Gascow Farm
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The DPD has not had regard to the Sustainable Community Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
These new proposals would destroy the environmental character of many parts of the town especially as theses parts are on green land. Many of these green land areas are of agricultural use. The loss of this land would be economically inviable.
There is brown land space in near by areas to Ulverston that lie in Furness. These need to be considered as well.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
At the beginning of the consultation only part of Gascow Farm was considered for building. To begin with this was not sound as it is classed as green land. After the initial consultation the whole of the area has been put forward for building work after the commendation of a building firm. This is not listening to the voice of the residents, this was listening to people who fit in with the plans. Gascow Farm has already been denied planning permission in the past because of flooding problems. Why are these problems now being overlooked? The plan to build houses of this scale in Ulverston in absurd. For a start many houses lie empty and they are being ignored. Secondly there are plenty of houses already for sale in the area. John Woodcock MP has also pointed out that Barrow has plenty of brown space areas to offer and yet have not been consulted. Why ignore brown space land in the area for the sake of destroying green land which should be protected. Ulverston is already struggling to maintain the town with many pot holed roads still not being fixed and services, such as recycling facilities, being cut. A new estate of the size being proposed would cripple the infrastructure of the town. I also don't agree with how the decisions are being made in Kendal. It seems convenient that Ulverston is one of the towns with the most amount of housing and opinions in this town are being ignored. New housing would introduce new people to the area not help local people in need of housing.
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
Brown land in the Furness area would be of more benefit so I feel that they need to take part in these consultations.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
438. Mr. Philip Jones (Individual) : 15 Apr 2012 00:37:00
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I have read the guidance notes
Policy/Site No.
LA1.1 Development Boundaries- ENDMOOR
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The consultation which took place was based on a plan for 62 houses at site M41-mod (land to the north of Sycamore Close). The plan now is for 100 homes but there has been no consultation based on this number. If this really is considered to be "legally compliant" I suggest that we need to take another look at the meaning of the words. There should now be a proper and full consultation based on the DPD which ought first to be amended to reflect a more accurate assessment of the actual level of need in the community. At the moment the DPD looks very much like an ill-considered and badly researched "stick on" determined in a most arbitrary manner which does not in any way reflect the actual level of need. Instead the DPD appears to be a rather clumsy attempt to provide plans which satisfy the broad brush approach of HMG. I acknowledge the need for the village to be allowed to grow but not by 30% in area at a stroke. The scale of the growth should not be allowed to rob Endmoor of its village status by turning it into a small town without the services normally associated with a small town.
The DPD does not accord with the following principles set out in The Core Strategy;
CS1.1.1; CS1.1.2; CS1.1.3; CS1.1.6; CS1.1.7; CS1.1.8; CS1.1.9; CS1.1.11;
In general terms, the DPD does not enhance the the resilience of the natural environment, nor does it minimise the use of non-renewable resources. It fails to protect the countryside for its intrinsic beauty etc.. It most certainly fails to minimise the need for travel. On the contrary, it serves only to guarantee the need for even more travel and the consequent increase in the use of fuel. Endmoor lacks the necessary services, infrastructure and employment opportunities to support such a large development. It is, quite simply, too much too fast.
1.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
I fully recognise the need for SOME new homes in the village but the level of need has not been properly quantified. The DPD figures are clumsily prepared and applied from without the community and do not reflect the actual need.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The DPD for both housing and commercial sites is not sound because there is no clear strategy with regard to waste water treatment.The infrastructure is not in place for such a large increase in the number houses and this makes the DPD unsustainable and undeliverable. The DPD alludes (without being specific) to a new sewage treatment plant at Low Park; the general assumption among local people is that SLDC mean this to be a massive enlargement of the existing plant and yet the landowner has not been consulted.
The road network is incapable of safely supporting the increase in traffic which would be expected if the mixed commercial site is developed at sites EN20 and EN33; this brings me to my objection to these developments on the grounds that there is no demonstrable demand for more commercial premises in this locality; there is already unused commercial capacity at Summerlands, Gatebeck Business Park and in the ongoing development at Jct. 36. The whole enterprise seems to assume a level of demand which does not exist. With spare commercial capacity already available in the village it would be nonsensical to provide even more to the great detriment of the greenfield areas and the wonderful drumlin landscape. Once this landscape is covered in units of one sort or another it is lost forever and to achieve what? An even greater surplus of unwanted premises.
In order to make the DPD acceptable the following steps should be taken;
Fresh consultations with local people to consider the DPD as it looks after these changes are made
Assess the real level of need for new housing whilst bearing in mind the parlous state of the economy, the available infrastructure and level of services.
Reduce the density and number of houses and incorporate in the design green recreational areas and stipulate that each new dwelling must have sufficient off-road parking so as to allow service and emergency vehicles proper access.
Set a much more reasonable limit (the DPD seeks to increase it by 30%) on the amount by which the footprint of the village can be increased. This to protect the character of Endmoor and its status as a village.
Abandon the plans to provide any more commercial premises because there are no reasonable grounds for believing that these are required.
Consider (and consult locally) more suitable alternatives for the siting of the proposed new sewage treatment plant.
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
I cannot support the DPD in its present form.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
439. Mr Alan C Jones (Individual) : 16 Apr 2012 14:48:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - All Allithwaite sites
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
South Lakeland District Council have conducted all aspects of the Proposed Land Allocations Document very much on a "need to know" basis, with all dealings dressed in jargon and abbreviations.
It is a fair guess to say that most of the local population are ignorant of the detail of it's proposals. I do not consider that enough effort has been made to engage stakeholders, with the exception of land owners and developers.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I think all residential development in Allithwaite is ill advised, paticularly on the field M32#.Recent Government planning guidlines state that development should be such as to encourage the use of public transport,walking, cycling. Allithwaite has next to no public transport. Cycling on the busy narrow and hilly B5277, the only artery towards employment and ameneties would be very ill advised. Pedestrian access to any housing at M32# would be along a very narrow twisty stretch of road without footpath.
I consider much of SLDC's DPD to be out of line with current Government Guidlines and should be subject to large scale ammendment.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
440. Mrs Valerie Jones (Individual) : 27 Apr 2012 16:45:00
Policy/Site No.
LA1.3 Housing Allocations - R110 GRANGE-OVER-SANDS SOUTH OF THORNFIELD ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I hereby give the reasons for not building on the field adjoining Kents Bank Rd & Thornfield Rd:
1) About 20 years ago planning permission was sougth for building on this field (known as Trickets field). It was turned down chiefly because of access. Since then the traffic flow has substantially increased and at times it is almost impossible to get out of Thornfield Rd or Methven Rd onto Kents Bank Rd.
2) There is absolutely no need for more housing in Grange as there are numerous houses & flats up for sale which are not selling.
3) There is no such thing as affordable housing as the high cost young people pay (my grandchildren included) prevents them being able to save for a deposit to get on the housing ladder.
4) Grange is unique ad should remain that way and ot become a concrete jungle like so many places. If there have to be new houses, the 'new' swimming pool should be knocked down (an eyesore) and houses built there.
5) Finally, the above mentioned field is the only place where you can look down from the road to the wonderful views of the Bay. It is full of rare birds & animals & used by the local farmer for his cows. Where will they go if it is built on?
For goodness sake leave a bit of green in Grange!
441. C Jones (Individual) : 8 May 2012 13:00:00
Policy/Site No.
LA1.3 Housing Allocations - R697 & part R242 ULVERSTON CROFTLANDS EAST
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
It is unnecessary to destroy green space when there are areas that need to be redeveloped ("eyesores" to the area) and brown field sites. Don't take the beauty and tourist appeal out of the area.
We need to keep farm land for that purpose.
The site from Colthouse Lane to Priory Road would become over-developed - do we really need this number of houses in Ulverston?
Please re-think the long term impact on our area if you continue to destroy our 'green spaces' - don't destroy our countryside.
442. C Jones (Individual) : 8 May 2012 13:04:00
Policy/Site No.
LA1.3 Housing Allocations - R690ulv, R691ULV, R126M, RN184, RN234# & part R242 ULVERSTON CROFTLANDS WEST - NOOK FARM
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
It is unnecessary to destroy green space when there are areas that need to be redeveloped ("eyesores" to the area) and brown field sites. Don't take the beauty and tourist appeal out of the area.
We need to keep farm land for that purpose.
The site from Colthouse Lane to Priory Road would become over-developed - do we really need this number of houses in Ulverston?
Please re-think the long term impact on our area if you continue to destroy our 'green spaces' - don't destroy our countryside.
443. C Jones (Individual) : 8 May 2012 13:06:00
Policy/Site No.
LA1.3 Housing Allocations - RN131M,RN141#, RN321# &RN284# Ulverston - Gascow Farm
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
It is unnecessary to destroy green space when there are areas that need to be redeveloped ("eyesores" to the area) and brown field sites. Don't take the beauty and tourist appeal out of the area.
We need to keep farm land for that purpose.
The site from Colthouse Lane to Priory Road would become over-developed - do we really need this number of houses in Ulverston?
Please re-think the long term impact on our area if you continue to destroy our 'green spaces' - don't destroy our countryside.
444. Mrs Valerie Jones (Individual) : 11 May 2012 11:34:00
Policy/Site No.
LA3.1 Mixed Use Allocation at Berners Pool, Grange-over-Sands
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
2) There is absolutely no need for more housing in Grange as there are numerous houses & flats up for sale which are not selling.
3) There is no such thing as affordable housing as the high cost young people pay (my grandchildren included) prevents them being able to save for a deposit to get on the housing ladder.
4) Grange is unique ad should remain that way and ot become a concrete jungle like so many places. If there have to be new houses, the 'new' swimming pool should be knocked down (an eyesore) and houses built there.
For goodness sake leave a bit of green in Grange!
445. Mrs Valerie Jones (Individual) : 11 May 2012 11:50:00
Policy/Site No.
LA3.2 Mixed Use Allocation at Land South of Allithwaite Road, Kent's Bank, Grange-over-Sands
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
2) There is absolutely no need for more housing in Grange as there are numerous houses & flats up for sale which are not selling.
3) There is no such thing as affordable housing as the high cost young people pay (my grandchildren included) prevents them being able to save for a deposit to get on the housing ladder.
4) Grange is unique ad should remain that way and ot become a concrete jungle like so many places. If there have to be new houses, the 'new' swimming pool should be knocked down (an eyesore) and houses built there.
For goodness sake leave a bit of green in Grange!
446. Mrs Valerie Jones (Individual) : 11 May 2012 11:51:00
Policy/Site No.
LA3.3 Mixed Use Allocation at Guide's Lot, Grange-over-Sands
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
2) There is absolutely no need for more housing in Grange as there are numerous houses & flats up for sale which are not selling.
3) There is no such thing as affordable housing as the high cost young people pay (my grandchildren included) prevents them being able to save for a deposit to get on the housing ladder.
4) Grange is unique ad should remain that way and ot become a concrete jungle like so many places. If there have to be new houses, the 'new' swimming pool should be knocked down (an eyesore) and houses built there.
For goodness sake leave a bit of green in Grange!
447. Mrs Valerie Jones (Individual) : 14 May 2012 10:27:00
Policy/Site No.
LA1.3 Housing Allocations - All Grange-over-Sands sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I hereby give the reasons for not building on the field adjoining Kents Bank Rd & Thornfield Rd:
1) About 20 years ago planning permission was sougth for building on this field (known as Trickets field). It was turned down chiefly because of access. Since then the traffic flow has substantially increased and at times it is almost impossible to get out of Thornfield Rd or Methven Rd onto Kents Bank Rd.
2) There is absolutely no need for more housing in Grange as there are numerous houses & flats up for sale which are not selling.
3) There is no such thing as affordable housing as the high cost young people pay (my grandchildren included) prevents them being able to save for a deposit to get on the housing ladder.
4) Grange is unique ad should remain that way and ot become a concrete jungle like so many places. If there have to be new houses, the 'new' swimming pool should be knocked down (an eyesore) and houses built there.
5) Finally, the above mentioned field is the only place where you can look down from the road to the wonderful views of the Bay. It is full of rare birds & animals & used by the local farmer for his cows. Where will they go if it is built on?
For goodness sake leave a bit of green in Grange!
448. Mrs Valerie Jones (Individual) : 14 May 2012 10:45:00
Policy/Site No.
LA3.1 Mixed Use Allocation at Berners Pool, Grange-over-Sands
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
Yes
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
If there have to be new houses, the 'new' swimming pool should be knocked down (an eyesore) and houses built there.
449. Mr Alan C Jones (Individual) : 15 May 2012 10:07:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - M32#-mod ALLITHWAITE LAND AT LANE ENDS
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I think all residential development in Allithwaite is ill advised, paticularly on the field M32#.Recent Government planning guidlines state that development should be such as to encourage the use of public transport,walking, cycling. Allithwaite has next to no public transport. Cycling on the busy narrow and hilly B5277, the only artery towards employment and ameneties would be very ill advised. Pedestrian access to any housing at M32# would be along a very narrow twisty stretch of road without footpath.
I consider much of SLDC's DPD to be out of line with current Government Guidlines and should be subject to large scale ammendment.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
450. Mr Alan C Jones (Individual) : 15 May 2012 10:11:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
1.9
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
South Lakeland District Council have conducted all aspects of the Proposed Land Allocations Document very much on a "need to know" basis, with all dealings dressed in jargon and abbreviations.
It is a fair guess to say that most of the local population are ignorant of the detail of it's proposals. I do not consider that enough effort has been made to engage stakeholders, with the exception of land owners and developers.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
451. Mr Peter Jones (Individual) : 15 May 2012 12:29:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - M32#-mod ALLITHWAITE LAND AT LANE ENDS
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The Statement of Community Involvement adopted on 13th September 2006, promised to inform the community throughout negotiations,allowing for early and on-going input at stages where responses can make a difference and selecting methods/techniques and venues which maximise the opportunity for all groups to take part and respond including the "hard to reach" groups. Community involvement has been negligible in our part of the village. The proposal put forward to include land marked M32#Mod which forms a boundary to our property only came to our attention on Monday 25th March 2012. We learnt this information by way of a single A4 piece of paper entitled Lower Allithwaite Parish Council Issue no.28 newsletter which was posted through our letterbox. This form of communication with regards to a hugely important matter is not acceptable. We understand that the parcel of land (M32) was submitted in September 2011 and was highlighted as being suitable for mixed residential/employment. However, it was later withdrawn, modified and re-submitted half its original size in January 2012 as being suitable for residential land. When we had the opportunity of looking at the draft copy on Sunday 1st April 2012, no mention was given to land behind Almond Bank (M32). This was because the draft copy referred to the land incorrectly as being land at Lane End which results in confusion! We also understand that of the many sites examined for these proposals, Allithwaite Parish Council had a strong preference for a piece of land marked RN230 but this was overruled by the SLDC. Understanding that the Government is committed to decision making at local level I find it inconceivable that after 3 years of research that we have not been directly invited to participate in these proposals.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Brown field sites within the community have not been used. There is not a demonstrable case for building on greenfield sites in ths area. The plans are not deliverable without major changes to the infrastructure - water, electricity, sewerage, transport and most importantly roads. M32#Mod is situated on a twisty piece of road with its entrance being on the a-pex of a blind corner. This is an extremely busy road forming the major route between Grange-Over-Sands, Flookburgh, Cark and Ravenstown and has both narrows to negotiate and no pedestrian footpath possibilities. With regards to the access, we cannot understand how the Highways Authority could have considered this access as being suitable for 11 dwellings when planning permission was turned down for dwellings on the opposite side of the road to the field M32 on the grounds as dangerous access!! An important factor is the suitability of the site M32 for families when there is no pavement running through this part of the village.
We also understand that there may well be historical archeological significance with regard to this land.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
452. Mr Peter Jones (Individual) : 15 May 2012 12:34:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
1.9
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The Statement of Community Involvement adopted on 13th September 2006, promised to inform the community throughout negotiations,allowing for early and on-going input at stages where responses can make a difference and selecting methods/techniques and venues which maximise the opportunity for all groups to take part and respond including the "hard to reach" groups. Community involvement has been negligible in our part of the village. The proposal put forward to include land marked M32#Mod which forms a boundary to our property only came to our attention on Monday 25th March 2012. We learnt this information by way of a single A4 piece of paper entitled Lower Allithwaite Parish Council Issue no.28 newsletter which was posted through our letterbox. This form of communication with regards to a hugely important matter is not acceptable. We understand that the parcel of land (M32) was submitted in September 2011 and was highlighted as being suitable for mixed residential/employment. However, it was later withdrawn, modified and re-submitted half its original size in January 2012 as being suitable for residential land. When we had the opportunity of looking at the draft copy on Sunday 1st April 2012, no mention was given to land behind Almond Bank (M32). This was because the draft copy referred to the land incorrectly as being land at Lane End which results in confusion! We also understand that of the many sites examined for these proposals, Allithwaite Parish Council had a strong preference for a piece of land marked RN230 but this was overruled by the SLDC. Understanding that the Government is committed to decision making at local level I find it inconceivable that after 3 years of research that we have not been directly invited to participate in these proposals.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
453. Mr Alan Jones (Individual) : 15 May 2012 13:04:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - All Allithwaite sites
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
The DPD has not had regard to the Sustainable Community Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The SCI failed to deliver effective and adequate consultation with the community resulting in real and meaningful dialogue. Points raised by residents were noted but then largely ignored. Alternative approaches not in line with the SLDC preferred options were not seriously addressed. The final allocations of land in Grange-over-Sands and Allithwaite as selected by SLDC, pay no regard to the wishes of the community. It ignores provision for neighbourhood planning in the allocation process which could have delivered a community wide acceptance of a plan.
SLDC have engendered opposition and resentment by riding rough shod over the wishes of the community. People feel detached from what is proposed and feel plans for their community are being imposed from on high. This is not consultation and is not consistent with national policy on 'Localism'.
The sustainability statement is not based on hard evidence. There has not been effective collaboration at county and district level and sound evidence on which to base the appraisal has not been forthcoming. The natural and man made environment of Grange-over-Sands, Kents Bank and Allithwaite has not been systematically nor scientifically assessed and SLDC proposals would destroy many of the features cherished by residents and visitors. The report is silent on accepted reference standards and how this area measures against them.
The SCS points up the importance of the natural environment, its attractions and the area's heritage yet the DPD makes proposals which will destroy or damage these in the case of Grange-over-Sands, Kents Bank and Allithwaite. Tourism is a major income provider yet who would come to the area if green spaces are destroyed, valued vistas blocked from view and significantly increased traffic channeled through what is currently a pleasant Victorian town.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
In the case of Grange-over-Sands the needs figures do not accord with past experience. The presumptions made are questionable and based on out of date figures. The area is evolving as older premises are redeveloped and small sites within the community become available for housing. Brown field sites within the community have not all been used. There is not a demonstrable case for building on greenfield sites in the area. 15/25 residences per year will produce up to 500 dwellings in 20 years and the past suggests this rate of renewal might be expected. Green field sites should be removed from the DPD for Grange and Kents Bank.
The plans do not retain significant and appropriate green gaps between Kents Bank and Allithwaite contrary to CS4.
The plans are not deliverable without major changes to the infrastructure - water, electricity, sewerage, roads, transport etc. The report is silent on how these essentials would be met. Grange-over-Sands could not withstand throughput of extra traffic without destruction of the essential character of the town and residential areas to wit Main Street and Risedale. The plans if implemented would be contrary to the Environmental Objectives in the Sustainability Appraisal Report.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
454. Mr Alan Jones (Individual) : 15 May 2012 13:06:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA3.1 Mixed Use Allocation at Berners Pool, Grange-over-Sands
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
The DPD has not had regard to the Sustainable Community Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The SCI failed to deliver effective and adequate consultation with the community resulting in real and meaningful dialogue. Points raised by residents were noted but then largely ignored. Alternative approaches not in line with the SLDC preferred options were not seriously addressed. The final allocations of land in Grange-over-Sands and Allithwaite as selected by SLDC, pay no regard to the wishes of the community. It ignores provision for neighbourhood planning in the allocation process which could have delivered a community wide acceptance of a plan.
SLDC have engendered opposition and resentment by riding rough shod over the wishes of the community. People feel detached from what is proposed and feel plans for their community are being imposed from on high. This is not consultation and is not consistent with national policy on 'Localism'.
The sustainability statement is not based on hard evidence. There has not been effective collaboration at county and district level and sound evidence on which to base the appraisal has not been forthcoming. The natural and man made environment of Grange-over-Sands, Kents Bank and Allithwaite has not been systematically nor scientifically assessed and SLDC proposals would destroy many of the features cherished by residents and visitors. The report is silent on accepted reference standards and how this area measures against them.
The SCS points up the importance of the natural environment, its attractions and the area's heritage yet the DPD makes proposals which will destroy or damage these in the case of Grange-over-Sands, Kents Bank and Allithwaite. Tourism is a major income provider yet who would come to the area if green spaces are destroyed, valued vistas blocked from view and significantly increased traffic channeled through what is currently a pleasant Victorian town.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
In the case of Grange-over-Sands the needs figures do not accord with past experience. The presumptions made are questionable and based on out of date figures. The area is evolving as older premises are redeveloped and small sites within the community become available for housing. Brown field sites within the community have not all been used. There is not a demonstrable case for building on greenfield sites in the area. 15/25 residences per year will produce up to 500 dwellings in 20 years and the past suggests this rate of renewal might be expected. Green field sites should be removed from the DPD for Grange and Kents Bank.
The plans do not retain significant and appropriate green gaps between Kents Bank and Allithwaite contrary to CS4.
The plans are not deliverable without major changes to the infrastructure - water, electricity, sewerage, roads, transport etc. The report is silent on how these essentials would be met. Grange-over-Sands could not withstand throughput of extra traffic without destruction of the essential character of the town and residential areas to wit Main Street and Risedale. The plans if implemented would be contrary to the Environmental Objectives in the Sustainability Appraisal Report.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
455. Mr Alan Jones (Individual) : 15 May 2012 13:09:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA3.2 Mixed Use Allocation at Land South of Allithwaite Road, Kent's Bank, Grange-over-Sands
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
The DPD has not had regard to the Sustainable Community Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The SCI failed to deliver effective and adequate consultation with the community resulting in real and meaningful dialogue. Points raised by residents were noted but then largely ignored. Alternative approaches not in line with the SLDC preferred options were not seriously addressed. The final allocations of land in Grange-over-Sands and Allithwaite as selected by SLDC, pay no regard to the wishes of the community. It ignores provision for neighbourhood planning in the allocation process which could have delivered a community wide acceptance of a plan.
SLDC have engendered opposition and resentment by riding rough shod over the wishes of the community. People feel detached from what is proposed and feel plans for their community are being imposed from on high. This is not consultation and is not consistent with national policy on 'Localism'.
The sustainability statement is not based on hard evidence. There has not been effective collaboration at county and district level and sound evidence on which to base the appraisal has not been forthcoming. The natural and man made environment of Grange-over-Sands, Kents Bank and Allithwaite has not been systematically nor scientifically assessed and SLDC proposals would destroy many of the features cherished by residents and visitors. The report is silent on accepted reference standards and how this area measures against them.
The SCS points up the importance of the natural environment, its attractions and the area's heritage yet the DPD makes proposals which will destroy or damage these in the case of Grange-over-Sands, Kents Bank and Allithwaite. Tourism is a major income provider yet who would come to the area if green spaces are destroyed, valued vistas blocked from view and significantly increased traffic channeled through what is currently a pleasant Victorian town.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
In the case of Grange-over-Sands the needs figures do not accord with past experience. The presumptions made are questionable and based on out of date figures. The area is evolving as older premises are redeveloped and small sites within the community become available for housing. Brown field sites within the community have not all been used. There is not a demonstrable case for building on greenfield sites in the area. 15/25 residences per year will produce up to 500 dwellings in 20 years and the past suggests this rate of renewal might be expected. Green field sites should be removed from the DPD for Grange and Kents Bank.
The plans do not retain significant and appropriate green gaps between Kents Bank and Allithwaite contrary to CS4.
The plans are not deliverable without major changes to the infrastructure - water, electricity, sewerage, roads, transport etc. The report is silent on how these essentials would be met. Grange-over-Sands could not withstand throughput of extra traffic without destruction of the essential character of the town and residential areas to wit Main Street and Risedale. The plans if implemented would be contrary to the Environmental Objectives in the Sustainability Appraisal Report.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
456. Mr Alan Jones (Individual) : 15 May 2012 13:11:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA3.3 Mixed Use Allocation at Guide's Lot, Grange-over-Sands
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
The DPD has not had regard to the Sustainable Community Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The SCI failed to deliver effective and adequate consultation with the community resulting in real and meaningful dialogue. Points raised by residents were noted but then largely ignored. Alternative approaches not in line with the SLDC preferred options were not seriously addressed. The final allocations of land in Grange-over-Sands and Allithwaite as selected by SLDC, pay no regard to the wishes of the community. It ignores provision for neighbourhood planning in the allocation process which could have delivered a community wide acceptance of a plan.
SLDC have engendered opposition and resentment by riding rough shod over the wishes of the community. People feel detached from what is proposed and feel plans for their community are being imposed from on high. This is not consultation and is not consistent with national policy on 'Localism'.
The sustainability statement is not based on hard evidence. There has not been effective collaboration at county and district level and sound evidence on which to base the appraisal has not been forthcoming. The natural and man made environment of Grange-over-Sands, Kents Bank and Allithwaite has not been systematically nor scientifically assessed and SLDC proposals would destroy many of the features cherished by residents and visitors. The report is silent on accepted reference standards and how this area measures against them.
The SCS points up the importance of the natural environment, its attractions and the area's heritage yet the DPD makes proposals which will destroy or damage these in the case of Grange-over-Sands, Kents Bank and Allithwaite. Tourism is a major income provider yet who would come to the area if green spaces are destroyed, valued vistas blocked from view and significantly increased traffic channeled through what is currently a pleasant Victorian town.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
In the case of Grange-over-Sands the needs figures do not accord with past experience. The presumptions made are questionable and based on out of date figures. The area is evolving as older premises are redeveloped and small sites within the community become available for housing. Brown field sites within the community have not all been used. There is not a demonstrable case for building on greenfield sites in the area. 15/25 residences per year will produce up to 500 dwellings in 20 years and the past suggests this rate of renewal might be expected. Green field sites should be removed from the DPD for Grange and Kents Bank.
The plans do not retain significant and appropriate green gaps between Kents Bank and Allithwaite contrary to CS4.
The plans are not deliverable without major changes to the infrastructure - water, electricity, sewerage, roads, transport etc. The report is silent on how these essentials would be met. Grange-over-Sands could not withstand throughput of extra traffic without destruction of the essential character of the town and residential areas to wit Main Street and Risedale. The plans if implemented would be contrary to the Environmental Objectives in the Sustainability Appraisal Report.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
457. Mr Alan Jones (Individual) : 15 May 2012 13:13:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - All Grange-over-Sands sites
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
The DPD has not had regard to the Sustainable Community Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The SCI failed to deliver effective and adequate consultation with the community resulting in real and meaningful dialogue. Points raised by residents were noted but then largely ignored. Alternative approaches not in line with the SLDC preferred options were not seriously addressed. The final allocations of land in Grange-over-Sands and Allithwaite as selected by SLDC, pay no regard to the wishes of the community. It ignores provision for neighbourhood planning in the allocation process which could have delivered a community wide acceptance of a plan.
SLDC have engendered opposition and resentment by riding rough shod over the wishes of the community. People feel detached from what is proposed and feel plans for their community are being imposed from on high. This is not consultation and is not consistent with national policy on 'Localism'.
The sustainability statement is not based on hard evidence. There has not been effective collaboration at county and district level and sound evidence on which to base the appraisal has not been forthcoming. The natural and man made environment of Grange-over-Sands, Kents Bank and Allithwaite has not been systematically nor scientifically assessed and SLDC proposals would destroy many of the features cherished by residents and visitors. The report is silent on accepted reference standards and how this area measures against them.
The SCS points up the importance of the natural environment, its attractions and the area's heritage yet the DPD makes proposals which will destroy or damage these in the case of Grange-over-Sands, Kents Bank and Allithwaite. Tourism is a major income provider yet who would come to the area if green spaces are destroyed, valued vistas blocked from view and significantly increased traffic channeled through what is currently a pleasant Victorian town.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
In the case of Grange-over-Sands the needs figures do not accord with past experience. The presumptions made are questionable and based on out of date figures. The area is evolving as older premises are redeveloped and small sites within the community become available for housing. Brown field sites within the community have not all been used. There is not a demonstrable case for building on greenfield sites in the area. 15/25 residences per year will produce up to 500 dwellings in 20 years and the past suggests this rate of renewal might be expected. Green field sites should be removed from the DPD for Grange and Kents Bank.
The plans do not retain significant and appropriate green gaps between Kents Bank and Allithwaite contrary to CS4.
The plans are not deliverable without major changes to the infrastructure - water, electricity, sewerage, roads, transport etc. The report is silent on how these essentials would be met. Grange-over-Sands could not withstand throughput of extra traffic without destruction of the essential character of the town and residential areas to wit Main Street and Risedale. The plans if implemented would be contrary to the Environmental Objectives in the Sustainability Appraisal Report.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
458. Miss Victoria Jones (Individual) : 15 May 2012 14:04:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
0.0 Whole Document
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The DPD has not had regard to the Sustainable Community Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
These new proposals would destroy the environmental character of many parts of the town especially as theses parts are on green land. Many of these green land areas are of agricultural use. The loss of this land would be economically inviable.
There is brown land space in near by areas to Ulverston that lie in Furness. These need to be considered as well.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
At the beginning of the consultation only part of Gascow Farm was considered for building. To begin with this was not sound as it is classed as green land. After the initial consultation the whole of the area has been put forward for building work after the commendation of a building firm. This is not listening to the voice of the residents, this was listening to people who fit in with the plans. Gascow Farm has already been denied planning permission in the past because of flooding problems. Why are these problems now being overlooked? The plan to build houses of this scale in Ulverston in absurd. For a start many houses lie empty and they are being ignored. Secondly there are plenty of houses already for sale in the area. John Woodcock MP has also pointed out that Barrow has plenty of brown space areas to offer and yet have not been consulted. Why ignore brown space land in the area for the sake of destroying green land which should be protected. Ulverston is already struggling to maintain the town with many pot holed roads still not being fixed and services, such as recycling facilities, being cut. A new estate of the size being proposed would cripple the infrastructure of the town. I also don't agree with how the decisions are being made in Kendal. It seems convenient that Ulverston is one of the towns with the most amount of housing and opinions in this town are being ignored. New housing would introduce new people to the area not help local people in need of housing.
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
Brown land in the Furness area would be of more benefit so I feel that they need to take part in these consultations.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
459. Mr. Philip Jones (Individual) : 15 May 2012 14:56:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - All Endmoor sites
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The consultation which took place was based on a plan for 62 houses at site M41-mod (land to the north of Sycamore Close). The plan now is for 100 homes but there has been no consultation based on this number. If this really is considered to be "legally compliant" I suggest that we need to take another look at the meaning of the words. There should now be a proper and full consultation based on the DPD which ought first to be amended to reflect a more accurate assessment of the actual level of need in the community. At the moment the DPD looks very much like an ill-considered and badly researched "stick on" determined in a most arbitrary manner which does not in any way reflect the actual level of need. Instead the DPD appears to be a rather clumsy attempt to provide plans which satisfy the broad brush approach of HMG. I acknowledge the need for the village to be allowed to grow but not by 30% in area at a stroke. The scale of the growth should not be allowed to rob Endmoor of its village status by turning it into a small town without the services normally associated with a small town.
The DPD does not accord with the following principles set out in The Core Strategy;
CS1.1.1; CS1.1.2; CS1.1.3; CS1.1.6; CS1.1.7; CS1.1.8; CS1.1.9; CS1.1.11;
In general terms, the DPD does not enhance the the resilience of the natural environment, nor does it minimise the use of non-renewable resources. It fails to protect the countryside for its intrinsic beauty etc.. It most certainly fails to minimise the need for travel. On the contrary, it serves only to guarantee the need for even more travel and the consequent increase in the use of fuel. Endmoor lacks the necessary services, infrastructure and employment opportunities to support such a large development. It is, quite simply, too much too fast.
1.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
I fully recognise the need for SOME new homes in the village but the level of need has not been properly quantified. The DPD figures are clumsily prepared and applied from without the community and do not reflect the actual need.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The DPD for both housing and commercial sites is not sound because there is no clear strategy with regard to waste water treatment.The infrastructure is not in place for such a large increase in the number houses and this makes the DPD unsustainable and undeliverable. The DPD alludes (without being specific) to a new sewage treatment plant at Low Park; the general assumption among local people is that SLDC mean this to be a massive enlargement of the existing plant and yet the landowner has not been consulted.
The road network is incapable of safely supporting the increase in traffic which would be expected if the mixed commercial site is developed at sites EN20 and EN33; this brings me to my objection to these developments on the grounds that there is no demonstrable demand for more commercial premises in this locality; there is already unused commercial capacity at Summerlands, Gatebeck Business Park and in the ongoing development at Jct. 36. The whole enterprise seems to assume a level of demand which does not exist. With spare commercial capacity already available in the village it would be nonsensical to provide even more to the great detriment of the greenfield areas and the wonderful drumlin landscape. Once this landscape is covered in units of one sort or another it is lost forever and to achieve what? An even greater surplus of unwanted premises.
In order to make the DPD acceptable the following steps should be taken;
Fresh consultations with local people to consider the DPD as it looks after these changes are made
Assess the real level of need for new housing whilst bearing in mind the parlous state of the economy, the available infrastructure and level of services.
Reduce the density and number of houses and incorporate in the design green recreational areas and stipulate that each new dwelling must have sufficient off-road parking so as to allow service and emergency vehicles proper access.
Set a much more reasonable limit (the DPD seeks to increase it by 30%) on the amount by which the footprint of the village can be increased. This to protect the character of Endmoor and its status as a village.
Abandon the plans to provide any more commercial premises because there are no reasonable grounds for believing that these are required.
Consider (and consult locally) more suitable alternatives for the siting of the proposed new sewage treatment plant.
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
I cannot support the DPD in its present form.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
460. Mr. Philip Jones (Individual) : 15 May 2012 15:04:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - M41M ENDMOOR NORTH OF SYCAMORE DRIVE
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The consultation which took place was based on a plan for 62 houses at site M41-mod (land to the north of Sycamore Close). The plan now is for 100 homes but there has been no consultation based on this number. If this really is considered to be "legally compliant" I suggest that we need to take another look at the meaning of the words. There should now be a proper and full consultation based on the DPD which ought first to be amended to reflect a more accurate assessment of the actual level of need in the community. At the moment the DPD looks very much like an ill-considered and badly researched "stick on" determined in a most arbitrary manner which does not in any way reflect the actual level of need. Instead the DPD appears to be a rather clumsy attempt to provide plans which satisfy the broad brush approach of HMG. I acknowledge the need for the village to be allowed to grow but not by 30% in area at a stroke. The scale of the growth should not be allowed to rob Endmoor of its village status by turning it into a small town without the services normally associated with a small town.
1.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
I cannot support the DPD in its present form.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The DPD for both housing and commercial sites is not sound because there is no clear strategy with regard to waste water treatment.The infrastructure is not in place for such a large increase in the number houses and this makes the DPD unsustainable and undeliverable. The DPD alludes (without being specific) to a new sewage treatment plant at Low Park; the general assumption among local people is that SLDC mean this to be a massive enlargement of the existing plant and yet the landowner has not been consulted.
In order to make the DPD acceptable the following steps should be taken;
Fresh consultations with local people to consider the DPD as it looks after these changes are made
Assess the real level of need for new housing whilst bearing in mind the parlous state of the economy, the available infrastructure and level of services.
Reduce the density and number of houses and incorporate in the design green recreational areas and stipulate that each new dwelling must have sufficient off-road parking so as to allow service and emergency vehicles proper access.
Set a much more reasonable limit (the DPD seeks to increase it by 30%) on the amount by which the footprint of the village can be increased. This to protect the character of Endmoor and its status as a village.
Abandon the plans to provide any more commercial premises because there are no reasonable grounds for believing that these are required.
Consider (and consult locally) more suitable alternatives for the siting of the proposed new sewage treatment plant.
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
I cannot support the DPD in its present form.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
461. Mr. Philip Jones (Individual) : 15 May 2012 15:12:00
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Policy/Site No.
LA1.8 Local Employment Allocations - EN20, EN33# ENDMOOR LAND NORTH OF GATEBECK LANE, GATEBECK
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The road network is incapable of safely supporting the increase in traffic which would be expected if the mixed commercial site is developed at sites EN20 and EN33; this brings me to my objection to these developments on the grounds that there is no demonstrable demand for more commercial premises in this locality; there is already unused commercial capacity at Summerlands, Gatebeck Business Park and in the ongoing development at Jct. 36. The whole enterprise seems to assume a level of demand which does not exist. With spare commercial capacity already available in the village it would be nonsensical to provide even more to the great detriment of the greenfield areas and the wonderful drumlin landscape. Once this landscape is covered in units of one sort or another it is lost forever and to achieve what? An even greater surplus of unwanted premises.
In order to make the DPD acceptable the following steps should be taken;
Fresh consultations with local people to consider the DPD as it looks after these changes are made
Assess the real level of need for new housing whilst bearing in mind the parlous state of the economy, the available infrastructure and level of services.
Reduce the density and number of houses and incorporate in the design green recreational areas and stipulate that each new dwelling must have sufficient off-road parking so as to allow service and emergency vehicles proper access.
Set a much more reasonable limit (the DPD seeks to increase it by 30%) on the amount by which the footprint of the village can be increased. This to protect the character of Endmoor and its status as a village.
Abandon the plans to provide any more commercial premises because there are no reasonable grounds for believing that these are required.
Consider (and consult locally) more suitable alternatives for the siting of the proposed new sewage treatment plant.
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
I cannot support the DPD in its present form.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
462. Mr & Mrs Michael & Dorothy Jopson (Individual) : 26 Apr 2012 15:53:00
Policy/Site No.
LA1.3 Housing Allocations - M41KM KENDAL SOUTH OF LUMLEY ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Loss of green field space is detrimental to the character and heritage of the area. This is contrary to Coalition Government Sustainable Development Policy, which recognizes brown field preference above important countryside areas. The Soundness and legality of the plan is therefore challenged as being contrary to Government Planning Policy.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I wish to object to and challenge the soundness of proposed land allocation for development – to south of Lumley Rd. (M41KM) and Scroggs Wood Light Industrial Site (E4M) on the following grounds:
- The proposed developments would spoil the initial impression to Kendal visitors, being on the main access route and adjacent to the Town boundary. The Lumley road site is steeply graded and properties would impose on the existing view for Kendal visitors. The line of trees acts as a natural barrier between countryside and properties. Building to the South of this line (E4M), would fundamentally change the Kendal “Gateway to the Lakes” character as a valued landscape. This is contrary to the adopted planning Core Strategy. The Soundness of the plan is therefore challenged on visual impact grounds, contrary to planning policy.
- Loss of green field space is detrimental to the character and heritage of the area. This is contrary to Coalition Government Sustainable Development Policy, which recognizes brown field preference above important countryside areas. The Soundness and legality of the plan is therefore challenged as being contrary to Government Planning Policy.
- Milnthorpe road already backs up to the bypass at peak times and cannot accommodate the massive increase that such development, in these locations, would create. Kendal town development to attract visitors is pointless if they cannot obtain satisfactory access. The associated pollution from stationary traffic is incompatible with sustainable development objectives. The soundness of the development is challenged on the basis that there is no traffic plan to address these issues.
- The A6 is a crucial access for emergency services, particularly following the downgrading of Westmorland General Hospital. Further congestion on this route would introduce undue risk. The potential for accidents when joining the main road would also be significantly increased. The Soundness of the plan is therefore challenged on safety grounds.
- The soundness of the development is challenged on the basis that there is inadequate local infrastructure including drainage, sewerage and roads.
- The proposed development is incompatible with the character of the historic Helsington development contrary to planning policy. The Soundness of the plan is therefore challenged as being detrimental to the historical character of the area.
- The site is clearly NOT “in an accessible location or an easily developable level site” (Achievability statement P133 2 C). The Soundness of the plan is therefore challenged as being contrary to this declared planning statement.
- There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of adequate existing residential space and more suitable alternative development sites.
- The Development plan should retain the "Kendal Gateway to the Lakes" image supporting tourism and established Cumbrian employment, not destroy it with unsightly, unnecessary development and traffic jams. You don’t put your wheelie bin on your front door step! The DPD appears to have completely disregarded the massive opposition and valid objections previously made. The soundness of this planned development is challenged as disregarding local opinion contrary to Government Policy.
463. Mr & Mrs Michael & Dorothy Jopson (Individual) : 26 Apr 2012 15:59:00
Policy/Site No.
LA1.6 Strategic Employment Sites - E4M KENDAL LAND AT SCROGGS WOOD, MILNTHORPE ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I wish to object to and challenge the soundness of proposed land allocation for development – to south of Lumley Rd. (M41KM) and Scroggs Wood Light Industrial Site (E4M) on the following grounds:
-The proposed developments would spoil the initial impression to Kendal visitors, being on the main access route and adjacent to the Town boundary. The Lumley road site is steeply graded and properties would impose on the existing view for Kendal visitors. The line of trees acts as a natural barrier between countryside and properties. Building to the South of this line (E4M), would fundamentally change the Kendal “Gateway to the Lakes” character as a valued landscape. This is contrary to the adopted planning Core Strategy. The Soundness of the plan is therefore challenged on visual impact grounds, contrary to planning policy.
-Loss of green field space is detrimental to the character and heritage of the area. This is contrary to Coalition Government Sustainable Development Policy, which recognizes brown field preference above important countryside areas. The Soundness and legality of the plan is therefore challenged as being contrary to Government Planning Policy.
- Milnthorpe road already backs up to the bypass at peak times and cannot accommodate the massive increase that such development, in these locations, would create. Kendal town development to attract visitors is pointless if they cannot obtain satisfactory access. The associated pollution from stationary traffic is incompatible with sustainable development objectives. The soundness of the development is challenged on the basis that there is no traffic plan to address these issues.
- The A6 is a crucial access for emergency services, particularly following the downgrading of Westmorland General Hospital. Further congestion on this route would introduce undue risk. The potential for accidents when joining the main road would also be significantly increased. The Soundness of the plan is therefore challenged on safety grounds.
- The soundness of the development is challenged on the basis that there is inadequate local infrastructure including drainage, sewerage and roads.
- The proposed development is incompatible with the character of the historic Helsington development contrary to planning policy. The Soundness of the plan is therefore challenged as being detrimental to the historical character of the area.
- The site is clearly NOT “in an accessible location or an easily developable level site” (Achievability statement P133 2 C). The Soundness of the plan is therefore challenged as being contrary to this declared planning statement.
- There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of adequate existing residential space and more suitable alternative development sites.
- There is spare capacity and expansion potential on existing established trading estates on Shap Road. The plan to relocate the Rugby club to Oxenholme and development of the Gilkes site are more suited to development than Scroggs Wood. The soundness of the case for such development is challenged on the basis of existing and more suitable alternative development sites compatible with planning policy.
- What and where is the business case and demand for a further speculative light industrial business park? Why would UK businesses move to such a park when financial assistance and tax breaks are available for designated City areas such as the Manchester Enterprise Zone? The soundness of this planned development is challenged on the basis of no established demand or business case.
- The Development plan should retain the "Kendal Gateway to the Lakes" image supporting tourism and established Cumbrian employment, not destroy it with unsightly, unnecessary development and traffic jams. You don’t put your wheelie bin on your front door step! The DPD appears to have completely disregarded the massive opposition and valid objections previously made. The soundness of this planned development is challenged as disregarding local opinion contrary to Government Policy.
464. Mr & Mrs Michael & Dorothy Jopson (Individual) : 26 Apr 2012 16:01:00
Policy/Site No.
LA1.3 Housing Allocations - All Kendal sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of adequate existing residential space and more suitable alternative development sites.
465. Mr & Mrs Michael & Dorothy Jopson (Individual) : 26 Apr 2012 16:03:00
Paragraph No.
0.0 Whole Document
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Is there a definition of “affordable housing” in the context of Kendal young person income? Or is this merely a rouse to allow land owners and builders to make massive profits, without any tangible commitment to house the low paid of Kendal? The Soundness is therefore challenged on the basis of no defined affordability test.
466. Mr & Mrs Michael & Dorothy Jopson (Individual) : 26 Apr 2012 16:04:00
Policy/Site No.
LA1.4 - Kendal Sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of adequate existing residential space and more suitable alternative development sites.
467. Mr & Mrs Brian and Doreen Jowett (Individual) : 23 Mar 2012 15:05:00
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Policy/Site No.
LA1.3 Housing Allocations - R653M-mod HOLME EAST OF MILNTHORPE RD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
We would like to express our objection to the proposed development of the land off Milnthorpe Road (R653M-mod) which appears on the Land Allocation plan for Holme.
This development will adjoin the existing Pear Tree Park/Mayfield Avenue housing estates, which have been completed recently and which have had a significant impact on the size and population of the village, not to mention the problems of sewerage disposal and drainage problems. Access and traffic problems are already a danger to the residents and this will be further adversely affected by yet another housing development.
Holme lacks the amenities required to support the existing population, resulting in extensive use of private motor vehicles to the towns of Kendal, Carnforth and the village of Milnthorpe for shopping, healthcare and financial institutions. The existing public transport links are insufficient to cope with a further increase in population and residents would be left with no alternative but to use private transport which would place a further burden on the road network and lead to increased risk of traffic accidents.
The land in question is used for agricultural production and adjoins the "Limestone Link" public footpath regularly used by walkers. The impact on the visual amenity by building on this land will be irreversible and will have a huge effect on the outlook from the properties which currently enjoy unobstructed rural views across open land. Development of this land will also have a very detrimental effect on the approach to the village from the Milnthorpe direction and will create a sudden demarcation of the change from open grazing to urbanisation.
This land is crossed by an overhead high-tension power line which would dissect the development and pose a real risk to any housing within its proximity. It is well known that there is a serious threat to health for humans caused by living within close distances of pylons and high voltage lines.
We hope that you will take note of our objection to this development, taking into account the above reasons.
Yours faithfully,
Brian & Doreen Jowett
468. Mr David Judson (Individual) : 16 Apr 2012 23:50:00
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Paragraph No.
0.0 Whole Document
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Like a vast number of South Lakeland residents I am very much opposed to this proposal in principle.
Whilst there is no doubt that local affordable housing is needed, this can be catered for within existing local and national planning policy.
I do not believe there is any need for this vast number of new housing, the majority of which will not be 'affordable'. It will spoil the character and nature of South Lakeland start it's decline into yet another urban sprawl.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
469. Mrs Margaret Kelly (Individual) : 10 May 2012 12:08:00
A typed or handwritten document was submitted. This has been scanned and can be downloaded below:
Paragraph No.
3.67
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Following a phone conversation with Mr McNeill I understand he consulted you with regard
to my property. This has now created an amendment to Site No RN 57 that states that the
use of single storey dwellings may be necessary.
I bought the above property from plan approximately 24 years ago, as you will see from the
enclosed plan my property is immediately adjacent to No 9 St Anthonys Close.
The developer at that time was instructed by SLDC Planning Department that 6,7,8 and 9 St
Anthonys Close should be 70ft away window to window from Kirkhead to the South to
protect the privacy of existing council properties.
Permitting development immediately to the East of my property will block it in on all sides
with reduction of light and privacy. I request that the amendment is extended to state that
only single storey development would be permitted allowing a reasonable distance
between existing and proposed properties.
I was informed by the LDF team that all sites had been inspected, if this had been the case
the points I have made would have been obvious. This is a modern estate designed to follow
the contour of the hillside, further development will not enhance the overall appearance of
the village.
(see attached plan)
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
I am not confident that all objections raised in writing will in fact be reviewed by the appointed Inspector.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
470. Mrs Margaret Kelly (Individual) : 10 May 2012 12:18:00
Policy/Site No.
LA1.3 Housing Allocations - RN57M MILNTHORPE ADJ. TO ST ANTHONY'S CLOSE
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The Land Allocations Document (DPD) is not within the Local Development Scheme and the key stages have not been followed
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not had regard to the Sustainable Community Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Core Strategy does not make clear how it intends to ensure 28% of housing development takes place on previously developed land & buildings (brown field sites). This has not made clear any definite plans to achieve this target.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Please see attached sheet, in respect of difficulties with infrastructure. There are not enough information regarding this (text of attachment detailed below):
The core strategy has not complied with requirements, the proposals are simply a charter for the developers and landowners to cash in on sites that in many cases are located on greenfield sites where affordable housing will be built adjacent to present properties and the remainder will be built directly next to open countryside. There has not been enough
consideration by SLDC in respect of brown field sites being incorporated in the DPD.
Early options made it clear that the Council would not change their policy and that the
majority of sites would be included despite the outcome of consultations, indeed one Parish councillor informed me that "these sites local to our village will be included whether you like it or not" furthermore at the full council meeting on the 18th January 2012 the council voted in line with their political parties and not with any consideration of the views of their constituents.
The DPD plan is clearly unsound, as no firm and definite plans have been submitted in
respect of the ability of certain villages, in particular Milnthorpe to accommodate further
development. All information regarding the impact on schools, traffic management, sewage
disposal, and parking to access v ital services have met with only general and often vague
consideration. When I enquired of the LDF team how the access to St Anthonys Hill could
be expected to accommodate further traffic I was told the road and pavement would be
widened, when I pointed out that this would require compulsory purchase of several residents gardens and demolishing one garage I was met by silence!
Alternative sites in the area of Ackenthwaite have been dismissed very early in the
consultation. No reason was given, there is however a possible link to one of the Parish
councillors who may have strong reasons to influence discounting this site. Residents offered alternative suggestions for emerging sites however these were quickly dismissed by SLDC
SLDC has not honoured its commitment to ensure continued involvement of local
communities throughout the process, indeed quite the opposite.
The main thrust of the proposals is that affordable housing is required. This fact is not in
dispute however there is little employment in Milnthorpe. The new Booths supermarket we
were told would offer job opportunities to local people, however Booths are not required to
employ local staff, and indeed may find it difficult to find sufficient people willing to travel
from elsewhere given the high cost of travel. Likewise young people will find it difficult to
cover the cost of travel from Milnthorpe to larger areas of employment.
The cost of the Land Allocations Development Plan has not been made public. Clearly at
great expense many presentations and documentation have been produced, however of 3,000 responses in the Kendal area showed that 98% of residents opposed the proposals proposed by SLDC.
It also appears that the Publication Stage Representation Form and information provided have been made so complex as to deter many ordinary residents from venturing opinions or
objections.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
I am not confident that all objections raised in writing will in fact be reviewed by the appointed Inspector.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
471. Mr Andrew Kendall (Individual) : 9 Apr 2012 11:41:00
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I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - Site Omission
If you have selected a ‘Site omission’ please enter the site reference or location and relevant policy below
R30, land near Wartbarrow Lane/Fellside in Allithwaite. Was part of R343m when considered, document "Allithwaite Final Stage 1"
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
This site was discounted at stage one of the consultation process for reasons documented in your on-line consultation appendices, some of which I would disagree with but respect your research and findings (I work in the water industry locally so know the sewer issue could be easily solved for example, so therefore don't find this a sound reason for discounting)
Looking at the most recent map on your web site field R30 is now within the development boundary (R343 is not) so can it be asked that this site is considered singularly? This field is without doubt infill in the village, and is certainly more infill than some of the land suggested now as to be allocated, RN 224 for example. Access for a smaller development through Fellside would be better too.
Can I finally add I find it very strange that R30 is within your development boundary yet not included in the proposal - this is the main point I wish to be reconsidered.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
Unsure what this will actually involved but more than willing to speak to the Inspector if needed regarding my point.
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Please notify me
472. Mr Martin Kennedy (Individual) : 17 Apr 2012 00:13:00
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I have read the guidance notes
Paragraph No.
0.5 Section 5
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Comments relate to the whole plan for Ulverston, but in particular the the large scale plans for additional housing at Croftlands Estate (ref 5.15 to 5.24)
It is difficult to understand any justification for the 1200 properties proposed in Ulverston. This would seem to be simply an aspiration on the Council's part rather than based on real needs. The number of additional properties is completely inconsistent with the proposed commercial/industrial development outlined in the plan and that which would be needed to provide jobs for this number of new residents.
There is a lot of vacant property in the town at present and efforts should be focussed on getting this back into use and concentrating any new build activity on brown-field sites. This should be more than adequate to meet the needs of Ulverston.
The proposed sites at Croftlands will extend Ulverston well into open countryside, towards the beauty spot of Birkrigg Common, destroying good quality agricultural land forever. This will also destroy the feel and attraction of the town to the tourists/visitors who are vital to the economy that SLDC says it wants to grow.
It seems that the Council is planning to allow a large amount of un-needed development, just so it can achieve the volumes of affordable housing that it wants to see. The liklihood is that to fill this total amount of property, there would need to be a migration from Barrow-in-Furness, a town which is in desparate need of re-development and where there are ample brownfield sites. Any large scale housing requirements for the Furness peninsular should be centred on Barrow and the SLDC plan should be co-ordinated with that for Barrow in this respect.
Aside from the lack of justification for the total amount of development, SLDC has also ignored the real practical issues raised by local residents.
- The concentration of new property on the proposed Croftlands sites will put a large volume of extra traffic on already busy roads running through the estate and adjoining roads to join the A590, both at Cross-a-Moor and the Quebec St junction (coast road), posing a massive safety risk
- A lot of the proposed development is on land proven to flood and even if this is alleviated by local engineering projects,it will push the wider drainage and sewerage systems over the edge
- Other infrastructure, schools etc are inadequate to support the extra development
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
473. Mr Martin Kennedy (Individual) : 15 May 2012 15:03:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - All Ulverston sites
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Comments relate to the whole plan for Ulverston, but in particular the the large scale plans for additional housing at Croftlands Estate (ref 5.15 to 5.24)
The proposed sites at Croftlands will extend Ulverston well into open countryside, towards the beauty spot of Birkrigg Common, destroying good quality agricultural land forever. This will also destroy the feel and attraction of the town to the tourists/visitors who are vital to the economy that SLDC says it wants to grow.
- The concentration of new property on the proposed Croftlands sites will put a large volume of extra traffic on already busy roads running through the estate and adjoining roads to join the A590, both at Cross-a-Moor and the Quebec St junction (coast road), posing a massive safety risk
- A lot of the proposed development is on land proven to flood and even if this is alleviated by local engineering projects,it will push the wider drainage and sewerage systems over the edge
- Other infrastructure, schools etc are inadequate to support the extra development
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
474. Mr Martin Kennedy (Individual) : 15 May 2012 15:05:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
5.15
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Comments relate to the whole plan for Ulverston, but in particular the the large scale plans for additional housing at Croftlands Estate (ref 5.15 to 5.24)
The proposed sites at Croftlands will extend Ulverston well into open countryside, towards the beauty spot of Birkrigg Common, destroying good quality agricultural land forever. This will also destroy the feel and attraction of the town to the tourists/visitors who are vital to the economy that SLDC says it wants to grow.
- The concentration of new property on the proposed Croftlands sites will put a large volume of extra traffic on already busy roads running through the estate and adjoining roads to join the A590, both at Cross-a-Moor and the Quebec St junction (coast road), posing a massive safety risk
- A lot of the proposed development is on land proven to flood and even if this is alleviated by local engineering projects,it will push the wider drainage and sewerage systems over the edge
- Other infrastructure, schools etc are inadequate to support the extra development
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
475. Mr Martin Kennedy (Individual) : 15 May 2012 15:06:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - R697 & part R242 ULVERSTON CROFTLANDS EAST
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Comments relate to the whole plan for Ulverston, but in particular the the large scale plans for additional housing at Croftlands Estate (ref 5.15 to 5.24)
The proposed sites at Croftlands will extend Ulverston well into open countryside, towards the beauty spot of Birkrigg Common, destroying good quality agricultural land forever. This will also destroy the feel and attraction of the town to the tourists/visitors who are vital to the economy that SLDC says it wants to grow.
- The concentration of new property on the proposed Croftlands sites will put a large volume of extra traffic on already busy roads running through the estate and adjoining roads to join the A590, both at Cross-a-Moor and the Quebec St junction (coast road), posing a massive safety risk
- A lot of the proposed development is on land proven to flood and even if this is alleviated by local engineering projects,it will push the wider drainage and sewerage systems over the edge
- Other infrastructure, schools etc are inadequate to support the extra development
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
476. Mr Martin Kennedy (Individual) : 15 May 2012 15:07:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - R690ulv, R691ULV, R126M, RN184, RN234# & part R242 ULVERSTON CROFTLANDS WEST - NOOK FARM
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Comments relate to the whole plan for Ulverston, but in particular the the large scale plans for additional housing at Croftlands Estate (ref 5.15 to 5.24)
The proposed sites at Croftlands will extend Ulverston well into open countryside, towards the beauty spot of Birkrigg Common, destroying good quality agricultural land forever. This will also destroy the feel and attraction of the town to the tourists/visitors who are vital to the economy that SLDC says it wants to grow.
- The concentration of new property on the proposed Croftlands sites will put a large volume of extra traffic on already busy roads running through the estate and adjoining roads to join the A590, both at Cross-a-Moor and the Quebec St junction (coast road), posing a massive safety risk
- A lot of the proposed development is on land proven to flood and even if this is alleviated by local engineering projects,it will push the wider drainage and sewerage systems over the edge
- Other infrastructure, schools etc are inadequate to support the extra development
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
477. Mr Martin Kennedy (Individual) : 15 May 2012 15:08:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - RN131M,RN141#, RN321# &RN284# Ulverston - Gascow Farm
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Comments relate to the whole plan for Ulverston, but in particular the the large scale plans for additional housing at Croftlands Estate (ref 5.15 to 5.24)
The proposed sites at Croftlands will extend Ulverston well into open countryside, towards the beauty spot of Birkrigg Common, destroying good quality agricultural land forever. This will also destroy the feel and attraction of the town to the tourists/visitors who are vital to the economy that SLDC says it wants to grow.
- The concentration of new property on the proposed Croftlands sites will put a large volume of extra traffic on already busy roads running through the estate and adjoining roads to join the A590, both at Cross-a-Moor and the Quebec St junction (coast road), posing a massive safety risk
- A lot of the proposed development is on land proven to flood and even if this is alleviated by local engineering projects,it will push the wider drainage and sewerage systems over the edge
- Other infrastructure, schools etc are inadequate to support the extra development
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
478. Mr Martin Kennedy (Individual) : 15 May 2012 15:10:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
0.0 Whole Document
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
It is difficult to understand any justification for the 1200 properties proposed in Ulverston. This would seem to be simply an aspiration on the Council's part rather than based on real needs. The number of additional properties is completely inconsistent with the proposed commercial/industrial development outlined in the plan and that which would be needed to provide jobs for this number of new residents.
There is a lot of vacant property in the town at present and efforts should be focussed on getting this back into use and concentrating any new build activity on brown-field sites. This should be more than adequate to meet the needs of Ulverston.
It seems that the Council is planning to allow a large amount of un-needed development, just so it can achieve the volumes of affordable housing that it wants to see. The liklihood is that to fill this total amount of property, there would need to be a migration from Barrow-in-Furness, a town which is in desparate need of re-development and where there are ample brownfield sites. Any large scale housing requirements for the Furness peninsular should be centred on Barrow and the SLDC plan should be co-ordinated with that for Barrow in this respect.
Aside from the lack of justification for the total amount of development, SLDC has also ignored the real practical issues raised by local residents.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
479. Mrs Valerie Kennedy (Individual) : 16 May 2012 11:42:00
A typed or handwritten document was submitted. This has been scanned and can be downloaded below:
Paragraph No.
7.1 General Comment
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
1. SLDC should not include Grange-over-Sands as one of its Key Service Centres because it does not meet the criteria in CS1.2 The development strategy for Principal Service Centres, Key Service Centres and Local Service Centres. This would mean that the number of proposed developments in Grange-over-Sands and district should be reduced and all proposed development sites should be reassessed. Development of brown field sites, such as Berners, should be prioritised and SLDC should take account of the views of local residents and Grange-over-Sands Town Council.
2. SLDC have not followed Government guidance about the use and interpretation of household surveys. They have not provided objective evidence to justify ‘housing need for Grange-over-Sands and District.
3. SLDC should be required to produce objective evidence to justify their plans to allow Grange-over-Sands to develop into a coastal urban sprawl incorporating Kents Bank.
4. SLDC should be required to remove sites MN25N, R672 and R79# from their Land Development DPD because development of these sites will lead to coalescence between the communities of Kents Bank and Allithwaite.
5. SLDC should be required to remove sites R449, R74 and R110 from their Land Development DPD because development of these sites will lead to further coalescence between the communities of Grange-over-Sands and Kents Bank.
6. SLDC should be required to produce clear evidence about how their proposed developments will enhance tourism in Grange-over-Sands and district.
7. SLDC should be required to explain why they have ignored recommendations made about green field sites and tourism in the Grange-over-Sands Regeneration Study (Douglas Wheeler Associates, November 2007), that they claim has informed SLDC's Core Strategy.
8. SLDC should be required to provide objective evidence that the local roads are adequate to support the proposed increase in population and traffic in Grange-over-Sands especially for known bottle-necks in Main Street and on Risedale Hill.
9. SLDC should not allow any development on prime green field land between Kents Bank and Allithwaite because it will lead to coalescence between these two separate communities.
1.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
I do not support SLDC’s Land Allocations DPD because it is based on spurious ‘housing need’ targets, has unnecessarily ear-marked important green field sites for development, encourages coalescence between Kents Bank and Allithwaite and does not meet the criteria of important Core Strategy policies.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The following text of response 11287 includes the introduction and summary of the main conclusions from my response to SLDC’s Land Allocation Development DPD consultation that was submitted as a report entitled: ‘Soundness’ response to SLDC’s Land Allocation Development Plan (DPD, Jan 2012) focussing on SLDC’s ‘housing need’ predictions & SLDC’s vision for Grange-over-Sands and District.
My report included photographs and maps to illustrate comments that were made in the report.
I have requested that a copy of my full report is made available to the Planning Inspector.
[A copy of the full report is attached]
Introduction
During SLDC’s two Land Development consultations (2011) I submitted forms for
nine proposed land development sites in Kents Bank and Allithwaite raising a number
of serious problems that would arise if these sites were included in SLDC’s final Land
Allocation Development Plan document.
None of these problems have been satisfactorily resolved; one was made even
worse by nearly doubling the size of the proposed development.
After the close of SLDC’s first 2011 Land Development consultation I submitted a
form querying the way that SLDC’s Core Strategy had been applied when proposing
land development throughout the district with particular reference to Grange-over-
Sands.
I queried the basis of SLDC’s housing need projections, the lack of baseline data on
sustainability and environmental impacts, the vested interests of land owners
suggesting development land etc… (Appendix 1)
None of these problems have been addressed adequately.
I have invested a substantial amount of time in preparing these submissions because
it is important the unique heritages of Grange-over-Sands, Kents Bank and
Allithwaite are preserved for future generations, and, that this delightful part of the
Morecambe Bay coast is not allowed to evolve into an urban coastal sprawl.
Friends, relatives and environmental research workers visiting me from Canada, New
Zealand, Brazil, Greece, Italy, Spain, Scandinavia and even the south of England are
always impressed by Victorian/Edwardian heritage of Grange-over-Sands town
centre and are attracted by its back-drop of undulating rough pastureland, dry stone
walls and narrow lanes linking its local communities.
This is why they come to visit us!
Please include my submission with the papers submitted to the Government
Inspector.
I would also like to participate in the oral public examination into the soundness of the
SLDC Land Allocation Development Plan by the Inspector.
SUMMARY
Proposals in the SLDC Land Allocations Development Plan Document are
NOT JUSTIFIED because:
-The large error bars associated with the average and median values of
the four scenarios used to predict SLDC’s ‘housing need’ demonstrate
the variability of the underlying data and the need for careful
interpretation of the results.
- SLDC have not provided selecting objective evidence to support the
selection of the highest ‘housing need’ prediction scenario of 640
dwellings per annum.
- SLDC’s ‘housing need’ data indicates that its ‘building needs targets
should be reduced to the median value of 347 dwellings per annum.
- SLDC’s councillors appear to have been given incomplete advice by
their expert advisers before adopting the highest ‘housing need’
prediction from the four scenarios tested by the POPGROUP model.
- SLDC have not provided objective evidence to support their proposed
development of housing and employment units on important green field
sites.
- SLDC have not provided objective evidence for the level of ‘affordable
housing’ need in South Lakeland.
- SLDC have not provided objective evidence to support the use of one
funding model for ‘affordable housing’: making developers subsidise
35% affordable dwellings on all sites.
- Grange-over-Sands does not meet the SLDC Core Strategy criteria
required for designation as a Key Service Centre.
- SLDC have ignored key recommendations in the Grange-over-Sands
Regeneration Study 2007 that they claim had informed their
development proposals for Grange-over-Sands and district.
- Grange-over-Sands does not have appropriate facilities, roads or
infrastructure to cope with 500 additional dwellings.
- SLDC’s proposals will undermine the tourist industry that is the life
blood of the Grange-over-Sands and the Cartmel peninsula.
- SLDC have ignored the historical heritage of Kents Bank as a separate
community; it is not a suburb of Grange-over-Sands; it has a historical
heritage dating back to Mediaeval times.
- SLDC’s development proposals fail to protect the boundaries between
Kents Bank and Allithwaite from coalescence.
- SLDC’s development proposals erode the remaining green gaps
between Grange-over-Sands and Kents Bank.
- The Cartmel peninsula road system is already inadequate and cannot
absorb the extra traffic generated 734 new dwellings and an
unspecified number of additional employment units.
- It would be expensive and difficult to agree a route for a new trunk road
to the A590 that by-passed Grange-over-Sands.
- SLDC has a duty to ensure that the communities of Kents Bank and
Allithwaite retain their integrity and do not become part of a urban n
coastal sprawl that destroys the unique characteristics of Grange-over-
Sands and its surrounding area.
- The proposals for Grange-over-Sands and district are not sustainable
because they will destroy the town’s attraction as a unique coastal town
where tourists exploring the Cartmel peninsula will want to stay.
- SLDC’s consultation process has not been fair to local residents.
- Developers have been allowed to appoint Land Agents to lobby for
particularly desirable green field sites to be included in SLDC’s Land
Allocation DPD.
- SLDC’s consultation process has not been fair to local residents.
Proposals in the SLDC Land Allocations Development Plan Document are
NOT DELIVERABLE because:
- SLDC have provided no objective evidence that developers will be
prepared to develop prime sites on the basis of 35% affordable housing
in Grange-over-Sands and District.
- SLDC have made no provision for infrastructure development such as
upgrading roads, resolving water run-off drainage problems, utility
capacity etc...
- SLDC have made no provision for resolving two known traffic
bottlenecks on Risedale Hill and Main Street, Grange-over-Sands; key
sections of the B2577, the road that links Grange-over-Sands, Kents
Bank, Allithwaite and Flookburgh to the A590, Kendal, Lancaster and
the M6.
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
I do not support SLDC’s Land Allocation DPD
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
I wish to take part in the oral examination because SLDC have not made an adequate response to significant planning concerns, raised by local residents, during earlier consultation phases, particularly those relating to:
1. ‘Housing need’ in the Grange-over-Sands area.
2. Proposed green field site land allocations for the Grange-over-Sands area.
3. The adverse impact of the proposed developments on tourism, the life-blood of Grange-over-Sands and the Cartmel Peninsula.
4. The inadequate road system that links Grange-over-Sands to other SLDC Service Centres.
In addition, SLDC have not provided objective evidence that justifies their classification of Grange-over-Sands as an SLDC Key Service Centre. Grange-over-Sands does not meet SLDC’s Core Strategy Document definition of Key Service Centre: it does not have a secondary school and it is not directly linked to other SLDC Service Centres by a main trunk road.
Nor does the SLDC Land Allocation DPD take account of local residents’ wishes about how their community should be developed, or the views of Grange-over-Sands Town Council.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
480. Mrs Valerie Kennedy (Individual) : 16 May 2012 11:51:00
A typed or handwritten document was submitted. This has been scanned and can be downloaded below:
Paragraph No.
0.0 Whole Document
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
1. SLDC should not include Grange-over-Sands as one of its Key Service Centres because it does not meet the criteria in CS1.2 The development strategy for Principal Service Centres, Key Service Centres and Local Service Centres. This would mean that the number of proposed developments in Grange-over-Sands and district should be reduced and all proposed development sites should be reassessed. Development of brown field sites, such as Berners, should be prioritised and SLDC should take account of the views of local residents and Grange-over-Sands Town Council.
2. SLDC have not followed Government guidance about the use and interpretation of household surveys. They have not provided objective evidence to justify ‘housing need for Grange-over-Sands and District.
3. SLDC should be required to produce objective evidence to justify their plans to allow Grange-over-Sands to develop into a coastal urban sprawl incorporating Kents Bank.
4. SLDC should be required to remove sites MN25N, R672 and R79# from their Land Development DPD because development of these sites will lead to coalescence between the communities of Kents Bank and Allithwaite.
5. SLDC should be required to remove sites R449, R74 and R110 from their Land Development DPD because development of these sites will lead to further coalescence between the communities of Grange-over-Sands and Kents Bank.
6. SLDC should be required to produce clear evidence about how their proposed developments will enhance tourism in Grange-over-Sands and district.
7. SLDC should be required to explain why they have ignored recommendations made about green field sites and tourism in the Grange-over-Sands Regeneration Study (Douglas Wheeler Associates, November 2007), that they claim has informed SLDC's Core Strategy.
8. SLDC should be required to provide objective evidence that the local roads are adequate to support the proposed increase in population and traffic in Grange-over-Sands especially for known bottle-necks in Main Street and on Risedale Hill.
9. SLDC should not allow any development on prime green field land between Kents Bank and Allithwaite because it will lead to coalescence between these two separate communities.
1.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
I do not support SLDC’s Land Allocations DPD because it is based on spurious ‘housing need’ targets and has unnecessarily ear-marked important greenfield sites for development.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Mrs Kennedy wishes to emphasise that the submitted response relates to all of the following:
LA1.1 Development boundaries: to ensure that new homes and workplaces are delivered in sustainable locations and to protect the character of the surrounding landscape.
LA1.2 Town centre boundaries: to maintain and enhance the vitality, viability and sustainability of the District’s town centres.
LA1.3 Housing allocations: to allocate available, deliverable and sustainable sites for a range of types and sizes of new housing to meet the needs of all sectors of the community.
LA1.9 Green gaps: to provide a framework for maintaining the framework of separate identities of communities in the District by maintaining visual and functional separation. (refers to Grange-over-Sands/Allithwaite boundary; ignores Grange-over-Sands/Kents Bank and Kents Bank/Allithwaite boundaries)
LA1.10 Existing green infrastructure purpose: to ensure that new development safe guards and where possible enhances the District’s green infrastructure.
LA3.2: Mixed use allocation at land south of Allithwaite Road, Kents Bank Grange-over-Sands:
LA3.3: Mixed use allocation at Guides Lot, Grange-over-Sands
And Core Strategy policies:
CS1.1 Sustainable development principles
CS1.2 The development strategy for Principal Service Centres, Key Service Centres and Local Service Centres
CS6.1 Meeting the housing requirement especially
CS6.2 Dwelling mix and type
CS6.3 Provision of affordable housing
CS7.1 Meeting the employment requirement
CS7.2 Type of employment land required and sectoral split
CS7.5 Town Centre and retail strategy – support will be given to maintaining the vitality and viability of town and local centres
CS7.6 Tourist development
CS8.1 Green infrastructure
CS8.2 Protection and enhancement of landscape and settlement
Especially site numbers:
Grange-over-Sands/Kents Bank: R449, R74 and R110
Kents Bank/Allithwaite: MN25N, R672, R79# and R89
The following text of response 11288 is taken from sections 1, 2 and 3 of my response to SLDC’s Land Allocation Development DPD consultation, in a report: ‘Soundness’ response to SLDC’s Land Allocation Development Plan (DPD, Jan 2012) focussing on SLDC’s ‘housing need’ predictions & SLDC’s vision for Grange-over-Sands and District.
My report included photographs, maps and tables to support comments that were made in the report. I have requested that this report be made available to the Planning Inspector.
The sections featured in response 11288 are:
1. Is SLDC’s interpretation of the Strategic Housing Market Assessment ‘sound’ in terms of the number of dwellings needed over the next 15 years?
2. Is SLDC’s policy for financing ‘affordable housing’ ‘sound’ and sustainable?
3. Does Grange-over-Sands meet SLDC’s Core Strategy criteria for a Key Service Centre?
The tables that were included with the text in the report have been stored elsewhere, formatting that clarified the text has been removed and spurious question marks have appeared that are not in the original text.
[The full report is attached]
1 Is SLDC’s interpretation of the Strategic Housing Market Assessment
‘sound’ in terms of the number of dwellings needed over the next 15 years?
1.1 The South Lakeland District 2011, Strategic Housing Market Assessment: Main Report
(October 2011) ARC4 states that a multi-method approach was used to model SLDC’s
‘housing need’ for the next 15 years including:
- A household survey.
- Interviews with key stakeholders.
- A review of relevant secondary data.
1.2 All four of the POPGROUP SLDC model predictions in ARC4 ‘s report rely heavily on
data from household surveys but, UK guidance* for Local Authorities states:
“…Throughout the guide there is an assumption that secondary data (ie data from local
administrative or national data collection exercises rather than specially commissioned
surveys or interviews) should be used where appropriate and feasible…” (page 16) and
*Strategic Housing Market Assessments: Practice Guidance Version 2, Department for Communities and Local Government. August 2007 (see Government web site)
1.3 The SLDC SHMA Report 2011 states that there was an overall 26% response rate to the
June 2011 household survey.
1.4 This is disingenuous. The response rate quoted is a percentage return of the number of
surveys sent out but, only 36.6% of SLDC occupied households were sent surveys.
1.5 Of those 37% households surveyed only 26% of households replied.
1.6 Therefore the survey information used was provided by 9.2% of the occupied
households on SLDC’s 2011 Council Tax register; this is not a representative sample.
1.7 In addition, only 67% of the households who replied are covered by the SLDC Land
Allocation Plan because the rest live in National Park areas that are outside the scope of
SLDC’s Land Allocation Development Plan.
1.8 The SLDC SHMA Report 2011 states that the total response rate was well in excess of
the 1,500 specified in Government guidance but gives no reference to the source of this
information.
1.9 If the aim was for at least 1,500 responses this is 8.9% of the surveys sent out or 3.3%
of occupied households on SLDC’s 2011 Council Tax register; neither are representative
samples therefore the information provided by the survey will include unquantifiable bias
as well as being impossible to verify.
1.10 Nor do these survey returns comply with recommendations in Annex C in the
Government Guidance on use of surveys which states:
“…Thirty per cent should be considered as an absolute minimum response rate. Fifty per
cent would be a good target, and in many areas, with the methods suggested above, it
should be achievable…” (page 23).
1.11 Even though the Government Guidance recommends that a 30% response rate should
be considered as an absolute minimum the SLDC SHMA report states that:
“…the survey element of the assessment is sufficiently statistically robust to undertake
detailed analysis and underpin core outputs of the study…”
1.12 This cannot be justified when the overall response rate to the surveys sent out was 26% and the response rate relative to occupied dwellings in South Lakeland was 9.2%.
1.13 The POPGROUP model used by ARC4 to project ‘housing need’ relies heavily on
information from a survey that was provided by 9’2% of the occupied households on
SLDC’s 2011 Council Tax register, and only 6.4% of the households who are covered by
the SLDC Land Allocation Plan.
1.14 The UK Government Guidance* also states:
“…Traditionally local surveys have been used although these can be costly to
administer and difficult to interpret…” (page 43)
1.15 It is not ‘sound’ to claim that the survey information is representative of the population
covered by SLDC’s Land Allocation document when it has been provided by only 9.2%
of SLDC’s occupied households.
1.16 There is no way to verify the accuracy of the information provided on the survey forms.
1.17 There is no reliable way of assessing the demographic bias of the survey information
relative to the households in SLDC. 2001 census information has been used in an
attempt to eliminate potential bias, but this is 11 years out-of-date!
1.18 The SLDC SHMA Report 2011 states that due to the demographic bias in the of the type of households replying to the survey the survey data for each sub-area was weighted by
comparison with 2001 census information on:
i. Tenure data: the proportion of affordable (social, rented and intermediate tenure)
and open market dwellings and
ii. Age of household reference person: under 60 and over 60 living in each of the
dwelling types.
1.19 SLDC’s Council Tax Database contains reliable, objective data that should have been
used as a source of information about changes in the number of occupied SLDC
households over the last ten years.
1.20 Information from SLDC’s Council Tax Database for 2001 to 2011 could have been
extracted and tabulated to provide information on: number of occupied households,
empty dwellings and second homes etc… for each of the last ten years.
1.21 The actual rate of growth in occupied households over the last ten years could then have been compared with the predicted growth from the four scenarios used for the
POPGROUP model.
1.22 The UK Government Guidance* also emphasises that the advantages of using
‘secondary data’ such as the Council Tax Database are that they:
i. Encourage consistency of approach between different authorities and housing
market areas.
ii. Reflect actual behaviour and events rather than aspirations.
iii. Often cheaper to obtain than primary data.
iv. Allows the monitoring of trends usually on an annual basis.
v. Can provide a picture of market conditions, based on small areas, which
identifies locational differences within housing market areas and
vi. The data are less affected by methodological problems of bias than surveys.
1.23 Table 1 below lists the main sources of data fed into the POPGROOUP model for
analysis as given in Appendix A of SLDC SHMA Report 2011.
1.24 It clearly demonstrates that the POPGROUP model relies heavily on information from
the SLDC household survey (2011; largely subjective and likely to be inaccurate for
questions on topics such as income) and Office for National Statistics (ONS) data
(based on national and regional trends).
1.25 ONS cautions on its website that:
“…Population estimates are calculated using a ‘top down’ approach. The national estimates for England and Wales are produced first; estimates for subnational areas are then produced and constrained to the national estimates. …” and
“…The data sources used are the best available on a nationally consistent basis. Information from administrative registers such as the numbers of births and deaths is reliable. However, estimates of international migration are largely derived from the International Passenger Survey (IPS) and are subject to sampling and non-sampling error…”
SEE TABLE 1 IN ATTACHED DOCUMENT
1.26 ONS warns on its website that:
“…Projections are uncertain and become increasingly uncertain the further they are carried
forward in time…
1.27 ONS population models are trend based with considerable uncertainties therefore
estimates for the future SLDC population and household characteristics derived from this
data should be interpreted with care because data used for SLDC projections may
include urban bias that is introduced because the NW region includes large urban
populations such as Liverpool and Manchester.
SEE TABLE 2 IN ATTACHED DOCUMENT
1.28 The POPGROUP demographic forecasting model is also trend based and uses a range of assumptions about natural change (births and deaths), migration and employment.
1.29 The ‘housing need’ predictions, per annum, for the whole of SLDC (including the Nation Park areas), from the four scenarios, range from 205 to 694 (Table 2, and Strategic
Housing Market Assessment report, Appendix C, page 49)
1.30 The mean of the four predictions is: 398 with a potential error of ± 296 dwellings per
annum, from the mean of the four predictions.
1.31 The median of the four predictions is: 347 with a potential error of +347 dwellings per
annum or -142 dwellings per annum, from the median of the four predictions.
1.32 The Strategic Housing Market Assessment report states many times that there is an
annual housing need of 640 per annum for SLDC (230: Lake District National Park; 9:
Yorkshire Dales and 402: SLDC), but the report does not explain how they have
selected these figures from the POPGROUP model predictions (Table 2).
1.33 ARC4’s proposed annual figure of 640 dwellings per annum is closest to the prediction of the labour force led POPGROUP scenario of 694 dwellings per annum: that is 240 more dwellings per annum than the average of the four scenarios, and, 293 more than the median of the four mode predictions.
1.34 The labour force led scenario is almost certainly an over estimate in terms of housing
need because it is be biased by information about National Insurance registrations for
overseas nationals applying for work during the period 2005/06 to 2009/10 (five years).
1.35 The five years selected will have a positive bias because the figures have been distorted by three years of exceptionally intensive cockling activity (when the price of cockles
rocketed in Europe), so that the Morecambe Bay cockle beds were fished out and
subsequently closed.
1.36 The figures for the labour force led scenario also include a high proportion of migrant
workers who come to the area for two or three years to improve their English and learn
Tourist industry service skills. They have no intention of living permanently in the area
and are frequently provided with accommodation by their employers. For example: The
Netherwood Hotel, Grange-over-Sands, Aynsome Manor Hotel, Cartmel, The Swan
Hotel, Newby Bridge etc…
1.37 The large error bars associated with the average and median values of the four
scenarios used to predict SLDC’s ‘housing need’ demonstrate the variability of the
underlying data and the need for careful interpretation of the results.
1.38 The average ‘housing need’ prediction has a positive bias because of weaknesses in the underlying employment data (see 1.35 and 1.36 above).
1.39 Given the uncertainties and weaknesses of the modelling data it would be more realistic to plan for a housing need using the median value of the four scenarios tested of: 347 dwellings per annum to determine ‘housing need’ throughput South Lakeland until 2025.
1.40 The selection of 640 dwellings per annum as SLDC’s housing need is not justified and is not supported by clear objective evidence.
1.41 Nor is it sustainable because the Land Allocation DPD does not make any provision for capital expenditure on infrastructure and services.
1.42 This would have the added advantage that it would not then be necessary to develop
important green field sites that should be part of the local heritage passed on to future
generations.
1.43 SLDC’s elected councillors cannot be expected to have the time and skills to read
through and understand the avalanche of documentation provided to support of the
housing need allocations; they therefore rely heavily of SLDC’s expert advisers.
1.44 It would appear that SLDC’s expert advisers gave incomplete information to councillors
about how the annual housing need figures were derived when councillors were asked
to approve SLDC’s Core Strategy document stating that there was an annual housing
requirement of 640 dwellings per annum.
1.45 Is it possible that SLDC selected a high housing need target because they have been
tempted by the UK Government’s offer of matched funding equivalent to the new build
Council Tax paid, for six years, for new build dwellings?
1.46 If so, SLDC have allowed a perceived short-term financial boost to cloud their judgement about the additional long-term costs of providing services to support their proposed housing need.
Section 1 Main Conclusions
SLDC’s annual ‘housing need’ targets are not sound because:
- The large error bars associated with the average and median values of
the four scenarios used to predict SLDC’s ‘housing need’ demonstrate
the variability of the underlying data and the need for careful
interpretation of the results.
- SLDC’s councillors appear to have been given incomplete advice by
their expert advisers before adopting the highest ‘housing need’
prediction from the four scenarios tested by the POPGROUP model
- SLDC’s ‘housing need’ data indicates that its ‘housing needs’ targets
should be reduced to the median value of 347 dwellings per annum.
- SLDC have selected the highest annual housing need prediction from
the four POPGROUP models tested.
- SLDC have not justified their ‘housing need’ selection of 640 dwellings
per annum with objective evidence.
- UK Government recommendations to Local Authorities recommend that
‘housing need’ prediction should not rely heavily on information supplied
by household surveys returned by a minority of households
- SLDC’s housing need predictions do rely heavily on information
provided from household surveys submitted by 6.4% of households
covered by SLDC’s Land Allocation Plan.
- SLDC may have selected a high annual housing need so that they
qualify for new build matched Council Tax funding from the UK
Government.
2 Is SLDC’s policy for financing ‘affordable housing’ ‘sound’ and sustainable?
2.1 SLDC defines Affordable housing as:
“…housing whether for rent, shared ownership or outright purchase, provided at cost
considered affordable in relation to income that are average, or in relation to the price of
general market housing…” (Source: glossary to the Allocations of Land Development
Plan Document, Emerging Site Options, Spring 2011).
2.2 This definition lacks clarity and is open to a wide range of interpretations.
2.3 ARC4’s SLDC Strategic Housing Market Assessment report relies heavily on survey
information which cannot be verified and needs to be interpreted with care (see
discussion in section1).
2.4 Survey information provided about the standard of accommodation and overcrowding
may be exaggerated by respondents who want to be re-housed.
2.5 The ‘housing need’ aspirations of some respondents may not be achievable for a wide
variety of reasons that are outside the control of SLDC.
2.6 SLDC’s Land Allocation DPD does not provide clear information about the number and
type of affordable dwellings that have been allocated to specific development sites eg
social, handicapped, sheltered, affordable rents for those who do not qualify for benefits,
shared ownership schemes, reduced price for affordable mortgages etc….
2.7 SLDC state that ‘affordable housing’ is divided into a range of categories but they do not
provide information about which categories are needed for specific development sites
supported by objective information justifying the use of sites selected those categories.
2.8 As part of the 2011 consultation exercise Cumbria County Council recommended that
MN25N, the important green gap site separating Kents Bank and Allithwaite, should only
be developed “…if a strategic housing allocation is required in the area…” but SLDC
have provided no evidence about the type of ‘affordable housing’ needed on this site and
no evidence to justify the need for 71 affordable dwellings at this specific location.
2.9 SLDC estimates for the number of ‘affordable houses’ needed throughout the district
cannot justified because they have not provided objective information about the number
of households on the waiting list for ‘affordable housing’ by SLDC service area, or by
type eg Kendal, Grange-over-Sands, single person, disabled, sheltered housing need,
family etc…
2.10 According to UK Government Advice to Local Authorities they should hold reliable data
about: “…the number of homeless families, those in temporary accommodation and the
extent of overcrowding…”
SEE TABLE 3 IN ATTACHED DOCUMENT
2.11 Table 3 summarises information about SLDC’s ‘affordable housing’ stock in the Cartmel peninsula provided on South Lakes Housing’s web pages. South Lakes Housing also provides information about their ‘affordable housing’ stock for the whole of South
Lakeland.
2.12 SLDC should therefore also have access up-to-date information about the number of
people on waiting lists for these of dwellings, the length of time that they have been on
the waiting list and the areas where they need accommodation that could have been
used to produce more accurate predictions about ‘affordable housing need’.
2.13 But, SLDC have provided no factual information about the number of households on
their waiting lists for affordable housing between 2002 and 2012 for each SLDC area
(Kendal, Ulverston, Grange-over-Sands etc…) showing type required (single person,
family, sheltered, disabled etc…) and typical waiting times. Why not?
2.14 The different terms and conditions for each ‘affordable housing’ development do not
preclude SLDC establishing a ‘master affordable housing list’, with information about the
geographical areas, the type of need (handicapped, sheltered housing, family housing,
retirement housing, ‘average income’ housing to rent or buy etc…) so that there is more
reliable data for the future modelling of local housing need.
2.15 The UK Government guidance also states that Cenus information should be used to
extract information about overcrowding and ‘hidden’ households, and, if this information
is out-of-date it can be compared with data from the Survey of English Housing (SHE) at
a regional level.
2.16 Reliable data from the National Census of 2011 will be released in July 2012; why hasn’t SLDC waited until this is available so that their estimates of affordable housing need are more reliable?
2.17 SLDC’s projected ‘affordable housing’ requirement for the Cartmel peninsula area is not based on objective data either in terms of numbers, or, areas of the District with a
particular ‘affordable housing’ need it is largely based on returns from survey
questionnaires (see Appendix 2).
2.18 SLDC has stated that the Grange-over-Sands area has an ‘affordable housing’ need of
35% of all new builds; their projected ‘new-build’ need of 501 (between 2010 and 2025)
equates to 175 ‘affordable’ residential units. But, the number of houses allocated to
Grange-over-Sands and district is an apparently arbitrary percent of SLDC’s projected
‘housing need’ assessment and is not allocated on evidenced need.
2.19 ‘Affordable housing’ is needed on the Cartmel Peninsula (including Grange-over-Sands and district) but, SLDC have not justified a specific need for 175 ‘affordable dwellings’ for the Cartmel peninsula based on objective evidence.
2.20 Nor have SLDC provided evidence that their overall ‘housing need’ policies, based on
the provision of 35% ‘affordable housing’, financed by subsidies from large development
projects requiring the use of swathes of ‘green gap’ land, are viable (see section 4).
2.21 The Conservative/Liberal Democrat Coalition Government has stated that it plans to
devolve more power to local councils for local planning decisions.
2.22 SLDC has completely ignored Grange-over-Sands Town Council submission to the 2011 consultation exercise as well as informed submissions from local residents. This attitude cannot be justified.
2.23 Recommendations by local councils about suitable development sites, local ‘affordable housing’ need and local infrastructure needs should be incorporated into the SLDC’s Land Allocation DPD to comply with Coalition Government policy.
2.24 SLDC’s ‘affordable housing’ policy depends on developers being forced to subsidise
‘affordable housing’ by allocating 35% of any dwellings built as ‘affordable houses’ but
they provide no objective evidence that this is feasible.
2.25 No examples are given of developers who have successfully developed sites on this
basis in the Cartmel peninsula. Are there any?
2.26 The more likely scenario is that developers will get planning permission and then claim that it is not financially viable for them to proceed on the 35% ‘affordable housing’ basis and then negotiate a reduced percentage of ‘affordable housing’ or, for the price of the ‘affordable housing’ to be raised.
2.27 In addition SLDC have not justified their selection of specific sites for ‘affordable housing’ with an objective evaluation of whether or not land proposed for development is in a suitable location for people who need affordable housing.
2.28 SLDC have not justified their reasons for ignoring other ways of financing ‘affordable
housing’ such as:
i. Using the Council Tax from second homes and holiday lets to set up a fund to
finance grants to local housing associations for new build affordable housing.
ii. Using funds from the SLSC reserve to make relatively low interest loans to local
residents who qualify for ‘affordable housing’ and who can prove that they have
paid their rent regularly for at least three years.
iii. Providing incentives for private owners to rent out empty properties as ‘affordable
housing’ eg grants to modernise properties that are made available for three years
or more, arrange for housing association to administer property (including
maintenance) at no extra cost to owner etc...
iv. Providing incentives for long-term residents of ‘family council houses’ to move to
smaller properties.
v. Developing a more effective system to ensure that housing association properties
are not sub-let by people moving away from the area due to changing their job; this
has happened and there do not appear to be effective systems to prevent it.
Section 2: Summary of main ‘affordable housing’ conclusions
SLDC’s annual ‘affordable housing need’ targets are NOT JUSIFIED because:
- Their definition of ‘affordable housing’ lacks clarity and is open to wide
interpretation.
- They are not based on objective evidence such as area waiting lists.
- They have not provided objective evidence that it is viable for developers to
develop site with a 35% ‘affordable housing’ requirement.
- They have not provided evidence that specific sites are suitable for the type of
‘affordable housing’ proposed.
- They have not considered alternative ways of financing ‘affordable housing’.
3 Does Grange-over-Sands meet SLDC’s Core Strategy criteria for a Key
Service Centre?
3.1 SLDC’s Land Allocation Plan states that Grange-over-Sands meets the criteria for
consideration as a Key Service Centre.
3.2 Section 2.10 of SLDC’s Core Strategy document justifies including Grange-over Sands
as a Key Service Centre because: “…
- It has good public transport links to outlying settlements.
- A primary school, a 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…”
3.3 Key Service Centre status is not justified because Grange-over-Sands does not meet
the public transport criteria for links to the outlying settlements. It is covered by the 532
Grange Area Bus Service:
- On Mondays to Saturdays the first circular bus leaves Grange station at 0800 hours
and the last bus leaves Grange station at 17.00.
- There are no buses linking the outlying villages in the evening.
- There are no buses linking the outlying villages on Bank Holidays or Sundays.
3.4 This means that residents of the Cartmel peninsula, including Grange-over-Sands and
district, are not able to use public transport if they wish to attend evening classes or
attend events organised at local community centres and village halls.
3.5 Key Service Centre status is not justified because Grange-over-Sands does not have a
secondary school which is listed as a requirement for Key Service Centres.
3.6 All children between the ages of 11 and 16 have to be bussed to Cartmel Priory school;
the local roads have no pavements and it would be dangerous for them to walk.
3.7 All children over 16 years old, living in Grange-over-Sands and district, have to travel by
bus or train to Kendal (15 miles), Milthorpe (12 miles), Ulverston (18 miles), Lancaster
(27 miles) or Barrow-in-Furness (27 miles) for sixth form and further education.
3.8 The introduction to SLDC’s Core Strategy document states: “ …Key Service Centres of
Grange-over-Sands, Milnthorpe,… are the main centres of provision of services and
employment for their hinterlands…” (page 10)
3.9 This is not justified because Grange-over-Sands is not the main centre of employment
for the Cartmel peninsula. Many workers living in this area commute to Kendal,
Lancaster, Ulverston and Barrow-in-Furness some also travel further afield to Sellafield
and Preston.
3.10 In most cases small business units would not provide these commuters with an
equivalent income to the one that they already have.
3.11 In 2003, when my workplace was transferred from Merlewood Research Station to
Lancaster University campus, no local employer would have paid me a salary that would
have made it worth changing jobs, even though I had considerably increased travel
costs at the new location and a 70 mile a day round trip to work.
3.12 Apart from retail shops and other tourist related businesses, such as hotels, most small businesses are based in Flookburgh with some in Cartmel, Allithwaite and Lindale, and a few in Grange-over-Sands.
3.13 There have been no large employers in Grange-over-Sands since the Natural
Environment Research Council’s Centre for Ecology and Hydrology was re-located from
Merlewood Research Station to the University of Lancaster Campus in October 2003
(80-90 staff). This property is now owned by the Holiday Bond Company. It has been
converted to luxury self-catering holiday apartments and currently has about six
employees.
3.14 SLDC’s Core Strategy document states that the Regional Spatial Strategy recommends:
“…that development in rural areas should be concentrated in these Key Service Centres
and should be of a scale and nature appropriate to fulfil the needs of local communities
in terms of housing, employment and services, and to enhance the quality of rural life…”
3.15 The development proposed for Grange-over-Sands and district is not appropriate in
terms of proposed housing, employment, services or quality of rural life (see section 4).
3.16 Grange-over-Sands does not have a hospital. All patients needing minor hospital
treatment have to travel to Kendal (30 mile round trip); those needing more specialist
treatment have to travel to Barrow-in-Furness or Lancaster (both approximately 54 mile
round trips).
3.17 Given the inadequacy of local roads trips to local hospitals are already time consuming; this will be considerably worse if 735 additional dwellings and an unspecified number of employment units are built in Grange-over-Sands and district before upgrading local roads (see also section 7).
3.18 A few days ago the family of a man in Grange-over-Sands who was assessed as
needing urgent medical treatment was told that there would be at least a four hour wait
for an ambulance and were recommended to find an alternative method of getting him to
hospital. Unfortunately this is not an isolated example.
3.19 This is evidence that Grange-over-Sands does not have the capacity to act as a Key
Service Centre for existing households.
3.20 How is the University of Morecambe Bay NHS Trust going to cope with the increased
number of households proposed by SLDC?
3.21 The ‘main’ road to Grange-over-Sands, from the A590 Meathop roundabout, is the
B5277 that also links Grange-over-Sands to Kents Bank, Allithwaite, Flookburgh, Cark
and Holker. Other villages in the Grange-over-Sands hinterland are linked by C roads.
3.22 Milnthorpe (A6) and Kirbky Lonsdale (A65), the other towns that SLDC has identified as
Key Service Centres, are linked directly to other towns and to the M6 by A roads making
them easily accessible.
3.23 Grange-over-Sands is not directly linked to SLDC Principal Service Centres, to other
Key Service Centres or to the M6 by a trunk road therefore SLDC cannot justify
identifying Grange-over-Sands as a Key Service Centre.
3.24 Grange-over-Sands is primarily a small coastal town that relies on tourism.
3.25 Tourists are attracted to Grange-over-Sands because of its unique heritage as a
Victorian coastal town surrounded by gentle limestone hills with traditional fell pastures
therefore it would be detrimental to Grange-over-Sands’ attraction as a tourist
destination if these pastures are built over as proposed in SLDC’s Land Allocation
document.
3.26 Grange-over-Sands does not meet the criteria of a Key Service Centre defined in
SLDC’s Core Strategy document SLDC are not justified proposing large-scale housing
and employment developments in Grange-over-Sands and District.
3.27 Section 2.20 of SLDC’s Core Strategy document states:”… the amount of land allocated in each Key Service Centre will have regard to: the capacity of existing services to
accommodate development; critical thresholds for new service investment; the size,
character and environmental capacity of the existing settlement; and the need to secure
regeneration and/or investor confidence…”
3.28 Again SLDC appear to have ignored their own criteria when defining Grange-over-Sands as a Key Service Centre suitable for large scale housing and employment developments because:
- The Grange-over-Sands and district road system is already inadequate (mainly C
roads; linked to A590 by B5277).
- Utility provision in Grange-over-Sands is inadequate and would need major capital
investment to sustain the proposed developments.
- The topography and environmental value of green spaces in Grange-over-Sands and
district will be destroyed along with tourism, the ‘life blood’ of the Cartmel peninsula if
development on the scale proposed is permitted.
3.29 It would appear that SLDC councillors were given inadequate information when they
voted to accept Planning Department recommendations, in SLDC’s Core Strategy
document, to classify Grange-over-Sands as a Key Service Centre.
3.30 There are only two SLDC District councillors for Grange-over-Sands so that their
representations on behalf of Grange-over-Sands and District are easily over-ridden by
the majority of councillors from Kendal and Ulverston.
3.31 Historically SLDC has also ignored representations from Grange-over-Sands Town
Council even though they are elected representatives of the local community. Why?
SLDC have ignored their stated objective of ensuring:
“…the adequate provision of additional housing…in a way that gives priority to the
housing needs of the town…”
Section 3: Should Grange-over-Sands be a Key Service Centre:
Summary of main conclusions
- Grange-over-Sands does not meet SLDC’s criteria for a Key Service
Centre therefore it should not have been classified as an SLDC Key
Service Centre.
- Grange-over-Sands should be treated as a small coastal town that is
dependent on the tourist industry and has unique development needs.
- Grange-over-Sands is not suitable for large scale development because
of its topographical location; the surrounding rough pasture lands are
part of its attraction.
- All proposed development should be considered in this context and
should be concentrated on brown field sites.
- Grange-over-Sands’ proximity of other local communities means that it
is inappropriate allow green field developments that will lead to Grange-over-
Sands absorbing other settlements.
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
I do not support SLDC’s Land Allocations DPD because it is based on spurious ‘housing need’ targets and has unnecessarily ear-marked important greenfield sites for development.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
I wish to take part in the oral examination because SLDC have not made an adequate response to significant planning concerns, raised by local residents, during earlier consultation phases, particularly those relating to:
1. ‘Housing need’ in the Grange-over-Sands area.
2. Proposed green field site land allocations for the Grange-over-Sands area.
3. The adverse impact of the proposed developments on tourism, the life-blood of Grange-over-Sands and the Cartmel Peninsula.
4. The inadequate road system that links Grange-over-Sands to other SLDC Service Centres.
In addition, SLDC have not provided objective evidence that justifies their classification of Grange-over-Sands as an SLDC Key Service Centre. Grange-over-Sands does not meet SLDC’s Core Strategy Document definition of Key Service Centre: it does not have a secondary school and it is not directly linked to other SLDC Service Centres by a main trunk road.
Nor does the SLDC Land Allocation DPD take account of local residents’ wishes about how their community should be developed, or the views of Grange-over-Sands Town Council.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
481. Mrs Valerie Kennedy (Individual) : 16 May 2012 12:00:00
A typed or handwritten document was submitted. This has been scanned and can be downloaded below:
Policy/Site No.
LA1.3 Housing Allocations - All Grange-over-Sands sites
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
1. SLDC should not include Grange-over-Sands as one of its Key Service Centres because it does not meet the criteria in CS1.2 The development strategy for Principal Service Centres, Key Service Centres and Local Service Centres. This would mean that the number of proposed developments in Grange-over-Sands and district should be reduced and all proposed development sites should be reassessed. Development of brown field sites, such as Berners, should be prioritised and SLDC should take account of the views of local residents and Grange-over-Sands Town Council.
2. SLDC have not followed Government guidance about the use and interpretation of household surveys. They have not provided objective evidence to justify ‘housing need for Grange-over-Sands and District.
3. SLDC should be required to produce objective evidence to justify their plans to allow Grange-over-Sands to develop into a coastal urban sprawl incorporating Kents Bank.
4. SLDC should be required to remove sites MN25N, R672 and R79# from their Land Development DPD because development of these sites will lead to coalescence between the communities of Kents Bank and Allithwaite.
5. SLDC should be required to remove sites R449, R74 and R110 from their Land Development DPD because development of these sites will lead to further coalescence between the communities of Grange-over-Sands and Kents Bank.
6. SLDC should be required to produce clear evidence about how their proposed developments will enhance tourism in Grange-over-Sands and district.
7. SLDC should be required to explain why they have ignored recommendations made about green field sites and tourism in the Grange-over-Sands Regeneration Study (Douglas Wheeler Associates, November 2007), that they claim has informed SLDC's Core Strategy.
8. SLDC should be required to provide objective evidence that the local roads are adequate to support the proposed increase in population and traffic in Grange-over-Sands especially for known bottle-necks in Main Street and on Risedale Hill.
9. SLDC should not allow any development on prime green field land between Kents Bank and Allithwaite because it will lead to coalescence between these two separate communities.
1.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
I do not support SLDC’s Land Allocations DPD because it is based on spurious ‘housing need’ targets and has unnecessarily ear-marked important greenfield sites for development.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The following text of response 11289 is taken from sections 4 and 7 of my SLDC LDF consultation submission entitled: ‘Soundness’ response to SLDC’s Land Allocation Development Plan (DPD, Jan 2012) focussing on SLDC’s ‘housing need’ predictions & SLDC’s vision for Grange-over-Sands and District.
My report included photographs, maps and tables to support comments that were made in the report. I have requested that this report be made available to the Planning Inspector.
The sections featured in response 11289 are:
4. (Does SLDC's Land Allocation Document protect the needs of Grange-over-Sands as a unique coastal tourist destination?
7. Does SLDC's Land Allocation Document make adequate provision for capital expenditure to upgrade local roads?
Photographs that were included with the text in the report have been stored elsewhere, formatting that clarified the text has been removed and spurious question marks have appeared that are not in the original text.
[The full report is attached]
4 Does SLDC’s Land Allocation Document protect the needs of Grange-over-
Sands as a unique coastal tourist destination?
4.1 SLDC’s Land Allocation Plan states that the Grange-over-Sands Regeneration Study
(November 2007), Douglas Wheeler Associates, has informed SLDC’s Core Strategy.
4.2 The Grange-over-Sands Regeneration Study states that Grange-over-Sands is:
i. North West England’s most distinctive, contemporary coastal resort town that has
used its Edwardian heritage as a strong asset in its regeneration.
ii. An exceptionally pleasant, very well maintained and friendly town with:
- An impressive promenade and superb views across Morecambe Bay.
- Excellent parks and garden.
- A well connected rail station.
- A strong community of established and new residents.
- A great place to live, work and visit.
iii. Has a strong convenience retailing and service orientated focus.
4.3 SLDC’s Core Strategy document states that:
"...We aim to achieve a balanced housing market by securing the provision of a range of
housing types and sizes to meet the needs of all sectors…” and
“…The exact scale and level of development supported will be dependent on individual
character, the impact on environmental capacity and infrastructure provision, and the
desire to meet the need for affordable housing as locally as possible…”
4.4 The proposed developments in SLDC’s Land Allocation document for Grange-over-
Sands and district have not achieved this objective because:
- They will increase the number of households by 25%.
- Local roads do not have the capacity to absorb the extra traffic that will be
generated.
- They will allow building on important green field sites.
- They will lead to the coalescence of Grange-over-Sands with adjacent
communities.
4.5 The questionable SLDC ‘new build’ target has been arbitrarily divided between defined
areas of South Lakeland district, on a percentage basis, between the Principal Service
Centres, Key Service Centres and rural areas.
4.6 The housing allocation made for Grange-over-Sands was based on its classification as a Key Service Centre but, as it does not meet the SLDC’s stated criteria for a Key Service
Centre (see Section 3), the housing allocation is not compatible with its needs as a
unique coastal tourist destination.
4.7 The allocation of new build’ for Grange-over-Sands, Kents Bank, Allithwaite and Cartmel
peninsula area does not appear to have factored in:
- The high percentage of retired people living in the area: a proportionally higher
amount of the existing housing stock will be available for ‘new’ households, on a
regular basis, due to the higher mortality.
- The high percentage of dwellings that are ‘second homes’ and ‘holiday lets’ some of
which are likely revert to normal residential use over time eg eight apartments in
Kents Bank were converted from ‘holiday apartments’ to ‘normal residential’
apartments in 2010.
4.8 SLDC has not justified the need for a massive ‘new build’ requirement in Grange-over-
Sands and district with objective evidence.
4.9 There is a need for ‘affordable housing’ but even that need has not been quantified
objectively.
4.10 The overall ‘new build’ housing figures have been inflated because of the policy of
requiring developers to subsidise ‘affordable housing’ (see section 2).
4.11 SLDC’s proposals will lead to a 25% increase in the number of households in Grangeover-Sands and Kents Bank without any provision for improvements to the local road
system or car parking facilities or utilities; this will be detrimental to the tourist industry.
4.12 Section 4.4 of SLDC’s Land Allocation document states:
“…Douglas Wheeler Associates prepared a Regeneration Study for Grange-over-
Sands in 2007. This carried out a detailed assessment of Grange as a Key
Service Centre that formed the basis of Core Strategy policies for the town…”
4.13 The independent Grange-over-Sands Regeneration Study 2007 found:
“…Around 7.5% of properties are second homes and clearly Grange should not become
dominated by second homes and retirement homes…”
4.14 If SLDC’s proposal to build 500 dwellings in Grange-over-Sands and district is realised the likely outcome will be to increase in the number of ‘second homes’, ‘holiday homes’, and ‘in-coming’ pensioners in order to subsidise 175 ‘affordable homes’; SLDC have not provided evidence to justify this need.
4.15 Building on this scale will not benefit the local community because it will lead to an
increased pressure on the NHS, local roads, public transport, utilities etc… and have an
adverse effect on local tourism.
4.16 There are currently 129 dwellings on the market in Grange-over-Sands and district
ranging from one and two bed-roomed apartments to large detached houses and
everything in between. Many of these properties have been on the market for over two
years; many others have been taken off the market and turned into private rented
accommodation. So, how can SLDC justify the need for 325 more new dwellings on the
open market?
4.17 The Grange-over-Sands Regeneration Study 2007 also stated that:
“…Additional housing will be provided to meet the needs of local people without
damaging the sensitive setting and character of the town…” and
“…the key to the success or failure of Grange-over-Sands…will be to invest in the
unique quality of the built and natural environment, infrastructure and public facilities
alongside promoting enterprise and business development…” and
“…It only requires one element to be below standard to reduce the overall appeal of the
place…”
4.18 Residents of Grange-over-Sands and district would agree with all the above objectives
but feel that SLDC’s Land Allocation DPD proposals do not match this expectation. For
instance, the study looked at Grange-over-Sands land development options in detail. It
recommended that land ‘north of playing field’ (R110: Trickett’s field) should not be
developed because: “…loss of open views from street is negative…”
4.19 This site is also important because it is one of the few remaining green gaps between
Grange-over-Sands and Kents Bank (see section 5).
4.20 The Grange-over-Sands Regeneration Study 2007 also stated that it was important to:
“…protect the network of green spaces and important environmental characteristics of
the town and its setting…” and
“…protect the network of green spaces and important characteristics of the town…give
priority to the use of previously developed land for development…”
4.21 Brown field sites such as Berners, the former candle factory and Bateman’s garage
should be developed for housing and employment before any green field sites are
considered; sensitive development of brown field sites will not destroy the rural
ambience of the area that is so attractive to tourists.
4.22 Tourism is the life-blood of Grange-over-Sands’ economy. SLDC is not justified in
proposing large scale developments on green field sites before undertaking a feasibility
study assessing the impact of the proposed developments on tourism. They have not
done this. Such arrogance is negligent given the potential impact on the local tourist
industry.
4.23 It is unlikely that tourists will want visit the Grange-over-Sands area during the
construction phases due to the impact on the already inadequate road system (see
section 7); post construction, who wants to visit a coastal urban sprawl?
4.24 Investment in basic infrastructure is needed before any major increase in housing but
the SLDC Land Allocation Development Plan does include any provision for solving the
known traffic bottle-necks of Risedale Hill and Main Street Grange-over-Sands (see
section 7). Why not?
4.25 Section 4.2 of the SLDC Land Allocation DPD states:
“…The Core Strategy (Policy CS4) sets the overall context for development in Grangeover-
Sands. This seeks to make provision for moderate housing development and
employment development, regenerate the Berners site, improve public transport, reinstate
footbridges and protect the network of Green Infrastructure as well as promoting
the vitality of Grange town Centre and promoting tourism…”
4.26 Local residents support all these objectives, but, the land development proposals that
SLDC have proposed for Grange-over-Sands and district contradict these objectives;
they have not protected the network Green infrastructure (see sections 5, 6 and 7) and
they have not promoted tourism, nor have they justified proposing to development of
green field sites with objective evidence.
4.27 As the Grange-over-Sands Regeneration Study 2007 said of Grange-over-Sands it is
important to:
- Maintain and enhance the viability of the town centre.
- Promote…appropriate development at the Berners Pool/BernersClose car
park/nursery/lido site to create a new focus.
- Promote the vitality and viability of Grange-over-Sands town centre.
- Promote the reintroduction of the Berners Close railway bridge.
- Focus on renovation rather than demolition.
- Minimise the impact on the environment and improve biodiversity
Unfortunately SLDC’s Land Allocation DPD appears to have lost sight of these
objectives.
Section 4: Grange-over-Sands, a unique coastal town;
summary of main conclusions
- Grange-over-Sands is a unique coastal town that is dependent on the tourist
industry and has unique development needs.
- Grange-over-Sands is not suitable for large scale development because of its
tourist needs; the surrounding rough pasture lands are part of its attraction.
- All proposed development should be considered in this context and should be
concentrated on brown field sites as recommended in the Grange-over-Sands
Regeneration Study 2007.
- The local road system, utilities and community support systems are already
inadequate; they are not robust enough to support 500 more households.
- The surrounding topography and proximity of other local communities means
that it is inappropriate allow large scale developments to extend into Kents
Bank or onto peripheral rough pasture land.
7 Does SLDC’s Land Allocation Document make adequate provision for
capital expenditure to upgrade local roads?
7.1 Allithwaite Road (B5277) is already inadequate for the amount of traffic regularly
travelling between Grange-over-Sands, Allithwaite, Flookburgh, Holker Hall, Kendal,
Lancaster and the M6.
7.2 The traffic problem is exacerbated when regular events such as Cartmel Races and
the Holker Garden Festival attract large crowds.
7.3 The stretch of Allithwaite Road between Kents Bank and Allithwaite from the top of
Risedale Hill is a fast stretch of undulating road that poses sight line problems for
drivers (see picture 3, section 6.15).
7.4 Developers would be forced to create new roads for development area MN25M linking
onto Allithwaite Road; this would increase traffic hazards on Allithwaite Road, or, lead
to the creation of an intrusive roundabout system that would destroy the rural nature
of this road and area
7.5 Greaves Wood Road bridleway forms the eastern, and southern, boundaries of
MN25M; it could not be used as access to MN25M development area because of a)
the Protected Limestone Pavement in Greaves Wood and b) it is a popular pedestrian
route for local residents, especially dog walkers (see Map 1, section 5.7 and Map 3,
section 6.4).
7.6 Access from Kirkhead Road to the MN25M development area is not practical; there
are no suitable gaps between the houses whose back gardens form the western
boundary of MN25M.
7.7 Industrial development and 202 residential units will generate a large amount of extra
traffic in Kents Bank that will all need to drive through Grange-over-Sands to reach the
A590 for access to Kendal, Lancaster and the M6; the local road system is not
suitable for this.
7.8 Local roads are not adequate to accommodate service vehicles for industrial
development.
PICTURES - see attached document
7.9 SLDC are also proposing to build dwellings on the land behind the lorry on Allithwaite
Road (picture 6) and on the left hand side of Allithwaite Road beyond the junction of
Allithwaite Road with Jack Hill (junction to the left of Kirkhead Road; picture 6); access to both these sites is constrained by their location and will cause road safety
problems.
7.10 Picture 5 clearly shows that it is not possible to widen or straighten Risedale Hill
without major road works involving compulsory purchase orders, demolition of walls
and completely altering the character of this part of Kents Bank and that the road is
not suitable for large volumes of traffic.
7.11 Traffic from three other nearby proposed residential developments in Kents Bank,
R672M: 36 residential units & R89: 45 residential units, R350M: 17 houses, also link
to Allithwaite Road, near the top of Risedale Hill therefore they should also be taken
into account when undertaking an area traffic impact study (see Map 1, section 5.7);
as should traffic generated by all residential and employment developments west of
Risedale Hill in Allithwaite and Flookburgh.
7.12 Once the traffic has negotiated Risedale Hill it then has to negotiate Main Street hill in
Grange-over-Sands another bottleneck that is often made worse by delivery vehicles
for the local shops because none of the shops on this part of Main Street have rear
access,
7.13 The local roads are in a poor state of repair and are not suitable for this level of traffic
increase.
7.14 SLDC have made no provision for improving these roads and have not justified a
need for developments that will make the traffic conditions considerably worse and
deter tourists.
7.15 There is no viable route for a Grange-over-Sands by-pass. A new trunk road to the
A590 would have to be routed across rough pastureland to the north of Grange-over-
Sands and would impinge on classic views of Cartmel and Cartmel Priory.
7.16 Car parking in Grange-over-Sands is already inadequate for local residents shopping
and tourists and again, no provision has been made in SLDC’s Land Allocation DPD
to improve local car parking facilities.
Section 7: Inadequate local roads in Grange-over-Sands and District;
summary of main conclusions
- The roads in Grange-over-Sands and district are already inadequate for the
traffic that they carry.
- There are two major bottlenecks: Risedale Hill and Main Street Hill that
cannot be widened due to their location.
- It would be expensive and difficult to agree a route for a new trunk road to the
A590 that by-passed Grange-over-Sands.
- SLDC have not made any provision to upgrade roads in Grange-over-Sands
and district.
- SLDC have not provided objective evidence to justify proposing large
development to the west of Grange-over-Sands given the already inadequate
road system.
SEE ALSO ALL APPENDICES on attached document
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
I do not support SLDC’s Land Allocation DPD
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
I wish to take part in the oral examination because SLDC have not made an adequate response to significant planning concerns, raised by local residents, during earlier consultation phases, particularly those relating to:
1. ‘Housing need’ in the Grange-over-Sands area.
2. Proposed green field site land allocations for the Grange-over-Sands area.
3. The adverse impact of the proposed developments on tourism, the life-blood of Grange-over-Sands and the Cartmel Peninsula.
4. The inadequate road system that links Grange-over-Sands to other SLDC Service Centres.
In addition, SLDC have not provided objective evidence that justifies their classification of Grange-over-Sands as an SLDC Key Service Centre. Grange-over-Sands does not meet SLDC’s Core Strategy Document definition of Key Service Centre: it does not have a secondary school and it is not directly linked to other SLDC Service Centres by a main trunk road.
Nor does the SLDC Land Allocation DPD take account of local residents’ wishes about how their community should be developed, or the views of Grange-over-Sands Town Council.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
482. Mrs Valerie Kennedy (Individual) : 16 May 2012 12:05:00
A typed or handwritten document was submitted. This has been scanned and can be downloaded below:
Policy/Site No.
LA3.1 Mixed Use Allocation at Berners Pool, Grange-over-Sands
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
1. SLDC should not include Grange-over-Sands as one of its Key Service Centres because it does not meet the criteria in CS1.2 The development strategy for Principal Service Centres, Key Service Centres and Local Service Centres. This would mean that the number of proposed developments in Grange-over-Sands and district should be reduced and all proposed development sites should be reassessed. Development of brown field sites, such as Berners, should be prioritised and SLDC should take account of the views of local residents and Grange-over-Sands Town Council.
2. SLDC have not followed Government guidance about the use and interpretation of household surveys. They have not provided objective evidence to justify ‘housing need for Grange-over-Sands and District.
3. SLDC should be required to produce objective evidence to justify their plans to allow Grange-over-Sands to develop into a coastal urban sprawl incorporating Kents Bank.
4. SLDC should be required to remove sites MN25N, R672 and R79# from their Land Development DPD because development of these sites will lead to coalescence between the communities of Kents Bank and Allithwaite.
5. SLDC should be required to remove sites R449, R74 and R110 from their Land Development DPD because development of these sites will lead to further coalescence between the communities of Grange-over-Sands and Kents Bank.
6. SLDC should be required to produce clear evidence about how their proposed developments will enhance tourism in Grange-over-Sands and district.
7. SLDC should be required to explain why they have ignored recommendations made about green field sites and tourism in the Grange-over-Sands Regeneration Study (Douglas Wheeler Associates, November 2007), that they claim has informed SLDC's Core Strategy.
8. SLDC should be required to provide objective evidence that the local roads are adequate to support the proposed increase in population and traffic in Grange-over-Sands especially for known bottle-necks in Main Street and on Risedale Hill.
9. SLDC should not allow any development on prime green field land between Kents Bank and Allithwaite because it will lead to coalescence between these two separate communities.
1.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
I do not support SLDC’s Land Allocations DPD because it is based on spurious ‘housing need’ targets and has unnecessarily ear-marked important greenfield sites for development.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The following text of response 11291 is taken from sections 4 and 7 of my SLDC LDF consultation submission entitled: ‘Soundness’ response to SLDC’s Land Allocation Development Plan (DPD, Jan 2012) focussing on SLDC’s ‘housing need’ predictions & SLDC’s vision for Grange-over-Sands and District.
My report included photographs, maps and tables to support comments that were made in the report. I have requested that this report be made available to the Planning Inspector.
The sections featured in response 11291 are:
4. Does SLDC's Land Allocation Document protect the needs of Grange-over-Sands as a unique coastal tourist destination?
7. Does SLDC's Land Allocation Document make adequate provision for capital expenditure to upgrade local roads?
Photographs that were included with the text in the report have been stored elsewhere, formatting that clarified the text has been removed and spurious question marks have appeared that are not in the original text.
[The full report is attached]
4 Does SLDC’s Land Allocation Document protect the needs of Grange-over-
Sands as a unique coastal tourist destination?
4.1 SLDC’s Land Allocation Plan states that the Grange-over-Sands Regeneration Study
(November 2007), Douglas Wheeler Associates, has informed SLDC’s Core Strategy.
4.2 The Grange-over-Sands Regeneration Study states that Grange-over-Sands is:
i. North West England’s most distinctive, contemporary coastal resort town that has
used its Edwardian heritage as a strong asset in its regeneration.
ii. An exceptionally pleasant, very well maintained and friendly town with:
- An impressive promenade and superb views across Morecambe Bay.
- Excellent parks and garden.
- A well connected rail station.
- A strong community of established and new residents.
- A great place to live, work and visit.
iii. Has a strong convenience retailing and service orientated focus.
4.3 SLDC’s Core Strategy document states that:
"...We aim to achieve a balanced housing market by securing the provision of a range of
housing types and sizes to meet the needs of all sectors…” and
“…The exact scale and level of development supported will be dependent on individual
character, the impact on environmental capacity and infrastructure provision, and the
desire to meet the need for affordable housing as locally as possible…”
4.4 The proposed developments in SLDC’s Land Allocation document for Grange-over-
Sands and district have not achieved this objective because:
- They will increase the number of households by 25%.
- Local roads do not have the capacity to absorb the extra traffic that will be
generated.
- They will allow building on important green field sites.
- They will lead to the coalescence of Grange-over-Sands with adjacent
communities.
4.5 The questionable SLDC ‘new build’ target has been arbitrarily divided between defined
areas of South Lakeland district, on a percentage basis, between the Principal Service
Centres, Key Service Centres and rural areas.
4.6 The housing allocation made for Grange-over-Sands was based on its classification as a Key Service Centre but, as it does not meet the SLDC’s stated criteria for a Key Service
Centre (see Section 3), the housing allocation is not compatible with its needs as a
unique coastal tourist destination.
4.7 The allocation of new build’ for Grange-over-Sands, Kents Bank, Allithwaite and Cartmel
peninsula area does not appear to have factored in:
- The high percentage of retired people living in the area: a proportionally higher
amount of the existing housing stock will be available for ‘new’ households, on a
regular basis, due to the higher mortality.
- The high percentage of dwellings that are ‘second homes’ and ‘holiday lets’ some of
which are likely revert to normal residential use over time eg eight apartments in
Kents Bank were converted from ‘holiday apartments’ to ‘normal residential’
apartments in 2010.
4.8 SLDC has not justified the need for a massive ‘new build’ requirement in Grange-over-
Sands and district with objective evidence.
4.9 There is a need for ‘affordable housing’ but even that need has not been quantified
objectively.
4.10 The overall ‘new build’ housing figures have been inflated because of the policy of
requiring developers to subsidise ‘affordable housing’ (see section 2).
4.11 SLDC’s proposals will lead to a 25% increase in the number of households in Grange-over-Sands and Kents Bank without any provision for improvements to the local road system or car parking facilities or utilities; this will be detrimental to the tourist industry.
4.12 Section 4.4 of SLDC’s Land Allocation document states:
“…Douglas Wheeler Associates prepared a Regeneration Study for Grange-over-
Sands in 2007. This carried out a detailed assessment of Grange as a Key
Service Centre that formed the basis of Core Strategy policies for the town…”
4.13 The independent Grange-over-Sands Regeneration Study 2007 found:
“…Around 7.5% of properties are second homes and clearly Grange should not become
dominated by second homes and retirement homes…”
4.14 If SLDC’s proposal to build 500 dwellings in Grange-over-Sands and district is realised the likely outcome will be to increase in the number of ‘second homes’, ‘holiday homes’, and ‘in-coming’ pensioners in order to subsidise 175 ‘affordable homes’; SLDC have not provided evidence to justify this need.
4.15 Building on this scale will not benefit the local community because it will lead to an
increased pressure on the NHS, local roads, public transport, utilities etc… and have an
adverse effect on local tourism.
4.16 There are currently 129 dwellings on the market in Grange-over-Sands and district
ranging from one and two bed-roomed apartments to large detached houses and
everything in between. Many of these properties have been on the market for over two
years; many others have been taken off the market and turned into private rented
accommodation. So, how can SLDC justify the need for 325 more new dwellings on the
open market?
4.17 The Grange-over-Sands Regeneration Study 2007 also stated that:
“…Additional housing will be provided to meet the needs of local people without
damaging the sensitive setting and character of the town…” and
“…the key to the success or failure of Grange-over-Sands…will be to invest in the
unique quality of the built and natural environment, infrastructure and public facilities
alongside promoting enterprise and business development…” and
“…It only requires one element to be below standard to reduce the overall appeal of the
place…”
4.18 Residents of Grange-over-Sands and district would agree with all the above objectives
but feel that SLDC’s Land Allocation DPD proposals do not match this expectation. For
instance, the study looked at Grange-over-Sands land development options in detail. It
recommended that land ‘north of playing field’ (R110: Trickett’s field) should not be
developed because: “…loss of open views from street is negative…”
4.19 This site is also important because it is one of the few remaining green gaps between
Grange-over-Sands and Kents Bank (see section 5).
4.20 The Grange-over-Sands Regeneration Study 2007 also stated that it was important to:
“…protect the network of green spaces and important environmental characteristics of
the town and its setting…” and
“…protect the network of green spaces and important characteristics of the town…give
priority to the use of previously developed land for development…”
4.21 Brown field sites such as Berners, the former candle factory and Bateman’s garage
should be developed for housing and employment before any green field sites are
considered; sensitive development of brown field sites will not destroy the rural
ambience of the area that is so attractive to tourists.
4.22 Tourism is the life-blood of Grange-over-Sands’ economy. SLDC is not justified in
proposing large scale developments on green field sites before undertaking a feasibility
study assessing the impact of the proposed developments on tourism. They have not
done this. Such arrogance is negligent given the potential impact on the local tourist
industry.
4.23 It is unlikely that tourists will want visit the Grange-over-Sands area during the
construction phases due to the impact on the already inadequate road system (see
section 7); post construction, who wants to visit a coastal urban sprawl?
4.24 Investment in basic infrastructure is needed before any major increase in housing but
the SLDC Land Allocation Development Plan does include any provision for solving the
known traffic bottle-necks of Risedale Hill and Main Street Grange-over-Sands (see
section 7). Why not?
4.25 Section 4.2 of the SLDC Land Allocation DPD states:
“…The Core Strategy (Policy CS4) sets the overall context for development in Grangeover-
Sands. This seeks to make provision for moderate housing development and
employment development, regenerate the Berners site, improve public transport, reinstate
footbridges and protect the network of Green Infrastructure as well as promoting
the vitality of Grange town Centre and promoting tourism…”
4.26 Local residents support all these objectives, but, the land development proposals that
SLDC have proposed for Grange-over-Sands and district contradict these objectives;
they have not protected the network Green infrastructure (see sections 5, 6 and 7) and
they have not promoted tourism, nor have they justified proposing to development of
green field sites with objective evidence.
4.27 As the Grange-over-Sands Regeneration Study 2007 said of Grange-over-Sands it is
important to:
- Maintain and enhance the viability of the town centre.
- Promote…appropriate development at the Berners Pool/BernersClose car
park/nursery/lido site to create a new focus.
- Promote the vitality and viability of Grange-over-Sands town centre.
- Promote the reintroduction of the Berners Close railway bridge.
- Focus on renovation rather than demolition.
- Minimise the impact on the environment and improve biodiversity
Unfortunately SLDC’s Land Allocation DPD appears to have lost sight of these
objectives.
Section 4: Grange-over-Sands, a unique coastal town;
summary of main conclusions
- Grange-over-Sands is a unique coastal town that is dependent on the tourist
industry and has unique development needs.
- Grange-over-Sands is not suitable for large scale development because of its
tourist needs; the surrounding rough pasture lands are part of its attraction.
- All proposed development should be considered in this context and should be
concentrated on brown field sites as recommended in the Grange-over-Sands
Regeneration Study 2007.
- The local road system, utilities and community support systems are already
inadequate; they are not robust enough to support 500 more households.
- The surrounding topography and proximity of other local communities means
that it is inappropriate allow large scale developments to extend into Kents
Bank or onto peripheral rough pasture land.
7 Does SLDC’s Land Allocation Document make adequate provision for
capital expenditure to upgrade local roads?
7.1 Allithwaite Road (B5277) is already inadequate for the amount of traffic regularly
travelling between Grange-over-Sands, Allithwaite, Flookburgh, Holker Hall, Kendal,
Lancaster and the M6.
7.2 The traffic problem is exacerbated when regular events such as Cartmel Races and
the Holker Garden Festival attract large crowds.
7.3 The stretch of Allithwaite Road between Kents Bank and Allithwaite from the top of
Risedale Hill is a fast stretch of undulating road that poses sight line problems for
drivers (see picture 3, section 6.15).
7.4 Developers would be forced to create new roads for development area MN25M linking
onto Allithwaite Road; this would increase traffic hazards on Allithwaite Road, or, lead
to the creation of an intrusive roundabout system that would destroy the rural nature
of this road and area
7.5 Greaves Wood Road bridleway forms the eastern, and southern, boundaries of
MN25M; it could not be used as access to MN25M development area because of a)
the Protected Limestone Pavement in Greaves Wood and b) it is a popular pedestrian
route for local residents, especially dog walkers (see Map 1, section 5.7 and Map 3,
section 6.4).
7.6 Access from Kirkhead Road to the MN25M development area is not practical; there
are no suitable gaps between the houses whose back gardens form the western
boundary of MN25M.
7.7 Industrial development and 202 residential units will generate a large amount of extra
traffic in Kents Bank that will all need to drive through Grange-over-Sands to reach the
A590 for access to Kendal, Lancaster and the M6; the local road system is not
suitable for this.
7.8 Local roads are not adequate to accommodate service vehicles for industrial
development.
SEE PICTURES ON ATTACHED DOCUMENT
7.9 SLDC are also proposing to build dwellings on the land behind the lorry on Allithwaite
Road (picture 6) and on the left hand side of Allithwaite Road beyond the junction of
Allithwaite Road with Jack Hill (junction to the left of Kirkhead Road; picture 6); access
to both these sites is constrained by their location and will cause road safety
problems.
7.10 Picture 5 clearly shows that it is not possible to widen or straighten Risedale Hill
without major road works involving compulsory purchase orders, demolition of walls
and completely altering the character of this part of Kents Bank and that the road is
not suitable for large volumes of traffic.
7.11 Traffic from three other nearby proposed residential developments in Kents Bank,
R672M: 36 residential units & R89: 45 residential units, R350M: 17 houses, also link
to Allithwaite Road, near the top of Risedale Hill therefore they should also be taken
into account when undertaking an area traffic impact study (see Map 1, section 5.7);
as should traffic generated by all residential and employment developments west of
Risedale Hill in Allithwaite and Flookburgh.
7.12 Once the traffic has negotiated Risedale Hill it then has to negotiate Main Street hill in
Grange-over-Sands another bottleneck that is often made worse by delivery vehicles
for the local shops because none of the shops on this part of Main Street have rear
access,
7.13 The local roads are in a poor state of repair and are not suitable for this level of traffic
increase.
7.14 SLDC have made no provision for improving these roads and have not justified a
need for developments that will make the traffic conditions considerably worse and
deter tourists.
7.15 There is no viable route for a Grange-over-Sands by-pass. A new trunk road to the
A590 would have to be routed across rough pastureland to the north of Grange-over-
Sands and would impinge on classic views of Cartmel and Cartmel Priory.
7.16 Car parking in Grange-over-Sands is already inadequate for local residents shopping
and tourists and again, no provision has been made in SLDC’s Land Allocation DPD
to improve local car parking facilities.
Section 7: Inadequate local roads in Grange-over-Sands and District;
summary of main conclusions
- The roads in Grange-over-Sands and district are already inadequate for the
traffic that they carry.
- There are two major bottlenecks: Risedale Hill and Main Street Hill that
cannot be widened due to their location.
- It would be expensive and difficult to agree a route for a new trunk road to the
A590 that by-passed Grange-over-Sands.
- SLDC have not made any provision to upgrade roads in Grange-over-Sands
and district.
- SLDC have not provided objective evidence to justify proposing large
development to the west of Grange-over-Sands given the already inadequate
road system.
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
I do not support SLDC’s Land Allocation DPD
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
I wish to take part in the oral examination because SLDC have not made an adequate response to significant planning concerns, raised by local residents, during earlier consultation phases, particularly those relating to:
1. ‘Housing need’ in the Grange-over-Sands area.
2. Proposed green field site land allocations for the Grange-over-Sands area.
3. The adverse impact of the proposed developments on tourism, the life-blood of Grange-over-Sands and the Cartmel Peninsula.
4. The inadequate road system that links Grange-over-Sands to other SLDC Service Centres.
In addition, SLDC have not provided objective evidence that justifies their classification of Grange-over-Sands as an SLDC Key Service Centre. Grange-over-Sands does not meet SLDC’s Core Strategy Document definition of Key Service Centre: it does not have a secondary school and it is not directly linked to other SLDC Service Centres by a main trunk road.
Nor does the SLDC Land Allocation DPD take account of local residents’ wishes about how their community should be developed, or the views of Grange-over-Sands Town Council.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
483. Mrs Valerie Kennedy (Individual) : 16 May 2012 12:15:00
A typed or handwritten document was submitted. This has been scanned and can be downloaded below:
Policy/Site No.
LA3.2 Mixed Use Allocation at Land South of Allithwaite Road, Kent's Bank, Grange-over-Sands
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
1. SLDC should not include Grange-over-Sands as one of its Key Service Centres because it does not meet the criteria in CS1.2 The development strategy for Principal Service Centres, Key Service Centres and Local Service Centres. This would mean that the number of proposed developments in Grange-over-Sands and district should be reduced and all proposed development sites should be reassessed. Development of brown field sites, such as Berners, should be prioritised and SLDC should take account of the views of local residents and Grange-over-Sands Town Council.
2. SLDC have not followed Government guidance about the use and interpretation of household surveys. They have not provided objective evidence to justify ‘housing need for Grange-over-Sands and District.
3. SLDC should be required to produce objective evidence to justify their plans to allow Grange-over-Sands to develop into a coastal urban sprawl incorporating Kents Bank.
4. SLDC should be required to remove sites MN25N, R672 and R79# from their Land Development DPD because development of these sites will lead to coalescence between the communities of Kents Bank and Allithwaite.
5. SLDC should be required to remove sites R449, R74 and R110 from their Land Development DPD because development of these sites will lead to further coalescence between the communities of Grange-over-Sands and Kents Bank.
6. SLDC should be required to produce clear evidence about how their proposed developments will enhance tourism in Grange-over-Sands and district.
7. SLDC should be required to explain why they have ignored recommendations made about green field sites and tourism in the Grange-over-Sands Regeneration Study (Douglas Wheeler Associates, November 2007), that they claim has informed SLDC's Core Strategy.
8. SLDC should be required to provide objective evidence that the local roads are adequate to support the proposed increase in population and traffic in Grange-over-Sands especially for known bottle-necks in Main Street and on Risedale Hill.
9. SLDC should not allow any development on prime green field land between Kents Bank and Allithwaite because it will lead to coalescence between these two separate communities.
1.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
I do not support SLDC’s Land Allocations DPD because it is based on spurious ‘housing need’ targets and has unnecessarily ear-marked important greenfield sites for development.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The following text of response 11292 is taken from sections 4, 5, 6 and 7 of my SLDC LDF consultation submission entitled: ‘Soundness’ response to SLDC’s Land Allocation Development Plan (DPD, Jan 2012) focussing on SLDC’s ‘housing need’ predictions & SLDC’s vision for Grange-over-Sands and District.
My report included photographs, maps and tables to support comments that were made in the report. I have requested that this report be made available to the Planning Inspector.
The sections featured in response 11292 are:
4. Does SLDC's Land Allocation Document protect the needs of Grange-over-Sands as a unique coastal tourist destination?
5 . Does SLDC’s Land Allocation Document attempt to ‘air-brush’ Kents Bank out of existence as a separate community?
6. Does SLDC’s Land Allocation Document protect against coalescence between Kents Bank and Allithwaite?
7. Does SLDC's Land Allocation Document make adequate provision for capital expenditure to upgrade local roads?
The tables that were included with the text in the report have been stored elsewhere, formatting that clarified the text has been removed and spurious question marks have appeared that are not in the original text.
[The full report is attached]
4 Does SLDC’s Land Allocation Document protect the needs of Grange-over-
Sands as a unique coastal tourist destination?
4.1 SLDC’s Land Allocation Plan states that the Grange-over-Sands Regeneration Study
(November 2007), Douglas Wheeler Associates, has informed SLDC’s Core Strategy.
4.2 The Grange-over-Sands Regeneration Study states that Grange-over-Sands is:
i. North West England’s most distinctive, contemporary coastal resort town that has
used its Edwardian heritage as a strong asset in its regeneration.
ii. An exceptionally pleasant, very well maintained and friendly town with:
- An impressive promenade and superb views across Morecambe Bay.
- Excellent parks and garden.
- A well connected rail station.
- A strong community of established and new residents.
- A great place to live, work and visit.
iii. Has a strong convenience retailing and service orientated focus.
4.3 SLDC’s Core Strategy document states that:
"...We aim to achieve a balanced housing market by securing the provision of a range of
housing types and sizes to meet the needs of all sectors…” and
“…The exact scale and level of development supported will be dependent on individual
character, the impact on environmental capacity and infrastructure provision, and the
desire to meet the need for affordable housing as locally as possible…”
4.4 The proposed developments in SLDC’s Land Allocation document for Grange-over-
Sands and district have not achieved this objective because:
- They will increase the number of households by 25%.
- Local roads do not have the capacity to absorb the extra traffic that will be
generated.
- They will allow building on important green field sites.
- They will lead to the coalescence of Grange-over-Sands with adjacent
communities.
4.5 The questionable SLDC ‘new build’ target has been arbitrarily divided between defined
areas of South Lakeland district, on a percentage basis, between the Principal Service
Centres, Key Service Centres and rural areas.
4.6 The housing allocation made for Grange-over-Sands was based on its classification as a Key Service Centre but, as it does not meet the SLDC’s stated criteria for a Key Service
Centre (see Section 3), the housing allocation is not compatible with its needs as a
unique coastal tourist destination.
4.7 The allocation of new build’ for Grange-over-Sands, Kents Bank, Allithwaite and Cartmel
peninsula area does not appear to have factored in:
- The high percentage of retired people living in the area: a proportionally higher
amount of the existing housing stock will be available for ‘new’ households, on a
regular basis, due to the higher mortality.
- The high percentage of dwellings that are ‘second homes’ and ‘holiday lets’ some of
which are likely revert to normal residential use over time eg eight apartments in
Kents Bank were converted from ‘holiday apartments’ to ‘normal residential’
apartments in 2010.
4.8 SLDC has not justified the need for a massive ‘new build’ requirement in Grange-over-
Sands and district with objective evidence.
4.9 There is a need for ‘affordable housing’ but even that need has not been quantified
objectively.
4.10 The overall ‘new build’ housing figures have been inflated because of the policy of
requiring developers to subsidise ‘affordable housing’ (see section 2).
4.11 SLDC’s proposals will lead to a 25% increase in the number of households in Grange-over-Sands and Kents Bank without any provision for improvements to the local road system or car parking facilities or utilities; this will be detrimental to the tourist industry.
4.12 Section 4.4 of SLDC’s Land Allocation document states:
“…Douglas Wheeler Associates prepared a Regeneration Study for Grange-over-
Sands in 2007. This carried out a detailed assessment of Grange as a Key
Service Centre that formed the basis of Core Strategy policies for the town…”
4.13 The independent Grange-over-Sands Regeneration Study 2007 found:
“…Around 7.5% of properties are second homes and clearly Grange should not become
dominated by second homes and retirement homes…”
4.14 If SLDC’s proposal to build 500 dwellings in Grange-over-Sands and district is realised the likely outcome will be to increase in the number of ‘second homes’, ‘holiday homes’,and ‘in-coming’ pensioners in order to subsidise 175 ‘affordable homes’; SLDC have not provided evidence to justify this need.
4.15 Building on this scale will not benefit the local community because it will lead to an
increased pressure on the NHS, local roads, public transport, utilities etc… and have an
adverse effect on local tourism.
4.16 There are currently 129 dwellings on the market in Grange-over-Sands and district
ranging from one and two bed-roomed apartments to large detached houses and
everything in between. Many of these properties have been on the market for over two
years; many others have been taken off the market and turned into private rented
accommodation. So, how can SLDC justify the need for 325 more new dwellings on the
open market?
4.17 The Grange-over-Sands Regeneration Study 2007 also stated that:
“…Additional housing will be provided to meet the needs of local people without
damaging the sensitive setting and character of the town…” and
“…the key to the success or failure of Grange-over-Sands…will be to invest in the
unique quality of the built and natural environment, infrastructure and public facilities
alongside promoting enterprise and business development…” and
“…It only requires one element to be below standard to reduce the overall appeal of the
place…”
4.18 Residents of Grange-over-Sands and district would agree with all the above objectives
but feel that SLDC’s Land Allocation DPD proposals do not match this expectation. For
instance, the study looked at Grange-over-Sands land development options in detail. It
recommended that land ‘north of playing field’ (R110: Trickett’s field) should not be
developed because: “…loss of open views from street is negative…”
4.19 This site is also important because it is one of the few remaining green gaps between
Grange-over-Sands and Kents Bank (see section 5).
4.20 The Grange-over-Sands Regeneration Study 2007 also stated that it was important to:
“…protect the network of green spaces and important environmental characteristics of
the town and its setting…” and
“…protect the network of green spaces and important characteristics of the town…give
priority to the use of previously developed land for development…”
4.21 Brown field sites such as Berners, the former candle factory and Bateman’s garage
should be developed for housing and employment before any green field sites are
considered; sensitive development of brown field sites will not destroy the rural
ambience of the area that is so attractive to tourists.
4.22 Tourism is the life-blood of Grange-over-Sands’ economy. SLDC is not justified in
proposing large scale developments on green field sites before undertaking a feasibility
study assessing the impact of the proposed developments on tourism. They have not
done this. Such arrogance is negligent given the potential impact on the local tourist
industry.
4.23 It is unlikely that tourists will want visit the Grange-over-Sands area during the
construction phases due to the impact on the already inadequate road system (see
section 7); post construction, who wants to visit a coastal urban sprawl?
4.24 Investment in basic infrastructure is needed before any major increase in housing but
the SLDC Land Allocation Development Plan does include any provision for solving the
known traffic bottle-necks of Risedale Hill and Main Street Grange-over-Sands (see
section 7). Why not?
4.25 Section 4.2 of the SLDC Land Allocation DPD states:
“…The Core Strategy (Policy CS4) sets the overall context for development in Grangeover-
Sands. This seeks to make provision for moderate housing development and
employment development, regenerate the Berners site, improve public transport, reinstate
footbridges and protect the network of Green Infrastructure as well as promoting
the vitality of Grange town Centre and promoting tourism…”
4.26 Local residents support all these objectives, but, the land development proposals that
SLDC have proposed for Grange-over-Sands and district contradict these objectives;
they have not protected the network Green infrastructure (see sections 5, 6 and 7) and
they have not promoted tourism, nor have they justified proposing to development of
green field sites with objective evidence.
4.27 As the Grange-over-Sands Regeneration Study 2007 said of Grange-over-Sands it is
important to:
- Maintain and enhance the viability of the town centre.
- Promote…appropriate development at the Berners Pool/BernersClose car
park/nursery/lido site to create a new focus.
- Promote the vitality and viability of Grange-over-Sands town centre.
- Promote the reintroduction of the Berners Close railway bridge.
- Focus on renovation rather than demolition.
- Minimise the impact on the environment and improve biodiversity
Unfortunately SLDC’s Land Allocation DPD appears to have lost sight of these
objectives.
Section 4: Grange-over-Sands, a unique coastal town;
summary of main conclusions
- Grange-over-Sands is a unique coastal town that is dependent on the tourist
industry and has unique development needs.
- Grange-over-Sands is not suitable for large scale development because of its
tourist needs; the surrounding rough pasture lands are part of its attraction.
- All proposed development should be considered in this context and should be
concentrated on brown field sites as recommended in the Grange-over-Sands
Regeneration Study 2007.
- The local road system, utilities and community support systems are already
inadequate; they are not robust enough to support 500 more households.
- The surrounding topography and proximity of other local communities means
that it is inappropriate allow large scale developments to extend into Kents
Bank or onto peripheral rough pasture land.
5 Does SLDC’s Land Allocation Document attempt to ‘air-brush’ Kents
Bank out of existence as a separate community?
5.1 SLDC’s Planning Department currently treats Kents Bank as a suburb of Grange-over-
Sands even though Kents Bank can trace its existence back to Mediaeval times when
monks from Cartmel lodged at Abbot Hall, Kents Bank, when ‘crossing the sands’
whereas Grange-over-Sands developed as a tourist resort in Victorian times after the
‘coming of the railway.
5.2 Kents Bank has its own station, Post Office, shop, Art Gallery, Abbot Hall Hotel and
Guide’s Farm. The post of Guide dates back to at least 1501 according to records of
Cartmel Priory.
5.3 During the past 20-25 years SLDC’s Planning Department have permitted infilling
development on many Kents Bank green field sites; they have allowed infilling on green
gaps between Kents Bank and Grange-over-Sands on the east, and, Kents Bank and
Allithwaite on the west.
5.4 Why is SLDC treating Kents Bank as a suburb of Grange-over-Sands? Residents of
Kents Bank do not support this view; they value their community and do not want to see
Kents Bank absorbed into Grange-over-Sands or Allithwaite. Kents Bank was
established hundreds of years before Grange-over-Sands.
5.5 This unsound approach has been perpetuated in SLDC’s Land Allocation DPD. Section
4.2 of the document is headed Grange-over-Sands and Kents Bank whereas Allithwaite
is considered as a separate community.
5.6 Subsequent text in SLDC’s Land Allocation DPD uses the name Grange-over-Sands
when it is actually referring to Kents Bank. For example paragraph 4.12 states:
“…The second major allocation is a large site on Allithwaite Road west of Kents Bank.
This is the only large site available in Grange-over-Sands…”
5.7 This is nonsense. The site referred to is MN25M; it is west of Kents Bank; it will
significantly extend Kents Bank’s western boundary and will lead to coalescence
between Kents Bank and Allithwaite if it is developed (see Map 1 and section 6).
SEE MAP 1 & 2 IN ATTACHED DOCUMENT
5.8 SLDC’s Land Allocation DPD gives Kents Bank similar problems with its Grange-over-
Sands boundaries; the green spaces between Grange-over-Sands and Kents Bank have
been gradually eroded over the years. If more green spaces between the two
communities are developed it will be the ‘death knell’ of Kents Bank as a separate
community (see Map 2)
5.9 It is clear from Map 2 that building on sites R110 (Trickett’s field) and R449/R74 will
erode the sense of separation between Grange-over-Sands and Kents Bank when
driving on the main road, the B5227 and that they will increase coalescence between
Grange-over-Sands and Kents Bank.
5.10 The Grange-over-Sands Regeneration Study 2007 considered site R110 (Trickett’s
field). They concluded that it should not be developed because:
“…loss of open views from street is negative…”
5.11 R449/R74 was not considered by the Grange-over-Sands Regeneration Study 2007 and its importance as a green field site has not been independently assessed. It is clear from Map 2 that development of these two sites will increase coalescence between Grangeover-Sands and Kents Bank. SLDC has provided no objective evidence to support the development of either of these green field sites.
5.12 The only green field site in Kents Bank that was considered by the Grange-over-Sands
Regeneration Study 2007 was site R89 (the Carter Road site, Berry Bank, Map 1 and
Map 2) and the report did not recommend development of R89 because of:
“…the loss of open area will be an issue…” and they concluded that
“…that residential development of the Allithwaite Road/Carter Road site is likely to be
controversial because of the ‘green field’ nature of the site…”
5.13 None of the development sites proposed for Kents Bank (Map 1), except R89, were
considered by the Grange-over-Sands Regeneration Study 2007; they have not been
independently assessed before inclusion in SLDC’s Land Allocation DPD.
SEE TABLE 4 in ATTACHED DOCUMENT
5.14 Table 4 clearly shows that a disproportionate amount of the unsustainable housing
allocation for Grange-over-Sands has been allocated to Kents Bank (58%)
5.15 The proposed development will increase the size of Kents Bank by 40% and extend its
boundaries towards Allithwaite causing coalescence between Kents Bank and
Allithwaite; SLDC have provided no objective evidence to justify increasing the size of
Kents Bank on this scale.
5.16 All the proposed housing development sites in Kents Bank have been allocated to
desirable green field sites except for Guides Lot (17 dwellings plus employment units)
but even this site includes a small additional green field and the site is adjacent to land
on Wart Barrow that is covered by a Limestone Pavement Order.
5.17 The proposed site MN25M is particularly contentious (see section 6).
5.18 Development of all the proposed sites near Risedale Hill and in Kents Bank will have an adverse effect on local drainage in areas that are already prone to flooding after heavy
rainfall eg Allithwaite Road beyond the top of Risedale Hill, Greaves Wood Road
(Bridleway) and Kirkhead Road.
5.19 The SLDC’s Land Allocation DPD has not taken account of problems highlighted by
Kents Bank residents in the 2011 consultation exercises. For example response forms
that I submitted for sites: MN25M, R672, 350M, R79#, R82#/R347# (see Appendices 3
to 7).
5.20 Many other residents also highlighted significant problems associated with the proposed land allocations for Kents Bank. All appear to have been ignored and lumped together in groups with a comment such as ‘noted’ beside them (see section 8). Why?
Section 5: Kents Bank as a separate community;
summary of main conclusions
- Kents Bank has been a separate community since Mediaeval times.
- SLDC have provided no clear evidence to justify increasing the size of Kents
Bank by 40%.
- SLDC have provided no clear evidence to justify sanctioning developments
that will increase coalescence between Grange-over-Sands and Kents Bank.
- SLDC have provided no clear evidence to justify sanctioning developments
that will increase coalescence between Kents Bank and Allithwaite.
- The local road system, utilities and community support systems are already
inadequate; they are not robust enough to support 298 more households in
Kents Bank.
6 Does SLDC’s Land Allocation Document protect against coalescence
between Kents Bank and Allithwaite?
6.1 To be sound SLDC need to show that they have considered potential coalescence
problems between communities. SLDC’s Core Strategy states:
CS1.2 states: “…Exceptionally, new development will be permitted in the open
countryside where it has an essential requirement for a rural location, is needed to
sustain existing businesses, provides for exceptional needs for affordable housing…”
6.2 According to SLDC’s Land Allocation DPD policy Green Gap Policy LA1.9 provides:
“…A framework for maintaining the separate identities of communities by maintaining
visual and functional separation…”
The green gap between Grange-over-Sands (not Kents Bank!) and Allithwaite is
identified as one of these important green gaps (see Map 1 and Map 3). Therefore, how
can they justify building on the site south of Allithwaite Road between Kents Bank and
Allithwaite ( MN25M)without clear objective evidence that there is a genuine need for
such development?
6.3 When SLDC prepared maps in support of their Land Allocation DPD the maps were split between Allithwaite and Kents Bank so that the dramatic reduction in the green gap
between Kents Bank and Allithwaite was not immediately obvious.
6.4 The impact of the proposed development sites for Kents Bank on coalescence between
Kents Bank and Allithwaite is clearly shown on Map 1 (section 5.7) and Map 3.
SEE MAP 3 IN ATTACHED DOCUMENT
6.5 Map 3 clearly illustrates the importance of the triangular piece of land as a green gap
between Kents Bank and Allithwaite. It also demonstrates SLDC’s poor understanding of
the boundaries between Kents Bank and Allithwaite. Currently there is only minimal
coalescence between Kents Bank and Allithwaite about a third of the way down
Kirkhead Road (see Map 3). Coalescence between the two communities will be
considerably increased if SLDC’s development proposals west of Kents Bank and south
of Allithwaite are permitted (see Map 1, section 5.7)
6.6 Appendix 5 of the Grange Fact File states:
“…Coalescence has already taken place to some degree as Kentsford Road joins Kents
Bank/Grange to the SE corner of Allithwaite…
6.7 This is nonsense! Kirkhead Road joins the south east corner of Allithwaite and the
houses at the top of Kirkhead Road are in Allithwaite (see Map 3, section 5.7). Kentsford
Road is adjacent to the railway and links Kirkhead Road and Carter; it does not form a
junction with Allithwaite Road.
6.8 The minimal coalescence between Kents Bank and Allithwaite on Kirkhead Road at
Laneside Farm is due to ribbon development in the 1930s (see Map 3, section 5.7).
6.9 The value of MN25N (the large site south of Allithwaite Road) as an important green gap
has never been independently assessed. It was not included in the Grange-over-Sands
Regenertion Study 2007 (which is supposed to have informed SLDC’s proposals for this
area) and Berry Bank (which was included was ruled out because “…loss of open area
will be an issue…” (see Map 1, section 5.7)
6.10 During the original consultation exercise SLDC was proposing an inappropriate
development of 120 residential units, plus employment units for MN25M. In spite of
widespread opposition proposals in the SLDC Land Allocation DPD nearly doubled the
number of dwellings for this site from 120 to 202 and had retained the employment units
with no objective evidence to support these proposals.
6.11 If MN25M is developed it will reduce the green gap between the communities of Kents
Bank and Allithwaite to 220 metres (site MN25M and R672) even though Section 4.22
of the SLDC Land Allocation (DPD) 2012 highlights: “…Key issues affecting
development in Allithwaite…The need to avoid coalescence with Kents Bank/Grange…”
How can SLDC justify their claim that a 220 metre gap is sufficient to avoid coalescence
between these two communities?
6.12 A significant number of local residents raised concerns about coalescence between
Kents Bank and Allithwaite during the 2011 consultation period their comments were
responded to with phrases such as “…Disagree, no proposed change it is considered
that the land does not perform a visual or functional separation and therefore does not
warrant green gap designation…” This is an outrageous description of a delightful
undulating green field site with wonderful views of Morecambe Bay that forms an
important green gap between the communities of Kents Bank and Allithwaite (see
Pictures 1 to 4).
6.13 Nor does it follow recommendations in the Grange-over-Sands Regeneration Study
2007 which stated that it was important to:
“…protect the network of green spaces and important environmental characteristics of
the town and its setting…” and
“…give priority to the use of previously developed land for development and focus on
renovation rather than demolition and new build and minimise the impact on the
environment and improve biodiversity…”
6.14 It may be significant that the land owners and developers are keen to develop this site.
On a clear day it has magnificent views of Morecambe Bay to the south and of Kirkhead
Tower to the southwest (see pictures in Table 4 below).
6.15 The land owners are so keen to see this MN25M developed that they appointed Land
Agents to liaise with SLDC Planning Department before the 2011 consultation exercise.
SEE PICTURES IN ATTACHED DOCUMENT
6.16 The complex topography of site MN25M (see Map 3) also means that drainage problems in Kents Bank will be exacerbated; a major development is likely to cause flooding in the troughs of natural undulations, as well as lower down, in southern areas of Kents Bank.
6.17 Kirkhead Road already becomes a stream bed during heavy rain; the southern end of
Greaves Wood bridleway floods during heavy rain.
6.18 Site MN25M is also an important local area for absorbing water runoff; the local drainage system does not have any ‘spare’ capacity and would need major capital investment to cope with a large-scale building development; there is no provision for this in the proposed SLDC’s land Allocation DPD.
6.19 Even a small industrial estate on this Greenfield site would have an adverse impact on
Kents Bank village, local wildlife and tourism potential.
6.20 It is inappropriate to encourage industrial development on a rural site that has been
farmed for centuries. Farming is an important local industry and part of the vernacular
landscape; this local industry should be retained for area MN25M to encourage a local
sustainable food supply and tourism.
6.21 Grange-over-Sands and the surrounding areas depend on tourism and farming;
changing the character of Kents Bank, in the way proposed, will have an adverse impact
on the tourism potential of Kents Bank.
6.22 Site MN25M is an open area that enhances the view east from Kirkhead Tower (an
ancient monument; see Picture 4) towards Grange-over-Sands; a view much admired by
visitors to the area.
6.23 MN25N is also an important wildlife corridor between Kirkhead, Greaves Wood and Wart Barrow that are all covered by Limestone Protection Orders; buzzards, kestrels and
sparrow hawks regularly hunt across this land and the woodland in the centre of the site
is a wildlife refuge.
6.24 SLDC’s response to all these adverse effects has been to state that a Development Brief will be prepared to guide development of this site even though they have not provided
clear objective evidence to show that development of this desirable and important green
field site is justified. A Development Brief will not solve the problems outlined above.
6.25 During the last 25 years SLDC have permitted:
i. Extensive infilling of green field sites in the Risedale Hill and Cardronna Road areas
of Kents Bank.
ii. The extension Kents Bank’s boundary westwards towards Allithwaite with a large
development north of Priory Lane.
iii. Extensive infilling along Priory Lane.
iv. Extensive infilling in the grounds of Kilmidyke House and Kentsford Road House.
v. Conversion of large Victorian buildings in the Kents Bank Conservation Area to
apartment blocks eg Kilmidyke House, Kentsford House, Kents Bank House and the
Kents Bank Hotel.
6.26 SLDC’s Land Allocation DPD has not justified perpetuating this policy of development
creep along the Cumbrian coast. It is time to call a halt to ensure that the communities of
Kents Bank and Allithwaite retain their integrity and do not become part of a coastal
urban sprawl that destroys the unique characteristics of Grange-over-Sands and its
surrounding area.
6.27 SLDC have provided no objective evidence to justify the need to build an additional 202
dwellings plus an unspecified number of employment units on the important green field
site between Kents Bank and Allithwaite.
Section 6: Coalescence between Kents Bank and Allithwaite;
summary of main conclusions
- SLDC have not justified reducing the boundary between Kents Bank and
Allithwaite to 220 metres.
- Development of sites MN25M and R672 will extend the boundaries of Kents
Bank towards Allithwaite; both will encroach onto open fell pastures that are
an important back-drop to Grange-over-Sands and district.
- SLDC has provided no clear evidence to justify building on these important
green field site between Kents Bank and Allithwaite.
- SLDC have not taken account of the impact of their land development
proposals on the natural drainage problems in Kents Bank.
- Such intensive development will disrupt an important wildlife corridor linking
Kirkhead, Greaves Wood and Wart Barrow; all areas of land that are covered
by Limestone Pavement Orders.
- A development Brief for MN25M will not be able to solve the fundamental
problem of coalescence between Kents Bank and Allithwaite caused by
development of this site.
- SLDC has a duty to ensure that the communities of Kents Bank and
Allithwaite retain their integrity and do not become part of a coastal urban
sprawl that destroys the unique characteristics of Grange-over-Sands and its
surrounding area.
7 Does SLDC’s Land Allocation Document make adequate provision for
capital expenditure to upgrade local roads?
7.1 Allithwaite Road (B5277) is already inadequate for the amount of traffic regularly
travelling between Grange-over-Sands, Allithwaite, Flookburgh, Holker Hall, Kendal,
Lancaster and the M6.
7.2 The traffic problem is exacerbated when regular events such as Cartmel Races and
the Holker Garden Festival attract large crowds.
7.3 The stretch of Allithwaite Road between Kents Bank and Allithwaite from the top of
Risedale Hill is a fast stretch of undulating road that poses sight line problems for
drivers (see picture 3, section 6.15).
7.4 Developers would be forced to create new roads for development area MN25M linking
onto Allithwaite Road; this would increase traffic hazards on Allithwaite Road, or, lead
to the creation of an intrusive roundabout system that would destroy the rural nature
of this road and area
7.5 Greaves Wood Road bridleway forms the eastern, and southern, boundaries of
MN25M; it could not be used as access to MN25M development area because of a)
the Protected Limestone Pavement in Greaves Wood and b) it is a popular pedestrian
route for local residents, especially dog walkers (see Map 1, section 5.7 and Map 3,
section 6.4).
7.6 Access from Kirkhead Road to the MN25M development area is not practical; there
are no suitable gaps between the houses whose back gardens form the western
boundary of MN25M.
7.7 Industrial development and 202 residential units will generate a large amount of extra
traffic in Kents Bank that will all need to drive through Grange-over-Sands to reach the
A590 for access to Kendal, Lancaster and the M6; the local road system is not
suitable for this.
7.8 Local roads are not adequate to accommodate service vehicles for industrial
development.
SEE PICTURES IN ATTACHED DOCUMENT
7.9 SLDC are also proposing to build dwellings on the land behind the lorry on Allithwaite
Road (picture 6) and on the left hand side of Allithwaite Road beyond the junction of
Allithwaite Road with Jack Hill (junction to the left of Kirkhead Road; picture 6); access
to both these sites is constrained by their location and will cause road safety
problems.
7.10 Picture 5 clearly shows that it is not possible to widen or straighten Risedale Hill
without major road works involving compulsory purchase orders, demolition of walls
and completely altering the character of this part of Kents Bank and that the road is
not suitable for large volumes of traffic.
7.11 Traffic from three other nearby proposed residential developments in Kents Bank,
R672M: 36 residential units & R89: 45 residential units, R350M: 17 houses, also link
to Allithwaite Road, near the top of Risedale Hill therefore they should also be taken
into account when undertaking an area traffic impact study (see Map 1, section 5.7);
as should traffic generated by all residential and employment developments west of
Risedale Hill in Allithwaite and Flookburgh.
7.12 Once the traffic has negotiated Risedale Hill it then has to negotiate Main Street hill in
Grange-over-Sands another bottleneck that is often made worse by delivery vehicles
for the local shops because none of the shops on this part of Main Street have rear
access,
7.13 The local roads are in a poor state of repair and are not suitable for this level of traffic
increase.
7.14 SLDC have made no provision for improving these roads and have not justified a
need for developments that will make the traffic conditions considerably worse and
deter tourists.
7.15 There is no viable route for a Grange-over-Sands by-pass. A new trunk road to the
A590 would have to be routed across rough pastureland to the north of Grange-over-
Sands and would impinge on classic views of Cartmel and Cartmel Priory.
7.16 Car parking in Grange-over-Sands is already inadequate for local residents shopping
and tourists and again, no provision has been made in SLDC’s Land Allocation DPD
to improve local car parking facilities.
Section 7: Inadequate local roads in Grange-over-Sands and District;
summary of main conclusions
- The roads in Grange-over-Sands and district are already inadequate for the
traffic that they carry.
- There are two major bottlenecks: Risedale Hill and Main Street Hill that
cannot be widened due to their location.
- It would be expensive and difficult to agree a route for a new trunk road to the
A590 that by-passed Grange-over-Sands.
- SLDC have not made any provision to upgrade roads in Grange-over-Sands
and district.
- SLDC have not provided objective evidence to justify proposing large
development to the west of Grange-over-Sands given the already inadequate
road system.
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
I do not support SLDC’s Land Allocation DPD
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
I wish to take part in the oral examination because SLDC have not made an adequate response to significant planning concerns, raised by local residents, during earlier consultation phases, particularly those relating to:
1. ‘Housing need’ in the Grange-over-Sands area.
2. Proposed green field site land allocations for the Grange-over-Sands area.
3. The adverse impact of the proposed developments on tourism, the life-blood of Grange-over-Sands and the Cartmel Peninsula.
4. The inadequate road system that links Grange-over-Sands to other SLDC Service Centres.
In addition, SLDC have not provided objective evidence that justifies their classification of Grange-over-Sands as an SLDC Key Service Centre. Grange-over-Sands does not meet SLDC’s Core Strategy Document definition of Key Service Centre: it does not have a secondary school and it is not directly linked to other SLDC Service Centres by a main trunk road.
Nor does the SLDC Land Allocation DPD take account of local residents’ wishes about how their community should be developed, or the views of Grange-over-Sands Town Council.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
484. Mrs Valerie Kennedy (Individual) : 16 May 2012 12:22:00
A typed or handwritten document was submitted. This has been scanned and can be downloaded below:
Policy/Site No.
LA3.3 Mixed Use Allocation at Guide's Lot, Grange-over-Sands
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
1. SLDC should not include Grange-over-Sands as one of its Key Service Centres because it does not meet the criteria in CS1.2 The development strategy for Principal Service Centres, Key Service Centres and Local Service Centres. This would mean that the number of proposed developments in Grange-over-Sands and district should be reduced and all proposed development sites should be reassessed. Development of brown field sites, such as Berners, should be prioritised and SLDC should take account of the views of local residents and Grange-over-Sands Town Council.
2. SLDC have not followed Government guidance about the use and interpretation of household surveys. They have not provided objective evidence to justify ‘housing need for Grange-over-Sands and District.
3. SLDC should be required to produce objective evidence to justify their plans to allow Grange-over-Sands to develop into a coastal urban sprawl incorporating Kents Bank.
4. SLDC should be required to remove sites MN25N, R672 and R79# from their Land Development DPD because development of these sites will lead to coalescence between the communities of Kents Bank and Allithwaite.
5. SLDC should be required to remove sites R449, R74 and R110 from their Land Development DPD because development of these sites will lead to further coalescence between the communities of Grange-over-Sands and Kents Bank.
6. SLDC should be required to produce clear evidence about how their proposed developments will enhance tourism in Grange-over-Sands and district.
7. SLDC should be required to explain why they have ignored recommendations made about green field sites and tourism in the Grange-over-Sands Regeneration Study (Douglas Wheeler Associates, November 2007), that they claim has informed SLDC's Core Strategy.
8. SLDC should be required to provide objective evidence that the local roads are adequate to support the proposed increase in population and traffic in Grange-over-Sands especially for known bottle-necks in Main Street and on Risedale Hill.
9. SLDC should not allow any development on prime green field land between Kents Bank and Allithwaite because it will lead to coalescence between these two separate communities.
1.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
I do not support SLDC’s Land Allocations DPD because it is based on spurious ‘housing need’ targets and has unnecessarily ear-marked important greenfield sites for development.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The following text of response 11293 is taken from sections 4, 5 and 7 of my SLDC LDF consultation submission entitled: ‘Soundness’ response to SLDC’s Land Allocation Development Plan (DPD, Jan 2012) focussing on SLDC’s ‘housing need’ predictions & SLDC’s vision for Grange-over-Sands and District.
My report included photographs, maps and tables to support comments that were made in the report. I have requested that this report be made available to the Planning Inspector.
The sections featured in response 11293 are:
4. Does SLDC's Land Allocation Document protect the needs of Grange-over-Sands as a unique coastal tourist destination?
5 . Does SLDC’s Land Allocation Document attempt to ‘air-brush’ Kents Bank out of existence as a separate community?
7. Does SLDC's Land Allocation Document make adequate provision for capital expenditure to upgrade local roads?
Photographs, tables and maps that were included with the text in the report have been stored elsewhere, formatting that clarified the text has been removed and spurious question marks have appeared that are not in the original text.
[The full report is attached]
4 Does SLDC’s Land Allocation Document protect the needs of Grange-over-
Sands as a unique coastal tourist destination?
4.1 SLDC’s Land Allocation Plan states that the Grange-over-Sands Regeneration Study
(November 2007), Douglas Wheeler Associates, has informed SLDC’s Core Strategy.
4.2 The Grange-over-Sands Regeneration Study states that Grange-over-Sands is:
i. North West England’s most distinctive, contemporary coastal resort town that has
used its Edwardian heritage as a strong asset in its regeneration.
ii. An exceptionally pleasant, very well maintained and friendly town with:
- An impressive promenade and superb views across Morecambe Bay.
- Excellent parks and garden.
- A well connected rail station.
- A strong community of established and new residents.
- A great place to live, work and visit.
iii. Has a strong convenience retailing and service orientated focus.
4.3 SLDC’s Core Strategy document states that:
"...We aim to achieve a balanced housing market by securing the provision of a range of
housing types and sizes to meet the needs of all sectors…” and
“…The exact scale and level of development supported will be dependent on individual
character, the impact on environmental capacity and infrastructure provision, and the
desire to meet the need for affordable housing as locally as possible…”
4.4 The proposed developments in SLDC’s Land Allocation document for Grange-over-
Sands and district have not achieved this objective because:
- They will increase the number of households by 25%.
- Local roads do not have the capacity to absorb the extra traffic that will be
generated.
- They will allow building on important green field sites.
- They will lead to the coalescence of Grange-over-Sands with adjacent
communities.
4.5 The questionable SLDC ‘new build’ target has been arbitrarily divided between defined
areas of South Lakeland district, on a percentage basis, between the Principal Service
Centres, Key Service Centres and rural areas.
4.6 The housing allocation made for Grange-over-Sands was based on its classification as a Key Service Centre but, as it does not meet the SLDC’s stated criteria for a Key Service
Centre (see Section 3), the housing allocation is not compatible with its needs as a
unique coastal tourist destination.
4.7 The allocation of new build’ for Grange-over-Sands, Kents Bank, Allithwaite and Cartmel
peninsula area does not appear to have factored in:
- The high percentage of retired people living in the area: a proportionally higher
amount of the existing housing stock will be available for ‘new’ households, on a
regular basis, due to the higher mortality.
- The high percentage of dwellings that are ‘second homes’ and ‘holiday lets’ some of
which are likely revert to normal residential use over time eg eight apartments in
Kents Bank were converted from ‘holiday apartments’ to ‘normal residential’
apartments in 2010.
4.8 SLDC has not justified the need for a massive ‘new build’ requirement in Grange-over-
Sands and district with objective evidence.
4.9 There is a need for ‘affordable housing’ but even that need has not been quantified
objectively.
4.10 The overall ‘new build’ housing figures have been inflated because of the policy of
requiring developers to subsidise ‘affordable housing’ (see section 2).
4.11 SLDC’s proposals will lead to a 25% increase in the number of households in Grangeover-Sands and Kents Bank without any provision for improvements to the local road
system or car parking facilities or utilities; this will be detrimental to the tourist industry.
4.12 Section 4.4 of SLDC’s Land Allocation document states:
“…Douglas Wheeler Associates prepared a Regeneration Study for Grange-over-
Sands in 2007. This carried out a detailed assessment of Grange as a Key
Service Centre that formed the basis of Core Strategy policies for the town…”
4.13 The independent Grange-over-Sands Regeneration Study 2007 found:
“…Around 7.5% of properties are second homes and clearly Grange should not become
dominated by second homes and retirement homes…”
4.14 If SLDC’s proposal to build 500 dwellings in Grange-over-Sands and district is realised the likely outcome will be to increase in the number of ‘second homes’, ‘holiday homes’, and ‘in-coming’ pensioners in order to subsidise 175 ‘affordable homes’; SLDC have not provided evidence to justify this need.
4.15 Building on this scale will not benefit the local community because it will lead to an
increased pressure on the NHS, local roads, public transport, utilities etc… and have an
adverse effect on local tourism.
4.16 There are currently 129 dwellings on the market in Grange-over-Sands and district
ranging from one and two bed-roomed apartments to large detached houses and
everything in between. Many of these properties have been on the market for over two
years; many others have been taken off the market and turned into private rented
accommodation. So, how can SLDC justify the need for 325 more new dwellings on the
open market?
4.17 The Grange-over-Sands Regeneration Study 2007 also stated that:
“…Additional housing will be provided to meet the needs of local people without
damaging the sensitive setting and character of the town…” and
“…the key to the success or failure of Grange-over-Sands…will be to invest in the
unique quality of the built and natural environment, infrastructure and public facilities
alongside promoting enterprise and business development…” and
“…It only requires one element to be below standard to reduce the overall appeal of the
place…”
4.18 Residents of Grange-over-Sands and district would agree with all the above objectives
but feel that SLDC’s Land Allocation DPD proposals do not match this expectation. For
instance, the study looked at Grange-over-Sands land development options in detail. It
recommended that land ‘north of playing field’ (R110: Trickett’s field) should not be
developed because: “…loss of open views from street is negative…”
4.19 This site is also important because it is one of the few remaining green gaps between
Grange-over-Sands and Kents Bank (see section 5).
4.20 The Grange-over-Sands Regeneration Study 2007 also stated that it was important to:
“…protect the network of green spaces and important environmental characteristics of
the town and its setting…” and
“…protect the network of green spaces and important characteristics of the town…give
priority to the use of previously developed land for development…”
4.21 Brown field sites such as Berners, the former candle factory and Bateman’s garage
should be developed for housing and employment before any green field sites are
considered; sensitive development of brown field sites will not destroy the rural
ambience of the area that is so attractive to tourists.
4.22 Tourism is the life-blood of Grange-over-Sands’ economy. SLDC is not justified in
proposing large scale developments on green field sites before undertaking a feasibility
study assessing the impact of the proposed developments on tourism. They have not
done this. Such arrogance is negligent given the potential impact on the local tourist
industry.
4.23 It is unlikely that tourists will want visit the Grange-over-Sands area during the
construction phases due to the impact on the already inadequate road system (see
section 7); post construction, who wants to visit a coastal urban sprawl?
4.24 Investment in basic infrastructure is needed before any major increase in housing but
the SLDC Land Allocation Development Plan does include any provision for solving the
known traffic bottle-necks of Risedale Hill and Main Street Grange-over-Sands (see
section 7). Why not?
4.25 Section 4.2 of the SLDC Land Allocation DPD states:
“…The Core Strategy (Policy CS4) sets the overall context for development in Grangeover-
Sands. This seeks to make provision for moderate housing development and
employment development, regenerate the Berners site, improve public transport, reinstate
footbridges and protect the network of Green Infrastructure as well as promoting
the vitality of Grange town Centre and promoting tourism…”
4.26 Local residents support all these objectives, but, the land development proposals that
SLDC have proposed for Grange-over-Sands and district contradict these objectives;
they have not protected the network Green infrastructure (see sections 5, 6 and 7) and
they have not promoted tourism, nor have they justified proposing to development of
green field sites with objective evidence.
4.27 As the Grange-over-Sands Regeneration Study 2007 said of Grange-over-Sands it is
important to:
- Maintain and enhance the viability of the town centre.
- Promote…appropriate development at the Berners Pool/BernersClose car
park/nursery/lido site to create a new focus.
- Promote the vitality and viability of Grange-over-Sands town centre.
- Promote the reintroduction of the Berners Close railway bridge.
- Focus on renovation rather than demolition.
- Minimise the impact on the environment and improve biodiversity
Unfortunately SLDC’s Land Allocation DPD appears to have lost sight of these
objectives.
Section 4: Grange-over-Sands, a unique coastal town;
summary of main conclusions
- Grange-over-Sands is a unique coastal town that is dependent on the tourist
industry and has unique development needs.
- Grange-over-Sands is not suitable for large scale development because of its
tourist needs; the surrounding rough pasture lands are part of its attraction.
- All proposed development should be considered in this context and should be
concentrated on brown field sites as recommended in the Grange-over-Sands
Regeneration Study 2007.
- The local road system, utilities and community support systems are already
inadequate; they are not robust enough to support 500 more households.
- The surrounding topography and proximity of other local communities means
that it is inappropriate allow large scale developments to extend into Kents
Bank or onto peripheral rough pasture land.
5 Does SLDC’s Land Allocation Document attempt to ‘air-brush’ Kents
Bank out of existence as a separate community?
5.1 SLDC’s Planning Department currently treats Kents Bank as a suburb of Grange-over-
Sands even though Kents Bank can trace its existence back to Mediaeval times when
monks from Cartmel lodged at Abbot Hall, Kents Bank, when ‘crossing the sands’
whereas Grange-over-Sands developed as a tourist resort in Victorian times after the
‘coming of the railway.
5.2 Kents Bank has its own station, Post Office, shop, Art Gallery, Abbot Hall Hotel and
Guide’s Farm. The post of Guide dates back to at least 1501 according to records of
Cartmel Priory.
5.3 During the past 20-25 years SLDC’s Planning Department have permitted infilling
development on many Kents Bank green field sites; they have allowed infilling on green
gaps between Kents Bank and Grange-over-Sands on the east, and, Kents Bank and
Allithwaite on the west.
5.4 Why is SLDC treating Kents Bank as a suburb of Grange-over-Sands? Residents of
Kents Bank do not support this view; they value their community and do not want to see
Kents Bank absorbed into Grange-over-Sands or Allithwaite. Kents Bank was
established hundreds of years before Grange-over-Sands.
5.5 This unsound approach has been perpetuated in SLDC’s Land Allocation DPD. Section
4.2 of the document is headed Grange-over-Sands and Kents Bank whereas Allithwaite
is considered as a separate community.
5.6 Subsequent text in SLDC’s Land Allocation DPD uses the name Grange-over-Sands
when it is actually referring to Kents Bank. For example paragraph 4.12 states:
“…The second major allocation is a large site on Allithwaite Road west of Kents Bank.
This is the only large site available in Grange-over-Sands…”
5.7 This is nonsense. The site referred to is MN25M; it is west of Kents Bank; it will
significantly extend Kents Bank’s western boundary and will lead to coalescence
between Kents Bank and Allithwaite if it is developed (see Map 1 and section 6).
REFER TO MAP 1 & 2 IN ATTACHED DOCUMENT
5.8 SLDC’s Land Allocation DPD gives Kents Bank similar problems with its Grange-over-
Sands boundaries; the green spaces between Grange-over-Sands and Kents Bank have
been gradually eroded over the years. If more green spaces between the two
communities are developed it will be the ‘death knell’ of Kents Bank as a separate
community (see Map 2)
5.9 It is clear from Map 2 that building on sites R110 (Trickett’s field) and R449/R74 will
erode the sense of separation between Grange-over-Sands and Kents Bank when
driving on the main road, the B5227 and that they will increase coalescence between
Grange-over-Sands and Kents Bank.
5.10 The Grange-over-Sands Regeneration Study 2007 considered site R110 (Trickett’s
field). They concluded that it should not be developed because:
“…loss of open views from street is negative…”
5.11 R449/R74 was not considered by the Grange-over-Sands Regeneration Study 2007 and its importance as a green field site has not been independently assessed. It is clear from Map 2 that development of these two sites will increase coalescence between Grangeover-Sands and Kents Bank. SLDC has provided no objective evidence to support the development of either of these green field sites.
5.12 The only green field site in Kents Bank that was considered by the Grange-over-Sands
Regeneration Study 2007 was site R89 (the Carter Road site, Berry Bank, Map 1 and
Map 2) and the report did not recommend development of R89 because of:
“…the loss of open area will be an issue…” and they concluded that
“…that residential development of the Allithwaite Road/Carter Road site is likely to be
controversial because of the ‘green field’ nature of the site…”
5.13 None of the development sites proposed for Kents Bank (Map 1), except R89, were
considered by the Grange-over-Sands Regeneration Study 2007; they have not been
independently assessed before inclusion in SLDC’s Land Allocation DPD.
REFER TO TABLE 4 in ATTACHED DOCUMENT
5.14 Table 4 clearly shows that a disproportionate amount of the unsustainable housing
allocation for Grange-over-Sands has been allocated to Kents Bank (58%)
5.15 The proposed development will increase the size of Kents Bank by 40% and extend its
boundaries towards Allithwaite causing coalescence between Kents Bank and
Allithwaite; SLDC have provided no objective evidence to justify increasing the size of
Kents Bank on this scale.
5.16 All the proposed housing development sites in Kents Bank have been allocated to
desirable green field sites except for Guides Lot (17 dwellings plus employment units)
but even this site includes a small additional green field and the site is adjacent to land
on Wart Barrow that is covered by a Limestone Pavement Order.
5.17 The proposed site MN25M is particularly contentious (see section 6).
5.18 Development of all the proposed sites near Risedale Hill and in Kents Bank will have an adverse effect on local drainage in areas that are already prone to flooding after heavy
rainfall eg Allithwaite Road beyond the top of Risedale Hill, Greaves Wood Road
(Bridleway) and Kirkhead Road.
5.19 The SLDC’s Land Allocation DPD has not taken account of problems highlighted by
Kents Bank residents in the 2011 consultation exercises. For example response forms
that I submitted for sites: MN25M, R672, 350M, R79#, R82#/R347# (see Appendices 3
to 7).
5.20 Many other residents also highlighted significant problems associated with the proposed land allocations for Kents Bank. All appear to have been ignored and lumped together in groups with a comment such as ‘noted’ beside them (see section 8). Why?
Section 5: Kents Bank as a separate community;
summary of main conclusions
- Kents Bank has been a separate community since Mediaeval times.
- SLDC have provided no clear evidence to justify increasing the size of Kents
Bank by 40%.
- SLDC have provided no clear evidence to justify sanctioning developments
that will increase coalescence between Grange-over-Sands and Kents Bank.
- SLDC have provided no clear evidence to justify sanctioning developments
that will increase coalescence between Kents Bank and Allithwaite.
- The local road system, utilities and community support systems are already
inadequate; they are not robust enough to support 298 more households in
Kents Bank.
7 Does SLDC’s Land Allocation Document make adequate provision for
capital expenditure to upgrade local roads?
7.1 Allithwaite Road (B5277) is already inadequate for the amount of traffic regularly
travelling between Grange-over-Sands, Allithwaite, Flookburgh, Holker Hall, Kendal,
Lancaster and the M6.
7.2 The traffic problem is exacerbated when regular events such as Cartmel Races and
the Holker Garden Festival attract large crowds.
7.3 The stretch of Allithwaite Road between Kents Bank and Allithwaite from the top of
Risedale Hill is a fast stretch of undulating road that poses sight line problems for
drivers (see picture 3, section 6.15).
7.4 Developers would be forced to create new roads for development area MN25M linking
onto Allithwaite Road; this would increase traffic hazards on Allithwaite Road, or, lead
to the creation of an intrusive roundabout system that would destroy the rural nature
of this road and area
7.5 Greaves Wood Road bridleway forms the eastern, and southern, boundaries of
MN25M; it could not be used as access to MN25M development area because of a)
the Protected Limestone Pavement in Greaves Wood and b) it is a popular pedestrian
route for local residents, especially dog walkers (see Map 1, section 5.7 and Map 3,
section 6.4).
7.6 Access from Kirkhead Road to the MN25M development area is not practical; there
are no suitable gaps between the houses whose back gardens form the western
boundary of MN25M.
7.7 Industrial development and 202 residential units will generate a large amount of extra
traffic in Kents Bank that will all need to drive through Grange-over-Sands to reach the
A590 for access to Kendal, Lancaster and the M6; the local road system is not
suitable for this.
7.8 Local roads are not adequate to accommodate service vehicles for industrial
development.
REFER TO PICTURES IN ATTACHED DOCUMENT
7.9 SLDC are also proposing to build dwellings on the land behind the lorry on Allithwaite
Road (picture 6) and on the left hand side of Allithwaite Road beyond the junction of
Allithwaite Road with Jack Hill (junction to the left of Kirkhead Road; picture 6); access
to both these sites is constrained by their location and will cause road safety
problems.
7.10 Picture 5 clearly shows that it is not possible to widen or straighten Risedale Hill
without major road works involving compulsory purchase orders, demolition of walls
and completely altering the character of this part of Kents Bank and that the road is
not suitable for large volumes of traffic.
7.11 Traffic from three other nearby proposed residential developments in Kents Bank,
R672M: 36 residential units & R89: 45 residential units, R350M: 17 houses, also link
to Allithwaite Road, near the top of Risedale Hill therefore they should also be taken
into account when undertaking an area traffic impact study (see Map 1, section 5.7);
as should traffic generated by all residential and employment developments west of
Risedale Hill in Allithwaite and Flookburgh.
7.12 Once the traffic has negotiated Risedale Hill it then has to negotiate Main Street hill in
Grange-over-Sands another bottleneck that is often made worse by delivery vehicles
for the local shops because none of the shops on this part of Main Street have rear
access,
7.13 The local roads are in a poor state of repair and are not suitable for this level of traffic
increase.
7.14 SLDC have made no provision for improving these roads and have not justified a
need for developments that will make the traffic conditions considerably worse and
deter tourists.
7.15 There is no viable route for a Grange-over-Sands by-pass. A new trunk road to the
A590 would have to be routed across rough pastureland to the north of Grange-over-
Sands and would impinge on classic views of Cartmel and Cartmel Priory.
7.16 Car parking in Grange-over-Sands is already inadequate for local residents shopping
and tourists and again, no provision has been made in SLDC’s Land Allocation DPD
to improve local car parking facilities.
Section 7: Inadequate local roads in Grange-over-Sands and District;
summary of main conclusions
- The roads in Grange-over-Sands and district are already inadequate for the
traffic that they carry.
- There are two major bottlenecks: Risedale Hill and Main Street Hill that
cannot be widened due to their location.
- It would be expensive and difficult to agree a route for a new trunk road to the
A590 that by-passed Grange-over-Sands.
- SLDC have not made any provision to upgrade roads in Grange-over-Sands
and district.
- SLDC have not provided objective evidence to justify proposing large
development to the west of Grange-over-Sands given the already inadequate
road system.
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
I do not support SLDC’s Land Allocation DPD
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
I wish to take part in the oral examination because SLDC have not made an adequate response to significant planning concerns, raised by local residents, during earlier consultation phases, particularly those relating to:
1. ‘Housing need’ in the Grange-over-Sands area.
2. Proposed green field site land allocations for the Grange-over-Sands area.
3. The adverse impact of the proposed developments on tourism, the life-blood of Grange-over-Sands and the Cartmel Peninsula.
4. The inadequate road system that links Grange-over-Sands to other SLDC Service Centres.
In addition, SLDC have not provided objective evidence that justifies their classification of Grange-over-Sands as an SLDC Key Service Centre. Grange-over-Sands does not meet SLDC’s Core Strategy Document definition of Key Service Centre: it does not have a secondary school and it is not directly linked to other SLDC Service Centres by a main trunk road.
Nor does the SLDC Land Allocation DPD take account of local residents’ wishes about how their community should be developed, or the views of Grange-over-Sands Town Council.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
485. Mrs Valerie Kennedy (Individual) : 16 May 2012 12:29:00
A typed or handwritten document was submitted. This has been scanned and can be downloaded below:
Policy/Site No.
LA1.3 Housing Allocations - R449/R74 GRANGE-OVER-SANDS OPPOSITE LITTLE FELL GATE FARM
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
1. SLDC should not include Grange-over-Sands as one of its Key Service Centres because it does not meet the criteria in CS1.2 The development strategy for Principal Service Centres, Key Service Centres and Local Service Centres. This would mean that the number of proposed developments in Grange-over-Sands and district should be reduced and all proposed development sites should be reassessed. Development of brown field sites, such as Berners, should be prioritised and SLDC should take account of the views of local residents and Grange-over-Sands Town Council.
2. SLDC have not followed Government guidance about the use and interpretation of household surveys. They have not provided objective evidence to justify ‘housing need for Grange-over-Sands and District.
3. SLDC should be required to produce objective evidence to justify their plans to allow Grange-over-Sands to develop into a coastal urban sprawl incorporating Kents Bank.
4. SLDC should be required to remove sites MN25N, R672 and R79# from their Land Development DPD because development of these sites will lead to coalescence between the communities of Kents Bank and Allithwaite.
5. SLDC should be required to remove sites R449, R74 and R110 from their Land Development DPD because development of these sites will lead to further coalescence between the communities of Grange-over-Sands and Kents Bank.
6. SLDC should be required to produce clear evidence about how their proposed developments will enhance tourism in Grange-over-Sands and district.
7. SLDC should be required to explain why they have ignored recommendations made about green field sites and tourism in the Grange-over-Sands Regeneration Study (Douglas Wheeler Associates, November 2007), that they claim has informed SLDC's Core Strategy.
8. SLDC should be required to provide objective evidence that the local roads are adequate to support the proposed increase in population and traffic in Grange-over-Sands especially for known bottle-necks in Main Street and on Risedale Hill.
9. SLDC should not allow any development on prime green field land between Kents Bank and Allithwaite because it will lead to coalescence between these two separate communities.
1.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
I do not support SLDC’s Land Allocations DPD because it is based on spurious ‘housing need’ targets and has unnecessarily ear-marked important greenfield sites for development.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The following text of response 11295 is taken from section 5, my SLDC LDF consultation submission entitled: ‘Soundness’ response to SLDC’s Land Allocation Development Plan (DPD, Jan 2012) focussing on SLDC’s ‘housing need’ predictions & SLDC’s vision for Grange-over-Sands and District.
My report included photographs, maps and tables to support comments that were made in the report. I have requested that this report be made available to the Planning Inspector.
The section featured in response 11295 is:
5. Does SLDC’s Land Allocation Document attempt to ‘air-brush’ Kents Bank out of existence as a separate community?
Tables and maps that were included with the text in the report have been stored elsewhere, formatting that clarified the text has been removed and spurious question marks have appeared that are not in the original text.
[The full report is attached]
5 Does SLDC’s Land Allocation Document attempt to ‘air-brush’ Kents
Bank out of existence as a separate community?
5.1 SLDC’s Planning Department currently treats Kents Bank as a suburb of Grange-over-
Sands even though Kents Bank can trace its existence back to Mediaeval times when
monks from Cartmel lodged at Abbot Hall, Kents Bank, when ‘crossing the sands’
whereas Grange-over-Sands developed as a tourist resort in Victorian times after the
‘coming of the railway.
5.2 Kents Bank has its own station, Post Office, shop, Art Gallery, Abbot Hall Hotel and
Guide’s Farm. The post of Guide dates back to at least 1501 according to records of
Cartmel Priory.
5.3 During the past 20-25 years SLDC’s Planning Department have permitted infilling
development on many Kents Bank green field sites; they have allowed infilling on green
gaps between Kents Bank and Grange-over-Sands on the east, and, Kents Bank and
Allithwaite on the west.
5.4 Why is SLDC treating Kents Bank as a suburb of Grange-over-Sands? Residents of
Kents Bank do not support this view; they value their community and do not want to see
Kents Bank absorbed into Grange-over-Sands or Allithwaite. Kents Bank was
established hundreds of years before Grange-over-Sands.
5.5 This unsound approach has been perpetuated in SLDC’s Land Allocation DPD. Section
4.2 of the document is headed Grange-over-Sands and Kents Bank whereas Allithwaite
is considered as a separate community.
5.6 Subsequent text in SLDC’s Land Allocation DPD uses the name Grange-over-Sands
when it is actually referring to Kents Bank. For example paragraph 4.12 states:
“…The second major allocation is a large site on Allithwaite Road west of Kents Bank.
This is the only large site available in Grange-over-Sands…”
5.7 This is nonsense. The site referred to is MN25M; it is west of Kents Bank; it will
significantly extend Kents Bank’s western boundary and will lead to coalescence
between Kents Bank and Allithwaite if it is developed (see Map 1 and section 6).
REFER TO MAP 1 & 2 IN ATTACHED DOCUMENT
5.8 SLDC’s Land Allocation DPD gives Kents Bank similar problems with its Grange-over-
Sands boundaries; the green spaces between Grange-over-Sands and Kents Bank have
been gradually eroded over the years. If more green spaces between the two
communities are developed it will be the ‘death knell’ of Kents Bank as a separate
community (see Map 2)
5.9 It is clear from Map 2 that building on sites R110 (Trickett’s field) and R449/R74 will
erode the sense of separation between Grange-over-Sands and Kents Bank when
driving on the main road, the B5227 and that they will increase coalescence between
Grange-over-Sands and Kents Bank.
5.10 The Grange-over-Sands Regeneration Study 2007 considered site R110 (Trickett’s
field). They concluded that it should not be developed because:
“…loss of open views from street is negative…”
5.11 R449/R74 was not considered by the Grange-over-Sands Regeneration Study 2007 and its importance as a green field site has not been independently assessed. It is clear from Map 2 that development of these two sites will increase coalescence between Grangeover-Sands and Kents Bank. SLDC has provided no objective evidence to support the development of either of these green field sites.
5.12 The only green field site in Kents Bank that was considered by the Grange-over-Sands
Regeneration Study 2007 was site R89 (the Carter Road site, Berry Bank, Map 1 and
Map 2) and the report did not recommend development of R89 because of:
“…the loss of open area will be an issue…” and they concluded that
“…that residential development of the Allithwaite Road/Carter Road site is likely to be
controversial because of the ‘green field’ nature of the site…”
5.13 None of the development sites proposed for Kents Bank (Map 1), except R89, were
considered by the Grange-over-Sands Regeneration Study 2007; they have not been
independently assessed before inclusion in SLDC’s Land Allocation DPD.
SEE TABLE 4 IN ATTACHED DOCUMENT
5.14 Table 4 clearly shows that a disproportionate amount of the unsustainable housing
allocation for Grange-over-Sands has been allocated to Kents Bank (58%)
5.15 The proposed development will increase the size of Kents Bank by 40% and extend its
boundaries towards Allithwaite causing coalescence between Kents Bank and
Allithwaite; SLDC have provided no objective evidence to justify increasing the size of
Kents Bank on this scale.
5.16 All the proposed housing development sites in Kents Bank have been allocated to
desirable green field sites except for Guides Lot (17 dwellings plus employment units)
but even this site includes a small additional green field and the site is adjacent to land
on Wart Barrow that is covered by a Limestone Pavement Order.
5.17 The proposed site MN25M is particularly contentious (see section 6).
5.18 Development of all the proposed sites near Risedale Hill and in Kents Bank will have an adverse effect on local drainage in areas that are already prone to flooding after heavy
rainfall eg Allithwaite Road beyond the top of Risedale Hill, Greaves Wood Road
(Bridleway) and Kirkhead Road.
5.19 The SLDC’s Land Allocation DPD has not taken account of problems highlighted by
Kents Bank residents in the 2011 consultation exercises. For example response forms
that I submitted for sites: MN25M, R672, 350M, R79#, R82#/R347# (see Appendices 3
to 7).
5.20 Many other residents also highlighted significant problems associated with the proposed land allocations for Kents Bank. All appear to have been ignored and lumped together in groups with a comment such as ‘noted’ beside them (see section 8). Why?
Section 5: Kents Bank as a separate community;
summary of main conclusions
- Kents Bank has been a separate community since Mediaeval times.
- SLDC have provided no clear evidence to justify increasing the size of Kents
Bank by 40%.
- SLDC have provided no clear evidence to justify sanctioning developments
that will increase coalescence between Grange-over-Sands and Kents Bank.
- SLDC have provided no clear evidence to justify sanctioning developments
that will increase coalescence between Kents Bank and Allithwaite.
- The local road system, utilities and community support systems are already
inadequate; they are not robust enough to support 298 more households in
Kents Bank.
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
I do not support SLDC’s Land Allocation DPD
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
I wish to take part in the oral examination because SLDC have not made an adequate response to significant planning concerns, raised by local residents, during earlier consultation phases, particularly those relating to:
1. ‘Housing need’ in the Grange-over-Sands area.
2. Proposed green field site land allocations for the Grange-over-Sands area.
3. The adverse impact of the proposed developments on tourism, the life-blood of Grange-over-Sands and the Cartmel Peninsula.
4. The inadequate road system that links Grange-over-Sands to other SLDC Service Centres.
In addition, SLDC have not provided objective evidence that justifies their classification of Grange-over-Sands as an SLDC Key Service Centre. Grange-over-Sands does not meet SLDC’s Core Strategy Document definition of Key Service Centre: it does not have a secondary school and it is not directly linked to other SLDC Service Centres by a main trunk road.
Nor does the SLDC Land Allocation DPD take account of local residents’ wishes about how their community should be developed, or the views of Grange-over-Sands Town Council.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
486. Mrs Valerie Kennedy (Individual) : 16 May 2012 12:32:00
A typed or handwritten document was submitted. This has been scanned and can be downloaded below:
Policy/Site No.
LA1.3 Housing Allocations - R89 GRANGE-OVER-SANDS NORTH OF CARTER ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
1. SLDC should not include Grange-over-Sands as one of its Key Service Centres because it does not meet the criteria in CS1.2 The development strategy for Principal Service Centres, Key Service Centres and Local Service Centres. This would mean that the number of proposed developments in Grange-over-Sands and district should be reduced and all proposed development sites should be reassessed. Development of brown field sites, such as Berners, should be prioritised and SLDC should take account of the views of local residents and Grange-over-Sands Town Council.
2. SLDC have not followed Government guidance about the use and interpretation of household surveys. They have not provided objective evidence to justify ‘housing need for Grange-over-Sands and District.
3. SLDC should be required to produce objective evidence to justify their plans to allow Grange-over-Sands to develop into a coastal urban sprawl incorporating Kents Bank.
4. SLDC should be required to remove sites MN25N, R672 and R79# from their Land Development DPD because development of these sites will lead to coalescence between the communities of Kents Bank and Allithwaite.
5. SLDC should be required to remove sites R449, R74 and R110 from their Land Development DPD because development of these sites will lead to further coalescence between the communities of Grange-over-Sands and Kents Bank.
6. SLDC should be required to produce clear evidence about how their proposed developments will enhance tourism in Grange-over-Sands and district.
7. SLDC should be required to explain why they have ignored recommendations made about green field sites and tourism in the Grange-over-Sands Regeneration Study (Douglas Wheeler Associates, November 2007), that they claim has informed SLDC's Core Strategy.
8. SLDC should be required to provide objective evidence that the local roads are adequate to support the proposed increase in population and traffic in Grange-over-Sands especially for known bottle-necks in Main Street and on Risedale Hill.
9. SLDC should not allow any development on prime green field land between Kents Bank and Allithwaite because it will lead to coalescence between these two separate communities.
1.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
I do not support SLDC’s Land Allocations DPD because it is based on spurious ‘housing need’ targets and has unnecessarily ear-marked important greenfield sites for development.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The following text of response 11296 is taken from sections 5 and 7 of my SLDC LDF consultation submission entitled: ‘Soundness’ response to SLDC’s Land Allocation Development Plan (DPD, Jan 2012) focussing on SLDC’s ‘housing need’ predictions & SLDC’s vision for Grange-over-Sands and District.
My report included photographs, maps and tables to support comments that were made in the report. I have requested that this report be made available to the Planning Inspector.
The sections featured in response 11296 are:
5 . Does SLDC’s Land Allocation Document attempt to ‘air-brush’ Kents Bank out of existence as a separate community?
7. Does SLDC's Land Allocation Document make adequate provision for capital expenditure to upgrade local roads?
Photographs, tables and maps that were included with the text in the report have been stored elsewhere, formatting that clarified the text has been removed and spurious question marks have appeared that are not in the original text.
[Full report is attached]
5 Does SLDC’s Land Allocation Document attempt to ‘air-brush’ Kents
Bank out of existence as a separate community?
5.1 SLDC’s Planning Department currently treats Kents Bank as a suburb of Grange-over-
Sands even though Kents Bank can trace its existence back to Mediaeval times when
monks from Cartmel lodged at Abbot Hall, Kents Bank, when ‘crossing the sands’
whereas Grange-over-Sands developed as a tourist resort in Victorian times after the
‘coming of the railway.
5.2 Kents Bank has its own station, Post Office, shop, Art Gallery, Abbot Hall Hotel and
Guide’s Farm. The post of Guide dates back to at least 1501 according to records of
Cartmel Priory.
5.3 During the past 20-25 years SLDC’s Planning Department have permitted infilling
development on many Kents Bank green field sites; they have allowed infilling on green
gaps between Kents Bank and Grange-over-Sands on the east, and, Kents Bank and
Allithwaite on the west.
5.4 Why is SLDC treating Kents Bank as a suburb of Grange-over-Sands? Residents of
Kents Bank do not support this view; they value their community and do not want to see
Kents Bank absorbed into Grange-over-Sands or Allithwaite. Kents Bank was
established hundreds of years before Grange-over-Sands.
5.5 This unsound approach has been perpetuated in SLDC’s Land Allocation DPD. Section
4.2 of the document is headed Grange-over-Sands and Kents Bank whereas Allithwaite
is considered as a separate community.
5.6 Subsequent text in SLDC’s Land Allocation DPD uses the name Grange-over-Sands
when it is actually referring to Kents Bank. For example paragraph 4.12 states:
“…The second major allocation is a large site on Allithwaite Road west of Kents Bank.
This is the only large site available in Grange-over-Sands…”
5.7 This is nonsense. The site referred to is MN25M; it is west of Kents Bank; it will
significantly extend Kents Bank’s western boundary and will lead to coalescence
between Kents Bank and Allithwaite if it is developed (see Map 1 and section 6).
REFER TO MAP 1 & 2 IN ATTACHED DOCUMENT
5.8 SLDC’s Land Allocation DPD gives Kents Bank similar problems with its Grange-over-
Sands boundaries; the green spaces between Grange-over-Sands and Kents Bank have
been gradually eroded over the years. If more green spaces between the two
communities are developed it will be the ‘death knell’ of Kents Bank as a separate
community (see Map 2)
5.9 It is clear from Map 2 that building on sites R110 (Trickett’s field) and R449/R74 will
erode the sense of separation between Grange-over-Sands and Kents Bank when
driving on the main road, the B5227 and that they will increase coalescence between
Grange-over-Sands and Kents Bank.
5.10 The Grange-over-Sands Regeneration Study 2007 considered site R110 (Trickett’s
field). They concluded that it should not be developed because:
“…loss of open views from street is negative…”
5.11 R449/R74 was not considered by the Grange-over-Sands Regeneration Study 2007 and its importance as a green field site has not been independently assessed. It is clear from Map 2 that development of these two sites will increase coalescence between Grangeover-Sands and Kents Bank. SLDC has provided no objective evidence to support the development of either of these green field sites.
5.12 The only green field site in Kents Bank that was considered by the Grange-over-Sands
Regeneration Study 2007 was site R89 (the Carter Road site, Berry Bank, Map 1 and
Map 2) and the report did not recommend development of R89 because of:
“…the loss of open area will be an issue…” and they concluded that
“…that residential development of the Allithwaite Road/Carter Road site is likely to be
controversial because of the ‘green field’ nature of the site…”
5.13 None of the development sites proposed for Kents Bank (Map 1), except R89, were
considered by the Grange-over-Sands Regeneration Study 2007; they have not been
independently assessed before inclusion in SLDC’s Land Allocation DPD.
SEE TABLE 4 IN ATTACHED DOCUMENT
5.14 Table 4 clearly shows that a disproportionate amount of the unsustainable housing
allocation for Grange-over-Sands has been allocated to Kents Bank (58%)
5.15 The proposed development will increase the size of Kents Bank by 40% and extend its
boundaries towards Allithwaite causing coalescence between Kents Bank and
Allithwaite; SLDC have provided no objective evidence to justify increasing the size of
Kents Bank on this scale.
5.16 All the proposed housing development sites in Kents Bank have been allocated to
desirable green field sites except for Guides Lot (17 dwellings plus employment units)
but even this site includes a small additional green field and the site is adjacent to land
on Wart Barrow that is covered by a Limestone Pavement Order.
5.17 The proposed site MN25M is particularly contentious (see section 6).
5.18 Development of all the proposed sites near Risedale Hill and in Kents Bank will have an adverse effect on local drainage in areas that are already prone to flooding after heavy
rainfall eg Allithwaite Road beyond the top of Risedale Hill, Greaves Wood Road
(Bridleway) and Kirkhead Road.
5.19 The SLDC’s Land Allocation DPD has not taken account of problems highlighted by
Kents Bank residents in the 2011 consultation exercises. For example response forms
that I submitted for sites: MN25M, R672, 350M, R79#, R82#/R347# (see Appendices 3
to 7).
5.20 Many other residents also highlighted significant problems associated with the proposed land allocations for Kents Bank. All appear to have been ignored and lumped together in groups with a comment such as ‘noted’ beside them (see section 8). Why?
Section 5: Kents Bank as a separate community;
summary of main conclusions
- Kents Bank has been a separate community since Mediaeval times.
- SLDC have provided no clear evidence to justify increasing the size of Kents
Bank by 40%.
- SLDC have provided no clear evidence to justify sanctioning developments
that will increase coalescence between Grange-over-Sands and Kents Bank.
- SLDC have provided no clear evidence to justify sanctioning developments
that will increase coalescence between Kents Bank and Allithwaite.
- The local road system, utilities and community support systems are already
inadequate; they are not robust enough to support 298 more households in
Kents Bank.
7 Does SLDC’s Land Allocation Document make adequate provision for
capital expenditure to upgrade local roads?
7.1 Allithwaite Road (B5277) is already inadequate for the amount of traffic regularly
travelling between Grange-over-Sands, Allithwaite, Flookburgh, Holker Hall, Kendal,
Lancaster and the M6.
7.2 The traffic problem is exacerbated when regular events such as Cartmel Races and
the Holker Garden Festival attract large crowds.
7.3 The stretch of Allithwaite Road between Kents Bank and Allithwaite from the top of
Risedale Hill is a fast stretch of undulating road that poses sight line problems for
drivers (see picture 3, section 6.15).
7.4 Developers would be forced to create new roads for development area MN25M linking
onto Allithwaite Road; this would increase traffic hazards on Allithwaite Road, or, lead
to the creation of an intrusive roundabout system that would destroy the rural nature
of this road and area
7.5 Greaves Wood Road bridleway forms the eastern, and southern, boundaries of
MN25M; it could not be used as access to MN25M development area because of a)
the Protected Limestone Pavement in Greaves Wood and b) it is a popular pedestrian
route for local residents, especially dog walkers (see Map 1, section 5.7 and Map 3,
section 6.4).
7.6 Access from Kirkhead Road to the MN25M development area is not practical; there
are no suitable gaps between the houses whose back gardens form the western
boundary of MN25M.
7.7 Industrial development and 202 residential units will generate a large amount of extra
traffic in Kents Bank that will all need to drive through Grange-over-Sands to reach the
A590 for access to Kendal, Lancaster and the M6; the local road system is not
suitable for this.
7.8 Local roads are not adequate to accommodate service vehicles for industrial
development.
SEE PICTURES IN ATTACHED DOCUMENT
7.9 SLDC are also proposing to build dwellings on the land behind the lorry on Allithwaite
Road (picture 6) and on the left hand side of Allithwaite Road beyond the junction of
Allithwaite Road with Jack Hill (junction to the left of Kirkhead Road; picture 6); access
to both these sites is constrained by their location and will cause road safety
problems.
7.10 Picture 5 clearly shows that it is not possible to widen or straighten Risedale Hill
without major road works involving compulsory purchase orders, demolition of walls
and completely altering the character of this part of Kents Bank and that the road is
not suitable for large volumes of traffic.
7.11 Traffic from three other nearby proposed residential developments in Kents Bank,
R672M: 36 residential units & R89: 45 residential units, R350M: 17 houses, also link
to Allithwaite Road, near the top of Risedale Hill therefore they should also be taken
into account when undertaking an area traffic impact study (see Map 1, section 5.7);
as should traffic generated by all residential and employment developments west of
Risedale Hill in Allithwaite and Flookburgh.
7.12 Once the traffic has negotiated Risedale Hill it then has to negotiate Main Street hill in
Grange-over-Sands another bottleneck that is often made worse by delivery vehicles
for the local shops because none of the shops on this part of Main Street have rear
access,
7.13 The local roads are in a poor state of repair and are not suitable for this level of traffic
increase.
7.14 SLDC have made no provision for improving these roads and have not justified a
need for developments that will make the traffic conditions considerably worse and
deter tourists.
7.15 There is no viable route for a Grange-over-Sands by-pass. A new trunk road to the
A590 would have to be routed across rough pastureland to the north of Grange-over-
Sands and would impinge on classic views of Cartmel and Cartmel Priory.
7.16 Car parking in Grange-over-Sands is already inadequate for local residents shopping
and tourists and again, no provision has been made in SLDC’s Land Allocation DPD
to improve local car parking facilities.
Section 7: Inadequate local roads in Grange-over-Sands and District;
summary of main conclusions
- The roads in Grange-over-Sands and district are already inadequate for the
traffic that they carry.
- There are two major bottlenecks: Risedale Hill and Main Street Hill that
cannot be widened due to their location.
- It would be expensive and difficult to agree a route for a new trunk road to the
A590 that by-passed Grange-over-Sands.
- SLDC have not made any provision to upgrade roads in Grange-over-Sands
and district.
- SLDC have not provided objective evidence to justify proposing large
development to the west of Grange-over-Sands given the already inadequate
road system.
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
I do not support SLDC’s Land Allocation DPD
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
I wish to take part in the oral examination because SLDC have not made an adequate response to significant planning concerns, raised by local residents, during earlier consultation phases, particularly those relating to:
1. ‘Housing need’ in the Grange-over-Sands area.
2. Proposed green field site land allocations for the Grange-over-Sands area.
3. The adverse impact of the proposed developments on tourism, the life-blood of Grange-over-Sands and the Cartmel Peninsula.
4. The inadequate road system that links Grange-over-Sands to other SLDC Service Centres.
In addition, SLDC have not provided objective evidence that justifies their classification of Grange-over-Sands as an SLDC Key Service Centre. Grange-over-Sands does not meet SLDC’s Core Strategy Document definition of Key Service Centre: it does not have a secondary school and it is not directly linked to other SLDC Service Centres by a main trunk road.
Nor does the SLDC Land Allocation DPD take account of local residents’ wishes about how their community should be developed, or the views of Grange-over-Sands Town Council.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
487. Mrs Valerie Kennedy (Individual) : 16 May 2012 12:34:00
A typed or handwritten document was submitted. This has been scanned and can be downloaded below:
Policy/Site No.
LA1.3 Housing Allocations - R672M GRANGE-OVER-SANDS WEST OF CARDRONA ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
1. SLDC should not include Grange-over-Sands as one of its Key Service Centres because it does not meet the criteria in CS1.2 The development strategy for Principal Service Centres, Key Service Centres and Local Service Centres. This would mean that the number of proposed developments in Grange-over-Sands and district should be reduced and all proposed development sites should be reassessed. Development of brown field sites, such as Berners, should be prioritised and SLDC should take account of the views of local residents and Grange-over-Sands Town Council.
2. SLDC have not followed Government guidance about the use and interpretation of household surveys. They have not provided objective evidence to justify ‘housing need for Grange-over-Sands and District.
3. SLDC should be required to produce objective evidence to justify their plans to allow Grange-over-Sands to develop into a coastal urban sprawl incorporating Kents Bank.
4. SLDC should be required to remove sites MN25N, R672 and R79# from their Land Development DPD because development of these sites will lead to coalescence between the communities of Kents Bank and Allithwaite.
5. SLDC should be required to remove sites R449, R74 and R110 from their Land Development DPD because development of these sites will lead to further coalescence between the communities of Grange-over-Sands and Kents Bank.
6. SLDC should be required to produce clear evidence about how their proposed developments will enhance tourism in Grange-over-Sands and district.
7. SLDC should be required to explain why they have ignored recommendations made about green field sites and tourism in the Grange-over-Sands Regeneration Study (Douglas Wheeler Associates, November 2007), that they claim has informed SLDC's Core Strategy.
8. SLDC should be required to provide objective evidence that the local roads are adequate to support the proposed increase in population and traffic in Grange-over-Sands especially for known bottle-necks in Main Street and on Risedale Hill.
9. SLDC should not allow any development on prime green field land between Kents Bank and Allithwaite because it will lead to coalescence between these two separate communities.
1.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
I do not support SLDC’s Land Allocations DPD because it is based on spurious ‘housing need’ targets and has unnecessarily ear-marked important greenfield sites for development.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The following text of response 11297 is taken from sections 5, 6 and 7 of my SLDC LDF consultation submission entitled: ‘Soundness’ response to SLDC’s Land Allocation Development Plan (DPD, Jan 2012) focussing on SLDC’s ‘housing need’ predictions & SLDC’s vision for Grange-over-Sands and District.
My report included photographs, maps and tables to support comments that were made in the report. I have requested that this report be made available to the Planning Inspector.
The sections featured in response 11297 are:
5 . Does SLDC’s Land Allocation Document attempt to ‘air-brush’ Kents Bank out of existence as a separate community?
6. Does SLDC’s Land Allocation Document protect against coalescence between Kents Bank and Allithwaite?
7. Does SLDC's Land Allocation Document make adequate provision for capital expenditure to upgrade local roads?
Photographs, tables and maps that were included with the text in the report have been stored elsewhere, formatting that clarified the text has been removed and spurious question marks have appeared that are not in the original text.
[The full report is attached]
5 Does SLDC’s Land Allocation Document attempt to ‘air-brush’ Kents
Bank out of existence as a separate community?
5.1 SLDC’s Planning Department currently treats Kents Bank as a suburb of Grange-over-
Sands even though Kents Bank can trace its existence back to Mediaeval times when
monks from Cartmel lodged at Abbot Hall, Kents Bank, when ‘crossing the sands’
whereas Grange-over-Sands developed as a tourist resort in Victorian times after the
‘coming of the railway.
5.2 Kents Bank has its own station, Post Office, shop, Art Gallery, Abbot Hall Hotel and
Guide’s Farm. The post of Guide dates back to at least 1501 according to records of
Cartmel Priory.
5.3 During the past 20-25 years SLDC’s Planning Department have permitted infilling
development on many Kents Bank green field sites; they have allowed infilling on green
gaps between Kents Bank and Grange-over-Sands on the east, and, Kents Bank and
Allithwaite on the west.
5.4 Why is SLDC treating Kents Bank as a suburb of Grange-over-Sands? Residents of
Kents Bank do not support this view; they value their community and do not want to see
Kents Bank absorbed into Grange-over-Sands or Allithwaite. Kents Bank was
established hundreds of years before Grange-over-Sands.
5.5 This unsound approach has been perpetuated in SLDC’s Land Allocation DPD. Section
4.2 of the document is headed Grange-over-Sands and Kents Bank whereas Allithwaite
is considered as a separate community.
5.6 Subsequent text in SLDC’s Land Allocation DPD uses the name Grange-over-Sands
when it is actually referring to Kents Bank. For example paragraph 4.12 states:
“…The second major allocation is a large site on Allithwaite Road west of Kents Bank.
This is the only large site available in Grange-over-Sands…”
5.7 This is nonsense. The site referred to is MN25M; it is west of Kents Bank; it will
significantly extend Kents Bank’s western boundary and will lead to coalescence
between Kents Bank and Allithwaite if it is developed (see Map 1 and section 6).
REFER TO MAP 1 & 2 IN ATTACHED DOCUMENT
5.8 SLDC’s Land Allocation DPD gives Kents Bank similar problems with its Grange-over-
Sands boundaries; the green spaces between Grange-over-Sands and Kents Bank have
been gradually eroded over the years. If more green spaces between the two
communities are developed it will be the ‘death knell’ of Kents Bank as a separate
community (see Map 2)
5.9 It is clear from Map 2 that building on sites R110 (Trickett’s field) and R449/R74 will
erode the sense of separation between Grange-over-Sands and Kents Bank when
driving on the main road, the B5227 and that they will increase coalescence between
Grange-over-Sands and Kents Bank.
5.10 The Grange-over-Sands Regeneration Study 2007 considered site R110 (Trickett’s
field). They concluded that it should not be developed because:
“…loss of open views from street is negative…”
5.11 R449/R74 was not considered by the Grange-over-Sands Regeneration Study 2007 and its importance as a green field site has not been independently assessed. It is clear from Map 2 that development of these two sites will increase coalescence between Grangeover-Sands and Kents Bank. SLDC has provided no objective evidence to support the development of either of these green field sites.
5.12 The only green field site in Kents Bank that was considered by the Grange-over-Sands
Regeneration Study 2007 was site R89 (the Carter Road site, Berry Bank, Map 1 and
Map 2) and the report did not recommend development of R89 because of:
“…the loss of open area will be an issue…” and they concluded that
“…that residential development of the Allithwaite Road/Carter Road site is likely to be
controversial because of the ‘green field’ nature of the site…”
5.13 None of the development sites proposed for Kents Bank (Map 1), except R89, were
considered by the Grange-over-Sands Regeneration Study 2007; they have not been
independently assessed before inclusion in SLDC’s Land Allocation DPD.
SEE TABLE 4 IN ATTACHED DOCUMENT
5.14 Table 4 clearly shows that a disproportionate amount of the unsustainable housing
allocation for Grange-over-Sands has been allocated to Kents Bank (58%)
5.15 The proposed development will increase the size of Kents Bank by 40% and extend its
boundaries towards Allithwaite causing coalescence between Kents Bank and
Allithwaite; SLDC have provided no objective evidence to justify increasing the size of
Kents Bank on this scale.
5.16 All the proposed housing development sites in Kents Bank have been allocated to
desirable green field sites except for Guides Lot (17 dwellings plus employment units)
but even this site includes a small additional green field and the site is adjacent to land
on Wart Barrow that is covered by a Limestone Pavement Order.
5.17 The proposed site MN25M is particularly contentious (see section 6).
5.18 Development of all the proposed sites near Risedale Hill and in Kents Bank will have an adverse effect on local drainage in areas that are already prone to flooding after heavy
rainfall eg Allithwaite Road beyond the top of Risedale Hill, Greaves Wood Road
(Bridleway) and Kirkhead Road.
5.19 The SLDC’s Land Allocation DPD has not taken account of problems highlighted by
Kents Bank residents in the 2011 consultation exercises. For example response forms
that I submitted for sites: MN25M, R672, 350M, R79#, R82#/R347# (see Appendices 3
to 7).
5.20 Many other residents also highlighted significant problems associated with the proposed land allocations for Kents Bank. All appear to have been ignored and lumped together in groups with a comment such as ‘noted’ beside them (see section 8). Why?
Section 5: Kents Bank as a separate community;
summary of main conclusions
- Kents Bank has been a separate community since Mediaeval times.
- SLDC have provided no clear evidence to justify increasing the size of Kents
Bank by 40%.
- SLDC have provided no clear evidence to justify sanctioning developments
that will increase coalescence between Grange-over-Sands and Kents Bank.
- SLDC have provided no clear evidence to justify sanctioning developments
that will increase coalescence between Kents Bank and Allithwaite.
- The local road system, utilities and community support systems are already
inadequate; they are not robust enough to support 298 more households in
Kents Bank.
6 Does SLDC’s Land Allocation Document protect against coalescence
between Kents Bank and Allithwaite?
6.1 To be sound SLDC need to show that they have considered potential coalescence
problems between communities. SLDC’s Core Strategy states:
CS1.2 states: “…Exceptionally, new development will be permitted in the open
countryside where it has an essential requirement for a rural location, is needed to
sustain existing businesses, provides for exceptional needs for affordable housing…”
6.2 According to SLDC’s Land Allocation DPD policy Green Gap Policy LA1.9 provides:
“…A framework for maintaining the separate identities of communities by maintaining
visual and functional separation…”
The green gap between Grange-over-Sands (not Kents Bank!) and Allithwaite is
identified as one of these important green gaps (see Map 1 and Map 3). Therefore, how
can they justify building on the site south of Allithwaite Road between Kents Bank and
Allithwaite ( MN25M)without clear objective evidence that there is a genuine need for
such development?
6.3 When SLDC prepared maps in support of their Land Allocation DPD the maps were split between Allithwaite and Kents Bank so that the dramatic reduction in the green gap
between Kents Bank and Allithwaite was not immediately obvious.
6.4 The impact of the proposed development sites for Kents Bank on coalescence between
Kents Bank and Allithwaite is clearly shown on Map 1 (section 5.7) and Map 3.
SEE MAP ON ATTACHED DOCUMENT
6.5 Map 3 clearly illustrates the importance of the triangular piece of land as a green gap
between Kents Bank and Allithwaite. It also demonstrates SLDC’s poor understanding of
the boundaries between Kents Bank and Allithwaite. Currently there is only minimal
coalescence between Kents Bank and Allithwaite about a third of the way down
Kirkhead Road (see Map 3). Coalescence between the two communities will be
considerably increased if SLDC’s development proposals west of Kents Bank and south
of Allithwaite are permitted (see Map 1, section 5.7)
6.6 Appendix 5 of the Grange Fact File states:
“…Coalescence has already taken place to some degree as Kentsford Road joins Kents
Bank/Grange to the SE corner of Allithwaite…
6.7 This is nonsense! Kirkhead Road joins the south east corner of Allithwaite and the
houses at the top of Kirkhead Road are in Allithwaite (see Map 3, section 5.7). Kentsford
Road is adjacent to the railway and links Kirkhead Road and Carter; it does not form a
junction with Allithwaite Road.
6.8 The minimal coalescence between Kents Bank and Allithwaite on Kirkhead Road at
Laneside Farm is due to ribbon development in the 1930s (see Map 3, section 5.7).
6.9 The value of MN25N (the large site south of Allithwaite Road) as an important green gap
has never been independently assessed. It was not included in the Grange-over-Sands
Regenertion Study 2007 (which is supposed to have informed SLDC’s proposals for this
area) and Berry Bank (which was included was ruled out because “…loss of open area
will be an issue…” (see Map 1, section 5.7)
6.10 During the original consultation exercise SLDC was proposing an inappropriate
development of 120 residential units, plus employment units for MN25M. In spite of
widespread opposition proposals in the SLDC Land Allocation DPD nearly doubled the
number of dwellings for this site from 120 to 202 and had retained the employment units
with no objective evidence to support these proposals.
6.11 If MN25M is developed it will reduce the green gap between the communities of Kents
Bank and Allithwaite to 220 metres (site MN25M and R672) even though Section 4.22
of the SLDC Land Allocation (DPD) 2012 highlights: “…Key issues affecting
development in Allithwaite…The need to avoid coalescence with Kents Bank/Grange…”
How can SLDC justify their claim that a 220 metre gap is sufficient to avoid coalescence
between these two communities?
6.12 A significant number of local residents raised concerns about coalescence between
Kents Bank and Allithwaite during the 2011 consultation period their comments were
responded to with phrases such as “…Disagree, no proposed change it is considered
that the land does not perform a visual or functional separation and therefore does not
warrant green gap designation…” This is an outrageous description of a delightful
undulating green field site with wonderful views of Morecambe Bay that forms an
important green gap between the communities of Kents Bank and Allithwaite (see
Pictures 1 to 4).
6.13 Nor does it follow recommendations in the Grange-over-Sands Regeneration Study
2007 which stated that it was important to:
“…protect the network of green spaces and important environmental characteristics of
the town and its setting…” and
“…give priority to the use of previously developed land for development and focus on
renovation rather than demolition and new build and minimise the impact on the
environment and improve biodiversity…”
6.14 It may be significant that the land owners and developers are keen to develop this site.
On a clear day it has magnificent views of Morecambe Bay to the south and of Kirkhead
Tower to the southwest (see pictures in Table 4 below).
6.15 The land owners are so keen to see this MN25M developed that they appointed Land
Agents to liaise with SLDC Planning Department before the 2011 consultation exercise.
SEE PICTURES ON ATTACHED DOCUMENT
6.16 The complex topography of site MN25M (see Map 3) also means that drainage problems in Kents Bank will be exacerbated; a major development is likely to cause flooding in the troughs of natural undulations, as well as lower down, in southern areas of Kents Bank.
6.17 Kirkhead Road already becomes a stream bed during heavy rain; the southern end of
Greaves Wood bridleway floods during heavy rain.
6.18 Site MN25M is also an important local area for absorbing water runoff; the local drainage system does not have any ‘spare’ capacity and would need major capital investment to cope with a large-scale building development; there is no provision for this in the proposed SLDC’s land Allocation DPD.
6.19 Even a small industrial estate on this Greenfield site would have an adverse impact on
Kents Bank village, local wildlife and tourism potential.
6.20 It is inappropriate to encourage industrial development on a rural site that has been
farmed for centuries. Farming is an important local industry and part of the vernacular
landscape; this local industry should be retained for area MN25M to encourage a local
sustainable food supply and tourism.
6.21 Grange-over-Sands and the surrounding areas depend on tourism and farming;
changing the character of Kents Bank, in the way proposed, will have an adverse impact
on the tourism potential of Kents Bank.
6.22 Site MN25M is an open area that enhances the view east from Kirkhead Tower (an
ancient monument; see Picture 4) towards Grange-over-Sands; a view much admired by
visitors to the area.
6.23 MN25N is also an important wildlife corridor between Kirkhead, Greaves Wood and Wart Barrow that are all covered by Limestone Protection Orders; buzzards, kestrels and
sparrow hawks regularly hunt across this land and the woodland in the centre of the site
is a wildlife refuge.
6.24 SLDC’s response to all these adverse effects has been to state that a Development Brief will be prepared to guide development of this site even though they have not provided
clear objective evidence to show that development of this desirable and important green
field site is justified. A Development Brief will not solve the problems outlined above.
6.25 During the last 25 years SLDC have permitted:
i. Extensive infilling of green field sites in the Risedale Hill and Cardronna Road areas
of Kents Bank.
ii. The extension Kents Bank’s boundary westwards towards Allithwaite with a large
development north of Priory Lane.
iii. Extensive infilling along Priory Lane.
iv. Extensive infilling in the grounds of Kilmidyke House and Kentsford Road House.
v. Conversion of large Victorian buildings in the Kents Bank Conservation Area to
apartment blocks eg Kilmidyke House, Kentsford House, Kents Bank House and the
Kents Bank Hotel.
6.26 SLDC’s Land Allocation DPD has not justified perpetuating this policy of development
creep along the Cumbrian coast. It is time to call a halt to ensure that the communities of
Kents Bank and Allithwaite retain their integrity and do not become part of a coastal
urban sprawl that destroys the unique characteristics of Grange-over-Sands and its
surrounding area.
6.27 SLDC have provided no objective evidence to justify the need to build an additional 202
dwellings plus an unspecified number of employment units on the important green field
site between Kents Bank and Allithwaite.
Section 6: Coalescence between Kents Bank and Allithwaite;
summary of main conclusions
- SLDC have not justified reducing the boundary between Kents Bank and
Allithwaite to 220 metres.
- Development of sites MN25M and R672 will extend the boundaries of Kents
Bank towards Allithwaite; both will encroach onto open fell pastures that are
an important back-drop to Grange-over-Sands and district.
- SLDC has provided no clear evidence to justify building on these important
green field site between Kents Bank and Allithwaite.
- SLDC have not taken account of the impact of their land development
proposals on the natural drainage problems in Kents Bank.
- Such intensive development will disrupt an important wildlife corridor linking
Kirkhead, Greaves Wood and Wart Barrow; all areas of land that are covered
by Limestone Pavement Orders.
- A development Brief for MN25M will not be able to solve the fundamental
problem of coalescence between Kents Bank and Allithwaite caused by
development of this site.
- SLDC has a duty to ensure that the communities of Kents Bank and
Allithwaite retain their integrity and do not become part of a coastal urban
sprawl that destroys the unique characteristics of Grange-over-Sands and its
surrounding area.
7 Does SLDC’s Land Allocation Document make adequate provision for
capital expenditure to upgrade local roads?
7.1 Allithwaite Road (B5277) is already inadequate for the amount of traffic regularly
travelling between Grange-over-Sands, Allithwaite, Flookburgh, Holker Hall, Kendal,
Lancaster and the M6.
7.2 The traffic problem is exacerbated when regular events such as Cartmel Races and
the Holker Garden Festival attract large crowds.
7.3 The stretch of Allithwaite Road between Kents Bank and Allithwaite from the top of
Risedale Hill is a fast stretch of undulating road that poses sight line problems for
drivers (see picture 3, section 6.15).
7.4 Developers would be forced to create new roads for development area MN25M linking
onto Allithwaite Road; this would increase traffic hazards on Allithwaite Road, or, lead
to the creation of an intrusive roundabout system that would destroy the rural nature
of this road and area
7.5 Greaves Wood Road bridleway forms the eastern, and southern, boundaries of
MN25M; it could not be used as access to MN25M development area because of a)
the Protected Limestone Pavement in Greaves Wood and b) it is a popular pedestrian
route for local residents, especially dog walkers (see Map 1, section 5.7 and Map 3,
section 6.4).
7.6 Access from Kirkhead Road to the MN25M development area is not practical; there
are no suitable gaps between the houses whose back gardens form the western
boundary of MN25M.
7.7 Industrial development and 202 residential units will generate a large amount of extra
traffic in Kents Bank that will all need to drive through Grange-over-Sands to reach the
A590 for access to Kendal, Lancaster and the M6; the local road system is not
suitable for this.
7.8 Local roads are not adequate to accommodate service vehicles for industrial
development.
SEE PICTURES IN ATTACHED DOCUMENT
7.9 SLDC are also proposing to build dwellings on the land behind the lorry on Allithwaite
Road (picture 6) and on the left hand side of Allithwaite Road beyond the junction of
Allithwaite Road with Jack Hill (junction to the left of Kirkhead Road; picture 6); access
to both these sites is constrained by their location and will cause road safety
problems.
7.10 Picture 5 clearly shows that it is not possible to widen or straighten Risedale Hill
without major road works involving compulsory purchase orders, demolition of walls
and completely altering the character of this part of Kents Bank and that the road is
not suitable for large volumes of traffic.
7.11 Traffic from three other nearby proposed residential developments in Kents Bank,
R672M: 36 residential units & R89: 45 residential units, R350M: 17 houses, also link
to Allithwaite Road, near the top of Risedale Hill therefore they should also be taken
into account when undertaking an area traffic impact study (see Map 1, section 5.7);
as should traffic generated by all residential and employment developments west of
Risedale Hill in Allithwaite and Flookburgh.
7.12 Once the traffic has negotiated Risedale Hill it then has to negotiate Main Street hill in
Grange-over-Sands another bottleneck that is often made worse by delivery vehicles
for the local shops because none of the shops on this part of Main Street have rear
access,
7.13 The local roads are in a poor state of repair and are not suitable for this level of traffic
increase.
7.14 SLDC have made no provision for improving these roads and have not justified a
need for developments that will make the traffic conditions considerably worse and
deter tourists.
7.15 There is no viable route for a Grange-over-Sands by-pass. A new trunk road to the
A590 would have to be routed across rough pastureland to the north of Grange-over-
Sands and would impinge on classic views of Cartmel and Cartmel Priory.
7.16 Car parking in Grange-over-Sands is already inadequate for local residents shopping
and tourists and again, no provision has been made in SLDC’s Land Allocation DPD
to improve local car parking facilities.
Section 7: Inadequate local roads in Grange-over-Sands and District;
summary of main conclusions
- The roads in Grange-over-Sands and district are already inadequate for the
traffic that they carry.
- There are two major bottlenecks: Risedale Hill and Main Street Hill that
cannot be widened due to their location.
- It would be expensive and difficult to agree a route for a new trunk road to the
A590 that by-passed Grange-over-Sands.
- SLDC have not made any provision to upgrade roads in Grange-over-Sands
and district.
- SLDC have not provided objective evidence to justify proposing large
development to the west of Grange-over-Sands given the already inadequate
road system.
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
I do not support SLDC’s Land Allocation DPD
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
I wish to take part in the oral examination because SLDC have not made an adequate response to significant planning concerns, raised by local residents, during earlier consultation phases, particularly those relating to:
1. ‘Housing need’ in the Grange-over-Sands area.
2. Proposed green field site land allocations for the Grange-over-Sands area.
3. The adverse impact of the proposed developments on tourism, the life-blood of Grange-over-Sands and the Cartmel Peninsula.
4. The inadequate road system that links Grange-over-Sands to other SLDC Service Centres.
In addition, SLDC have not provided objective evidence that justifies their classification of Grange-over-Sands as an SLDC Key Service Centre. Grange-over-Sands does not meet SLDC’s Core Strategy Document definition of Key Service Centre: it does not have a secondary school and it is not directly linked to other SLDC Service Centres by a main trunk road.
Nor does the SLDC Land Allocation DPD take account of local residents’ wishes about how their community should be developed, or the views of Grange-over-Sands Town Council.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
488. Mrs Valerie Kennedy (Individual) : 16 May 2012 12:37:00
A typed or handwritten document was submitted. This has been scanned and can be downloaded below:
Policy/Site No.
LA1.3 Housing Allocations - RN79#-mod ALLITHWAITE LAND NORTH OF JACK HILL
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
1. SLDC should not include Grange-over-Sands as one of its Key Service Centres because it does not meet the criteria in CS1.2 The development strategy for Principal Service Centres, Key Service Centres and Local Service Centres. This would mean that the number of proposed developments in Grange-over-Sands and district should be reduced and all proposed development sites should be reassessed. Development of brown field sites, such as Berners, should be prioritised and SLDC should take account of the views of local residents and Grange-over-Sands Town Council.
2. SLDC have not followed Government guidance about the use and interpretation of household surveys. They have not provided objective evidence to justify ‘housing need for Grange-over-Sands and District.
3. SLDC should be required to produce objective evidence to justify their plans to allow Grange-over-Sands to develop into a coastal urban sprawl incorporating Kents Bank.
4. SLDC should be required to remove sites MN25N, R672 and R79# from their Land Development DPD because development of these sites will lead to coalescence between the communities of Kents Bank and Allithwaite.
5. SLDC should be required to remove sites R449, R74 and R110 from their Land Development DPD because development of these sites will lead to further coalescence between the communities of Grange-over-Sands and Kents Bank.
6. SLDC should be required to produce clear evidence about how their proposed developments will enhance tourism in Grange-over-Sands and district.
7. SLDC should be required to explain why they have ignored recommendations made about green field sites and tourism in the Grange-over-Sands Regeneration Study (Douglas Wheeler Associates, November 2007), that they claim has informed SLDC's Core Strategy.
8. SLDC should be required to provide objective evidence that the local roads are adequate to support the proposed increase in population and traffic in Grange-over-Sands especially for known bottle-necks in Main Street and on Risedale Hill.
9. SLDC should not allow any development on prime green field land between Kents Bank and Allithwaite because it will lead to coalescence between these two separate communities.
1.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
I do not support SLDC’s Land Allocations DPD because it is based on spurious ‘housing need’ targets and has unnecessarily ear-marked important greenfield sites for development.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The following text of response 11298 is taken from sections 5 and 7 of my SLDC LDF consultation submission entitled: ‘Soundness’ response to SLDC’s Land Allocation Development Plan (DPD, Jan 2012) focussing on SLDC’s ‘housing need’ predictions & SLDC’s vision for Grange-over-Sands and District.
My report included photographs, maps and tables to support comments that were made in the report. I have requested that this report be made available to the Planning Inspector.
The sections featured in response 11298 are:
5 . Does SLDC’s Land Allocation Document attempt to ‘air-brush’ Kents Bank out of existence as a separate community?
7. Does SLDC's Land Allocation Document make adequate provision for capital expenditure to upgrade local roads?
Photographs, tables and maps that were included with the text in the report have been stored elsewhere, formatting that clarified the text has been removed and spurious question marks have appeared that are not in the original text
[The full report is attached]
5 Does SLDC’s Land Allocation Document attempt to ‘air-brush’ Kents
Bank out of existence as a separate community?
5.1 SLDC’s Planning Department currently treats Kents Bank as a suburb of Grange-over-
Sands even though Kents Bank can trace its existence back to Mediaeval times when
monks from Cartmel lodged at Abbot Hall, Kents Bank, when ‘crossing the sands’
whereas Grange-over-Sands developed as a tourist resort in Victorian times after the
‘coming of the railway.
5.2 Kents Bank has its own station, Post Office, shop, Art Gallery, Abbot Hall Hotel and
Guide’s Farm. The post of Guide dates back to at least 1501 according to records of
Cartmel Priory.
5.3 During the past 20-25 years SLDC’s Planning Department have permitted infilling
development on many Kents Bank green field sites; they have allowed infilling on green
gaps between Kents Bank and Grange-over-Sands on the east, and, Kents Bank and
Allithwaite on the west.
5.4 Why is SLDC treating Kents Bank as a suburb of Grange-over-Sands? Residents of
Kents Bank do not support this view; they value their community and do not want to see
Kents Bank absorbed into Grange-over-Sands or Allithwaite. Kents Bank was
established hundreds of years before Grange-over-Sands.
5.5 This unsound approach has been perpetuated in SLDC’s Land Allocation DPD. Section
4.2 of the document is headed Grange-over-Sands and Kents Bank whereas Allithwaite
is considered as a separate community.
5.6 Subsequent text in SLDC’s Land Allocation DPD uses the name Grange-over-Sands
when it is actually referring to Kents Bank. For example paragraph 4.12 states:
“…The second major allocation is a large site on Allithwaite Road west of Kents Bank.
This is the only large site available in Grange-over-Sands…”
5.7 This is nonsense. The site referred to is MN25M; it is west of Kents Bank; it will
significantly extend Kents Bank’s western boundary and will lead to coalescence
between Kents Bank and Allithwaite if it is developed (see Map 1 and section 6).
REFER TO MAP 1 & 2 IN ATTACHED DOCUMENT
5.8 SLDC’s Land Allocation DPD gives Kents Bank similar problems with its Grange-over-
Sands boundaries; the green spaces between Grange-over-Sands and Kents Bank have
been gradually eroded over the years. If more green spaces between the two
communities are developed it will be the ‘death knell’ of Kents Bank as a separate
community (see Map 2)
5.9 It is clear from Map 2 that building on sites R110 (Trickett’s field) and R449/R74 will
erode the sense of separation between Grange-over-Sands and Kents Bank when
driving on the main road, the B5227 and that they will increase coalescence between
Grange-over-Sands and Kents Bank.
5.10 The Grange-over-Sands Regeneration Study 2007 considered site R110 (Trickett’s
field). They concluded that it should not be developed because:
“…loss of open views from street is negative…”
5.11 R449/R74 was not considered by the Grange-over-Sands Regeneration Study 2007 and its importance as a green field site has not been independently assessed. It is clear from Map 2 that development of these two sites will increase coalescence between Grangeover-Sands and Kents Bank. SLDC has provided no objective evidence to support the development of either of these green field sites.
5.12 The only green field site in Kents Bank that was considered by the Grange-over-Sands
Regeneration Study 2007 was site R89 (the Carter Road site, Berry Bank, Map 1 and
Map 2) and the report did not recommend development of R89 because of:
“…the loss of open area will be an issue…” and they concluded that
“…that residential development of the Allithwaite Road/Carter Road site is likely to be
controversial because of the ‘green field’ nature of the site…”
5.13 None of the development sites proposed for Kents Bank (Map 1), except R89, were
considered by the Grange-over-Sands Regeneration Study 2007; they have not been
independently assessed before inclusion in SLDC’s Land Allocation DPD.
SEE TABLE 4 IN ATTACHED DOCUMENT
5.14 Table 4 clearly shows that a disproportionate amount of the unsustainable housing
allocation for Grange-over-Sands has been allocated to Kents Bank (58%)
5.15 The proposed development will increase the size of Kents Bank by 40% and extend its
boundaries towards Allithwaite causing coalescence between Kents Bank and
Allithwaite; SLDC have provided no objective evidence to justify increasing the size of
Kents Bank on this scale.
5.16 All the proposed housing development sites in Kents Bank have been allocated to
desirable green field sites except for Guides Lot (17 dwellings plus employment units)
but even this site includes a small additional green field and the site is adjacent to land
on Wart Barrow that is covered by a Limestone Pavement Order.
5.17 The proposed site MN25M is particularly contentious (see section 6).
5.18 Development of all the proposed sites near Risedale Hill and in Kents Bank will have an adverse effect on local drainage in areas that are already prone to flooding after heavy
rainfall eg Allithwaite Road beyond the top of Risedale Hill, Greaves Wood Road
(Bridleway) and Kirkhead Road.
5.19 The SLDC’s Land Allocation DPD has not taken account of problems highlighted by
Kents Bank residents in the 2011 consultation exercises. For example response forms
that I submitted for sites: MN25M, R672, 350M, R79#, R82#/R347# (see Appendices 3
to 7).
5.20 Many other residents also highlighted significant problems associated with the proposed land allocations for Kents Bank. All appear to have been ignored and lumped together in groups with a comment such as ‘noted’ beside them (see section 8). Why?
Section 5: Kents Bank as a separate community;
summary of main conclusions
- Kents Bank has been a separate community since Mediaeval times.
- SLDC have provided no clear evidence to justify increasing the size of Kents
Bank by 40%.
- SLDC have provided no clear evidence to justify sanctioning developments
that will increase coalescence between Grange-over-Sands and Kents Bank.
- SLDC have provided no clear evidence to justify sanctioning developments
that will increase coalescence between Kents Bank and Allithwaite.
- The local road system, utilities and community support systems are already
inadequate; they are not robust enough to support 298 more households in
Kents Bank.
7 Does SLDC’s Land Allocation Document make adequate provision for
capital expenditure to upgrade local roads?
7.1 Allithwaite Road (B5277) is already inadequate for the amount of traffic regularly
travelling between Grange-over-Sands, Allithwaite, Flookburgh, Holker Hall, Kendal,
Lancaster and the M6.
7.2 The traffic problem is exacerbated when regular events such as Cartmel Races and
the Holker Garden Festival attract large crowds.
7.3 The stretch of Allithwaite Road between Kents Bank and Allithwaite from the top of
Risedale Hill is a fast stretch of undulating road that poses sight line problems for
drivers (see picture 3, section 6.15).
7.4 Developers would be forced to create new roads for development area MN25M linking
onto Allithwaite Road; this would increase traffic hazards on Allithwaite Road, or, lead
to the creation of an intrusive roundabout system that would destroy the rural nature
of this road and area
7.5 Greaves Wood Road bridleway forms the eastern, and southern, boundaries of
MN25M; it could not be used as access to MN25M development area because of a)
the Protected Limestone Pavement in Greaves Wood and b) it is a popular pedestrian
route for local residents, especially dog walkers (see Map 1, section 5.7 and Map 3,
section 6.4).
7.6 Access from Kirkhead Road to the MN25M development area is not practical; there
are no suitable gaps between the houses whose back gardens form the western
boundary of MN25M.
7.7 Industrial development and 202 residential units will generate a large amount of extra
traffic in Kents Bank that will all need to drive through Grange-over-Sands to reach the
A590 for access to Kendal, Lancaster and the M6; the local road system is not
suitable for this.
7.8 Local roads are not adequate to accommodate service vehicles for industrial
development.
SEE PICTURES IN ATTACHED DOCUMENT
7.9 SLDC are also proposing to build dwellings on the land behind the lorry on Allithwaite
Road (picture 6) and on the left hand side of Allithwaite Road beyond the junction of
Allithwaite Road with Jack Hill (junction to the left of Kirkhead Road; picture 6); access
to both these sites is constrained by their location and will cause road safety
problems.
7.10 Picture 5 clearly shows that it is not possible to widen or straighten Risedale Hill
without major road works involving compulsory purchase orders, demolition of walls
and completely altering the character of this part of Kents Bank and that the road is
not suitable for large volumes of traffic.
7.11 Traffic from three other nearby proposed residential developments in Kents Bank,
R672M: 36 residential units & R89: 45 residential units, R350M: 17 houses, also link
to Allithwaite Road, near the top of Risedale Hill therefore they should also be taken
into account when undertaking an area traffic impact study (see Map 1, section 5.7);
as should traffic generated by all residential and employment developments west of
Risedale Hill in Allithwaite and Flookburgh.
7.12 Once the traffic has negotiated Risedale Hill it then has to negotiate Main Street hill in
Grange-over-Sands another bottleneck that is often made worse by delivery vehicles
for the local shops because none of the shops on this part of Main Street have rear
access,
7.13 The local roads are in a poor state of repair and are not suitable for this level of traffic
increase.
7.14 SLDC have made no provision for improving these roads and have not justified a
need for developments that will make the traffic conditions considerably worse and
deter tourists.
7.15 There is no viable route for a Grange-over-Sands by-pass. A new trunk road to the
A590 would have to be routed across rough pastureland to the north of Grange-over-
Sands and would impinge on classic views of Cartmel and Cartmel Priory.
7.16 Car parking in Grange-over-Sands is already inadequate for local residents shopping
and tourists and again, no provision has been made in SLDC’s Land Allocation DPD
to improve local car parking facilities.
Section 7: Inadequate local roads in Grange-over-Sands and District;
summary of main conclusions
- The roads in Grange-over-Sands and district are already inadequate for the
traffic that they carry.
- There are two major bottlenecks: Risedale Hill and Main Street Hill that
cannot be widened due to their location.
- It would be expensive and difficult to agree a route for a new trunk road to the
A590 that by-passed Grange-over-Sands.
- SLDC have not made any provision to upgrade roads in Grange-over-Sands
and district.
- SLDC have not provided objective evidence to justify proposing large
development to the west of Grange-over-Sands given the already inadequate
road system.
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
I do not support SLDC’s Land Allocation DPD
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
I wish to take part in the oral examination because SLDC have not made an adequate response to significant planning concerns, raised by local residents, during earlier consultation phases, particularly those relating to:
1. ‘Housing need’ in the Grange-over-Sands area.
2. Proposed green field site land allocations for the Grange-over-Sands area.
3. The adverse impact of the proposed developments on tourism, the life-blood of Grange-over-Sands and the Cartmel Peninsula.
4. The inadequate road system that links Grange-over-Sands to other SLDC Service Centres.
In addition, SLDC have not provided objective evidence that justifies their classification of Grange-over-Sands as an SLDC Key Service Centre. Grange-over-Sands does not meet SLDC’s Core Strategy Document definition of Key Service Centre: it does not have a secondary school and it is not directly linked to other SLDC Service Centres by a main trunk road.
Nor does the SLDC Land Allocation DPD take account of local residents’ wishes about how their community should be developed, or the views of Grange-over-Sands Town Council.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
489. Mrs Valerie Kennedy (Individual) : 16 May 2012 12:44:00
A typed or handwritten document was submitted. This has been scanned and can be downloaded below:
Policy/Site No.
LA1.3 Housing Allocations - R347# ALLITHWAITE LAND REAR OF BANKFIELD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
1. SLDC should not include Grange-over-Sands as one of its Key Service Centres because it does not meet the criteria in CS1.2 The development strategy for Principal Service Centres, Key Service Centres and Local Service Centres. This would mean that the number of proposed developments in Grange-over-Sands and district should be reduced and all proposed development sites should be reassessed. Development of brown field sites, such as Berners, should be prioritised and SLDC should take account of the views of local residents and Grange-over-Sands Town Council.
2. SLDC have not followed Government guidance about the use and interpretation of household surveys. They have not provided objective evidence to justify ‘housing need for Grange-over-Sands and District.
3. SLDC should be required to produce objective evidence to justify their plans to allow Grange-over-Sands to develop into a coastal urban sprawl incorporating Kents Bank.
4. SLDC should be required to remove sites MN25N, R672 and R79# from their Land Development DPD because development of these sites will lead to coalescence between the communities of Kents Bank and Allithwaite.
5. SLDC should be required to remove sites R449, R74 and R110 from their Land Development DPD because development of these sites will lead to further coalescence between the communities of Grange-over-Sands and Kents Bank.
6. SLDC should be required to produce clear evidence about how their proposed developments will enhance tourism in Grange-over-Sands and district.
7. SLDC should be required to explain why they have ignored recommendations made about green field sites and tourism in the Grange-over-Sands Regeneration Study (Douglas Wheeler Associates, November 2007), that they claim has informed SLDC's Core Strategy.
8. SLDC should be required to provide objective evidence that the local roads are adequate to support the proposed increase in population and traffic in Grange-over-Sands especially for known bottle-necks in Main Street and on Risedale Hill.
9. SLDC should not allow any development on prime green field land between Kents Bank and Allithwaite because it will lead to coalescence between these two separate communities.
1.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
I do not support SLDC’s Land Allocations DPD because it is based on spurious ‘housing need’ targets and has unnecessarily ear-marked important greenfield sites for development.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The following text of response 11292 is taken from sections 4, 5, 6 and 7 of my SLDC LDF consultation submission entitled: ‘Soundness’ response to SLDC’s Land Allocation Development Plan (DPD, Jan 2012) focussing on SLDC’s ‘housing need’ predictions & SLDC’s vision for Grange-over-Sands and District.
My report included photographs, maps and tables to support comments that were made in the report. I have requested that this report be made available to the Planning Inspector.
The sections featured in response 11292 are:
5 . Does SLDC’s Land Allocation Document attempt to ‘air-brush’ Kents Bank out of existence as a separate community?
Photographs, tables and maps that were included with the text in the report have been stored elsewhere, formatting that clarified the text has been removed and spurious question marks have appeared that are not in the original text.
[The full report is attached]
5 Does SLDC’s Land Allocation Document attempt to ‘air-brush’ Kents
Bank out of existence as a separate community?
5.1 SLDC’s Planning Department currently treats Kents Bank as a suburb of Grange-over-
Sands even though Kents Bank can trace its existence back to Mediaeval times when
monks from Cartmel lodged at Abbot Hall, Kents Bank, when ‘crossing the sands’
whereas Grange-over-Sands developed as a tourist resort in Victorian times after the
‘coming of the railway.
5.2 Kents Bank has its own station, Post Office, shop, Art Gallery, Abbot Hall Hotel and
Guide’s Farm. The post of Guide dates back to at least 1501 according to records of
Cartmel Priory.
5.3 During the past 20-25 years SLDC’s Planning Department have permitted infilling
development on many Kents Bank green field sites; they have allowed infilling on green
gaps between Kents Bank and Grange-over-Sands on the east, and, Kents Bank and
Allithwaite on the west.
5.4 Why is SLDC treating Kents Bank as a suburb of Grange-over-Sands? Residents of
Kents Bank do not support this view; they value their community and do not want to see
Kents Bank absorbed into Grange-over-Sands or Allithwaite. Kents Bank was
established hundreds of years before Grange-over-Sands.
5.5 This unsound approach has been perpetuated in SLDC’s Land Allocation DPD. Section
4.2 of the document is headed Grange-over-Sands and Kents Bank whereas Allithwaite
is considered as a separate community.
5.6 Subsequent text in SLDC’s Land Allocation DPD uses the name Grange-over-Sands
when it is actually referring to Kents Bank. For example paragraph 4.12 states:
“…The second major allocation is a large site on Allithwaite Road west of Kents Bank.
This is the only large site available in Grange-over-Sands…”
5.7 This is nonsense. The site referred to is MN25M; it is west of Kents Bank; it will
significantly extend Kents Bank’s western boundary and will lead to coalescence
between Kents Bank and Allithwaite if it is developed (see Map 1 and section 6).
REFER TO MAP 1 & 2 IN ATTACHED DOCUMENT
5.8 SLDC’s Land Allocation DPD gives Kents Bank similar problems with its Grange-over-
Sands boundaries; the green spaces between Grange-over-Sands and Kents Bank have
been gradually eroded over the years. If more green spaces between the two
communities are developed it will be the ‘death knell’ of Kents Bank as a separate
community (see Map 2)
5.9 It is clear from Map 2 that building on sites R110 (Trickett’s field) and R449/R74 will
erode the sense of separation between Grange-over-Sands and Kents Bank when
driving on the main road, the B5227 and that they will increase coalescence between
Grange-over-Sands and Kents Bank.
5.10 The Grange-over-Sands Regeneration Study 2007 considered site R110 (Trickett’s
field). They concluded that it should not be developed because:
“…loss of open views from street is negative…”
5.11 R449/R74 was not considered by the Grange-over-Sands Regeneration Study 2007 and its importance as a green field site has not been independently assessed. It is clear from Map 2 that development of these two sites will increase coalescence between Grangeover-Sands and Kents Bank. SLDC has provided no objective evidence to support the development of either of these green field sites.
5.12 The only green field site in Kents Bank that was considered by the Grange-over-Sands
Regeneration Study 2007 was site R89 (the Carter Road site, Berry Bank, Map 1 and
Map 2) and the report did not recommend development of R89 because of:
“…the loss of open area will be an issue…” and they concluded that
“…that residential development of the Allithwaite Road/Carter Road site is likely to be
controversial because of the ‘green field’ nature of the site…”
5.13 None of the development sites proposed for Kents Bank (Map 1), except R89, were
considered by the Grange-over-Sands Regeneration Study 2007; they have not been
independently assessed before inclusion in SLDC’s Land Allocation DPD.
SEE TABLE 4 IN ATTACHED DOCUMENT
5.14 Table 4 clearly shows that a disproportionate amount of the unsustainable housing
allocation for Grange-over-Sands has been allocated to Kents Bank (58%)
5.15 The proposed development will increase the size of Kents Bank by 40% and extend its
boundaries towards Allithwaite causing coalescence between Kents Bank and
Allithwaite; SLDC have provided no objective evidence to justify increasing the size of
Kents Bank on this scale.
5.16 All the proposed housing development sites in Kents Bank have been allocated to
desirable green field sites except for Guides Lot (17 dwellings plus employment units)
but even this site includes a small additional green field and the site is adjacent to land
on Wart Barrow that is covered by a Limestone Pavement Order.
5.17 The proposed site MN25M is particularly contentious (see section 6).
5.18 Development of all the proposed sites near Risedale Hill and in Kents Bank will have an adverse effect on local drainage in areas that are already prone to flooding after heavy
rainfall eg Allithwaite Road beyond the top of Risedale Hill, Greaves Wood Road
(Bridleway) and Kirkhead Road.
5.19 The SLDC’s Land Allocation DPD has not taken account of problems highlighted by
Kents Bank residents in the 2011 consultation exercises. For example response forms
that I submitted for sites: MN25M, R672, 350M, R79#, R82#/R347# (see Appendices 3
to 7).
5.20 Many other residents also highlighted significant problems associated with the proposed land allocations for Kents Bank. All appear to have been ignored and lumped together in groups with a comment such as ‘noted’ beside them (see section 8). Why?
Section 5: Kents Bank as a separate community;
summary of main conclusions
- Kents Bank has been a separate community since Mediaeval times.
- SLDC have provided no clear evidence to justify increasing the size of Kents
Bank by 40%.
- SLDC have provided no clear evidence to justify sanctioning developments
that will increase coalescence between Grange-over-Sands and Kents Bank.
- SLDC have provided no clear evidence to justify sanctioning developments
that will increase coalescence between Kents Bank and Allithwaite.
- The local road system, utilities and community support systems are already
inadequate; they are not robust enough to support 298 more households in
Kents Bank.
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
I do not support SLDC’s Land Allocation DPD
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
I wish to take part in the oral examination because SLDC have not made an adequate response to significant planning concerns, raised by local residents, during earlier consultation phases, particularly those relating to:
1. ‘Housing need’ in the Grange-over-Sands area.
2. Proposed green field site land allocations for the Grange-over-Sands area.
3. The adverse impact of the proposed developments on tourism, the life-blood of Grange-over-Sands and the Cartmel Peninsula.
4. The inadequate road system that links Grange-over-Sands to other SLDC Service Centres.
In addition, SLDC have not provided objective evidence that justifies their classification of Grange-over-Sands as an SLDC Key Service Centre. Grange-over-Sands does not meet SLDC’s Core Strategy Document definition of Key Service Centre: it does not have a secondary school and it is not directly linked to other SLDC Service Centres by a main trunk road.
Nor does the SLDC Land Allocation DPD take account of local residents’ wishes about how their community should be developed, or the views of Grange-over-Sands Town Council.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
490. Mrs Valerie Kennedy (Individual) : 16 May 2012 12:45:00
A typed or handwritten document was submitted. This has been scanned and can be downloaded below:
Policy/Site No.
LA1.3 Housing Allocations - RN265# ALLITHWAITE LAND WEST OF BRACKEN EDGE
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
1. SLDC should not include Grange-over-Sands as one of its Key Service Centres because it does not meet the criteria in CS1.2 The development strategy for Principal Service Centres, Key Service Centres and Local Service Centres. This would mean that the number of proposed developments in Grange-over-Sands and district should be reduced and all proposed development sites should be reassessed. Development of brown field sites, such as Berners, should be prioritised and SLDC should take account of the views of local residents and Grange-over-Sands Town Council.
2. SLDC have not followed Government guidance about the use and interpretation of household surveys. They have not provided objective evidence to justify ‘housing need for Grange-over-Sands and District.
3. SLDC should be required to produce objective evidence to justify their plans to allow Grange-over-Sands to develop into a coastal urban sprawl incorporating Kents Bank.
4. SLDC should be required to remove sites MN25N, R672 and R79# from their Land Development DPD because development of these sites will lead to coalescence between the communities of Kents Bank and Allithwaite.
5. SLDC should be required to remove sites R449, R74 and R110 from their Land Development DPD because development of these sites will lead to further coalescence between the communities of Grange-over-Sands and Kents Bank.
6. SLDC should be required to produce clear evidence about how their proposed developments will enhance tourism in Grange-over-Sands and district.
7. SLDC should be required to explain why they have ignored recommendations made about green field sites and tourism in the Grange-over-Sands Regeneration Study (Douglas Wheeler Associates, November 2007), that they claim has informed SLDC's Core Strategy.
8. SLDC should be required to provide objective evidence that the local roads are adequate to support the proposed increase in population and traffic in Grange-over-Sands especially for known bottle-necks in Main Street and on Risedale Hill.
9. SLDC should not allow any development on prime green field land between Kents Bank and Allithwaite because it will lead to coalescence between these two separate communities.
1.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
I do not support SLDC’s Land Allocations DPD because it is based on spurious ‘housing need’ targets and has unnecessarily ear-marked important greenfield sites for development.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The following text of response 11301 is taken from sections 5 of my SLDC LDF consultation submission entitled: ‘Soundness’ response to SLDC’s Land Allocation Development Plan (DPD, Jan 2012) focussing on SLDC’s ‘housing need’ predictions & SLDC’s vision for Grange-over-Sands and District.
My report included photographs, maps and tables to support comments that were made in the report. I have requested that this report be made available to the Planning Inspector.
The section featured in response 11301 is:
5 . Does SLDC’s Land Allocation Document attempt to ‘air-brush’ Kents Bank out of existence as a separate community?
Photographs, tables and maps that were included with the text in the report have been stored elsewhere, formatting that clarified the text has been removed and spurious question marks have appeared that are not in the original text
[The full report is attached]
5 Does SLDC’s Land Allocation Document attempt to ‘air-brush’ Kents
Bank out of existence as a separate community?
5.1 SLDC’s Planning Department currently treats Kents Bank as a suburb of Grange-over-
Sands even though Kents Bank can trace its existence back to Mediaeval times when
monks from Cartmel lodged at Abbot Hall, Kents Bank, when ‘crossing the sands’
whereas Grange-over-Sands developed as a tourist resort in Victorian times after the
‘coming of the railway.
5.2 Kents Bank has its own station, Post Office, shop, Art Gallery, Abbot Hall Hotel and
Guide’s Farm. The post of Guide dates back to at least 1501 according to records of
Cartmel Priory.
5.3 During the past 20-25 years SLDC’s Planning Department have permitted infilling
development on many Kents Bank green field sites; they have allowed infilling on green
gaps between Kents Bank and Grange-over-Sands on the east, and, Kents Bank and
Allithwaite on the west.
5.4 Why is SLDC treating Kents Bank as a suburb of Grange-over-Sands? Residents of
Kents Bank do not support this view; they value their community and do not want to see
Kents Bank absorbed into Grange-over-Sands or Allithwaite. Kents Bank was
established hundreds of years before Grange-over-Sands.
5.5 This unsound approach has been perpetuated in SLDC’s Land Allocation DPD. Section
4.2 of the document is headed Grange-over-Sands and Kents Bank whereas Allithwaite
is considered as a separate community.
5.6 Subsequent text in SLDC’s Land Allocation DPD uses the name Grange-over-Sands
when it is actually referring to Kents Bank. For example paragraph 4.12 states:
“…The second major allocation is a large site on Allithwaite Road west of Kents Bank.
This is the only large site available in Grange-over-Sands…”
5.7 This is nonsense. The site referred to is MN25M; it is west of Kents Bank; it will
significantly extend Kents Bank’s western boundary and will lead to coalescence
between Kents Bank and Allithwaite if it is developed (see Map 1 and section 6).
REFER TO MAP 1 & 2 IN ATTACHED DOCUMENT
5.8 SLDC’s Land Allocation DPD gives Kents Bank similar problems with its Grange-over-
Sands boundaries; the green spaces between Grange-over-Sands and Kents Bank have
been gradually eroded over the years. If more green spaces between the two
communities are developed it will be the ‘death knell’ of Kents Bank as a separate
community (see Map 2)
5.9 It is clear from Map 2 that building on sites R110 (Trickett’s field) and R449/R74 will
erode the sense of separation between Grange-over-Sands and Kents Bank when
driving on the main road, the B5227 and that they will increase coalescence between
Grange-over-Sands and Kents Bank.
5.10 The Grange-over-Sands Regeneration Study 2007 considered site R110 (Trickett’s
field). They concluded that it should not be developed because:
“…loss of open views from street is negative…”
5.11 R449/R74 was not considered by the Grange-over-Sands Regeneration Study 2007 and its importance as a green field site has not been independently assessed. It is clear from Map 2 that development of these two sites will increase coalescence between Grangeover-Sands and Kents Bank. SLDC has provided no objective evidence to support the development of either of these green field sites.
5.12 The only green field site in Kents Bank that was considered by the Grange-over-Sands
Regeneration Study 2007 was site R89 (the Carter Road site, Berry Bank, Map 1 and
Map 2) and the report did not recommend development of R89 because of:
“…the loss of open area will be an issue…” and they concluded that
“…that residential development of the Allithwaite Road/Carter Road site is likely to be
controversial because of the ‘green field’ nature of the site…”
5.13 None of the development sites proposed for Kents Bank (Map 1), except R89, were
considered by the Grange-over-Sands Regeneration Study 2007; they have not been
independently assessed before inclusion in SLDC’s Land Allocation DPD.
SEE TABLE 4 IN ATTACHED DOCUMENT
5.14 Table 4 clearly shows that a disproportionate amount of the unsustainable housing
allocation for Grange-over-Sands has been allocated to Kents Bank (58%)
5.15 The proposed development will increase the size of Kents Bank by 40% and extend its
boundaries towards Allithwaite causing coalescence between Kents Bank and
Allithwaite; SLDC have provided no objective evidence to justify increasing the size of
Kents Bank on this scale.
5.16 All the proposed housing development sites in Kents Bank have been allocated to
desirable green field sites except for Guides Lot (17 dwellings plus employment units)
but even this site includes a small additional green field and the site is adjacent to land
on Wart Barrow that is covered by a Limestone Pavement Order.
5.17 The proposed site MN25M is particularly contentious (see section 6).
5.18 Development of all the proposed sites near Risedale Hill and in Kents Bank will have an adverse effect on local drainage in areas that are already prone to flooding after heavy
rainfall eg Allithwaite Road beyond the top of Risedale Hill, Greaves Wood Road
(Bridleway) and Kirkhead Road.
5.19 The SLDC’s Land Allocation DPD has not taken account of problems highlighted by
Kents Bank residents in the 2011 consultation exercises. For example response forms
that I submitted for sites: MN25M, R672, 350M, R79#, R82#/R347# (see Appendices 3
to 7).
5.20 Many other residents also highlighted significant problems associated with the proposed land allocations for Kents Bank. All appear to have been ignored and lumped together in groups with a comment such as ‘noted’ beside them (see section 8). Why?
Section 5: Kents Bank as a separate community;
summary of main conclusions
- Kents Bank has been a separate community since Mediaeval times.
- SLDC have provided no clear evidence to justify increasing the size of Kents
Bank by 40%.
- SLDC have provided no clear evidence to justify sanctioning developments
that will increase coalescence between Grange-over-Sands and Kents Bank.
- SLDC have provided no clear evidence to justify sanctioning developments
that will increase coalescence between Kents Bank and Allithwaite.
- The local road system, utilities and community support systems are already
inadequate; they are not robust enough to support 298 more households in
Kents Bank.
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
I do not support SLDC’s Land Allocation DPD
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
I wish to take part in the oral examination because SLDC have not made an adequate response to significant planning concerns, raised by local residents, during earlier consultation phases, particularly those relating to:
1. ‘Housing need’ in the Grange-over-Sands area.
2. Proposed green field site land allocations for the Grange-over-Sands area.
3. The adverse impact of the proposed developments on tourism, the life-blood of Grange-over-Sands and the Cartmel Peninsula.
4. The inadequate road system that links Grange-over-Sands to other SLDC Service Centres.
In addition, SLDC have not provided objective evidence that justifies their classification of Grange-over-Sands as an SLDC Key Service Centre. Grange-over-Sands does not meet SLDC’s Core Strategy Document definition of Key Service Centre: it does not have a secondary school and it is not directly linked to other SLDC Service Centres by a main trunk road.
Nor does the SLDC Land Allocation DPD take account of local residents’ wishes about how their community should be developed, or the views of Grange-over-Sands Town Council.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
491. Mrs Valerie Kennedy (Individual) : 16 May 2012 12:47:00
A typed or handwritten document was submitted. This has been scanned and can be downloaded below:
Policy/Site No.
LA1.3 Housing Allocations - R110 GRANGE-OVER-SANDS SOUTH OF THORNFIELD ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
1. SLDC should not include Grange-over-Sands as one of its Key Service Centres because it does not meet the criteria in CS1.2 The development strategy for Principal Service Centres, Key Service Centres and Local Service Centres. This would mean that the number of proposed developments in Grange-over-Sands and district should be reduced and all proposed development sites should be reassessed. Development of brown field sites, such as Berners, should be prioritised and SLDC should take account of the views of local residents and Grange-over-Sands Town Council.
2. SLDC have not followed Government guidance about the use and interpretation of household surveys. They have not provided objective evidence to justify ‘housing need for Grange-over-Sands and District.
3. SLDC should be required to produce objective evidence to justify their plans to allow Grange-over-Sands to develop into a coastal urban sprawl incorporating Kents Bank.
4. SLDC should be required to remove sites MN25N, R672 and R79# from their Land Development DPD because development of these sites will lead to coalescence between the communities of Kents Bank and Allithwaite.
5. SLDC should be required to remove sites R449, R74 and R110 from their Land Development DPD because development of these sites will lead to further coalescence between the communities of Grange-over-Sands and Kents Bank.
6. SLDC should be required to produce clear evidence about how their proposed developments will enhance tourism in Grange-over-Sands and district.
7. SLDC should be required to explain why they have ignored recommendations made about green field sites and tourism in the Grange-over-Sands Regeneration Study (Douglas Wheeler Associates, November 2007), that they claim has informed SLDC's Core Strategy.
8. SLDC should be required to provide objective evidence that the local roads are adequate to support the proposed increase in population and traffic in Grange-over-Sands especially for known bottle-necks in Main Street and on Risedale Hill.
9. SLDC should not allow any development on prime green field land between Kents Bank and Allithwaite because it will lead to coalescence between these two separate communities.
1.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
I do not support SLDC’s Land Allocations DPD because it is based on spurious ‘housing need’ targets and has unnecessarily ear-marked important greenfield sites for development.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The following text of response 11292 is taken from sections 4, 5, 6 and 7 of my SLDC LDF consultation submission entitled: ‘Soundness’ response to SLDC’s Land Allocation Development Plan (DPD, Jan 2012) focussing on SLDC’s ‘housing need’ predictions & SLDC’s vision for Grange-over-Sands and District.
My report included photographs, maps and tables to support comments that were made in the report. I have requested that this report be made available to the Planning Inspector.
The sections featured in response 11292 are:
5 . Does SLDC’s Land Allocation Document attempt to ‘air-brush’ Kents Bank out of existence as a separate community?
Photographs, tables and maps that were included with the text in the report have been stored elsewhere, formatting that clarified the text has been removed and spurious question marks have appeared that are not in the original text.
[The full report is attached]
5 Does SLDC’s Land Allocation Document attempt to ‘air-brush’ Kents
Bank out of existence as a separate community?
5.1 SLDC’s Planning Department currently treats Kents Bank as a suburb of Grange-over-
Sands even though Kents Bank can trace its existence back to Mediaeval times when
monks from Cartmel lodged at Abbot Hall, Kents Bank, when ‘crossing the sands’
whereas Grange-over-Sands developed as a tourist resort in Victorian times after the
‘coming of the railway.
5.2 Kents Bank has its own station, Post Office, shop, Art Gallery, Abbot Hall Hotel and
Guide’s Farm. The post of Guide dates back to at least 1501 according to records of
Cartmel Priory.
5.3 During the past 20-25 years SLDC’s Planning Department have permitted infilling
development on many Kents Bank green field sites; they have allowed infilling on green
gaps between Kents Bank and Grange-over-Sands on the east, and, Kents Bank and
Allithwaite on the west.
5.4 Why is SLDC treating Kents Bank as a suburb of Grange-over-Sands? Residents of
Kents Bank do not support this view; they value their community and do not want to see
Kents Bank absorbed into Grange-over-Sands or Allithwaite. Kents Bank was
established hundreds of years before Grange-over-Sands.
5.5 This unsound approach has been perpetuated in SLDC’s Land Allocation DPD. Section
4.2 of the document is headed Grange-over-Sands and Kents Bank whereas Allithwaite
is considered as a separate community.
5.6 Subsequent text in SLDC’s Land Allocation DPD uses the name Grange-over-Sands
when it is actually referring to Kents Bank. For example paragraph 4.12 states:
“…The second major allocation is a large site on Allithwaite Road west of Kents Bank.
This is the only large site available in Grange-over-Sands…”
5.7 This is nonsense. The site referred to is MN25M; it is west of Kents Bank; it will
significantly extend Kents Bank’s western boundary and will lead to coalescence
between Kents Bank and Allithwaite if it is developed (see Map 1 and section 6).
REFER TO MAP 1 & 2 IN ATTACHED DOCUMENT
5.8 SLDC’s Land Allocation DPD gives Kents Bank similar problems with its Grange-over-
Sands boundaries; the green spaces between Grange-over-Sands and Kents Bank have
been gradually eroded over the years. If more green spaces between the two
communities are developed it will be the ‘death knell’ of Kents Bank as a separate
community (see Map 2)
5.9 It is clear from Map 2 that building on sites R110 (Trickett’s field) and R449/R74 will
erode the sense of separation between Grange-over-Sands and Kents Bank when
driving on the main road, the B5227 and that they will increase coalescence between
Grange-over-Sands and Kents Bank.
5.10 The Grange-over-Sands Regeneration Study 2007 considered site R110 (Trickett’s
field). They concluded that it should not be developed because:
“…loss of open views from street is negative…”
5.11 R449/R74 was not considered by the Grange-over-Sands Regeneration Study 2007 and its importance as a green field site has not been independently assessed. It is clear from Map 2 that development of these two sites will increase coalescence between Grangeover-Sands and Kents Bank. SLDC has provided no objective evidence to support the development of either of these green field sites.
5.12 The only green field site in Kents Bank that was considered by the Grange-over-Sands
Regeneration Study 2007 was site R89 (the Carter Road site, Berry Bank, Map 1 and
Map 2) and the report did not recommend development of R89 because of:
“…the loss of open area will be an issue…” and they concluded that
“…that residential development of the Allithwaite Road/Carter Road site is likely to be
controversial because of the ‘green field’ nature of the site…”
5.13 None of the development sites proposed for Kents Bank (Map 1), except R89, were
considered by the Grange-over-Sands Regeneration Study 2007; they have not been
independently assessed before inclusion in SLDC’s Land Allocation DPD.
SEE TABLE 4 IN ATTACHED DOCUMENT
5.14 Table 4 clearly shows that a disproportionate amount of the unsustainable housing
allocation for Grange-over-Sands has been allocated to Kents Bank (58%)
5.15 The proposed development will increase the size of Kents Bank by 40% and extend its
boundaries towards Allithwaite causing coalescence between Kents Bank and
Allithwaite; SLDC have provided no objective evidence to justify increasing the size of
Kents Bank on this scale.
5.16 All the proposed housing development sites in Kents Bank have been allocated to
desirable green field sites except for Guides Lot (17 dwellings plus employment units)
but even this site includes a small additional green field and the site is adjacent to land
on Wart Barrow that is covered by a Limestone Pavement Order.
5.17 The proposed site MN25M is particularly contentious (see section 6).
5.18 Development of all the proposed sites near Risedale Hill and in Kents Bank will have an adverse effect on local drainage in areas that are already prone to flooding after heavy
rainfall eg Allithwaite Road beyond the top of Risedale Hill, Greaves Wood Road
(Bridleway) and Kirkhead Road.
5.19 The SLDC’s Land Allocation DPD has not taken account of problems highlighted by
Kents Bank residents in the 2011 consultation exercises. For example response forms
that I submitted for sites: MN25M, R672, 350M, R79#, R82#/R347# (see Appendices 3
to 7).
5.20 Many other residents also highlighted significant problems associated with the proposed land allocations for Kents Bank. All appear to have been ignored and lumped together in groups with a comment such as ‘noted’ beside them (see section 8). Why?
Section 5: Kents Bank as a separate community;
summary of main conclusions
- Kents Bank has been a separate community since Mediaeval times.
- SLDC have provided no clear evidence to justify increasing the size of Kents
Bank by 40%.
- SLDC have provided no clear evidence to justify sanctioning developments
that will increase coalescence between Grange-over-Sands and Kents Bank.
- SLDC have provided no clear evidence to justify sanctioning developments
that will increase coalescence between Kents Bank and Allithwaite.
- The local road system, utilities and community support systems are already
inadequate; they are not robust enough to support 298 more households in
Kents Bank.
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
I do not support SLDC’s Land Allocation DPD
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
I wish to take part in the oral examination because SLDC have not made an adequate response to significant planning concerns, raised by local residents, during earlier consultation phases, particularly those relating to:
1. ‘Housing need’ in the Grange-over-Sands area.
2. Proposed green field site land allocations for the Grange-over-Sands area.
3. The adverse impact of the proposed developments on tourism, the life-blood of Grange-over-Sands and the Cartmel Peninsula.
4. The inadequate road system that links Grange-over-Sands to other SLDC Service Centres.
In addition, SLDC have not provided objective evidence that justifies their classification of Grange-over-Sands as an SLDC Key Service Centre. Grange-over-Sands does not meet SLDC’s Core Strategy Document definition of Key Service Centre: it does not have a secondary school and it is not directly linked to other SLDC Service Centres by a main trunk road.
Nor does the SLDC Land Allocation DPD take account of local residents’ wishes about how their community should be developed, or the views of Grange-over-Sands Town Council.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
492. Mrs Valerie Kennedy (Individual) : 16 May 2012 12:49:00
A typed or handwritten document was submitted. This has been scanned and can be downloaded below:
Policy/Site No.
LA1.3 Housing Allocations - All Flookburgh sites
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
1. SLDC should not include Grange-over-Sands as one of its Key Service Centres because it does not meet the criteria in CS1.2 The development strategy for Principal Service Centres, Key Service Centres and Local Service Centres. This would mean that the number of proposed developments in Grange-over-Sands and district should be reduced and all proposed development sites should be reassessed. Development of brown field sites, such as Berners, should be prioritised and SLDC should take account of the views of local residents and Grange-over-Sands Town Council.
2. SLDC have not followed Government guidance about the use and interpretation of household surveys. They have not provided objective evidence to justify ‘housing need for Grange-over-Sands and District.
3. SLDC should be required to produce objective evidence to justify their plans to allow Grange-over-Sands to develop into a coastal urban sprawl incorporating Kents Bank.
4. SLDC should be required to remove sites MN25N, R672 and R79# from their Land Development DPD because development of these sites will lead to coalescence between the communities of Kents Bank and Allithwaite.
5. SLDC should be required to remove sites R449, R74 and R110 from their Land Development DPD because development of these sites will lead to further coalescence between the communities of Grange-over-Sands and Kents Bank.
6. SLDC should be required to produce clear evidence about how their proposed developments will enhance tourism in Grange-over-Sands and district.
7. SLDC should be required to explain why they have ignored recommendations made about green field sites and tourism in the Grange-over-Sands Regeneration Study (Douglas Wheeler Associates, November 2007), that they claim has informed SLDC's Core Strategy.
8. SLDC should be required to provide objective evidence that the local roads are adequate to support the proposed increase in population and traffic in Grange-over-Sands especially for known bottle-necks in Main Street and on Risedale Hill.
9. SLDC should not allow any development on prime green field land between Kents Bank and Allithwaite because it will lead to coalescence between these two separate communities.
1.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
I do not support SLDC’s Land Allocations DPD because it is based on spurious ‘housing need’ targets and has unnecessarily ear-marked important greenfield sites for development.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The following text of response 11303 is taken from sections 7 of my SLDC LDF consultation submission entitled: ‘Soundness’ response to SLDC’s Land Allocation Development Plan (DPD, Jan 2012) focussing on SLDC’s ‘housing need’ predictions & SLDC’s vision for Grange-over-Sands and District.
My report included photographs, maps and tables to support comments that were made in the report. I have requested that this report be made available to the Planning Inspector.
The sections featured in response 11303 are:
7. Does SLDC's Land Allocation Document make adequate provision for capital expenditure to upgrade local roads?
Photographs, tables and maps that were included with the text in the report have been stored elsewhere, formatting that clarified the text has been removed and spurious question marks have appeared that are not in the original text.
[The full report is attached]
7 Does SLDC’s Land Allocation Document make adequate provision for
capital expenditure to upgrade local roads?
7.1 Allithwaite Road (B5277) is already inadequate for the amount of traffic regularly
travelling between Grange-over-Sands, Allithwaite, Flookburgh, Holker Hall, Kendal,
Lancaster and the M6.
7.2 The traffic problem is exacerbated when regular events such as Cartmel Races and
the Holker Garden Festival attract large crowds.
7.3 The stretch of Allithwaite Road between Kents Bank and Allithwaite from the top of
Risedale Hill is a fast stretch of undulating road that poses sight line problems for
drivers (see picture 3, section 6.15).
7.4 Developers would be forced to create new roads for development area MN25M linking
onto Allithwaite Road; this would increase traffic hazards on Allithwaite Road, or, lead
to the creation of an intrusive roundabout system that would destroy the rural nature
of this road and area
7.5 Greaves Wood Road bridleway forms the eastern, and southern, boundaries of
MN25M; it could not be used as access to MN25M development area because of a)
the Protected Limestone Pavement in Greaves Wood and b) it is a popular pedestrian
route for local residents, especially dog walkers (see Map 1, section 5.7 and Map 3,
section 6.4).
7.6 Access from Kirkhead Road to the MN25M development area is not practical; there
are no suitable gaps between the houses whose back gardens form the western
boundary of MN25M.
7.7 Industrial development and 202 residential units will generate a large amount of extra
traffic in Kents Bank that will all need to drive through Grange-over-Sands to reach the
A590 for access to Kendal, Lancaster and the M6; the local road system is not
suitable for this.
7.8 Local roads are not adequate to accommodate service vehicles for industrial
development.
SEE PICTURES IN ATTACHED DOCUMENT
7.9 SLDC are also proposing to build dwellings on the land behind the lorry on Allithwaite
Road (picture 6) and on the left hand side of Allithwaite Road beyond the junction of
Allithwaite Road with Jack Hill (junction to the left of Kirkhead Road; picture 6); access
to both these sites is constrained by their location and will cause road safety
problems.
7.10 Picture 5 clearly shows that it is not possible to widen or straighten Risedale Hill
without major road works involving compulsory purchase orders, demolition of walls
and completely altering the character of this part of Kents Bank and that the road is
not suitable for large volumes of traffic.
7.11 Traffic from three other nearby proposed residential developments in Kents Bank,
R672M: 36 residential units & R89: 45 residential units, R350M: 17 houses, also link
to Allithwaite Road, near the top of Risedale Hill therefore they should also be taken
into account when undertaking an area traffic impact study (see Map 1, section 5.7);
as should traffic generated by all residential and employment developments west of
Risedale Hill in Allithwaite and Flookburgh.
7.12 Once the traffic has negotiated Risedale Hill it then has to negotiate Main Street hill in
Grange-over-Sands another bottleneck that is often made worse by delivery vehicles
for the local shops because none of the shops on this part of Main Street have rear
access,
7.13 The local roads are in a poor state of repair and are not suitable for this level of traffic
increase.
7.14 SLDC have made no provision for improving these roads and have not justified a
need for developments that will make the traffic conditions considerably worse and
deter tourists.
7.15 There is no viable route for a Grange-over-Sands by-pass. A new trunk road to the
A590 would have to be routed across rough pastureland to the north of Grange-over-
Sands and would impinge on classic views of Cartmel and Cartmel Priory.
7.16 Car parking in Grange-over-Sands is already inadequate for local residents shopping
and tourists and again, no provision has been made in SLDC’s Land Allocation DPD
to improve local car parking facilities.
Section 7: Inadequate local roads in Grange-over-Sands and District;
summary of main conclusions
- The roads in Grange-over-Sands and district are already inadequate for the
traffic that they carry.
- There are two major bottlenecks: Risedale Hill and Main Street Hill that
cannot be widened due to their location.
- It would be expensive and difficult to agree a route for a new trunk road to the
A590 that by-passed Grange-over-Sands.
- SLDC have not made any provision to upgrade roads in Grange-over-Sands
and district.
- SLDC have not provided objective evidence to justify proposing large
development to the west of Grange-over-Sands given the already inadequate
road system.
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
I do not support SLDC’s Land Allocation DPD
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
I wish to take part in the oral examination because SLDC have not made an adequate response to significant planning concerns, raised by local residents, during earlier consultation phases, particularly those relating to:
1. ‘Housing need’ in the Grange-over-Sands area.
2. Proposed green field site land allocations for the Grange-over-Sands area.
3. The adverse impact of the proposed developments on tourism, the life-blood of Grange-over-Sands and the Cartmel Peninsula.
4. The inadequate road system that links Grange-over-Sands to other SLDC Service Centres.
In addition, SLDC have not provided objective evidence that justifies their classification of Grange-over-Sands as an SLDC Key Service Centre. Grange-over-Sands does not meet SLDC’s Core Strategy Document definition of Key Service Centre: it does not have a secondary school and it is not directly linked to other SLDC Service Centres by a main trunk road.
Nor does the SLDC Land Allocation DPD take account of local residents’ wishes about how their community should be developed, or the views of Grange-over-Sands Town Council.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
493. Mrs Valerie Kennedy (Individual) : 16 May 2012 12:51:00
A typed or handwritten document was submitted. This has been scanned and can be downloaded below:
Paragraph No.
1.9
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
1. SLDC should not include Grange-over-Sands as one of its Key Service Centres because it does not meet the criteria in CS1.2 The development strategy for Principal Service Centres, Key Service Centres and Local Service Centres. This would mean that the number of proposed developments in Grange-over-Sands and district should be reduced and all proposed development sites should be reassessed. Development of brown field sites, such as Berners, should be prioritised and SLDC should take account of the views of local residents and Grange-over-Sands Town Council.
2. SLDC have not followed Government guidance about the use and interpretation of household surveys. They have not provided objective evidence to justify ‘housing need for Grange-over-Sands and District.
3. SLDC should be required to produce objective evidence to justify their plans to allow Grange-over-Sands to develop into a coastal urban sprawl incorporating Kents Bank.
4. SLDC should be required to remove sites MN25N, R672 and R79# from their Land Development DPD because development of these sites will lead to coalescence between the communities of Kents Bank and Allithwaite.
5. SLDC should be required to remove sites R449, R74 and R110 from their Land Development DPD because development of these sites will lead to further coalescence between the communities of Grange-over-Sands and Kents Bank.
6. SLDC should be required to produce clear evidence about how their proposed developments will enhance tourism in Grange-over-Sands and district.
7. SLDC should be required to explain why they have ignored recommendations made about green field sites and tourism in the Grange-over-Sands Regeneration Study (Douglas Wheeler Associates, November 2007), that they claim has informed SLDC's Core Strategy.
8. SLDC should be required to provide objective evidence that the local roads are adequate to support the proposed increase in population and traffic in Grange-over-Sands especially for known bottle-necks in Main Street and on Risedale Hill.
9. SLDC should not allow any development on prime green field land between Kents Bank and Allithwaite because it will lead to coalescence between these two separate communities.
1.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
I do not support SLDC’s Land Allocations DPD because it is based on spurious ‘housing need’ targets and has unnecessarily ear-marked important greenfield sites for development.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The following text of response 11304 is taken from sections 8 of my SLDC LDF consultation submission entitled: ‘Soundness’ response to SLDC’s Land Allocation Development Plan (DPD, Jan 2012) focussing on SLDC’s ‘housing need’ predictions & SLDC’s vision for Grange-over-Sands and District.
My report included photographs, maps, tables and Appendices to support comments that were made in the report. I have requested that this report be made available to the Planning Inspector.
The sections featured in response 11304 are:
8. Was SLDC’s consultation process sound?
Photographs, tables, maps and Appendices that were included with the text in the report have been stored elsewhere and formatting that clarified the text has been removed
[The full report is attached]
8 Was SLDC’s consultation process ‘sound’?
8.1 SLDC’s consultation process appears to have been flawed.
8.2 Members of the public were offered a chance to make comments on SLDC’s Land
Development proposals in 2011 but the system for assessing these submissions lacks
clarity and objectivity.
8.3 The SLDC Planning Department:
i. Prepared the Land Allocation DPD.
ii. Assessed responses from local residents with phrases such as ‘noted’ or ‘taken into
account’.
iii. Ignored factual evidence submitted.
8.4 There has been no independent scrutiny of submissions made during the consultation
process.
8.5 There has been no open discussion about alternative options for the provision of
‘affordable housing’ and the majority Liberal Democrat Council have been under a ‘three
line whip’ to support the proposals.
8.6 In addition developers have been allowed to appoint Land Agents to lobby for
particularly desirable green field sites to be included in SLDC’s Land Allocation DP.
8.7 This can hardly be described as a fair process.
8.8 The reality is that many of the proposals in SLDC’s Land Allocation DPD do not ‘live up
to their SLDC ‘billing’ in the plan. A prime example of this being the claim that a 220
metre gap on the B5227 between Kents Bank and Allithwaite is sufficient to avoid
coalescence between the two communities.
8.9 SLDC’s ‘soundness consultation period’ has been the minimum allowed (six weeks) and has included the Easter holiday fortnight. Again, this puts local residents at a
disadvantage.
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
I do not support SLDC’s Land Allocation DPD
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
I wish to take part in the oral examination because SLDC have not made an adequate response to significant planning concerns, raised by local residents, during earlier consultation phases, particularly those relating to:
1. ‘Housing need’ in the Grange-over-Sands area.
2. Proposed green field site land allocations for the Grange-over-Sands area.
3. The adverse impact of the proposed developments on tourism, the life-blood of Grange-over-Sands and the Cartmel Peninsula.
4. The inadequate road system that links Grange-over-Sands to other SLDC Service Centres.
In addition, SLDC have not provided objective evidence that justifies their classification of Grange-over-Sands as an SLDC Key Service Centre. Grange-over-Sands does not meet SLDC’s Core Strategy Document definition of Key Service Centre: it does not have a secondary school and it is not directly linked to other SLDC Service Centres by a main trunk road.
Nor does the SLDC Land Allocation DPD take account of local residents’ wishes about how their community should be developed, or the views of Grange-over-Sands Town Council.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
494. Mrs Valerie Kennedy (Individual) : 16 May 2012 12:52:00
A typed or handwritten document was submitted. This has been scanned and can be downloaded below:
Paragraph No.
1.10
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
1. SLDC should not include Grange-over-Sands as one of its Key Service Centres because it does not meet the criteria in CS1.2 The development strategy for Principal Service Centres, Key Service Centres and Local Service Centres. This would mean that the number of proposed developments in Grange-over-Sands and district should be reduced and all proposed development sites should be reassessed. Development of brown field sites, such as Berners, should be prioritised and SLDC should take account of the views of local residents and Grange-over-Sands Town Council.
2. SLDC have not followed Government guidance about the use and interpretation of household surveys. They have not provided objective evidence to justify ‘housing need for Grange-over-Sands and District.
3. SLDC should be required to produce objective evidence to justify their plans to allow Grange-over-Sands to develop into a coastal urban sprawl incorporating Kents Bank.
4. SLDC should be required to remove sites MN25N, R672 and R79# from their Land Development DPD because development of these sites will lead to coalescence between the communities of Kents Bank and Allithwaite.
5. SLDC should be required to remove sites R449, R74 and R110 from their Land Development DPD because development of these sites will lead to further coalescence between the communities of Grange-over-Sands and Kents Bank.
6. SLDC should be required to produce clear evidence about how their proposed developments will enhance tourism in Grange-over-Sands and district.
7. SLDC should be required to explain why they have ignored recommendations made about green field sites and tourism in the Grange-over-Sands Regeneration Study (Douglas Wheeler Associates, November 2007), that they claim has informed SLDC's Core Strategy.
8. SLDC should be required to provide objective evidence that the local roads are adequate to support the proposed increase in population and traffic in Grange-over-Sands especially for known bottle-necks in Main Street and on Risedale Hill.
9. SLDC should not allow any development on prime green field land between Kents Bank and Allithwaite because it will lead to coalescence between these two separate communities.
1.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
I do not support SLDC’s Land Allocations DPD because it is based on spurious ‘housing need’ targets and has unnecessarily ear-marked important greenfield sites for development.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The following text of response 11305 is taken from section 8 of my SLDC LDF consultation submission entitled: ‘Soundness’ response to SLDC’s Land Allocation Development Plan (DPD, Jan 2012) focussing on SLDC’s ‘housing need’ predictions & SLDC’s vision for Grange-over-Sands and District.
My report included photographs, maps, tables and Appendices to support comments that were made in the report. I have requested that this report be made available to the Planning Inspector.
The section featured in response 11305 is:
8. Was SLDC's consultation process sound?
Photographs, tables and maps that were included with the text in the report have been stored elsewhere and formatting that clarified the text has been removed.
[The full report is attached]
8 Was SLDC’s consultation process ‘sound’?
8.1 SLDC’s consultation process appears to have been flawed.
8.2 Members of the public were offered a chance to make comments on SLDC’s Land
Development proposals in 2011 but the system for assessing these submissions lacks
clarity and objectivity.
8.3 The SLDC Planning Department:
i. Prepared the Land Allocation DPD.
ii. Assessed responses from local residents with phrases such as ‘noted’ or ‘taken into
account’.
iii. Ignored factual evidence submitted.
8.4 There has been no independent scrutiny of submissions made during the consultation
process.
8.5 There has been no open discussion about alternative options for the provision of
‘affordable housing’ and the majority Liberal Democrat Council have been under a ‘three
line whip’ to support the proposals.
8.6 In addition developers have been allowed to appoint Land Agents to lobby for
particularly desirable green field sites to be included in SLDC’s Land Allocation DP.
8.7 This can hardly be described as a fair process.
8.8 The reality is that many of the proposals in SLDC’s Land Allocation DPD do not ‘live up
to their SLDC ‘billing’ in the plan. A prime example of this being the claim that a 220
metre gap on the B5227 between Kents Bank and Allithwaite is sufficient to avoid
coalescence between the two communities.
8.9 SLDC’s ‘soundness consultation period’ has been the minimum allowed (six weeks) and has included the Easter holiday fortnight. Again, this puts local residents at a
disadvantage.
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
I do not support SLDC’s Land Allocation DPD
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
I wish to take part in the oral examination because SLDC have not made an adequate response to significant planning concerns, raised by local residents, during earlier consultation phases, particularly those relating to:
1. ‘Housing need’ in the Grange-over-Sands area.
2. Proposed green field site land allocations for the Grange-over-Sands area.
3. The adverse impact of the proposed developments on tourism, the life-blood of Grange-over-Sands and the Cartmel Peninsula.
4. The inadequate road system that links Grange-over-Sands to other SLDC Service Centres.
In addition, SLDC have not provided objective evidence that justifies their classification of Grange-over-Sands as an SLDC Key Service Centre. Grange-over-Sands does not meet SLDC’s Core Strategy Document definition of Key Service Centre: it does not have a secondary school and it is not directly linked to other SLDC Service Centres by a main trunk road.
Nor does the SLDC Land Allocation DPD take account of local residents’ wishes about how their community should be developed, or the views of Grange-over-Sands Town Council.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
495. Mr & Mrs Philip & Carol Key (Individual) : 25 Apr 2012 08:32:00
Policy/Site No.
LA1.3 Housing Allocations - R121M-mod KENDAL EAST OF CASTLE GREEN ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I would like to inform you of my objection to the development of land
adjacent to Castle Green Lane and Oak Tree Road (R121M)
I believe that the impact upon biodiversity, flooding and the landscape
would be such that the proposals cannot be considered to be sound
and goes against all previous assessments.
Protected species such as Great Crested Newts are known to require land
of around 500 metres surrounding their ponds for feeding and
hibernation. The biodiversity evidence base states that
"The greatest threat to them in Cumbria is the destruction of their ponds
and surrounding terrestrial habitat."
The proposals to develop (R121M) would degrade most of the land and
the pond.
The map underestimates the size of the pond which is worrying as it
suggests that the research done to date has not been thorough or accurate
enough and serves as another indication that the proposals are not sound.
The land feeds into the Stock Beck catchment, which has been shown to
be prone to flooding and has required a flood alleviation scheme to be
introduced. Developing this land would exacerbate this flooding problem
and could well undermine all the work that has gone before. This would
have serious implications on nearby properties and as yet no proper
consideration has been given to how this would be dealt with. All other
land draining into the Stock Beck catchment has been removed from
consideration; it is perplexing that R121M is still being put forward.
The land itself has been put forward for county landscape designation in
1999 and a Kendal Town Council Commissioned report called The
Landscape Character Assessment (GALPIN), which SLDC have chosen
to ignore states that Rl21M was the most sensitive in landscape terms of
all the nineteen possible development sites in Kendal and had a low
capacity for development. Furthermore SLDC local plan 2006 stated that
"Developments of higher hillsides further east (ofR56) would be unduly
prominent"
I believe the proposals are therefore unsound and that any problems and
contradictory evidence has not been given proper consideration before
their advancement.
Indeed it is very telling that the planner responsible did not even step foot
on the site until 22nd July 2011 and that was at the residents' invitation.
496. Mrs Patricia A Kilshaw (Individual) : 4 May 2012 17:04:00
Policy/Site No.
LA1.7 Business and Science Park Sites - M11M - Mod ULVERSTON LAND AT LIGHTBURN ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
M11M
The site should remain part of green gap between Ulverston and Swarthmoor. I disagree with SLDC assessment of loss of identity between Ulverston and Swarthmoor. The land forms a significant area of green field and any building would necessarily change the sky line
The site is bounded by railway line and major trunk road A590, therefore the only access is via the major trunk road.
See CS 10.1 & 10.2 highways impact on trunk roads, Managing impact of new development.
Reference was noted to a forthcoming Transport Study - not yet carried out.
There is already evidence of traffic accidents in this area therefore site is not suitable.
CS7.2 set out employment land requirements. Ther are already unoccupied office premises on nearby business sites.
Water Drainage: Extra use on this site would lead to considerable extra need for water drainage which is not practical, also it would lead to extra risk of flooding further south, which is a current problem.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
497. Mrs Patricia A Kilshaw (Individual) : 8 May 2012 15:12:00
Policy/Site No.
LA1.9 Green Gaps between - ULVERSTON and SWARTHMOOR
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The site should remain part of Green Gap between Ulverston & Swarthmoor.
I disagree with SLDC assessment on loss of identity between Ulverston & Swarthmoor.
This land forms a significant area of green field & any building would necessarilt change the sky-line.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
498. Mrs Patricia A Kilshaw (Individual) : 15 May 2012 14:10:00
Policy/Site No.
LA1.3 Housing Allocations - RN250 ULVERSTON STONE CROSS MANSION
1.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The site should remain part of green gap between Ulverston and Swarthmoor. I disagree with SLDC assessment of loss of identity between Ulverston and Swarthmoor. The land forms a significant area of green field and any building would necessarily change the sky line
The site is bounded by railway line and major trunk road A590, therefore the only access is via the major trunk road.
See CS 10.1 & 10.2 highways impact on trunk roads, Managing impact of new development.
Reference was noted to a forthcoming Transport Study - not yet carried out.
There is already evidence of traffic accidents in this area therefore site is not suitable.
CS7.2 set out employment land requirements. Ther are already unoccupied office premises on nearby business sites.
Water Drainage: Extra use on this site would lead to considerable extra need for water drainage which is not practical, also it would lead to extra risk of flooding further south, which is a current problem.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
499. Mrs Elizabeth Laidlaw (Individual) : 17 Apr 2012 16:53:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.1 Development Boundaries- ENDMOOR
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
• Building to the north of Endmoor will spoil the skyline from the North and East and will resemble an urban sprawl.
• The M41M plan shows an increased numbers of dwellings from 68 to 100 which the village was not consulted on. 68 is too dense for the area. The services in the village do not match the needs of this many extra houses. There is no agreed Infrastructure Plan with United Utilities to upgrade the sewerage system to support any new development.
• Development of area M41M would be a major intrusion on the landscape visible from a wide area of surrounding countryside and roads. This is a greenfield site but there are alternative 'brown fields' in the area which could be considered.
• I am strongly opposed to development South of Dove Nest Lane – R670, because of the extra traffic and its unsuitability on access, insufficient sewerage capacity and run off grounds.
• The number of houses proposed for Endmoor is out of proportion for the size of the village when larger settlements have fewer houses proposed.
• Endmoor is barely a village as it has no pub, post office or church. The bus service is infrequent and expensive and the railway over four miles away.
• I can see no justification for another employment site when there are plenty of vacant units in the area.
• There is an adequate supply of market housing available for sale; some properties in Endmoor have been on the market for 2 years or more.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
500. Mrs Elizabeth Laidlaw (Individual) : 16 May 2012 14:48:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - All Endmoor sites
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
• The number of houses proposed for Endmoor is out of proportion for the size of the village when larger settlements have fewer houses proposed.
• Endmoor is barely a village as it has no pub, post office or church. The bus service is infrequent and expensive and the railway over four miles away.
• I can see no justification for another employment site when there are plenty of vacant units in the area.
• There is an adequate supply of market housing available for sale; some properties in Endmoor have been on the market for 2 years or more.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
501. Mrs Elizabeth Laidlaw (Individual) : 16 May 2012 14:52:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - M41M ENDMOOR NORTH OF SYCAMORE DRIVE
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
• Building to the north of Endmoor will spoil the skyline from the North and East and will resemble an urban sprawl.
• The M41M plan shows an increased numbers of dwellings from 68 to 100 which the village was not consulted on. 68 is too dense for the area. The services in the village do not match the needs of this many extra houses. There is no agreed Infrastructure Plan with United Utilities to upgrade the sewerage system to support any new development.
• Development of area M41M would be a major intrusion on the landscape visible from a wide area of surrounding countryside and roads. This is a greenfield site but there are alternative 'brown fields' in the area which could be considered.
• The number of houses proposed for Endmoor is out of proportion for the size of the village when larger settlements have fewer houses proposed.
• Endmoor is barely a village as it has no pub, post office or church. The bus service is infrequent and expensive and the railway over four miles away.
• I can see no justification for another employment site when there are plenty of vacant units in the area.
• There is an adequate supply of market housing available for sale; some properties in Endmoor have been on the market for 2 years or more.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
502. Mrs Elizabeth Laidlaw (Individual) : 16 May 2012 15:05:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - R670-mod ENDMOOR SOUTH OF BOWLING GREEN
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
• I am strongly opposed to development South of Dove Nest Lane – R670, because of the extra traffic and its unsuitability on access, insufficient sewerage capacity and run off grounds.
• The number of houses proposed for Endmoor is out of proportion for the size of the village when larger settlements have fewer houses proposed.
• Endmoor is barely a village as it has no pub, post office or church. The bus service is infrequent and expensive and the railway over four miles away.
• I can see no justification for another employment site when there are plenty of vacant units in the area.
• There is an adequate supply of market housing available for sale; some properties in Endmoor have been on the market for 2 years or more.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
503. Mr and Ms Arthur and Jean Lambert (Individual) : 23 Apr 2012 09:42:00
Paragraph No.
1.10
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
It appears futile giving any comments regarding Land allocation development .
you and your team have not been interested in any comments that the general public Have had to say. Your only support appears to be from people wishing to sell there land.
504. Mr and Ms Arthur and Jean Lambert (Individual) : 23 Apr 2012 09:47:00
A typed or handwritten document was submitted. This has been scanned and can be downloaded below:
Policy/Site No.
LA1.3 Housing Allocations - R690ulv, R691ULV, R126M, RN184, RN234# & part R242 ULVERSTON CROFTLANDS WEST - NOOK FARM
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
With no guarantee regarding the provision of new jobs in the area, how on earth will
new residents be able to afford these properties, cart before horse comes to mind.
Regarding new properties being built on brown field sites you appear to have ignored
your own targets and policies yet again. Didn't you state in your previous documents
that 50% of new properties would be on brownfield sites.
Now we have 93% of proposals on Greenfield sites, you also stated that
use of agricultural land should be of a poorer quality, yet most of south Ulverston
is prime farming land being lost to development?
Coronation Hall23rd March 2011 most of the people attending the meeting were
shocked at the ghotos displayed regarding flooding .
Countryfile 20 March 2011 Mr Richard Benyon MP Minister for the Natural Environment stated "it is clear government policy not to build on land that floods"
yet you appear to ignore this advice. R690 Rl56 and R242 have been under water for
many weeks in previous years. - Please find enclosed photo of your future Ulverston South.
505. Mr & Mrs Lancaster (Individual) : 8 May 2012 16:59:00
Policy/Site No.
LA1.3 Housing Allocations - RN152 GREENODD LAND AT THE OLD VICARAGE
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
We strongly object to the proposal to build houses in the field situated behind the property reasons are privacy and light drainage & swerage which as been a problem for a long time and adding more homes will not help has the treatment plant doesn't seem to be able to cope at present.
There is also the problem of traffic both during and afterwards.
There are a number of properties either for sale or to let at the moment.
506. Mr David Lancaster (Individual) : 9 May 2012 15:32:00
A typed or handwritten document was submitted. This has been scanned and can be downloaded below:
Policy/Site No.
LA1.3 Housing Allocations - RN152 GREENODD LAND AT THE OLD VICARAGE
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Unsure! Again I ask, were the owners, as well as the Environmental Agency, consulted over water, drainage, sewage?
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
A petition (signed by the majority) do not want this development for the reasons attached on separate sheet [see text below]. I also asked if the owners (church) were consulted over flooding (no response).
Text of letter:
I attended a local Parish Council meeting held in Greenodd Village Hall on Tuesday 6th March 2012, to express my concerns and my objections to the proposal to build 22 dwellings on the land mentioned above. I have also registered my concerns by telephone to the Diocese - the owners of the land. I am the present church warden, a post I have held for some 30 years.
I have a copy of Appendix 8 - Greenodd & Pennybridge Emerging Options Consultation Stage 1 (Final Version) and I recognise and support all the objections raised in that document to build on this land, north of our churchyard.
I enclose photographic evidence of a potential flood risk to this development, evidence which I raised over 20 years ago when the new vicarage was built behind the old vicarage, close to the field.
I would ask if South Lakeland District Council has engaged with the owners - "Re: Appendix 8 - The Council has fully engaged with the Environmental Agency and other relevant key professional bodies / persons."
From my photographs (Jan 1990 - see attached document) you will note the depth excavated to find a sound base (foundation) for the building of the new vicarage - measured some 3-4 metres. It flooded and was repeatedly pumped out and large drains installed.
I would further add, in my opinion to this development, an observation on "Landscape Impact". This is a sloping field draining natural springs and housing behind present dwellings including the new vicarage would overlook obtrusively and reduce natural light to existing homes. Furthermore, people have expressed a great desire to preserve the tranquility and the peace afforded by our local church and churchyard. Those who visit for church services, weddings, funerals, special events with the school children, or just to tend the graves of relatives can, at present, reflect on the beautiful countryside and the views afforded of the Coniston Mountain range and the lovely Crake Valley; an asset which would disappear in one instant.
On a personal note I add that I am oposed to building on producing agricultural land, whether it's for a crop of hay or for grazing farm animals - as at present. I firmly believe that with an ever increasing population, nationally and worldwide, that we are, in the future, going to need all the agricultural land and more. It would see, even in this rural county, that we are reducing land and the number of people working on the land - and jobs we certainly need.
I am not convinced that there is a need for so many new dwellings (is it 6000 by 2025?) - certainly 400 a year more recommended. I have counted 13 dwellings up for sale in our parish - prices ranging from £140,000 to £395,000 - most on offer since last year and no buyers. Our friends wished to move and haven't had a single visit in 6 months.
At present there are few holiday homes in Greenodd and Penny Bridge. This is not the case at Spark Bridge and further up the valley to Coniston. Our primary school is full and so is the new pre-school built on the same site. I am told this is not the case elsewhere. Surely this is an indicator that our community in its endeavours has, to a large extent "got things right" - realising and knowing what is important for our future here. Our people fought to keep our school and church viable, to retain our village post office, along with other shops and businesses and they support our thriving societies. At the meetings on this matter there has been a resounding "no" to this development with a petition signed by the majority. We are alos supportive of our representative on the SLDC and our Parish Council.
I appeal to you to reconsider and to reject building on this land; to concentrate your efforts where the need for building is greatest - and, where possible, using "infill" and former sites used for industry.
It was stated at the meeting on 06.03.12 that another site in our parish had been "turned down" because of access - mainly to the main Greenodd to Coniston road. Building another 22 dwellings, further up the hill from this site is surely going to increase the number of vehicles accessing the same road.
When I spoke at a previous parish council meeting on this matter I stated that on the south and south west sides of this proposed development there were a large number of mature trees - an avenue of tall beech and sycamore trees in the churchyard alongside this field, and a large number of oaks, chestnut, ash etc between the vicarage and the field. My concern was that the disturbance to the roots, if building took place, and the age of the trees, might threaten buildings constructed in the said field. In recent years two very large beech trees have fallen into the field. I also stated that a supply pipe to the church oil fired central heating boiler passes along the south side of this field to the oil tank - and that a "soak-away" from the church toiltet is in this vicinity.
- Loss of landscape and amenity
- Topography
- Impact of church, graveyard, etc and impact on funerals, weddings, grave visits
- Loss of agricultural land / greenfield site and potential impact on agricultural employment
- Known issues such as drainage / ground water / surface water in the field (photos attached)
- Concern over existinf sewage problems upstream of the new sewage treatment plant (which is not working properly at present because of these problems)
- There are presently at least thirteen properties in Greenodd and Penny Bridge either for sale, for let or empty, suggest lack of demand for additional residential housing
- The primary school is presently full / at capacity with little scope for expansion
- Major concerns over access / traffic both during construction and thereafter
- The likely devaluation of existing neighbouring properties, impact on light etc. for those properties and the fact that they will be overlooked by any development
- The LDF document refers to the site as being an "infill site" which is inaccurate as there is no existing development to the south of the field and it can easily be argued that development would not constitute "rounding off" and that it would not be "well located in relation to existing services and facilities"
- There are relatively few mature trees bordering two sides "shielding the church and existing dwelling on R291": in fact, the beech trees to the south of the field represent a significant danger to any future development (2 have already blown over into this field)
- The reference in the document that development would "safeguard the Crakeside Business Park and Crakeside Works as local imployment areas" is tenuous at best because of the close proximity of housing in nearby Ulverston, Lowick Parish and Backbarrow and Haverthwaite.
- More buildings for holiday homes? (4 already in Ellis Wood - last development) across the road
- church sewage 'soakaway' in this area. Also oil supply pipe.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
507. Mr David Lancaster (Individual) : 9 May 2012 15:40:00
A typed or handwritten document was submitted. This has been scanned and can be downloaded below:
Policy/Site No.
LA1.3 Housing Allocations - RN152 GREENODD LAND AT THE OLD VICARAGE
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
removal of site
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I would ask if South Lakeland District Council has engaged with the owners - "Re: Appendix 8 - The Council has fully engaged with the Environmental Agency and other relevant key professional bodies / persons."
I am not convinced that there is a need for so many new dwellings (is it 6000 by 2025?) - certainly 400 a year more recommended. I have counted 13 dwellings up for sale in our parish - prices ranging from £140,000 to £395,000 - most on offer since last year and no buyers. Our friends wished to move and haven't had a single visit in 6 months.
At present there are few holiday homes in Greenodd and Penny Bridge. This is not the case at Spark Bridge and further up the valley to Coniston. Our primary school is full and so is the new pre-school built on the same site. I am told this is not the case elsewhere. Surely this is an indicator that our community in its endeavours has, to a large extent "got things right" - realising and knowing what is important for our future here. Our people fought to keep our school and church viable, to retain our village post office, along with other shops and businesses and they support our thriving societies. At the meetings on this matter there has been a resounding "no" to this development with a petition signed by the majority. We are also supportive of our representative on the SLDC and our Parish Council.
It was stated at the meeting on 06.03.12 that another site in our parish had been "turned down" because of access - mainly to the main Greenodd to Coniston road. Building another 22 dwellings, further up the hill from this site is surely going to increase the number of vehicles accessing the same road.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
508. Mrs L.P. Langfield (Individual) : 12 Apr 2012 15:19:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA3.2 Mixed Use Allocation at Land South of Allithwaite Road, Kent's Bank, Grange-over-Sands
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Insufficient information available on which to base a rational assessment of the effect on local infrastructure.
Appraisal of soundness relating to area MN25M viz impact on existing local infrastructure:
Information given is simply that 202 new dwellings and a number of employment units are proposed. There is no info as to the type of buildings proposed nor any info to enable a rough estimate of the increased population generated by this development and its impact on the local infrastructure. Some examples of this are given below:
New roads & footways - no information re layout and their points of access to the existing road system is available. On-road parking in vicinity of Kents Bank station would significantly increase to nuisance levels. Increased traffic in this area would be a danger to pedestrains, particularly on the lower length of Kirkhead Road to Kents Bank Station where there are no footways, nor sufficient width available to provide them. There are also 3 bus routes squeezing through this point.
Surface Water Drainage - The large increase in impervious areas would cause great increase in storm water run-off. The contours of this site dictate that all of this flow will arrive rapidly to the point at the junction of Kirkhead Road and Greaves Wood Road - which is already subject to flooding.
Sewage Generation - Increased population (no info available). Would the local sewage treatment facilities be capable of coping with increased volume.
CONCLUSION: Considering that there is insufficient information in the public domain which allows estimates of the impact of this development on the existing infrastructure one must conclude that this development proposal must be judged UNSOUND.
509. Mr Bob Langston (Individual) : 11 Apr 2012 16:53:00
Policy/Site No.
LA1.3 Housing Allocations - All Arnside sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Having recently read the local news reports of the SLDC proposed land allocations for Arnside, I am writing to express my deep concern and amazement that seemingly, none of the proposed alternatives put forward during and following the roadshows, seem to have even been considered.
I have just read the draft proposed alternative document from the Arnside Parish Plan Trust, and I have to say, that even in its draft form, I find it exceptionally well thought out and presented, with some very sound arguments for the proposals it makes.
I would encourage you to reconsider your initial proposals and give some serious thought to the alternatives proposed in the APPT document, and the arguments that have been used to arrive at them.
510. Mr K A Lasbury (Individual) : 5 Apr 2012 17:33:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
0.0 Whole Document
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The DPD has not been prepared in accordance with the Town & County Planning Regulations 2004 (as amended)
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The recent "Norfolk" judgement suggests that the SLDC process is equally unlawful. Whilst some changes have been made over the last 4 years they have been relatively minor and peripheral. The proposals in the approved documents which will now go before an Inspector at an Inquiry are largely unchanged and can be demonstrated to have been founded on flawed original data . Assessments of alternatives have not been thoroughly undertaken and have not been fully explained publicly.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
There has been little evidence provided to justify the overall numbers of housing included within the Plan.
A major plank of the Council's policies has been the provision of affordable housing - it is not disputed that there is such a need. However the overall scale of housing proposed appears entirely predicated on the ability of the private sector to subsidise the provision of the number of affordable houses deemed to be required for the District. No apparent effort is demonstrated to provide affordable housing by other funding mechanisms. To do so would reduce the overall size of the housing proposal. Thus UNSOUND on grounds of proven need.
YDNP and LDNP take up a large proportion of SLDC area. SLDC housing (and industrial) numbers have been concentrated into the relatively small area outside the Park boundaries in part to accommodate needs that arise from within the Parks. Consequently an excessive concentration is proposed which will place excessive pressures on the infrastructure (transport, education, health etc) within those small areas.(I develop the infrastructure consequences in my representation about Kendal itself) The entire LDF proposal is UNSOUND on the grounds that many of the measures proposed to address impacts mentioned within the documents are aspirational with no clear timescale or commitment to deliver from the various parties .
The basic housing numbers proposed by SLDC have remained unchanged throughout the (excessively) prolonged LDF process and SLDC appear to have failed to take account of the fundamental policy change by LDNP within their LDF to permit 900 affodable houses to be built within the Park. SLDC proposed housing numbers should have been reduced proportionately. Thus UNSOUND.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
I will need to expand on some of my detailed representations about Kendal and site R170M specifically.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
511. Mr K A Lasbury (Individual) : 5 Apr 2012 17:39:00
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I have read the guidance notes
Policy/Site No.
LA1.1 Development Boundaries- KENDAL
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I have challenged the "soundness" of the overall housing numbers in my representation about the entire document. Those points apply equally to Kendal itself.
The proposals for Kendal are UNSOUND because they fail several of the effectiveness criteria within The Planning Inspectorate Soundness Guidance - there is no sound infrastructure delivery plan and there is not a clear commitment that those who would have to deliver eg Cumbria County Council, United Utilities, Electricity North West etc would/could do so within the timescale of the LDF. Whilst I largely concentrate on traffic issues it is appropriate to raise issues about capacity of the waste water treatment works, the sewerage system, electrical supply issues where the LDF documents do not contain any clear and firm commitment to accommodate the consequences of the deveopment proposed.
TRAFFIC. Cumbria County Council's (most recent) Kendal Traffic Study states that there is congestion now in Kendal. It concludes that there would be "significant increases in congestion as a result of the proposed levels of LDF development". The study tested various "schemes" and concluded that congestion can be mitigated to no worse than base scenario. That conclusion is based on at least 3 very questionable assumptions -
a 5% reduction in traffic from the sustainable travel programme - a figure with no substantiation; such a reduction has probably been achieved in other locations but there is no evidence it could be achieved in Kendal, and not with the programme outlined;
250 vehicles removed from peak hour flows by a Park and Ride site - there is no substantiation of this figure in the study and the County Council's Study report itself casts doubt on the ability to achieve that reduction; additionally there is no commitment to deliver the site itself nor any evidence on the practicalities and (capital and current) financial consequences of operating an effective P&R site.
More realistic (ie lower) figures for both of the above would produce an entirely different analysis with an inevitable deterioration in congestion as a result.
Three pieces of new highway infrastructure are included in the Study - two major new routes - the Northern and Southern Development Routes and a new road connection within the town centre. This is completely UNSOUND as none of these projects have any status with the highway authority; are in no programme; two of them (at least) have had none of the statutory environmental and economic assessments undertaken; none of them have been through any "public process" and thus have little, if any, chance of being delivered within the Plan timeframe.
An earlier, SLDC sponsored traffic study, hurriedly undertaken as part of the LDF process, introduced yet another major project - a Kendal Inner Relief Road. Again that had no status, no assessment, no detail etc.
It is clear that these large projects have only been included in the traffic studies as smoke screens attempting to convince the public and the Inspector that the excessive development proposals could be satisfactorily accommodated in Kendal. In this regard it seems almost unnecessary to repeat that this is UNSOUND.
A part of Kendal suffers from poor air quality and there is an Air Quality Management Area in the centre of town. The first SLDC plan failed to deliver any improvement and similar results are expected of the current document (recent improvements at some sites can probably be attributed to the current poor economic situation). Even if the traffic study conclusions are accepted the combined impact of all LDF development and the extensive infrastructure programme studied would leave the town "no worse than base scenario" - in other words air quality will not improve.
Again,all the above confirms the document is UNSOUND
The Community Infrastructure Levy is suggested as the answer to funding all the wider and community infrastructure needs. I understand that it will not be applied to the affordable housing element of any development and that individual developments may also apply to be exempted on viability grounds. Site specific infrastructure requirements will still have to be funded by the developer through Section 106 Agreements in addition to the Levy.
With the excessive financial demands that will inevitably be placed on each development in terms of school places, direct highway consequences, a 35% affordable housing contribution etc etc, it seems highly likely that any contribution to an Infrastructure Levy for wider scale projects would be relatively modest and inadequate. These financial implications appear to again confirm that the proposals are UNSOUND.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
Further discussion of the points outlined above is essential
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
512. Mr K A Lasbury (Individual) : 5 Apr 2012 17:41:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - R170M-mod KENDAL NORTH OF LAUREL GARDENS
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I have questioned the scale of housing overall and the impact on Kendal itself in other representations, and they apply equally to this site.
The inclusion of this site in UNSOUND largely on traffic grounds which are outlined below.
In addition the unsuitability of the site is demonstrated by the flooding that occurs now in the north west corner and in the adjacent properties. The Fact File for this site acknowledges this flooding and states that it is being looked into. It does not indicate that a solution is available and will be delivered
The site is so distant from any facilities - doctors, schools, shops, employment sites within the town that it will inevitably generate high private vehicle usage regardless of any attempt to introduce "active travel plans"; and on that basis alone it totally fails any sustainability test.
TRAFFIC
ACCESS to the site
Cumbria County Council are quoted within the Fact File for this site "achieving adequate visibility will be problematic given alignment of road and limited frontage". Measurements on site confirm that safe access, compliant with appropriate standards, cannot be achieved here (as has been pointed out at every consultation stage - and ignored by SLDC). That point alone makes the inclusion of this site UNSOUND.
BURNESIDE ROAD
Development of this site (and those proposed in Burneside) would increase traffic flows on Burneside Road - a totally unacceptable and UNSOUND proposition taking into account this road's many substandard features with their potential safety consequences. These features include - several locations where forward visibility is very severely constrained (and could not reasonably be improved); a railway over bridge with narrow carriageway and footway (the footway is heavily used by pedsestrian school children) where the road width is effectively further reduced by unprotected and rough faced abutments; a very substandard access to an industrial estate (which again could not be reasonably improved); and extensive frontage development, some with no on site parking, others where vehicles have to reverse into or out of the site, often between the extensive on street parking. Additionally the road is used by large articulated HGVs accessing the paper mill in Burneside.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
I would need to expand on the access and other safety issues involved in the site.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
513. Mr K A Lasbury (Individual) : 16 May 2012 15:21:00
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I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - All Kendal sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I have challenged the "soundness" of the overall housing numbers in my representation about the entire document. Those points apply equally to Kendal itself.
The proposals for Kendal are UNSOUND because they fail several of the effectiveness criteria within The Planning Inspectorate Soundness Guidance - there is no sound infrastructure delivery plan and there is not a clear commitment that those who would have to deliver eg Cumbria County Council, United Utilities, Electricity North West etc would/could do so within the timescale of the LDF. Whilst I largely concentrate on traffic issues it is appropriate to raise issues about capacity of the waste water treatment works, the sewerage system, electrical supply issues where the LDF documents do not contain any clear and firm commitment to accommodate the consequences of the deveopment proposed.
TRAFFIC. Cumbria County Council's (most recent) Kendal Traffic Study states that there is congestion now in Kendal. It concludes that there would be "significant increases in congestion as a result of the proposed levels of LDF development". The study tested various "schemes" and concluded that congestion can be mitigated to no worse than base scenario. That conclusion is based on at least 3 very questionable assumptions -
a 5% reduction in traffic from the sustainable travel programme - a figure with no substantiation; such a reduction has probably been achieved in other locations but there is no evidence it could be achieved in Kendal, and not with the programme outlined;
250 vehicles removed from peak hour flows by a Park and Ride site - there is no substantiation of this figure in the study and the County Council's Study report itself casts doubt on the ability to achieve that reduction; additionally there is no commitment to deliver the site itself nor any evidence on the practicalities and (capital and current) financial consequences of operating an effective P&R site.
More realistic (ie lower) figures for both of the above would produce an entirely different analysis with an inevitable deterioration in congestion as a result.
Three pieces of new highway infrastructure are included in the Study - two major new routes - the Northern and Southern Development Routes and a new road connection within the town centre. This is completely UNSOUND as none of these projects have any status with the highway authority; are in no programme; two of them (at least) have had none of the statutory environmental and economic assessments undertaken; none of them have been through any "public process" and thus have little, if any, chance of being delivered within the Plan timeframe.
An earlier, SLDC sponsored traffic study, hurriedly undertaken as part of the LDF process, introduced yet another major project - a Kendal Inner Relief Road. Again that had no status, no assessment, no detail etc.
It is clear that these large projects have only been included in the traffic studies as smoke screens attempting to convince the public and the Inspector that the excessive development proposals could be satisfactorily accommodated in Kendal. In this regard it seems almost unnecessary to repeat that this is UNSOUND.
A part of Kendal suffers from poor air quality and there is an Air Quality Management Area in the centre of town. The first SLDC plan failed to deliver any improvement and similar results are expected of the current document (recent improvements at some sites can probably be attributed to the current poor economic situation). Even if the traffic study conclusions are accepted the combined impact of all LDF development and the extensive infrastructure programme studied would leave the town "no worse than base scenario" - in other words air quality will not improve.
Again,all the above confirms the document is UNSOUND
The Community Infrastructure Levy is suggested as the answer to funding all the wider and community infrastructure needs. I understand that it will not be applied to the affordable housing element of any development and that individual developments may also apply to be exempted on viability grounds. Site specific infrastructure requirements will still have to be funded by the developer through Section 106 Agreements in addition to the Levy.
With the excessive financial demands that will inevitably be placed on each development in terms of school places, direct highway consequences, a 35% affordable housing contribution etc etc, it seems highly likely that any contribution to an Infrastructure Levy for wider scale projects would be relatively modest and inadequate. These financial implications appear to again confirm that the proposals are UNSOUND.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
Further discussion of the points outlined above is essential
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
514. Mr K A Lasbury (Individual) : 16 May 2012 15:29:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.4 - Kendal Sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I have challenged the "soundness" of the overall housing numbers in my representation about the entire document. Those points apply equally to Kendal itself.
The proposals for Kendal are UNSOUND because they fail several of the effectiveness criteria within The Planning Inspectorate Soundness Guidance - there is no sound infrastructure delivery plan and there is not a clear commitment that those who would have to deliver eg Cumbria County Council, United Utilities, Electricity North West etc would/could do so within the timescale of the LDF. Whilst I largely concentrate on traffic issues it is appropriate to raise issues about capacity of the waste water treatment works, the sewerage system, electrical supply issues where the LDF documents do not contain any clear and firm commitment to accommodate the consequences of the deveopment proposed.
TRAFFIC. Cumbria County Council's (most recent) Kendal Traffic Study states that there is congestion now in Kendal. It concludes that there would be "significant increases in congestion as a result of the proposed levels of LDF development". The study tested various "schemes" and concluded that congestion can be mitigated to no worse than base scenario. That conclusion is based on at least 3 very questionable assumptions -
a 5% reduction in traffic from the sustainable travel programme - a figure with no substantiation; such a reduction has probably been achieved in other locations but there is no evidence it could be achieved in Kendal, and not with the programme outlined;
250 vehicles removed from peak hour flows by a Park and Ride site - there is no substantiation of this figure in the study and the County Council's Study report itself casts doubt on the ability to achieve that reduction; additionally there is no commitment to deliver the site itself nor any evidence on the practicalities and (capital and current) financial consequences of operating an effective P&R site.
More realistic (ie lower) figures for both of the above would produce an entirely different analysis with an inevitable deterioration in congestion as a result.
Three pieces of new highway infrastructure are included in the Study - two major new routes - the Northern and Southern Development Routes and a new road connection within the town centre. This is completely UNSOUND as none of these projects have any status with the highway authority; are in no programme; two of them (at least) have had none of the statutory environmental and economic assessments undertaken; none of them have been through any "public process" and thus have little, if any, chance of being delivered within the Plan timeframe.
An earlier, SLDC sponsored traffic study, hurriedly undertaken as part of the LDF process, introduced yet another major project - a Kendal Inner Relief Road. Again that had no status, no assessment, no detail etc.
It is clear that these large projects have only been included in the traffic studies as smoke screens attempting to convince the public and the Inspector that the excessive development proposals could be satisfactorily accommodated in Kendal. In this regard it seems almost unnecessary to repeat that this is UNSOUND.
A part of Kendal suffers from poor air quality and there is an Air Quality Management Area in the centre of town. The first SLDC plan failed to deliver any improvement and similar results are expected of the current document (recent improvements at some sites can probably be attributed to the current poor economic situation). Even if the traffic study conclusions are accepted the combined impact of all LDF development and the extensive infrastructure programme studied would leave the town "no worse than base scenario" - in other words air quality will not improve.
Again,all the above confirms the document is UNSOUND
The Community Infrastructure Levy is suggested as the answer to funding all the wider and community infrastructure needs. I understand that it will not be applied to the affordable housing element of any development and that individual developments may also apply to be exempted on viability grounds. Site specific infrastructure requirements will still have to be funded by the developer through Section 106 Agreements in addition to the Levy.
With the excessive financial demands that will inevitably be placed on each development in terms of school places, direct highway consequences, a 35% affordable housing contribution etc etc, it seems highly likely that any contribution to an Infrastructure Levy for wider scale projects would be relatively modest and inadequate. These financial implications appear to again confirm that the proposals are UNSOUND.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
Further discussion of the points outlined above is essential.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
515. Mr K A Lasbury (Individual) : 16 May 2012 15:31:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.6 Strategic Employment Sites - E4M KENDAL LAND AT SCROGGS WOOD, MILNTHORPE ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The respondent has subsequently clarified that no reference has been made in his response to employment sites, thus text has been withdrawn from this response.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
516. Mr K A Lasbury (Individual) : 16 May 2012 15:32:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.7 Business and Science Park Sites - M2M-mod KENDAL LAND EAST OF BURTON ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The respondent has subsequently clarified that no reference has been made in his response to employment sites, thus text has been withdrawn from this response.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
517. Mr K A Lasbury (Individual) : 16 May 2012 15:41:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.8 Local Employment Sites - All Kendal sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The respondent has subsequently clarified that no reference has been made in his response to employment sites, thus text has been withdrawn from this response.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
518. Mrs I P Lates (Individual) : 23 Apr 2012 16:11:00
Policy/Site No.
LA1.3 Housing Allocations - All Swarthmoor sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The traffic is horrendous at the junction of main road and the A590, if you go ahead with the proposed developements in cross-a-moor and ulverston how do you propose to solve the problem of access now let alone with the extra traffic from the new developements,the road surfaces are not of a standard to accomodate the extra traffic either, also when Trinkeld was built I believe there were terrible problems with flooding , will the new buildings proposed exasperate this problem.
519. Mr Darren Leather (Individual) : 15 Apr 2012 20:16:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - RN117M KENDAL WEST OF VALLEY DRIVE
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
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.
Plenty of more suitable sites, originally on the LA DPD maps for the SLDC district, have not been included on the latest maps.
The evidence above shows that these traffic problems in Kendal will not be fixed before the year 2025 therefore site RN117M is UNSOUND and must be removed from the LA DPD.
New extensions to settlements therefore may be relatively densely designed and built right up against the existing settlement,resulting in green fields being ‘swallowed up’. This will mean they are built on exactly the land of most value to the existing community – the fields or woods at the ends of their gardens, the green edge to the town. Local residents against new development may be accused of ignoring the needs of others for housing, but they have a genuine point. They may not have bought the right to their countryside views, but they certainly have paid for them, and these developments are on exactly the fields of most landscape value to existing residents."
The "Taylor Report" confirms that the proposed system is UNSUSTAINABLE and therefore the development of site RN117M (being a peripheral Green Gap site) is UNSOUND and must be removed from the LA DPD.
This confirms that development of the peripheral Green Gap site RN117M is not sustainable and therefore UNSOUND.
“The Council believes the Planning Authority should follow Taylor and adopt this model in preparing its final Land Allocations policies for Kendal, as the only way in which the NPPF demand for sustainable development can be achieved in the town. It is important to note that this is not in conflict with the Core Strategy positioning of Kendal as a Principal Service Centre, or with the requirements for meeting forecast housing demand. From Taylor, the requirements for sustainable development in rural market towns is clear: it cannot be delivered by allocating isolated sites around the town; a hub and spoke model is required. Even without the NPPF’s insistence on sustainable development, there are other intrinsic advantages to the hub and spoke model for Kendal. The Council’s previous Response to Consultation highlighted the major infrastructure challenges to be overcome in the town. These become far more soluble if development proceeds on hub-by-hub basis, when the infrastructure work can be concentrated on the corresponding spokes. For example, it is far simpler to improve bus services, cycling provision, etc. if only one or two ‘spokes’ have to be addressed.
The evidence in the EHLSS shows that there are suitable sites available (the scope of the SHLAS only covered sites within existing settlement boundaries, and is of less relevance), and there are options both for completely new communities on green field sites, or for breathing new life into existing communities.”
This confirms that the strategy is incorrect for Kendal and should be replaced by the “hub & spoke” strategy. It also confirms that the peripheral Green Gap site RN117M is unsustainable and therefore UNSOUND.
“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; Promoting sustainable transport and achieving a positive impact on the Kendal Air Quality Management Area;
One of the main comments of the people who responded to the SLDC consultations and opposed them was the appearance of Kendal. This is imbedded in the above paragraph and has been totally ignored. The LA DPD is UNSOUND with regard to the above paragraph.Site RN117M IS MENTIONED IN THIS VIEW.
UTILITIES:
South Lakeland District Council does not hold or have access to data/information regarding the catchment area of the Kendal Sewerage Works.”
SLDC/UU admit that the headroom (i.e. spare capacity) is not excessive. Despite this SLDC have no results of any modelling and have not insisted that this modelling be carried out by UU. SLDC do not even know the catchment area for Kendal Sewage Works. There is nothing in the documentation on the SLDC web site to indicate that SLDC do have this information today . Therefore SLDC do not know how many dwellings can be built before Kendal Sewage Works needs a major upgrade costing many millions of pounds.
National Grid Gas Distribution own and operate the local gas distribution network in South Lakeland. The confidential nature of the process means National Grid are unable to confirm whether they are currently processing or have made any offers for connection within Cumbria"
States nothing here about National Grid Gas Distribution having "a statutory duty to develop and maintain an efficient and economical system of water supply within its area."
Meeting “Deliverability” is impossible without all the utility companies signing up to the timescales planned, they can have the proviso that it depends on building going ahead. How can the LA DPD possibly be monitored without signed commitment from the utility companies to the plan timescales. Until they are the LA DPD is UNSOUND.
This Infrastructure document is only a statement; there is no indication when the Infrastructure Delivery Plan will be available to the public or any indication that the timescales can be met. The LA DPD is UNSOUND until the Infrastructure Delivery Plan and the Kendal Transport Plan is available with all milestones agreed and signed off by the respective utility companies.
On a personal note I wish to appeal to those making these decisions:
To Think long and hard about what we are preventing for our future generations to enjoy.Green areas give people a feeling of well being,somewhere to escape the hustle and bustle of our everyday hectic lives.
Yes we need homes for the future,but not by ruining the calmness and tranquility of our green areas
Stay true to the beliefs of the majority of local people and re-assess this DPD,Kendal does not need to ruin it's green belt,,,,STOP THIS URBAN SPRAWL NOW!
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
520. Mr Paul Leech (Individual) : 19 Apr 2012 11:03:00
A typed or handwritten document was submitted. This has been scanned and can be downloaded below:
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I have read the guidance notes
Policy/Site No.
LA1.1 Development Boundaries- CARTMEL
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Delete the proposed extension of the village development boundary. If this is not done then the two sites at the southern end of Allithwaite Road should be excluded from the boundary.
The Parish Council (PC) along with the Planning Officer for SLDC have conducted public information sessions in the Village Hall showing options for development which have been put forward for public comment. Throughout that period the Village Development Boundary (VDB) has been shown in its original position as a broken black line (coloured red on the attached plan).
When SLDC published their Plan on 2 March 2012 for the present Final Consultation and Examination, we saw FOR THE FIRST TIME that the VDB had been massively extended to embrace the Headless Cross area of the village. Enquiries showed that the PC had proposed this in a letter dated 15 April 2011 (LE 1 072 in Council's evidence) to the Planning Officer. Apparently this was the PC's reaction to a petition signed by
nearly all the residents in Headless Cross who had heard that SLDC wanted to make it an independent hamlet, separated from Cartmel. It turned out that SLDC had never made any such proposals (see page 1 of Appendix 8). Despite this the PC had not withdrawn the DVB extension. We consider that the PC's proposal for the extension of the VDB was premature and excessive. Unfortunately the PC and the Planning Officer did not include this proposed boundary change on the maps for the subsequent public consultation sessions. In failing to publish that proposal they inadvertently denied the opportunity for the people of Cartmel to comment upon it at that formative stage. It may be that the advertisements issued by
the SLDC satisfy the legal requirements for public consultation but the man in the street is probably unaware that this change has been made. The objectors believe that there was no need for the extension of the VDB and that it should revert to its original position.
If the proposal to extend the VDB is not rejected then it is requested that the two sites RN148 and RN171 (blue on the attached plan) at the southern end of Allithwaite Road be excluded from the VDB. The PC wrote to the Planning Officer on 16 September 2011 objecting to these two housing proposals but they omitted to ask for the VDB to be amended to exclude both sites. Clearly the PC, having objected to the
development of the two sites, does not want to see them included within the VDB.
The PC has now repeated this objection and requested that the sites be excluded from the VDB. The objectors support this and point out that a similar amendment was made by the Planning Officer when the nearby site at Headless Close RN156 (yellow on attached plan) was withdrawn. The fundamental objection to RN 148 is that it is high above the level of Allithwaite Road and on the inside of a bend which would lead to increased traffic dangers and overbearing development. RN148 and RN171 are both arbitrary extensions of ribbon development into the open countryside in breach of the principles which planners and planning authorities normally strive to prevent.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
In order to be able to respond to points which the LPA may raise on the above issues.
521. MRS BARBARA LEWIS (Individual) : 17 Apr 2012 15:30:00
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Policy/Site No.
LA1.3 Housing Allocations - RN121M-mod LEVENS FORMER POULTRY SHEDS, BRIGSTEER ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not been prepared in accordance with the Town & County Planning Regulations 2004 (as amended)
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The consultation was inadequate.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Building houses in this area is not appropriate. The infrastructure is not adequate - roads, drains, transport. Development of the nunber of houses envisaged for this site should be in the towns or in the villages - not out in the countryside.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
522. Mr & Mrs A.E. and C.A. Line (Individual) : 12 Apr 2012 10:16:00
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I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - RN152 GREENODD LAND AT THE OLD VICARAGE
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
It is not justified in that the vast majority of the local community do not want this site developed, prefering that noted under as AS29 as more appropriate.
It is not effective in that sewage & drainage problems are likely to occur, these having been encountered previously with an adjacent development, and still continue from time to time. Additionally, it is considered there is no demand for further housing, there being some 16 properties on the market in the two villages of Greenodd and Penny Bridge, at various prices, and these have been up for sale for some considerable time. Traffic and parking problems will likely be exacerbated from any development of this site for 22 houses.
Perhaps not particularly relevant, but I consider worthy of mentioning, is the situation regarding the adjacent church and churchyard which provides wonderful views up the Crake Valley to the Coniston mountain range. This being appreciated and taken advantage of, not only by local people, but also by visitors to the church for such as christening, weddings and funerals. In the latter respect much solace is gained by people visiting the graves of the dearly departed, being surrounded by the beautiful views and scenary. This is very much an amenity not to be lost or spoilt by development of this adjoining field.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
523. Mr Neil Little (Individual) : 16 Apr 2012 20:42:00
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I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - R121M-mod KENDAL EAST OF CASTLE GREEN ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The Land Allocations Document (DPD) is not within the Local Development Scheme and the key stages have not been followed
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
The DPD has not had regard to the Sustainable Community Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
• The views of Kendal Town Council, The Friends of the Lake District, various utility companies and the local residents have been ignored. This is both unjustified and illogical.
• This site (R121M) has been rejected for development in the past, and the reasons for this rejection have not changed, namely the real issues over flooding and drainage; the undulating nature of the land; erosion of the green landscape; effect on biodiversity. It is illogical and unreasonable to now include this site in the development plan.
• The plans are based on an overall need for 6,000 new dwellings in South Lakeland over the next 15 years, based on an annual need of 400 dwellings. The October 2011 Strategic Housing Market Assessment has now reduced this annual need to 205 dwellings, so on this basis the overall need should be reduced to under 3,100 new dwellings. However the overall need has not changed, so I would contend that the current plans are based on unreliable and unjustified requirements, and that SLDC is being inflexible.
• Access to this site is apparently now not to be a new road from Castle Green Road, but by extending Oak Tree Road. It would more than double traffic on Oak Tree Road, which is quite unfeasible, given the very difficult access into Oak Tree Road from Castle Green Road, and the narrowness of Oak Tree Road.
• Due to the nature of the site, infrastructure costs will be disproportionately high, which in turn will make the development far more risky and potentially unviable for any developer.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
For the reasons outlined in section 1.3, I believe that this site needs to be taken out of the Land Allocations DPD.
In summary, this proposed development of R121M is based on many unsound premises, including a lack of rigorous research into the site; ignoring the views of the local community and of other interested stakeholders; ignoring past plans for this site; and core strategy policies are not being adhered to.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
524. Mr and Mrs GJD Little (Individual) : 17 May 2012 09:24:00
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I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - R89 GRANGE-OVER-SANDS NORTH OF CARTER ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
1.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
NB: Acknowledgement that the DPD is legally compliant should not be taken to imply support for its contents.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Please find enclosed herewith a Publication Stage Representation Form, duly completed, with reference to the Berry Bank field site variously labelled MN15 R353 or, most recently R89, together with , for reference purposes, a copy of our comments, already received by you, following the Development Team's Open Day in Grange held on April 5th 2011.
It would appear that the above document is legally compliant; however it will be noted that we regard the DPD in its present form as 'unsound', as failing the test we have indicated in section 2.2 on page 4.
For details of objection and indications of how DPD should be amended, see attached sheets A1 & A2 [text detailed below]:
A1: Note: Having telephoned the 'help-line' number 0845 050 4434, we have been assured that the following comment need not be in capital letters, nor need it be restricted to 500 words.
It would seem that, and I quote, 'each comment will require a seperate form'; this being the case, though we consider it a wasteful and scarcely satisfactory procedure, it will be in the circumstances necessary to concentrate on one aspect to illustrate our belief that the DPD in its present form is 'unsound'.
Appendix8 Grange over Sands Emerging Options consultation Stage 1 (Final Version) relates to the area 'Grange South' and the site which is of concern to use, namely MN15, or R89, (Berry Bank field). In it, some twenty or more objections are raised by persons with properties adjoining this site, from the boundary of which one corner of our bungalow is less than five feet.
In a few instances, the council's reply is that the objection is "noted" (presumably meaning 'dismissed'). To one objection, the unbelievable response is that it is "unclear what is meant" by 'disruption due to the construction of dwellings' on the site - followed shortly afterwards by the admission that it would take approximately one year for every thirty houses and would involve "noise and vibration for adjoining properties". Our comment, however, concerns the fact that in more than half of the council's responses is the statement, which might be cynically regarded by some as a 'let-out clause', and I quote -
[A2] "Mitigation measures will be a requirement to offset any potential adverse impact". This statement, in these words in each case, is applied equally to questions as widely diverse as site access, drainage, biodiversity, increase in and disruption to local traffic, etc. No indication is given of what this "mitigation" will involve, who will decide on its definition in the circumstances, what it will cost , or sho precisely will be responsible for its execution, clearly suggesting that the council hasn't as yet made any decisions. The DPD as it stands is therefore clearly 'unsound'. Incidentally, the concluding summary of Appendix 8, as well as stating that site R89 Berry Bank's "hedgerows and trees should be retained" (there are no 'trees' on the site, they are all in the private properties around its perimeter), declares that "opportunities for mitigation and enhancement (another undefined term) should be taken", not "will be required"! For the SLDC Land Allocations DPD to be regarded as sound, the 'mitigating measures', wherever referred to, should be described in detail, rather than being included as a repeated and vaguely worded footnote; until this is done, whatever time it may take, the DPD will not fulfil the criterion of 'soundness'.
[Comments made following the Development Team's Open Day in Grange held on April 5th 2011]:
The Environment of Area MN15 R353 R89:
Access to the above area (by name Bery Bank), at present only by way
of a farm-gate, would, supposing it is proposed to erect numerous
dwellings on this site, be of necessity either from the length of
Allithwaite Road defined by the existing wall and hedge from the
telephone box at the top of the hill (See map: marked B) to the prominent
telegraph pole (marked P), and/or on the southern side from the junction
of Allithwaite Road with Carter Road as far as the 90-degree corner at
Carter Bam, where Kentsford Road leads down to Kents Bank railway
station. Evidently there would be no question of constructing two
entrances, one in the north boundary of the Area and one in the south
boundary having a direct and easy connexion with each other, as the
existence of such north-south route through the Area would encourage its
use as the kind of short-cut familiarly known as a 'rat run'.
To consider first the Allithwaite Road approach to the Area. Drivers
of vehicles climbing the short but steep and winding hill from the town
centre can only see the telephone box (B) at the last moment, and often
encounter cars emerging from the very narrow road on their right leading
to the Guides Lot rubbish disposal site. Having reached the summit of
the hill, it is quite usual, except on the rare occasions when a police
camera van is present, for motorists to exceed the speed limit, there being
no repeat traffic signals at this point to warn them that the 30 mph zone
continues for another 100 or so metres. This and the year-by-year increasing volume of traffic, makes an exit from Cardrona Court (CC), even when the speed limit is observed, not without risk, because of limited visibility.
As regards the southern boundary of the Area, this is at present
defmed by a length of stone wall, behind which the field slopes steeply
upward. Vehicles approaching the 90-degree corner where Carter Road
meets Kentsford Road, whether from the direction of Allithwaite Road or
from the Kents Bank station direction, have very restricted visibility, to
which any southern exit from Berry Bank would pose an additional
hazard. It is quite obvious therefore that any vehicle emerging from Area
MN15 R353 R89, whether from an exit in its northerly or south
boundary, could encounter considerable difficulties, such as even in the
present circumstances are already experienced by residents, particularly
those living along the Allithwaite Road.
Berry Bank (the Area designated MN15 R353 R89}:
To pass now to the subject of how the proposed building of houses on
Berry Bank would affect properties (like ours) directly bordering on the
field itself. My wife and I would not presume to suggest what opinions
other property-owners in this situation might have, but confine ourselves
to our own concerns and anxieties. The first of these is regarding the
question of land drainage. The surface of Berry Bank has at its northern
end a surface measurably higher than parts of our back garden. On
several occasions in the past year, the heavy cloudbursts which are now
becoming more common, even of short duration have produced the
phenomenon of a stream of fast-flowing if shallow water emanating from
the field near the comer of our bungalow (marked M on map), which is
literally only 2 metres from the field boundary, and running past the rear
wall of the bungalow to collect in a sizeable pool by the wooden fence
separating us from our neigbbour. We are in consequence extremely
concerned as to what effect the presence of 45 houses, all requiring
adequate drainage, and the process itself of erecting and servicing these
dwellings (which will certainly interfere with the natural drainage of the
field ), would have on our property. Next, and not entirely unconnected
with this, is our belief that there is insufficient space in Berry Bank field
for such a large number of houses. Surely- and at present no plans seem
to be available - they would have to be small and very close together to
allow for roadways, parking facilities, etc.; and, lest we should be
accused of snobbery, I refrain from adding, not in keeping with their
surroundings. Allowing an average of three occupants and one vehicle for each household, this would result in the appearance in a previously very quiet neighbourhood of perhaps some 150 persons and 50 vehicles.
When, at tbe meeting on April 5th, I ventured to enquire whether the resultant
loss of value {as attractive places for retirement) of local
properties, as well as the loss of privacy, and -in our particular instance the
total loss of our much-admired view across the Bay, would result
perhaps in an adjustment of rateable value. This was, I would not say
ridiculed, but instantly dismissed. Finally, there was at the meeting
reference to 'affordable housing'. Affordable by whom, exactly, in the
present financial situation and for the foreseeable future, with rising unemployment
and sluggishness of some banks as regards mortgages ?
Housing for local people was mentioned, but not where they would be
able to find sufficiently well-paid employment to afford it. What
restrictions would be put in place to ensure that nobody wonld be allowed
to buy more than one property, or buy simply to sub-let ?
Because of the apparent lack of answers to these questions, as well as our
considered opinion that the Area is unsuitable for development, for tbe
reasons we have outlined elsewhere, we oppose the suggestion that the
Area designated MN15 R353 R89, Beery Bank field, should be used.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
525. Mr Neil Little (Individual) : 17 May 2012 09:38:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
0.0 Whole Document
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The Land Allocations Document (DPD) is not within the Local Development Scheme and the key stages have not been followed
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
The DPD has not had regard to the Sustainable Community Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
• The plans are based on an overall need for 6,000 new dwellings in South Lakeland over the next 15 years, based on an annual need of 400 dwellings. The October 2011 Strategic Housing Market Assessment has now reduced this annual need to 205 dwellings, so on this basis the overall need should be reduced to under 3,100 new dwellings. However the overall need has not changed, so I would contend that the current plans are based on unreliable and unjustified requirements, and that SLDC is being inflexible.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
526. Mr and Mrs GJD Little (Individual) : 17 May 2012 10:06:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
1.9
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
1.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
NB: Acknowlegement that the DPD is legally compliant should not be taken to imply support for its contents.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Please find enclosed herewith a Publication Stage Representation Form, duly completed, with reference to the Berry Bank field site variously labelled MN15 R353 or, most recently R89, together with , for reference purposes, a copy of our comments, already received by you, following the Development Team's Open Day in Grange held on April 5th 2011.
It would appear that the above document is legally compliant; however it will be noted that we regard the DPD in its present form as 'unsound', as failing the test we have indicated in section 2.2 on page 4.
For details of objection and indications of how DPD should be amended, see attached sheets A1 & A2 [text detailed below]:
A1: Note: Having telephoned the 'help-line' number 0845 050 4434, we have been assured that the following comment need not be in capital letters, nor need it be restricted to 500 words.
It would seem that, and I quote, 'each comment will require a seperate form'; this being the case, though we consider it a wasteful and scarcely satisfactory procedure, it will be in the circumstances necessary to concentrate on one aspect to illustrate our belief that the DPD in its present form is 'unsound'.
Appendix8 Grange over Sands Emerging Options consultation Stage 1 (Final Version) relates to the area 'Grange South' and the site which is of concern to use, namely MN15, or R89, (Berry Bank field). In it, some twenty or more objections are raised by persons with properties adjoining this site, from the boundary of which one corner of our bungalow is less than five feet.
In a few instances, the council's reply is that the objection is "noted" (presumably meaning 'dismissed'). To one objection, the unbelievable response is that it is "unclear what is meant" by 'disruption due to the construction of dwellings' on the site - followed shortly afterwards by the admission that it would take approximately one year for every thirty houses and would involve "noise and vibration for adjoining properties". Our comment, however, concerns the fact that in more than half of the council's responses is the statement, which might be cynically regarded by some as a 'let-out clause', and I quote -
[A2] "Mitigation measures will be a requirement to offset any potential adverse impact". This statement, in these words in each case, is applied equally to questions as widely diverse as site access, drainage, biodiversity, increase in and disruption to local traffic, etc. No indication is given of what this "mitigation" will involve, who will decide on its definition in the circumstances, what it will cost , or sho precisely will be responsible for its execution, clearly suggesting that the council hasn't as yet made any decisions. The DPD as it stands is therefore clearly 'unsound'. Incidentally, the concluding summary of Appendix 8, as well as stating that site R89 Berry Bank's "hedgerows and trees should be retained" (there are no 'trees' on the site, they are all in the private properties around its perimeter), declares that "opportunities for mitigation and enhancement (another undefined term) should be taken", not "will be required"! For the SLDC Land Allocations DPD to be regarded as sound, the 'mitigating measures', wherever referred to, should be described in detail, rather than being included as a repeated and vaguely worded footnote; until this is done, whatever time it may take, the DPD will not fulfil the criterion of 'soundness'.
[Comments made following the Development Team's Open Day in Grange held on April 5th 2011]:
At the Open Day held by the Development Team at Grange over Sands
on April 5th 2011, the decided impression, not just of my wife and myself
but the audience in general, was that comments by those present
regarding potential housing sites would be of limited value. This was
first because such sites, and the number of dwellings to be erected on
each, had the appearance of having been already decided upon, secondly
because no detailed plans of the layout of the proposed dwellings on each
site seemed to be available for study, and thirdly because in the face of
substantial opposition by the audience, the team's only and oft-repeated
reply was that they had no choice in the matter, by virtue of being compelled by central government, despite what effect the erection of 500
houses might have upon the character of Grange as a tourist attraction
and/or a place to which people might quietly retire.
When, at tbe meeting on April 5th, I ventured to enquire whether the resultant
loss of value {as attractive places for retirement) of local
properties, as well as the loss of privacy, and -in our particular instance the
total loss of our much-admired view across the Bay, would result
perhaps in an adjustment of rateable value. This was, I would not say
ridiculed, but instantly dismissed. Finally, there was at the meeting
reference to 'affordable housing'. Affordable by whom, exactly, in the
present financial situation and for the foreseeable future, with rising unemployment
and sluggishness of some banks as regards mortgages ?
Housing for local people was mentioned, but not where they would be
able to find sufficiently well-paid employment to afford it. What
restrictions would be put in place to ensure that nobody wonld be allowed
to buy more than one property, or buy simply to sub-let ?
Because of the apparent lack of answers to these questions, as well as our
considered opinion that the Area is unsuitable for development, for tbe
reasons we have outlined elsewhere, we oppose the suggestion that the
Area designated MN15 R353 R89, Beery Bank field, should be used.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
527. Mr & Mrs Terence and Barbara Long (Individual) : 9 May 2012 12:34:00
Policy/Site No.
LA1.3 Housing Allocations - R675M-mod HOLME WEST OF BURTON ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I think the area R675M in Holme should be removed from the Development Plan. Many villagers objected to this area, as noted in the 'Comments Book' at the Consultation Day in Home Parish Hall. This is good agricultural land and should be used as such. Once built on it is lost for ever. Please take notice of villagers comments. It is our village that is being overwhelmed by new developments.
Re Local Development Framework- Holme. Area R675M.
I have obtained your "Publication Stage Representation Form" for comments
on the Land Allocations Development Plan Document, and quite frankly have
found it impossible to understand. I am sure a Degree in Law is required,
therefore I hope you will consider the following letter.
I have several comments regarding the proposed Local Development
Framework for Holme village.
1. The overwhelming opinions of villagers in the consultation were against
major housing development, particularly on the R675M area, as their entries in
the 'Comments Book' at the Consultation Day in Holme Parish Hall. These
comments have obviously not been considered during the decision making
process. The village has had a huge amount of building over the last 30
years and is being overwhelmed by it.
Building on this area will mean the urbanisation of the canal tow-path which is
used by villagers and visitors alike, as a "country-side walk" not an urban one.
The land is prime farmland and should be kept for food production not
building. Once land has been built on it is lost forever.
Houses should also be built near to employment as the cost of travelling by
car or public transport is becoming prohibitive.
2. Changes in Government Policy Framework has re-defined "Suitable
Development" to recognise the value of rural, economic and social
development and to protect the intrinsic value of rural areas. The emphasis is
to protect greenfield sites and to favour brownfield sites.
3. Site R675M. Canal Close/Mount Pleasant to Burton Road junction has
previously been restricted to 6 new dwellings in a past planning application
and the current proposal is for a further 59 dwellings! (Incidentally this is an
unadapted road, so who owns it?)
528. Mrs Gill Longfellow (Individual) : 17 Apr 2012 16:31:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA3.2 Mixed Use Allocation at Land South of Allithwaite Road, Kent's Bank, Grange-over-Sands
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Proposed Mixed Use allocation in Policy LA3.2, Land South of Allithwaite Road, Kents Bank, (Inset Map Site Ref M25M) should be removed.
Type and scale of development is inappropriate for environmental capacity of this site.
Local concerns have not been taken adequately into consideration, in line with Localism Act.
The allocation is not in line with national policy in NPPF paras 7, 17, 109, 111, 150 AND 170.
The allocation does not meet the requirements of the Core Strategy policies CS1.2 and CS6.6 which seek to give priority to the re-use of previously developed land and buildings.
The proposed allocation conflicts with the Core Stratey policy CS8.2 as it does not identify a green gap to prevent the hamlet of Kents Bank from coalescence with Grange over Sands, two settlements where it is considered, and has been for many years, important to retain a distinction.
The proposed allocation conflicts with Core Strategy policy CS8.10 which seeks to ensure that development is of a scale and character which maintains or enhances the quality of the landscape or townscape.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Delete the mixed use allocation at Land South of Allithwaite Road, Kents Bank (Inset Map Ref M25M).
The proposed allocation far exceeds the environmental capacity of the site and of the vicinity. It would also cause severe harm to the significant landscape and wildlife interests on the site and in the surrounding area acknowledged to exist in the DPD and Fact Files. The proposed uses are inappropriate.
By including the allocation of this site, the DPD is not considered the most appropriate strategy for the area.
The DPD is not considered to be consistent with national policy in NPPF which seeks to:
a) enhance the local environment through the protection and enhancement of valued landscapes (para 109),
b) enable local people to shape their surroundings whilst having regard to the character of an area, and the conservation and enhancement of the natural environment (para 17),
c) deliver sustainable development through Local Plans that reflects the views and aspirations of local communities (para 150), and
d) encourage the re-use of previously developed land (para 111).
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
529. Mr Peter Lord (Individual) : 17 Apr 2012 11:19:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - RN213-mod BRIGSTEER LAND OPPOSITE THE WHEATSHEAF
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
An exceptional allocation has been made for site RN213 in Brigsteer on the basis of 'the degree of community involvement and support for proposal'. This was because a Community Land Trust steering group had proposed the land for development. This is considered unsound for the following reasons.
1) In an opinion survey of residents in March 2011 where over half of Brigsteer residents responded, 78% were opposed to the development and the Parish Meeting agreed with this opinion.
The results of this opinion survey were included in a response from the Helsington Parish Council which gave conditional support for development on RN213. The parish council said it would prefer smaller scale alternatives and use of existing buildings.
2)A Parish Meeting was called on April 10, 2012 which included proposals from an elector for supporting or opposing development on site RN213. A vote was taken from electors attending the meeting with the result that 20 voted in favour of the site and 31 against. In addition electors were also asked if they would like to vote for development to be delayed until after 2015 and 17 voted in favour.
55 electors asked the Parish Council to consider this voting in response to SLDC.
At the Parish Council meeting the proposal was defeated by four to two due to the fact that four Parish Councillors are also Directors of HCLT and appear to have a possible vested interest.
Development of site RN213 does not have sufficient community support to justify exceptional allocation. I would like the site to be removed from the DPD.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
530. Mr Brian Loveless (Individual) : 20 Apr 2012 08:28:00
A typed or handwritten document was submitted. This has been scanned and can be downloaded below:
Policy/Site No.
LA1.3 Housing Allocations - R697 & part R242 ULVERSTON CROFTLANDS EAST
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I consider that the SLDC's Land Allocation Development Plan consultation process was unsound with regard to the land adjoining Parkhead Road in Ulverston as the issues regarding flooding and sewerage overload raised in my email of 7th February 2011 have not been addressed
Those issues concern the underground stream that runs under plot R242. After wet
weather this sometimes overflows and comes to the surface causing flooding on the
lower lying parts of the plot (photos enclosed). At their worst, these floods have
encroached to within 30 metres of our front door. We are concerned that any
construction work may damage or further restrict the underground drainage, causing
worse flooding. Also, at present the floodwater is clean, since it drains off fields.
However if houses are built on the part liable to flooding, then the water could
become contaminated with sewage.
The stream has its origins in higher ground to the west ofMountbarrow Road, and
flows underground through the limestone until it eventually reaches the surface as a
powerful spring by the roadside near the North Lodge of Conishead Priory.
The stream normally causes no problems except after very wet weather, when the
capacity of the underground watercourse to the east of Parkhead Road becomes
inadequate. The stream then rises to the surface in a series of temporary springs
which flood the fields to the south. As the restricted underground watercourse is a
natural geological feature, it is difficult to see how the flooding could be remedied
without extensive underground operations to run a diversion past the point(s) of
constriction, if these can be identified.
To my knowledge, South Lakeland District Council have made no attempt to address
this problem.
531. Mr and Mrs J Lowther (Individual) : 27 Apr 2012 12:28:00
Policy/Site No.
LA1.3 Housing Allocations - M41KM KENDAL SOUTH OF LUMLEY ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I wish to object to and challenge the soundness of proposal 2C – Land to south of Lumley Rd. and Scroggs Wood Light industrial Site on the following grounds:
- Inadequate local infrastructure including schools, health care, sewerage and roads.
- Milnthorpe road already backs up to the bypass at peak times and cannot accommodate the massive increase that such development, in these locations, would create. Kendal town development to attract visitors is pointless if they cannot obtain satisfactory access. The associated pollution from stationary traffic is incompatible with sustainable development objectives. The soundness of the development is challenged on the basis that there is no traffic plan to address these issues.
- The A6 is a crucial access for emergency services, particularly following the downgrading of Westmorland General Hospital. Further congestion on this route would introduce undue risk. The Soundness of the plan is therefore challenged on safety grounds. To South Lakeland District Council, Development Strategy Team, South Lakeland House, Lowther Street, Kendal, LA9 4UD
- The proposed 2C developments would spoil the initial impression to Kendal visitors, being on the main access route and adjacent to the Town boundary. The Lumley road site is steeply graded and properties would impose on the existing views for existing residents and visitors. The line of trees acts as a natural barrier to the Bellingham Estate. Building to the South of this line would fundamentally change the Kendal “Gateway to the Lakes” character. The Soundness of the plan is therefore challenged on visual impact grounds.
- Loss of green field space is detrimental to the character of the area and contrary to Coalition Government Sustainable Development Policy, which recognizes brown field preference. The Soundness of the plan is therefore challenged as being contrary to Government Planning Policy.
- The proposed mixed use development is incompatible with the character of the historic Helsington development and other existing properties. The Soundness of the plan is therefore challenged as being detrimental to the historical character of the area.
- The site is clearly NOT “in an accessible location or an easily developable level site” (Achievability statement P133 2 C). The Soundness of the plan is therefore challenged as being contrary to this declared planning statement.
- There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of existing residential space and more suitable alternative development sites.
- The Development plan should retain the "Kendal Gateway to the Lakes" image supporting tourism and established Cumbrian employment, not destroy it with unsightly, unnecessary development and traffic jams. You don’t put your wheelie bin on your front door step. I have an alternative suggestion for this site – why not continue its use as sheep farming land?
532. Mr and Mrs J Lowther (Individual) : 27 Apr 2012 12:30:00
Policy/Site No.
LA1.6 Strategic Employment Sites - E4M KENDAL LAND AT SCROGGS WOOD, MILNTHORPE ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I wish to object to and challenge the soundness of proposal 2C – Land to south of Lumley Rd. and Scroggs Wood Light industrial Site on the following grounds:
- Inadequate local infrastructure including schools, health care, sewerage and roads.
- Milnthorpe road already backs up to the bypass at peak times and cannot accommodate the massive increase that such development, in these locations, would create. Kendal town development to attract visitors is pointless if they cannot obtain satisfactory access. The associated pollution from stationary traffic is incompatible with sustainable development objectives. The soundness of the development is challenged on the basis that there is no traffic plan to address these issues.
- The A6 is a crucial access for emergency services, particularly following the downgrading of Westmorland General Hospital. Further congestion on this route would introduce undue risk. The Soundness of the plan is therefore challenged on safety grounds. To South Lakeland District Council, Development Strategy Team, South Lakeland House, Lowther Street, Kendal, LA9 4UD
- The proposed 2C developments would spoil the initial impression to Kendal visitors, being on the main access route and adjacent to the Town boundary. The Lumley road site is steeply graded and properties would impose on the existing views for existing residents and visitors. The line of trees acts as a natural barrier to the Bellingham Estate. Building to the South of this line would fundamentally change the Kendal “Gateway to the Lakes” character. The Soundness of the plan is therefore challenged on visual impact grounds.
- Loss of green field space is detrimental to the character of the area and contrary to Coalition Government Sustainable Development Policy, which recognizes brown field preference. The Soundness of the plan is therefore challenged as being contrary to Government Planning Policy.
- The proposed mixed use development is incompatible with the character of the historic Helsington development and other existing properties. The Soundness of the plan is therefore challenged as being detrimental to the historical character of the area.
- The site is clearly NOT “in an accessible location or an easily developable level site” (Achievability statement P133 2 C). The Soundness of the plan is therefore challenged as being contrary to this declared planning statement.
- There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of existing residential space and more suitable alternative development sites.
- There is spare capacity and expansion potential on existing established trading estates on Shap Road. The plan to relocate the Rugby club to Oxenholme and development of the Gilkes site are more suited to development than Scroggs Wood. The soundness of the case for such development is challenged on the basis of existing and more suitable alternative development sites.
- What and where is the business case and demand for a further speculative light industrial business park? Why would UK businesses move to such a park when financial assistance and tax breaks are available for designated City areas such as the Manchester Enterprise Zone? The soundness of this planned development is challenged on the basis of no demand or business case.
- The Development plan should retain the "Kendal Gateway to the Lakes" image supporting tourism and established Cumbrian employment, not destroy it with unsightly, unnecessary development and traffic jams. You don’t put your wheelie bin on your front door step. I have an alternative suggestion for this site – why not continue its use as sheep farming land?
533. Mr and Mrs J Lowther (Individual) : 27 Apr 2012 12:31:00
Policy/Site No.
LA1.3 Housing Allocations - All Kendal sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of existing residential space and more suitable alternative development sites.
534. Mr and Mrs J Lowther (Individual) : 27 Apr 2012 12:31:00
Paragraph No.
0.0 Whole Document
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Is there a definition of “affordable housing” in the context of Kendal young person income? Or is this merely a rouse to allow land owners and builders to make massive profits, without any tangible commitment to house the low paid of Kendal? The Soundness is therefore challenged on the basis of no defined affordability test.
535. Mr and Mrs J Lowther (Individual) : 27 Apr 2012 12:32:00
Policy/Site No.
LA1.4 - Kendal Sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of existing residential space and more suitable alternative development sites.
536. Mr M Lowther (Individual) : 27 Apr 2012 12:40:00
Policy/Site No.
LA1.3 Housing Allocations - M41KM KENDAL SOUTH OF LUMLEY ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I wish to object to and challenge the soundness of proposal 2C – Land to south of Lumley Rd. and Scroggs Wood Light industrial Site on the following grounds:
- Inadequate local infrastructure including schools, health care, sewerage and roads.
- Milnthorpe road already backs up to the bypass at peak times and cannot accommodate the massive increase that such development, in these locations, would create. Kendal town development to attract visitors is pointless if they cannot obtain satisfactory access. The associated pollution from stationary traffic is incompatible with sustainable development objectives. The soundness of the development is challenged on the basis that there is no traffic plan to address these issues.
- The A6 is a crucial access for emergency services, particularly following the downgrading of Westmorland General Hospital. Further congestion on this route would introduce undue risk. The Soundness of the plan is therefore challenged on safety grounds. To South Lakeland District Council, Development Strategy Team, South Lakeland House, Lowther Street, Kendal, LA9 4UD
- The proposed 2C developments would spoil the initial impression to Kendal visitors, being on the main access route and adjacent to the Town boundary. The Lumley road site is steeply graded and properties would impose on the existing views for existing residents and visitors. The line of trees acts as a natural barrier to the Bellingham Estate. Building to the South of this line would fundamentally change the Kendal “Gateway to the Lakes” character. The Soundness of the plan is therefore challenged on visual impact grounds.
- Loss of green field space is detrimental to the character of the area and contrary to Coalition Government Sustainable Development Policy, which recognizes brown field preference. The Soundness of the plan is therefore challenged as being contrary to Government Planning Policy.
- The proposed mixed use development is incompatible with the character of the historic Helsington development and other existing properties. The Soundness of the plan is therefore challenged as being detrimental to the historical character of the area.
- The site is clearly NOT “in an accessible location or an easily developable level site” (Achievability statement P133 2 C). The Soundness of the plan is therefore challenged as being contrary to this declared planning statement.
- There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of existing residential space and more suitable alternative development sites.
- The Development plan should retain the "Kendal Gateway to the Lakes" image supporting tourism and established Cumbrian employment, not destroy it with unsightly, unnecessary development and traffic jams. You don’t put your wheelie bin on your front door step. I have an alternative suggestion for this site – why not continue its use as sheep farming land?
537. Mr M Lowther (Individual) : 27 Apr 2012 12:42:00
Policy/Site No.
LA1.6 Strategic Employment Sites - E4M KENDAL LAND AT SCROGGS WOOD, MILNTHORPE ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I wish to object to and challenge the soundness of proposal 2C – Land to south of Lumley Rd. and Scroggs Wood Light industrial Site on the following grounds:
- Inadequate local infrastructure including schools, health care, sewerage and roads.
- Milnthorpe road already backs up to the bypass at peak times and cannot accommodate the massive increase that such development, in these locations, would create. Kendal town development to attract visitors is pointless if they cannot obtain satisfactory access. The associated pollution from stationary traffic is incompatible with sustainable development objectives. The soundness of the development is challenged on the basis that there is no traffic plan to address these issues.
- The A6 is a crucial access for emergency services, particularly following the downgrading of Westmorland General Hospital. Further congestion on this route would introduce undue risk. The Soundness of the plan is therefore challenged on safety grounds. To South Lakeland District Council, Development Strategy Team, South Lakeland House, Lowther Street, Kendal, LA9 4UD
- The proposed 2C developments would spoil the initial impression to Kendal visitors, being on the main access route and adjacent to the Town boundary. The Lumley road site is steeply graded and properties would impose on the existing views for existing residents and visitors. The line of trees acts as a natural barrier to the Bellingham Estate. Building to the South of this line would fundamentally change the Kendal “Gateway to the Lakes” character. The Soundness of the plan is therefore challenged on visual impact grounds.
- Loss of green field space is detrimental to the character of the area and contrary to Coalition Government Sustainable Development Policy, which recognizes brown field preference. The Soundness of the plan is therefore challenged as being contrary to Government Planning Policy.
- The proposed mixed use development is incompatible with the character of the historic Helsington development and other existing properties. The Soundness of the plan is therefore challenged as being detrimental to the historical character of the area.
- The site is clearly NOT “in an accessible location or an easily developable level site” (Achievability statement P133 2 C). The Soundness of the plan is therefore challenged as being contrary to this declared planning statement.
- There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of existing residential space and more suitable alternative development sites.
- There is spare capacity and expansion potential on existing established trading estates on Shap Road. The plan to relocate the Rugby club to Oxenholme and development of the Gilkes site are more suited to development than Scroggs Wood. The soundness of the case for such development is challenged on the basis of existing and more suitable alternative development sites.
- What and where is the business case and demand for a further speculative light industrial business park? Why would UK businesses move to such a park when financial assistance and tax breaks are available for designated City areas such as the Manchester Enterprise Zone? The soundness of this planned development is challenged on the basis of no demand or business case.
- The Development plan should retain the "Kendal Gateway to the Lakes" image supporting tourism and established Cumbrian employment, not destroy it with unsightly, unnecessary development and traffic jams. You don’t put your wheelie bin on your front door step. I have an alternative suggestion for this site – why not continue its use as sheep farming land?
538. Mr M Lowther (Individual) : 27 Apr 2012 12:43:00
Policy/Site No.
LA1.3 Housing Allocations - All Kendal sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of existing residential space and more suitable alternative development sites.
539. Mr M Lowther (Individual) : 27 Apr 2012 12:44:00
Paragraph No.
0.0 Whole Document
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Is there a definition of “affordable housing” in the context of Kendal young person income? Or is this merely a rouse to allow land owners and builders to make massive profits, without any tangible commitment to house the low paid of Kendal? The Soundness is therefore challenged on the basis of no defined affordability test.
540. Mr M Lowther (Individual) : 27 Apr 2012 12:45:00
Policy/Site No.
LA1.4 - Kendal Sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of existing residential space and more suitable alternative development sites.
541. Mr John P Lyons (Individual) : 10 May 2012 08:32:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
0.0 Whole Document
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
If adopted the proposals by SLDC will lead, inevitably, to the Market Towns of Kendal and
Ulverston becoming clones of suburbs of cities and the Westmorland villages, in particular
my village of End moor, becoming suburban dormitories ruining their unique sense of
location and place
Whilst a small minority will benefit the 97% majority will be condemned to Environmental
poverty for generations to come
l····My Representation are that the Proposals by SLDC are unsound for 4 reasons
a) That they are contrary to a number of criteria set out in the LDF
b) That they not justified because they are not founded on a robust and credible
evidence base
c) There is no evidence that SLDC have considered alternatives
d) They are not deliverable because the infrastructure delivery planning is unsound
If implemented the effect of these proposals would be that whist a minority of the
community would benefit the majority would suffer environmental poverty for years, if not
generations ,to come
4- There is no evidence that SLDC have considered alternatives
SLDC are required to show that the proposals are the best option of the alternatives
However they have not produced any evidence that they have considered options
This is particularly the case if the non affordable homes aspect is considered. SLDC admit
that they have no idea where the balance of population in excess of ONS Population
Prediction ( some 9,000 persons) will come from
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
542. Mr John P Lyons (Individual) : 10 May 2012 08:37:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - All Endmoor sites
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
SUMMARY
If adopted the proposals by SLDC will lead, inevitably, to the Market Towns of Kendal and
Ulverston becoming clones of suburbs of cities and the Westmorland villages, in particular
my village of End moor, becoming suburban dormitories ruining their unique sense of
location and place
Whilst a small minority will benefit the 97% majority will be condemned to Environmental
poverty for generations to come
l····My Representation are that the Proposals by SLDC are unsound for 4 reasons
a) That they are contrary to a number of criteria set out in the LDF
b) That they not justified because they are not founded on a robust and credible
evidence base
c) There is no evidence that SLDC have considered alternatives
d) They are not deliverable because the infrastructure delivery planning is unsound
If implemented the effect of these proposals would be that whist a minority of the
community would benefit the majority would suffer environmental poverty for years, if not
generations ,to come
3-Not founded on robust and credible evidence
The data produced by SLDC clearly shows Population Projections increase for the Plan
Period of 5,000-which implies an additional housing requirement of 2,500 home for the
District -not the 8.800 stated
Further -the proposals for End moor are for a 30% increase in the footprint of the Village
Development area, a 48% increase in dwellings and an implied 48% increase in population .
These are unsustainable percentages for which SLDC has not produced any evidence of need
For End moor the number of persons on the Housing list is 4, which (based on the 35% rule)
implies a need for 11 homes rather than the 125 proposed. Thus the evidence provided by
SLDC is neither robust nor credible
Further -the proposals for End moor are for a 30% increase in the footprint of the Village
Development area, a 48% increase in dwellings and an implied 48% increase in population .
These are unsustainable percentages for which SLDC has not produced any evidence of need
4- There is no evidence that SLDC have considered alternatives
SLDC are required to show that the proposals are the best option of the alternatives
However they have not produced any evidence that they have considered options
This is particularly the case if the non affordable homes aspect is considered. SLDC admit
that they have no idea where the balance of population in excess of ONS Population
Prediction ( some 9,000 persons) will come from
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
543. Mr John P Lyons (Individual) : 10 May 2012 08:41:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - M41M ENDMOOR NORTH OF SYCAMORE DRIVE
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
2-APPLICATION TO ENDMOOR -Site M41M
CONTRARY TO LDF CRITERIA
The proposals contradict the following LDF criteria
2.1-·CSl.l Sustainable Development Principles --
2-Vital to protect countryside for its ecological value
The Drumlins within and adjacent to M41M are a rare geological and landscape featurethe
scale of the proposed development would have a massive and adverse impact on that
5-it must be ensured that a high quality localised and appropriate design is incorporated into
all developments to retain distinctive character and sense of place-
The density proposed for this development means it is impossible to meet this criterion
6-Most new developments should be directed to existing Service Centres where there is
adequate service and infrastructure capacity to support level of development-----
In End moor there is neither the service or infrastructure capacity
11-Support for tourism needs to be balanced with protecting the attractiveness of the area
The Drumlins within and adjacent to M41M are a rare geological and landscape featurethe
scale of the proposed development would have a massive and adverse impact on that
2.2 CS 5-Environment
Protect and enhance the diverse character and local distinctiveness of the area by high
quality design
The density proposed for M41M will mean that this criterion cannot be met
The majority of buildings in End moor are single storey or if 2 storeys the height is concealed
by the natural contours of the ground. The exception is the development of Sycamore Close
-(abutting M41M )which SLDC recognises is an urban edge ((Reword Strategy)and is an
unacceptable edge to the village. The density of housing proposed for M41M is greater than
that of Sycamore Close therefore rather than meet the requirements of CSS the scale of the
proposed development would in itself contradict the principle of 'high quality design'.
2.3 CS6.6-Making Effective and efficient use of land and buildings
4-Lower building density than 30 dwellings per Ha will be supported if Environmental
constraints mean the site is not suitable for high density development
As explained above the proposed density will contravene CS 5 therefore CS6.6 should be
applied
2.4 CS7 .4-Rural Economy
7he Council recognises the environment as a critical driver in the local economy'
This being so then anything which adversely affects the environment should not be
allowed. The scale and density proposed will have a detrimental effect on the environment
-as already shown by the existing development at Sycamore Close which SLDC
acknowledges as being of urban style
2.6 CS8.2 Protection and enhancement of Landscape and Settlement Character
Para 9.3 .. The visual character af South Lakelands landscape is highly valued by residents and
visitors, High priority must be given ta the protection, conservation and enhancement of this
landscape character --------
The Drumlins within and adjacent to M41M and beyond to Gatebeck Lane are a rare
geological and landscape feature and proposed density of development would be against
the principle of CS 8.2 para 9.3-
2.7 CS8.10-Design
New developments should protect and enhance key local views and features/characteristics
of local importance
The Drumlins within and adjacent to M41M and beyond to Gatebeck Lane are a rare
geological and landscape feature and proposed density of development would be against
the principle of CS 8.2 para 9.3-
4- There is no evidence that SLDC have considered alternatives
SLDC are required to show that the proposals are the best option of the alternatives
However they have not produced any evidence that they have considered options
This is particularly the case if the non affordable homes aspect is considered. SLDC admit
that they have no idea where the balance of population in excess of ONS Population
Prediction ( some 9,000 persons) will come from
5-They are not deliverable because the infrastructure delivery planning is unsound
There are two infrastructure issues -sewerage and roads.
For the first it is acknowledged that the current arrangements are running at capacity yet no
firm proposals have been set down to deal with this
On the roads it is clear that a development of 100 homes (which would imply around 200
+vehicles) would create a major problem exiting on to a very bust stretch of the trunk A65.
No proposals have been set down showing how this issue would be addressed
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
544. Mr John P Lyons (Individual) : 10 May 2012 09:07:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - R670-mod ENDMOOR SOUTH OF BOWLING GREEN
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
3-APPLICATION TO ENDMOOR-Site R670
CONTRARY TO LDF CRITERIA-Application to End moor- SiteR670
The proposals contradict the following LDF criteria
3.1--CSl.lSustainable Development Principles- numbered as follows
2-Vital to protect countryside for its ecological value
The Drumlins and general landscape within, adjacent to and forming part of landscape
around RN670 are a rare geological and landscape feature-the scale of the proposed
development would have a massive and adverse impact on that
5-it must be ensured that a high quality localised and appropriate design is incorporated into
all developments to retain distinctive character and sense of place -
The topography coupled with the density proposed for this development means it is
impossible to meet this criterion
6-Most new developments should be directed to existing Service Centres where there is
adequate service and infrastructure capacity to support level of development-----
In End moor there is neither the service or infrastructure capacity
11-Supportfor tourism needs to be balanced with protecting the attractiveness of the area
The Drumlins and general landscape within, adjacent to and forming part of landscape
around RN670 are a rare geological and landscape feature-the scale of the proposed
development would have a massive and adverse impact on that
3.2 CS 5-Environment
Protect and enhance the diverse character and local distinctiveness of the area by high
quality design
The density proposed for R670 will mean that this criterion cannot be met
3.3 CS6.6-Making Effective and efficient use of land and buildings
4-Lower building density than 30 dwellings per Ha will be supported if Environmental
constraints mean the site is not suitable for high density development
As explained above the proposed density will contravene CS 5 therefore CS6.6 should be
applied
3.4 CS7 .4-Rural Economy
7he Council recognises the environment as a critical driver in the local economy'
This being so then anything which adversely affects the environment should not be allowed.
The scale and density proposed will have a detrimental effect on the environment -as
already shown by the existing development at Sycamore Close which SLDC acknowledges as
being of urban style
3.6 CS8.2 Protection and enhancement of Landscape and Settlement Character
Para 9.3 .. The visual character of South Lakelands landscape is highly valued by residents and
visitors, High priority must be given to the protection, conservation and enhancement of this
landscape character--------
The Drumlins within and adjacent to R 670 and beyond to the M6 are a rare geological and
landscape feature and proposed density of development would be against the principle of
CS 8.2 para 9.3-
3.7 CSS.lO-Design
New developments should protect and enhance key local views and features/characteristics
of local importance
The Drumlins within and adjacent to R 670 and beyond to the MG are a rare geological and
landscape feature and proposed density of development would be against the principle of
CS 8.2 para 9.3-
3-Not founded on robust and credible evidence
The data produced by SLDC clearly shows Population Projections increase for the Plan
Period of 5,000-which implies an additional housing requirement of 2,500 home for the
District -not the 8.800 stated
For End moor the number of persons on the Housing list is 4, which (based on the 35% rule)
implies a need for 11 homes rather than the 125 proposed. Thus the evidence provided by
SLDC is neither robust nor credible
4- There is no evidence that SLDC have considered alternatives
SLDC are required to show that the proposals are the best option of the alternatives
However they have not produced any evidence that they have considered options
This is particularly the case if the non affordable homes aspect is considered. SLDC admit
that they have no idea where the balance of population in excess of ONS Population
Prediction ( some 9,000 persons) will come from
5-They are not deliverable because the infrastructure delivery planning is unsound
There are two infrastructure issues -sewerage and roads.
For the first it is acknowledged that the current arrangements are running at capacity yet no
firm proposals have been set down to deal with this
On the roads it is clear that a development of 25 homes (which would imply around 100
+vehicle movement a day) would create a major problem
There are 3 road junctions where the existing dangers would be heightened
(a) From A65 to Woodside
(b)The immediate turn to Enyeat Road
(c) The 4 way junction abutting the site which would become a 5 way junction.
No proposals have been set down showing how this issue would be addressed
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
545. Mr Peter Major (Individual) : 17 Apr 2012 17:15:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - R121M-mod KENDAL EAST OF CASTLE GREEN ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
We do not believe sufficient consideration has been given to the fact that this is an affluent and picturesque area of the town and would not lend itself, in any way, to being developed under the government proposals for 'low cost housing'. Furthermore, no information as to the cost and impact of basic infrastructure (access roads, services, land drainage, etc.) has been published, or even investigated, and we believe these aspects to be crutial as, due to the sensitivity of the area (widlife and flooding) further developement would be prohibitively expensive and could render existing properties in this area uninsureable due to flood risk.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I refer to my reasonings above and suggest that this area be remove from all future development planning.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
I do not consider this on line 'facility' to be of sufficient deapth and breadth to adequately cover this subject and would welcome further examination of issues raised and the ramifications (possible legal action) of ignoring these, and other, glaring omitions.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
546. Mrs Beryl Mansbridge (Individual) : 16 Apr 2012 08:07:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - RN213-mod BRIGSTEER LAND OPPOSITE THE WHEATSHEAF
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The main reason for including the site RN213 in Brigsteer is because of the 'degree of community involvement and support.' This is unsound because:
1) In December 2010 residents of the parish were invited to a meeting to hear about developments planned on two pieces of woodland in Brigsteer which had been proposed for affordable homes by a Community Land Trust steering group. This was quite a shock for residents of the village as it was the first time they had heard of a CLT being formed. A further meeting was promised for early 2011. This has not yet taken place in spite of repeated requests for democratic communication and consultation with the community.
2) An opinion survey was carried out in March 2011 by a group of local residents. Over half of Brigsteer residents responded, 78% being opposed to the proposed development of RN213. A Parish Meeting followed this survey and was attended by Alastair McNeill and Iain Withington. The opinions expressed agreed with this survey and the results were included in a formal consultation response from the Helsington Parish Council.
3) The initial consultation response from the Parish Council gave only conditional support for development of RN213. It asked for smaller scale alternatives and use of existing buildings and schemes such as 'Home on the Farm' to be explored before any potential development of RN213 in the second phase of the Land Allocation Plan.
4) In September 2011 Helsington Parish Council considered their response to the consultation as to whether sites for development should be allocated in small villages and hamlets. It was unanimously resolved that the policies in the Core Strategy supported by Neighbourhood Plans would be a more appropriate way of identifying and meeting development needs in small villages and hamlets. This was their official response to SLDC.
5) A Helsington Parish Meeting was held on April 10th 2012 at which members of the electorate confirmed their rejection of proposals to develop site RN213 and asked the Parish Council to respond to SLDC accordingly.
It is therefore not sound to assert that the development of site RN213 has sufficient community support to justify exceptional allocation. I would like Brigsteer to be treated in the same way as other small villages and hamlets with RN213 removed from the DPD.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
547. Mr Michael Mansbridge (Individual) : 17 Apr 2012 11:34:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - RN213-mod BRIGSTEER LAND OPPOSITE THE WHEATSHEAF
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The main reason for including the site RN213 in Brigsteer is because of the 'degree of community involvement and support.' This is unsound because:
1) In December 2010 residents of the parish were invited to a meeting to hear about developments planned on two pieces of woodland in Brigsteer which had been proposed for affordable homes by a Community Land Trust steering group. This was quite a shock for residents of the village as it was the first time they had heard of a CLT being formed. A further meeting was promised for early 2011. This has not yet taken place in spite of repeated requests for democratic communication and consultation with the community. No other verbal dialouge has taken place with the electorate.
2) An opinion survey was carried out in March 2011 by a group of local residents. Over half of Brigsteer residents responded, 78% being opposed to the proposed development of RN213. A Parish Meeting followed this survey and was attended by Alastair McNeill and Iain Withington. The opinions expressed agreed with this survey and the results were included in a formal consultation response from the Helsington Parish Council.
3) The initial consultation response from the Parish Council gave only conditional support for development of RN213. It asked for smaller scale alternatives and use of existing buildings and schemes such as 'Home on the Farm' to be explored before any potential development of RN213 in the second phase of the Land Allocation Plan.
4) In September 2011 Helsington Parish Council considered their response to the consultation as to whether sites for development should be allocated in small villages and hamlets. It was unanimously resolved that the policies in the Core Strategy supported by Neighbourhood Plans would be a more appropriate way of identifying and meeting development needs in small villages and hamlets. This was their official response to SLDC.
5) Brigsteer has no basic infrastructure, i.e. one bus a week, no employment other than farming, no school, no shop, no medical services, and The Wheatsheaf our local public house has recently closed. The only people who "need" to live in a small rural village must surely be from the farming community. I would like to see schemes developed that are solely for the local farming community and be protected forever.
6) Directors of the CLT failed to attend the Parish Meeting on March 7th 2012 and the electorate present had to ask for another Parish Meeting with a request that the HCLT should be invited to speak. A Helsington Parish Meeting was held on April 10th 2012 at which members of the electorate confirmed their rejection of proposals to develop RN213. The votes were 20 in favour and 31 against development and the Parish Council were asked to respond accordingly. This request was ignored by the Parish Council.
The Parish Council consists of seven members, five of whom are currently Directors of the HCLT.
It is therefore not sound to assert that the development of site RN213 has sufficient community support to justify exceptional allocation. I would like Brigsteer to be treated in the same way as other small villages and hamlets with RN213 removed from the DPD.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
548. Mrs Christine Marland (Individual) : 12 Apr 2012 14:22:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - All Arnside sites
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
The DPD has not had regard to the Sustainable Community Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
All Arnside sites should be left undeveloped especially R81 and R88. There is no requirement for additional homes for retirees (usually incomers). There is a small need for additional low cost housing. Brownfield sites should be used.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
This is an area within an 'Area of Outstanding National Beauty'. All green areas should be protected for posterity. It is an area for visitors and locals to walk and enjoy.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
549. Mrs Christine Marland (Individual) : 12 Apr 2012 14:32:00
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I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - R81 ARNSIDE REDHILLS ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
The DPD has not had regard to the Sustainable Community Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
All Arnside sites should be left undeveloped especially R81 and R88. There is no requirement for additional homes for retirees (usually incomers). There is a small need for additional low cost housing. Brownfield sites should be used.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
This is an area within an 'Area of Outstanding National Beauty'. All green areas should be protected for posterity.
It is an area for visitors and locals to walk and enjoy.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
550. Mrs Christine Marland (Individual) : 12 Apr 2012 14:45:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - RN337# ARNSIDE STATION RD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
The DPD has not had regard to the Sustainable Community Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
All Arnside sites should be left undeveloped especially R81 and R88. There is no requirement for additional homes for retirees (usually incomers). There is a small need for additional low cost housing. Brownfield sites should be used.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
This is an area within an 'Area of Outstanding National Beauty'. All green areas should be protected for posterity.
It is an area for visitors and locals to walk and enjoy.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
551. Mr Daniel Mason (Individual) : 17 Apr 2012 16:40:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - All Endmoor sites
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The land allocations proposed for Endmoor are excessive compared to the size of Endmoor at this present time. The proposed site (M41M-mod) to the north of Sycamore Close could contain up to 100 houses. The village of Endmoor only contains just over 200 houses approximately and having an expansion of around 50% would be highly damaging for the community as well as being unsustainable.
(a) The primary school would very likely be too small for the resulting village, with the new housing leaving no room for any possible expansion of the school without losing some of its playing field.
(b) The sewage system is at its limit (although I understand there are plans to upgrade those)
(c) The sudden influx of 100 homes worth of people would be likely to destroy the Endmoor community as it is now. It has taken a while to naturally absorb the development of Sycamore Close (28 houses). Endmoor is not just a suburb of Kendal; it is and should remain a village.
(d) The visual impact from the A65 of a development on that site would be great. Sycamore close, a line of fairly nondescript white houses, is bad enough but the development boundary of site M41M-mod would be 3 times longer.
(e) Land Allocation favours the large housing estate builders which destroys any sort of local style and does not support small local builders or those who wish to build their own house and avoid the cost of profit.
(f) There is also an unsustainable boundary creep towards Low Park, resulting in the loss of open green space. Endmoor is becoming out of proportion (spreading far from the traditional centre of the pub, shop and bakery) but this urban sprawl is avoidable.
(g) In the Land Allocations Development Plan Document Endmoor Fact File the Sustainability Appraisal rated sites R660 (part of M41M-mod) and R670 the least well. However this seems to have been ignored when deciding on sites. Site R83, one of three to score best overall has not been included in the land allocation. What is the point in an Appraisal if the results are going to be ignored?
(h) On a broader level Endmoor and other settlements in the normal South Lakeland area are taking all the burden of housing allocation because such a large proportion of the District is in one of two national parks which seem to be taking none of the burden. The national park areas are ones with the highest second home rate and these are the areas that need affordable housing the most therefore they should take some of the burden of housing allocation.
There is a need for homes in Endmoor but not on the large scale proposed. Small scale building over a length of time would allow the community to absorb any new people at a natural and sustainable rate and also allow the burden of housing to be spread around the village.
Changes suggested:
(a) The use of sites R670-mod and R83 would provide smaller areas of housing over a longer period of time. Site R83 is also sustainably better than the other options as proven by South Lakelands own Sustainability Appraisal.
(b) Sites to the west of the A65 around the original centre of the village have not even been considered. Development on these areas (west of A65 between Endmoor Farm and the public clock) would create a more rounded village. A one directional urban sprawl towards Low Park could be curtailed and these sites would also create a steady and more natural expansion of housing in the village.
(c) If any sort of development was to happen on site M41M-mod, it needs to be far smaller and a substantial green space needs to be drawn into the plans at this stage to ensure that it is not dropped from any development. The land to the east of the A65 used to be a coppice called Long Wood therefore a wooded area to screen and contain any further development would be ideal. Any housing needs to be kept away from the school to allow any future expansion and the number of houses that could be absorbed into the community does not want to be any larger than 20-25 houses. However this site is one of the least successful in the Sustainability Appraisal and should only be approached as an option for land allocation when all others have been built upon, which they have not.
(d) On a boarder note more housing should be allocated with in the National Parks (i.e. a joint effort between SLDC and the Nat. Parks). The actions mentioned in the Community Strategy, regarding the raising of council tax on second homes, second home restriction and restriction of the Right To Buy, and should be implemented to effectively bring houses back into the local market. This should run alongside affordable housing allocation with in the Nat. Parks.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
552. Mr Daniel Mason (Individual) : 17 Apr 2012 16:54:00
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I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - RN133M KENDAL WEST OF OXENHOLME ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Site RN133M and RN301M should be reduced in size as they restrict any future extension of the Hospital. At present the hospital building is under-used however with a growing local population and transport costs rising it is highly likley that Westmorland General Hospital will need to be extended at some future point. At least half the area of those sites nearest the hospital should be put aside or preferably labeled for hospital/health development. It is unsustainable to think that there will be no need to expand the hospital in the future.
553. Mr Daniel Mason (Individual) : 18 May 2012 15:31:00
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I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - Site Omission
If you have selected a ‘Site omission’ please enter the site reference or location and relevant policy below
R83
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
(g) In the Land Allocations Development Plan Document Endmoor Fact File the Sustainability Appraisal rated sites R660 (part of M41M-mod) and R670 the least well. However this seems to have been ignored when deciding on sites. Site R83, one of three to score best overall has not been included in the land allocation. What is the point in an Appraisal if the results are going to be ignored?
(a) The use of sites R670-mod and R83 would provide smaller areas of housing over a longer period of time. Site R83 is also sustainably better than the other options as proven by South Lakelands own Sustainability Appraisal.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
554. Mr Daniel Mason (Individual) : 18 May 2012 15:34:00
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I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - M41M ENDMOOR NORTH OF SYCAMORE DRIVE
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The land allocations proposed for Endmoor are excessive compared to the size of Endmoor at this present time. The proposed site (M41M-mod) to the north of Sycamore Close could contain up to 100 houses. The village of Endmoor only contains just over 200 houses approximately and having an expansion of around 50% would be highly damaging for the community as well as being unsustainable.
(a) The primary school would very likely be too small for the resulting village, with the new housing leaving no room for any possible expansion of the school without losing some of its playing field.
(b) The sewage system is at its limit (although I understand there are plans to upgrade those)
(c) The sudden influx of 100 homes worth of people would be likely to destroy the Endmoor community as it is now. It has taken a while to naturally absorb the development of Sycamore Close (28 houses). Endmoor is not just a suburb of Kendal; it is and should remain a village.
(d) The visual impact from the A65 of a development on that site would be great. Sycamore close, a line of fairly nondescript white houses, is bad enough but the development boundary of site M41M-mod would be 3 times longer.
(e) Land Allocation favours the large housing estate builders which destroys any sort of local style and does not support small local builders or those who wish to build their own house and avoid the cost of profit.
(f) There is also an unsustainable boundary creep towards Low Park, resulting in the loss of open green space. Endmoor is becoming out of proportion (spreading far from the traditional centre of the pub, shop and bakery) but this urban sprawl is avoidable.
(g) In the Land Allocations Development Plan Document Endmoor Fact File the Sustainability Appraisal rated sites R660 (part of M41M-mod) and R670 the least well. However this seems to have been ignored when deciding on sites. Site R83, one of three to score best overall has not been included in the land allocation. What is the point in an Appraisal if the results are going to be ignored?
(c) If any sort of development was to happen on site M41M-mod, it needs to be far smaller and a substantial green space needs to be drawn into the plans at this stage to ensure that it is not dropped from any development. The land to the east of the A65 used to be a coppice called Long Wood therefore a wooded area to screen and contain any further development would be ideal. Any housing needs to be kept away from the school to allow any future expansion and the number of houses that could be absorbed into the community does not want to be any larger than 20-25 houses. However this site is one of the least successful in the Sustainability Appraisal and should only be approached as an option for land allocation when all others have been built upon, which they have not.
(d) On a boarder note more housing should be allocated with in the National Parks (i.e. a joint effort between SLDC and the Nat. Parks). The actions mentioned in the Community Strategy, regarding the raising of council tax on second homes, second home restriction and restriction of the Right To Buy, and should be implemented to effectively bring houses back into the local market. This should run alongside affordable housing allocation with in the Nat. Parks.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
555. Mr Daniel Mason (Individual) : 18 May 2012 15:37:00
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I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - R670-mod ENDMOOR SOUTH OF BOWLING GREEN
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The land allocations proposed for Endmoor are excessive compared to the size of Endmoor at this present time. The proposed site (M41M-mod) to the north of Sycamore Close could contain up to 100 houses. The village of Endmoor only contains just over 200 houses approximately and having an expansion of around 50% would be highly damaging for the community as well as being unsustainable.
(a) The primary school would very likely be too small for the resulting village, with the new housing leaving no room for any possible expansion of the school without losing some of its playing field.
(b) The sewage system is at its limit (although I understand there are plans to upgrade those)
(c) The sudden influx of 100 homes worth of people would be likely to destroy the Endmoor community as it is now. It has taken a while to naturally absorb the development of Sycamore Close (28 houses). Endmoor is not just a suburb of Kendal; it is and should remain a village.
(d) The visual impact from the A65 of a development on that site would be great. Sycamore close, a line of fairly nondescript white houses, is bad enough but the development boundary of site M41M-mod would be 3 times longer.
(e) Land Allocation favours the large housing estate builders which destroys any sort of local style and does not support small local builders or those who wish to build their own house and avoid the cost of profit.
(f) There is also an unsustainable boundary creep towards Low Park, resulting in the loss of open green space. Endmoor is becoming out of proportion (spreading far from the traditional centre of the pub, shop and bakery) but this urban sprawl is avoidable.
(g) In the Land Allocations Development Plan Document Endmoor Fact File the Sustainability Appraisal rated sites R660 (part of M41M-mod) and R670 the least well. However this seems to have been ignored when deciding on sites. Site R83, one of three to score best overall has not been included in the land allocation. What is the point in an Appraisal if the results are going to be ignored?
(a) The use of sites R670-mod and R83 would provide smaller areas of housing over a longer period of time. Site R83 is also sustainably better than the other options as proven by South Lakelands own Sustainability Appraisal.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
556. Mr Daniel Mason (Individual) : 18 May 2012 15:45:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.10 Existing Green Infrastructure
If you have selected a ‘Site omission’ please enter the site reference or location and relevant policy below
AS122
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
(g) In the Land Allocations Development Plan Document Endmoor Fact File the Sustainability Appraisal rated sites R660 (part of M41M-mod) and R670 the least well. However this seems to have been ignored when deciding on sites. Site R83, one of three to score best overall has not been included in the land allocation. What is the point in an Appraisal if the results are going to be ignored?
(a) The use of sites R670-mod and R83 would provide smaller areas of housing over a longer period of time. Site R83 is also sustainably better than the other options as proven by South Lakelands own Sustainability Appraisal.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
557. Mr Graham Matthews (Individual) : 11 Apr 2012 20:47:00
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I have read the guidance notes
Policy/Site No.
LA1.1 Development Boundaries- KENDAL
If you have selected a ‘Site omission’ please enter the site reference or location and relevant policy below
Site ref RN169M andRN299*
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The DPD has not had regard to the Sustainable Community Strategy
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Development of this area will spoil an area of beautiful countryside admired and photographed by many tourists .
Cause irreversible traffic problems .
Lead to increased flooding problems for the area north and east of the development .
Many brownfield sites are available without the need to develop open countryside .
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
558. Mr Robert Matthews (Individual) : 26 Apr 2012 09:20:00
A typed or handwritten document was submitted. This has been scanned and can be downloaded below:
Policy/Site No.
LA1.3 Housing Allocations - RN337# ARNSIDE STATION RD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
More notice needs to be taken of the alternatives to greenfield developments and also the fact that the views of many residents and objectors appear to have been ignored. There is also a political split within South Lakeland District Council over the requirement for 6000 additional homes.
In order to make the Development Plan Document sound it needs to
place more emphasis on alternatives to developing greenfield sites
(e.g. utilisation of more brownfield sites, under occupied dwellings,
vacant properties, second homes and use of the Government's £1m.
Empty Homes Fund and Empty Dwellings Management Orders- see
enclosed extracts from the Westmorland Gazette- Annex D): also the
identified need is not supported by the Conservatives on South
Lakeland District Council, so has become a political issue. Hence the
question ofLocal Needs as assessed in the Strategic Housing Market
Assessment (p.9 of the Land Allocations- Sustainability Appraisal
Scoping Report) should be challenged. Only until the above factors
have been re-assessed should the DPD be deemed sound.
With regard to Residential Site RN 337# (Arnside) sufficient regard
has not been taken of the flooding/highway farchealogicalfaesthetic
issues outlined in my submission of 11April2011in connection with
LDFLA. Should any development be approved however it should be at
the S.E. end of the site.
Why have certain sites in Arnside, such as that shown as R693M on
Map 5 of the Options document been discounted, and why has the
disused garage site on Ashleigh Road not been considered for
housing. In September 2011 Arnside Village Society identified more
than 70 dwellings available for sale in the village, so where is the
demand. Arnside already has acute traffic problems. I therefore
dispute the requirement for 86 affordable homes up to the end of the
strategy period (para 3.82 page 83 ofthe LADPD).
The requirement to confine reasoning to 500 words does not permit
space for supporting documentation; hence I have enclosed separate
sheets containing these, including comments on specific paragraphs
of the Scoping and Allocations Document, and hope these are
admissible (Annex B and Annex C).
AnnexB
Supporting Documentation commenting on Specific Issues contained in the
LAND ALLOCATIONS - SUSTAINABILITY APPRAISAL SCOPING REPORT
Page 9 -'Local Needs as assessed in the Strategic Housing Market Assessment."
I doubt the validity of this- See enclosed extracts from the Westmorland
Gazette. (Annex D)
Main Implications for Land Allocations DPD
Page 10 of the 'Framework'
Para 2 -'The South Lakeland District Council Core Strategy target is equivalent
to 8,000 additional dwellings being built between 2003 and 2025 ....................... ,
Particular care must be taken to protect the special landscape of the Arnside and
Silverdale AONB.
I doubt the validity of these statements - see enclosed extracts (Annex D),
and with reoard to the AONB my comments in relation to Site RN337#
(AnnexA)
Built environment and Design
Page 19 Relevant aims and objectives
Para 2 - 'Protecting and enhancing the historic environment and its special
features and qualities as well as its contribution to the character of the area
and recognising the regeneration potential of the heritage environment.'
See above comments
Main Implications for the DPD
Pages 20 and 21 'Land Allocations DPD must demonstrate the application .......... .
to ensure new developments are not at risk of flooding, minimise and
mitigate against any risk and do not increase the risk of flooding elsewhere.'
See my submission in connection with Site RN337# and photo at Annex D.
AnnexC
Supporting Information disputing Specific Issues contained in the
LAND ALLOCATIONS DEVELOPMENT PLAN DOCUMENT relative to Site RN337#
Arnside - page 83
Para 3.82 - I dispute the requirement for 86 affordable homes up to the
end of the Strategy -See my comments in the second half of Annex A.
Page 84- para 3.86 "Avoidance of Flood risk"
See my comments in Annex A and Annex B.
Page 85- para 3.92 " .......... development needs to be accommodated .........
where needs can be met with minimal impact on landscape
quality .. "
See my comments in Annex A and Annex B.
Pages 85 and 86- para 3.93 " ......... The site is highly visible, located at
the main entrance to the village. The quality of the buildings
and landscaping treatment must reflect this high profile
location in an area of national landscape importance."
See my comments in Annex A and Annex B.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
In order to expand on the written documentation and evidence.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
559. Mr Robert Matthews (Individual) : 30 Apr 2012 14:53:00
Paragraph No.
0.0 Whole Document
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
More notice needs to be taken of the alternatives to greenfield developments
In order to make the Development Plan Document sound it needs to
place more emphasis on alternatives to developing greenfield sites
(e.g. utilisation of more brownfield sites, under occupied dwellings,
vacant properties, second homes and use of the Government's £1m.
Empty Homes Fund and Empty Dwellings Management Orders- see
enclosed extracts from the Westmorland Gazette- Annex D): also the
identified need is not supported by the Conservatives on South
Lakeland District Council, so has become a political issue. Hence the
question ofLocal Needs as assessed in the Strategic Housing Market
Assessment (p.9 of the Land Allocations- Sustainability Appraisal
Scoping Report) should be challenged. Only until the above factors
have been re-assessed should the DPD be deemed sound.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
In order to expand on the written documentation and evidence.
560. Mr Robert Matthews (Individual) : 30 Apr 2012 14:57:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - All Arnside sites
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Why have certain sites in Arnside, such as that shown as R693M on
Map 5 of the Options document been discounted, and why has the
disused garage site on Ashleigh Road not been considered for
housing. In September 2011 Arnside Village Society identified more
than 70 dwellings available for sale in the village, so where is the
demand. Arnside already has acute traffic problems. I therefore
dispute the requirement for 86 affordable homes up to the end of the
strategy period (para 3.82 page 83 ofthe LADPD).
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
In order to expand on the written documentation and evidence.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
561. Mr Robert Matthews (Individual) : 30 Apr 2012 15:01:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
7.1 General Comment
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The requirement to confine reasoning to 500 words does not permit
space for supporting documentation; hence I have enclosed separate
sheets containing these, including comments on specific paragraphs
of the Scoping and Allocations Document, and hope these are
admissible (Annex B and Annex C).
There is also a political split within South Lakeland District Council over the requirement for 6000 additional homes.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
In order to expand on the written documentation and evidence.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
562. Mr Robert Matthews (Individual) : 30 Apr 2012 15:05:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
1.10
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
the views of many residents and objectors appear to have been ignored
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
In order to expand on the written documentation and evidence.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
563. Mr Robert Matthews (Individual) : 4 May 2012 10:48:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - Site Omission
If you have selected a ‘Site omission’ please enter the site reference or location and relevant policy below
R693#
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Why have certain sites in Arnside, such as that shown as R693M on
Map 5 of the Options document been discounted
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
in order to expand on written documentation and evidence
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
564. Mr Robert Matthews (Individual) : 4 May 2012 10:49:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - Site Omission
If you have selected a ‘Site omission’ please enter the site reference or location and relevant policy below
RN269#
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
why has the disused garage site on Ashleigh Road not been considered for
housing.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
see other responses
565. Mr Graham Matthews (Individual) : 18 May 2012 11:20:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - RN169M+ RN299# KENDAL WEST OF HIGH SPARROWMIRE
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The DPD has not had regard to the Sustainable Community Strategy
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Development of this area will spoil an area of beautiful countryside admired and photographed by many tourists .
Cause irreversible traffic problems .
Lead to increased flooding problems for the area north and east of the development .
Many brownfield sites are available without the need to develop open countryside .
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
566. Mr Arthur Mayo (Individual) : 4 May 2012 15:15:00
Policy/Site No.
LA1.3 Housing Allocations - M41KM KENDAL SOUTH OF LUMLEY ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Soundness"
Is it sound to not to include the plans for road developments on all potential sites, e.g. the "back up" that happens on the A6 from the south, most of the time.
Should the last inspector's report not be given special credence.
Potential and future brownfield sites given priority over greenfield land.
Kendal as the "Gateway to the Lakes"
be left as it is as per the first inspector's report.
The land towards Scrogg's wood is very visible from the "Bye pass" and A6 also it is very undulating and could lead to skyline development.
Is it sound to have business parks to the south of Kendal, when this has been permitted to the north of the town.
Problems of sewage disposl are still occuring east of the A6 near to Scogg's wood
I hope that these few extra comments on "soundness" are of some help with everyone's deliberations.
Arthur Mayo
567. Mr Arthur Mayo (Individual) : 4 May 2012 15:16:00
Policy/Site No.
LA1.6 Strategic Employment Sites - E4M KENDAL LAND AT SCROGGS WOOD, MILNTHORPE ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Soundness"
Is it sound to not to include the plans for road developments on all potential sites, e.g. the "back up" that happens on the A6 from the south, most of the time.
Should the last inspector's report not be given special credence.
Potential and future brownfield sites given priority over greenfield land.
Kendal as the "Gateway to the Lakes"
be left as it is as per the first inspector's report.
The land towards Scrogg's wood is very visible from the "Bye pass" and A6 also it is very undulating and could lead to skyline development.
Is it sound to have business parks to the south of Kendal, when this has been permitted to the north of the town.
Problems of sewage disposl are still occuring east of the A6 near to Scogg's wood
I hope that these few extra comments on "soundness" are of some help with everyone's deliberations.
Arthur Mayo
568. Ms Lesley McCanney (Individual) : 24 Apr 2012 15:07:00
Policy/Site No.
LA1.3 Housing Allocations - All Burton-in-Kendal sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I am writing to object to the proposed LDF for Burton in Kendal. We have lived in this village since 1992 and have seen the amenities shrink so it seems incredible that housing should expand. The pressure that the new development would put on the sewage, drainage, roads and pavements would be intolerable. The access would also be under strain, at busy school times now it is grid-lock getting around the village. As of yesterday, when Burton Butchers closed, we have one shop in the village. We used to have the shop, a bakers, a post office, a bank, a hairdressers, two pubs and a garage at either end of the village. There is no employment locally for any residents and a bus service which you can only take at limited times of the day, putting more pressure on the roads. The car parking in Burton has always be problematic without another potentially 146 more cars - and that is only counting one car per household. There must surely be more sensible places to build where there is employment, health services, shops, public transport and space etc..
569. Mr/s M A McLay (Individual) : 23 Apr 2012 08:40:00
Policy/Site No.
LA1.3 Housing Allocations - All Grange-over-Sands sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I live in Grange, and my mother lives in Kents Bank. At the moment these are
two well defined entities, but I understand that the SDLC's plan is, not only to
merge these areas, but also to run them into the village of Allithwaite. Keeping
a thin "green" strip, between the newly extended Grange/Kents Bank, and
Allithwaite is just risable.
Apart from the ugly sprawl of hundreds of modem houses being forced upon a
predominantly characterful Edwardian area, which is an abyssmal prospect in
itself, I would be interested to know how the demand for this huge number of
houses was determined? I would appreciate a reply to the way the "demand"
was suggested, and why, and by whom, with some substantiated proof that the demand
for housing actually exists. Grange has approaching 150 homes for sale at present
and this number is currently on the increase.
If provision for local occupancy is required, then it would be more sensible to utilise
the present housing stock, which is immediately available, and could be utilised
very inexpensively, and without any disruption. The council could make the limited
number of purchases as demand arose, and either let them to locals, or sell them
using a scheme which would allow locals to purchase them.
On a more practical note, the infrastructure in the Grange area is already overloaded.
The main street, with its narrowed parking areas, means that cars struggle to get off
the road completely, with all the resulting congestion that that entails. (that was
another piece of foolish planning which we suffer daily) The propsect of many, many
hundreds oflarge lorry journeys through Grange's Main Street is appalling.
In addition, when these houses are occupied, there will be an anticipated additional
500 vehicles to cope with on a daily basis, because the householders will all have
to travel somewhere else to work. Not forgetting the new school provision, which
will be required.
To drop such a large number of people into an area , which cannot provide them
with work is almost embarrassingly ludicrous. And more astonishing, is that you
Planners think that this is a good idea .. .... really??
I think that I have made my opnions fairly clear. Not everyone who opposes this
crazy proposal will take the time to write, but without exageration, I can say that
I have not spoken to one person, who is in favour. To railroad an entire town with
a plan, devised by beaurocrats is wholly unacceptable. It will be opposed at every opportunity until reason prevails.
570. Mr/s M A McLay (Individual) : 10 May 2012 14:54:00
Policy/Site No.
LA3.1 Mixed Use Allocation at Berners Pool, Grange-over-Sands
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I live in Grange, and my mother lives in Kents Bank. At the moment these are
two well defined entities, but I understand that the SDLC's plan is, not only to
merge these areas, but also to run them into the village of Allithwaite. Keeping
a thin "green" strip, between the newly extended Grange/Kents Bank, and
Allithwaite is just risable.
Apart from the ugly sprawl of hundreds of modem houses being forced upon a
predominantly characterful Edwardian area, which is an abyssmal prospect in
itself, I would be interested to know how the demand for this huge number of
houses was determined? I would appreciate a reply to the way the "demand"
was suggested, and why, and by whom, with some substantiated proof that the demand
for housing actually exists. Grange has approaching 150 homes for sale at present
and this number is currently on the increase.
If provision for local occupancy is required, then it would be more sensible to utilise
the present housing stock, which is immediately available, and could be utilised
very inexpensively, and without any disruption. The council could make the limited
number of purchases as demand arose, and either let them to locals, or sell them
using a scheme which would allow locals to purchase them.
On a more practical note, the infrastructure in the Grange area is already overloaded.
The main street, with its narrowed parking areas, means that cars struggle to get off
the road completely, with all the resulting congestion that that entails. (that was
another piece of foolish planning which we suffer daily) The propsect of many, many
hundreds oflarge lorry journeys through Grange's Main Street is appalling.
In addition, when these houses are occupied, there will be an anticipated additional
500 vehicles to cope with on a daily basis, because the householders will all have
to travel somewhere else to work. Not forgetting the new school provision, which
will be required.
To drop such a large number of people into an area , which cannot provide them
with work is almost embarrassingly ludicrous. And more astonishing, is that you
Planners think that this is a good idea .. .... really??
I think that I have made my opnions fairly clear. Not everyone who opposes this
crazy proposal will take the time to write, but without exageration, I can say that
I have not spoken to one person, who is in favour. To railroad an entire town with
a plan, devised by beaurocrats is wholly unacceptable. It will be opposed at every opportunity until reason prevails.
571. Mr/s M A McLay (Individual) : 10 May 2012 15:08:00
Policy/Site No.
LA3.2 Mixed Use Allocation at Land South of Allithwaite Road, Kent's Bank, Grange-over-Sands
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I live in Grange, and my mother lives in Kents Bank. At the moment these are
two well defined entities, but I understand that the SDLC's plan is, not only to
merge these areas, but also to run them into the village of Allithwaite. Keeping
a thin "green" strip, between the newly extended Grange/Kents Bank, and
Allithwaite is just risable.
Apart from the ugly sprawl of hundreds of modem houses being forced upon a
predominantly characterful Edwardian area, which is an abyssmal prospect in
itself, I would be interested to know how the demand for this huge number of
houses was determined? I would appreciate a reply to the way the "demand"
was suggested, and why, and by whom, with some substantiated proof that the demand
for housing actually exists. Grange has approaching 150 homes for sale at present
and this number is currently on the increase.
If provision for local occupancy is required, then it would be more sensible to utilise
the present housing stock, which is immediately available, and could be utilised
very inexpensively, and without any disruption. The council could make the limited
number of purchases as demand arose, and either let them to locals, or sell them
using a scheme which would allow locals to purchase them.
On a more practical note, the infrastructure in the Grange area is already overloaded.
The main street, with its narrowed parking areas, means that cars struggle to get off
the road completely, with all the resulting congestion that that entails. (that was
another piece of foolish planning which we suffer daily) The propsect of many, many
hundreds oflarge lorry journeys through Grange's Main Street is appalling.
In addition, when these houses are occupied, there will be an anticipated additional
500 vehicles to cope with on a daily basis, because the householders will all have
to travel somewhere else to work. Not forgetting the new school provision, which
will be required.
To drop such a large number of people into an area , which cannot provide them
with work is almost embarrassingly ludicrous. And more astonishing, is that you
Planners think that this is a good idea .. .... really??
I think that I have made my opnions fairly clear. Not everyone who opposes this
crazy proposal will take the time to write, but without exageration, I can say that
I have not spoken to one person, who is in favour. To railroad an entire town with
a plan, devised by beaurocrats is wholly unacceptable. It will be opposed at every opportunity until reason prevails.
572. Mr/s M A McLay (Individual) : 10 May 2012 15:09:00
Policy/Site No.
LA3.3 Mixed Use Allocation at Guide's Lot, Grange-over-Sands
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I live in Grange, and my mother lives in Kents Bank. At the moment these are
two well defined entities, but I understand that the SDLC's plan is, not only to
merge these areas, but also to run them into the village of Allithwaite. Keeping
a thin "green" strip, between the newly extended Grange/Kents Bank, and
Allithwaite is just risable.
Apart from the ugly sprawl of hundreds of modem houses being forced upon a
predominantly characterful Edwardian area, which is an abyssmal prospect in
itself, I would be interested to know how the demand for this huge number of
houses was determined? I would appreciate a reply to the way the "demand"
was suggested, and why, and by whom, with some substantiated proof that the demand
for housing actually exists. Grange has approaching 150 homes for sale at present
and this number is currently on the increase.
If provision for local occupancy is required, then it would be more sensible to utilise
the present housing stock, which is immediately available, and could be utilised
very inexpensively, and without any disruption. The council could make the limited
number of purchases as demand arose, and either let them to locals, or sell them
using a scheme which would allow locals to purchase them.
On a more practical note, the infrastructure in the Grange area is already overloaded.
The main street, with its narrowed parking areas, means that cars struggle to get off
the road completely, with all the resulting congestion that that entails. (that was
another piece of foolish planning which we suffer daily) The propsect of many, many
hundreds oflarge lorry journeys through Grange's Main Street is appalling.
In addition, when these houses are occupied, there will be an anticipated additional
500 vehicles to cope with on a daily basis, because the householders will all have
to travel somewhere else to work. Not forgetting the new school provision, which
will be required.
To drop such a large number of people into an area , which cannot provide them
with work is almost embarrassingly ludicrous. And more astonishing, is that you
Planners think that this is a good idea .. .... really??
I think that I have made my opnions fairly clear. Not everyone who opposes this
crazy proposal will take the time to write, but without exageration, I can say that
I have not spoken to one person, who is in favour. To railroad an entire town with
a plan, devised by beaurocrats is wholly unacceptable. It will be opposed at every opportunity until reason prevails.
573. Ms Diane Meakin (Individual) : 2 May 2012 10:21:00
A typed or handwritten document was submitted. This has been scanned and can be downloaded below:
Paragraph No.
0.0 Whole Document
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Please find enclosed maps with annotations which act as general summaries of present remarks regarding this present consultation on Land Allocation, together with this covering letter and a list of those maps the whole together to be MY RESPONSE.
During the last twelve years or even more I have put forward various letter summary papers that refer to land under South Lakeland District Council including that which concluded with the Inquiry of March 2012 into S.L.D.C. Core 2025 Plans. I particularly note this as it was cleared with the assumption that the Council would have the same amount of land at its allocation as from prior than. But since that date both the Lake District National Park and the Yorkshire Dales National Park have made representations to claim parts of this land for their own. Altogether as much as one third of land as at Two Thousand and Ten would be lost to SLDC which makes me wonder the legality of Core 2025 especially as YDNP Planning comes under the North East Regional Board as Sedbergh does now.
(See also attached maps)
574. Ms Diane Meakin (Individual) : 2 May 2012 12:18:00
A typed or handwritten document was submitted. This has been scanned and can be downloaded below:
Policy/Site No.
LA1.3 Housing Allocations - RN133M KENDAL WEST OF OXENHOLME ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
EMPLOYMENT COMBINED:
Nearby estates
"Get up"
"Put to bed"
"Have a bath"
Part time or Full time
Joint jobs = club of offices, teachers, maintenance ..../ vehicles.
Even considered ..... [text omitted - unable to decipher] Outer. Running / walking wheelchair track 9ft width to allow. Small quiet building for service. Seen houses shelters dotted about. My Idea Put ... [text omitted] consultation. The whole of this LAND to be especially catered for over 55's (legal definition - age= could be used PLANNING). While too late for the area known now as The Oaks. I suggested a legal [clause?] as leasees of the land - itself in Trusteeship to preserve major parts as open Parkland. At parts "Hamlets" in different styles according to position. Hamlets = not as told in school as 5 to 6 houses. But small developments which allow for 'pre adjustment for older people - one floor apartments for two comfortably. The buildings below line of road = view preserved and local stone used.
CEGAC club = shares of = small house £. Rules = Kendalians born, leved 20 years +; NOT bought out by 'just returned'. Frees larger houses for families in area. On bus / train routes; local / long distant. Club house capable of meeting / livingroom; Classrooms / hobbies i.e. pottery class. Base level swimming pool; Indoors - outdoors. Close by hospital for general consultation / emergencies. A Clubhouse; cafe for residents with guests allowed; full professional kitchen (work); supplying same and delivery on order to dwellings; anchor point for handle bars.
(see attached document)
575. Ms Diane Meakin (Individual) : 2 May 2012 12:34:00
Policy/Site No.
LA1.7 Business and Science Park Sites - M2M-mod KENDAL LAND EAST OF BURTON ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
1. M2M - completely against; fight and fight again .... Combined employment; Parkland; apartments / hamlets, no roads, exceeds access, quiet building, club house, cafe, classrooms, exercise swimming (Sandgates suggestion type - over subscribed)
2. Completely against this - see Kendal South East Maps; fought in inquiries several times; why restate?
3. I have been in various inquiries over the years where this land has been put forward for use. Each time the Inspector has agreed with our points. One of the greatest views out over the fields to the castle of The Parr family (6th wife of Henry VIII) surrounding it the 'Old Grey Town' of Kendal. Why keep putting it back into such plans except pounds?
4. EMPLOYMENT COMBINED:
Nearby estates
"Get up"
"Put to bed"
"Have a bath"
Part time or Full time
Joint jobs = club of offices, teachers, maintenance ..../ vehicles.
Even considered ..... [text omitted - unable to decipher] Outer. Running / walking wheelchair track 9ft width to allow. Small quiet building for service. Seen houses shelters dotted about. My Idea Put ... [text omitted] consultation. The whole of this LAND to be especially catered for over 55's (legal definition - age= could be used PLANNING). While too late for the area known now as The Oaks. I suggested a legal [clause?] as leasees of the land - itself in Trusteeship to preserve major parts as open Parkland. At parts "Hamlets" in different styles according to position. Hamlets = not as told in school as 5 to 6 houses. But small developments which allow for 'pre adjustment for older people - one floor apartments for two comfortably. The buildings below line of road = view preserved and local stone used.
CEGAC club = shares of = small house £. Rules = Kendalians born, leved 20 years +; NOT bought out by 'just returned'. Frees larger houses for families in area. On bus / train routes; local / long distant. Club house capable of meeting / livingroom; Classrooms / hobbies i.e. pottery class. Base level swimming pool; Indoors - outdoors. Close by hospital for general consultation / emergencies. A Clubhouse; cafe for residents with guests allowed; full professional kitchen (work); supplying same and delivery on order to dwellings; anchor point for handle bars.
576. Ms Diane Meakin (Individual) : 2 May 2012 14:00:00
Policy/Site No.
LA1.9 Green Gaps between - KENDAL and OXENHOLME
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
EMPLOYMENT COMBINED:
Nearby estates
"Get up"
"Put to bed"
"Have a bath"
Part time or Full time
Joint jobs = club of offices, teachers, maintenance ..../ vehicles.
Even considered ..... [text omitted - unable to decipher] Outer. Running / walking wheelchair track 9ft width to allow. Small quiet building for service. Seen houses shelters dotted about. My Idea Put ... [text omitted] consultation. The whole of this LAND to be especially catered for over 55's (legal definition - age= could be used PLANNING). While too late for the area known now as The Oaks. I suggested a legal [clause?] as leasees of the land - itself in Trusteeship to preserve major parts as open Parkland. At parts "Hamlets" in different styles according to position. Hamlets = not as told in school as 5 to 6 houses. But small developments which allow for 'pre adjustment for older people - one floor apartments for two comfortably. The buildings below line of road = view preserved and local stone used.
CEGAC club = shares of = small house £. Rules = Kendalians born, leved 20 years +; NOT bought out by 'just returned'. Frees larger houses for families in area. On bus / train routes; local / long distant. Club house capable of meeting / livingroom; Classrooms / hobbies i.e. pottery class. Base level swimming pool; Indoors - outdoors. Close by hospital for general consultation / emergencies. A Clubhouse; cafe for residents with guests allowed; full professional kitchen (work); supplying same and delivery on order to dwellings; anchor point for handle bars.
(see attached document)
577. Ms Diane Meakin (Individual) : 2 May 2012 14:19:00
A typed or handwritten document was submitted. This has been scanned and can be downloaded below:
Policy/Site No.
LA1.4 Broad Locations for New Housing - BURTON ROAD, KENDAL
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Breaks natural boundaries of town; followed by this SUGGESTED DEVELOPMENT - NO, NO, NO.
(see attached documentation)
578. Ms Diane Meakin (Individual) : 2 May 2012 14:22:00
Policy/Site No.
LA1.3 Housing Allocations - R97 /MN34# KENDAL SOUTH OF NATLAND BECK FARM
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Breaks natural boundaries of town; followed by this SUGGESTED DEVELOPMENT - NO, NO, NO.
Both R97M-mod and MN34# are the SAME PRINCIPLES AS M2M-mod. Prominent positions - green field sites.
Not particularly appealing site of Kendal Canal ... works .... for [text omission - unable to decipher]
579. Ms Diane Meakin (Individual) : 2 May 2012 14:27:00
A typed or handwritten document was submitted. This has been scanned and can be downloaded below:
Policy/Site No.
LA1.8 Local Employment Allocations - E31M KENDAL LAND SOUTH OF K SHOES, NATLAND ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
This was partially suggest for the restoration of Kendal's Canal of which South Lakeland has already paid consultants for feasability studies; Kendal Canal under reopening consideration ..
(see attached document)
Not particularly appealing site of Kendal Canal ... works .... for [text omission - unable to decipher]
ROMAN FORT: Not been completely discovered nor touched in many years. Could be bigger than thought as Watergate ub [text omission - unable to decipher] Defence York Ingleborough ... See vessels = long as well as short route = forts west coast.
580. Ms Diane Meakin (Individual) : 2 May 2012 14:33:00
Policy/Site No.
LA1.3 Housing Allocations - R107M mod and R150M KENDAL KENDAL PARKS
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Not up to railway. ... with all year shrub Tree Screen and Stone Boundaries for houses. Public path joined along with other accesses. Present and in the future.
Consideration to access via farm .. access under railway to Paltis / Road. High Park and via Kendal Park Farm. (Presently barred / wired) As well as various connections to access off Kendal Parks Estate and Cheviot Road (Barretts) such as able to join PS6.
Even starred - must include Park ... strip with all year screening planted NO back gardens visible.
Main visitor approach Lake District, Windermere Railway = disinterested visitors; no visitors; no business; no £'s made; no upkeep.
581. Ms Diane Meakin (Individual) : 2 May 2012 15:16:00
A typed or handwritten document was submitted. This has been scanned and can be downloaded below:
Policy/Site No.
LA1.3 Housing Allocations - All Kendal sites
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
In the Inquiry of March 2010 this Action Plan was mentioned and various other matters arising. Particularly regard a third supermarket that could be classed as 'Town Centre'.
There was reference to the Jubilee Fields (Kendal North East) and fields below West Coast Main Railway Line at Oxenholme off Oxenholme Road. The fact of these large areas of Town removed from Plan Core 2025 and this Land Allocation has sometimes proved difficult to make complete judgements.
Jubilee Fields here guarded - good. But possible some development associated with ex Milk Marketing Board Road (opposite Morrisons / Queen Katherine) could be considered adjacent? By roadside (west) on way to this (new) Business Park - i.e. small units = as Beezon Road ex railway but [text omitted - unable to decipher]
Kendal Old Quarry = 'Penningtons'. Stopped due to water discovered. Limestone filtered = pre historic possibilities? Any heavy machinery / Industrial usage should be properly assessed / sealed surface to reduce contamination.
Still do not like 'blank' of this action plan which has had a variety of suggestions not all good AND includes housing which being separate PLAN does not seem to count towards number called for through The North West Planning Regional Authority which is disconcerting at the least.
On upper northern part of this sheet (see attached plan) I mentioned how the sweep of the bypass but also visible from the Brigsteer Road would be able to view this overrun of new building.
Ironically as Bradley Fields where the old Kendal Horse Racing is still noted is a SSSI - Site of Special Scientific Interest. How long will it remain so when there are bridges to convey dog walkers to and into it. Just a nice 'swing' of a route for a walk. Aside from spoiling the greenfields approach to the Lake District.
Some suggestions - possible walk linkage to northern end of Parkway off PS61.
Query (map ref Kendal South East) - This is water what is the sense of the gas mains near railway?
582. Ms Diane Meakin (Individual) : 2 May 2012 15:24:00
Policy/Site No.
LA1.3 Housing Allocations - R121M-mod KENDAL EAST OF CASTLE GREEN ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Use of this brings buildings closer to the railway. I remarked on this type of closeness in the past. Over the years I have seen the disinterest of train passengers to look out of the window even when the Lake District Hills (National Park) are visible.
I fear that this act of dischantment could tell against future business.
583. Ms Diane Meakin (Individual) : 2 May 2012 16:05:00
Policy/Site No.
LA1.3 Housing Allocations - RN169M+ RN299# KENDAL WEST OF HIGH SPARROWMIRE
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Termage:
'Blood Kendalians' - those people with a very strong connection to the area i.e. born and possible parents also born Kendal (or very near - 5 miles)
This [site] completely breaks the boundaries of Kendal. Completely green fields NEVER BEEN BUILT UPON. Any claims as 'gaps' not what one could call same. This is rising land - top of road is high but houses not easily seen due to screening of gardens. Stone - variable walling too.
At past consultations RN169M & RN299# suggested IF passed for building give special protection. To be built part sunden in GROUND as additional and local co-operative of 'Blood Kendalians'. As all aboe red signed land should be starred for special consideration. Design materials; screening.
584. Ms Diane Meakin (Individual) : 2 May 2012 16:12:00
Policy/Site No.
LA1.4 Broad Locations for New Housing - APPLEBY ROAD, KENDAL
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Low 1 - so named as near watercourse that could be overwhelmed by a new drainage system on this low lying site.
Site 2 - Even bigger possibly.
Both sites bring transport problems to mind. Road narrows and not made for any type of heavy or high volume traffic.
Inquiry, Core 2010 suggested problems; capacity water = Wattsfield Sewage Workd.
Delay on Planning several years.
Size is not given but if one fills in field boundaries in which these are set area is much larger.
My understanding is these red dashed circles denote additional areas under consideration for more buildings. Both are huge areas OUTSIDE present boundaries that are built.
585. Ms Diane Meakin (Individual) : 4 May 2012 09:14:00
Policy/Site No.
LA1.8 Local Employment Allocations - E23K# KENDAL LAND NORTH OF MEADOWBANK BUSINESS PARK
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
This continues the outside boundaries. Problems mentioned below.
Traffic [word omitted] alos apply BUT prefer usage of site to others suggested. Continuation of past extension for employment. Inquiry Core 2010 suggested problems. Capacity waste = Wattsfield Sewage Works. Delay on Planning several years.
586. Ms Diane Meakin (Individual) : 4 May 2012 09:20:00
Policy/Site No.
LA1.8 Local Employment Allocations - E33 KENDAL LAND AT BOUNDARY BANK
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I think this is suggested. New Council Waste site if Canal Head north closed. Water is underneath and should be guarded in sealed surfaces.
587. Ms Diane Meakin (Individual) : 4 May 2012 09:29:00
Policy/Site No.
LA1.3 Housing Allocations - R129M KENDAL SOUTH OF UNDERBARROW ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
This too via lovely old peice of ground with vegetation undistrubed. Surprised - considered due to contours suitable for building upon. Lock out use of heavy machinery DESIGN / TO SITE / Unique development. This is such a disappointment to use these beautiful green fields; not green gaps visible on top of hill coming along on bypass. Hope you can save green lane; very old way; special treatment.
588. Ms Diane Meakin (Individual) : 4 May 2012 09:35:00
Policy/Site No.
LA1.3 Housing Allocations - R31# KENDAL LAND AT VICARAGE DRIVE
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Could be an interesting block of apartments not to be wasted on a few houses. 'Sheltered' by high ground rise = possible security of ground stability. Buildings along railway - see my notes on disenchant visitors to lake District; same applies here.
589. Ms Diane Meakin (Individual) : 4 May 2012 09:45:00
A typed or handwritten document was submitted. This has been scanned and can be downloaded below:
Policy/Site No.
LA1.3 Housing Allocations - M41KM KENDAL SOUTH OF LUMLEY ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
M41KM AGAIN outside the existing town boundaries on green field site. Pleasant approach to Kendal Town with stone used and mature vegetation. Surprised. In future = leads to = red dashed circle (see attached plan)
590. Ms Diane Meakin (Individual) : 4 May 2012 09:56:00
Policy/Site No.
LA1.6 Strategic Employment Sites - E4M KENDAL LAND AT SCROGGS WOOD, MILNTHORPE ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Time and time again; passed accepted boundary of Scroggs Wood green site; partly in possible flood plain.
These green fields on the right into Kendal look across green fields. Once called Area of Outstanding Natural Beauty towards the unspoilt land south of Kendal upwards to the eastern hills that being the town.
591. Ms Diane Meakin (Individual) : 4 May 2012 09:59:00
A typed or handwritten document was submitted. This has been scanned and can be downloaded below:
Policy/Site No.
LA1.3 Housing Allocations - Site Omission
If you have selected a ‘Site omission’ please enter the site reference or location and relevant policy below
Site omission ON56#
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
[Please refer to attached document]
LAND ALLOCATION PLANS CONSULTATION April 2012
This shows employment; industrial - craft outlet, visitor centre. Additional usage of sponsered CCC bus route used by local people. Able to divert before entering village. Main entrance. Easy access to A roads and motorway / bypass.
Re Water Canal - without waiting for reconnection to Lancaster at Tewitfield due to 'CUT OFF' M6 motoway 1962.
As Inquiry evidence, Canal Trust; This section (as shown on map) to be part of Section 3 redevelopment plan to re-water whole length - join onto canal into Lancaster and thence all English / Welsh system navigation as is.
My suggestion - Why wait? from as shown re water whole or from Sedgwick. On present bus route - day tickets available. Could extend to South Kendal - re-water - to Watercrook.
Local housing a solution. Separation from existing housing and yet naturally screened by raising ground.
IDEA - As suggested Core Plan 2025 SLDC and Inquiry 2010; develop fields in a natural screened hollow.
Excavate 5 ft only required (waste riddled stone used)
Two harbour pools on either side of bridge; new returned track access; access only (foot traffic).
East 'Houseboats' local people = local stock building; West - 'visitors' own or hired (i.e. Norfolk Broads); craft 'village' suppliers (workshops / shops / display) chandlers; None vehicle one in park (stone wall screened).
592. Ms Diane Meakin (Individual) : 4 May 2012 10:39:00
Policy/Site No.
LA1.3 Housing Allocations - RN223 OXENHOLME LAND E OF BURTON RD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
This infills a lovely little paddock field; will it lead to more infill up hill joining on between / level Beaswood (Oxenholme)
Later suggested extension - condition of some denied. Sorry if built; would prefer not.
593. Ms Diane Meakin (Individual) : 4 May 2012 10:49:00
Policy/Site No.
LA1.3 Housing Allocations - R108M OXENHOLME LAND S OF FELL CLOSE
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Again field boundary broken - not green gap. Once before put forward to use whole site to Helm Lane - ... wedge to develop whole.
No; not only for key suggested idea.
Completely against R108M.
Parkside and Natland Churches filling; natural burial ground (ashes) & memorial usage of stat reg; nearest to houses [text omission]; "Woodland Walk" - basically Hawthorn trees (reduced sizes) near road; some old natural holly; paths zig-zag = levelled for wheelchair usage; low kerbs = for brass plate memorials. Possible 'Family Section' - as Family grave sites.
594. Ms Diane Meakin (Individual) : 4 May 2012 11:00:00
A typed or handwritten document was submitted. This has been scanned and can be downloaded below:
Policy/Site No.
LA1.3 Housing Allocations - R62 NATLAND WEST OF SEDGWICK RD, NATLAND
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Disappointed - this field has been retained. Hope some consideration is given to surrounding houses and styles. H = was Holmes (see attached document), a local nursery, good quality plants raised on own premises. Now sold and built upon by not very welcoming design; last seen compared with spacing and looks of carefully crafted buildings on north, east and south of same. Hope more care given to any allowed on this site.
595. Ms Diane Meakin (Individual) : 4 May 2012 11:26:00
A typed or handwritten document was submitted. This has been scanned and can be downloaded below:
Policy/Site No.
LA1.3 Housing Allocations - Site Omission
If you have selected a ‘Site omission’ please enter the site reference or location and relevant policy below
Site omission - R120#
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
EMPLOYMENT COMBINED:
Nearby estates
"Get up"
"Put to bed"
"Have a bath"
Part time or Full time
Joint jobs = club of offices, teachers, maintenance ..../ vehicles.
Even considered ..... [text omitted - unable to decipher] Outer. Running / walking wheelchair track 9ft width to allow. Small quiet building for service. Seen houses shelters dotted about. My Idea Put ... [text omitted] consultation. The whole of this LAND to be especially catered for over 55's (legal definition - age= could be used PLANNING). While too late for the area known now as The Oaks. I suggested a legal [clause?] as leasees of the land - itself in Trusteeship to preserve major parts as open Parkland. At parts "Hamlets" in different styles according to position. Hamlets = not as told in school as 5 to 6 houses. But small developments which allow for 'pre adjustment for older people - one floor apartments for two comfortably. The buildings below line of road = view preserved and local stone used.
CEGAC club = shares of = small house £. Rules = Kendalians born, leved 20 years +; NOT bought out by 'just returned'. Frees larger houses for families in area. On bus / train routes; local / long distant. Club house capable of meeting / livingroom; Classrooms / hobbies i.e. pottery class. Base level swimming pool; Indoors - outdoors. Close by hospital for general consultation / emergencies. A Clubhouse; cafe for residents with guests allowed; full professional kitchen (work); supplying same and delivery on order to dwellings; anchor point for handle bars.
Natland - Map 19:
The suggestion on this map has been put forward by both word and in the written. I was disappointed not to see it NOT given the consideration I feel it deserves due to its nature and circumstances of the future. It is, I believe, ideally situated as it is close to Kendal and can be driven, walked , bus or riden to with ease.
It is a quiet locality inspite of this close proximity to the town and easily arrived at from reasons of localities.
Bus x35 to Westmorland General Hospital from Kendal Grange areas = 1 mile. A65 to site [text omitted - unable to decipher]. 555 bus change bus station / Milnthorpe road stops. Also bus 41 town becomes 44 Hallgarth or change Town Hall / Stricklandgate; 567 Kendal to Sedbergh onto Kirkby Stephen - many return to Kendal from same town into Helmside. Bus stops both ways less than 1/2 mile; easy walk Helmside; garage, petrol and shop (see attached document)
596. Ms Diane Meakin (Individual) : 4 May 2012 11:48:00
A typed or handwritten document was submitted. This has been scanned and can be downloaded below:
Policy/Site No.
LA1.3 Housing Allocations - All Oxenholme sites
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Natland - Map 19:
The suggestion on this map has been put forward by both word and in the written. I was disappointed not to see it NOT given the consideration I feel it deserves due to its nature and circumstances of the future. It is, I believe, ideally situated as it is close to Kendal and can be driven, walked , bus or riden to with ease.
It is a quiet locality inspite of this close proximity to the town and easily arrived at from reasons of localities.
Bus x35 to Westmorland General Hospital from Kendal Grange areas = 1 mile. A65 to site [text omitted - unable to decipher]. 555 bus change bus station / Milnthorpe road stops. Also bus 41 town becomes 44 Hallgarth or change Town Hall / Stricklandgate; 567 Kendal to Sedbergh onto Kirkby Stephen - many return to Kendal from same town into Helmside. Bus stops both ways less than 1/2 mile; easy walk Helmside; garage, petrol and shop (see attached document)
Parkside and Natland Churches filling; natural burial ground (ashes) & memorial usage of stat reg; nearest to houses [text omission]; "Woodland Walk" - basically Hawthorn trees (reduced sizes) near road; some old natural holly; paths zig-zag = levelled for wheelchair usage; low kerbs = for brass plate memorials. Possible 'Family Section' - as Family grave sites.
[Text below to be read in conjunction with attached document / plan]
Closed off northern end (Kendal side) former A6 s route cut off.
OD = old road; new drive approach to houses alongside;
G = Field gate off A65; adaptable for easy entrance;
T = trees act as screen on higher ground - natural screen from A65; A65 wide verge; grass flat - possible easy extra space tarred for parking; across road existing layby but never used for walkers up Helm Lane onto The Helme (hill)
E = suggested site of eco friendly toilets; 'natural' with shelter / view / benches = in memorium (?)
No dogs allowed; special tie rail to side. Railway natural filter / barrier down hill view across valley to Scout Scar [some text omitted - unable to decipher]
597. Ms Diane Meakin (Individual) : 4 May 2012 12:09:00
A typed or handwritten document was submitted. This has been scanned and can be downloaded below:
Policy/Site No.
LA1.3 Housing Allocations - Site Omission
If you have selected a ‘Site omission’ please enter the site reference or location and relevant policy below
Land south of R108M
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Natland - Map 19:
Bus x35 to Westmorland General Hospital from Kendal Grange areas = 1 mile. A65 to site [text omitted - unable to decipher]. 555 bus change bus station / Milnthorpe road stops. Also bus 41 town becomes 44 Hallgarth or change Town Hall / Stricklandgate; 567 Kendal to Sedbergh onto Kirkby Stephen - many return to Kendal from same town into Helmside. Bus stops both ways less than 1/2 mile; easy walk Helmside; garage, petrol and shop (see attached document)
Parkside and Natland Churches filling; natural burial ground (ashes) & memorial usage of stat reg; nearest to houses [text omission]; "Woodland Walk" - basically Hawthorn trees (reduced sizes) near road; some old natural holly; paths zig-zag = levelled for wheelchair usage; low kerbs = for brass plate memorials. Possible 'Family Section' - as Family grave sites.
[Text below to be read in conjunction with attached document / plan]
Closed off northern end (Kendal side) former A6 s route cut off.
OD = old road; new drive approach to houses alongside;
G = Field gate off A65; adaptable for easy entrance;
T = trees act as screen on higher ground - natural screen from A65; A65 wide verge; grass flat - possible easy extra space tarred for parking; across road existing layby but never used for walkers up Helm Lane onto The Helme (hill)
E = suggested site of eco friendly toilets; 'natural' with shelter / view / benches = in memorium (?)
No dogs allowed; special tie rail to side. Railway natural filter / barrier down hill view across valley to Scout Scar [some text omitted - unable to decipher]
598. Ms Diane Meakin (Individual) : 4 May 2012 12:18:00
Policy/Site No.
LA1.3 Housing Allocations - M38M BURNESIDE LAND OPPOSITE HOLME HOUSES
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I will just mention this patch of ground M38M. Is just as you are pulling out of Burneside on the train heading to Windermere with the Lake District National Park boundary VERY CLOSE. Apart from this my comments about infill up to the railway line and the disenchantment of our many guests.
I would request:
1. Development is starred for special design requirements (Development Brief for site) AND includes natural stone in both housing and boundary (walls). Together with all year screen - natural planting i.e. holly - can be cut to 10ft high to stop 'urbanization' look - back gardens - seen from train.
599. Ms Diane Meakin (Individual) : 4 May 2012 12:31:00
Policy/Site No.
LA1.3 Housing Allocations - All Burneside sites
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Although I no longer live near Burneside, I am heart [word omitted] of it at times like these. While I am sure others will produce their comments, I will restrict mine to those below while reserving rights to speak, write or otherwise communicate at times as [word omitted] - i.e. in any Inquiry.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
600. Ms Diane Meakin (Individual) : 4 May 2012 12:37:00
Policy/Site No.
LA1.3 Housing Allocations - R489M BURNESIDE LAND ADJ HALL PARK
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Sorry these fields will be built upon while leaving main comments to those most closely concerned. Hope rememberance is given to fact that a lot of stone is in Burneside used in both houses, other buildings and boundary walls. Perhaps particular attention could be paid to this matter over and above normal planning brief and no modern white rendered outsides that are not appropriate to situation.
601. Ms Diane Meakin (Individual) : 4 May 2012 12:40:00
Policy/Site No.
LA1.8 Local Employment Allocations - E32M BURNESIDE LAND ADJ CROPPERS PAPER MILL
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Presume allowance for expansion of mill - no objection; otherwise weary about traffic routes in particular - reserve comments.
602. Ms Diane Meakin (Individual) : 4 May 2012 12:43:00
Policy/Site No.
LA2.13 OUTDOOR SPORTS FACILITIES, SOUTH OF BURNESIDE FOOTBALL CLUB, BURNESIDE
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Not sure what this is supposed to show. Hope not further urbanisation of site with buildings i.e. houses or industrial units. Unless part of flood prevention or similar. Even so would like design brief * star.
603. Ms Diane Meakin (Individual) : 4 May 2012 12:48:00
A typed or handwritten document was submitted. This has been scanned and can be downloaded below:
Policy/Site No.
LA1.10 Existing Green Infrastructure
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
AS100 protection OK [text omitted - unable to decipher] park alongside railway line.
[refer to attached document]
604. Ms Diane Meakin (Individual) : 4 May 2012 12:53:00
Policy/Site No.
LA1.3 Housing Allocations - RN57M MILNTHORPE ADJ. TO ST ANTHONY'S CLOSE
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Think ... [word omission] close to folly; top of hill; too much in view possibly - see from Kent Estuary instead of fold of hills which shields most of village.
605. Ms Diane Meakin (Individual) : 4 May 2012 13:10:00
Policy/Site No.
LA1.8 Local Employment Allocations - M9M1-mod MILNTHORPE LAND ADJACENT TO BRIDGE END BUSINESS PARK, PARK ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Access route difficult? Access route concerns
606. Ms Diane Meakin (Individual) : 4 May 2012 13:12:00
Policy/Site No.
LA1.3 Housing Allocations - R151M-mod MILNTHORPE SOUTH OF MILNTHORPE
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Again out of village boundary. Will it be considered?
607. Ms Diane Meakin (Individual) : 4 May 2012 13:17:00
A typed or handwritten document was submitted. This has been scanned and can be downloaded below:
Policy/Site No.
LA1.4 Broad Locations for New Housing - LAND ADJACENT TO FIRS ROAD, MILNTHORPE
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
[See attached plan - to be read in conjunction with text below:
? Query - are these lands also included inthis marked as possible expansion.
Join up cross hatch marked land around red dashed circle marked for possible expansion. Some screening, natural stone boundary, mature gree retained - needs included if developed.
608. Miss Heather Meek (Individual) : 17 Mar 2012 08:18:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - R51M LEVENS EAST OF GREENGATE CRESCENT
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Current consultation is no consultation at all - specialist knowledge required to respond.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Only one plan for paying for the affordables - unsound in this financial climate.
Current financial climate challenges justification of financial model, making demand uncertain & therefore whether the plan is Effective or Deliverable.
One of core strategy criteria is 'Good’ public transport links so that a settlement is within a 30 minute public transport journey to a GP, a hospital, a primary school, a secondary school, areas of employment and a major retail centre. This will not be possible given the location and if it was why is that not in place now.
National Policy - still in melting pot, revised draft National Policy Planning Framework due out end March.
Inadequate infrastructure (utilities etc.) & no plan or timetable for improvement- United Utilities has no budget for improved sewerage treatment facilities.
No plan for dealing with the 100 plus empty houses in SLDC area
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
609. Mrs Helen Meek (Individual) : 17 Apr 2012 15:06:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
0.0 Whole Document
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The process of making a representation is difficult. It is not easy for members of the general public to understand the process and the criteria by which they should be commenting on the developments. It also disadvantages those that do not have access to the internet. It seems that the process is designed to put people off communicating their views, rather than welcoming their comments, due to the complexity of the process. I was keen to view all the comments made in relation to a designated area. However, the filter system appeared not to work and therefore I resorted to having to view all the comments.
The consultation process has consisted of several different stages. At each stage there has been a request for comments from the general public and interested parties. It seems that many people have invested a great deal of time and energy into preparing their responses. However, these comments are not automatically considered at the next stage of the process and interested parties have to submit their comments again. This strategy does not encourage consultation and could even be viewed cynically as a tactic to reduce the number of responses submitted as the consultation process has proceeded.
I think the DPD is not legally compliant because the process of responding has been difficult and has therefore disenfranchised some sections of the local community.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Overall comments
1. Need for low cost housing
A major problem in this local area is not just the availability of low cost housing (many young people cannot afford the low cost housing that is already available) but the lack of employment opportunities and low paid jobs that are prevalent in the local area. The focus should be on attracting employers that can offer well paid jobs so that our young people can remain in the local area. Also, many of the proposed houses will not be “affordable housing”.
2. Changing Environment
The economic environment has changed since SLDC first embarked on their plan for thousands of new homes. We are now currently in the middle of a global recession and the plans now seem no longer realistic or appropriate.
3. Use of Brown field sites
There are brown field sites within the local area community that have not been used. It is difficult to see how using green field sites can be justified given this fact that will lead to the development of “urban sprawl”.
Specific Comments in relation to
RN223
We feel that the type of housing that is proposed for this area will be too high density and will be out of character with existing properties in this area (individual styles and large gardens)
Flooding may be a potential problem in this area. This field is part of the water catchment area for the Helm. In winter there is almost always surface water visible in this field (suggests significant potential problems and hazard with locating sewage and other underground services).
There will be problems with high levels of noise from the A65 with houses located in this area
It is likely that this development will increase traffic along the already busy A65. Low cost housing is proposed for this site but we feel that this site is located too far from most amenities and work opportunities in Kendal. Therefore, most residents would not be prepared to walk into Kendal and would therefore rely on their cars which will increase traffic.
R108
We feel that the type of housing that is proposed for this area will be too high density and will be out of character with existing properties in this area (individual styles and large gardens). This issue will be exacerbated when combined with the proposed housing on site RN223 on the opposite side of the A65.
There will be problems with high levels of noise from the A65 and the railway with houses located in this area.
It is likely that this development will increase traffic along the already busy A65. Low cost housing is proposed for this site but we feel that this site is located too far from most amenities and work opportunities in Kendal. Therefore, most residents would not be prepared to walk into Kendal and would rely on their cars which will increase traffic.
This development will be highly visible from the Helm and will have a detrimental effect on the views and landscape.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
610. Mrs Helen Meek (Individual) : 18 May 2012 16:46:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
1.9
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The process of making a representation is difficult. It is not easy for members of the general public to understand the process and the criteria by which they should be commenting on the developments. It also disadvantages those that do not have access to the internet. It seems that the process is designed to put people off communicating their views, rather than welcoming their comments, due to the complexity of the process. I was keen to view all the comments made in relation to a designated area. However, the filter system appeared not to work and therefore I resorted to having to view all the comments.
The consultation process has consisted of several different stages. At each stage there has been a request for comments from the general public and interested parties. It seems that many people have invested a great deal of time and energy into preparing their responses. However, these comments are not automatically considered at the next stage of the process and interested parties have to submit their comments again. This strategy does not encourage consultation and could even be viewed cynically as a tactic to reduce the number of responses submitted as the consultation process has proceeded.
I think the DPD is not legally compliant because the process of responding has been difficult and has therefore disenfranchised some sections of the local community.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
611. Mrs Helen Meek (Individual) : 18 May 2012 16:46:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
1.10
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The process of making a representation is difficult. It is not easy for members of the general public to understand the process and the criteria by which they should be commenting on the developments. It also disadvantages those that do not have access to the internet. It seems that the process is designed to put people off communicating their views, rather than welcoming their comments, due to the complexity of the process. I was keen to view all the comments made in relation to a designated area. However, the filter system appeared not to work and therefore I resorted to having to view all the comments.
The consultation process has consisted of several different stages. At each stage there has been a request for comments from the general public and interested parties. It seems that many people have invested a great deal of time and energy into preparing their responses. However, these comments are not automatically considered at the next stage of the process and interested parties have to submit their comments again. This strategy does not encourage consultation and could even be viewed cynically as a tactic to reduce the number of responses submitted as the consultation process has proceeded.
I think the DPD is not legally compliant because the process of responding has been difficult and has therefore disenfranchised some sections of the local community.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
612. Mrs Helen Meek (Individual) : 18 May 2012 16:48:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - RN223 OXENHOLME LAND E OF BURTON RD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Specific Comments in relation to
RN223
We feel that the type of housing that is proposed for this area will be too high density and will be out of character with existing properties in this area (individual styles and large gardens)
Flooding may be a potential problem in this area. This field is part of the water catchment area for the Helm. In winter there is almost always surface water visible in this field (suggests significant potential problems and hazard with locating sewage and other underground services).
There will be problems with high levels of noise from the A65 with houses located in this area
It is likely that this development will increase traffic along the already busy A65. Low cost housing is proposed for this site but we feel that this site is located too far from most amenities and work opportunities in Kendal. Therefore, most residents would not be prepared to walk into Kendal and would therefore rely on their cars which will increase traffic.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
613. Mrs Helen Meek (Individual) : 18 May 2012 16:50:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - R108M OXENHOLME LAND S OF FELL CLOSE
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
R108
We feel that the type of housing that is proposed for this area will be too high density and will be out of character with existing properties in this area (individual styles and large gardens). This issue will be exacerbated when combined with the proposed housing on site RN223 on the opposite side of the A65.
There will be problems with high levels of noise from the A65 and the railway with houses located in this area.
It is likely that this development will increase traffic along the already busy A65. Low cost housing is proposed for this site but we feel that this site is located too far from most amenities and work opportunities in Kendal. Therefore, most residents would not be prepared to walk into Kendal and would rely on their cars which will increase traffic.
This development will be highly visible from the Helm and will have a detrimental effect on the views and landscape.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
614. Mrs. Kathleen Miller (Individual) : 24 Apr 2012 09:37:00
Policy/Site No.
LA1.3 Housing Allocations - RN684 SWM SWARTHMOOR ADJACENT TO KINGSLEY AVENUE
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Contrary to all the information in Council Publications I can find no means at all of protesting against the proposed development of houses at Kingsley Avenue. Therefore I resort to this email.
My protest is against the apparent use of Rufus Lane as an access to the proposed new development. As it stands the amount of car-parking at the junction with Kingsley Avenue and Rufus Lane is an accident waiting to happen. Cars parked on the pavement on either side of the road would force anyone with a push-chair, pram or wheelchair, off the pavement and around the parked vehicle. As I have already said AN ACCIDENT WAITING TO HAPPEN.
Also, the difficulty for vehicles accessing the main road from Rufus Lane has to be experienced to be understood.
I would therefore ask the following questions.
a) HAS ANY COUNCILLOR FROM SOUTH LAKELAND SEEN THE PARKING SITUATION AT THIS PROPOSED SITE?
b) IS ANY COUNCILLOR FROM SOUTH LAKELAND INTERESTED IN SEEING THIS PROPOSED SITE?
c) WOULD ANY COUNCILLOR FROM SOUTH LAKELAND BE PREPARED TO MOVE INTO AN AREA WHERE THESE DIFFICULTIES ARE PREVALENT?
d) IS ANY COUNCILLOR FROM SOUTH LAKELAND PREPARED TO ANSWER FOR THE CONSEQUENCES OF THAT ACCIDENT THAT IS WAITING TO HAPPEN?
On another note. I believe that the number of proposed dwellings exceeds the allowance for the number of houses in a cul-de-sac and exceeds it by a large margin.
I am prepared to look further into this if necessary. HAS ANY SOUTH LAKELAND DISTRICT COUNCILLOR EVEN THOUGHT ABOUT IT?
615. Mr & Mrs Richard & Marilyn Miller (Individual) : 27 Apr 2012 09:10:00
Policy/Site No.
LA1.3 Housing Allocations - M41KM KENDAL SOUTH OF LUMLEY ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Loss of green field space is detrimental to the character and heritage of the area. This is contrary to Coalition Government Sustainable Development Policy, which recognizes brown field preference above important countryside areas. The Soundness and legality of the plan is therefore challenged as being contrary to Government Planning Policy.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I wish to object to and challenge the soundness of proposed land allocation for development – to south of Lumley Rd. (M41KM) and Scroggs Wood Light Industrial Site (E4M) on the following grounds:
- The proposed developments would spoil the initial impression to Kendal visitors, being on the main access route and adjacent to the Town boundary. The Lumley road site is steeply graded and properties would impose on the existing view for Kendal visitors. The line of trees acts as a natural barrier between countryside and properties. Building to the South of this line (E4M), would fundamentally change the Kendal “Gateway to the Lakes” character as a valued landscape. This is contrary to the adopted planning Core Strategy. The Soundness of the plan is therefore challenged on visual impact grounds, contrary to planning policy.
- Loss of green field space is detrimental to the character and heritage of the area. This is contrary to Coalition Government Sustainable Development Policy, which recognizes brown field preference above important countryside areas. The Soundness and legality of the plan is therefore challenged as being contrary to Government Planning Policy.
- Milnthorpe road already backs up to the bypass at peak times and cannot accommodate the massive increase that such development, in these locations, would create. Kendal town development to attract visitors is pointless if they cannot obtain satisfactory access. The associated pollution from stationary traffic is incompatible with sustainable development objectives. The soundness of the development is challenged on the basis that there is no traffic plan to address these issues.
- The A6 is a crucial access for emergency services, particularly following the downgrading of Westmorland General Hospital. Further congestion on this route would introduce undue risk. The potential for accidents when joining the main road would also be significantly increased. The Soundness of the plan is therefore challenged on safety grounds.
- The soundness of the development is challenged on the basis that there is inadequate local infrastructure including drainage, sewerage and roads.
- The proposed development is incompatible with the character of the historic Helsington development contrary to planning policy. The Soundness of the plan is therefore challenged as being detrimental to the historical character of the area.
- The site is clearly NOT “in an accessible location or an easily developable level site” (Achievability statement P133 2 C). The Soundness of the plan is therefore challenged as being contrary to this declared planning statement.
- There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of adequate existing residential space and more suitable alternative development sites.
- The Development plan should retain the "Kendal Gateway to the Lakes" image supporting tourism and established Cumbrian employment, not destroy it with unsightly, unnecessary development and traffic jams. You don’t put your wheelie bin on your front door step! The DPD appears to have completely disregarded the massive opposition and valid objections previously made. The soundness of this planned development is challenged as disregarding local opinion contrary to Government Policy.
616. Mr & Mrs Richard & Marilyn Miller (Individual) : 27 Apr 2012 09:16:00
Policy/Site No.
LA1.6 Strategic Employment Sites - E4M KENDAL LAND AT SCROGGS WOOD, MILNTHORPE ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I wish to object to and challenge the soundness of proposed land allocation for development – to south of Lumley Rd. (M41KM) and Scroggs Wood Light Industrial Site (E4M) on the following grounds:
- The proposed developments would spoil the initial impression to Kendal visitors, being on the main access route and adjacent to the Town boundary. The Lumley road site is steeply graded and properties would impose on the existing view for Kendal visitors. The line of trees acts as a natural barrier between countryside and properties. Building to the South of this line (E4M), would fundamentally change the Kendal “Gateway to the Lakes” character as a valued landscape. This is contrary to the adopted planning Core Strategy. The Soundness of the plan is therefore challenged on visual impact grounds, contrary to planning policy.
- Loss of green field space is detrimental to the character and heritage of the area. This is contrary to Coalition Government Sustainable Development Policy, which recognizes brown field preference above important countryside areas. The Soundness and legality of the plan is therefore challenged as being contrary to Government Planning Policy.
- Milnthorpe road already backs up to the bypass at peak times and cannot accommodate the massive increase that such development, in these locations, would create. Kendal town development to attract visitors is pointless if they cannot obtain satisfactory access. The associated pollution from stationary traffic is incompatible with sustainable development objectives. The soundness of the development is challenged on the basis that there is no traffic plan to address these issues.
- The A6 is a crucial access for emergency services, particularly following the downgrading of Westmorland General Hospital. Further congestion on this route would introduce undue risk. The potential for accidents when joining the main road would also be significantly increased. The Soundness of the plan is therefore challenged on safety grounds.
- The soundness of the development is challenged on the basis that there is inadequate local infrastructure including drainage, sewerage and roads.
- The proposed development is incompatible with the character of the historic Helsington development contrary to planning policy. The Soundness of the plan is therefore challenged as being detrimental to the historical character of the area.
- The site is clearly NOT “in an accessible location or an easily developable level site” (Achievability statement P133 2 C). The Soundness of the plan is therefore challenged as being contrary to this declared planning statement.
- There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of adequate existing residential space and more suitable alternative development sites.
- There is spare capacity and expansion potential on existing established trading estates on Shap Road. The plan to relocate the Rugby club to Oxenholme and development of the Gilkes site are more suited to development than Scroggs Wood. The soundness of the case for such development is challenged on the basis of existing and more suitable alternative development sites compatible with planning policy.
- What and where is the business case and demand for a further speculative light industrial business park? Why would UK businesses move to such a park when financial assistance and tax breaks are available for designated City areas such as the Manchester Enterprise Zone? The soundness of this planned development is challenged on the basis of no established demand or business case.
- The Development plan should retain the "Kendal Gateway to the Lakes" image supporting tourism and established Cumbrian employment, not destroy it with unsightly, unnecessary development and traffic jams. You don’t put your wheelie bin on your front door step! The DPD appears to have completely disregarded the massive opposition and valid objections previously made. The soundness of this planned development is challenged as disregarding local opinion contrary to Government Policy.
617. Mr & Mrs Richard & Marilyn Miller (Individual) : 27 Apr 2012 09:19:00
Policy/Site No.
LA1.3 Housing Allocations - All Kendal sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of adequate existing residential space and more suitable alternative development sites.
618. Mr & Mrs Richard & Marilyn Miller (Individual) : 27 Apr 2012 09:20:00
Paragraph No.
0.0 Whole Document
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Is there a definition of “affordable housing” in the context of Kendal young person income? Or is this merely a rouse to allow land owners and builders to make massive profits, without any tangible commitment to house the low paid of Kendal? The Soundness is therefore challenged on the basis of no defined affordability test.
619. Mr & Mrs Richard & Marilyn Miller (Individual) : 27 Apr 2012 09:22:00
Policy/Site No.
LA1.4 - Kendal Sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of adequate existing residential space and more suitable alternative development sites.
620. Miss A. Mitchell (Individual) : 9 May 2012 15:42:00
Policy/Site No.
LA1.3 Housing Allocations - R121M-mod KENDAL EAST OF CASTLE GREEN ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Please find below my response to the unsoundness of the possible development of the
fields at the top of Oak Tree Road, Kendal which comes under Reference Rl21M in the
SLDC Land Allocation document:-
I find the proposals are unsound on the following points:-
I understand that the SLDC's preferred access to the site may be via Oak Tree Road
which is too narrow for any extra traffic. Also if this is not viable presumably the only
other access is via the field at the rear of Rowan Tree Crescent which would entail great
additional costs in relation to road building, street lighting etc.
There is a colony of Great Crested Newts in and around the pond below the Castle
Green Hotel and we understand that they need at least 500 metres for food, habitation
and hibernation and the greatest threat to this proteeted species is loss of habitat. We
also understand that another colony has been discovered at Broom Close which is on the
northern boundary of the site.
There are many issues of flooding of this area and most of the properties espeeially at
the top of Oak Tree Road and the land at the rear of Rowan Tree Crescent adjoining the
site have been flooded on a regular basis Any additional housing would increase this
problem substantially.
In this respect I ask that the site is withdrawn from the SLDC Land Allocation
document.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
621. Dr G J Moore (Individual) : 10 May 2012 13:22:00
Policy/Site No.
LA1.3 Housing Allocations - RN152 GREENODD LAND AT THE OLD VICARAGE
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The DPD has not had regard to the Sustainable Community Strategy
The Land Allocations Document (DPD) is not within the Local Development Scheme and the key stages have not been followed
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not been prepared in accordance with the Town & County Planning Regulations 2004 (as amended)
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
1. The field is a vilage amenity which gives space and comfort to those who use and visit the church. As a community benefit, open access to everyone it is a priceless asset with fine views to the north and hills;
2. The field is at the highest point in the village and any development is likely to dominate the dwellings in the village below.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
1. The field is a vilage amenity which gives space and comfort to those who use and visit the church. As a community benefit, open access to everyone it is a priceless asset with fine views to the north and hills;
2. The field is at the highest point in the village and any development is likely to dominate the dwellings in the village below;
See also text of supplementary letter below:
The proposed development on this site in Penny Bridge is to be deplored.
The field is the only open space in village of Greenodd and Penny Bridge that has open access. We have no playground nor sports fields, no open area for recreation or to sit in contemplation. The field beside the path from lych gate to church front door is one of the great benefits to living in the village. It has superb vistas to the north to the Coniston hills along the length of the Crake Valley and it provides solace to those attending funerals or visiting graves and great joy to those attending weddings. What a great loss it would be if these pleasures were to be defiled by a housing development.
The housing development opposite the church field, completed some years ago has caused considerable problems to the survace and sewerage in the village which even the new water treatment plant in Greenodd has not yet managed to successfully cope with.
The is NO NEED for further housing. A housing survey in 2008 found no local need and there is a surfeit of houses for sale and rent in Greenodd and Penny Bridge at the present time.
This proposal for development is unnecessary and would b e adespoilation of a wonderful village amenity. It represents environmental vandalism of the highest order and there can be no justification for commercial gain.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
I was chairman of the Parish Council when the original consultation was taking place. I have since retired but retain an interest.
622. Dr G J Moore (Individual) : 10 May 2012 14:11:00
Policy/Site No.
LA1.3 Housing Allocations - RN152 GREENODD LAND AT THE OLD VICARAGE
If you have selected a ‘Site omission’ please enter the site reference or location and relevant policy below
Settlement-wide issues.
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
The DPD has not had regard to the Sustainable Community Strategy
The Land Allocations Document (DPD) is not within the Local Development Scheme and the key stages have not been followed
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not been prepared in accordance with the Town & County Planning Regulations 2004 (as amended)
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
There is no need for additional housing in the village.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
There is no need for additional housing in the village.
There in NO NEED for further housing. A housing survey in 2008 found no local need and there is a surfeit of houses for sale and rent in Greenodd and Penny Bridge at the present time.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
I was chairman of the Parish Council when the original consultation was taking place. I have since retired but retain an interest.
623. Mr & Mrs H F Morphet (Individual) : 11 May 2012 11:02:00
Policy/Site No.
LA1.7 Business and Science Park Sites - M11M - Mod ULVERSTON LAND AT LIGHTBURN ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Following a recent request made by ourselves and a meeting with MP J Woodcock and other local
residents I was advised to put my concerns in writing as appose to a member of your team coming
and seeing us in person to view what we would like to discuss
My wife and I are the tenant farmers at Swarthmoor Hall Farm with sucession for our family to
continue farming here for many years to come. Swarthmoor Hall Farm is the only Organic Dairy Farm
in this area supplying English Lakes Ice-cream with all their milk and Appleby Creamery with all their
Organic milk for cheese making as well as what they produce on behalf of us. We also produce and
deliver Organic milk across the NorthWest from Penrith to Manchester on a daily basis, not
forgetting our doorstep customers and other local milkmen.
Here at the farm not only are our three sons and their partners involved in the business we also
employ a full-time farm worker, a full-time HGV driver and two part-time secretaries.
Swarthmoor Hall Farm consists of 100acres of grazing for our 140 cow herd. In recent years we lost a
large quantity of the grazing around our farm for housing development and this further
development at Swarthmoor Hall Lane/Urswick Road would mean a further 10% loss, not to mention
grazing also being lost due to the Sainsbury's development at The Bee Hive. Surrounding our farm
there is no further grazing available for our cows due to Swarthmoor's ever expending housing and
Ulverston's expending development towards our farm.
Should the development of housing at Swarthmoor Hall Lane/Urswick Road go ahead there will be
massive consequences to our farm and business. Our dairy farm would no longer be a viable
business as we would have to reduce our herd due to lack of grazing resulting in loss of employment,
the loss of our home and the loss of an otherwise secure future for our family. Other environmental
issues we could see facing us would include that to be able to access the grazing at the other side of
the development we would have to walk our herd either along a main urban road or through the
centre of the new housing development. This would in turn result in an increase in noise and smell
pollution to residents as well as increasing health and safety risks. It is very obvious to all parties
involved that increasing the number of people living in this area will in turn also result in an
increased level of vandalism, dog risk to our livestock, fly tipping and other crime.
I also have a grave concern that part of the land in question is known to be wet land. Building next to
or on this would increase risk of flooding and leave me with land I cannot use for arable or grazing. I
must also point out that the land adjacent to the development was used as a Foot & Mouth burial
site during the outbreak in 1968.
My wife and I therefor ask that you reconsider the application made for this housing development in
order to avoid the severe consequences of above.
624. Mr & Mrs H F Morphet (Individual) : 11 May 2012 11:05:00
Policy/Site No.
LA1.3 Housing Allocations - R689 ULVM ULVERSTON NORTH URSWICK ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Following a recent request made by ourselves and a meeting with MP J Woodcock and other local residents I was advised to put my concerns in writing as appose to a member of your team coming and seeing us in person to view what we would like to discuss
My wife and I are the tenant farmers at Swarthmoor Hall Farm with sucession for our family to continue farming here for many years to come. Swarthmoor Hall Farm is the only Organic Dairy Farm in this area supplying English Lakes Ice-cream with all their milk and Appleby Creamery with all their Organic milk for cheese making as well as what they produce on behalf of us. We also produce and deliver Organic milk across the NorthWest from Penrith to Manchester on a daily basis, not forgetting our doorstep customers and other local milkmen.
Here at the farm not only are our three sons and their partners involved in the business we also employ a full-time farm worker, a full-time HGV driver and two part-time secretaries.
Swarthmoor Hall Farm consists of 100acres of grazing for our 140 cow herd. In recent years we lost a large quantity of the grazing around our farm for housing development and this further development at Swarthmoor Hall Lane/Urswick Road would mean a further 10% loss, not to mention grazing also being lost due to the Sainsbury's development at The Bee Hive. Surrounding our farm there is no further grazing available for our cows due to Swarthmoor's ever expending housing and Ulverston's expending development towards our farm.
625. Mr Andrew Mortimer (Individual) : 15 Apr 2012 16:43:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
0.0 Whole Document
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I do not believe that South Lakeland District Council’s Land Allocation Development Plan Document (DPD) should be adopted in relation to planning for Grange-over-Sands and District because it is not sound.
It is not founded on robust and credible evidence, it makes assumptions that are based on out-of-date and poor research and, most importantly, it contains significant inconsistencies across the collection of ‘Local Development Framework’ (LDF) documents and, in particular, discrepancies and contradictions with the Core Strategy.
My principal objections are made on the grounds of:
1. site selection,
2. density
3. impact on transport infrastructure
4. failure to comply with core strategy methodology
1. Site Selection
I do not believe that the sites in Grange-over-Sands, identified for development in this plan, take sufficient account of the “detailed criteria” set out in DPD para 2.23 namely:
“General criteria such as the capacity of the site, the appropriate density at which it could be developed, the ease of accessing the site, the impact of topography and relief and the scope to meet identified needs …”
“Landscape and Settlement considerations including the potential impact of development on landscape and views, the scale of development relative to the settlement size, whether the site preserves the separate identity of settlements and the impact of development on site features such as trees, watercourses and buildings”
I also believe that some development would compromise an identified Green Gap.
For example, this would be the case if development were allowed on the scale proposed on site MN25M which would both visually and effectively join together the settlements of Grange-over-Sands, Kents Bank and Allithwaite.
Proposed development R110 would also compromise an important recreational open space. This is land “which is not accessible to the public but which nonetheless has amenity value because of its openness, appearance or landscape quality.” Using such sites for the density of development proposed contradicts the criteria for preserving Amenity Open Space, suggested in DPD para 2.63. It would also compromise the important recreational open space immediately next to it, turning it into little more than an urban playground.
Further, recommendations in the Grange Regeneration Study (which has informed the Core Strategy) about building a sense of place, business and tourist development etc would also be threatened by the DPD. Currently, as one walks or drives through Grange-over-Sands on the B5277, clear views across Morecambe Bay open out to give the visual and environmental qualities that make Grange unique and which attract visitors. The proposed developments would change those, often tree-lined, views into an unattractive urban ribbon development.
If the objective is “to deliver the vision and objectives set out in the Council’s adopted Core Strategy and help to make South Lakeland the best place to live, work and visit”(DPD 1.5), then the DPD choice of development sites in Grange-over-Sands must be considered more carefully.
2. Density
The DPD has not taken notice of the Core Strategy’s overarching development strategy (CS1.2), with regard to the impact that the suggested density of housing development in Grange-over-Sands would have in general on the landscape, historic setting, and the environment. Under the DPD proposals, between Grange Station and Kents Bank, all but one “greenfield” site would disappear.
The volume of housing development proposed is out of character and will change the unique and special nature of the area. It is not “moderate” as the Core Strategy would claim (Policy CS4).
500 dwellings in Grange-over-Sands would increase the current population by at least 25%.
I do not believe that an increase in population of a quarter could be considered “moderate”. Even the Local Transport Plan for South Lakeland (CCC Local Transport Plan 3, “Moving Cumbria Forward”, 2011 – 2016) describes this as “substantial housing allocation”.
In addition, some of the individual sites challenge the Core Strategy with regard to density of housing. “Core Strategy Policy CS6.6 seeks an average density of 30 dwellings per hectare, with higher densities in town centres and locations with good public transport and lower densities in areas where there are environmental constraints.”
There is a clear breach of this policy in regard to site R110, south of Thornfield Road, where the DPD recommends building 66 dwellings on only 1.83 ha. This is not a town centre site and is not a location with good public transport.
3. Impact on Transport Infrastructure
The DPD, by placing all the emphasis on development in Grange South, ignores the Core Strategy’s warning (CS5.32) that “given the problem of town centre congestion in Grange at peak times…. significantly higher traffic levels could well threaten the core economic activity of the town, namely tourism”.
An increase in population, on the scale proposed in the plan, would certainly result in at least 25% more traffic which would challenge its ambition of
“promoting the vitality of Grange Town Centre and promoting tourism”. (DPD 4.2)
The final plan seems to ignore the fact that,
“The main B5277 road runs through the heart of Grange over Sands … In places this road narrows and on some stretches, there is a feeling of car domination.”
(SLDC Framework Land Allocations Development Plan Document Consultation on emerging site options – Grange over Sands)
The Core Strategy also suggests 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.” (CS5.12)
Statistics from “count points” on the A590 show that between the Meathop Roundabout and Newby Bridge over 5000 vehicles joined or left the A590 per day in 2010. (Highways Agency Cumbria AADF statistics 2011) This confirms that there is already an extremely high volume of traffic coming in and out of the Cartmel Peninsula on unsuitable roads. Even The Development Plan itself admits,
“Elsewhere in the peninsula … the road network … is constrained in places.” (DPD 4.1)
It is likely to become very much more “constrained” if the volume of traffic grows by almost 25% in line with the proposed population increase in Grange-over-Sands, not forgetting the fact that,
“Car ownership levels in Grange … are high, with 80.7% of households having access to a car or van (compared to a Cumbria average of 75.6%)”.
(SLDC Framework Land Allocations Development Plan Document Consultation on emerging site options – Grange over Sands)
Even more significant is the apparent failure of SLDC to consider the impact of its plans for Grange-over-Sands, the Cartmel Peninsula and Ulverston together, on the wider transport infrastructure and especially the increase in volume of traffic on the A590. Whatever the discussions SLDC have had with The Highways Agency, the latter have no plans for improvements to the A590 before 2025 except a possible roundabout construction at Greenodd. A spokesman has told me that “Our current major scheme programme does not include any schemes on the A590”.
The most recent average annual daily flow (AADF) figures for the A590 show a steady increase of traffic on this road over the last 10 years, with almost 4000 more vehicles travelling daily in 2010 than in 2009. (Highways Agency Cumbria AADF statistics 2011)
This volume of traffic would be increased significantly by the proposals in the DPD for housing and industrial development in Cartmel Peninsula and Ulverston.
In the Cumbria County Council Local Transport Plan 2006 – 2011, it was noted that,
"The A590 between the Furness peninsula and the M6 motorway has several constrictions, including passing through Ulverston and ... long single carriageway sections with unimproved alignments. This causes unreliable and extended journey times between Furness and the rest of the region and UK, impeding economic development. The worsening position regarding average journey times on A590 has already been noted in the context of road safety”
What this means, according to provisional data published by the Highways Agency, is that on average only about 65% of journeys undertaken on A590 in 2011 were ‘on time’.(The national average for ‘on-time’ journeys was approximately 85%)(Journey Reliability Data to November 2011 – data.gov.uk)
In addition, Cumbria Constabulary has unofficially acknowledged that there were 3 fatalities and 6 serious injuries as a result of accidents in 2011 on the A590, making it the worst road in Cumbria for fatal accidents over the past 10 years.
If the potential increase in traffic as a result of DPD is added to the Department of Transport's own national statistical projections for 2025 of a 25% increase in volume of all traffic, and an increase in car ownership of 30% (Table TRA 9905), I believe that the actual increase in traffic on this dangerous road is likely to be at least 50% by 2025.
4. Failure to Comply with Core Strategy Methodology
Core Strategy clearly lays out a sequence for the planning process.
CS1.1 sets out “Sustainable Development Principles” including
“Development should accord with the following sequential approach:
• first, using existing buildings (including conversion) within settlements, and previously
developed land within settlements;
• second, using other suitable infill opportunities within settlements;
• third, the development of other land where this is well located in relation to housing, jobs, other services and infrastructure.”
CS1.2 states “Priority will be given to the reuse of existing buildings and previously developed land for all new housing development”
The question is now raised as to whether, in the light of the withdrawal of the Berner’s site proposals in Grange-over-Sands (25/01/12), these DPD plans might no longer be seen as having a ‘sequential’ approach –
“A sequential approach which looks first at previously used land and buildings within settlements” (2.22) before any ‘greenfield’ sites are developed.
The current land allocation plans for Grange need to be looked at again in the light of these principles and the recent failure of proposed schemes.
No ‘greenfield’ site should be earmarked for development until the use of ‘brownfield’ sites is resolved.
I believe that any one of these 4 issues renders the Land Allocation Proposals unsound but together they demand a radical reappraisal by South Lakes District Council as to how it develops land usage in Grange-over-Sands and District.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
626. Mr Andrew Mortimer (Individual) : 15 May 2012 11:58:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - All Grange-over-Sands sites
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I do not believe that South Lakeland District Council’s Land Allocation Development Plan Document (DPD) should be adopted in relation to planning for Grange-over-Sands and District because it is not sound.
It is not founded on robust and credible evidence, it makes assumptions that are based on out-of-date and poor research and, most importantly, it contains significant inconsistencies across the collection of ‘Local Development Framework’ (LDF) documents and, in particular, discrepancies and contradictions with the Core Strategy.
My principal objections are made on the grounds of:
1. site selection,
2. density
3. impact on transport infrastructure
4. failure to comply with core strategy methodology
1. Site Selection
I do not believe that the sites in Grange-over-Sands, identified for development in this plan, take sufficient account of the “detailed criteria” set out in DPD para 2.23 namely:
“General criteria such as the capacity of the site, the appropriate density at which it could be developed, the ease of accessing the site, the impact of topography and relief and the scope to meet identified needs …”
“Landscape and Settlement considerations including the potential impact of development on landscape and views, the scale of development relative to the settlement size, whether the site preserves the separate identity of settlements and the impact of development on site features such as trees, watercourses and buildings”
I also believe that some development would compromise an identified Green Gap.
For example, this would be the case if development were allowed on the scale proposed on site MN25M which would both visually and effectively join together the settlements of Grange-over-Sands, Kents Bank and Allithwaite.
Proposed development R110 would also compromise an important recreational open space. This is land “which is not accessible to the public but which nonetheless has amenity value because of its openness, appearance or landscape quality.” Using such sites for the density of development proposed contradicts the criteria for preserving Amenity Open Space, suggested in DPD para 2.63. It would also compromise the important recreational open space immediately next to it, turning it into little more than an urban playground.
Further, recommendations in the Grange Regeneration Study (which has informed the Core Strategy) about building a sense of place, business and tourist development etc would also be threatened by the DPD. Currently, as one walks or drives through Grange-over-Sands on the B5277, clear views across Morecambe Bay open out to give the visual and environmental qualities that make Grange unique and which attract visitors. The proposed developments would change those, often tree-lined, views into an unattractive urban ribbon development.
If the objective is “to deliver the vision and objectives set out in the Council’s adopted Core Strategy and help to make South Lakeland the best place to live, work and visit”(DPD 1.5), then the DPD choice of development sites in Grange-over-Sands must be considered more carefully.
2. Density
The DPD has not taken notice of the Core Strategy’s overarching development strategy (CS1.2), with regard to the impact that the suggested density of housing development in Grange-over-Sands would have in general on the landscape, historic setting, and the environment. Under the DPD proposals, between Grange Station and Kents Bank, all but one “greenfield” site would disappear.
The volume of housing development proposed is out of character and will change the unique and special nature of the area. It is not “moderate” as the Core Strategy would claim (Policy CS4).
500 dwellings in Grange-over-Sands would increase the current population by at least 25%.
I do not believe that an increase in population of a quarter could be considered “moderate”. Even the Local Transport Plan for South Lakeland (CCC Local Transport Plan 3, “Moving Cumbria Forward”, 2011 – 2016) describes this as “substantial housing allocation”.
In addition, some of the individual sites challenge the Core Strategy with regard to density of housing. “Core Strategy Policy CS6.6 seeks an average density of 30 dwellings per hectare, with higher densities in town centres and locations with good public transport and lower densities in areas where there are environmental constraints.”
There is a clear breach of this policy in regard to site R110, south of Thornfield Road, where the DPD recommends building 66 dwellings on only 1.83 ha. This is not a town centre site and is not a location with good public transport.
3. Impact on Transport Infrastructure
The DPD, by placing all the emphasis on development in Grange South, ignores the Core Strategy’s warning (CS5.32) that “given the problem of town centre congestion in Grange at peak times…. significantly higher traffic levels could well threaten the core economic activity of the town, namely tourism”.
An increase in population, on the scale proposed in the plan, would certainly result in at least 25% more traffic which would challenge its ambition of
“promoting the vitality of Grange Town Centre and promoting tourism”. (DPD 4.2)
The final plan seems to ignore the fact that,
“The main B5277 road runs through the heart of Grange over Sands … In places this road narrows and on some stretches, there is a feeling of car domination.”
(SLDC Framework Land Allocations Development Plan Document Consultation on emerging site options – Grange over Sands)
The Core Strategy also suggests 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.” (CS5.12)
Statistics from “count points” on the A590 show that between the Meathop Roundabout and Newby Bridge over 5000 vehicles joined or left the A590 per day in 2010. (Highways Agency Cumbria AADF statistics 2011) This confirms that there is already an extremely high volume of traffic coming in and out of the Cartmel Peninsula on unsuitable roads. Even The Development Plan itself admits,
“Elsewhere in the peninsula … the road network … is constrained in places.” (DPD 4.1)
It is likely to become very much more “constrained” if the volume of traffic grows by almost 25% in line with the proposed population increase in Grange-over-Sands, not forgetting the fact that,
“Car ownership levels in Grange … are high, with 80.7% of households having access to a car or van (compared to a Cumbria average of 75.6%)”.
(SLDC Framework Land Allocations Development Plan Document Consultation on emerging site options – Grange over Sands)
Even more significant is the apparent failure of SLDC to consider the impact of its plans for Grange-over-Sands, the Cartmel Peninsula and Ulverston together, on the wider transport infrastructure and especially the increase in volume of traffic on the A590. Whatever the discussions SLDC have had with The Highways Agency, the latter have no plans for improvements to the A590 before 2025 except a possible roundabout construction at Greenodd. A spokesman has told me that “Our current major scheme programme does not include any schemes on the A590”.
The most recent average annual daily flow (AADF) figures for the A590 show a steady increase of traffic on this road over the last 10 years, with almost 4000 more vehicles travelling daily in 2010 than in 2009. (Highways Agency Cumbria AADF statistics 2011)
This volume of traffic would be increased significantly by the proposals in the DPD for housing and industrial development in Cartmel Peninsula and Ulverston.
In the Cumbria County Council Local Transport Plan 2006 – 2011, it was noted that,
"The A590 between the Furness peninsula and the M6 motorway has several constrictions, including passing through Ulverston and ... long single carriageway sections with unimproved alignments. This causes unreliable and extended journey times between Furness and the rest of the region and UK, impeding economic development. The worsening position regarding average journey times on A590 has already been noted in the context of road safety”
What this means, according to provisional data published by the Highways Agency, is that on average only about 65% of journeys undertaken on A590 in 2011 were ‘on time’.(The national average for ‘on-time’ journeys was approximately 85%)(Journey Reliability Data to November 2011 – data.gov.uk)
In addition, Cumbria Constabulary has unofficially acknowledged that there were 3 fatalities and 6 serious injuries as a result of accidents in 2011 on the A590, making it the worst road in Cumbria for fatal accidents over the past 10 years.
If the potential increase in traffic as a result of DPD is added to the Department of Transport's own national statistical projections for 2025 of a 25% increase in volume of all traffic, and an increase in car ownership of 30% (Table TRA 9905), I believe that the actual increase in traffic on this dangerous road is likely to be at least 50% by 2025.
4. Failure to Comply with Core Strategy Methodology
Core Strategy clearly lays out a sequence for the planning process.
CS1.1 sets out “Sustainable Development Principles” including
“Development should accord with the following sequential approach:
• first, using existing buildings (including conversion) within settlements, and previously
developed land within settlements;
• second, using other suitable infill opportunities within settlements;
• third, the development of other land where this is well located in relation to housing, jobs, other services and infrastructure.”
CS1.2 states “Priority will be given to the reuse of existing buildings and previously developed land for all new housing development”
The question is now raised as to whether, in the light of the withdrawal of the Berner’s site proposals in Grange-over-Sands (25/01/12), these DPD plans might no longer be seen as having a ‘sequential’ approach –
“A sequential approach which looks first at previously used land and buildings within settlements” (2.22) before any ‘greenfield’ sites are developed.
The current land allocation plans for Grange need to be looked at again in the light of these principles and the recent failure of proposed schemes.
No ‘greenfield’ site should be earmarked for development until the use of ‘brownfield’ sites is resolved.
I believe that any one of these 4 issues renders the Land Allocation Proposals unsound but together they demand a radical reappraisal by South Lakes District Council as to how it develops land usage in Grange-over-Sands and District.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
627. Mr Andrew Mortimer (Individual) : 15 May 2012 12:01:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA3.1 Mixed Use Allocation at Berners Pool, Grange-over-Sands
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I do not believe that South Lakeland District Council’s Land Allocation Development Plan Document (DPD) should be adopted in relation to planning for Grange-over-Sands and District because it is not sound.
It is not founded on robust and credible evidence, it makes assumptions that are based on out-of-date and poor research and, most importantly, it contains significant inconsistencies across the collection of ‘Local Development Framework’ (LDF) documents and, in particular, discrepancies and contradictions with the Core Strategy.
My principal objections are made on the grounds of:
1. site selection,
2. density
3. impact on transport infrastructure
4. failure to comply with core strategy methodology
1. Site Selection
I do not believe that the sites in Grange-over-Sands, identified for development in this plan, take sufficient account of the “detailed criteria” set out in DPD para 2.23 namely:
“General criteria such as the capacity of the site, the appropriate density at which it could be developed, the ease of accessing the site, the impact of topography and relief and the scope to meet identified needs …”
“Landscape and Settlement considerations including the potential impact of development on landscape and views, the scale of development relative to the settlement size, whether the site preserves the separate identity of settlements and the impact of development on site features such as trees, watercourses and buildings”
I also believe that some development would compromise an identified Green Gap.
For example, this would be the case if development were allowed on the scale proposed on site MN25M which would both visually and effectively join together the settlements of Grange-over-Sands, Kents Bank and Allithwaite.
Proposed development R110 would also compromise an important recreational open space. This is land “which is not accessible to the public but which nonetheless has amenity value because of its openness, appearance or landscape quality.” Using such sites for the density of development proposed contradicts the criteria for preserving Amenity Open Space, suggested in DPD para 2.63. It would also compromise the important recreational open space immediately next to it, turning it into little more than an urban playground.
Further, recommendations in the Grange Regeneration Study (which has informed the Core Strategy) about building a sense of place, business and tourist development etc would also be threatened by the DPD. Currently, as one walks or drives through Grange-over-Sands on the B5277, clear views across Morecambe Bay open out to give the visual and environmental qualities that make Grange unique and which attract visitors. The proposed developments would change those, often tree-lined, views into an unattractive urban ribbon development.
If the objective is “to deliver the vision and objectives set out in the Council’s adopted Core Strategy and help to make South Lakeland the best place to live, work and visit”(DPD 1.5), then the DPD choice of development sites in Grange-over-Sands must be considered more carefully.
2. Density
The DPD has not taken notice of the Core Strategy’s overarching development strategy (CS1.2), with regard to the impact that the suggested density of housing development in Grange-over-Sands would have in general on the landscape, historic setting, and the environment. Under the DPD proposals, between Grange Station and Kents Bank, all but one “greenfield” site would disappear.
The volume of housing development proposed is out of character and will change the unique and special nature of the area. It is not “moderate” as the Core Strategy would claim (Policy CS4).
500 dwellings in Grange-over-Sands would increase the current population by at least 25%.
I do not believe that an increase in population of a quarter could be considered “moderate”. Even the Local Transport Plan for South Lakeland (CCC Local Transport Plan 3, “Moving Cumbria Forward”, 2011 – 2016) describes this as “substantial housing allocation”.
In addition, some of the individual sites challenge the Core Strategy with regard to density of housing. “Core Strategy Policy CS6.6 seeks an average density of 30 dwellings per hectare, with higher densities in town centres and locations with good public transport and lower densities in areas where there are environmental constraints.”
There is a clear breach of this policy in regard to site R110, south of Thornfield Road, where the DPD recommends building 66 dwellings on only 1.83 ha. This is not a town centre site and is not a location with good public transport.
3. Impact on Transport Infrastructure
The DPD, by placing all the emphasis on development in Grange South, ignores the Core Strategy’s warning (CS5.32) that “given the problem of town centre congestion in Grange at peak times…. significantly higher traffic levels could well threaten the core economic activity of the town, namely tourism”.
An increase in population, on the scale proposed in the plan, would certainly result in at least 25% more traffic which would challenge its ambition of
“promoting the vitality of Grange Town Centre and promoting tourism”. (DPD 4.2)
The final plan seems to ignore the fact that,
“The main B5277 road runs through the heart of Grange over Sands … In places this road narrows and on some stretches, there is a feeling of car domination.”
(SLDC Framework Land Allocations Development Plan Document Consultation on emerging site options – Grange over Sands)
The Core Strategy also suggests 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.” (CS5.12)
Statistics from “count points” on the A590 show that between the Meathop Roundabout and Newby Bridge over 5000 vehicles joined or left the A590 per day in 2010. (Highways Agency Cumbria AADF statistics 2011) This confirms that there is already an extremely high volume of traffic coming in and out of the Cartmel Peninsula on unsuitable roads. Even The Development Plan itself admits,
“Elsewhere in the peninsula … the road network … is constrained in places.” (DPD 4.1)
It is likely to become very much more “constrained” if the volume of traffic grows by almost 25% in line with the proposed population increase in Grange-over-Sands, not forgetting the fact that,
“Car ownership levels in Grange … are high, with 80.7% of households having access to a car or van (compared to a Cumbria average of 75.6%)”.
(SLDC Framework Land Allocations Development Plan Document Consultation on emerging site options – Grange over Sands)
Even more significant is the apparent failure of SLDC to consider the impact of its plans for Grange-over-Sands, the Cartmel Peninsula and Ulverston together, on the wider transport infrastructure and especially the increase in volume of traffic on the A590. Whatever the discussions SLDC have had with The Highways Agency, the latter have no plans for improvements to the A590 before 2025 except a possible roundabout construction at Greenodd. A spokesman has told me that “Our current major scheme programme does not include any schemes on the A590”.
The most recent average annual daily flow (AADF) figures for the A590 show a steady increase of traffic on this road over the last 10 years, with almost 4000 more vehicles travelling daily in 2010 than in 2009. (Highways Agency Cumbria AADF statistics 2011)
This volume of traffic would be increased significantly by the proposals in the DPD for housing and industrial development in Cartmel Peninsula and Ulverston.
In the Cumbria County Council Local Transport Plan 2006 – 2011, it was noted that,
"The A590 between the Furness peninsula and the M6 motorway has several constrictions, including passing through Ulverston and ... long single carriageway sections with unimproved alignments. This causes unreliable and extended journey times between Furness and the rest of the region and UK, impeding economic development. The worsening position regarding average journey times on A590 has already been noted in the context of road safety”
What this means, according to provisional data published by the Highways Agency, is that on average only about 65% of journeys undertaken on A590 in 2011 were ‘on time’.(The national average for ‘on-time’ journeys was approximately 85%)(Journey Reliability Data to November 2011 – data.gov.uk)
In addition, Cumbria Constabulary has unofficially acknowledged that there were 3 fatalities and 6 serious injuries as a result of accidents in 2011 on the A590, making it the worst road in Cumbria for fatal accidents over the past 10 years.
If the potential increase in traffic as a result of DPD is added to the Department of Transport's own national statistical projections for 2025 of a 25% increase in volume of all traffic, and an increase in car ownership of 30% (Table TRA 9905), I believe that the actual increase in traffic on this dangerous road is likely to be at least 50% by 2025.
4. Failure to Comply with Core Strategy Methodology
Core Strategy clearly lays out a sequence for the planning process.
CS1.1 sets out “Sustainable Development Principles” including
“Development should accord with the following sequential approach:
• first, using existing buildings (including conversion) within settlements, and previously
developed land within settlements;
• second, using other suitable infill opportunities within settlements;
• third, the development of other land where this is well located in relation to housing, jobs, other services and infrastructure.”
CS1.2 states “Priority will be given to the reuse of existing buildings and previously developed land for all new housing development”
The question is now raised as to whether, in the light of the withdrawal of the Berner’s site proposals in Grange-over-Sands (25/01/12), these DPD plans might no longer be seen as having a ‘sequential’ approach –
“A sequential approach which looks first at previously used land and buildings within settlements” (2.22) before any ‘greenfield’ sites are developed.
The current land allocation plans for Grange need to be looked at again in the light of these principles and the recent failure of proposed schemes.
No ‘greenfield’ site should be earmarked for development until the use of ‘brownfield’ sites is resolved.
I believe that any one of these 4 issues renders the Land Allocation Proposals unsound but together they demand a radical reappraisal by South Lakes District Council as to how it develops land usage in Grange-over-Sands and District.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
628. Mr Andrew Mortimer (Individual) : 15 May 2012 12:04:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA3.2 Mixed Use Allocation at Land South of Allithwaite Road, Kent's Bank, Grange-over-Sands
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I do not believe that South Lakeland District Council’s Land Allocation Development Plan Document (DPD) should be adopted in relation to planning for Grange-over-Sands and District because it is not sound.
It is not founded on robust and credible evidence, it makes assumptions that are based on out-of-date and poor research and, most importantly, it contains significant inconsistencies across the collection of ‘Local Development Framework’ (LDF) documents and, in particular, discrepancies and contradictions with the Core Strategy.
My principal objections are made on the grounds of:
1. site selection,
2. density
3. impact on transport infrastructure
4. failure to comply with core strategy methodology
1. Site Selection
I do not believe that the sites in Grange-over-Sands, identified for development in this plan, take sufficient account of the “detailed criteria” set out in DPD para 2.23 namely:
“General criteria such as the capacity of the site, the appropriate density at which it could be developed, the ease of accessing the site, the impact of topography and relief and the scope to meet identified needs …”
“Landscape and Settlement considerations including the potential impact of development on landscape and views, the scale of development relative to the settlement size, whether the site preserves the separate identity of settlements and the impact of development on site features such as trees, watercourses and buildings”
I also believe that some development would compromise an identified Green Gap.
For example, this would be the case if development were allowed on the scale proposed on site MN25M which would both visually and effectively join together the settlements of Grange-over-Sands, Kents Bank and Allithwaite.
Proposed development R110 would also compromise an important recreational open space. This is land “which is not accessible to the public but which nonetheless has amenity value because of its openness, appearance or landscape quality.” Using such sites for the density of development proposed contradicts the criteria for preserving Amenity Open Space, suggested in DPD para 2.63. It would also compromise the important recreational open space immediately next to it, turning it into little more than an urban playground.
Further, recommendations in the Grange Regeneration Study (which has informed the Core Strategy) about building a sense of place, business and tourist development etc would also be threatened by the DPD. Currently, as one walks or drives through Grange-over-Sands on the B5277, clear views across Morecambe Bay open out to give the visual and environmental qualities that make Grange unique and which attract visitors. The proposed developments would change those, often tree-lined, views into an unattractive urban ribbon development.
If the objective is “to deliver the vision and objectives set out in the Council’s adopted Core Strategy and help to make South Lakeland the best place to live, work and visit”(DPD 1.5), then the DPD choice of development sites in Grange-over-Sands must be considered more carefully.
2. Density
The DPD has not taken notice of the Core Strategy’s overarching development strategy (CS1.2), with regard to the impact that the suggested density of housing development in Grange-over-Sands would have in general on the landscape, historic setting, and the environment. Under the DPD proposals, between Grange Station and Kents Bank, all but one “greenfield” site would disappear.
The volume of housing development proposed is out of character and will change the unique and special nature of the area. It is not “moderate” as the Core Strategy would claim (Policy CS4).
500 dwellings in Grange-over-Sands would increase the current population by at least 25%.
I do not believe that an increase in population of a quarter could be considered “moderate”. Even the Local Transport Plan for South Lakeland (CCC Local Transport Plan 3, “Moving Cumbria Forward”, 2011 – 2016) describes this as “substantial housing allocation”.
In addition, some of the individual sites challenge the Core Strategy with regard to density of housing. “Core Strategy Policy CS6.6 seeks an average density of 30 dwellings per hectare, with higher densities in town centres and locations with good public transport and lower densities in areas where there are environmental constraints.”
There is a clear breach of this policy in regard to site R110, south of Thornfield Road, where the DPD recommends building 66 dwellings on only 1.83 ha. This is not a town centre site and is not a location with good public transport.
3. Impact on Transport Infrastructure
The DPD, by placing all the emphasis on development in Grange South, ignores the Core Strategy’s warning (CS5.32) that “given the problem of town centre congestion in Grange at peak times…. significantly higher traffic levels could well threaten the core economic activity of the town, namely tourism”.
An increase in population, on the scale proposed in the plan, would certainly result in at least 25% more traffic which would challenge its ambition of
“promoting the vitality of Grange Town Centre and promoting tourism”. (DPD 4.2)
The final plan seems to ignore the fact that,
“The main B5277 road runs through the heart of Grange over Sands … In places this road narrows and on some stretches, there is a feeling of car domination.”
(SLDC Framework Land Allocations Development Plan Document Consultation on emerging site options – Grange over Sands)
The Core Strategy also suggests 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.” (CS5.12)
Statistics from “count points” on the A590 show that between the Meathop Roundabout and Newby Bridge over 5000 vehicles joined or left the A590 per day in 2010. (Highways Agency Cumbria AADF statistics 2011) This confirms that there is already an extremely high volume of traffic coming in and out of the Cartmel Peninsula on unsuitable roads. Even The Development Plan itself admits,
“Elsewhere in the peninsula … the road network … is constrained in places.” (DPD 4.1)
It is likely to become very much more “constrained” if the volume of traffic grows by almost 25% in line with the proposed population increase in Grange-over-Sands, not forgetting the fact that,
“Car ownership levels in Grange … are high, with 80.7% of households having access to a car or van (compared to a Cumbria average of 75.6%)”.
(SLDC Framework Land Allocations Development Plan Document Consultation on emerging site options – Grange over Sands)
Even more significant is the apparent failure of SLDC to consider the impact of its plans for Grange-over-Sands, the Cartmel Peninsula and Ulverston together, on the wider transport infrastructure and especially the increase in volume of traffic on the A590. Whatever the discussions SLDC have had with The Highways Agency, the latter have no plans for improvements to the A590 before 2025 except a possible roundabout construction at Greenodd. A spokesman has told me that “Our current major scheme programme does not include any schemes on the A590”.
The most recent average annual daily flow (AADF) figures for the A590 show a steady increase of traffic on this road over the last 10 years, with almost 4000 more vehicles travelling daily in 2010 than in 2009. (Highways Agency Cumbria AADF statistics 2011)
This volume of traffic would be increased significantly by the proposals in the DPD for housing and industrial development in Cartmel Peninsula and Ulverston.
In the Cumbria County Council Local Transport Plan 2006 – 2011, it was noted that,
"The A590 between the Furness peninsula and the M6 motorway has several constrictions, including passing through Ulverston and ... long single carriageway sections with unimproved alignments. This causes unreliable and extended journey times between Furness and the rest of the region and UK, impeding economic development. The worsening position regarding average journey times on A590 has already been noted in the context of road safety”
What this means, according to provisional data published by the Highways Agency, is that on average only about 65% of journeys undertaken on A590 in 2011 were ‘on time’.(The national average for ‘on-time’ journeys was approximately 85%)(Journey Reliability Data to November 2011 – data.gov.uk)
In addition, Cumbria Constabulary has unofficially acknowledged that there were 3 fatalities and 6 serious injuries as a result of accidents in 2011 on the A590, making it the worst road in Cumbria for fatal accidents over the past 10 years.
If the potential increase in traffic as a result of DPD is added to the Department of Transport's own national statistical projections for 2025 of a 25% increase in volume of all traffic, and an increase in car ownership of 30% (Table TRA 9905), I believe that the actual increase in traffic on this dangerous road is likely to be at least 50% by 2025.
4. Failure to Comply with Core Strategy Methodology
Core Strategy clearly lays out a sequence for the planning process.
CS1.1 sets out “Sustainable Development Principles” including
“Development should accord with the following sequential approach:
• first, using existing buildings (including conversion) within settlements, and previously
developed land within settlements;
• second, using other suitable infill opportunities within settlements;
• third, the development of other land where this is well located in relation to housing, jobs, other services and infrastructure.”
CS1.2 states “Priority will be given to the reuse of existing buildings and previously developed land for all new housing development”
The question is now raised as to whether, in the light of the withdrawal of the Berner’s site proposals in Grange-over-Sands (25/01/12), these DPD plans might no longer be seen as having a ‘sequential’ approach –
“A sequential approach which looks first at previously used land and buildings within settlements” (2.22) before any ‘greenfield’ sites are developed.
The current land allocation plans for Grange need to be looked at again in the light of these principles and the recent failure of proposed schemes.
No ‘greenfield’ site should be earmarked for development until the use of ‘brownfield’ sites is resolved.
I believe that any one of these 4 issues renders the Land Allocation Proposals unsound but together they demand a radical reappraisal by South Lakes District Council as to how it develops land usage in Grange-over-Sands and District.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
629. Mr Andrew Mortimer (Individual) : 15 May 2012 12:05:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA3.3 Mixed Use Allocation at Guide's Lot, Grange-over-Sands
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I do not believe that South Lakeland District Council’s Land Allocation Development Plan Document (DPD) should be adopted in relation to planning for Grange-over-Sands and District because it is not sound.
It is not founded on robust and credible evidence, it makes assumptions that are based on out-of-date and poor research and, most importantly, it contains significant inconsistencies across the collection of ‘Local Development Framework’ (LDF) documents and, in particular, discrepancies and contradictions with the Core Strategy.
My principal objections are made on the grounds of:
1. site selection,
2. density
3. impact on transport infrastructure
4. failure to comply with core strategy methodology
1. Site Selection
I do not believe that the sites in Grange-over-Sands, identified for development in this plan, take sufficient account of the “detailed criteria” set out in DPD para 2.23 namely:
“General criteria such as the capacity of the site, the appropriate density at which it could be developed, the ease of accessing the site, the impact of topography and relief and the scope to meet identified needs …”
“Landscape and Settlement considerations including the potential impact of development on landscape and views, the scale of development relative to the settlement size, whether the site preserves the separate identity of settlements and the impact of development on site features such as trees, watercourses and buildings”
I also believe that some development would compromise an identified Green Gap.
For example, this would be the case if development were allowed on the scale proposed on site MN25M which would both visually and effectively join together the settlements of Grange-over-Sands, Kents Bank and Allithwaite.
Proposed development R110 would also compromise an important recreational open space. This is land “which is not accessible to the public but which nonetheless has amenity value because of its openness, appearance or landscape quality.” Using such sites for the density of development proposed contradicts the criteria for preserving Amenity Open Space, suggested in DPD para 2.63. It would also compromise the important recreational open space immediately next to it, turning it into little more than an urban playground.
Further, recommendations in the Grange Regeneration Study (which has informed the Core Strategy) about building a sense of place, business and tourist development etc would also be threatened by the DPD. Currently, as one walks or drives through Grange-over-Sands on the B5277, clear views across Morecambe Bay open out to give the visual and environmental qualities that make Grange unique and which attract visitors. The proposed developments would change those, often tree-lined, views into an unattractive urban ribbon development.
If the objective is “to deliver the vision and objectives set out in the Council’s adopted Core Strategy and help to make South Lakeland the best place to live, work and visit”(DPD 1.5), then the DPD choice of development sites in Grange-over-Sands must be considered more carefully.
2. Density
The DPD has not taken notice of the Core Strategy’s overarching development strategy (CS1.2), with regard to the impact that the suggested density of housing development in Grange-over-Sands would have in general on the landscape, historic setting, and the environment. Under the DPD proposals, between Grange Station and Kents Bank, all but one “greenfield” site would disappear.
The volume of housing development proposed is out of character and will change the unique and special nature of the area. It is not “moderate” as the Core Strategy would claim (Policy CS4).
500 dwellings in Grange-over-Sands would increase the current population by at least 25%.
I do not believe that an increase in population of a quarter could be considered “moderate”. Even the Local Transport Plan for South Lakeland (CCC Local Transport Plan 3, “Moving Cumbria Forward”, 2011 – 2016) describes this as “substantial housing allocation”.
In addition, some of the individual sites challenge the Core Strategy with regard to density of housing. “Core Strategy Policy CS6.6 seeks an average density of 30 dwellings per hectare, with higher densities in town centres and locations with good public transport and lower densities in areas where there are environmental constraints.”
There is a clear breach of this policy in regard to site R110, south of Thornfield Road, where the DPD recommends building 66 dwellings on only 1.83 ha. This is not a town centre site and is not a location with good public transport.
3. Impact on Transport Infrastructure
The DPD, by placing all the emphasis on development in Grange South, ignores the Core Strategy’s warning (CS5.32) that “given the problem of town centre congestion in Grange at peak times…. significantly higher traffic levels could well threaten the core economic activity of the town, namely tourism”.
An increase in population, on the scale proposed in the plan, would certainly result in at least 25% more traffic which would challenge its ambition of
“promoting the vitality of Grange Town Centre and promoting tourism”. (DPD 4.2)
The final plan seems to ignore the fact that,
“The main B5277 road runs through the heart of Grange over Sands … In places this road narrows and on some stretches, there is a feeling of car domination.”
(SLDC Framework Land Allocations Development Plan Document Consultation on emerging site options – Grange over Sands)
The Core Strategy also suggests 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.” (CS5.12)
Statistics from “count points” on the A590 show that between the Meathop Roundabout and Newby Bridge over 5000 vehicles joined or left the A590 per day in 2010. (Highways Agency Cumbria AADF statistics 2011) This confirms that there is already an extremely high volume of traffic coming in and out of the Cartmel Peninsula on unsuitable roads. Even The Development Plan itself admits,
“Elsewhere in the peninsula … the road network … is constrained in places.” (DPD 4.1)
It is likely to become very much more “constrained” if the volume of traffic grows by almost 25% in line with the proposed population increase in Grange-over-Sands, not forgetting the fact that,
“Car ownership levels in Grange … are high, with 80.7% of households having access to a car or van (compared to a Cumbria average of 75.6%)”.
(SLDC Framework Land Allocations Development Plan Document Consultation on emerging site options – Grange over Sands)
Even more significant is the apparent failure of SLDC to consider the impact of its plans for Grange-over-Sands, the Cartmel Peninsula and Ulverston together, on the wider transport infrastructure and especially the increase in volume of traffic on the A590. Whatever the discussions SLDC have had with The Highways Agency, the latter have no plans for improvements to the A590 before 2025 except a possible roundabout construction at Greenodd. A spokesman has told me that “Our current major scheme programme does not include any schemes on the A590”.
The most recent average annual daily flow (AADF) figures for the A590 show a steady increase of traffic on this road over the last 10 years, with almost 4000 more vehicles travelling daily in 2010 than in 2009. (Highways Agency Cumbria AADF statistics 2011)
This volume of traffic would be increased significantly by the proposals in the DPD for housing and industrial development in Cartmel Peninsula and Ulverston.
In the Cumbria County Council Local Transport Plan 2006 – 2011, it was noted that,
"The A590 between the Furness peninsula and the M6 motorway has several constrictions, including passing through Ulverston and ... long single carriageway sections with unimproved alignments. This causes unreliable and extended journey times between Furness and the rest of the region and UK, impeding economic development. The worsening position regarding average journey times on A590 has already been noted in the context of road safety”
What this means, according to provisional data published by the Highways Agency, is that on average only about 65% of journeys undertaken on A590 in 2011 were ‘on time’.(The national average for ‘on-time’ journeys was approximately 85%)(Journey Reliability Data to November 2011 – data.gov.uk)
In addition, Cumbria Constabulary has unofficially acknowledged that there were 3 fatalities and 6 serious injuries as a result of accidents in 2011 on the A590, making it the worst road in Cumbria for fatal accidents over the past 10 years.
If the potential increase in traffic as a result of DPD is added to the Department of Transport's own national statistical projections for 2025 of a 25% increase in volume of all traffic, and an increase in car ownership of 30% (Table TRA 9905), I believe that the actual increase in traffic on this dangerous road is likely to be at least 50% by 2025.
4. Failure to Comply with Core Strategy Methodology
Core Strategy clearly lays out a sequence for the planning process.
CS1.1 sets out “Sustainable Development Principles” including
“Development should accord with the following sequential approach:
• first, using existing buildings (including conversion) within settlements, and previously
developed land within settlements;
• second, using other suitable infill opportunities within settlements;
• third, the development of other land where this is well located in relation to housing, jobs, other services and infrastructure.”
CS1.2 states “Priority will be given to the reuse of existing buildings and previously developed land for all new housing development”
The question is now raised as to whether, in the light of the withdrawal of the Berner’s site proposals in Grange-over-Sands (25/01/12), these DPD plans might no longer be seen as having a ‘sequential’ approach –
“A sequential approach which looks first at previously used land and buildings within settlements” (2.22) before any ‘greenfield’ sites are developed.
The current land allocation plans for Grange need to be looked at again in the light of these principles and the recent failure of proposed schemes.
No ‘greenfield’ site should be earmarked for development until the use of ‘brownfield’ sites is resolved.
I believe that any one of these 4 issues renders the Land Allocation Proposals unsound but together they demand a radical reappraisal by South Lakes District Council as to how it develops land usage in Grange-over-Sands and District.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
630. Mrs Irene Mower (Individual) : 16 May 2012 12:41:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - Site Omission
If you have selected a ‘Site omission’ please enter the site reference or location and relevant policy below
Supports site omission - RN22 - orchard opposite school on Storth Road
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
This is a greenfield site & government policy is to use grown field when available and 2 such sites exist in Storth. The orchard on Storth Road is an important wildlife site & should be nurtured, not destroyed. See separate sheet [text provided below]:
I am very concerned by the suggestion that a particular site in Storth is being suggested as suitable for building on. This site is an orchard on Storth Road, opposite the school.
Storth lies within an Area of Outstanding Natural Beauty and it is therefore desirable to keep our village and the surrounding countryside, naturally beautiful. This particular area is an greenfield site and the government's policy to build on brown field areas should be adhered to, and the two frown field sites on quarry lane used instead.
I live near the orchard in question and am passionate about nature conservation. I have been conducting an entomological study here for 3 years and the orchard appears to be a valuable wildlife haven. I have, for instance found two very rare moths, one of which was a first record for the AONB. Many other fairly scarce species have been found. These records are important in themselves, but are also an indicator of the rich bio-diversity of this site.
Another issues of concern if houses were built on this plot would be Storth Road itself. At school opening and closing times this road can be severely congested. There is no pavement and walking along the road at 8.30 am and 3.30pm is a case of dodging the traffic. This is unsatisfactory for a fit adult, never mind an old person or schoo child. Inevitably, increased housing opposite the school will merely intensify this problem.
The sites on Quarry Lane would not have these traffic problems and would not diminish the valuable wildlife of which the AONB is very found, if they were chosen for this building project.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
631. Mrs P Moxon (Individual) : 11 Apr 2012 16:00:00
Policy/Site No.
LA1.3 Housing Allocations - All Arnside sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Obviously the people who have decided to build on our green sites have neither experienced the conditions or problems of living in Arnside.
Primarily the sewerage system is absolutely inadequate for the people living here. Consistently we have to 'rod' our drainage systems, otherwise 'smells and excrement are a problem. Yes, in this day and age!!
The traffic system is chaotic. Directions to the A6 via Milnthorpe consists of a winding, narrow road with a very bad bridge.
Otherwise the alternatives to the A6 is via Beetham again very narrow winding lanes.
Parking in Arnside is inadequate for the local population, never mind the tourists who visit.
632. Mr Graeme Murray (Individual) : 11 Apr 2012 22:32:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.1 Development Boundaries- ENDMOOR
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The current strategy is not justified, evidenced by :-
• SLDC used 2005 Business plans, acknowledged as out of date. Following economic downturn, figures are deficient and do not reflect the current needs.
• SLDC Housing figures provided by Office of National Statistics, updated in 2006. Increases out of date, also out with the CCC projected increases, who deem only 2400 new homes required, not 6000. This represents a 4.6% increase in housing stock, against an 11.5% by SLDC.
• Development des not take into account the 1000 homes identified by Tim Farron in need of refurbishment.
• No requirement for local commercial / industrial development has been demonstrated. Large numbers of vacant commercial property available and already developing Auction Mart site.
• Local meeting held with SLDC. SLDC advised proposed development of M41 site, 68 homes and mixed commercial land not required. Fewer homes and no commercial development suitable for the site. Revised plans see 100 homes. No consultation took place on increases with villagers or PC.
• Sewerage / Waste water requirements show Endmoor STW and Crooklands to be at capacity. Proposed upgrade at Low Park funding in 2014 which is not guaranteed.
• Current Water supply stated by UU in need of network reinforcement..
• At Crematorium proposal, independent consultant concluded application be refused on grounds highway network unsuitable for expected volume of traffic. EN33 Commercial development would entail higher traffic volumes.
• Proposed development of EN33 is outwith Policy CS7.4
• The 30 Houses per hectare in M41M/R670 is contrary to the
? SLDC Dev Framework Section 2 Page 16 Sustainable Development Principles CS1.1 Point 2 & 3
? Land Allocation Dev Plan Doc, Appendix 1 Sustainability Appraisal for Endmoor P187
• Proposed housing density 2.5 times current village density and higher than other local village enlargements proposed.
• M41M , R670 would see 30% increase in village area, 48% increase in homes / population. SLDC stated extensions to LSC’s only permitted where a clear need for development was identified, significant environmental impacts could be avoided and previous developed land utilised.
The plans are not effective, the document is not deliverable, flexible or suitable for monitoring.
This is evidenced by :-
• The Phase 2 development of the M41M site is planned for 2017 – 2025. SLDC state a Development Brief would be required before any development could proceed. However builders interested in developing site, bringing it forward 5 years. There seems to be lack of clarity between SLDC’s phasing of the development and the building of new homes and the sewerage infrastructure
• In January 2010, the SLDC identified key issues for Endmoor included the need for a more satisfactory northern edge and the need to safeguard the surrounding landscape. Replacing a 7 home edge with a 100 home development on greenfield site does not meet these requirements.
To make the DPD legally compliant or sound, the following changes are considered necessary
1) Review design figures based on current housing and business needs
2) Reduce the Density and Number of houses in M41M/R670 to meet Dev Framework
3) Reduce the size of area of the Village Development Boundary such that this will be more compliant with the Sustainable Development Principles CS1.1 -2&3
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
633. Mrs Beverley Murray (Individual) : 15 Apr 2012 21:16:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.1 Development Boundaries- ENDMOOR
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The Land Allocations Document (DPD) is not within the Local Development Scheme and the key stages have not been followed
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not been prepared in accordance with the Town & County Planning Regulations 2004 (as amended)
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Tax payers' money used for consultation but majority public opinion disregarded, i.e. consultation for 68 homes and commercial units mixed, on the Endmoor A65 site, the public at the meeting over whelmingly said NO to commercial being required and NO to 68 houses as TOO MANY and not in keeping with other development of villages the size of Endmoor. SLDC then proposed moving the commercial to another site down a country lane and increased number of houses built to 100. NO public consultation on either of these proposals. This official consultation form has NOT been sent out to every member of the public in the SLDC area as it should have been and is too complicated and not easily accessable to all. How many staff were allocated to help public with this form? What ratio per capita? How widely advertised? I have 10 O'levels, 3 A'levels and a R.G.N certificate and I am finding it almost impossible to understand this politicised jargon.
Why does the form have a political bias to supporting the SLDC Land Allocation DPD, as stipulated by section 1.4 and 2.4 and why is any opposition described as test of soundness? It would appear that you are making it more difficult for the general public to understand how to object and easy how to support.
SLDC have stated information in their DPD paperwork which is wrong and has NOT been corrected despite having it pointed out to them at public meetings. Endmoor does NOT have a full time post office. The SLDC report said that the Northern edge of the village needed softening, there are currently the gardens of 7 homes and the proposal was to soften their impact by building 68 houses and commercial units. Even the SLDC representative at the public consultation stated that this was clearly ludicrous, yet it remains in the report. Can not comment on softening by building 100 houses as was no public consultation about that figure.
Figures used by SLDC for housing density were those for urban areas NOT rural and yet they have not only applied but increased that density for this village when the proposed development is NOT on a bus route.
The proposed 48% increase in the Endmoor village population / geograghical area does not meet the councils stated claims that Local Service Centre increases would be proportionately less than Key Service Centres. SLDC have not followed their own protocol or national protocol AGAIN.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The SLDC has not followed its own protocols. The 1000 empty homes identified bt Tim Farron have not been deducted from the total number of homes required. No mention has been made of efforts to repair these homes. Most proposed sites are green agricultural fields, NOT INFILL, NOT BROWN FIELD. Follow your OWN protocol that you promised the public.
All information was collated from figures gathered in 2005 (business), and 2006 (population increases), therefore, all pre recession and all out of date, a fact which SLDC acknowledges but REFUSES to UPDATE or change. Use credible, current, statistics.
The Endmoor A65 site is an area of outstanding landscape with views towards the Howgill Fells and currently has sheep grazing on it.
There is a very expensive and infrequent bus service to Endmoor, £6.25 return before Aprils' increases. Very difficult to exist in the village or maintain employment without at least one car per household. I have first hand knowledge of this as I am a virtual prisoner now that I can't afford to run my own car any more. That equates to 100-200 extra cars in the village all trying to exit via the A65 in an accident black spot. I believe the police are NOT happy about this.
SLDC must consider the ENVIROMENTAL IMPACT as they PROMISED the electorate and listen to the experts.
The primary school has insufficient places in its pre school classes, this must be clarified with the Head Teacher. SLDC must seek relevant information and account for this in it's plans, including the cost to tax payers for the free bus service all secondary pupils in Endmoor are intitled to.
The electricity was lost several times in 2011 as was water pressure. The sewarage system is at full capacity. The cost to tax payers to upgrade an already failing system would be massive. SLDC must consider the costs involved to the ordinary tax payers and be correct and frugle in the use of public money.
SLDC must show an interest in public opinion and not belittle the public as did your representative on a local radio show, calling any disagreament with your proposals as the "VOCAL MINORITY". This would appear completely UNDEMOCRATIC as it was stated before the submission deadline for opposition. Show the public some respect!
The proposed developments for the housing in Endmoor would increase the housing stock by 48% a figure not proposed any where else in South Lakeland. This means Endmoor would become 2/3rds the size of Milnthorpe, with none of the facilities. Endmoor having one local store which is up for sale and one small bakery. SLDC need to justift why a special case has been made of Endmoor and why surveyers are sizing up the field at the proposed site before public opnion has been sort or building permission granted. SLDC must be open and honest with the public and investigate or/and justify what is going on.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
634. Mrs Janice Murray (Individual) : 4 May 2012 16:24:00
Policy/Site No.
LA1.3 Housing Allocations - R121M-mod KENDAL EAST OF CASTLE GREEN ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not had regard to the Sustainable Community Strategy
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Further visits to the site. A plnner did not visit the site until July 2011!
Has previously been judged inappropriately for an area of development. This original report needs to be taken into consideration.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
635. Mr Graeme Murray (Individual) : 11 May 2012 12:47:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
0.0 Whole Document
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The current strategy is not justified, evidenced by :-
• SLDC used 2005 Business plans, acknowledged as out of date. Following economic downturn, figures are deficient and do not reflect the current needs.
• SLDC Housing figures provided by Office of National Statistics, updated in 2006. Increases out of date, also out with the CCC projected increases, who deem only 2400 new homes required, not 6000. This represents a 4.6% increase in housing stock, against an 11.5% by SLDC.
• Development des not take into account the 1000 homes identified by Tim Farron in need of refurbishment.
• No requirement for local commercial / industrial development has been demonstrated. Large numbers of vacant commercial property available and already developing Auction Mart site.
To make the DPD legally compliant or sound, the following changes are considered necessary
1) Review design figures based on current housing and business needs
2) Reduce the Density and Number of houses in M41M/R670 to meet Dev Framework
3) Reduce the size of area of the Village Development Boundary such that this will be more compliant with the Sustainable Development Principles CS1.1 -2&3
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
636. Mr Graeme Murray (Individual) : 11 May 2012 12:53:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - M41M ENDMOOR NORTH OF SYCAMORE DRIVE
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
• Local meeting held with SLDC. SLDC advised proposed development of M41 site, 68 homes and mixed commercial land not required. Fewer homes and no commercial development suitable for the site. Revised plans see 100 homes. No consultation took place on increases with villagers or PC.
• Sewerage / Waste water requirements show Endmoor STW and Crooklands to be at capacity. Proposed upgrade at Low Park funding in 2014 which is not guaranteed.
• Current Water supply stated by UU in need of network reinforcement..
• At Crematorium proposal, independent consultant concluded application be refused on grounds highway network unsuitable for expected volume of traffic.
• The 30 Houses per hectare in M41M/R670 is contrary to the
? SLDC Dev Framework Section 2 Page 16 Sustainable Development Principles CS1.1 Point 2 & 3
? Land Allocation Dev Plan Doc, Appendix 1 Sustainability Appraisal for Endmoor P187
• Proposed housing density 2.5 times current village density and higher than other local village enlargements proposed.
• M41M , R670 would see 30% increase in village area, 48% increase in homes / population. SLDC stated extensions to LSC’s only permitted where a clear need for development was identified, significant environmental impacts could be avoided and previous developed land utilised.
The plans are not effective, the document is not deliverable, flexible or suitable for monitoring.
This is evidenced by :-
• The Phase 2 development of the M41M site is planned for 2017 – 2025. SLDC state a Development Brief would be required before any development could proceed. However builders interested in developing site, bringing it forward 5 years. There seems to be lack of clarity between SLDC’s phasing of the development and the building of new homes and the sewerage infrastructure
• In January 2010, the SLDC identified key issues for Endmoor included the need for a more satisfactory northern edge and the need to safeguard the surrounding landscape. Replacing a 7 home edge with a 100 home development on greenfield site does not meet these requirements.
To make the DPD legally compliant or sound, the following changes are considered necessary
1) Review design figures based on current housing and business needs
2) Reduce the Density and Number of houses in M41M/R670 to meet Dev Framework
3) Reduce the size of area of the Village Development Boundary such that this will be more compliant with the Sustainable Development Principles CS1.1 -2&3
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
637. Mr Graeme Murray (Individual) : 11 May 2012 12:58:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.8 Local Employment Allocations - EN20, EN33# ENDMOOR LAND NORTH OF GATEBECK LANE, GATEBECK
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
EN33 Commercial development would entail higher traffic volumes.
• Proposed development of EN33 is outwith Policy CS7.4
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
638. Mr Graeme Murray (Individual) : 11 May 2012 13:02:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - R670-mod ENDMOOR SOUTH OF BOWLING GREEN
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
• The 30 Houses per hectare in M41M/R670 is contrary to the
? SLDC Dev Framework Section 2 Page 16 Sustainable Development Principles CS1.1 Point 2 & 3
? Land Allocation Dev Plan Doc, Appendix 1 Sustainability Appraisal for Endmoor P187
• Proposed housing density 2.5 times current village density and higher than other local village enlargements proposed.
• M41M , R670 would see 30% increase in village area, 48% increase in homes / population. SLDC stated extensions to LSC’s only permitted where a clear need for development was identified, significant environmental impacts could be avoided and previous developed land utilised.
To make the DPD legally compliant or sound, the following changes are considered necessary
1) Review design figures based on current housing and business needs
2) Reduce the Density and Number of houses in M41M/R670 to meet Dev Framework
3) Reduce the size of area of the Village Development Boundary such that this will be more compliant with the Sustainable Development Principles CS1.1 -2&3
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
639. Mrs Beverley Murray (Individual) : 18 May 2012 16:39:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
1.9
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The Land Allocations Document (DPD) is not within the Local Development Scheme and the key stages have not been followed
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not been prepared in accordance with the Town & County Planning Regulations 2004 (as amended)
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Tax payers' money used for consultation but majority public opinion disregarded, i.e. consultation for 68 homes and commercial units mixed, on the Endmoor A65 site, the public at the meeting over whelmingly said NO to commercial being required and NO to 68 houses as TOO MANY and not in keeping with other development of villages the size of Endmoor. SLDC then proposed moving the commercial to another site down a country lane and increased number of houses built to 100. NO public consultation on either of these proposals. This official consultation form has NOT been sent out to every member of the public in the SLDC area as it should have been and is too complicated and not easily accessable to all. How many staff were allocated to help public with this form? What ratio per capita? How widely advertised? I have 10 O'levels, 3 A'levels and a R.G.N certificate and I am finding it almost impossible to understand this politicised jargon.
Why does the form have a political bias to supporting the SLDC Land Allocation DPD, as stipulated by section 1.4 and 2.4 and why is any opposition described as test of soundness? It would appear that you are making it more difficult for the general public to understand how to object and easy how to support.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
640. Mrs Beverley Murray (Individual) : 18 May 2012 16:40:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
1.10
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The Land Allocations Document (DPD) is not within the Local Development Scheme and the key stages have not been followed
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not been prepared in accordance with the Town & County Planning Regulations 2004 (as amended)
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Tax payers' money used for consultation but majority public opinion disregarded, i.e. consultation for 68 homes and commercial units mixed, on the Endmoor A65 site, the public at the meeting over whelmingly said NO to commercial being required and NO to 68 houses as TOO MANY and not in keeping with other development of villages the size of Endmoor. SLDC then proposed moving the commercial to another site down a country lane and increased number of houses built to 100. NO public consultation on either of these proposals. This official consultation form has NOT been sent out to every member of the public in the SLDC area as it should have been and is too complicated and not easily accessable to all. How many staff were allocated to help public with this form? What ratio per capita? How widely advertised? I have 10 O'levels, 3 A'levels and a R.G.N certificate and I am finding it almost impossible to understand this politicised jargon.
Why does the form have a political bias to supporting the SLDC Land Allocation DPD, as stipulated by section 1.4 and 2.4 and why is any opposition described as test of soundness? It would appear that you are making it more difficult for the general public to understand how to object and easy how to support.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
641. Mrs Beverley Murray (Individual) : 18 May 2012 16:41:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - All Endmoor sites
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The Land Allocations Document (DPD) is not within the Local Development Scheme and the key stages have not been followed
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not been prepared in accordance with the Town & County Planning Regulations 2004 (as amended)
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Tax payers' money used for consultation but majority public opinion disregarded, i.e. consultation for 68 homes and commercial units mixed, on the Endmoor A65 site, the public at the meeting over whelmingly said NO to commercial being required and NO to 68 houses as TOO MANY and not in keeping with other development of villages the size of Endmoor. SLDC then proposed moving the commercial to another site down a country lane and increased number of houses built to 100. NO public consultation on either of these proposals. This official consultation form has NOT been sent out to every member of the public in the SLDC area as it should have been and is too complicated and not easily accessable to all. How many staff were allocated to help public with this form? What ratio per capita? How widely advertised? I have 10 O'levels, 3 A'levels and a R.G.N certificate and I am finding it almost impossible to understand this politicised jargon.
Why does the form have a political bias to supporting the SLDC Land Allocation DPD, as stipulated by section 1.4 and 2.4 and why is any opposition described as test of soundness? It would appear that you are making it more difficult for the general public to understand how to object and easy how to support.
SLDC have stated information in their DPD paperwork which is wrong and has NOT been corrected despite having it pointed out to them at public meetings. Endmoor does NOT have a full time post office. The SLDC report said that the Northern edge of the village needed softening, there are currently the gardens of 7 homes and the proposal was to soften their impact by building 68 houses and commercial units. Even the SLDC representative at the public consultation stated that this was clearly ludicrous, yet it remains in the report. Can not comment on softening by building 100 houses as was no public consultation about that figure.
Figures used by SLDC for housing density were those for urban areas NOT rural and yet they have not only applied but increased that density for this village when the proposed development is NOT on a bus route.
The proposed 48% increase in the Endmoor village population / geograghical area does not meet the councils stated claims that Local Service Centre increases would be proportionately less than Key Service Centres. SLDC have not followed their own protocol or national protocol AGAIN.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The SLDC has not followed its own protocols. The 1000 empty homes identified bt Tim Farron have not been deducted from the total number of homes required. No mention has been made of efforts to repair these homes. Most proposed sites are green agricultural fields, NOT INFILL, NOT BROWN FIELD. Follow your OWN protocol that you promised the public.
All information was collated from figures gathered in 2005 (business), and 2006 (population increases), therefore, all pre recession and all out of date, a fact which SLDC acknowledges but REFUSES to UPDATE or change. Use credible, current, statistics.
The Endmoor A65 site is an area of outstanding landscape with views towards the Howgill Fells and currently has sheep grazing on it.
There is a very expensive and infrequent bus service to Endmoor, £6.25 return before Aprils' increases. Very difficult to exist in the village or maintain employment without at least one car per household. I have first hand knowledge of this as I am a virtual prisoner now that I can't afford to run my own car any more. That equates to 100-200 extra cars in the village all trying to exit via the A65 in an accident black spot. I believe the police are NOT happy about this.
SLDC must consider the ENVIROMENTAL IMPACT as they PROMISED the electorate and listen to the experts.
The primary school has insufficient places in its pre school classes, this must be clarified with the Head Teacher. SLDC must seek relevant information and account for this in it's plans, including the cost to tax payers for the free bus service all secondary pupils in Endmoor are intitled to.
The electricity was lost several times in 2011 as was water pressure. The sewarage system is at full capacity. The cost to tax payers to upgrade an already failing system would be massive. SLDC must consider the costs involved to the ordinary tax payers and be correct and frugle in the use of public money.
SLDC must show an interest in public opinion and not belittle the public as did your representative on a local radio show, calling any disagreament with your proposals as the "VOCAL MINORITY". This would appear completely UNDEMOCRATIC as it was stated before the submission deadline for opposition. Show the public some respect!
The proposed developments for the housing in Endmoor would increase the housing stock by 48% a figure not proposed any where else in South Lakeland. This means Endmoor would become 2/3rds the size of Milnthorpe, with none of the facilities. Endmoor having one local store which is up for sale and one small bakery. SLDC need to justift why a special case has been made of Endmoor and why surveyers are sizing up the field at the proposed site before public opnion has been sort or building permission granted. SLDC must be open and honest with the public and investigate or/and justify what is going on.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
642. Mr & Mrs K & L Myers (Individual) : 25 Apr 2012 10:10:00
Paragraph No.
1.10
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
SLOC are proceeding with this illogical proposal, rejecting credible evidence from the Town Council Report which is supported, unanimously, by Cumbria County Council Local area committee.
SLDC's official line is to disregard objections from residents affected by the proposed development -this is totally wrong as "evidence of participation of the local community", is a key requirement of soundness.
locally I understand there have been almost 400 people against and only 2 in favour of the development. Obviously, the land owner and the developer will be in favour, but neither live locally. Is it SLDC policy to value non locals at least 200 times more than locals? This does not conform to the latest Government proposals and is an unreasonable policy.
SLDC have failed to show that they have local support and that their proposal is based on facts.
It is basically an unjustified and unsound proposal.
643. Mr & Mrs K & L Myers (Individual) : 25 Apr 2012 10:17:00
Policy/Site No.
LA1.3 Housing Allocations - R121M-mod KENDAL EAST OF CASTLE GREEN ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
We are still very concerned about your proposal to develop R121M.
Drainage- there are already existing drainage issues through and around Oak Tree Road. We are not aware of any reports on the effects of this development on drainage. Has anyone from the council visited the site to see the volume of water
that cascades through the walls just above Oak Tree Road during very heavy rain? The water run-off from the field up to the railway has to go somewhere. Will this development have any effect on the railway embankment? The development
must have some effect on the Stockbeck Flood Alleviation Scheme. Why has every other proposed development which could affect the Stockbeck scheme been removed from consideration? Why not this one?To date none of these issues
have been addressed. These are serious omissions. This one issue could potentially show that the development is unviable.
Access-Two points of access are still proposed, one from Castle green Lane and one from Oak Tree road. To use Oak Tree Road would be a serious risk. It is a narrow road and to open it for through traffic would fundamentally change its use.
Your own 'Atkins' report supported this view and came to the conclusion that Oak Tree Road should not be used for access.
SLDC have failed to show that they have local support and that their proposal is based on facts.
It is basically an unjustified and unsound proposal.
644. Mr C Narrainen (Individual) : 24 Apr 2012 15:20:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA2.14 Land North of Sycamore Drive, Endmoor
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
Yes
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
645. Mr C Narrainen (Individual) : 24 Apr 2012 15:21:00
Policy/Site No.
LA1.3 Housing Allocations - M41M ENDMOOR NORTH OF SYCAMORE DRIVE
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
Yes
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
646. Miss S M Naylor (Individual) : 9 May 2012 17:07:00
Policy/Site No.
LA1.3 Housing Allocations - All Grange-over-Sands sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I have been meaning to write to you for quite a while as with many others around here I'm very concerned about our green fields area that you want ot build on. We must have green spaces for the bird and other wild life. Apart from that there will be a water problem, drains etc.
I hope you will reconsider this there is enough traffic around these parts now. It will spoil the whole area.
Please think again. Thank you.
647. Miss S M Naylor (Individual) : 14 May 2012 08:42:00
Policy/Site No.
LA3.1 Mixed Use Allocation at Berners Pool, Grange-over-Sands
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I have been meaning to write to you for quite a while as with many others around here I'm very concerned about our green fields area that you want ot build on. We must have green spaces for the bird and other wild life. Apart from that there will be a water problem, drains etc.
I hope you will reconsider this there is enough traffic around these parts now. It will spoil the whole area.
Please think again. Thank you.
648. Miss S M Naylor (Individual) : 14 May 2012 08:42:00
Policy/Site No.
LA3.2 Mixed Use Allocation at Land South of Allithwaite Road, Kent's Bank, Grange-over-Sands
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I have been meaning to write to you for quite a while as with many others around here I'm very concerned about our green fields area that you want ot build on. We must have green spaces for the bird and other wild life. Apart from that there will be a water problem, drains etc.
I hope you will reconsider this there is enough traffic around these parts now. It will spoil the whole area.
Please think again. Thank you.
649. Miss S M Naylor (Individual) : 14 May 2012 08:43:00
Policy/Site No.
LA3.3 Mixed Use Allocation at Guide's Lot, Grange-over-Sands
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I have been meaning to write to you for quite a while as with many others around here I'm very concerned about our green fields area that you want ot build on. We must have green spaces for the bird and other wild life. Apart from that there will be a water problem, drains etc.
I hope you will reconsider this there is enough traffic around these parts now. It will spoil the whole area.
Please think again. Thank you.
650. Mr and Mrs Keith & Pauline Mary Neighbour (Individual) : 8 Apr 2012 17:27:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
0.0 Whole Document
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The Land Allocations Document (DPD) is not within the Local Development Scheme and the key stages have not been followed
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Legal Compliance 1
One of the main common objections to the LDF is the sheer size and scale of the proposed Development within the District.
It would seem right at the very beginning of the LDF process SLDC had the facility to lobby the last Government’s Regional Spatial Strategy for an increase in its allocated figure of 265 dwellings per year and secured a 50% increase to take the District’s housing target to 400 per annum in an attempt to meet the affordable need.
This represented a 33% increase to the original allocated figure of 265 (an extra 133 dwellings per year). Therefore 33% of the 6,000 requirement is to meet the affordable need of 2,000 dwellings. As a result the district will see an accelerated growth increase of 33% above the original Regional Spatial Strategy’s allocated figure.
On the other hand right from the very beginning of this process, we the constituents were denied the facility, via the Consultation Response system, to oppose/question the numbers – informed by the Planners that you could not, they were sacrosanct.
But numbers are one of the major issues residents have about the proposals. This of course is entirely different to SLDC who did seem to have the right to oppose, and subsequently change the figures, a bit one-sided don’t you think?
The LDF does not conform at all to the original (until it is abolished) Regional Spatial Strategy numbers.
Legal Compliance 2
SLDC has failed to deliver appropriate, sufficient and effective methods of engagement in response to the needs of the community.
The public have been asked to submit to the soundness of a DPD comprising approximately 460 technical documents covering 14,500 pages (visually, this would represent a stack of A4 paper approx. 1.5 metres tall). SLDC chose only to allow for the minimally prescribed consultation period of six weeks.
Residents who are less inclined or able to read through a complex set of documents containing thousands of pages of text, tables, maps and appendices (either in paper form or via the SLDC website) have therefore been broadly excluded from making any substantial comments or submissions which are deemed to be ‘viable’ by SLDC.
It has failed to be creative in the way it reaches out to all parts of the community, participation has been limited to the usual ‘informed and active minority’.
Crucially, the disenfranchisement of the older generation from the consultation process has meant that a significant percentage of the population has been under-represented (where currently 29% of the population of South Lakeland is over 60).
Where SLDC have engaged with the public in face to face meetings in the community, it has been with a “presentational style” of plans to be delivered, rather than of options for consultation. It has been alleged that in response to challenges, SLDC representatives have been heard to comment at public meetings that the plans will be delivered ‘regardless of public opposition’. Despite an outward impression of a robust consultation process, it could be said this has simply been a ‘tick-the-box’ exercise.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
in any meaningful way when preparing the final land allocations document. To the contrary, there are instances where additional sites have been added or numbers of dwellings increased in areas where submissions were made opposing original plans.
The delivery of the consultation by SLDC has resulted in a sense of detachment from the planning process as many residents feel marginalised by an ‘indifferent approach’ to their opinions and aspirations for their neighbourhoods. Communities have not been treated as stake-holders in the future success of their towns and villages.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The LDF housing numbers proposed by SLDC have remained unchanged since the process began a number of years ago.
Kendal Town Council LDF LA Further Consultation Summer 2011 document highlighted the latest forecast produced in Spring 2011 showing a drastically reduced requirement:
• only 360 dwellings across the 20 years, or
• just over 4,000 including migration, projected on the last five years’ evidence.
This suggests that a more appropriate target for the next 5-10 years would be around 200 dwellings per annum.
I recognise the SLDC area needs truly affordable housing and I support that. However there must be concerns on SOUNDNESS about how this is going to be achieved because LA DPD proposes that it can only be delivered by the private sector. This strategy is untried, untested, aspirational and funded by inward migration purchasing market value dwellings on a ratio of two to one at accelerated growth rate.
No mention has been made in regard to the population increase of approx. 8,000 that will accompany this strategy. There appears to be no sound infrastructure delivery plan either to accommodate the increase in dwellings or the population.
Land allocation has been increased by a third, densities increased to 35dph and most of the land has to come from both Green Gap and Greenfield sites. Based on the latest KTC figures this cannot be JUSTIFIED. In addition it cannot be EFFECTIVE as no adjustment has been taken in regard to coherence with the strategies of neighbouring authorities. The Lake District National Park having identified a requirement of 900 affordable dwellings.
Proposed Changes I would like to see would include.
1 A reduction in the housing numbers in line with KTC updated forecast to 200 dwellings per annum.
2 A reduction of (the family jewels) i.e. Green Gap/Green Field Sites.
4 A reduction in housing densities from 35dph to a maximum of 25dph on Greenfield Sites.
5 The provision of affordable housing to include other funding mechanisms.
6 Coherence with the strategies of neighbouring authorities on affordable dwellings.
Why:-
Hope the above is self-explanatory.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
651. Mr and Mrs Keith & Pauline Mary Neighbour (Individual) : 8 Apr 2012 17:33:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.1 Development Boundaries- KENDAL
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I fully support KENDAL TOWN COUNCIL SUSTAINABLE DEVELOPMENT IN KENDAL Submission to the Planning Inspector SLDC Land Allocations DPD - Submission Edition March 2012 Approved by Council: 2nd April 2012
In particular their comments on:-
Making use of the latest housing forecasts to set short/medium term allocations, rather than the forecasts available at the time the Core Strategy was drawn up.
Recognising forecast errors in the planning process - this means ensuring that the new development can be sustainable within the range of likely outcomes over this period.
Support for and the importance of the Taylor Review 9 pulled together in July 2008 setting out the policy framework necessary to deliver the “vision of a living, working sustainable countryside”. Taylor provided compelling evidence that “doughnut development” was the wrong approach for sustainable rural market towns, and that a “hub and spoke” model represented the best pattern for sustainability.
The evidence in Taylor also shows that adopting this approach would make it considerably easier to deliver the dependent infrastructure.
The Town Council indicates that the LPA has clearly failed in its duty to compare against an alternative which is not only “reasonable”, but according to the best practice collated by Taylor, is also more sustainable, causes less problems with town centre infrastructure, and is more acceptable to residents.
They acknowledge that evidence in the EHLSS indicates that suitable sites could be available (the scope of the SHLAA only covered sites within existing settlement boundaries, and is of less relevance), and there are options both for completely new communities on green field sites, or for breathing new life into existing communities.
They are requesting the Inspector to instruct the LPA to produce a robust evaluation of alternative
approaches to land allocations to meet the housing targets identified for Kendal in the “Core Strategy”, with a particular focus on the recommendations of the Taylor Report.
They acknowledge Kendal residents identify “The level of traffic congestion” as their second highest priority for improvement - coming in just ahead of “Affordable decent housing”. So the LPA has been keen to demonstrate that the developments in the LDF can be delivered without exacerbating congestion in town.
They inform us that in 2009, the LPA commissioned a Kendal Transport Assessment, based on an earlier preliminary land allocation, from independent consultants WS Atkins.
This assessment concluded that the existing highway network plus proposed improvements would just
about accommodate the forecast level of traffic, provided three large sites were removed.
In the “Emerging Options” Land Allocations, these three sites were not only included, but were actually expanded in size. The LPA was challenged by the Town Council to justify this inclusion against the published evidence which the LPA had themselves commissioned from independent consultants.
In reply, the LPA chose not to re-engage independent consultants, but asked Cumbria County Council (CCC) to re-run their traffic models against the latest allocations.
There are two significant differences between the independent consultant’s report and this CCC work.
The CCC study had a significantly different approach to that of Atkins – which appears to result in discounting the LDF impact down from 15.6%/18.7% morning/afternoon down to just 2.3%/6.1%.
KTC then go to say even with this much more generous approach, the Interim study reached much the same conclusion that the existing highway network would not be able to accommodate the proposed levels of LDF
KTC have previously argued that Kendal’s infrastructure requires long term planning, with an evidence-based, published, and defensible roadmap for developing the town and its infrastructure to underpin planning policies.
They argue that with Kendal’s ageing infrastructure, improvements are so substantial that they are likely to need contributions from several partners to deliver and that there needs to be an overall credible plan for infrastructure.
They acknowledge the issues with traffic directly impact on the air quality in Kendal town centre. The air quality in Kendal currently fails statutory guidelines, and has deteriorated since 2008-09. Slow-moving traffic waiting at junction approaches is widely believed to be the major contributory factor.
The road network is already working at capacity, with the effect that NO2 levels in the town centre
are close to or above the Objective.
The CCC modelling work now shows that this “capacity” is simply not deliverable.
Applying the precautionary principle, the Council believes any planned Land Allocations which would be rejected on traffic grounds must also be rejected on air quality until a robust plan is in place.
Without a robust infrastructure “Master Plan” linked to sites, the Council fears it will prove impossible to enforce the necessary Section 106 obligations, which are governed by the government’s Circular 05/2005:20.
The Council asks the Inspector to withhold approval of the DPD until there is a credible infrastructure plan showing the impact of the major sites on the overall town infrastructure, and with high level solutions identified and costed with enough detail to enable the economic deliverability of the sites to be proven.
Proposed Changes I would like to see:-
1. All changes and suggestions as identified within all three of Kendal Town Council’s Sustainable Development in Kendal Submissions to the LPA in their response to the Local Development Framework.
Why - Because their submissions are based on reality and make total sense to me.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
652. Mr and Mrs Keith & Pauline Mary Neighbour (Individual) : 8 Apr 2012 17:44:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA2.2 Land North of Laurel Gardens
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
1) TRAFFIC
1.i) South Lakeland District Council commissioned an SLDC Transport Assessment Report (Atkins Report – June 2009) for future development in Kendal (see document “Kendal_TAJune_2009.pdf”).
Two of the three main conclusions stated are.
- The volume of development traffic from The Todds site, R170M west of Burneside Road was considered to be inappropriate for this location.
- Recommended that further development in the Shap Road/Appleby Road Corridor should be resisted.
The report (page 7) specifically mentions the Middle Sparrowmire R170M site (referred to as “The Todds”) as being inappropriate because “the Windermere Road corridor already suffers congestion and delays during peak periods, it is considered that additional large-scale development in this area will lead to deterioration in traffic conditions”.
Page 60 suggests site development proposals, which should be reviewed, includes site R170M.
Page 71 states “In addition, it is recommended that the size of residential development at the Todds (Sites R148/R170) and Stonebank Green (Sites M39/R676/R103/R675) should be subject to careful review to ensure that development does not adversely affect the operation of the highway network.”
1.ii) Kendal Town Council Response to Consultation - SLDC "Emerging Options" Land Allocation DPD- April 2011
• The Todds, west of Burneside Road (Sites R148/R170) - 317 houses - has become Sites
R170M/R46/RN169M/R44 - 403 houses, plus Sites sharing the same traffic corridor, R489M and
M38M in Burneside - 102 houses.
The evidence from the previous Assessment is that these latest Allocations currently do not have a traffic solution which would make them deliverable. The Council believes these sites should not be included in Allocations until a solution is put forward which successfully passes the modelling test.
This statement refers to site R170M.
1.iii) Kendal Local Development Framework Transport Study Revised Modelling Results
• Cumbria County Council January 2012 has been put forward as a possible solution to Kendal’s traffic infrastructure including possible traffic solutions for site R170M.
The LDF has been in the consultation stage for 8 years, yet here we are at the 11th hour with a Traffic STUDY including some dubious results (see Kendal Town Council Submission) not a PLAN.
This is a STUDY it is NOT a PLAN – there is no commitment to deliver the schemes mentioned – some of the schemes involved are big, expensive, will require extensive environmental and economic assessment to confirm whether they are practical, justified or even whether they are deliverable. When the studies have been completed they would have to enter some formal forward programme and they would have to go through their own “planning process” including land acquisition which would/could involve compulsory purchase. So there is no commitment – the study even says that they would be expensive and difficult to justify in terms of their benefit to the network in the town.
All of the schemes together only result in “no detriment”. There is no evidence that any of the projects are deliverable. There is no commitment by “partners” ie Cumbria CC to deliver the larger projects.
1.v) The development of site R170M and other sites at Burneside would increase traffic flows along Burneside Road. Burneside Road has many adverse safety features throughout its urban length which simply cannot be addressed by any physical means. Without a credible Transport plan in place, the development of site R170M should be removed from the LA DPD.
Policy LA2.2 is unsound to include site R170M within the LA DPD.
2) TRAFFIC ACCESS
2.i) Access to site R170M would have to be from the already busy ‘C’ class highway, between bends with severely restricted visibility and alongside an expanding Golf Club (Carus Green). It would be difficult if not impossible to achieve safely. Cumbria County Council (Highways) admits - “achieving adequate visibility will be problematic given alignment of road and limited frontage. Such a large site would require a secondary access”.
The Conclusion of a privately commissioned report undertaken by a Chartered Civil Engineer stated :- “There is severely restricted forward visibility on both bends in Burneside Road either side of the proposed access location.
In either scenario tested the visibility from the proposed access towards Kendal falls far short of the standard required.
A new junction cannot be safely introduced in this location.”
2.ii) Cumbria County Council (Highways) state site R170M would require a secondary access route. There is no information available on any Consultation Documentation relating to the reason for this or the location of a secondary access route.
2.iii) To include this ‘C’ class highway as a possible location for access and without an identified location for a secondary access route makes the Policy LA2.2 unsound to include site R170M within the LA DPD.
3) GREEN GAP
3.i) Site R170M is part of a Green Gap retained as Green Gap following the last Public Inquiry (1996).
3.ii) Confusion over Green Gap and Coalescence R170M Site History
Site R170M was removed by SLDC in its Deposit Draft just prior to the public inquiry in 1996. There was an objection to this removal by the land owner Mr Downham. This is what it states on page 137 of the Inspector's Report 1996:
"Inspector's Conclusions:
6.9 The objection by Mr Downham is not concerned with the provision of a green gap, but the extent of that gap. It is argued that the green gap, as shown in the Consultation draft of the Plan, follows a public footpath running between substantial hedges, a clearly defined landscape boundary: whilst the residential allocation at Sparrowmire has been reduced in the Deposit Draft, an equivalent extension to the green gap is not necessary. However, and most importantly in my view, the objection indicates that the "land should remain unallocated as white land so that when the Plan is reviewed in 10 years' time it can be considered as potential residential land". I consider this underlying reason for excluding the land from the green gap identifies the very reason it should remain so designated. Structure Plan Policy 14 and the reasoned justification makes no reference to the length of time during which the vulnerable areas of countryside between settlements should be protected. Although policies and proposals in the Local Plan must clearly relate to the Plan period, and can be subject to review thereafter, it appears to me common sense that what is unacceptable now, will most probably be equally unacceptable at the end of the Plan period: certainly I consider the Plan should seek to engender a degree of public confidence that the separation secured will not, at some future time, be lightly squandered. For these reasons I believe that, where a green gap is seen as necessary, it is more important that the whole gap between the settlements should be designated as green gap than that substantial, but arbitrary landscape features should be rigidly followed. I also consider the inter-visibility of settlements is not a factor which should affect the definition of green gaps."
3.iii) Site R170M should not have been included in proposed policy LA2.2 because it was assessed at the last Public Inquiry (1996). The Public Inspectors conclusion in considering that future plans should seek to engender a degree of public confidence and that the inter-visibility of settlements is not a factor which should affect the definition of green gaps should not be overturned.
3.v) Burneside Parish Council also rejected R170M as this site would further erode the designated Green Gap to prevent coalescence with Burneside.
4) SEWERAGE
4.i) United Utilities state there are major issues on the network with no investment programmed before 2015. These issues relate to problems with the Kentrigg Sewer and that major investment is needed prior to development of site R170M.
Our understanding is that there is no guarantee of investment after 2015 to build the necessary sewerage infrastructure required to develop site R170M and the scale of investment is unlikely to be affordable by any developer.
4.ii) Without the necessary sewerage infrastructure in place policy LA2.2 is unsound and not deliverable in relation to site R170M.
5) FLOODING
5.i) There are known flooding issues on site R170M, which was one of the main reasons this site was rejected some time ago at the last Public Inquiry.
Since the development of the Briarigg estate some 8 years ago there is now new flooding over Burneside Road and into several residential properties adjacent to the bridleway on the west side of Burneside Road. It is inevitable development of site R170M will increase the flood risk to these and even more properties in the area.
7) LANDSCAPE CHARACTER AND PREVIOUS EXPANSION
7.i) Previous expansion in this area includes Moor Field Close, Kettlewell Road, Acre Moss Lane, Overdale Close, Mossghyll, Aysgarth Close, Peat Bank, Newbiggin and the Briarigg Estate.
This amounts to some 400 dwellings over 18 hectares of greenfield sites.
The proposed policy LA2.2 is unsound to include another 197 dwellings over yet another 7.85 hectares of open greenfield Green Gap land.
7.ii) South Lakeland Employment and Housing Land Search Study stated “There is some potential for expansion in the area, although given the scale of previous expansion, this should be limited. This study discounted the site R170M as a potential suitable area for development.”
8) ACCESS TO FACILITIES
8.i) All the main facilities are distant - Doctors, Hospital, Schools, Shops, Supermarkets, Rail Links, Bus Links and employment sites. The inevitable result of this will therefore necessitate yet more journeys across Kendal town breaching sustainability by adding to the already congested highway infrastructure (see Atkins report).
This again makes site R170M unsound and unsustainable.
Proposed Changes I would like to see:-
1 The removal of site R170M from LDF.
Why:-
For all the above reasons.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
653. Mr and Mrs Keith & Pauline Mary Neighbour (Individual) : 18 May 2012 15:32:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - R170M-mod KENDAL NORTH OF LAUREL GARDENS
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
1) TRAFFIC
1.i) South Lakeland District Council commissioned an SLDC Transport Assessment Report (Atkins Report – June 2009) for future development in Kendal (see document “Kendal_TAJune_2009.pdf”).
Two of the three main conclusions stated are.
- The volume of development traffic from The Todds site, R170M west of Burneside Road was considered to be inappropriate for this location.
- Recommended that further development in the Shap Road/Appleby Road Corridor should be resisted.
The report (page 7) specifically mentions the Middle Sparrowmire R170M site (referred to as “The Todds”) as being inappropriate because “the Windermere Road corridor already suffers congestion and delays during peak periods, it is considered that additional large-scale development in this area will lead to deterioration in traffic conditions”.
Page 60 suggests site development proposals, which should be reviewed, includes site R170M.
Page 71 states “In addition, it is recommended that the size of residential development at the Todds (Sites R148/R170) and Stonebank Green (Sites M39/R676/R103/R675) should be subject to careful review to ensure that development does not adversely affect the operation of the highway network.”
1.ii) Kendal Town Council Response to Consultation - SLDC "Emerging Options" Land Allocation DPD- April 2011
• The Todds, west of Burneside Road (Sites R148/R170) - 317 houses - has become Sites
R170M/R46/RN169M/R44 - 403 houses, plus Sites sharing the same traffic corridor, R489M and
M38M in Burneside - 102 houses.
The evidence from the previous Assessment is that these latest Allocations currently do not have a traffic solution which would make them deliverable. The Council believes these sites should not be included in Allocations until a solution is put forward which successfully passes the modelling test.
This statement refers to site R170M.
1.iii) Kendal Local Development Framework Transport Study Revised Modelling Results
• Cumbria County Council January 2012 has been put forward as a possible solution to Kendal’s traffic infrastructure including possible traffic solutions for site R170M.
The LDF has been in the consultation stage for 8 years, yet here we are at the 11th hour with a Traffic STUDY including some dubious results (see Kendal Town Council Submission) not a PLAN.
This is a STUDY it is NOT a PLAN – there is no commitment to deliver the schemes mentioned – some of the schemes involved are big, expensive, will require extensive environmental and economic assessment to confirm whether they are practical, justified or even whether they are deliverable. When the studies have been completed they would have to enter some formal forward programme and they would have to go through their own “planning process” including land acquisition which would/could involve compulsory purchase. So there is no commitment – the study even says that they would be expensive and difficult to justify in terms of their benefit to the network in the town.
All of the schemes together only result in “no detriment”. There is no evidence that any of the projects are deliverable. There is no commitment by “partners” ie Cumbria CC to deliver the larger projects.
1.v) The development of site R170M and other sites at Burneside would increase traffic flows along Burneside Road. Burneside Road has many adverse safety features throughout its urban length which simply cannot be addressed by any physical means. Without a credible Transport plan in place, the development of site R170M should be removed from the LA DPD.
Policy LA2.2 is unsound to include site R170M within the LA DPD.
2) TRAFFIC ACCESS
2.i) Access to site R170M would have to be from the already busy ‘C’ class highway, between bends with severely restricted visibility and alongside an expanding Golf Club (Carus Green). It would be difficult if not impossible to achieve safely. Cumbria County Council (Highways) admits - “achieving adequate visibility will be problematic given alignment of road and limited frontage. Such a large site would require a secondary access”.
The Conclusion of a privately commissioned report undertaken by a Chartered Civil Engineer stated :- “There is severely restricted forward visibility on both bends in Burneside Road either side of the proposed access location.
In either scenario tested the visibility from the proposed access towards Kendal falls far short of the standard required.
A new junction cannot be safely introduced in this location.”
2.ii) Cumbria County Council (Highways) state site R170M would require a secondary access route. There is no information available on any Consultation Documentation relating to the reason for this or the location of a secondary access route.
2.iii) To include this ‘C’ class highway as a possible location for access and without an identified location for a secondary access route makes the Policy LA2.2 unsound to include site R170M within the LA DPD.
3) GREEN GAP
3.i) Site R170M is part of a Green Gap retained as Green Gap following the last Public Inquiry (1996).
3.ii) Confusion over Green Gap and Coalescence R170M Site History
Site R170M was removed by SLDC in its Deposit Draft just prior to the public inquiry in 1996. There was an objection to this removal by the land owner Mr Downham. This is what it states on page 137 of the Inspector's Report 1996:
"Inspector's Conclusions:
6.9 The objection by Mr Downham is not concerned with the provision of a green gap, but the extent of that gap. It is argued that the green gap, as shown in the Consultation draft of the Plan, follows a public footpath running between substantial hedges, a clearly defined landscape boundary: whilst the residential allocation at Sparrowmire has been reduced in the Deposit Draft, an equivalent extension to the green gap is not necessary. However, and most importantly in my view, the objection indicates that the "land should remain unallocated as white land so that when the Plan is reviewed in 10 years' time it can be considered as potential residential land". I consider this underlying reason for excluding the land from the green gap identifies the very reason it should remain so designated. Structure Plan Policy 14 and the reasoned justification makes no reference to the length of time during which the vulnerable areas of countryside between settlements should be protected. Although policies and proposals in the Local Plan must clearly relate to the Plan period, and can be subject to review thereafter, it appears to me common sense that what is unacceptable now, will most probably be equally unacceptable at the end of the Plan period: certainly I consider the Plan should seek to engender a degree of public confidence that the separation secured will not, at some future time, be lightly squandered. For these reasons I believe that, where a green gap is seen as necessary, it is more important that the whole gap between the settlements should be designated as green gap than that substantial, but arbitrary landscape features should be rigidly followed. I also consider the inter-visibility of settlements is not a factor which should affect the definition of green gaps."
3.iii) Site R170M should not have been included in proposed policy LA2.2 because it was assessed at the last Public Inquiry (1996). The Public Inspectors conclusion in considering that future plans should seek to engender a degree of public confidence and that the inter-visibility of settlements is not a factor which should affect the definition of green gaps should not be overturned.
3.v) Burneside Parish Council also rejected R170M as this site would further erode the designated Green Gap to prevent coalescence with Burneside.
4) SEWERAGE
4.i) United Utilities state there are major issues on the network with no investment programmed before 2015. These issues relate to problems with the Kentrigg Sewer and that major investment is needed prior to development of site R170M.
Our understanding is that there is no guarantee of investment after 2015 to build the necessary sewerage infrastructure required to develop site R170M and the scale of investment is unlikely to be affordable by any developer.
4.ii) Without the necessary sewerage infrastructure in place policy LA2.2 is unsound and not deliverable in relation to site R170M.
5) FLOODING
5.i) There are known flooding issues on site R170M, which was one of the main reasons this site was rejected some time ago at the last Public Inquiry.
Since the development of the Briarigg estate some 8 years ago there is now new flooding over Burneside Road and into several residential properties adjacent to the bridleway on the west side of Burneside Road. It is inevitable development of site R170M will increase the flood risk to these and even more properties in the area.
7) LANDSCAPE CHARACTER AND PREVIOUS EXPANSION
7.i) Previous expansion in this area includes Moor Field Close, Kettlewell Road, Acre Moss Lane, Overdale Close, Mossghyll, Aysgarth Close, Peat Bank, Newbiggin and the Briarigg Estate.
This amounts to some 400 dwellings over 18 hectares of greenfield sites.
The proposed policy LA2.2 is unsound to include another 197 dwellings over yet another 7.85 hectares of open greenfield Green Gap land.
7.ii) South Lakeland Employment and Housing Land Search Study stated “There is some potential for expansion in the area, although given the scale of previous expansion, this should be limited. This study discounted the site R170M as a potential suitable area for development.”
8) ACCESS TO FACILITIES
8.i) All the main facilities are distant - Doctors, Hospital, Schools, Shops, Supermarkets, Rail Links, Bus Links and employment sites. The inevitable result of this will therefore necessitate yet more journeys across Kendal town breaching sustainability by adding to the already congested highway infrastructure (see Atkins report).
This again makes site R170M unsound and unsustainable.
Proposed Changes I would like to see:-
1 The removal of site R170M from LDF.
Why:-
For all the above reasons.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
654. Mr and Mrs Keith & Pauline Mary Neighbour (Individual) : 18 May 2012 16:21:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - All Kendal sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I fully support KENDAL TOWN COUNCIL SUSTAINABLE DEVELOPMENT IN KENDAL Submission to the Planning Inspector SLDC Land Allocations DPD - Submission Edition March 2012 Approved by Council: 2nd April 2012
In particular their comments on:-
Making use of the latest housing forecasts to set short/medium term allocations, rather than the forecasts available at the time the Core Strategy was drawn up.
Recognising forecast errors in the planning process - this means ensuring that the new development can be sustainable within the range of likely outcomes over this period.
Support for and the importance of the Taylor Review 9 pulled together in July 2008 setting out the policy framework necessary to deliver the “vision of a living, working sustainable countryside”. Taylor provided compelling evidence that “doughnut development” was the wrong approach for sustainable rural market towns, and that a “hub and spoke” model represented the best pattern for sustainability.
The evidence in Taylor also shows that adopting this approach would make it considerably easier to deliver the dependent infrastructure.
The Town Council indicates that the LPA has clearly failed in its duty to compare against an alternative which is not only “reasonable”, but according to the best practice collated by Taylor, is also more sustainable, causes less problems with town centre infrastructure, and is more acceptable to residents.
They acknowledge that evidence in the EHLSS indicates that suitable sites could be available (the scope of the SHLAA only covered sites within existing settlement boundaries, and is of less relevance), and there are options both for completely new communities on green field sites, or for breathing new life into existing communities.
They are requesting the Inspector to instruct the LPA to produce a robust evaluation of alternative
approaches to land allocations to meet the housing targets identified for Kendal in the “Core Strategy”, with a particular focus on the recommendations of the Taylor Report.
They acknowledge Kendal residents identify “The level of traffic congestion” as their second highest priority for improvement - coming in just ahead of “Affordable decent housing”. So the LPA has been keen to demonstrate that the developments in the LDF can be delivered without exacerbating congestion in town.
They inform us that in 2009, the LPA commissioned a Kendal Transport Assessment, based on an earlier preliminary land allocation, from independent consultants WS Atkins.
This assessment concluded that the existing highway network plus proposed improvements would just
about accommodate the forecast level of traffic, provided three large sites were removed.
In the “Emerging Options” Land Allocations, these three sites were not only included, but were actually expanded in size. The LPA was challenged by the Town Council to justify this inclusion against the published evidence which the LPA had themselves commissioned from independent consultants.
In reply, the LPA chose not to re-engage independent consultants, but asked Cumbria County Council (CCC) to re-run their traffic models against the latest allocations.
There are two significant differences between the independent consultant’s report and this CCC work.
The CCC study had a significantly different approach to that of Atkins – which appears to result in discounting the LDF impact down from 15.6%/18.7% morning/afternoon down to just 2.3%/6.1%.
KTC then go to say even with this much more generous approach, the Interim study reached much the same conclusion that the existing highway network would not be able to accommodate the proposed levels of LDF
KTC have previously argued that Kendal’s infrastructure requires long term planning, with an evidence-based, published, and defensible roadmap for developing the town and its infrastructure to underpin planning policies.
They argue that with Kendal’s ageing infrastructure, improvements are so substantial that they are likely to need contributions from several partners to deliver and that there needs to be an overall credible plan for infrastructure.
They acknowledge the issues with traffic directly impact on the air quality in Kendal town centre. The air quality in Kendal currently fails statutory guidelines, and has deteriorated since 2008-09. Slow-moving traffic waiting at junction approaches is widely believed to be the major contributory factor.
The road network is already working at capacity, with the effect that NO2 levels in the town centre
are close to or above the Objective.
The CCC modelling work now shows that this “capacity” is simply not deliverable.
Applying the precautionary principle, the Council believes any planned Land Allocations which would be rejected on traffic grounds must also be rejected on air quality until a robust plan is in place.
Without a robust infrastructure “Master Plan” linked to sites, the Council fears it will prove impossible to enforce the necessary Section 106 obligations, which are governed by the government’s Circular 05/2005:20.
The Council asks the Inspector to withhold approval of the DPD until there is a credible infrastructure plan showing the impact of the major sites on the overall town infrastructure, and with high level solutions identified and costed with enough detail to enable the economic deliverability of the sites to be proven.
Proposed Changes I would like to see:-
1. All changes and suggestions as identified within all three of Kendal Town Council’s Sustainable Development in Kendal Submissions to the LPA in their response to the Local Development Framework.
Why - Because their submissions are based on reality and make total sense to me.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
655. Mr and Mrs Keith & Pauline Mary Neighbour (Individual) : 18 May 2012 16:23:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.4 - Kendal Sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I fully support KENDAL TOWN COUNCIL SUSTAINABLE DEVELOPMENT IN KENDAL Submission to the Planning Inspector SLDC Land Allocations DPD - Submission Edition March 2012 Approved by Council: 2nd April 2012
In particular their comments on:-
Making use of the latest housing forecasts to set short/medium term allocations, rather than the forecasts available at the time the Core Strategy was drawn up.
Recognising forecast errors in the planning process - this means ensuring that the new development can be sustainable within the range of likely outcomes over this period.
Support for and the importance of the Taylor Review 9 pulled together in July 2008 setting out the policy framework necessary to deliver the “vision of a living, working sustainable countryside”. Taylor provided compelling evidence that “doughnut development” was the wrong approach for sustainable rural market towns, and that a “hub and spoke” model represented the best pattern for sustainability.
The evidence in Taylor also shows that adopting this approach would make it considerably easier to deliver the dependent infrastructure.
The Town Council indicates that the LPA has clearly failed in its duty to compare against an alternative which is not only “reasonable”, but according to the best practice collated by Taylor, is also more sustainable, causes less problems with town centre infrastructure, and is more acceptable to residents.
They acknowledge that evidence in the EHLSS indicates that suitable sites could be available (the scope of the SHLAA only covered sites within existing settlement boundaries, and is of less relevance), and there are options both for completely new communities on green field sites, or for breathing new life into existing communities.
They are requesting the Inspector to instruct the LPA to produce a robust evaluation of alternative
approaches to land allocations to meet the housing targets identified for Kendal in the “Core Strategy”, with a particular focus on the recommendations of the Taylor Report.
They acknowledge Kendal residents identify “The level of traffic congestion” as their second highest priority for improvement - coming in just ahead of “Affordable decent housing”. So the LPA has been keen to demonstrate that the developments in the LDF can be delivered without exacerbating congestion in town.
They inform us that in 2009, the LPA commissioned a Kendal Transport Assessment, based on an earlier preliminary land allocation, from independent consultants WS Atkins.
This assessment concluded that the existing highway network plus proposed improvements would just
about accommodate the forecast level of traffic, provided three large sites were removed.
In the “Emerging Options” Land Allocations, these three sites were not only included, but were actually expanded in size. The LPA was challenged by the Town Council to justify this inclusion against the published evidence which the LPA had themselves commissioned from independent consultants.
In reply, the LPA chose not to re-engage independent consultants, but asked Cumbria County Council (CCC) to re-run their traffic models against the latest allocations.
There are two significant differences between the independent consultant’s report and this CCC work.
The CCC study had a significantly different approach to that of Atkins – which appears to result in discounting the LDF impact down from 15.6%/18.7% morning/afternoon down to just 2.3%/6.1%.
KTC then go to say even with this much more generous approach, the Interim study reached much the same conclusion that the existing highway network would not be able to accommodate the proposed levels of LDF
KTC have previously argued that Kendal’s infrastructure requires long term planning, with an evidence-based, published, and defensible roadmap for developing the town and its infrastructure to underpin planning policies.
They argue that with Kendal’s ageing infrastructure, improvements are so substantial that they are likely to need contributions from several partners to deliver and that there needs to be an overall credible plan for infrastructure.
They acknowledge the issues with traffic directly impact on the air quality in Kendal town centre. The air quality in Kendal currently fails statutory guidelines, and has deteriorated since 2008-09. Slow-moving traffic waiting at junction approaches is widely believed to be the major contributory factor.
The road network is already working at capacity, with the effect that NO2 levels in the town centre
are close to or above the Objective.
The CCC modelling work now shows that this “capacity” is simply not deliverable.
Applying the precautionary principle, the Council believes any planned Land Allocations which would be rejected on traffic grounds must also be rejected on air quality until a robust plan is in place.
Without a robust infrastructure “Master Plan” linked to sites, the Council fears it will prove impossible to enforce the necessary Section 106 obligations, which are governed by the government’s Circular 05/2005:20.
The Council asks the Inspector to withhold approval of the DPD until there is a credible infrastructure plan showing the impact of the major sites on the overall town infrastructure, and with high level solutions identified and costed with enough detail to enable the economic deliverability of the sites to be proven.
Proposed Changes I would like to see:-
1. All changes and suggestions as identified within all three of Kendal Town Council’s Sustainable Development in Kendal Submissions to the LPA in their response to the Local Development Framework.
Why - Because their submissions are based on reality and make total sense to me.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
656. Mr and Mrs Keith & Pauline Mary Neighbour (Individual) : 18 May 2012 16:23:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.6 Strategic Employment Sites - E4M KENDAL LAND AT SCROGGS WOOD, MILNTHORPE ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I fully support KENDAL TOWN COUNCIL SUSTAINABLE DEVELOPMENT IN KENDAL Submission to the Planning Inspector SLDC Land Allocations DPD - Submission Edition March 2012 Approved by Council: 2nd April 2012
In particular their comments on:-
Making use of the latest housing forecasts to set short/medium term allocations, rather than the forecasts available at the time the Core Strategy was drawn up.
Recognising forecast errors in the planning process - this means ensuring that the new development can be sustainable within the range of likely outcomes over this period.
Support for and the importance of the Taylor Review 9 pulled together in July 2008 setting out the policy framework necessary to deliver the “vision of a living, working sustainable countryside”. Taylor provided compelling evidence that “doughnut development” was the wrong approach for sustainable rural market towns, and that a “hub and spoke” model represented the best pattern for sustainability.
The evidence in Taylor also shows that adopting this approach would make it considerably easier to deliver the dependent infrastructure.
The Town Council indicates that the LPA has clearly failed in its duty to compare against an alternative which is not only “reasonable”, but according to the best practice collated by Taylor, is also more sustainable, causes less problems with town centre infrastructure, and is more acceptable to residents.
They acknowledge that evidence in the EHLSS indicates that suitable sites could be available (the scope of the SHLAA only covered sites within existing settlement boundaries, and is of less relevance), and there are options both for completely new communities on green field sites, or for breathing new life into existing communities.
They are requesting the Inspector to instruct the LPA to produce a robust evaluation of alternative
approaches to land allocations to meet the housing targets identified for Kendal in the “Core Strategy”, with a particular focus on the recommendations of the Taylor Report.
They acknowledge Kendal residents identify “The level of traffic congestion” as their second highest priority for improvement - coming in just ahead of “Affordable decent housing”. So the LPA has been keen to demonstrate that the developments in the LDF can be delivered without exacerbating congestion in town.
They inform us that in 2009, the LPA commissioned a Kendal Transport Assessment, based on an earlier preliminary land allocation, from independent consultants WS Atkins.
This assessment concluded that the existing highway network plus proposed improvements would just
about accommodate the forecast level of traffic, provided three large sites were removed.
In the “Emerging Options” Land Allocations, these three sites were not only included, but were actually expanded in size. The LPA was challenged by the Town Council to justify this inclusion against the published evidence which the LPA had themselves commissioned from independent consultants.
In reply, the LPA chose not to re-engage independent consultants, but asked Cumbria County Council (CCC) to re-run their traffic models against the latest allocations.
There are two significant differences between the independent consultant’s report and this CCC work.
The CCC study had a significantly different approach to that of Atkins – which appears to result in discounting the LDF impact down from 15.6%/18.7% morning/afternoon down to just 2.3%/6.1%.
KTC then go to say even with this much more generous approach, the Interim study reached much the same conclusion that the existing highway network would not be able to accommodate the proposed levels of LDF
KTC have previously argued that Kendal’s infrastructure requires long term planning, with an evidence-based, published, and defensible roadmap for developing the town and its infrastructure to underpin planning policies.
They argue that with Kendal’s ageing infrastructure, improvements are so substantial that they are likely to need contributions from several partners to deliver and that there needs to be an overall credible plan for infrastructure.
They acknowledge the issues with traffic directly impact on the air quality in Kendal town centre. The air quality in Kendal currently fails statutory guidelines, and has deteriorated since 2008-09. Slow-moving traffic waiting at junction approaches is widely believed to be the major contributory factor.
The road network is already working at capacity, with the effect that NO2 levels in the town centre
are close to or above the Objective.
The CCC modelling work now shows that this “capacity” is simply not deliverable.
Applying the precautionary principle, the Council believes any planned Land Allocations which would be rejected on traffic grounds must also be rejected on air quality until a robust plan is in place.
Without a robust infrastructure “Master Plan” linked to sites, the Council fears it will prove impossible to enforce the necessary Section 106 obligations, which are governed by the government’s Circular 05/2005:20.
The Council asks the Inspector to withhold approval of the DPD until there is a credible infrastructure plan showing the impact of the major sites on the overall town infrastructure, and with high level solutions identified and costed with enough detail to enable the economic deliverability of the sites to be proven.
Proposed Changes I would like to see:-
1. All changes and suggestions as identified within all three of Kendal Town Council’s Sustainable Development in Kendal Submissions to the LPA in their response to the Local Development Framework.
Why - Because their submissions are based on reality and make total sense to me.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
657. Mr and Mrs Keith & Pauline Mary Neighbour (Individual) : 18 May 2012 16:24:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.7 Business and Science Park Sites - M2M-mod KENDAL LAND EAST OF BURTON ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I fully support KENDAL TOWN COUNCIL SUSTAINABLE DEVELOPMENT IN KENDAL Submission to the Planning Inspector SLDC Land Allocations DPD - Submission Edition March 2012 Approved by Council: 2nd April 2012
In particular their comments on:-
Making use of the latest housing forecasts to set short/medium term allocations, rather than the forecasts available at the time the Core Strategy was drawn up.
Recognising forecast errors in the planning process - this means ensuring that the new development can be sustainable within the range of likely outcomes over this period.
Support for and the importance of the Taylor Review 9 pulled together in July 2008 setting out the policy framework necessary to deliver the “vision of a living, working sustainable countryside”. Taylor provided compelling evidence that “doughnut development” was the wrong approach for sustainable rural market towns, and that a “hub and spoke” model represented the best pattern for sustainability.
The evidence in Taylor also shows that adopting this approach would make it considerably easier to deliver the dependent infrastructure.
The Town Council indicates that the LPA has clearly failed in its duty to compare against an alternative which is not only “reasonable”, but according to the best practice collated by Taylor, is also more sustainable, causes less problems with town centre infrastructure, and is more acceptable to residents.
They acknowledge that evidence in the EHLSS indicates that suitable sites could be available (the scope of the SHLAA only covered sites within existing settlement boundaries, and is of less relevance), and there are options both for completely new communities on green field sites, or for breathing new life into existing communities.
They are requesting the Inspector to instruct the LPA to produce a robust evaluation of alternative
approaches to land allocations to meet the housing targets identified for Kendal in the “Core Strategy”, with a particular focus on the recommendations of the Taylor Report.
They acknowledge Kendal residents identify “The level of traffic congestion” as their second highest priority for improvement - coming in just ahead of “Affordable decent housing”. So the LPA has been keen to demonstrate that the developments in the LDF can be delivered without exacerbating congestion in town.
They inform us that in 2009, the LPA commissioned a Kendal Transport Assessment, based on an earlier preliminary land allocation, from independent consultants WS Atkins.
This assessment concluded that the existing highway network plus proposed improvements would just
about accommodate the forecast level of traffic, provided three large sites were removed.
In the “Emerging Options” Land Allocations, these three sites were not only included, but were actually expanded in size. The LPA was challenged by the Town Council to justify this inclusion against the published evidence which the LPA had themselves commissioned from independent consultants.
In reply, the LPA chose not to re-engage independent consultants, but asked Cumbria County Council (CCC) to re-run their traffic models against the latest allocations.
There are two significant differences between the independent consultant’s report and this CCC work.
The CCC study had a significantly different approach to that of Atkins – which appears to result in discounting the LDF impact down from 15.6%/18.7% morning/afternoon down to just 2.3%/6.1%.
KTC then go to say even with this much more generous approach, the Interim study reached much the same conclusion that the existing highway network would not be able to accommodate the proposed levels of LDF
KTC have previously argued that Kendal’s infrastructure requires long term planning, with an evidence-based, published, and defensible roadmap for developing the town and its infrastructure to underpin planning policies.
They argue that with Kendal’s ageing infrastructure, improvements are so substantial that they are likely to need contributions from several partners to deliver and that there needs to be an overall credible plan for infrastructure.
They acknowledge the issues with traffic directly impact on the air quality in Kendal town centre. The air quality in Kendal currently fails statutory guidelines, and has deteriorated since 2008-09. Slow-moving traffic waiting at junction approaches is widely believed to be the major contributory factor.
The road network is already working at capacity, with the effect that NO2 levels in the town centre
are close to or above the Objective.
The CCC modelling work now shows that this “capacity” is simply not deliverable.
Applying the precautionary principle, the Council believes any planned Land Allocations which would be rejected on traffic grounds must also be rejected on air quality until a robust plan is in place.
Without a robust infrastructure “Master Plan” linked to sites, the Council fears it will prove impossible to enforce the necessary Section 106 obligations, which are governed by the government’s Circular 05/2005:20.
The Council asks the Inspector to withhold approval of the DPD until there is a credible infrastructure plan showing the impact of the major sites on the overall town infrastructure, and with high level solutions identified and costed with enough detail to enable the economic deliverability of the sites to be proven.
Proposed Changes I would like to see:-
1. All changes and suggestions as identified within all three of Kendal Town Council’s Sustainable Development in Kendal Submissions to the LPA in their response to the Local Development Framework.
Why - Because their submissions are based on reality and make total sense to me.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
658. Mr and Mrs Keith & Pauline Mary Neighbour (Individual) : 18 May 2012 16:25:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.8 Local Employment Sites - All Kendal sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I fully support KENDAL TOWN COUNCIL SUSTAINABLE DEVELOPMENT IN KENDAL Submission to the Planning Inspector SLDC Land Allocations DPD - Submission Edition March 2012 Approved by Council: 2nd April 2012
In particular their comments on:-
Making use of the latest housing forecasts to set short/medium term allocations, rather than the forecasts available at the time the Core Strategy was drawn up.
Recognising forecast errors in the planning process - this means ensuring that the new development can be sustainable within the range of likely outcomes over this period.
Support for and the importance of the Taylor Review 9 pulled together in July 2008 setting out the policy framework necessary to deliver the “vision of a living, working sustainable countryside”. Taylor provided compelling evidence that “doughnut development” was the wrong approach for sustainable rural market towns, and that a “hub and spoke” model represented the best pattern for sustainability.
The evidence in Taylor also shows that adopting this approach would make it considerably easier to deliver the dependent infrastructure.
The Town Council indicates that the LPA has clearly failed in its duty to compare against an alternative which is not only “reasonable”, but according to the best practice collated by Taylor, is also more sustainable, causes less problems with town centre infrastructure, and is more acceptable to residents.
They acknowledge that evidence in the EHLSS indicates that suitable sites could be available (the scope of the SHLAA only covered sites within existing settlement boundaries, and is of less relevance), and there are options both for completely new communities on green field sites, or for breathing new life into existing communities.
They are requesting the Inspector to instruct the LPA to produce a robust evaluation of alternative
approaches to land allocations to meet the housing targets identified for Kendal in the “Core Strategy”, with a particular focus on the recommendations of the Taylor Report.
They acknowledge Kendal residents identify “The level of traffic congestion” as their second highest priority for improvement - coming in just ahead of “Affordable decent housing”. So the LPA has been keen to demonstrate that the developments in the LDF can be delivered without exacerbating congestion in town.
They inform us that in 2009, the LPA commissioned a Kendal Transport Assessment, based on an earlier preliminary land allocation, from independent consultants WS Atkins.
This assessment concluded that the existing highway network plus proposed improvements would just
about accommodate the forecast level of traffic, provided three large sites were removed.
In the “Emerging Options” Land Allocations, these three sites were not only included, but were actually expanded in size. The LPA was challenged by the Town Council to justify this inclusion against the published evidence which the LPA had themselves commissioned from independent consultants.
In reply, the LPA chose not to re-engage independent consultants, but asked Cumbria County Council (CCC) to re-run their traffic models against the latest allocations.
There are two significant differences between the independent consultant’s report and this CCC work.
The CCC study had a significantly different approach to that of Atkins – which appears to result in discounting the LDF impact down from 15.6%/18.7% morning/afternoon down to just 2.3%/6.1%.
KTC then go to say even with this much more generous approach, the Interim study reached much the same conclusion that the existing highway network would not be able to accommodate the proposed levels of LDF
KTC have previously argued that Kendal’s infrastructure requires long term planning, with an evidence-based, published, and defensible roadmap for developing the town and its infrastructure to underpin planning policies.
They argue that with Kendal’s ageing infrastructure, improvements are so substantial that they are likely to need contributions from several partners to deliver and that there needs to be an overall credible plan for infrastructure.
They acknowledge the issues with traffic directly impact on the air quality in Kendal town centre. The air quality in Kendal currently fails statutory guidelines, and has deteriorated since 2008-09. Slow-moving traffic waiting at junction approaches is widely believed to be the major contributory factor.
The road network is already working at capacity, with the effect that NO2 levels in the town centre
are close to or above the Objective.
The CCC modelling work now shows that this “capacity” is simply not deliverable.
Applying the precautionary principle, the Council believes any planned Land Allocations which would be rejected on traffic grounds must also be rejected on air quality until a robust plan is in place.
Without a robust infrastructure “Master Plan” linked to sites, the Council fears it will prove impossible to enforce the necessary Section 106 obligations, which are governed by the government’s Circular 05/2005:20.
The Council asks the Inspector to withhold approval of the DPD until there is a credible infrastructure plan showing the impact of the major sites on the overall town infrastructure, and with high level solutions identified and costed with enough detail to enable the economic deliverability of the sites to be proven.
Proposed Changes I would like to see:-
1. All changes and suggestions as identified within all three of Kendal Town Council’s Sustainable Development in Kendal Submissions to the LPA in their response to the Local Development Framework.
Why - Because their submissions are based on reality and make total sense to me.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
659. Mr and Mrs Keith & Pauline Mary Neighbour (Individual) : 18 May 2012 16:33:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
1.9
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The Land Allocations Document (DPD) is not within the Local Development Scheme and the key stages have not been followed
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Legal Compliance 2
SLDC has failed to deliver appropriate, sufficient and effective methods of engagement in response to the needs of the community.
The public have been asked to submit to the soundness of a DPD comprising approximately 460 technical documents covering 14,500 pages (visually, this would represent a stack of A4 paper approx. 1.5 metres tall). SLDC chose only to allow for the minimally prescribed consultation period of six weeks.
Residents who are less inclined or able to read through a complex set of documents containing thousands of pages of text, tables, maps and appendices (either in paper form or via the SLDC website) have therefore been broadly excluded from making any substantial comments or submissions which are deemed to be ‘viable’ by SLDC.
It has failed to be creative in the way it reaches out to all parts of the community, participation has been limited to the usual ‘informed and active minority’.
Crucially, the disenfranchisement of the older generation from the consultation process has meant that a significant percentage of the population has been under-represented (where currently 29% of the population of South Lakeland is over 60).
Where SLDC have engaged with the public in face to face meetings in the community, it has been with a “presentational style” of plans to be delivered, rather than of options for consultation. It has been alleged that in response to challenges, SLDC representatives have been heard to comment at public meetings that the plans will be delivered ‘regardless of public opposition’. Despite an outward impression of a robust consultation process, it could be said this has simply been a ‘tick-the-box’ exercise.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
in any meaningful way when preparing the final land allocations document. To the contrary, there are instances where additional sites have been added or numbers of dwellings increased in areas where submissions were made opposing original plans.
The delivery of the consultation by SLDC has resulted in a sense of detachment from the planning process as many residents feel marginalised by an ‘indifferent approach’ to their opinions and aspirations for their neighbourhoods. Communities have not been treated as stake-holders in the future success of their towns and villages.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
660. Mr and Mrs Keith & Pauline Mary Neighbour (Individual) : 18 May 2012 16:35:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
1.10
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The Land Allocations Document (DPD) is not within the Local Development Scheme and the key stages have not been followed
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Legal Compliance 2
SLDC has failed to deliver appropriate, sufficient and effective methods of engagement in response to the needs of the community.
The public have been asked to submit to the soundness of a DPD comprising approximately 460 technical documents covering 14,500 pages (visually, this would represent a stack of A4 paper approx. 1.5 metres tall). SLDC chose only to allow for the minimally prescribed consultation period of six weeks.
Residents who are less inclined or able to read through a complex set of documents containing thousands of pages of text, tables, maps and appendices (either in paper form or via the SLDC website) have therefore been broadly excluded from making any substantial comments or submissions which are deemed to be ‘viable’ by SLDC.
It has failed to be creative in the way it reaches out to all parts of the community, participation has been limited to the usual ‘informed and active minority’.
Crucially, the disenfranchisement of the older generation from the consultation process has meant that a significant percentage of the population has been under-represented (where currently 29% of the population of South Lakeland is over 60).
Where SLDC have engaged with the public in face to face meetings in the community, it has been with a “presentational style” of plans to be delivered, rather than of options for consultation. It has been alleged that in response to challenges, SLDC representatives have been heard to comment at public meetings that the plans will be delivered ‘regardless of public opposition’. Despite an outward impression of a robust consultation process, it could be said this has simply been a ‘tick-the-box’ exercise.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
in any meaningful way when preparing the final land allocations document. To the contrary, there are instances where additional sites have been added or numbers of dwellings increased in areas where submissions were made opposing original plans.
The delivery of the consultation by SLDC has resulted in a sense of detachment from the planning process as many residents feel marginalised by an ‘indifferent approach’ to their opinions and aspirations for their neighbourhoods. Communities have not been treated as stake-holders in the future success of their towns and villages.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
661. Mrs Grace Nelson (Individual) : 13 Apr 2012 15:47:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - RN213-mod BRIGSTEER LAND OPPOSITE THE WHEATSHEAF
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
1.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
i support this land allocation because it is the only available site in Brigsteer which is in need of some low cost houseing at the meeting at brigsteer village hall 10 april ther was many young couples who would love to live in the village but because most hoyse prices start at 350 thouasnd they have no chance the people who are against it are all living next to it but have not asked to seen the plans they just dont want it it is not near the clt houses because that lasnd is all built up already i hope you will go ahead with these plans for people like me who has lived here all her life but has to still live with her mum, along with my husband and two kids over people who have lived here less than 10 years and dont want their view spoiled
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
Yes
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
we need to build more homes for the young people as brigsteer is full of second homes and retierd people
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
662. Mr & Mrs David & Jennifer Nelson (Individual) : 18 Apr 2012 14:47:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - RN152 GREENODD LAND AT THE OLD VICARAGE
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
remove site
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Loss of agricultural land which our family has farmed for more than 70 years. Drainage and groundwater problem. Extra traffic - one main road in village. No playground in village for children. At least 13 houses in village for sale, as field is on a hill, impact on neighbouring properties. Impact on church and church yard. Plus parking problems, a danger on hill.
663. Ms Glenis Newton (Individual) : 2 Apr 2012 09:17:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - M9M2-mod MILNTHORPE NORTH WEST OF MILNTHORPE
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The scale of proposed development is grossly disproportionate to the size of the site in question and would cause unacceptable negative impact on the village landscape.
As an elevated site, the buildings would be highly visible not only from the neighbouring Dallam Chase and Grisleymires Lane but also from Church Street, Kirkgate and the area to the north of the village and from Dallam Tower Estate and the area to the south, meaning that the impact would be visually intrusive on a wide scale.
The nearby Booths development and the proposed commercial sites next to Houghton's coachworks already detract from the appearance of this corner of the village and more development would only serve to further destroy the character of the village.
Access to this site is already a safety issue due to the business traffic via Grisleymires Lane, that includes many large lorries to both the coachworks and Booths. Further development here would serve to exacerbate the problem.
Drainage and sewerage systems are already highly temperamental and placing any number of houses on this site would add further unnecessary pressure.
This greenfield site is also in constant farming use (for the grazing of both cows and sheep and for silage, cut here several times throughout the year) so is already an active working part of the village and necessary to the essential village character of Milnthorpe.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
664. Ms Glenis Newton (Individual) : 15 Apr 2012 08:59:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - M9M2-mod MILNTHORPE NORTH WEST OF MILNTHORPE
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I add this further comment to that already stated:
I am greatly concerned about the creep onto green land around towns and villages and this site in particular with respect to light pollution. The joy of being able to see the night sky has and is being robbed from us and especially children, many never see stars! The Houghton's development has had numerous and excessive lamp posts put in, awaiting the furtherance of the development and further lights would totally pollute the light for people and animals here.
Furthermore I am very concerned that the hedge rows remain in tact for bats, birds and other creatures. Why do we need to decimate the countryside and take the easy path when other alternatives exist?
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
665. Mr R B F Nicholson (Individual) : 19 Apr 2012 16:58:00
Policy/Site No.
LA1.3 Housing Allocations - R653M-mod HOLME EAST OF MILNTHORPE RD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I refer to your letter Ref: 60:12:43 dated 30 March 2012 and I confirm that, since the mid-1980's, part of the area of 'Site R625M-Mod' comprises land which forms part of the curtailment of "Silvercroft" and consequently is in my ownership.
The main of land affected, apart from minor inaccuracies along the boundaries with "Greystone" and "Rosecroft", if the area of land located immediately to the east of the plot of "Laurel Bank" and in this context I would commend your attention to the latest Land Registry plans (Recently, in the last year or so, those LR Plans have been officially corrected to rectify the previous errors indicated on their records arising from inaccuracies in their transposition of the 'original' western boundary of Field No.OS 172)
the effect of the above fact is that, as requested in your above letter and before the deadline date of 17 April 2012 stated therein, I confirm that this land will NOT be available for developement.
666. Mr and Mrs Roy and Janet Nicholson (Individual) : 24 Apr 2012 15:03:00
Policy/Site No.
LA1.3 Housing Allocations - R76M BURTON-in-KENDAL EAST OF HUTTON CLOSE
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
We wish to state that the above proposed development site is unsound
because:
The village already suffers from traffic congestion, particularly
during school pick up/drop off times,any further increase in housing
would add to this problem and the liklihood of accidents will
increase.
The access from this proposed site is poorly positioned below the crest
of a hill with inadequate pavements for children,this has already
resulted in several close calls!
Development of this site has already been rejected twice by government
bodies as unsound and nothing has changed since these recommendations.
The scale of the building suggested would overwhelm the village and
it's facilities, this would cause the village to lose its identity.
There are currently numerous properties for sale/let in the village
rendering new builds unnecessary.
The proposed land allocation cannot meet the criteria to be'sound'
due to the problems highlighted and also the effect on sewerage and
drainage which would be unsustainable.
667. Mr Peter Nightingale (Individual) : 4 May 2012 14:42:00
A typed or handwritten document was submitted. This has been scanned and can be downloaded below:
Paragraph No.
1.10
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
A PERSONAL SUBMISSION against ‘SOUNDNESS’
Objections to the INTEGRITY of the Responses to Submissions
made to the South Lakeland District Council’s
“Land Allocations Development Plan Document”.
Prepared by Peter Nightingale, Grange-over-Sands – April 2012. In due course I hope that I may be called for Interview by the Delegated Planning Inspector to discuss the complexity of information leading to this submission.
OVERVIEW
1. Personal Information
2. Introduction
3. Outline
4. Factual References
5. Summary
6. Conclusions
1 - Personal Information
1.1 My name is Peter K. Nightingale,
1.2 My submission is based upon a spreadsheet I have compiled from documents recording all the Submissions made to SLDC when the Land Allocation Plan was made available for the Consultation process, and noting all the SLDC’s responses to those submissions. (The particular documents (2.2 below) refer only to Grange-over-Sands.) The spreadsheet is very extensive, and is an integral part of this submission; it is attached by way of an accompanying CD. (AVAILABLE ON REQUEST FROM DEVELOPMENT PLANS TEAM 01539 717490 - please give reference 7910_nightingale_XL)
1.3 In addition, I have to report that the documents to which I refer (2.2 below) are extremely difficult to locate and have rarely been publicly available. Currently (12/4/2012) they do not appear on the SLDC website. It has thus been extremely difficult, perhaps impossible, for members of the general public to discover the responses to their individual submissions; other than by paying a visit to the Grange Town Hall or SLDC premises; and even then the printed document may not be immediately available, if at all. My own copies were provided by the Town Clerk at Grange-over-Sands in the form of an e-mail attachment; and are thus unavailable to folk who do not have a computer. I believe it is incumbent upon the District Council, in the course of open consultation, to make their responses easily accessible, and in my view this has not occurred.
1.4 Moreover, I aim to indicate that many responses within their Documents are themselves very far short of satisfactory.
1.5 Because I make frequent reference to the ‘Responding Officer’ who wrote these Appendices, I refer to him/her as RO.
2 - Introduction
2.1 This document refers to my belief that the data recorded within Appendix 8 – “Grange over Sands Emerging Options Consultation Stage 1 (Final Version)” and Appendix 9 - Grange over Sands Emerging Options Consultation Stage 2 (Final Version)” is very substantially flawed. I shall refer where necessary to these two documents as A8 GoS.EOCs1 and A9 GoS.EOCs2. It is essential, I would suggest, that the examining Inspector has both of these documents to hand.
2.2 The appendices referred to record all the submissions by Grange-over-Sands residents and other interested parties to the SLDC Land Allocation Plan. The RO’s answers (responses) are in three categories – Support, Neutral and Objection. In general terms it may be assumed that neutral submissions are those from Utility Companies; or from County & District/Town Council officials who are responding to queries on such matters as Environmental, Highway, Drainage or Water issues; and the like. Nevertheless, the RO’s responses are recorded.
2.2a The remaining categories are those of ‘Support’ or ‘Objection’. In both cases they refer to submissions from such bodies as Grange Town Council, Friends of the Lake District, Natural England, The Environment Agency, Landowner’s Agents and so forth. Overwhelmingly however, the responses are from local residents from the two areas of Grange and Kent’s Bank.
2.2b I have separated these two districts – Grange and Kent’s (Kents) Bank - at the outset of this report as there is a degree of disagreement within the documentation regarding their separate identities as individual settlements.
2.2c Not surprisingly, the overwhelming majority of submissions are objections.
2.3 Because there have been an extremely large number of submissions from the Grange locality, these two appendices (2.2) are respectively 108 and 17 pages long in printed form. Each proposed Allocation studied here contains a huge amount of submission / response data in the form of:
2.3a Name & Reference Identity of the person or public entity making representation.
2.3b Submission: One might have expected submissions / comments / objections to have been recorded verbatim by the RO. A large number have, but many others (indeed, the majority) have been bundled together as one ‘type’ of submission and their content has clearly been paraphrased. (See paras: 4.2f / Table 4 & 4.2g/ Table 5.)
2.3c Paragraph(s) by the SLDC Responding (Planning) Officer - responses to submissions.
2.3d Each page of the printed document contains from 1 or 2 up to 10 of these individual sections. Hence, locating any specific submission and its response can be extremely complex. In my view, this is ‘spreadsheet’ territory.
2.4 This submission is therefore accompanied by a CD containing an Excel spreadsheet replicating all the information in said appendices. The data has been analysed to obtain a series of illuminating facts, which I believe are entirely relevant to the matter of ‘soundness’ of the whole DPD; certainly as it applies within Grange-over-Sands.
3 – Outline
3.1 The spreadsheet has provided data across a wide range of calculations. For example, submissions of Support totalled 53, Neutral submissions amounted to 95, and Objecting submissions were 1253.
3.2 Many Supporters, Neutral commentators and Objectors have submitted multiple representations. As is fully explained in the notes to the Spreadsheet, where comments were submitted individually and thus were allocated their own, separate SLDC ID code, they are counted individually. However, where multiple comments were made as one single, overall submission, although the Correspondent’s ID code is repeated (but not invariably) throughout various sections of the response document, the second (and subsequent) appearances of the ID code is/are not counted. This has the effect of clarifying the overall context of the submissions and responses. See the next paragraph for a very clear indication of how this ‘clarifying’ effect works – e.g. 53/16 & 95/21.
3.3 Support and Neutral submissions were combined by the RO as one entity. Of 148 examples of supporting comment, 53 were from only 16 Supporters and 95 Neutral comments came from only 21 sources. On the other hand, a total of 1253 Objections were submitted by 297 Objectors (of whom 114 Core objectors –appearing more than once – submitted 956 between them. (Table 1)
Table 1
Please refer to attached document
3.4 Moreover, the manner in which the RO ‘bundled together’ individual objections, paraphrasing many into his own frequently recognisable and repeated phraseology (see 4.2g), resulted in ALL 1253 objections merely receiving 466 Officer Responses. Of these, 81 responses may be termed as ‘Genuine’, with a further 31 being ‘Genuine Variants’ (a genuine phrase with a previously-used comment tacked on), Therefore, ‘genuine’ or ‘genuine variant’ phrases were written once and then re-used, becoming ‘Formulaic’. Meanwhile, 65 of the Officer Responses quoted the essentially valueless comment ‘Noted’. Thereafter, all responses were ‘Formulaic’ (240) or a variant thereof (116). (See Table 2)
Table 2
Please refer to attached document
Note: I include ‘Mitigation’ because the RO seems to assume that ‘mitigation’ is a universal cure-all! ‘Variants of Genuine’ is my description for a Genuine Response incorporating a ‘formulaic’ phrase as a rider. As an example, refer to GADAG Line # 1090 of the yellow ‘Objection Response Tally’ – a genuine response regarding United Utilities, but with the standard ‘mitigation’ phrase added. This genuine response was given the code AL, then became formulaic, and appeared 7 times in all.
4 – Factual References
4.1 This submission is accompanied on the CD by a Word.doc “Analysis of Officer’s Response Wording and Total Appearances”. May I ask you to print this, if it is not already available? But it is not necessary to read it in its entirety!
4.2 For it is merely provided as a reference to the total number of times that the RO has re-used an original comment as a further response – illustrating repeated instances of a ‘genuine’ reply then melding into a ‘formulaic’ reply. Under the circumstances, this may have become an inevitable practice. Whether it is a justifiable practice may be another matter, particularly in the overall importance of local consultation being seen to be transparent.
4.2a Referring to the accompanying spreadsheet – yellow “Objection Response Tally” – Column R attributes codes from A to DF to each newly-phrased, ‘genuine’, response to an objection. Column S tallies the attribution codes applied.
4.2b A quick glance through the items mentioned above will indicate that there is a huge hidden arsenal of responses, which have been deployed to eliminate each objection (or, indeed, to eliminate multiple objections!) without – in the view of the writer – serious consideration. A most simple matter: side-step thought by the use of ‘copy and paste’. This ingenious invention may be labour-saving – but its introduction was not, I assume, intended as replacement for the brain cell! (Table 3)
Table 3
Please refer to attached document
4.2c Total 84 in code column ‘D’ is NOT a misprint. This particular response related to traffic measures; all traffic-related submissions have been treated with what is effectively the contempt of a non-response. Nowhere throughout the documents that I have copied and typed in full into the spreadsheet (not copied, in the RO’s sense) is there ONE genuine written reply to any specific traffic issue raised, at whatever location discussed in the submission. They have invariably been greeted with this (initially) ‘genuine’ response. Which one can take at face value – the RO is not a traffic expert – but perhaps that should not prevent his taking a rather more considered approach to his duty to provide responses that are realistic in their context.
4.2d Use of the ‘code’ letters A to Z and then through AA/BA/CA to DF indicates a total of 110 different responses. 3 of these were overlooked by compiler’s error (leaving 107) and the total of ‘genuine’ responses in the Excel summary sheet also amounts to 107. Therefore this indicates that a mere 16.8% of the total of 1263 objections received a genuine response. Is this acceptable consultation? One would doubt it.
4.2e On page 33.8 of the printed version [Row 196 / GADAG Line 1138 on the spreadsheet], two (unidentifiable) objectors from (a mere!) 10 on page 31 wrote a very specific description of problems when walking/cycling while intermixed with traffic at a precise location. Assuming that they did not confer in their submissions, the RO has nevertheless combined them together, which must have entailed a degree of ‘editing’. So he has applied his thoughts to combining their questions, rather than to preparing a response; for at hand he already has a pre-written ‘traffic’ weapon with which to lance this particular pustule.
4.2f The most glaring example(s) of the RO’s ‘one size fits all’ view of multiple objectors and their individual objections comes between pages 59 and 75 of A8 GoS.EOCs1. This concerns the prospect of building upon an area known as Grange Fell, hitherto sacrosanct. GF in particular caused a huge public outcry amongst local residents and there were 103 objectors listed, many with multiple objections. The RO’s propensity and determination to bundle objections together under a single heading really built up its own magnificent head of steam here - see Table 4.
Table 4
Please refer to attached document
Note: Compiler’s threshold for quoting Multiple Objections bundled together has been a minimum of 4 – there are frequently a mere 2 or 3 bundled which are not quoted in this table. In this particular sequence of pages (59>75), the formulaic responses are repetitive to the tune of 57, but the RO has also managed to conjure up 12 brand new genuine responses, only one of which appears more than once – they were therefore entirely specific to this location. There is a certain irony in the fact that – because of this public outrage – this site was withdrawn from the allocations procedure before the consultation process was completed, meaning that the land was no longer available – its potential 36 dwelling allocation was therefore divided between the other locations under review, increasing their ‘risk’. A further irony is that there may have been a ‘misjudgement’ in the decision to ‘withdraw’ this site before the completion of the LAP, and Grange Fell may yet be re-included if there are subsequent consultations!
4.2g In regard to this particular problem – Multiple Objections – one can identify the RO’s method of bringing them together beneath one heading. He identifies a theme – ‘Highways access’, p59.3 – and finds objections to fit (6). ‘Traffic congestion’, p60.3 (18). Indeed, so drawn is he to this manner of combining objections that he appears to first of all think of a category and then search for objections to fit it – not always with a degree of success. For example, on pages 60/61/62 are these ‘multiples’ drawn together. Some objectors may have used these shorthand phrases; but surely not with such broad strokes of the pen? ‘Highways safety’ – 2; ‘Flood risk’ – 2; ‘Settlement character’ – not a phrase rolling from everyone’s lips – 2; ‘Landscape impact’ – when did this, as a phrase, last slide across the bar in the ‘Coach and Horses’? – 4; ‘Biodiversity’ – the answer to a crossword clue – 4; ‘Social Infrastructure’ – here he was disappointed in his quest for candidates – 1 only; ‘Residential amenity’ – is this a loo? – 2. However (p64.6), alongside the phrase ‘Scale of development’ – “SLDC has identified 8% more land than it was supposed to” – the RO has hit pay dirt. 70 objectors quoted ‘Scale of development’ as their talisman, and the RO has attributed one singular phrase submitted by one single objector as their banner motif. This attribution alone, within 108 + 17 pages of documentation, shows that the RO had lost his hold on reality and that the consultation has been nothing but a farce.
4.2h A slightly different example of the RO’s style of responding is to be seen (once again in A8 GoS.EOCs1) in the ‘objections’ pages regarding site MN25M, which starts on Page 6 with ‘support’ comments, and a discussion of ‘other issues raised’. On Page 9 are listed, en bloc, all the ‘objecting’ parties, including one or two public bodies. (In the spreadsheet, this starts at Row 42 (line 1028) of the yellow ‘Objector-ID-Objection’ tab.) You will note here that for pages 7 & 8 – support or comments – those submitting have their SLDC ID noted. However, from page 9 onward everyone’s identity is ‘lost’ in the ‘bundling together’ of individual objectors as one, solid phalanx. The very serious consequence of this is that it is utterly impossible for anyone to identify responses in relation to a specific objection – perhaps one of their own – and indeed the way that the objections themselves have quite clearly been paraphrased or received one response for many submissions cannot be acceptable. I know in particular of one objector (Valerie Kennedy, identified under (EM427) & (EM404) on page 9) who submitted an extremely detailed and well-argued piece of research running to many pages of objection, argument and conclusion. Not only is neither of her identity #’s quoted as a source anywhere between pages 9 & 21, where the objections to MN25M conclude, but it would appear that many of her very cogent arguments and conclusions have never been addressed. Moreover, NONE of the ‘identities’ of any of the objectors have been quoted, other than for those of two public bodies (p17 pp3/4). Therefore this whole section is impossible to analyse in any serious manner whatsoever. “Who objected where, how and why?” is an utterly impossible question to answer. For this reason alone I consider this whole process to be flawed. Table 5 indicates how objections have been ‘bundled together’ to ‘fit’ a response. In order to achieve this, objections have had to be paraphrased.
Table 5
Please refer to attached document
Note: ‘Bundling together’ of less than 5 objections has again been disregarded in this table. In this instance, as discussion of this projected site is almost at the beginning of the RO’s report, about 25 newly-generated ‘genuine’ responses have been devised within the total of 63 respondent paragraphs. In addition, ‘Noted’ scored 9. ‘Noted’ is essentially meaningless – has the objection been noted anywhere other than in this document? It is equivalent to a shrug of the shoulders, or the flicking aside of a mildly aggravating fly.
4.2i Without quoting more specific data from either of the two appendices or the spreadsheet, may I refer you to page 83 of the printed Appendix 8, which is a very clear instance of 15 or 16 combined objections under one heading receiving a single response, and thereafter pages 85/86/87, where for approximately 34 ‘suggestions’ each (bar 1) received a response of ‘Noted’ (further skewing the balances) and which emanated from 20 different identifiable sources. In this instance, the source and the suggestion have been tied together (which did not occur within 4.2g above, where no sources were linked to any objection). Similarly, on pages 88/89/part 90, 13 individuals have suggested a further 22 courses of action for GTC to effect in the future. Not one of these, however, has been attributed to a quoted individual. These inconsistencies throughout the document(s) indicate, to me at least, that whatever consultation (comment, objection) was received by SLDC was treated with no serious consideration whatsoever, and there are quite clearly elements of a dismissive attitude of mind on display. See 4.2j.
4.2j The tenor of this submission is now becoming very clear – there are multiple ways wherein the manner in which the RO addressed the important task in hand may be analysed, and the flaws are clear to see under this particular scrutiny. I shall therefore turn to only two more specific instances which add further doubt to the integrity of his review of objections. These both occur in A9 GoS.EOCs2, the Appendix prepared after the consultation had ended, but before the LADP was published and initially accepted by the District Council. Fortunately, this is only 17 pages long – but it contains a lot of matter. (Within the spreadsheet, this appears as pages 111 to 127, to permit the same ability to analyse the extra data using the existing spreadsheet formulae. These additional analyses start at GADAG line 1483 – Row 497 – on either of the yellow tabs, or at GADAG line 184 – Row 164 – on the blue tabs.) Firstly, the initial pages incorporate a very large number of ‘Noted’ responses, almost entirely in response to Utility Companies and so on, which skew the final balances quite heavily. Once again, ‘bundling’ occurs, as in Table 5 (but not to the same extent), but still making it impossible to discern responses to particular further objections, and in that whole section there is only one ‘new’ genuine response (DF), which is in reply to an objection from Network Rail for possible access to the Lido across their railway line. In every other instance of ‘new’ submission and objection, the RO has resorted to the original formulaic answers he had devised and used previously. In my view, no serious consideration at all appears to have been given to the second Appendix (9).
4.2k The most serious indicator, in my opinion, of how the RO views his responsibilities comes in his total disregard for comments made by Grange Town Council, which as a body of some merit and import, and a channel of opinion both to and from the District Council, should properly receive respect from the RO. Who is, in essence, an employee of the wider public, including the ratepayers of Grange via their precept to SLDC; of whom he is a direct employee, of whatever status, importance or seniority. Within A9 GoS.EOCs2, the ‘Further Consultation Responses’, GTC has had occasion to submit a ‘block’ commentary of four paragraphs on issues raised; this first appears on page 8 (118 in the spreadsheet), and has been copied and pasted across pages 9/10, 12/13, 14/15 – a total of four appearance. As have the RO’s responses. But the telling thing is this: there are four paragraphs – three receive a (formulaic) response. The one paragraph that has never received a reply – and it is my belief it has never received a reply, anywhere, whether within or without these pages – is as follows: “Previous consultation responses from the Town Council do not appear to have been taken on board, and no response has been received addressing specific concerns raised.” In so far as the RO gave replies to the three other paragraphs contained in this submission, it is inconceivable that he had not read this specific comment. Indeed, he may himself have typed it from the GTC submission; it is not clear whether this has been done by a secretary throughout, for instance, and subsequently the RO has sat down to devise his responses. Nevertheless, he chose to ignore it (copying and pasting it a further three times after the initial appearance). To my mind, this is totally indicative of a smug, pompous, self-important and dismissive attitude that appears to be endemic within this whole consultation process, which seem to have been a matter of condescending to hold a ‘consultation’, with no genuine intention to seriously respond to issues raised (even from Councillors) and to hustle the whole procedure through the District Council in a series of nods and winks, strong-arming and Party whipping. If it started with noble intentions, as one would hope, it became diverted into a quagmire, and ultimately this was no consultation at all.
5 – Summary
5.1 It is evident that in regard to submissions from Public Bodies, Utilities and in particular members of the public, SLDC entrusted their ‘responses’ for Grange-over-Sands to a senior Planning Officer. I have referred to him/her as the ‘Responding Officer’, the RO. He/she (generally referred to in these notes as ‘he’) established a very comprehensive system with which to annotate all the comments and objections received, and a system to ‘respond’ to them competently, fairly and with candour and dispassion.
5.2 At the outset, responses were considered, individual and professional. However, at some stage the floodgates were opened and a tide of submissions was received. The RO and his staff were presumably beset, daily, with a never-ending, ever-swelling paper mountain - a Vesuvius, indeed, of comment or objection. (And it has to be visualised, additionally, that a similar tsunami of paperwork was arriving from every locality within SLDC. A factor we may have overlooked.) And so, whether or not ‘our’ RO also had responsibility for other settlements in the locality, it is very easy to be critical of his or her motives as the consultation period drew to a close. Presumably, there was a huge pressure to commit ‘something’ to paper.
5.3 Hence, perhaps, the chaos into which the response system descended. In light of the two paragraphs above, perhaps it is no surprise that matters went a little haywire.
5.4 However, battleground chaos is no excuse for poor decisions – we learned (or thought we had learned) that lesson at the close of the First World War. Almost a century ago.
5.5 Our RO made many poor decisions in putting his name to the data disclosed in Tables 3, 4 & 5. Rarely were his ‘formulaic’ responses used with perception – had he realised that they would be illuminated within such an uncomfortable spotlight, there may have been many moments for reconsideration. However, time and circumstance were not on his side. There can be little doubt that the report that he produced – however challenging the circumstances – leaves very much to be desired. It is full of inconsistencies in approach, is riddled with shortcomings in factual presentation, omits accurate attributions and latterly has an air, unfortunately, of the hurried and slapdash. In consequence, it is clearly not fit for purpose.
6 – Conclusions
6.1 My conclusions are extremely simple – because it is evident that SLDC were unable to publish clearly and unequivocally their responses to every individual objector to the LAPD, the process is intrinsically unsound. It is manifestly important that – in a public consultation – every view is accepted, weighed on its merits, and upheld or discarded. Drawing a balance may be a fine line – so be it. But when – as in this case – so many individual comments and objections have been subsumed into a greater maw, within which very little is finite – then the process is unsound. Naively, perhaps, I believe that ‘soundness’ for the individual is founded in natural justice – that is: the right to have been heard; and to have been heard to have been heard. For many people in this process, that has not occurred. Therefore, ‘soundness’ itself has not occurred.
Peter Nightingale, Grange-over-Sands, Cumbria. 15/04/2012
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
to discuss the complexity of information leading to this submission.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
668. Mr Mike Norton (Individual) : 11 Apr 2012 11:30:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - R121M-mod KENDAL EAST OF CASTLE GREEN ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I believe SLDC have failed to deliver an effective and adequate consultation with the community resulting in real and meaningful dialogue. The consultaion has not been in accordance with the SCI and as such is unsound. Points raised by residents were noted but then largely ignored. This is evidenced by the approximate 400 responses to site R121M of which over 99% were against. SLDC have engendered opposition and resentment by riding rough shod over the wishes of the community which is totally unreasonable. There has been a vast amount of information, which has been difficult for many to access, and hard to wade through for those with the considerable amount of time needed, available and the computer knowledge and commitment to do so. Site specific searches have regularly failed making it difficult to access relevant information. This has not been consultation and has not been consistent with national policy on 'Localism'.
In order to be legally compliant I believe SLDC need to honestly listen to the community and accept the fact they need to adopt an alternative strategy rather than making minor changes to their current unsound strategy, in the misguided hope that this will be acceptable.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I strongly believe that SLDC’ s strategy is unsound for the following reasons:
1)They have not taken evidence into account that disagreed with their initial unsound strategy, and have failed to significantly alter their strategy to make it effective and deliverable. Examples of this include the Galpin report commissioned by Kendal Town Council and the report by Friends of the Lake District which were not accepted although both sound reports found site R121M to be totally unsuitable for development.
2)R121M was given the County Landscape designation in 1999 but this seems to have been ignored and the site put forward for convenience rather than based on evidence.
3)Where obstacles have been identified, an inadequate reference to 'mitigation' has been made, without any attempt to address the underlying issues. For this site the serious issues of access, flooding and great crested newts have all been treated as such. For the site to be considered, these issues should have been addressed by this stage. Not doing so makes the choice of site unviable and undeliverable.
4)The highways access to the site is clearly ill thought out and muddled. I personally asked Dan Hudson at a public meeting arranged locally about access and he told us that it would be on to Castle Green Lane. Now it seems the preferred option has changed to Oak Tree Road. Why and how this has changed is totally unclearand the community have not been informed of thsi change.
5)The considerable flooding issue with this site seems to have been ignored, but all other sites flowing into the Stock Beck Flood Alleviation system have been removed, presumably on flooding grounds. So why hasn't this site?
6)Great crested newts range over the whole area of the site and further afield. They are rightly protected and it is a serious omission not to have considered the possible alternative mitigation measures necessary. The cost and perceived success of such mitigation may well make the site unfeasible.
Although my comments so far relate to Site R121M, I believe there are serious issues with the whole Land Allocations Development Plan Document. The recent "Norfolk" judgement suggests that the SLDC process is equally unlawful. Whilst some changes have been made over the last 4 years they have been relatively minor and peripheral. The proposals in the approved documents which will now go before an Inspector are largely unchanged and can be demonstrated to have been founded on flawed original data. The presumptions made are questionable and based on out of date figures. For example how can SLDC not have taken the changes to the annual numbers of dwellings needed into consideration? This alone makes their strategy, based on such incorrect information, totally unjustified and illogical.
These are significant deficiencies which cannot be corrected by tinkering with the text. I believe the document is unsound and needs to be be withdrawn and fully re-appraised. Assessments of alternatives have not been thoroughly undertaken and have not been fully explained publicly. An alternative strategy is necessary to meet the changing needs of the community and it is essential that this is based on the recommendations of the people who live here and the Town Council. The alternative strategy must include essential infrastructure plans and all necessary mitigation measures to make it a deliverable and viable document.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
669. Mr Mike Norton (Individual) : 18 May 2012 15:27:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
1.9
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I believe SLDC have failed to deliver an effective and adequate consultation with the community resulting in real and meaningful dialogue. The consultaion has not been in accordance with the SCI and as such is unsound. Points raised by residents were noted but then largely ignored. This is evidenced by the approximate 400 responses to site R121M of which over 99% were against. SLDC have engendered opposition and resentment by riding rough shod over the wishes of the community which is totally unreasonable. There has been a vast amount of information, which has been difficult for many to access, and hard to wade through for those with the considerable amount of time needed, available and the computer knowledge and commitment to do so. Site specific searches have regularly failed making it difficult to access relevant information. This has not been consultation and has not been consistent with national policy on 'Localism'.
In order to be legally compliant I believe SLDC need to honestly listen to the community and accept the fact they need to adopt an alternative strategy rather than making minor changes to their current unsound strategy, in the misguided hope that this will be acceptable.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
670. Mr & Mrs John and Linda Nott (Individual) : 14 Apr 2012 14:25:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - RN109M RN315# SWARTHMOOR OFF CROSS-a-MOOR
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I believe the DPD is unsound because important infrastructure issues have not been properly addressed and the document should not be submitted for government approval until these issues are resolved.
My house is close to the Cross a Moor Lane / Main Road junction with the A590 and I know from first hand experience that negotiating this junction is notoriously difficult. The A590 has been identified as the busiest road in the county apart from the M6 and turning right out of Cross a Moor lane to head in the Barrow direction is all but impossible at most times throughout the day, as is turning right from Main Road to head towards Ulverston. The excessive number of houses resulting from this plan will exacerbate the difficulties to a point where our lives will be seriously affected. The plan should include the measures required to ensure that the increased traffic is manageable, but it doesn’t.
There are no spare places at Pennington Junior School which means that children of existing Swarthmoor families will be in competition with those from this development in a way that hasn’t previously been an issue. In any case there will be a need to transport younger children to other schools rather than have them walk to Pennington School. This is not sound planning and again should have been dealt with in the plan not left to a developer after consent has been given.
I am also greatly concerned that the land owner of RN109M has clearly influenced the decision to increase the area of land initially selected as an Emerging Option, by having RN315# incorporated into the plan. It is common knowledge that RN109M as it existed as an Emerging Option, was not considered to be economically attractive to the owner and he employed an agent (Story Homes) to present a case for increasing the size of the plot. This case has been accepted by the planners as an alternative to losing the plot and has resulted in a land owner and developer having been responsible for the creation of this part of the DPD. This cannot be appropriate and should be investigated as a matter of urgency.
I believe that there are other of instances of the original areas of land being increased in size and would expect these also to be brought to the attention of the government inspector. RN131M, in Ulverston South ward, is an example of Story Homes’ involvement.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
671. Mr & Mrs John and Linda Nott (Individual) : 23 May 2012 17:10:00
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I have read the guidance notes
Paragraph No.
1.9
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I am also greatly concerned that the land owner of RN109M has clearly influenced the decision to increase the area of land initially selected as an Emerging Option, by having RN315# incorporated into the plan. It is common knowledge that RN109M as it existed as an Emerging Option, was not considered to be economically attractive to the owner and he employed an agent (Story Homes) to present a case for increasing the size of the plot. This case has been accepted by the planners as an alternative to losing the plot and has resulted in a land owner and developer having been responsible for the creation of this part of the DPD. This cannot be appropriate and should be investigated as a matter of urgency.
I believe that there are other of instances of the original areas of land being increased in size and would expect these also to be brought to the attention of the government inspector. RN131M, in Ulverston South ward, is an example of Story Homes’ involvement.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
672. Mrs Marie Nugent (Individual) : 16 Apr 2012 13:47:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
0.0 Whole Document
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
SLDC has ignored the wishes of Levens parishioners expressed in previous consultaions. The Levens Residents Group surveyed the opinions of all parishioners and the views expressed by the vast majority of respondents were that the development envisaged in the SLDC's proposals is far too big for the village. SLDC have allocated 73 houses for the village whereas all Levens needs is 11 afforable homes as identified in the 2008 Rural Housing Needs Survey. The Levens Village Plan identified small developments for future planning. Developments of potentially 50 and 23 house per site does not reflect local opinion. It goes against it and therefore does not reflect the Localism Act. It therefore is not sound.
Alteratives: (i)Consideration also needs to be given to the the possibility of further sites becoming available during the first 5 years. For example the Salesian Convent site at Brettargh Holt which will be offered for sale in July 2012. (ii) There is no evidence that SLDC has considered using any other powers such as those relating to taking over empty properties to increase the housing stock.
Public transport to and from Levens Village is very poor and all commuting to Key Local Centres by those living in the new dwellings would be by car. This cannot meet any definition of environmental friendliness.
There is no clear evidence that to show that those in need of affordable housing would be able to afford to buy or rent the planned "affordable" housing. Slow take up on recent developments would suggest not.
Last but not least condideration needs to be given to the Levens Fact File which cites European protected species at site R51M.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
673. Mrs Marie Nugent (Individual) : 8 May 2012 16:58:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - All Levens sites
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
SLDC has ignored the wishes of Levens parishioners expressed in previous consultaions. The Levens Residents Group surveyed the opinions of all parishioners and the views expressed by the vast majority of respondents were that the development envisaged in the SLDC's proposals is far too big for the village. SLDC have allocated 73 houses for the village whereas all Levens needs is 11 afforable homes as identified in the 2008 Rural Housing Needs Survey. The Levens Village Plan identified small developments for future planning. Developments of potentially 50 and 23 house per site does not reflect local opinion. It goes against it and therefore does not reflect the Localism Act. It therefore is not sound.
Alteratives: (i)Consideration also needs to be given to the the possibility of further sites becoming available during the first 5 years. For example the Salesian Convent site at Brettargh Holt which will be offered for sale in July 2012. (ii) There is no evidence that SLDC has considered using any other powers such as those relating to taking over empty properties to increase the housing stock.
Public transport to and from Levens Village is very poor and all commuting to Key Local Centres by those living in the new dwellings would be by car. This cannot meet any definition of environmental friendliness.
There is no clear evidence that to show that those in need of affordable housing would be able to afford to buy or rent the planned "affordable" housing. Slow take up on recent developments would suggest not.
Last but not least condideration needs to be given to the Levens Fact File which cites European protected species at site R51M.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
674. Mrs Janet O'Brien (Individual) : 19 Apr 2012 10:18:00
Policy/Site No.
LA1.3 Housing Allocations - RN140 MILNTHORPE LAND AT OWLET ASH FIELDS, ACKENTHWAITE
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
It has been brought to my attention possible proposed plans for homes on land near to my house. I have been lead to believe that the access for these homes could be passed the back of my property, which would lead to my garage being demolished, a childrens play area going or moved and valuable parking spaces going.
I am opposed to this access through Owlet Ash Fields as there is enough traffic and parked vehicles already. A proposed 22 properties has the potential of fetching approximately another 44 vehicles through the estate as most families have at least 2 vehicles.
Unfortunately I am unable to attend the meeting on Monday 16th April due to me working shifts, but I would be grateful for any information, details or comments from you on this subject.
I have already written one letter to SLDC and received a reply off Alastair McNeill .
I would like you to accept this email as my opposition to the proposed plans at site RN140 and would like an email off you to say you have received my opposition before 5pm on Tuesday 17th April.
675. Mr Stan O'Connor (Individual) : 25 Apr 2012 08:40:00
Paragraph No.
0.0 Whole Document
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Many people (including, I’m afraid myself) think that your proposals for future housing development will prove to be flawed, either on the demand side, the supply side or probably both.
SLDC should recognise this possibility and take prudent steps to minimise adverse effects should the plan not prove to be viable. One such step would be to ensure that brown field sites are developed prior to green field sites. An example is the present Auction Mart site. We should analyse who buys these houses, where did they come from – are they from the ‘housing required’ list. Detailed information, such as this should be collected on a District basis by the Council and made available to the public. We will then be able to judge if the plan is achieving its aims. You are more likely to take the public with you if you keep us fully informed and are open about the progress of the plan.
676. Mr John Ogden (Individual) : 8 Apr 2012 19:27:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA2.3 Land East of Castle Green Road
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
The DPD has not had regard to the Sustainable Community Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
SLDC expects residents to either spend up to 3 hours downloading documents or spend hours in the library trying to decipher the legal jargon of their documents. Large numbers of people are therefore excluded from expressing their support or rejection of the plans. Consultation meetings were presentational and responses to questions were evasive or not answered. Input from residents directly affected are not taken into account which is undemocratic. All Kendal residents are affected when development is large scale. 400 people objected to R121M and R56 and 2 supported it!
The planner responsible for this site did not visit until July 2011 and that was at the invitation of the residents.
Latest national government guidelines for development discourage the use of green spaces and require input of local residents.
SLDC have ignored the rejection of an appeal to develop R56 in 1997.
SLDC's own Local Plan 2006 stated development of higher hillsides would be unduly prominent.
R121 was deemed worthy of County Landscape designation in 1999.
R121 was judged negatively for development by SLDC themselves in original site notes.
SLDC did not accept the Town Council submisson on the Taylor review of 2011.
SLDC did not accept a report from Friends of the Lake District as part of their evidence base. This report stated that development of R121M would be in conflict with RSS Policy EM1, Saved Structure Plan Policy E37, Core Strategy Policy 8.2 and PPS7.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
SLDC in its own statements - 3.20 and 3.21 acknowledges that the site has "an existing and complex flood issue" which would have to be mitigated but do not say how. We are concerned that Stock Beck Flood Alleviation scheme would be relied upon but this is also untested. They also acknowledge a transport assessment would be required. Nobody had measured the width of Oak Tree Road (the preferred access route) beforehand.They also state development must provide for "safeguarding significant tree groups, stone walls, and hedgerows". SLDC also states that "Castle Green Road and Castle Green Lane" are "areas of biodiversity importance". To develop an estate of housing with these constraints will require considerable expense to evaluate and "mitigate" and this has not yet been done. Then the work to be done would be expensive thus only making it viable for developers to build "expensive" houses to recoup their outlay. Even if "affordable" housing were to be built the hillside location with its views would attract a premium on later sales of properties.
SLDC has not provided information on how the increased pressure on Kendal's infrastructure would be dealt with, eg traffic, air quality, sewerage, hospitals, surgeries etc.
We accept that "affordable" housing is needed but this oft repeated phrase has not been satisfactorily defined. Wages are low in this area and in the continuing poor economic climate there is no reason to believe that Kendal will be able to attract large employers paying much over minimum wage. Also there continue to be large numbers of vacant or unsold properties in the area.
In accordance with national government planning guidelines all development of greenfield sites should be removed from the DPD.
SLDC should now reconsider the alternative strategy for Kendal as put forward by Kendal Town Council.
SLDC should define what "affordable" housing is, review the actual numbers of people requiring this and how it should be funded.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
677. Mr & Mrs David & Nora Ogden (Individual) : 23 Apr 2012 11:35:00
Policy/Site No.
LA1.3 Housing Allocations - All Arnside sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
It has been brought to our attention that there are plans to build houses on what is currently green belt land in our village. We are sure there is a need for affordable homes to ensure the continuity for Arnside younger generations to live in the place of their birth when they reach the point of raising their own family. There has also been in the past the building of homes by private developers which have attracted new people to the village but this has been very controlled and we are sure both these situations could be accommodated by releasing various brown field sites which exist .
It is essential that the village continues to grow preferably in an organic manner to ensure the approach roads and the existing roads in the village do not become clogged up because parking is currently a problem especially as the influx of visitors, which are the life blood for many of the businesses, seem to be on the increase. However if building was allowed on some of the green sites that have been highlighted it would certainly add to the congestion on some of the narrow junctions ,Silverdale Rd ,the Promenade, Station Rd and extra wear and tear on what is only the most direct road in and out of Arnside the B 5282.
We trust the council will take note that the majority of Arnside people do not wish for a large influx of new residents although we do recognise the need of affordable housing for the young persons of this village.
678. Mr John Ogden (Individual) : 18 May 2012 11:30:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - R121M-mod KENDAL EAST OF CASTLE GREEN ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
The DPD has not had regard to the Sustainable Community Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
SLDC expects residents to either spend up to 3 hours downloading documents or spend hours in the library trying to decipher the legal jargon of their documents. Large numbers of people are therefore excluded from expressing their support or rejection of the plans. Consultation meetings were presentational and responses to questions were evasive or not answered. Input from residents directly affected are not taken into account which is undemocratic. All Kendal residents are affected when development is large scale. 400 people objected to R121M and R56 and 2 supported it!
The planner responsible for this site did not visit until July 2011 and that was at the invitation of the residents.
Latest national government guidelines for development discourage the use of green spaces and require input of local residents.
SLDC have ignored the rejection of an appeal to develop R56 in 1997.
SLDC's own Local Plan 2006 stated development of higher hillsides would be unduly prominent.
R121 was deemed worthy of County Landscape designation in 1999.
R121 was judged negatively for development by SLDC themselves in original site notes.
SLDC did not accept the Town Council submisson on the Taylor review of 2011.
SLDC did not accept a report from Friends of the Lake District as part of their evidence base. This report stated that development of R121M would be in conflict with RSS Policy EM1, Saved Structure Plan Policy E37, Core Strategy Policy 8.2 and PPS7.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
SLDC in its own statements - 3.20 and 3.21 acknowledges that the site has "an existing and complex flood issue" which would have to be mitigated but do not say how. We are concerned that Stock Beck Flood Alleviation scheme would be relied upon but this is also untested. They also acknowledge a transport assessment would be required. Nobody had measured the width of Oak Tree Road (the preferred access route) beforehand.They also state development must provide for "safeguarding significant tree groups, stone walls, and hedgerows". SLDC also states that "Castle Green Road and Castle Green Lane" are "areas of biodiversity importance". To develop an estate of housing with these constraints will require considerable expense to evaluate and "mitigate" and this has not yet been done. Then the work to be done would be expensive thus only making it viable for developers to build "expensive" houses to recoup their outlay. Even if "affordable" housing were to be built the hillside location with its views would attract a premium on later sales of properties.
SLDC has not provided information on how the increased pressure on Kendal's infrastructure would be dealt with, eg traffic, air quality, sewerage, hospitals, surgeries etc.
We accept that "affordable" housing is needed but this oft repeated phrase has not been satisfactorily defined. Wages are low in this area and in the continuing poor economic climate there is no reason to believe that Kendal will be able to attract large employers paying much over minimum wage. Also there continue to be large numbers of vacant or unsold properties in the area.
In accordance with national government planning guidelines all development of greenfield sites should be removed from the DPD.
SLDC should now reconsider the alternative strategy for Kendal as put forward by Kendal Town Council.
SLDC should define what "affordable" housing is, review the actual numbers of people requiring this and how it should be funded.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
679. Mr John Ogden (Individual) : 18 May 2012 11:33:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
1.9
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
The DPD has not had regard to the Sustainable Community Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
SLDC expects residents to either spend up to 3 hours downloading documents or spend hours in the library trying to decipher the legal jargon of their documents. Large numbers of people are therefore excluded from expressing their support or rejection of the plans. Consultation meetings were presentational and responses to questions were evasive or not answered. Input from residents directly affected are not taken into account which is undemocratic. All Kendal residents are affected when development is large scale. 400 people objected to R121M and R56 and 2 supported it!
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
680. Mr Glyn Ormerod (Individual) : 23 Mar 2012 15:12:00
A typed or handwritten document was submitted. This has been scanned and can be downloaded below:
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.1 Development Boundaries- BURTON-IN-KENDAL
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
Yes
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
Regarding the the proposed new land allocation in Burton-in-Kendal RN226
I am fully supportive of the above proposal
However please can you take into account if for any reason RN226 which lies to the East of my property does not get granted in this final consulation, my original proposal to SLDC approx 31-03-2011 http://www.southlakeland.gov.uk/LDFDocuments/OrmerodG_LE582_310311.pdf
The drawing clear show that my proposal is to have the building boundary moved slighty East of where it lies now, so that it runs in line with my property boundry and not through the middle as it does at present.
681. Ms Hayley Owen (Individual) : 8 Mar 2012 11:14:00
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I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - R76M BURTON-in-KENDAL EAST OF HUTTON CLOSE
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Consider the lack of educational facilities, the lack of shops,medical and parking and pavements. Consider the definition of village - which it is just about clinging to against the definition of a small town which it is fast becoming. Whom are the target markets for the new homes - because given the mortgage market and financial restrictions of wages paid to local people THEY are not going to be moving in to the homes because they cannot afford it. The destruction of yet another greenfield site together with the other 3 planned sites for housing development will mean the loss of valuable agricultural and play areas with NO chance of gaining them back.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
682. Ms Hayley Owen (Individual) : 8 Mar 2012 11:22:00
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Policy/Site No.
LA1.5 Existing Employment Areas - EEA10 CLAWTHORPE CLAWTHORPE HALL BUSINESS CENTRE
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Firstly try filling the existing business centres at Dalton Hall and this site before extending permissions. They haev yet to build the development you have already approved against the wishes of the local and parish personel. Where are they going to park, the access is currently an accident waiting to happen so will become worse. There is detrement to the green fields surrounding the proposed site. we have a BRAND NEW development at Crooklands and Carnforth with thousands of square meters of buildings and business park opportunities yet they are yet to be filled. There is no CLEAR NEED for anyone other than the owners of the land and the existing businessss park - so where is the community in this as no new work or jobs will be created just an expansion and relocation of the exisiting workforce into a Hamlet of 20 houses which start at
£250, 000 - so no one working in the site can live in the Hamlet and no one living in the Hamlet would have work or economic stimuation form the 3rd development of this site.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
683. Ms V E Oxley (Individual) : 18 Apr 2012 16:19:00
Policy/Site No.
LA1.3 Housing Allocations - All Ulverston sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I think that SLDCs Land Allocation Development Plan consultation process was NOT sound. SLDC have not addressed many of the problems raised by residents during the consultation period.
SLDC appear to have made no provision for upgrading local roads which are already getting overcrowded and in a state of disrepair. The A590 through the Ulverston area is already a 'bottleneck' where traffic can grind to a complete halt at the slightest delay.
Why does SLDC want to destroy our precious countryside by favouring the development of greenfield sites? Why does SLDC want to erode the important green gaps between communities when this goes against the wishes of local residents (who provide your income via council tax), and also goes against your own policy guidance in the DLSC Core Strategy document? Who is going to make a profit out of trashing our beautiful countryside? Much of the land is high quality agricultural land and SLDCs document states that 'agricultural land of poor quality is used in preference to the best and more versatile land'.
What measures has SLDC taken to ensure that utilities such as drainage, water supply and electricity are adequate to support the proposed scale of development? How can our schools and doctors cope with that number of additional residents? I would sincerely request SLDC to find an alternative strategy, which does not involve the widespread destruction of our green spaces.
684. Mrs Christine Palmer (Individual) : 17 Apr 2012 14:30:00
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I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - M41M ENDMOOR NORTH OF SYCAMORE DRIVE
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The proposed denisty of housing would have a substantial effect on both thelook and feel of the village. The proposed 30% increase in area of the Village Development boundary is a huge increase when there are neither the services nor amenities to cope with the extra housing.
At present there are only a couple of applicants waiting for affordable housing on the parish lists and so the number of local occupancy/affordable houses should be limited to not more than 10
We need to protect the local landscape, such as the drumlins, becasue of their intrinsic beauty as part of the Lake District scenery.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
685. Mrs Ann Park (Individual) : 13 Apr 2012 14:31:00
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I have read the guidance notes
Policy/Site No.
LA1.1 Development Boundaries- ENDMOOR
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not consistent with national policy.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
1, The consultation process is flawed as the proposals now put forward do not bear any resemblance to the original proposals we were asked to comment upon, therefore we not been given the opportunity to consult on the land allocation plans. Furthermore little attention appears to be given to the people who are unable to make their comments electronically in fact feel it has been positively obstructive given the question put to myself by the residents.
2, Endmoor gave a very positive response to the introduction of new housing however it would appear we are being asked to take many more houses in a shorter period than was ever suggested to us. The village cannot sustain this amount of development as the infrastructure is not in place. We are being asked to take a disproportionate amount of housing in comparison to the service centres located nearby. We do not have: Doctors, a pharmacy, a bank, a dentist, we have one small village store and an outreach post office located in the village hall. The size of the proposed development will undoubtedly change the nature of the village as it will increase the village in one area by 48%. Can this be well thought out? The numbers are not sound in that as the Parish Clerk I am aware of previous surveys taken on behalf of SLDC that showed a need for 10 houses up to and including the year 2012 and yet we are being asked to take 100 in one area, 44 of them as affordable housing.
3. The sewerage system within Endmoor is to say the least poor, my own house being on a septic tank as are my neighbours due to lack of sewer infrastructure, when asking SLDC and United Utilities about the intention to upgrade there is nothing in the pipeline - do we assume 100 houses are all going to have septic tanks and the resulting sewerage trucks. In this day and age is this sound reasoning? Little is said about the intention to deal with surface water does this not indicate a lack of planning forethought?
4. The road infrastructure around Endmoor is geared to rural traffic, farm vehicles etc and many are single track, the influx of so many houses being built in one area will cause many problems and until a carefully thought out plan is in place to accommodate this increase this proposal should not be granted. I do not see anything in the plan to ease my concerns.
5. Endmoor is surrounded by industrial sites, Summerlands currently has numerous units empty as it is too far from Kendal to make business viable, Gatebeck also has sites empty for the same reason, why build more when we cannot fill the ones available?
I am happy to see some growth in housing in the village and feel it necessary for the future however as a resident I am keen to ensure the village grows whilst retaining its character not simply adding 100 dwellings on the edge of the village, which will dwarf the village and cause untold problems with sewerage, surface water, traffic, all the new residents will need to go outside the village for services, therefore many more journeys. With regard to employment the village is too far out to attract businesses as is the current situation, SLDC has talked about storage, whilst in theory is possible in practice the sites suggested do not lend themselves to heavy traffic so where it the justification or soundness in this plan? I feel little has been thought through with regard to the infrastructure problems in general and therefore feel in addition to the lack of consultation the soundness is brought into question.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
686. Mrs Ann Park (Individual) : 18 May 2012 11:55:00
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I have read the guidance notes
Paragraph No.
1.9
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
1, The consultation process is flawed as the proposals now put forward do not bear any resemblance to the original proposals we were asked to comment upon, therefore we not been given the opportunity to consult on the land allocation plans. Furthermore little attention appears to be given to the people who are unable to make their comments electronically in fact feel it has been positively obstructive given the question put to myself by the residents.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
687. Mrs Ann Park (Individual) : 18 May 2012 11:57:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
1.10
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
1, The consultation process is flawed as the proposals now put forward do not bear any resemblance to the original proposals we were asked to comment upon, therefore we not been given the opportunity to consult on the land allocation plans. Furthermore little attention appears to be given to the people who are unable to make their comments electronically in fact feel it has been positively obstructive given the question put to myself by the residents.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
688. Mrs Ann Park (Individual) : 18 May 2012 11:59:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - All Endmoor sites
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
2, Endmoor gave a very positive response to the introduction of new housing however it would appear we are being asked to take many more houses in a shorter period than was ever suggested to us. The village cannot sustain this amount of development as the infrastructure is not in place. We are being asked to take a disproportionate amount of housing in comparison to the service centres located nearby. We do not have: Doctors, a pharmacy, a bank, a dentist, we have one small village store and an outreach post office located in the village hall. The size of the proposed development will undoubtedly change the nature of the village as it will increase the village in one area by 48%. Can this be well thought out? The numbers are not sound in that as the Parish Clerk I am aware of previous surveys taken on behalf of SLDC that showed a need for 10 houses up to and including the year 2012 and yet we are being asked to take 100 in one area, 44 of them as affordable housing.
3. The sewerage system within Endmoor is to say the least poor, my own house being on a septic tank as are my neighbours due to lack of sewer infrastructure, when asking SLDC and United Utilities about the intention to upgrade there is nothing in the pipeline - do we assume 100 houses are all going to have septic tanks and the resulting sewerage trucks. In this day and age is this sound reasoning? Little is said about the intention to deal with surface water does this not indicate a lack of planning forethought?
4. The road infrastructure around Endmoor is geared to rural traffic, farm vehicles etc and many are single track, the influx of so many houses being built in one area will cause many problems and until a carefully thought out plan is in place to accommodate this increase this proposal should not be granted. I do not see anything in the plan to ease my concerns.
5. Endmoor is surrounded by industrial sites, Summerlands currently has numerous units empty as it is too far from Kendal to make business viable, Gatebeck also has sites empty for the same reason, why build more when we cannot fill the ones available?
I am happy to see some growth in housing in the village and feel it necessary for the future however as a resident I am keen to ensure the village grows whilst retaining its character not simply adding 100 dwellings on the edge of the village, which will dwarf the village and cause untold problems with sewerage, surface water, traffic, all the new residents will need to go outside the village for services, therefore many more journeys. With regard to employment the village is too far out to attract businesses as is the current situation, SLDC has talked about storage, whilst in theory is possible in practice the sites suggested do not lend themselves to heavy traffic so where it the justification or soundness in this plan? I feel little has been thought through with regard to the infrastructure problems in general and therefore feel in addition to the lack of consultation the soundness is brought into question.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
689. Ms Jane Parker (Individual) : 24 Apr 2012 16:15:00
Policy/Site No.
LA1.3 Housing Allocations - R697 & part R242 ULVERSTON CROFTLANDS EAST
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
plans are unsound in relation to croftlands estate because 1. iThe double in houses will double traffic: Birchwood Drive, already busy with local buses, through traffic and many parked cars, would become hazardous and no plans have been made to
deal with this.
2. Similarly no plans have been made for the increase in local services - such as schools, doctors sewage capacity (already full) - necessary for a double population.
690. Ms Jane Parker (Individual) : 24 Apr 2012 16:16:00
Policy/Site No.
LA1.3 Housing Allocations - R690ulv, R691ULV, R126M, RN184, RN234# & part R242 ULVERSTON CROFTLANDS WEST - NOOK FARM
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
plans are unsound in relation to croftlands estate because 1. iThe double in houses will double traffic: Birchwood Drive, already busy with local buses, through traffic and many parked cars, would become hazardous and no plans have been made to
deal with this.
2. Similarly no plans have been made for the increase in local services - such as schools, doctors sewage capacity (already full) - necessary for a double population.
691. Ms Jane Parker (Individual) : 24 Apr 2012 16:18:00
Policy/Site No.
LA1.3 Housing Allocations - All Ulverston sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
3. Need in this area over and above kendal, Dalton and Barrow has not been clearly demonstrated. Indeed, houses on the estate are not selling quickly.
4. 1,250 more houses in Ulverston represents about 10 percent increase in population. Larger towns such as Barrow and Kendal could more effectively absorb these numbers without increasing their populations by 10 percent.
5.There will be increased car usage: The A590 between Ulverston and Barrow is already notoriously busy and since Barrow has more industry etc commuting will increase, overloading the road and forcing traffic dangerously into small country lanes.
6. The majority (93 percent) of the houses planned for Ulverston will be on green field sights, though there are brown field sights elsewhere and many of these sights are liable to flooding
692. Mrs V Parkinson (Individual) : 18 Apr 2012 15:34:00
Policy/Site No.
LA1.3 Housing Allocations - All Ulverston sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I would like to object to the above proposal on the grounds that SLDC Land Allocation Development Plan consultation process was not 'sound'.
Perhaps the Planning Department have never tried to exit the A590 at Cross-a-Moor to turn either left or right during 'peak' times. It is a nightmare, already Main Street at Swarthmoor is used as a 'quick way' for Croftland residents to exit or get on to the A590. It is used by local schoo children to get to and from Penningto at Croftlands schools.
What are SLDC plans for the pavements on Main Street? To walk in safety you have to cross this road when the pavement stops and continues on the opposite side.
Remember these are country road and were not built to be used by HGVs which even at this moment are being used as a quick route by them.
What are the statistics for accidents happening at Cross-a-Moor? Do the Planning Board propose to widen this part of the A590 to allow the central reservation more vehicles to be situated, to exit the road to turn left or right?
I am in favour of affordable housing but to build more new homes when we already have many people that are unable to sell property, is crazy. The point is the young people just cannot get the mortgages required, because they do not have the deposit required.
Please listen to the residents issues with these proposed plans, does Ulverston need all these new homes, it is a small market town and as such the infrastructure cannot take such a huge plan.
693. Mrs Dorothy Pass (Individual) : 9 Apr 2012 11:20:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.1 Development Boundaries- SWARTHMOOR.
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I believe the document is unsound because the infrastructure issues have not been addressed. In fact it would be fair to say that they have been kicked into the long grass to be dealt with after the land has been sold with the result that as usual the residents will be left to live with the planning shortfalls.
Pennington Junior School is already fully subscribed so the children of existing Swarthmoor families will be disadvantaged and unable to attend their own local school because of the extra children resulting from this development, which will be almost adjacent to the school. Families who have lived in the village for generations will be forced to make unnecessary journeys to take their children to other schools. Sticking portacabins in the school playground is not a solution although I suspect it will figure highly in any plan, if indeed such a plan even exists.
Turning right at any junction with the A590 is avoided at all costs by people currently living to the east of the road. However, there are alternative routes available to these people to leave the village eliminating the need to make dangerous right turns. People living to the west of the A590, either at RN109M or indeed Kingsley Avenue, will have no option but to perform dangerous right turns when heading towards Barrow. It matters not where the access to RN109M is located, be it Cross a Moor lane or directly onto the A590 it will be almost impossible and most certainly dangerous at most times of day, to make a right turn towards Barrow.
There are no shops in Swarthmoor which means that residents have to travel by road to either Ulverston or Barrow to purchase anything. Surely reducing road journeys should be a key factor in any planning decision.
I am also extremely concerned that in the case of RN109M, the land owner seems to have held the council to ransom by making it clear that RN109M would not be available unless RN315# was added to it. In other words, the land owner appears to have played a major part in creating the development plan. This is not something that has happened in the past and it won’t happen under the new planning law. Land owners should not be allowed to dictate where development takes place. That is the role of local councils. I believe that this has also occurred in other areas currently under consideration by SLDC.
Finally, the real irony is that there are other more suitable sites available away from the A590, which were identified during the previous consultations and didn’t attract significant objections but were summarily dismissed because of the planner’s obsession with RN109M. This has been a seriously bad case of planners riding roughshod over local residents with the full support of the Lib Dem controlled SLDC.
These sites should be reconsidered.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
694. Mrs Dorothy Pass (Individual) : 16 May 2012 09:58:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - All Swarthmoor sites
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I believe the document is unsound because the infrastructure issues have not been addressed. In fact it would be fair to say that they have been kicked into the long grass to be dealt with after the land has been sold with the result that as usual the residents will be left to live with the planning shortfalls.
Pennington Junior School is already fully subscribed so the children of existing Swarthmoor families will be disadvantaged and unable to attend their own local school because of the extra children resulting from this development, which will be almost adjacent to the school. Families who have lived in the village for generations will be forced to make unnecessary journeys to take their children to other schools. Sticking portacabins in the school playground is not a solution although I suspect it will figure highly in any plan, if indeed such a plan even exists.
Turning right at any junction with the A590 is avoided at all costs by people currently living to the east of the road. However, there are alternative routes available to these people to leave the village eliminating the need to make dangerous right turns. People living to the west of the A590, either at RN109M or indeed Kingsley Avenue, will have no option but to perform dangerous right turns when heading towards Barrow. It matters not where the access to RN109M is located, be it Cross a Moor lane or directly onto the A590 it will be almost impossible and most certainly dangerous at most times of day, to make a right turn towards Barrow.
There are no shops in Swarthmoor which means that residents have to travel by road to either Ulverston or Barrow to purchase anything. Surely reducing road journeys should be a key factor in any planning decision.
Finally, the real irony is that there are other more suitable sites available away from the A590, which were identified during the previous consultations and didn’t attract significant objections but were summarily dismissed because of the planner’s obsession with RN109M. This has been a seriously bad case of planners riding roughshod over local residents with the full support of the Lib Dem controlled SLDC.
These sites should be reconsidered.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
695. Mrs Dorothy Pass (Individual) : 16 May 2012 10:00:00
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I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - RN109M RN315# SWARTHMOOR OFF CROSS-a-MOOR
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I am also extremely concerned that in the case of RN109M, the land owner seems to have held the council to ransom by making it clear that RN109M would not be available unless RN315# was added to it. In other words, the land owner appears to have played a major part in creating the development plan. This is not something that has happened in the past and it won’t happen under the new planning law. Land owners should not be allowed to dictate where development takes place. That is the role of local councils. I believe that this has also occurred in other areas currently under consideration by SLDC.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
696. Mr Christopher Patching (Individual) : 16 Apr 2012 10:58:00
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I have read the guidance notes
Policy/Site No.
LA1.10 Existing Green Infrastructure - Site Omission
If you have selected a ‘Site omission’ please enter the site reference or location and relevant policy below
HEVERSHAM AND LEASGILL SITE R75
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
People have not been made fully aware of the need to put forward areas of "local green space" that they feel are important to their community, as part of the allocations of land document.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The government is putting greater emphasis on areas of local green space through the NPPF whereby local communities, through local and neighbourhood plans, should be able to identify, for special protection, green areas of particular importance to them. The criteria for land which could be included under these local designations would be flexible to suit local need (Refer to Impact assessment NPPF). It indicates that this work can only be undertaken when plans are prepared or reviewed. We should be careful to consider the best use for Greenfield land and not automatically assume it will be for housing and feel it is vitally important to map the revised areas of local green space before development begins. In this respect we feel a full review of local green space and the criteria by which it is determined is now required as part of the allocations of land document
Local green spaces can perform many functions, not just areas for recreation and are made up of many physical components which can include woodlands, agricultural land, fields, village greens, open spaces, churchyards, allotments, hedges, trees, ponds etc. It can add to the areas network of green infrastructure by the creation of areas for wildlife and providing environmental connectivity (wildlife corridors or stepping stones), protection of areas for their visual amenity, conserving views from and into green landscapes, their historic importance, conserving historic landscapes, woodlands etc. If planned carefully it could also allow us to adapt to the effects of climate change (i.e. surface water drainage/storage), use of areas for food production, preserve green space for the use of future generations, support biodiversity and help conserve and enhance the natural, local and historic environment which surrounds us, maintaining our connection with it and so promoting a "sense of place”.
The importance of green infrastructure is now being recognized as a life support system, as part of a multi-functional network of natural components of green and blue spaces lying within and between cities, towns and villages that provides multiple social, economic and environmental benefits (which is necessary to deliver sustainable development).
The CLERE Model for multifunctional green space identifies 5 broad types of green space: community, landscape, ecosystem, recreation and economy.
(Refer to North West Green Infrastructure Guide).
We live in the area of Heversham and Leasgill. The Cumbria landscape character assessment shows the villages as lying in an area characterized as Broad Valleys (8b):
Characterized by wide and deep valleys with open floodplains, rural farmland, pockets of scrub, woodland and coniferous plantations, hedges and stone walls, road and railway lines often follow the linear valley contours.
• Traditional villages and their siting that follows the grain of the valleys are sensitive to unsympathetic expansion. Tradition stone bridges and roads could be sensitive to flooding events and highway improvements.
• Development for infrastructure and housing should be carefully sited, avoiding open valley floors, obstruction of corridor views and set high standards of landscape treatment. It should minimize impact on local character through ensuring design and scale respects the local vernacular and character. Fringe development should be discouraged in non-traditional materials that will affect the setting of the village.
The villages lie on the lower Eastern slope of the open floodplain (valley) which is the upper tidal estuary of Morecambe Bay and the river Kent.
It is an area of recognized international and national importance for wildlife and forms part of the Morecambe Bay Wetlands project for the reintroduction of wetlands to this area and encompasses the wetlands of Foulshaw moss SSSI, Morecambe Bay SSSI/Ramsar site and is a BAP Priority Habitat area.
We think that site R75 should be considered as local green space for Heversham and Leasgill. It highlights areas where the current designations for local green spaces are lacking when compared to the NPPF vision for local green spaces and their function within a wider network of green infrastructure, for example:
The problems with flooding, due to surface water drainage, on the A6 have been identified and this site is used to mitigate these problems by storing the flood water.
This site is also immediately adjacent to the flood plain and wetland areas of the Kent Estuary and the BAP Priority Habitat Area (refer to maps).
This site also has the only open, far reaching views, over the valley as you travel along the road through the village so would maintain the communities only connection with this wider valued landscape.
It would also have a significant visual impact, as you travel around the coast (the Cumbrian Coastal Way emerges onto the A6 at this point) as it is a steep sloping site and therefore any development would be very prominent.
It would also allow wildlife habitats room to migrate inland, with the effects of climate change, providing a continuation of the wildlife corridor along the Coastal Way and act as a stepping stone to the higher ground, namely Heversham Head Plantation, which is also an area of local/national importance.
It also has local importance as the historic boundary between Heversham and Levens which ran through the middle of this site.
It would also relate to the Core Strategies vision for the future …”although settlements have grown, there is a network of green spaces maintained within them providing a link with the wider countryside”.
For these reasons we think it should now be designated as a local green space.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
697. Mr & Mrs Matthew & Doreen Patrick (Individual) : 30 Mar 2012 10:36:00
Policy/Site No.
LA1.3 Housing Allocations - All Burton-in-Kendal sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
We wish to strenuously object to the development plan as outlined in your
document "Proposed L.D.F. for Burton" on the following basis:-
The village of Burton does not have sufficient infrastructure to cope with the
extra housing in terms of shops, school placements, sewerage capacity and
physical street dimensions. Previous experience with road traffic through the
village shows major problems caused by the narrow aspect of the through
road. A number of vehicle accidents in the last year have highlighted this,
and within that time, we have seen a car upside down on the pavement on
Main Street within a hundred yards of the end of Mowbray Drive. In addition,
whenever there is a blockage on the M6, excessive traffic is diverted through
the village which causes gridlocks !!
It is simply not acceptable to 'dump' all the new development into the zone
between Burton and Holme because clearly development in the two areas of
'Natural Beauty' i.e. Silverdale/Arnside and the Yorkshire Dales National Park
are prohibited. A class example of this is the location of a 90 metre Wind
Turbine adjacent to Burton Services over-riding all local objections.
Cont'd/ ...... .
We feel it is time to stand up against tacit planning acceptance which favours
developers and builders against existing residents and would ask you to
accept this letter as our formal objection to this plan.
We wish to enjoy some 'green and pleasant land' while it still exists. Indeed,
had the council and its councillors not 'dragged their feet' for Burton and
Holme to be included within the Area of Natural Beauty as its residents had
requested some long time ago, your plan would never have been considered.
698. Mr Peter Pattinson (Individual) : 10 May 2012 09:19:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - All Endmoor sites
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
South Lakeland Land Allocations Development Plan Document Representation
l.Housing Site 1 M41M-mod Land North of Sycamore Close Endmoor (100 dwellings) and
Housing Site 2 R670-mod Land Adjacent to Endmoor Farm (25 dwellings.)
1n housing sites 1 and 2 the DPD proposes to build 125 dwellings which together increase the area
of Endmoor village by 30% and increase the number of homes in Endmoor village by 48%. There
are too many dwellings packed too densely with no open green spaces. The DPD is not sound and
the strategy is wrong. There is no evidence of need for so many houses. 1n South Lakeland there are
1000 empty dwellings needing to be refurbished according to Tim Farron and there 2,500 empty
dwellings which don't need refurbishing according to Radio Cumbria because of a downturn in the
economy. This development will damage the beautiful landscape especially the drumlins and is in a
village with no jobs for workers, no banks, no doctors, no dentists, shops are closing down and the
post office has closed down. The outreach post office has reduced hours of opening. Occupants of
the new dwellings will have to travel to Kendal or Milnthorpe for work or shopping or banks or
doctors etc which is a waste of non renewable resources and will damage air quality. There is a
major problem with sewage (see Infrastructure below.) A better alternative would be to use the
thousands of empty properties in South Lakeland and then if it is necessary to build more dwellings,
build them in places where there are jobs, banks, doctors, shops other services and infrastructure.
3 Infrastructure Waste Water Treatment
The DPD for the above housing and employment sites is not sound because there is no clear strategy
with regard to waste water treatment. Therefore none of the above developments can go ahead and
therefore the DPD is not deliverable. No consultation took place that the sewage treatment works at
Crooklands and Endmoor do not have enough capacity for the above housing developments
and will have to be closed and the sewage pumped to Low Park Lane sewage works which
will be too small and will be replaced by a very large new sewage treatment works. United
Utilities will have to lay large diameter sewage pipes from the Crooklands and Endmoor
sewage treatment works all the way to a new very large sewage treatment works at Low Park
Lane. The sewage pipes will have to be laid deep underground causing damage to the
beautiful landscape especially the drumlins. The sewage from the Crooklands and Endmoor sewage
treatment works will have to be pumped uphill to Low Park Lane sewage treatment works. Laying the
pipes for this distance and pumping the sewage uphill all this way and building a very large sewage
treatment works is a waste of non renewable resources. Large sewage works are usually smelly and
damage air quality. A better alternative is to build a new sewage works on Sites EN20/EN33 at
Gatebeck near the river instead of building the commercial/industrial sites there. Sewage from
Crooklands and Endmoor sewage works could be pumped to here which is easier and waste less
renewable resources than pumping it uphill to Low Park Lane sewage works and it would not be
necessary to enlarge the sewage works at Low Park Lane.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
699. Mr Peter Pattinson (Individual) : 10 May 2012 09:22:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - M41M ENDMOOR NORTH OF SYCAMORE DRIVE
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
South Lakeland Land Allocations Development Plan Document Representation
l.Housing Site 1 M41M-mod Land North of Sycamore Close Endmoor (100 dwellings) and
Housing Site 2 R670-mod Land Adjacent to Endmoor Farm (25 dwellings.)
1n housing sites 1 and 2 the DPD proposes to build 125 dwellings which together increase the area
of Endmoor village by 30% and increase the number of homes in Endmoor village by 48%. There
are too many dwellings packed too densely with no open green spaces. The DPD is not sound and
the strategy is wrong. There is no evidence of need for so many houses. 1n South Lakeland there are
1000 empty dwellings needing to be refurbished according to Tim Farron and there 2,500 empty
dwellings which don't need refurbishing according to Radio Cumbria because of a downturn in the
economy. This development will damage the beautiful landscape especially the drumlins and is in a
village with no jobs for workers, no banks, no doctors, no dentists, shops are closing down and the
post office has closed down. The outreach post office has reduced hours of opening. Occupants of
the new dwellings will have to travel to Kendal or Milnthorpe for work or shopping or banks or
doctors etc which is a waste of non renewable resources and will damage air quality. There is a
major problem with sewage (see Infrastructure below.) A better alternative would be to use the
thousands of empty properties in South Lakeland and then if it is necessary to build more dwellings,
build them in places where there are jobs, banks, doctors, shops other services and infrastructure.
3 Infrastructure Waste Water Treatment
The DPD for the above housing and employment sites is not sound because there is no clear strategy
with regard to waste water treatment. Therefore none of the above developments can go ahead and
therefore the DPD is not deliverable. No consultation took place that the sewage treatment works at
Crooklands and Endmoor do not have enough capacity for the above housing developments
and will have to be closed and the sewage pumped to Low Park Lane sewage works which
will be too small and will be replaced by a very large new sewage treatment works. United
Utilities will have to lay large diameter sewage pipes from the Crooklands and Endmoor
sewage treatment works all the way to a new very large sewage treatment works at Low Park
Lane. The sewage pipes will have to be laid deep underground causing damage to the
beautiful landscape especially the drumlins. The sewage from the Crooklands and Endmoor sewage
treatment works will have to be pumped uphill to Low Park Lane sewage treatment works. Laying the
pipes for this distance and pumping the sewage uphill all this way and building a very large sewage
treatment works is a waste of non renewable resources. Large sewage works are usually smelly and
damage air quality. A better alternative is to build a new sewage works on Sites EN20/EN33 at
Gatebeck near the river instead of building the commercial/industrial sites there. Sewage from
Crooklands and Endmoor sewage works could be pumped to here which is easier and waste less
renewable resources than pumping it uphill to Low Park Lane sewage works and it would not be
necessary to enlarge the sewage works at Low Park Lane.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
700. Mr Peter Pattinson (Individual) : 10 May 2012 09:25:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - R670-mod ENDMOOR SOUTH OF BOWLING GREEN
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
South Lakeland Land Allocations Development Plan Document Representation
l.Housing Site 1 M41M-mod Land North of Sycamore Close Endmoor (100 dwellings) and
Housing Site 2 R670-mod Land Adjacent to Endmoor Farm (25 dwellings.)
1n housing sites 1 and 2 the DPD proposes to build 125 dwellings which together increase the area
of Endmoor village by 30% and increase the number of homes in Endmoor village by 48%. There
are too many dwellings packed too densely with no open green spaces. The DPD is not sound and
the strategy is wrong. There is no evidence of need for so many houses. 1n South Lakeland there are
1000 empty dwellings needing to be refurbished according to Tim Farron and there 2,500 empty
dwellings which don't need refurbishing according to Radio Cumbria because of a downturn in the
economy. This development will damage the beautiful landscape especially the drumlins and is in a
village with no jobs for workers, no banks, no doctors, no dentists, shops are closing down and the
post office has closed down. The outreach post office has reduced hours of opening. Occupants of
the new dwellings will have to travel to Kendal or Milnthorpe for work or shopping or banks or
doctors etc which is a waste of non renewable resources and will damage air quality. There is a
major problem with sewage (see Infrastructure below.) A better alternative would be to use the
thousands of empty properties in South Lakeland and then if it is necessary to build more dwellings,
build them in places where there are jobs, banks, doctors, shops other services and infrastructure.
3 Infrastructure Waste Water Treatment
The DPD for the above housing and employment sites is not sound because there is no clear strategy
with regard to waste water treatment. Therefore none of the above developments can go ahead and
therefore the DPD is not deliverable. No consultation took place that the sewage treatment works at
Crooklands and Endmoor do not have enough capacity for the above housing developments
and will have to be closed and the sewage pumped to Low Park Lane sewage works which
will be too small and will be replaced by a very large new sewage treatment works. United
Utilities will have to lay large diameter sewage pipes from the Crooklands and Endmoor
sewage treatment works all the way to a new very large sewage treatment works at Low Park
Lane. The sewage pipes will have to be laid deep underground causing damage to the
beautiful landscape especially the drumlins. The sewage from the Crooklands and Endmoor sewage
treatment works will have to be pumped uphill to Low Park Lane sewage treatment works. Laying the
pipes for this distance and pumping the sewage uphill all this way and building a very large sewage
treatment works is a waste of non renewable resources. Large sewage works are usually smelly and
damage air quality. A better alternative is to build a new sewage works on Sites EN20/EN33 at
Gatebeck near the river instead of building the commercial/industrial sites there. Sewage from
Crooklands and Endmoor sewage works could be pumped to here which is easier and waste less
renewable resources than pumping it uphill to Low Park Lane sewage works and it would not be
necessary to enlarge the sewage works at Low Park Lane.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
701. Mr Peter Pattinson (Individual) : 10 May 2012 09:28:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.8 Local Employment Allocations - EN20, EN33# ENDMOOR LAND NORTH OF GATEBECK LANE, GATEBECK
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
2.Mixed Commercial/Industrial Premises Sites EN20 and EN33 Land at Gatebeck
The DPD is not sound and the strategy is wrong. This is the wrong place for a new site. There is no
evidence of need for more mixed commercial/industrial sites as there is already a surplus of
vacant and apparently unwanted units of this nature in Gatebeck and Sunnnerlands because of
a downturn in the economy and because Gatebeck and Sunnnerlands are too far away from centres
where commercial/industrial units would be viable. Commercial/industrial units on this land at
Gatebeck especially the storage and distribution type will give rise to unacceptable levels of traffic
including trucks on the very narrow country lanes and create conditions prejudicial to highway
safety. Gatebeck Lane is very dangerous due to the large number of vehicles including trucks
travelling very fast around the narrow tight bends and blind comers. Also the development will
damage the beautiful landscape especially the drumlins. There is a major problem with sewage (see
Infrastructure below.) A better alternative would be to use the vacant units in Gatebeck and
Sunnnerlands. There are commercial/industrial units available at Farleton where the auction mart is
being built as well as at Milnthorpe and Kendal
3 Infrastructure Waste Water Treatment
The DPD for the above housing and employment sites is not sound because there is no clear strategy
with regard to waste water treatment. Therefore none of the above developments can go ahead and
therefore the DPD is not deliverable. No consultation took place that the sewage treatment works at
Crooklands and Endmoor do not have enough capacity for the above housing developments
and will have to be closed and the sewage pumped to Low Park Lane sewage works which
will be too small and will be replaced by a very large new sewage treatment works. United
Utilities will have to lay large diameter sewage pipes from the Crooklands and Endmoor
sewage treatment works all the way to a new very large sewage treatment works at Low Park
Lane. The sewage pipes will have to be laid deep underground causing damage to the
beautiful landscape especially the drumlins. The sewage from the Crooklands and Endmoor sewage
treatment works will have to be pumped uphill to Low Park Lane sewage treatment works. Laying the
pipes for this distance and pumping the sewage uphill all this way and building a very large sewage
treatment works is a waste of non renewable resources. Large sewage works are usually smelly and
damage air quality. A better alternative is to build a new sewage works on Sites EN20/EN33 at
Gatebeck near the river instead of building the commercial/industrial sites there. Sewage from
Crooklands and Endmoor sewage works could be pumped to here which is easier and waste less
renewable resources than pumping it uphill to Low Park Lane sewage works and it would not be
necessary to enlarge the sewage works at Low Park Lane.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
702. Mr Peter Pattinson (Individual) : 10 May 2012 09:30:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
0.0 Whole Document
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The SLDC Land Allocations DPD strategy is not sound, it is not justified in that is is not founded on a
robust and credible evidence base and is not sustainable and is not considered the most appropriate
strategy when considered against the reasonable alternatives. It is not effective in that the document is
not deliverable, flexible or suitable for monitoring. It is not consistent with national policy. It does not
comply with the SLDC Core Strategy listed below:
CS 1.1 Sustainable Development Principles
CS 1.1.1 Improve air quality, strengthen ecosystem services to enhance resilience of the natural
environment and minimize the use of non-renewable resources.
CS 1,1 ,2 It is vital to protect the countryside for its intrinsic beauty, diversity and natural resources and
for its ecological and geological values.
CS 1.1.3 Enhance landscape characters and features.
CSL 1.6 Minimise the need to travel.
CS 1.1. 7 New developments should be directed to existing service centres where there is adequate
service and infrastructure capacity to accommodate the levels of development.
CS 1. 1.8 Development should first use existing buildings and previously developed land and when this
is used up, should develop land where this is well located for jobs, other services and infrastructure.
CS 1.1.9 Developments should meet the diverse social and economic needs of local communities.
CS 1.1.1 0 Development needs to be balanced with protecting and enhancing the attractiveness of the
area.
CS 1.2 The development strategy New development will only be permitted in open countryside where it,
has an essential requirement for a rural location and is needed to sustain existing businesses.
CSS The East. Protect the network of green infrastructure and important environmental characteristics
and ensure that new development safeguards and enhances the natural environment.
CS6.6 Making effective and efficient use ofland and buildings
Bring previously developed land and buildings and empty housing into housing use.
CS7 .1 Do not overdevelop employment sites in relation to the actual scale of economic growth in light
of a review of employment trends and needs.
CS7.4 Employment related development should not be detrimental to the character and appearance of
the landscape and should not give rise to unacceptable levels of traffic and should not create conditions
prejudicial to highway safety.
CS8.1 Green Infrastructure Ensure that green infrastructure is an integral part of creating sustainable
communities and protect the countryside from inappropriate development and protect species and
habitats and create new habitats and wildlife corridors.
CS8.2 Protection and enhancement of landscape and settlement character
CS8.4 Biodiversity and Geodiversity. Protect enhance and restore the biodiversity and geodiversity
value ofland and buildings
CS8.1 0 Design The siting, design, and scale of all development should maintain or enhance the quality
of the landscape.
CS 10.2 Transport impact of new development. Development will be designed to reduce the need
to travel and the expected nature and volume of traffic generated by the proposal could be
accommodated by the existing road network without detriment to the amenity or character of
the surrounding area, local air quality or highway safety
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
703. Mr & Mrs Colin & Sherie Paxton (Individual) : 25 May 2012 10:03:00
Policy/Site No.
LA1.3 Housing Allocations - M41KM KENDAL SOUTH OF LUMLEY ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
- Loss of green field space is detrimental to the character and heritage of the area. This is contrary to Coalition Government Sustainable Development Policy, which recognizes brown field preference above important countryside areas. The Soundness and legality of the plan is therefore challenged as being contrary to Government Planning Policy.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
We wish to object to and challenge the soundness of proposed land allocation for development – to south of Lumley Rd. (M41KM) and Scroggs Wood Light Industrial Site (E4M) on the following grounds:
- The proposed developments would spoil the initial impression to Kendal visitors, being on the main access route and adjacent to the Town boundary. The Lumley road site is steeply graded and properties would impose on the existing view for Kendal visitors. The line of trees acts as a natural barrier between countryside and properties. Building to the South of this line (E4M), would fundamentally change the Kendal “Gateway to the Lakes” character as a valued landscape. This is contrary to the adopted planning Core Strategy. The Soundness of the plan is therefore challenged on visual impact grounds, contrary to planning policy.
- Loss of green field space is detrimental to the character and heritage of the area. This is contrary to Coalition Government Sustainable Development Policy, which recognizes brown field preference above important countryside areas. The Soundness and legality of the plan is therefore challenged as being contrary to Government Planning Policy.
- Milnthorpe Road already backs up to the bypass at peak times with access to and from our Lane proving diffcult and dangerous especially at this time. Furthermore Milnthorpe Road cannot accommodate the massive increase that such development, in these locations, would create. Kendal town development to attract visitors is pointless if they cannot obtain satisfactory access. The associated pollution from stationary traffic is incompatible with sustainable development objectives. The soundness of the development is challenged on the basis that there is no traffic plan to address these issues.
- The A6 is a crucial access for emergency services, particularly following the downgrading of Westmorland General Hospital. Further congestion on this route would introduce undue risk. The potential for accidents when joining the main road would also be significantly increased. The Soundness of the plan is therefore challenged on safety grounds.
- The soundness of the development is challenged on the basis that there is inadequate local infrastructure including drainage, sewerage and roads.
- The proposed development is incompatible with the character of the historic Helsington development contrary to planning policy. The Soundness of the plan is therefore challenged as being detrimental to the historical character of the area.
- The site is clearly NOT “in an accessible location or an easily developable level site” (Achievability statement P133 2 C). The Soundness of the plan is therefore challenged as being contrary to this declared planning statement.
- There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of adequate existing residential space and more suitable alternative development sites.
- The Development plan should retain the "Kendal Gateway to the Lakes" image supporting tourism and established Cumbrian employment, not destroy it with unsightly, unnecessary development and traffic jams. You don’t put your wheelie bin on your front door step! The DPD appears to have completely disregarded the massive opposition and valid objections previously made. The soundness of this planned development is challenged as disregarding local opinion contrary to Government Policy.
704. Mr & Mrs Colin & Sherie Paxton (Individual) : 25 May 2012 10:06:00
Policy/Site No.
LA1.6 Strategic Employment Sites - E4M KENDAL LAND AT SCROGGS WOOD, MILNTHORPE ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
We wish to object to and challenge the soundness of proposed land allocation for development – to south of Lumley Rd. (M41KM) and Scroggs Wood Light Industrial Site (E4M) on the following grounds:
- The proposed developments would spoil the initial impression to Kendal visitors, being on the main access route and adjacent to the Town boundary. The Lumley road site is steeply graded and properties would impose on the existing view for Kendal visitors. The line of trees acts as a natural barrier between countryside and properties. Building to the South of this line (E4M), would fundamentally change the Kendal “Gateway to the Lakes” character as a valued landscape. This is contrary to the adopted planning Core Strategy. The Soundness of the plan is therefore challenged on visual impact grounds, contrary to planning policy.
- Loss of green field space is detrimental to the character and heritage of the area. This is contrary to Coalition Government Sustainable Development Policy, which recognizes brown field preference above important countryside areas. The Soundness and legality of the plan is therefore challenged as being contrary to Government Planning Policy.
- Milnthorpe Road already backs up to the bypass at peak times with access to and from our Lane proving diffcult and dangerous especially at this time. Furthermore Milnthorpe Road cannot accommodate the massive increase that such development, in these locations, would create. Kendal town development to attract visitors is pointless if they cannot obtain satisfactory access. The associated pollution from stationary traffic is incompatible with sustainable development objectives. The soundness of the development is challenged on the basis that there is no traffic plan to address these issues.
- The A6 is a crucial access for emergency services, particularly following the downgrading of Westmorland General Hospital. Further congestion on this route would introduce undue risk. The potential for accidents when joining the main road would also be significantly increased. The Soundness of the plan is therefore challenged on safety grounds.
- The soundness of the development is challenged on the basis that there is inadequate local infrastructure including drainage, sewerage and roads.
- The proposed development is incompatible with the character of the historic Helsington development contrary to planning policy. The Soundness of the plan is therefore challenged as being detrimental to the historical character of the area.
- The site is clearly NOT “in an accessible location or an easily developable level site” (Achievability statement P133 2 C). The Soundness of the plan is therefore challenged as being contrary to this declared planning statement.
- There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of adequate existing residential space and more suitable alternative development sites.
- There is spare capacity and expansion potential on existing established trading estates on Shap Road. The plan to relocate the Rugby club to Oxenholme and development of the Gilkes site are more suited to development than Scroggs Wood. The soundness of the case for such development is challenged on the basis of existing and more suitable alternative development sites compatible with planning policy.
- What and where is the business case and demand for a further speculative light industrial business park? Why would UK businesses move to such a park when financial assistance and tax breaks are available for designated City areas such as the Manchester Enterprise Zone? The soundness of this planned development is challenged on the basis of no established demand or business case.
- The Development plan should retain the "Kendal Gateway to the Lakes" image supporting tourism and established Cumbrian employment, not destroy it with unsightly, unnecessary development and traffic jams. You don’t put your wheelie bin on your front door step! The DPD appears to have completely disregarded the massive opposition and valid objections previously made. The soundness of this planned development is challenged as disregarding local opinion contrary to Government Policy.
705. Mr & Mrs Colin & Sherie Paxton (Individual) : 25 May 2012 10:08:00
Policy/Site No.
LA1.3 Housing Allocations - All Kendal sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of adequate existing residential space and more suitable alternative development sites.
706. Mr & Mrs Colin & Sherie Paxton (Individual) : 25 May 2012 10:09:00
Paragraph No.
0.0 Whole Document
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Is there a definition of “affordable housing” in the context of Kendal young person income? Or is this merely a rouse to allow land owners and builders to make massive profits, without any tangible commitment to house the low paid of Kendal? The Soundness is therefore challenged on the basis of no defined affordability test.
707. Mr & Mrs Colin & Sherie Paxton (Individual) : 25 May 2012 10:10:00
Policy/Site No.
LA1.4 - Kendal Sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of adequate existing residential space and more suitable alternative development sites.
708. Mrs Sarabeth Pearce (Individual) : 10 Apr 2012 12:20:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.1 Development Boundaries- ARNSIDE
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
SLDC’s Core Strategy, and national planning policy, set out the criteria for Land Allocations within an AONB.
National policy as stated in the new NPPF is that land within an AONB has “the highest status of protection in relation to landscape and scenic beauty “(para 115).
SLDC’s core strategy restates many of these policies and principles.
Policies include the need to protect green spaces important to the natural environment of the AONB, and the requirement to maintain the open character of the settlements concerned. They set out the sequential approach to be adopted in the allocation of sites (previously used sites etc).
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I support the Arnside Parish Plan Trust and the APC.
SPECIFIC CONCERNS AND OBJECTIONS OF ARNSIDE PARISH PLAN TRUST (APPT) AND ARNSIDE PARISH COUNCIL REGARDING SLDC’s CURRENT LAND ALLOCATIONS.
1. SUMMARY
Arnside Parish Plan Trust and Arnside Parish Council believe that SLDC has produced a Land Allocation plan which does not pass the main tests of soundness and which;
• is not consistent with the detailed policies set out in its Core Strategy designed to apply the duty of the Council to protect the special characteristics and historic landscape of the Arnside and Silverdale Area of Outstanding Natural Beauty. In particular, its land allocations for housing propose using exclusively greenfield sites and land rated currently as "Important Open Space" which will have an adverse impact on the AONB landscape and on Arnside's settlement character.
• fails to identify how specific local needs (for affordable rented social housing) will be delivered in practise, and who will deliver that need.
• does not reconcile effectively the “highest level of protection” given to land within an AONB, as expressed in the new version of the NPPF, with delivering the local needs which qualify as “exceptional circumstances”.
• has failed to explore sufficiently all potential alternatives and to apply the appropriate land use hierarchy. Instead it defaults to allocating greenfield sites and Important Open Spaces within the AONB which currently have “the highest level of protection” and are particularly valued by the local community and by the management of the AONB.
• fails to address the need to regenerate brownfield sites in the village to repair the environmental damage they are inflicting.
• has failed to win the support of the local community (550 signed petition against) and to respond to emerging local plans. Neither does it have the support of the management of the AONB, Arnside Parish Council, Arnside Parish Plan Trust and other bodies important to the management of the specially protected environment of the AONB.
• relies on a planning policy which is not sustainable because it sets too high a site threshold of 0.3ha which could prevent a more organic approach to land use which will impose less damage than the development of large sites.
• assumes that a planning policy of relying on commercial development to provide affordable housing through a 65/35 allocation ratio is viable, without providing any evidence that this policy is workable in today’s and foreseeable market conditions.
• assumes that this 65/35 ratio (which consumes three times the amount of land needed for affordable housing) can be justified in relation to “the highest level of protection” provided by the NPPF against inappropriate development of land within an AONB.
• is not sustainable. Instead, it will damage the rural, open character of the village and its attraction to residents and visitors alike in a sensitive location within the AONB. This will undermine the economy on which the local community depends for a viable future.
APPT and APC set out in more detail below the basis of its objections. The process for filing objections is complex and difficult for lay people to use with confidence. As this document has been prepared without the benefit of advice from a planning lawyer, we hope that all our points will still be considered even if not categorised correctly.
We also reserve the right to make further submissions, and to present emerging new information, at the Inspector’s hearing.
2. AMPLIFICATION
2.1. Overview
Our principal objections to the current Land Allocations for Arnside are that SLDC has not met the standards of evidence and proof required to justify the allocation of greenfield sites against the special protections afforded to such land by the national policies contained in the new version of the NPPF, and, as a result, neither has it gained the support of the local community. The Allocations are not sound in the context of the specific circumstances of Arnside.
Apart from one brownfield site allocated for employment purposes, all sites allocated for housing are greenfield sites, and two of these are currently designated “Important Open Spaces”. Land within an AONB has the highest level of protection under the NPPF and, within this AONB, these Important Open Spaces have, over a long time, been regarded by the community as having special value to the character and sustainability of Arnside.
We assert that SLDC has a special duty to apply to these sites the highest level of protection available. We further assert that they have not demonstrated to the standard required that there are no other viable alternatives within Arnside, or in surrounding areas, to meet specific local needs for affordable housing. Market housing does not fit the criteria of "need" in this context, especially as there are consistently over 70 dwellings available for sale in all price ranges in Arnside.
The Arnside community (through Arnside Parish Council and Arnside Parish Plan Trust) believe that there are viable alternatives which could be brought into play over the extended period covered by the Land Allocations process. Under the new Community Planning and Neighbourhood Planning regimes, SLDC should therefore take the opportunity to explore these alternatives more effectively with community representatives and to establish whether a better plan could be produced.
Because of the failure of SLDC to demonstrate that it has used its best endeavours to explore all reasonable alternatives, and because of a number of weaknesses in the evidence base used as set out in more detail below, we object to SLDC’s current Land Allocations because they fail the test of soundness on a number of points.
2.2. Housing needs in Arnside
We recognise and accept that more affordable housing is needed in Arnside. The most accurate survey currently available of need in the area (dated 2009) indicates that there is a short term need for 27 affordable homes in the village. It is clear that by far the main element of that need is for social rented housing. Longer term needs are still very unclear.
There is already an adequate supply of market housing with available stock being sustained at over 70 homes for sale of all types and price ranges, so there is no “exceptional need” to allocate land for market housing.
There is also a history within the village of affordable housing being built but failing to be maintained as part of the ongoing affordable housing stock because it has been traded on as holiday homes and general market housing. This needs to be avoided in future.
We understand that, within a confined area such as Arnside, it is difficult to find sites which balance the conflicting objectives of providing needed affordable housing while at the same time preserving the character of the settlement within the AONB to the “highest standards of protection” that SLDC, and we, are obliged to achieve.
We are concerned, however, that SLDC has produced a range of numbers to justify its Land Allocations. The attached Appendix illustrates the range of numbers cited in the plan. Under pressure from the local community, SLDC has reduced progressively the numbers allocated to the AONB in proportion to other areas within South Lakes District to try more effectively to minimise the adverse impact on the core characteristics of the AONB. We welcome the reduction in numbers and the attempts to address this challenge.
However, the fact that these numbers have only recently been further amended, and that they are based on proportional data drawn from the wider region rather than specific local needs, illustrates the lack of certainty and the weak evidence base for the need within Arnside.
This is important because precise allocations are required to deliver the right types of homes, and in order to avoid the allocation of inappropriate sites, and the unnecessary - and avoidable - destruction of highly valued greenfield space. We therefore believe that this element of the plan is unsound because the calculation of need requires further work to ensure the correct housing types are delivered, and to ensure that unnecessary damage to the character of the village within the AONB is avoided.
APPT and APC are keen to engage in further work with SLDC to establish a more accurate assessment of housing need within the village.
2.3. Inappropriate Land Allocations
Arnside contains currently brownfield - and other smaller sites - which SLDC has not listed in the Land Allocations. These sites could, and should, be developed both to supply affordable housing needs and to repair the detrimental affect on the character of the village caused by the derelict brownfield locations. It is argued by APPT/APC that these sites, if brought into use over the term of the Land Allocations Plan to 2025, could supply much of the specifically identified affordable housing needs of the Village.
The current SLDC Land Allocations, however, use exclusively greenfield sites, two of which are currently listed as Important Open Space, and as such are important to defining the open and rural character of the village within the AONB and maintaining its long term economic sustainability.
We believe that the current allocations fail the test of supporting the economic and environmental sustainability test for the reasons set out in detail in the emerging Village Plan for Arnside (http://www.arnside.gov.uk/Warehouse/ArnsideLookingForward4.pdf).
They are also the main concern of the 550+ signature petitions raised and submitted to SLDC during this process which stressed the need to protect these greenfields and Important Open Spaces. As a result, the current Allocations do not have the support of the Arnside community, and therefore they fail the soundness test for community engagement and support.
The current Allocations also fail to meet the sequential test for the use of brownfield sites etc before allocating greenfield sites. The allocation of greenfield sites currently designated as Important Open Space within an AONB is even further up the sequential hierarchy and therefore further from meeting the soundness test.
As stated above, there are a range of smaller infill and brownfield sites which would not have as adverse an environmental impact and which could be brought into use over the plan period, especially if SLDC applied some of its other powers, or to adjust some of its current planning policies (see below), or if it took a longer view of potential availability.
The current allocations therefore fail the “exceptional circumstances” and “highest level of protection” national policy soundness test for Land Allocations within an AONB. This is because the current documents fail to demonstrate that SLDC has used its best endeavours to find alternatives over the lifetime of this planning period, and because it has not adapted its planning policies to fit the special circumstances and “highest level of protection” applying within an AONB.
2.4. Specific concerns about the soundness of local policies.
We have concerns about some of the stated policies and planning assumptions applied by SLDC within this process. If valid, they would mean that SLDC’s plan would fail the soundness tests in several regards.
• SLDC has taken a policy decision not to include sites of less than 0.3 hectares in the current Land Allocations. As a consequence it has had to resort to allocating sensitive and controversial large greenfield sites. SLDC has admitted, however, that the smaller sites could well come into play during the plan period and they would probably get planning permission. Such sites could, however, supply a substantial part of the local need for social rented housing, especially if they were developed in small increments by a housing association or similar body. We understand that a smaller threshold of 0.1ha is being applied within the Lake District National Park. We believe therefore that the soundness test will not be met because SLDC has made this policy decision without opting for an alternative approach to allocate smaller sites which could be used in the context of the exceptional circumstance test and highest level of protection applying within an AONB. The community believe that the larger and very sensitive greenfield sites should be removed from the allocations until the smaller site potential has been exhausted.
• The Local Development Plan appears also to be critically dependent on the success of the assumption that the main local need – for social rented affordable housing – will be delivered through the policy of allocating sites to commercial developers, subject to them building a 35% ratio of affordable housing within development sites. Despite considerable pressing for evidence, SLDC has not provided any data to demonstrate that this policy is viable and will succeed in the current economy and in future commercial development markets.
This is particularly important in view of major changes to financial and housing markets since 2008. SLDC needs to prove that commercial developers will be able to overcome the additional financial burden placed on these sites to pay for affordable housing and for such elements as the Community Infrastructure Levy. This has to be done against a background of a difficult credit market, very low housing turnover volumes, and falling house prices. All this in an area where the planning portfolio holder hopes and believes that this land allocation policy will reduce the price of market housing by 20%, thus increasing the pressure on the development funding model.
We have evidence locally that builders are unable to raise finance for site development and the above burdens will only aggravate these problems.
Because this is such a critical and fundamental assumption underlying the whole of SLDC’s Land Allocations, and because the future supply of affordable housing appears to depend entirely on it operating effectively, it is essential that robust and “bankable” evidence is provided by SLDC. Without it, the current Land Allocations cannot pass the deliverability test for the supply of local affordable housing and is therefore not sound.
• The 65/35 development ratio also has one further major weakness; it requires three times the amount of land which would be needed if only the local need for affordable housing is covered. This cannot be said to be meeting the test of “highest level of protection” or “exceptional circumstances” and is not sound because it does not comply with National Policy as expressed in the new version of the NPPF.
• It is much more likely that an appropriate body needs to be found which will focus specifically on building social rented housing without needing to rely on subsidies from a premium placed on commercial developments of market housing. The SLDC documents do not deal adequately with this issue and are therefore unsound because they fail to provide sufficient evidence that the Land Allocations and associated policies will deliver the specific local need for social rented housing.
• SLDC also appears to be driven by fear of the consequences of the new NPPF and their perception that developers will have unfettered access to land if sites are not allocated in a controlled process such as these Land Allocations. This is, it says, because of the “presumption in favour of development”.
We do not believe this to be true within an AONB because of the obligation to apply the “highest level of protection”, and inappropriate land allocations can continue to be resisted. There is therefore no need to rush this process. The current land allocations for Arnside should therefore be referred back for further work with the community to produce a more appropriate plan.
• SLDC appears to be over-relying on the very short term application of the “Deliverability” criteria within the Development Framework. In practise, this has led it to rely on sites where there is a clear immediate intention of the owner to make the site available for development and to capitalise on a commercial opportunity. If that commitment has not been made to date, potentially useful and less sensitive sites have been excluded, even if there is a reasonable chance that they will come into play over the longer term. The consequence of this is that derelict and previously used sites, which should be improved as part of any sensible spatial plan for any community, have been ignored. The knock-on consequence is that greenfield sites could be destroyed while derelict sites remain unused. This is not a sensible planning policy and fails even the commonsense soundness test.
• It is clear that it will take some time to bring into play some of the smaller and brownfield sites within the village but it is argued that the exceptional circumstances of the village within the AONB justify the extra effort (or time delay) that may be required. SLDC has failed to use their best endeavours to apply this extra effort by (for example) using the powers they have to bring derelict sites into use (such as Compulsory Purchase Orders). APPT are keen to work with SLDC to produce a Plan which achieves these objectives but, so far, SLDC has failed this test of soundness in meeting the exceptional circumstances criteria required within an AONB. The new Community planning regime under the Localism Act provides the opportunity to put this right by SLDC working closely with the community. The current land allocations should be deferred until this process has been completed. APPT/APC have an early draft of a community plan already in progress (http://www.arnside.gov.uk/Warehouse/ArnsideLookingForward4.pdf) and are keen to engage SLDC 's support in moving to a complete and workable version.
• We understand that the management of the Arnside & Silverdale Area of Outstanding Natural Beauty have similar and additional objections to the soundness of these Allocations. Arnside Parish Council, through Arnside Parish Plan Trust, intend to coordinate their emerging plans with this and other stakeholders for this area.
• We also understand that Lancaster City Council has a more appropriate treatment of land within the AONB in its Land Allocations policies but that SLDC has not yet coordinated its approach effectively with LCC. There may be solutions to local housing needs which could be accommodated within the neighbouring territories of LCC. SLDC will therefore fail to meet the soundness test until this process has been completed.
• Because of the above, the current Land Allocations should be referred back for revision. This revision would benefit from input from the emerging Arnside Community and Neighbourhood Plans which will address these issues.
Appendix 1
Land Allocation Development Plan Document – Calculation of Housing Need within the AONB*
There are 4 calculations of potential housing needs contained in the document for the AONB part of SLDC
CALCULATION 1
This is based on the AONB population as a % of the total Local Development Framework (LDF) area population
LDF Population 75000
AONB population 5% 3800 (Arnside 2300 and Beetham 1500)
Based on total district housing target of 400 per annum then 5% of this is 20 per annum for the AONB (12 for Arnside and 8 for Beetham)
Over the period 2003-2025 the total for the AONB is 460 (276 for Arnside and 184 for Beetham)
CALCULATION 2
This is based on the 2009 Strategic Market Assessment for Rural South Kendal. The figures for Annual Affordable Housing Requirements (See Page 63) for the period 2009-2015 were based on the 2006 Housing Needs Survey and indicates respondents aspirations.
Rural South Kendal Total 1105
AONB population 15.7% 173
(Arnside 104 and Beetham 69 based on population split shown in calculation 1)
If the above figures were projected at the same level for the whole of the plan 2009-2025 then this gives a total affordable housing need of 555 (333 for Arnside and 222 for Beetham based on population split shown in calculation 1)
CALCULATION 3
This is based on the 2011 Strategic Market Assessment for Rural South Kendal not including Milnthorpe and Kirkby Lonsdale. Again the survey appears to be aspirational. The response rate for Rural South Kendal was 30%. The calculations for the affordable housing market for 2011-2016 were based on:
• Households currently in housing which is unsuitable for their use and who are unable to afford to buy or rent in the market (backlog need)
• New household forming who cannot afford to buy or rent in the market
• Existing households expected to fall into need
• The supply of affordable housing through social renting and intermediate tenure stock
This calculation is similar to number 2
Rural South Kendal Total 435
AONB population 18.54% 225
(Arnside 133 and Beetham 89) based on population split shown in calculation 1)
CALCULATION 4
This is based on Arnside 2009 Housing Needs Survey and 2007 Beetham Housing Needs Survey to determine the need for affordable housing. This survey applied to social rented housing only and represented respondents aspirations and does not necessarily represent actual take up of affordable homes if they were offered. See Appendix Below: Analysis & Critical Review of Housing Needs
2009-14 Arnside 27 ? therefore projected number for 2009-2025 is 86
2007-12 Beetham* 17 ? therefore projected number for 2009-2025 is 61
But in order to deliver the affordable element an allowance for market housing has to be given. If affordable housing is delivered at 35% of market schemes this would bring the total need for 2009-2025 to 420 (Arnside 252 and Beetham 168)
*in the AONB part of Beetham
SUMMARY
Reference in Land Allocation Document Arnside Beetham Total Comments
3.79 Calculation 1 Total need 2003-2025 276 184 460 AONB population as a % of Local Development Area population
3.80 Calculation 2 Affordable need 2009-2025 333 222 555 AONB as a % of Rural South Kendal from an aspirational survey
3.81 Calculation 3 Affordable need 2009-2025 135 90 225 AONB as a % of Rural South Kendal LESS Milnthorpe and Kirkby Lonsdale from an aspirational survey
3.87 Calculation 4 Affordable need 2009-2025
Calculation 4 but also market allowance to achieve this 2009-2025 86
252 61
168 147
420 Arnside and Beetham aspirations for affordable housing
Market allowance figures are unrealistic because unlikely this scenario will happen
From the above 4 calculations it was concluded that the total housing need over the plan period was somewhere between 200 and 400 but because of the low housing delivery since 2003 to the present there was a need to do more per annum in the remaining period of the plan.
Because these calculations assume use of the 65/35% ration of market to affordable housing, the actual need for affordable housing is much less.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
709. Mr Duncan Pearce (Individual) : 10 Apr 2012 12:26:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.1 Development Boundaries- ARNSIDE
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
SLDC’s Core Strategy, and national planning policy, set out the criteria for Land Allocations within an AONB.
National policy as stated in the new NPPF is that land within an AONB has “the highest status of protection in relation to landscape and scenic beauty “(para 115).
SLDC’s core strategy restates many of these policies and principles.
Policies include the need to protect green spaces important to the natural environment of the AONB, and the requirement to maintain the open character of the settlements concerned. They set out the sequential approach to be adopted in the allocation of sites (previously used sites etc).
Sustainability (including economic sustainability) of the settlements concerned is also an important criteria.
One important provision in Planning Policy Statement 7 (PPS7) states
• “22. Major developments should not take place in these designated areas, except in exceptional circumstances.” A similar statement is included in para 116 of the new NPPF.
Land within an AONB is therefore subject to special criteria when considering the “presumption in favour of sustainable development”.
Because the barriers to development are set at a high level, the standards of proof are also very high that all alternatives have been thoroughly tested and exhausted before greenfield sites are allocated for development.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I support the Arnside Parish Plan Trust and the APC.
SPECIFIC CONCERNS AND OBJECTIONS OF ARNSIDE PARISH PLAN TRUST (APPT) AND ARNSIDE PARISH COUNCIL REGARDING SLDC’s CURRENT LAND ALLOCATIONS.
1. SUMMARY
Arnside Parish Plan Trust and Arnside Parish Council believe that SLDC has produced a Land Allocation plan which does not pass the main tests of soundness and which;
• is not consistent with the detailed policies set out in its Core Strategy designed to apply the duty of the Council to protect the special characteristics and historic landscape of the Arnside and Silverdale Area of Outstanding Natural Beauty. In particular, its land allocations for housing propose using exclusively greenfield sites and land rated currently as "Important Open Space" which will have an adverse impact on the AONB landscape and on Arnside's settlement character.
• fails to identify how specific local needs (for affordable rented social housing) will be delivered in practise, and who will deliver that need.
• does not reconcile effectively the “highest level of protection” given to land within an AONB, as expressed in the new version of the NPPF, with delivering the local needs which qualify as “exceptional circumstances”.
• has failed to explore sufficiently all potential alternatives and to apply the appropriate land use hierarchy. Instead it defaults to allocating greenfield sites and Important Open Spaces within the AONB which currently have “the highest level of protection” and are particularly valued by the local community and by the management of the AONB.
• fails to address the need to regenerate brownfield sites in the village to repair the environmental damage they are inflicting.
• has failed to win the support of the local community (550 signed petition against) and to respond to emerging local plans. Neither does it have the support of the management of the AONB, Arnside Parish Council, Arnside Parish Plan Trust and other bodies important to the management of the specially protected environment of the AONB.
• relies on a planning policy which is not sustainable because it sets too high a site threshold of 0.3ha which could prevent a more organic approach to land use which will impose less damage than the development of large sites.
• assumes that a planning policy of relying on commercial development to provide affordable housing through a 65/35 allocation ratio is viable, without providing any evidence that this policy is workable in today’s and foreseeable market conditions.
• assumes that this 65/35 ratio (which consumes three times the amount of land needed for affordable housing) can be justified in relation to “the highest level of protection” provided by the NPPF against inappropriate development of land within an AONB.
• is not sustainable. Instead, it will damage the rural, open character of the village and its attraction to residents and visitors alike in a sensitive location within the AONB. This will undermine the economy on which the local community depends for a viable future.
APPT and APC set out in more detail below the basis of its objections. The process for filing objections is complex and difficult for lay people to use with confidence. As this document has been prepared without the benefit of advice from a planning lawyer, we hope that all our points will still be considered even if not categorised correctly.
We also reserve the right to make further submissions, and to present emerging new information, at the Inspector’s hearing.
2. AMPLIFICATION
2.1. Overview
Our principal objections to the current Land Allocations for Arnside are that SLDC has not met the standards of evidence and proof required to justify the allocation of greenfield sites against the special protections afforded to such land by the national policies contained in the new version of the NPPF, and, as a result, neither has it gained the support of the local community. The Allocations are not sound in the context of the specific circumstances of Arnside.
Apart from one brownfield site allocated for employment purposes, all sites allocated for housing are greenfield sites, and two of these are currently designated “Important Open Spaces”. Land within an AONB has the highest level of protection under the NPPF and, within this AONB, these Important Open Spaces have, over a long time, been regarded by the community as having special value to the character and sustainability of Arnside.
We assert that SLDC has a special duty to apply to these sites the highest level of protection available. We further assert that they have not demonstrated to the standard required that there are no other viable alternatives within Arnside, or in surrounding areas, to meet specific local needs for affordable housing. Market housing does not fit the criteria of "need" in this context, especially as there are consistently over 70 dwellings available for sale in all price ranges in Arnside.
The Arnside community (through Arnside Parish Council and Arnside Parish Plan Trust) believe that there are viable alternatives which could be brought into play over the extended period covered by the Land Allocations process. Under the new Community Planning and Neighbourhood Planning regimes, SLDC should therefore take the opportunity to explore these alternatives more effectively with community representatives and to establish whether a better plan could be produced.
Because of the failure of SLDC to demonstrate that it has used its best endeavours to explore all reasonable alternatives, and because of a number of weaknesses in the evidence base used as set out in more detail below, we object to SLDC’s current Land Allocations because they fail the test of soundness on a number of points.
2.2. Housing needs in Arnside
We recognise and accept that more affordable housing is needed in Arnside. The most accurate survey currently available of need in the area (dated 2009) indicates that there is a short term need for 27 affordable homes in the village. It is clear that by far the main element of that need is for social rented housing. Longer term needs are still very unclear.
There is already an adequate supply of market housing with available stock being sustained at over 70 homes for sale of all types and price ranges, so there is no “exceptional need” to allocate land for market housing.
There is also a history within the village of affordable housing being built but failing to be maintained as part of the ongoing affordable housing stock because it has been traded on as holiday homes and general market housing. This needs to be avoided in future.
We understand that, within a confined area such as Arnside, it is difficult to find sites which balance the conflicting objectives of providing needed affordable housing while at the same time preserving the character of the settlement within the AONB to the “highest standards of protection” that SLDC, and we, are obliged to achieve.
We are concerned, however, that SLDC has produced a range of numbers to justify its Land Allocations. The attached Appendix illustrates the range of numbers cited in the plan. Under pressure from the local community, SLDC has reduced progressively the numbers allocated to the AONB in proportion to other areas within South Lakes District to try more effectively to minimise the adverse impact on the core characteristics of the AONB. We welcome the reduction in numbers and the attempts to address this challenge.
However, the fact that these numbers have only recently been further amended, and that they are based on proportional data drawn from the wider region rather than specific local needs, illustrates the lack of certainty and the weak evidence base for the need within Arnside.
This is important because precise allocations are required to deliver the right types of homes, and in order to avoid the allocation of inappropriate sites, and the unnecessary - and avoidable - destruction of highly valued greenfield space. We therefore believe that this element of the plan is unsound because the calculation of need requires further work to ensure the correct housing types are delivered, and to ensure that unnecessary damage to the character of the village within the AONB is avoided.
APPT and APC are keen to engage in further work with SLDC to establish a more accurate assessment of housing need within the village.
2.3. Inappropriate Land Allocations
Arnside contains currently brownfield - and other smaller sites - which SLDC has not listed in the Land Allocations. These sites could, and should, be developed both to supply affordable housing needs and to repair the detrimental affect on the character of the village caused by the derelict brownfield locations. It is argued by APPT/APC that these sites, if brought into use over the term of the Land Allocations Plan to 2025, could supply much of the specifically identified affordable housing needs of the Village.
The current SLDC Land Allocations, however, use exclusively greenfield sites, two of which are currently listed as Important Open Space, and as such are important to defining the open and rural character of the village within the AONB and maintaining its long term economic sustainability.
We believe that the current allocations fail the test of supporting the economic and environmental sustainability test for the reasons set out in detail in the emerging Village Plan for Arnside (http://www.arnside.gov.uk/Warehouse/ArnsideLookingForward4.pdf).
They are also the main concern of the 550+ signature petitions raised and submitted to SLDC during this process which stressed the need to protect these greenfields and Important Open Spaces. As a result, the current Allocations do not have the support of the Arnside community, and therefore they fail the soundness test for community engagement and support.
The current Allocations also fail to meet the sequential test for the use of brownfield sites etc before allocating greenfield sites. The allocation of greenfield sites currently designated as Important Open Space within an AONB is even further up the sequential hierarchy and therefore further from meeting the soundness test.
As stated above, there are a range of smaller infill and brownfield sites which would not have as adverse an environmental impact and which could be brought into use over the plan period, especially if SLDC applied some of its other powers, or to adjust some of its current planning policies (see below), or if it took a longer view of potential availability.
The current allocations therefore fail the “exceptional circumstances” and “highest level of protection” national policy soundness test for Land Allocations within an AONB. This is because the current documents fail to demonstrate that SLDC has used its best endeavours to find alternatives over the lifetime of this planning period, and because it has not adapted its planning policies to fit the special circumstances and “highest level of protection” applying within an AONB.
2.4. Specific concerns about the soundness of local policies.
We have concerns about some of the stated policies and planning assumptions applied by SLDC within this process. If valid, they would mean that SLDC’s plan would fail the soundness tests in several regards.
• SLDC has taken a policy decision not to include sites of less than 0.3 hectares in the current Land Allocations. As a consequence it has had to resort to allocating sensitive and controversial large greenfield sites. SLDC has admitted, however, that the smaller sites could well come into play during the plan period and they would probably get planning permission. Such sites could, however, supply a substantial part of the local need for social rented housing, especially if they were developed in small increments by a housing association or similar body. We understand that a smaller threshold of 0.1ha is being applied within the Lake District National Park. We believe therefore that the soundness test will not be met because SLDC has made this policy decision without opting for an alternative approach to allocate smaller sites which could be used in the context of the exceptional circumstance test and highest level of protection applying within an AONB. The community believe that the larger and very sensitive greenfield sites should be removed from the allocations until the smaller site potential has been exhausted.
• The Local Development Plan appears also to be critically dependent on the success of the assumption that the main local need – for social rented affordable housing – will be delivered through the policy of allocating sites to commercial developers, subject to them building a 35% ratio of affordable housing within development sites. Despite considerable pressing for evidence, SLDC has not provided any data to demonstrate that this policy is viable and will succeed in the current economy and in future commercial development markets.
This is particularly important in view of major changes to financial and housing markets since 2008. SLDC needs to prove that commercial developers will be able to overcome the additional financial burden placed on these sites to pay for affordable housing and for such elements as the Community Infrastructure Levy. This has to be done against a background of a difficult credit market, very low housing turnover volumes, and falling house prices. All this in an area where the planning portfolio holder hopes and believes that this land allocation policy will reduce the price of market housing by 20%, thus increasing the pressure on the development funding model.
We have evidence locally that builders are unable to raise finance for site development and the above burdens will only aggravate these problems.
Because this is such a critical and fundamental assumption underlying the whole of SLDC’s Land Allocations, and because the future supply of affordable housing appears to depend entirely on it operating effectively, it is essential that robust and “bankable” evidence is provided by SLDC. Without it, the current Land Allocations cannot pass the deliverability test for the supply of local affordable housing and is therefore not sound.
• The 65/35 development ratio also has one further major weakness; it requires three times the amount of land which would be needed if only the local need for affordable housing is covered. This cannot be said to be meeting the test of “highest level of protection” or “exceptional circumstances” and is not sound because it does not comply with National Policy as expressed in the new version of the NPPF.
• It is much more likely that an appropriate body needs to be found which will focus specifically on building social rented housing without needing to rely on subsidies from a premium placed on commercial developments of market housing. The SLDC documents do not deal adequately with this issue and are therefore unsound because they fail to provide sufficient evidence that the Land Allocations and associated policies will deliver the specific local need for social rented housing.
• SLDC also appears to be driven by fear of the consequences of the new NPPF and their perception that developers will have unfettered access to land if sites are not allocated in a controlled process such as these Land Allocations. This is, it says, because of the “presumption in favour of development”.
We do not believe this to be true within an AONB because of the obligation to apply the “highest level of protection”, and inappropriate land allocations can continue to be resisted. There is therefore no need to rush this process. The current land allocations for Arnside should therefore be referred back for further work with the community to produce a more appropriate plan.
• SLDC appears to be over-relying on the very short term application of the “Deliverability” criteria within the Development Framework. In practise, this has led it to rely on sites where there is a clear immediate intention of the owner to make the site available for development and to capitalise on a commercial opportunity. If that commitment has not been made to date, potentially useful and less sensitive sites have been excluded, even if there is a reasonable chance that they will come into play over the longer term. The consequence of this is that derelict and previously used sites, which should be improved as part of any sensible spatial plan for any community, have been ignored. The knock-on consequence is that greenfield sites could be destroyed while derelict sites remain unused. This is not a sensible planning policy and fails even the commonsense soundness test.
• It is clear that it will take some time to bring into play some of the smaller and brownfield sites within the village but it is argued that the exceptional circumstances of the village within the AONB justify the extra effort (or time delay) that may be required. SLDC has failed to use their best endeavours to apply this extra effort by (for example) using the powers they have to bring derelict sites into use (such as Compulsory Purchase Orders). APPT are keen to work with SLDC to produce a Plan which achieves these objectives but, so far, SLDC has failed this test of soundness in meeting the exceptional circumstances criteria required within an AONB. The new Community planning regime under the Localism Act provides the opportunity to put this right by SLDC working closely with the community. The current land allocations should be deferred until this process has been completed. APPT/APC have an early draft of a community plan already in progress (http://www.arnside.gov.uk/Warehouse/ArnsideLookingForward4.pdf) and are keen to engage SLDC 's support in moving to a complete and workable version.
• We understand that the management of the Arnside & Silverdale Area of Outstanding Natural Beauty have similar and additional objections to the soundness of these Allocations. Arnside Parish Council, through Arnside Parish Plan Trust, intend to coordinate their emerging plans with this and other stakeholders for this area.
• We also understand that Lancaster City Council has a more appropriate treatment of land within the AONB in its Land Allocations policies but that SLDC has not yet coordinated its approach effectively with LCC. There may be solutions to local housing needs which could be accommodated within the neighbouring territories of LCC. SLDC will therefore fail to meet the soundness test until this process has been completed.
• Because of the above, the current Land Allocations should be referred back for revision. This revision would benefit from input from the emerging Arnside Community and Neighbourhood Plans which will address these issues.
Appendix 1
Land Allocation Development Plan Document – Calculation of Housing Need within the AONB*
There are 4 calculations of potential housing needs contained in the document for the AONB part of SLDC
CALCULATION 1
This is based on the AONB population as a % of the total Local Development Framework (LDF) area population
LDF Population 75000
AONB population 5% 3800 (Arnside 2300 and Beetham 1500)
Based on total district housing target of 400 per annum then 5% of this is 20 per annum for the AONB (12 for Arnside and 8 for Beetham)
Over the period 2003-2025 the total for the AONB is 460 (276 for Arnside and 184 for Beetham)
CALCULATION 2
This is based on the 2009 Strategic Market Assessment for Rural South Kendal. The figures for Annual Affordable Housing Requirements (See Page 63) for the period 2009-2015 were based on the 2006 Housing Needs Survey and indicates respondents aspirations.
Rural South Kendal Total 1105
AONB population 15.7% 173
(Arnside 104 and Beetham 69 based on population split shown in calculation 1)
If the above figures were projected at the same level for the whole of the plan 2009-2025 then this gives a total affordable housing need of 555 (333 for Arnside and 222 for Beetham based on population split shown in calculation 1)
CALCULATION 3
This is based on the 2011 Strategic Market Assessment for Rural South Kendal not including Milnthorpe and Kirkby Lonsdale. Again the survey appears to be aspirational. The response rate for Rural South Kendal was 30%. The calculations for the affordable housing market for 2011-2016 were based on:
• Households currently in housing which is unsuitable for their use and who are unable to afford to buy or rent in the market (backlog need)
• New household forming who cannot afford to buy or rent in the market
• Existing households expected to fall into need
• The supply of affordable housing through social renting and intermediate tenure stock
This calculation is similar to number 2
Rural South Kendal Total 435
AONB population 18.54% 225
(Arnside 133 and Beetham 89) based on population split shown in calculation 1)
CALCULATION 4
This is based on Arnside 2009 Housing Needs Survey and 2007 Beetham Housing Needs Survey to determine the need for affordable housing. This survey applied to social rented housing only and represented respondents aspirations and does not necessarily represent actual take up of affordable homes if they were offered. See Appendix Below: Analysis & Critical Review of Housing Needs
2009-14 Arnside 27 ? therefore projected number for 2009-2025 is 86
2007-12 Beetham* 17 ? therefore projected number for 2009-2025 is 61
But in order to deliver the affordable element an allowance for market housing has to be given. If affordable housing is delivered at 35% of market schemes this would bring the total need for 2009-2025 to 420 (Arnside 252 and Beetham 168)
*in the AONB part of Beetham
SUMMARY
Reference in Land Allocation Document Arnside Beetham Total Comments
3.79 Calculation 1 Total need 2003-2025 276 184 460 AONB population as a % of Local Development Area population
3.80 Calculation 2 Affordable need 2009-2025 333 222 555 AONB as a % of Rural South Kendal from an aspirational survey
3.81 Calculation 3 Affordable need 2009-2025 135 90 225 AONB as a % of Rural South Kendal LESS Milnthorpe and Kirkby Lonsdale from an aspirational survey
3.87 Calculation 4 Affordable need 2009-2025
Calculation 4 but also market allowance to achieve this 2009-2025 86
252 61
168 147
420 Arnside and Beetham aspirations for affordable housing
Market allowance figures are unrealistic because unlikely this scenario will happen
From the above 4 calculations it was concluded that the total housing need over the plan period was somewhere between 200 and 400 but because of the low housing delivery since 2003 to the present there was a need to do more per annum in the remaining period of the plan.
Because these calculations assume use of the 65/35% ration of market to affordable housing, the actual need for affordable housing is much less.
pport the Arnside Parish Plan Trust and the APC.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
710. Mr Duncan Pearce (Individual) : 8 May 2012 15:55:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - All Arnside sites
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
SLDC’s Core Strategy, and national planning policy, set out the criteria for Land Allocations within an AONB.
National policy as stated in the new NPPF is that land within an AONB has “the highest status of protection in relation to landscape and scenic beauty “(para 115).
SLDC’s core strategy restates many of these policies and principles.
Policies include the need to protect green spaces important to the natural environment of the AONB, and the requirement to maintain the open character of the settlements concerned. They set out the sequential approach to be adopted in the allocation of sites (previously used sites etc).
Sustainability (including economic sustainability) of the settlements concerned is also an important criteria.
One important provision in Planning Policy Statement 7 (PPS7) states
• “22. Major developments should not take place in these designated areas, except in exceptional circumstances.” A similar statement is included in para 116 of the new NPPF.
Land within an AONB is therefore subject to special criteria when considering the “presumption in favour of sustainable development”.
Because the barriers to development are set at a high level, the standards of proof are also very high that all alternatives have been thoroughly tested and exhausted before greenfield sites are allocated for development.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I support the Arnside Parish Plan Trust and the APC.
SPECIFIC CONCERNS AND OBJECTIONS OF ARNSIDE PARISH PLAN TRUST (APPT) AND ARNSIDE PARISH COUNCIL REGARDING SLDC’s CURRENT LAND ALLOCATIONS.
1. SUMMARY
Arnside Parish Plan Trust and Arnside Parish Council believe that SLDC has produced a Land Allocation plan which does not pass the main tests of soundness and which;
• is not consistent with the detailed policies set out in its Core Strategy designed to apply the duty of the Council to protect the special characteristics and historic landscape of the Arnside and Silverdale Area of Outstanding Natural Beauty. In particular, its land allocations for housing propose using exclusively greenfield sites and land rated currently as "Important Open Space" which will have an adverse impact on the AONB landscape and on Arnside's settlement character.
• fails to identify how specific local needs (for affordable rented social housing) will be delivered in practise, and who will deliver that need.
• does not reconcile effectively the “highest level of protection” given to land within an AONB, as expressed in the new version of the NPPF, with delivering the local needs which qualify as “exceptional circumstances”.
• has failed to explore sufficiently all potential alternatives and to apply the appropriate land use hierarchy. Instead it defaults to allocating greenfield sites and Important Open Spaces within the AONB which currently have “the highest level of protection” and are particularly valued by the local community and by the management of the AONB.
• fails to address the need to regenerate brownfield sites in the village to repair the environmental damage they are inflicting.
• has failed to win the support of the local community (550 signed petition against) and to respond to emerging local plans. Neither does it have the support of the management of the AONB, Arnside Parish Council, Arnside Parish Plan Trust and other bodies important to the management of the specially protected environment of the AONB.
• relies on a planning policy which is not sustainable because it sets too high a site threshold of 0.3ha which could prevent a more organic approach to land use which will impose less damage than the development of large sites.
• assumes that a planning policy of relying on commercial development to provide affordable housing through a 65/35 allocation ratio is viable, without providing any evidence that this policy is workable in today’s and foreseeable market conditions.
• assumes that this 65/35 ratio (which consumes three times the amount of land needed for affordable housing) can be justified in relation to “the highest level of protection” provided by the NPPF against inappropriate development of land within an AONB.
• is not sustainable. Instead, it will damage the rural, open character of the village and its attraction to residents and visitors alike in a sensitive location within the AONB. This will undermine the economy on which the local community depends for a viable future.
APPT and APC set out in more detail below the basis of its objections. The process for filing objections is complex and difficult for lay people to use with confidence. As this document has been prepared without the benefit of advice from a planning lawyer, we hope that all our points will still be considered even if not categorised correctly.
We also reserve the right to make further submissions, and to present emerging new information, at the Inspector’s hearing.
2. AMPLIFICATION
2.1. Overview
Our principal objections to the current Land Allocations for Arnside are that SLDC has not met the standards of evidence and proof required to justify the allocation of greenfield sites against the special protections afforded to such land by the national policies contained in the new version of the NPPF, and, as a result, neither has it gained the support of the local community. The Allocations are not sound in the context of the specific circumstances of Arnside.
Apart from one brownfield site allocated for employment purposes, all sites allocated for housing are greenfield sites, and two of these are currently designated “Important Open Spaces”. Land within an AONB has the highest level of protection under the NPPF and, within this AONB, these Important Open Spaces have, over a long time, been regarded by the community as having special value to the character and sustainability of Arnside.
We assert that SLDC has a special duty to apply to these sites the highest level of protection available. We further assert that they have not demonstrated to the standard required that there are no other viable alternatives within Arnside, or in surrounding areas, to meet specific local needs for affordable housing. Market housing does not fit the criteria of "need" in this context, especially as there are consistently over 70 dwellings available for sale in all price ranges in Arnside.
The Arnside community (through Arnside Parish Council and Arnside Parish Plan Trust) believe that there are viable alternatives which could be brought into play over the extended period covered by the Land Allocations process. Under the new Community Planning and Neighbourhood Planning regimes, SLDC should therefore take the opportunity to explore these alternatives more effectively with community representatives and to establish whether a better plan could be produced.
Because of the failure of SLDC to demonstrate that it has used its best endeavours to explore all reasonable alternatives, and because of a number of weaknesses in the evidence base used as set out in more detail below, we object to SLDC’s current Land Allocations because they fail the test of soundness on a number of points.
2.2. Housing needs in Arnside
We recognise and accept that more affordable housing is needed in Arnside. The most accurate survey currently available of need in the area (dated 2009) indicates that there is a short term need for 27 affordable homes in the village. It is clear that by far the main element of that need is for social rented housing. Longer term needs are still very unclear.
There is already an adequate supply of market housing with available stock being sustained at over 70 homes for sale of all types and price ranges, so there is no “exceptional need” to allocate land for market housing.
There is also a history within the village of affordable housing being built but failing to be maintained as part of the ongoing affordable housing stock because it has been traded on as holiday homes and general market housing. This needs to be avoided in future.
We understand that, within a confined area such as Arnside, it is difficult to find sites which balance the conflicting objectives of providing needed affordable housing while at the same time preserving the character of the settlement within the AONB to the “highest standards of protection” that SLDC, and we, are obliged to achieve.
We are concerned, however, that SLDC has produced a range of numbers to justify its Land Allocations. The attached Appendix illustrates the range of numbers cited in the plan. Under pressure from the local community, SLDC has reduced progressively the numbers allocated to the AONB in proportion to other areas within South Lakes District to try more effectively to minimise the adverse impact on the core characteristics of the AONB. We welcome the reduction in numbers and the attempts to address this challenge.
However, the fact that these numbers have only recently been further amended, and that they are based on proportional data drawn from the wider region rather than specific local needs, illustrates the lack of certainty and the weak evidence base for the need within Arnside.
This is important because precise allocations are required to deliver the right types of homes, and in order to avoid the allocation of inappropriate sites, and the unnecessary - and avoidable - destruction of highly valued greenfield space. We therefore believe that this element of the plan is unsound because the calculation of need requires further work to ensure the correct housing types are delivered, and to ensure that unnecessary damage to the character of the village within the AONB is avoided.
APPT and APC are keen to engage in further work with SLDC to establish a more accurate assessment of housing need within the village.
2.3. Inappropriate Land Allocations
Arnside contains currently brownfield - and other smaller sites - which SLDC has not listed in the Land Allocations. These sites could, and should, be developed both to supply affordable housing needs and to repair the detrimental affect on the character of the village caused by the derelict brownfield locations. It is argued by APPT/APC that these sites, if brought into use over the term of the Land Allocations Plan to 2025, could supply much of the specifically identified affordable housing needs of the Village.
The current SLDC Land Allocations, however, use exclusively greenfield sites, two of which are currently listed as Important Open Space, and as such are important to defining the open and rural character of the village within the AONB and maintaining its long term economic sustainability.
We believe that the current allocations fail the test of supporting the economic and environmental sustainability test for the reasons set out in detail in the emerging Village Plan for Arnside (http://www.arnside.gov.uk/Warehouse/ArnsideLookingForward4.pdf).
They are also the main concern of the 550+ signature petitions raised and submitted to SLDC during this process which stressed the need to protect these greenfields and Important Open Spaces. As a result, the current Allocations do not have the support of the Arnside community, and therefore they fail the soundness test for community engagement and support.
The current Allocations also fail to meet the sequential test for the use of brownfield sites etc before allocating greenfield sites. The allocation of greenfield sites currently designated as Important Open Space within an AONB is even further up the sequential hierarchy and therefore further from meeting the soundness test.
As stated above, there are a range of smaller infill and brownfield sites which would not have as adverse an environmental impact and which could be brought into use over the plan period, especially if SLDC applied some of its other powers, or to adjust some of its current planning policies (see below), or if it took a longer view of potential availability.
The current allocations therefore fail the “exceptional circumstances” and “highest level of protection” national policy soundness test for Land Allocations within an AONB. This is because the current documents fail to demonstrate that SLDC has used its best endeavours to find alternatives over the lifetime of this planning period, and because it has not adapted its planning policies to fit the special circumstances and “highest level of protection” applying within an AONB.
2.4. Specific concerns about the soundness of local policies.
We have concerns about some of the stated policies and planning assumptions applied by SLDC within this process. If valid, they would mean that SLDC’s plan would fail the soundness tests in several regards.
• SLDC has taken a policy decision not to include sites of less than 0.3 hectares in the current Land Allocations. As a consequence it has had to resort to allocating sensitive and controversial large greenfield sites. SLDC has admitted, however, that the smaller sites could well come into play during the plan period and they would probably get planning permission. Such sites could, however, supply a substantial part of the local need for social rented housing, especially if they were developed in small increments by a housing association or similar body. We understand that a smaller threshold of 0.1ha is being applied within the Lake District National Park. We believe therefore that the soundness test will not be met because SLDC has made this policy decision without opting for an alternative approach to allocate smaller sites which could be used in the context of the exceptional circumstance test and highest level of protection applying within an AONB. The community believe that the larger and very sensitive greenfield sites should be removed from the allocations until the smaller site potential has been exhausted.
• The Local Development Plan appears also to be critically dependent on the success of the assumption that the main local need – for social rented affordable housing – will be delivered through the policy of allocating sites to commercial developers, subject to them building a 35% ratio of affordable housing within development sites. Despite considerable pressing for evidence, SLDC has not provided any data to demonstrate that this policy is viable and will succeed in the current economy and in future commercial development markets.
This is particularly important in view of major changes to financial and housing markets since 2008. SLDC needs to prove that commercial developers will be able to overcome the additional financial burden placed on these sites to pay for affordable housing and for such elements as the Community Infrastructure Levy. This has to be done against a background of a difficult credit market, very low housing turnover volumes, and falling house prices. All this in an area where the planning portfolio holder hopes and believes that this land allocation policy will reduce the price of market housing by 20%, thus increasing the pressure on the development funding model.
We have evidence locally that builders are unable to raise finance for site development and the above burdens will only aggravate these problems.
Because this is such a critical and fundamental assumption underlying the whole of SLDC’s Land Allocations, and because the future supply of affordable housing appears to depend entirely on it operating effectively, it is essential that robust and “bankable” evidence is provided by SLDC. Without it, the current Land Allocations cannot pass the deliverability test for the supply of local affordable housing and is therefore not sound.
• The 65/35 development ratio also has one further major weakness; it requires three times the amount of land which would be needed if only the local need for affordable housing is covered. This cannot be said to be meeting the test of “highest level of protection” or “exceptional circumstances” and is not sound because it does not comply with National Policy as expressed in the new version of the NPPF.
• It is much more likely that an appropriate body needs to be found which will focus specifically on building social rented housing without needing to rely on subsidies from a premium placed on commercial developments of market housing. The SLDC documents do not deal adequately with this issue and are therefore unsound because they fail to provide sufficient evidence that the Land Allocations and associated policies will deliver the specific local need for social rented housing.
• SLDC also appears to be driven by fear of the consequences of the new NPPF and their perception that developers will have unfettered access to land if sites are not allocated in a controlled process such as these Land Allocations. This is, it says, because of the “presumption in favour of development”.
We do not believe this to be true within an AONB because of the obligation to apply the “highest level of protection”, and inappropriate land allocations can continue to be resisted. There is therefore no need to rush this process. The current land allocations for Arnside should therefore be referred back for further work with the community to produce a more appropriate plan.
• SLDC appears to be over-relying on the very short term application of the “Deliverability” criteria within the Development Framework. In practise, this has led it to rely on sites where there is a clear immediate intention of the owner to make the site available for development and to capitalise on a commercial opportunity. If that commitment has not been made to date, potentially useful and less sensitive sites have been excluded, even if there is a reasonable chance that they will come into play over the longer term. The consequence of this is that derelict and previously used sites, which should be improved as part of any sensible spatial plan for any community, have been ignored. The knock-on consequence is that greenfield sites could be destroyed while derelict sites remain unused. This is not a sensible planning policy and fails even the commonsense soundness test.
• It is clear that it will take some time to bring into play some of the smaller and brownfield sites within the village but it is argued that the exceptional circumstances of the village within the AONB justify the extra effort (or time delay) that may be required. SLDC has failed to use their best endeavours to apply this extra effort by (for example) using the powers they have to bring derelict sites into use (such as Compulsory Purchase Orders). APPT are keen to work with SLDC to produce a Plan which achieves these objectives but, so far, SLDC has failed this test of soundness in meeting the exceptional circumstances criteria required within an AONB. The new Community planning regime under the Localism Act provides the opportunity to put this right by SLDC working closely with the community. The current land allocations should be deferred until this process has been completed. APPT/APC have an early draft of a community plan already in progress (http://www.arnside.gov.uk/Warehouse/ArnsideLookingForward4.pdf) and are keen to engage SLDC 's support in moving to a complete and workable version.
• We understand that the management of the Arnside & Silverdale Area of Outstanding Natural Beauty have similar and additional objections to the soundness of these Allocations. Arnside Parish Council, through Arnside Parish Plan Trust, intend to coordinate their emerging plans with this and other stakeholders for this area.
• We also understand that Lancaster City Council has a more appropriate treatment of land within the AONB in its Land Allocations policies but that SLDC has not yet coordinated its approach effectively with LCC. There may be solutions to local housing needs which could be accommodated within the neighbouring territories of LCC. SLDC will therefore fail to meet the soundness test until this process has been completed.
• Because of the above, the current Land Allocations should be referred back for revision. This revision would benefit from input from the emerging Arnside Community and Neighbourhood Plans which will address these issues.
Appendix 1
Land Allocation Development Plan Document – Calculation of Housing Need within the AONB*
There are 4 calculations of potential housing needs contained in the document for the AONB part of SLDC
CALCULATION 1
This is based on the AONB population as a % of the total Local Development Framework (LDF) area population
LDF Population 75000
AONB population 5% 3800 (Arnside 2300 and Beetham 1500)
Based on total district housing target of 400 per annum then 5% of this is 20 per annum for the AONB (12 for Arnside and 8 for Beetham)
Over the period 2003-2025 the total for the AONB is 460 (276 for Arnside and 184 for Beetham)
CALCULATION 2
This is based on the 2009 Strategic Market Assessment for Rural South Kendal. The figures for Annual Affordable Housing Requirements (See Page 63) for the period 2009-2015 were based on the 2006 Housing Needs Survey and indicates respondents aspirations.
Rural South Kendal Total 1105
AONB population 15.7% 173
(Arnside 104 and Beetham 69 based on population split shown in calculation 1)
If the above figures were projected at the same level for the whole of the plan 2009-2025 then this gives a total affordable housing need of 555 (333 for Arnside and 222 for Beetham based on population split shown in calculation 1)
CALCULATION 3
This is based on the 2011 Strategic Market Assessment for Rural South Kendal not including Milnthorpe and Kirkby Lonsdale. Again the survey appears to be aspirational. The response rate for Rural South Kendal was 30%. The calculations for the affordable housing market for 2011-2016 were based on:
• Households currently in housing which is unsuitable for their use and who are unable to afford to buy or rent in the market (backlog need)
• New household forming who cannot afford to buy or rent in the market
• Existing households expected to fall into need
• The supply of affordable housing through social renting and intermediate tenure stock
This calculation is similar to number 2
Rural South Kendal Total 435
AONB population 18.54% 225
(Arnside 133 and Beetham 89) based on population split shown in calculation 1)
CALCULATION 4
This is based on Arnside 2009 Housing Needs Survey and 2007 Beetham Housing Needs Survey to determine the need for affordable housing. This survey applied to social rented housing only and represented respondents aspirations and does not necessarily represent actual take up of affordable homes if they were offered. See Appendix Below: Analysis & Critical Review of Housing Needs
2009-14 Arnside 27 ? therefore projected number for 2009-2025 is 86
2007-12 Beetham* 17 ? therefore projected number for 2009-2025 is 61
But in order to deliver the affordable element an allowance for market housing has to be given. If affordable housing is delivered at 35% of market schemes this would bring the total need for 2009-2025 to 420 (Arnside 252 and Beetham 168)
*in the AONB part of Beetham
SUMMARY
Reference in Land Allocation Document Arnside Beetham Total Comments
3.79 Calculation 1 Total need 2003-2025 276 184 460 AONB population as a % of Local Development Area population
3.80 Calculation 2 Affordable need 2009-2025 333 222 555 AONB as a % of Rural South Kendal from an aspirational survey
3.81 Calculation 3 Affordable need 2009-2025 135 90 225 AONB as a % of Rural South Kendal LESS Milnthorpe and Kirkby Lonsdale from an aspirational survey
3.87 Calculation 4 Affordable need 2009-2025
Calculation 4 but also market allowance to achieve this 2009-2025 86
252 61
168 147
420 Arnside and Beetham aspirations for affordable housing
Market allowance figures are unrealistic because unlikely this scenario will happen
From the above 4 calculations it was concluded that the total housing need over the plan period was somewhere between 200 and 400 but because of the low housing delivery since 2003 to the present there was a need to do more per annum in the remaining period of the plan.
Because these calculations assume use of the 65/35% ration of market to affordable housing, the actual need for affordable housing is much less.
pport the Arnside Parish Plan Trust and the APC.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
711. Mr Duncan Pearce (Individual) : 8 May 2012 15:57:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA2.12 Mixed Use Allocation at Sandside Road, Arnside
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
SLDC’s Core Strategy, and national planning policy, set out the criteria for Land Allocations within an AONB.
National policy as stated in the new NPPF is that land within an AONB has “the highest status of protection in relation to landscape and scenic beauty “(para 115).
SLDC’s core strategy restates many of these policies and principles.
Policies include the need to protect green spaces important to the natural environment of the AONB, and the requirement to maintain the open character of the settlements concerned. They set out the sequential approach to be adopted in the allocation of sites (previously used sites etc).
Sustainability (including economic sustainability) of the settlements concerned is also an important criteria.
One important provision in Planning Policy Statement 7 (PPS7) states
• “22. Major developments should not take place in these designated areas, except in exceptional circumstances.” A similar statement is included in para 116 of the new NPPF.
Land within an AONB is therefore subject to special criteria when considering the “presumption in favour of sustainable development”.
Because the barriers to development are set at a high level, the standards of proof are also very high that all alternatives have been thoroughly tested and exhausted before greenfield sites are allocated for development.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I support the Arnside Parish Plan Trust and the APC.
SPECIFIC CONCERNS AND OBJECTIONS OF ARNSIDE PARISH PLAN TRUST (APPT) AND ARNSIDE PARISH COUNCIL REGARDING SLDC’s CURRENT LAND ALLOCATIONS.
1. SUMMARY
Arnside Parish Plan Trust and Arnside Parish Council believe that SLDC has produced a Land Allocation plan which does not pass the main tests of soundness and which;
• is not consistent with the detailed policies set out in its Core Strategy designed to apply the duty of the Council to protect the special characteristics and historic landscape of the Arnside and Silverdale Area of Outstanding Natural Beauty. In particular, its land allocations for housing propose using exclusively greenfield sites and land rated currently as "Important Open Space" which will have an adverse impact on the AONB landscape and on Arnside's settlement character.
• fails to identify how specific local needs (for affordable rented social housing) will be delivered in practise, and who will deliver that need.
• does not reconcile effectively the “highest level of protection” given to land within an AONB, as expressed in the new version of the NPPF, with delivering the local needs which qualify as “exceptional circumstances”.
• has failed to explore sufficiently all potential alternatives and to apply the appropriate land use hierarchy. Instead it defaults to allocating greenfield sites and Important Open Spaces within the AONB which currently have “the highest level of protection” and are particularly valued by the local community and by the management of the AONB.
• fails to address the need to regenerate brownfield sites in the village to repair the environmental damage they are inflicting.
• has failed to win the support of the local community (550 signed petition against) and to respond to emerging local plans. Neither does it have the support of the management of the AONB, Arnside Parish Council, Arnside Parish Plan Trust and other bodies important to the management of the specially protected environment of the AONB.
• relies on a planning policy which is not sustainable because it sets too high a site threshold of 0.3ha which could prevent a more organic approach to land use which will impose less damage than the development of large sites.
• assumes that a planning policy of relying on commercial development to provide affordable housing through a 65/35 allocation ratio is viable, without providing any evidence that this policy is workable in today’s and foreseeable market conditions.
• assumes that this 65/35 ratio (which consumes three times the amount of land needed for affordable housing) can be justified in relation to “the highest level of protection” provided by the NPPF against inappropriate development of land within an AONB.
• is not sustainable. Instead, it will damage the rural, open character of the village and its attraction to residents and visitors alike in a sensitive location within the AONB. This will undermine the economy on which the local community depends for a viable future.
APPT and APC set out in more detail below the basis of its objections. The process for filing objections is complex and difficult for lay people to use with confidence. As this document has been prepared without the benefit of advice from a planning lawyer, we hope that all our points will still be considered even if not categorised correctly.
We also reserve the right to make further submissions, and to present emerging new information, at the Inspector’s hearing.
2. AMPLIFICATION
2.1. Overview
Our principal objections to the current Land Allocations for Arnside are that SLDC has not met the standards of evidence and proof required to justify the allocation of greenfield sites against the special protections afforded to such land by the national policies contained in the new version of the NPPF, and, as a result, neither has it gained the support of the local community. The Allocations are not sound in the context of the specific circumstances of Arnside.
Apart from one brownfield site allocated for employment purposes, all sites allocated for housing are greenfield sites, and two of these are currently designated “Important Open Spaces”. Land within an AONB has the highest level of protection under the NPPF and, within this AONB, these Important Open Spaces have, over a long time, been regarded by the community as having special value to the character and sustainability of Arnside.
We assert that SLDC has a special duty to apply to these sites the highest level of protection available. We further assert that they have not demonstrated to the standard required that there are no other viable alternatives within Arnside, or in surrounding areas, to meet specific local needs for affordable housing. Market housing does not fit the criteria of "need" in this context, especially as there are consistently over 70 dwellings available for sale in all price ranges in Arnside.
The Arnside community (through Arnside Parish Council and Arnside Parish Plan Trust) believe that there are viable alternatives which could be brought into play over the extended period covered by the Land Allocations process. Under the new Community Planning and Neighbourhood Planning regimes, SLDC should therefore take the opportunity to explore these alternatives more effectively with community representatives and to establish whether a better plan could be produced.
Because of the failure of SLDC to demonstrate that it has used its best endeavours to explore all reasonable alternatives, and because of a number of weaknesses in the evidence base used as set out in more detail below, we object to SLDC’s current Land Allocations because they fail the test of soundness on a number of points.
2.2. Housing needs in Arnside
We recognise and accept that more affordable housing is needed in Arnside. The most accurate survey currently available of need in the area (dated 2009) indicates that there is a short term need for 27 affordable homes in the village. It is clear that by far the main element of that need is for social rented housing. Longer term needs are still very unclear.
There is already an adequate supply of market housing with available stock being sustained at over 70 homes for sale of all types and price ranges, so there is no “exceptional need” to allocate land for market housing.
There is also a history within the village of affordable housing being built but failing to be maintained as part of the ongoing affordable housing stock because it has been traded on as holiday homes and general market housing. This needs to be avoided in future.
We understand that, within a confined area such as Arnside, it is difficult to find sites which balance the conflicting objectives of providing needed affordable housing while at the same time preserving the character of the settlement within the AONB to the “highest standards of protection” that SLDC, and we, are obliged to achieve.
We are concerned, however, that SLDC has produced a range of numbers to justify its Land Allocations. The attached Appendix illustrates the range of numbers cited in the plan. Under pressure from the local community, SLDC has reduced progressively the numbers allocated to the AONB in proportion to other areas within South Lakes District to try more effectively to minimise the adverse impact on the core characteristics of the AONB. We welcome the reduction in numbers and the attempts to address this challenge.
However, the fact that these numbers have only recently been further amended, and that they are based on proportional data drawn from the wider region rather than specific local needs, illustrates the lack of certainty and the weak evidence base for the need within Arnside.
This is important because precise allocations are required to deliver the right types of homes, and in order to avoid the allocation of inappropriate sites, and the unnecessary - and avoidable - destruction of highly valued greenfield space. We therefore believe that this element of the plan is unsound because the calculation of need requires further work to ensure the correct housing types are delivered, and to ensure that unnecessary damage to the character of the village within the AONB is avoided.
APPT and APC are keen to engage in further work with SLDC to establish a more accurate assessment of housing need within the village.
2.3. Inappropriate Land Allocations
Arnside contains currently brownfield - and other smaller sites - which SLDC has not listed in the Land Allocations. These sites could, and should, be developed both to supply affordable housing needs and to repair the detrimental affect on the character of the village caused by the derelict brownfield locations. It is argued by APPT/APC that these sites, if brought into use over the term of the Land Allocations Plan to 2025, could supply much of the specifically identified affordable housing needs of the Village.
The current SLDC Land Allocations, however, use exclusively greenfield sites, two of which are currently listed as Important Open Space, and as such are important to defining the open and rural character of the village within the AONB and maintaining its long term economic sustainability.
We believe that the current allocations fail the test of supporting the economic and environmental sustainability test for the reasons set out in detail in the emerging Village Plan for Arnside (http://www.arnside.gov.uk/Warehouse/ArnsideLookingForward4.pdf).
They are also the main concern of the 550+ signature petitions raised and submitted to SLDC during this process which stressed the need to protect these greenfields and Important Open Spaces. As a result, the current Allocations do not have the support of the Arnside community, and therefore they fail the soundness test for community engagement and support.
The current Allocations also fail to meet the sequential test for the use of brownfield sites etc before allocating greenfield sites. The allocation of greenfield sites currently designated as Important Open Space within an AONB is even further up the sequential hierarchy and therefore further from meeting the soundness test.
As stated above, there are a range of smaller infill and brownfield sites which would not have as adverse an environmental impact and which could be brought into use over the plan period, especially if SLDC applied some of its other powers, or to adjust some of its current planning policies (see below), or if it took a longer view of potential availability.
The current allocations therefore fail the “exceptional circumstances” and “highest level of protection” national policy soundness test for Land Allocations within an AONB. This is because the current documents fail to demonstrate that SLDC has used its best endeavours to find alternatives over the lifetime of this planning period, and because it has not adapted its planning policies to fit the special circumstances and “highest level of protection” applying within an AONB.
2.4. Specific concerns about the soundness of local policies.
We have concerns about some of the stated policies and planning assumptions applied by SLDC within this process. If valid, they would mean that SLDC’s plan would fail the soundness tests in several regards.
• SLDC has taken a policy decision not to include sites of less than 0.3 hectares in the current Land Allocations. As a consequence it has had to resort to allocating sensitive and controversial large greenfield sites. SLDC has admitted, however, that the smaller sites could well come into play during the plan period and they would probably get planning permission. Such sites could, however, supply a substantial part of the local need for social rented housing, especially if they were developed in small increments by a housing association or similar body. We understand that a smaller threshold of 0.1ha is being applied within the Lake District National Park. We believe therefore that the soundness test will not be met because SLDC has made this policy decision without opting for an alternative approach to allocate smaller sites which could be used in the context of the exceptional circumstance test and highest level of protection applying within an AONB. The community believe that the larger and very sensitive greenfield sites should be removed from the allocations until the smaller site potential has been exhausted.
• The Local Development Plan appears also to be critically dependent on the success of the assumption that the main local need – for social rented affordable housing – will be delivered through the policy of allocating sites to commercial developers, subject to them building a 35% ratio of affordable housing within development sites. Despite considerable pressing for evidence, SLDC has not provided any data to demonstrate that this policy is viable and will succeed in the current economy and in future commercial development markets.
This is particularly important in view of major changes to financial and housing markets since 2008. SLDC needs to prove that commercial developers will be able to overcome the additional financial burden placed on these sites to pay for affordable housing and for such elements as the Community Infrastructure Levy. This has to be done against a background of a difficult credit market, very low housing turnover volumes, and falling house prices. All this in an area where the planning portfolio holder hopes and believes that this land allocation policy will reduce the price of market housing by 20%, thus increasing the pressure on the development funding model.
We have evidence locally that builders are unable to raise finance for site development and the above burdens will only aggravate these problems.
Because this is such a critical and fundamental assumption underlying the whole of SLDC’s Land Allocations, and because the future supply of affordable housing appears to depend entirely on it operating effectively, it is essential that robust and “bankable” evidence is provided by SLDC. Without it, the current Land Allocations cannot pass the deliverability test for the supply of local affordable housing and is therefore not sound.
• The 65/35 development ratio also has one further major weakness; it requires three times the amount of land which would be needed if only the local need for affordable housing is covered. This cannot be said to be meeting the test of “highest level of protection” or “exceptional circumstances” and is not sound because it does not comply with National Policy as expressed in the new version of the NPPF.
• It is much more likely that an appropriate body needs to be found which will focus specifically on building social rented housing without needing to rely on subsidies from a premium placed on commercial developments of market housing. The SLDC documents do not deal adequately with this issue and are therefore unsound because they fail to provide sufficient evidence that the Land Allocations and associated policies will deliver the specific local need for social rented housing.
• SLDC also appears to be driven by fear of the consequences of the new NPPF and their perception that developers will have unfettered access to land if sites are not allocated in a controlled process such as these Land Allocations. This is, it says, because of the “presumption in favour of development”.
We do not believe this to be true within an AONB because of the obligation to apply the “highest level of protection”, and inappropriate land allocations can continue to be resisted. There is therefore no need to rush this process. The current land allocations for Arnside should therefore be referred back for further work with the community to produce a more appropriate plan.
• SLDC appears to be over-relying on the very short term application of the “Deliverability” criteria within the Development Framework. In practise, this has led it to rely on sites where there is a clear immediate intention of the owner to make the site available for development and to capitalise on a commercial opportunity. If that commitment has not been made to date, potentially useful and less sensitive sites have been excluded, even if there is a reasonable chance that they will come into play over the longer term. The consequence of this is that derelict and previously used sites, which should be improved as part of any sensible spatial plan for any community, have been ignored. The knock-on consequence is that greenfield sites could be destroyed while derelict sites remain unused. This is not a sensible planning policy and fails even the commonsense soundness test.
• It is clear that it will take some time to bring into play some of the smaller and brownfield sites within the village but it is argued that the exceptional circumstances of the village within the AONB justify the extra effort (or time delay) that may be required. SLDC has failed to use their best endeavours to apply this extra effort by (for example) using the powers they have to bring derelict sites into use (such as Compulsory Purchase Orders). APPT are keen to work with SLDC to produce a Plan which achieves these objectives but, so far, SLDC has failed this test of soundness in meeting the exceptional circumstances criteria required within an AONB. The new Community planning regime under the Localism Act provides the opportunity to put this right by SLDC working closely with the community. The current land allocations should be deferred until this process has been completed. APPT/APC have an early draft of a community plan already in progress (http://www.arnside.gov.uk/Warehouse/ArnsideLookingForward4.pdf) and are keen to engage SLDC 's support in moving to a complete and workable version.
• We understand that the management of the Arnside & Silverdale Area of Outstanding Natural Beauty have similar and additional objections to the soundness of these Allocations. Arnside Parish Council, through Arnside Parish Plan Trust, intend to coordinate their emerging plans with this and other stakeholders for this area.
• We also understand that Lancaster City Council has a more appropriate treatment of land within the AONB in its Land Allocations policies but that SLDC has not yet coordinated its approach effectively with LCC. There may be solutions to local housing needs which could be accommodated within the neighbouring territories of LCC. SLDC will therefore fail to meet the soundness test until this process has been completed.
• Because of the above, the current Land Allocations should be referred back for revision. This revision would benefit from input from the emerging Arnside Community and Neighbourhood Plans which will address these issues.
Appendix 1
Land Allocation Development Plan Document – Calculation of Housing Need within the AONB*
There are 4 calculations of potential housing needs contained in the document for the AONB part of SLDC
CALCULATION 1
This is based on the AONB population as a % of the total Local Development Framework (LDF) area population
LDF Population 75000
AONB population 5% 3800 (Arnside 2300 and Beetham 1500)
Based on total district housing target of 400 per annum then 5% of this is 20 per annum for the AONB (12 for Arnside and 8 for Beetham)
Over the period 2003-2025 the total for the AONB is 460 (276 for Arnside and 184 for Beetham)
CALCULATION 2
This is based on the 2009 Strategic Market Assessment for Rural South Kendal. The figures for Annual Affordable Housing Requirements (See Page 63) for the period 2009-2015 were based on the 2006 Housing Needs Survey and indicates respondents aspirations.
Rural South Kendal Total 1105
AONB population 15.7% 173
(Arnside 104 and Beetham 69 based on population split shown in calculation 1)
If the above figures were projected at the same level for the whole of the plan 2009-2025 then this gives a total affordable housing need of 555 (333 for Arnside and 222 for Beetham based on population split shown in calculation 1)
CALCULATION 3
This is based on the 2011 Strategic Market Assessment for Rural South Kendal not including Milnthorpe and Kirkby Lonsdale. Again the survey appears to be aspirational. The response rate for Rural South Kendal was 30%. The calculations for the affordable housing market for 2011-2016 were based on:
• Households currently in housing which is unsuitable for their use and who are unable to afford to buy or rent in the market (backlog need)
• New household forming who cannot afford to buy or rent in the market
• Existing households expected to fall into need
• The supply of affordable housing through social renting and intermediate tenure stock
This calculation is similar to number 2
Rural South Kendal Total 435
AONB population 18.54% 225
(Arnside 133 and Beetham 89) based on population split shown in calculation 1)
CALCULATION 4
This is based on Arnside 2009 Housing Needs Survey and 2007 Beetham Housing Needs Survey to determine the need for affordable housing. This survey applied to social rented housing only and represented respondents aspirations and does not necessarily represent actual take up of affordable homes if they were offered. See Appendix Below: Analysis & Critical Review of Housing Needs
2009-14 Arnside 27 ? therefore projected number for 2009-2025 is 86
2007-12 Beetham* 17 ? therefore projected number for 2009-2025 is 61
But in order to deliver the affordable element an allowance for market housing has to be given. If affordable housing is delivered at 35% of market schemes this would bring the total need for 2009-2025 to 420 (Arnside 252 and Beetham 168)
*in the AONB part of Beetham
SUMMARY
Reference in Land Allocation Document Arnside Beetham Total Comments
3.79 Calculation 1 Total need 2003-2025 276 184 460 AONB population as a % of Local Development Area population
3.80 Calculation 2 Affordable need 2009-2025 333 222 555 AONB as a % of Rural South Kendal from an aspirational survey
3.81 Calculation 3 Affordable need 2009-2025 135 90 225 AONB as a % of Rural South Kendal LESS Milnthorpe and Kirkby Lonsdale from an aspirational survey
3.87 Calculation 4 Affordable need 2009-2025
Calculation 4 but also market allowance to achieve this 2009-2025 86
252 61
168 147
420 Arnside and Beetham aspirations for affordable housing
Market allowance figures are unrealistic because unlikely this scenario will happen
From the above 4 calculations it was concluded that the total housing need over the plan period was somewhere between 200 and 400 but because of the low housing delivery since 2003 to the present there was a need to do more per annum in the remaining period of the plan.
Because these calculations assume use of the 65/35% ration of market to affordable housing, the actual need for affordable housing is much less.
pport the Arnside Parish Plan Trust and the APC.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
712. Mr David Philip (Individual) : 24 Apr 2012 10:30:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - RN152 GREENODD LAND AT THE OLD VICARAGE
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
the LDF document refers to the land incorrectly as Oak Vale, but having ascertained which parcel is referenced, this land is currently in agricultural use and as a building site does not comply with the current UK plans;
• the land is not 'infill' as it is not developed on the southern boundary;
the land is not suitable for building the proposed 22 houses as is unstable, liable to flooding and the extreme elevation would seriously impair light to the existing development to the north;
the drainage in the village is already compromised by the excess surface water evidenced by the flooding which occurs on the roads and the inability of the new water treatment plant to cope;
the school could not support the additional pupils which would be introduced by such a development;
the transport infrastructure would not cope with the additional demand;
the property I occupy was previously owned by the Diocese of Carlisle and there are restrictive covenants which prevent me from causing any detriment to the adjacent properties owned by the Church which would .
affect services and the general enjoyment of anyone attending those amenities. Such a development would seriously compromise this aspect.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
713. Mr David Philip (Individual) : 24 Apr 2012 10:32:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
there is no evidence of the need for additional housing in this area as already there are thirteen properties for sale and no potential buyers, further supported by the 2008 Parish Survey;
714. Ms Margaret Pierce (Individual) : 23 Apr 2012 11:14:00
Policy/Site No.
LA1.3 Housing Allocations - RN225-mod ARNSIDE HOLLINS LANE
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I object strongly to the development plan for Arnside; especially to the l development of 34 properties on the field on Hollins Lane. I have many concerns regarding the proposal to allow 34 houses to be built on this field on.
I feel that this development will have a negative effect on the village.
The proposed development for 34 houses
on Hollins Lane will mean a large increase in traffic on Hollins Lane; this could
be as great as an extra 68 vehicles. Hollins Lane is a single-track lane with
limited passing places for vehicles, and currently struggles to accommodate
the traffic that uses it, particularly in rush hour. Hollins Lane is much busier
during the holiday season when it is frequently used as a shortcut from
Silverdale Road to Black Dyke Road by tourists.
it is a long walk to
the station from Hollins Lane which may be difficult for some such as disabled
people and individuals with young children.
Home Housing recently explored the possibility of building six houses on
Hollins Lane. After considerable time surveying the drainage available they
decided that the sewers did not have the capacity to support the additional
waste from six properties and because of the density of limestone in the field
there was not enough natural rainwater drainage on the land to sustain the
development. This raises questions regarding the feasibility of a development
of 34 properties and the ability to create suitable, sustainable drainage for
domestic waste and rainwater.
The development on Hollins Lane will have a marked impact on the properties
at the south side of the field; especially because of the gradient of the field. As
a result of the Prescription Act of 1832, the windows of my property have
earned a right of light by having well over the required 20 years of
unobstructed daylight. This law also applies to the garden; which must receive
adequate daylight on March 29th. Because of the slope of the land on Hollins
Lane any development on the field would cast a shadow over my house and
garden restricting the amount of light to my property. Therefore the
development would need to be built Ill away from my property and others on the south side of the field. This would ensure the quantity of light to the
garden and windows is not adversely affected; causing the amount of light to,
fall below the accepted level, constituting an obstruction.
The Human Rights Act 1998, Article 8 offers protection for a person's private
and family life. It has previously been used to extend protection to a person's
office space as Ill as his or her domestic home. I feel that the protection of
private life and the home is relevant to decisions made in the development
plan for Hollins Lane as any development on the field on Hollins Lane would
adversely affect my enjoyment of my property which may be an interference
with my rights under Article 8. Anyone standing in the field at the back of my
house can see directly into my rooms, part way up the field they can see
directly into my Kitchen, lounge, dining room and bedrooms. This is not'
acceptable as it impinges on my privacy.
The case for privacy has recently been highlighted in Cumbria when a
planning officer dismissed an appeal against refusal of permission for three
two-storey terraced houses in Hawkshead. This was because the proposed
development would impact on the privacy of nearby residents.
I feel that the field has been chosen for the development sole[y on the
grounds that it may be available as opposed to being suitable
715. Ms Margaret Pierce (Individual) : 23 Apr 2012 11:16:00
Policy/Site No.
LA1.3 Housing Allocations - All Arnside sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The transportation infrastructure does not adequately support the
developments planned for Arnside. The proposed development for 34 houses
on Hollins Lane will mean a large increase in traffic on Hollins Lane; this could
be as great as an extra 68 vehicles. Hollins Lane is a single-track lane with
limited passing places for vehicles, and currently struggles to accommodate
the traffic that uses it, particularly in rush hour. Hollins Lane is much busier
during the holiday season when it is frequently used as a shortcut from
Silverdale Road to Black Dyke Road by tourists.
There will be an escalation of commuter traffic because there are very few
employment opportunities in Arnside; with only tourism, land management
and local service sectors having a significant presence. The potential
increase in commuter traffic could be hazardous; especially alongside the
possible growth in numbers of young children. The likely increase in
commuter traffic is certainly not environmentally friendly; surely houses should
be built in areas which have employment opportunities so traffic pollution is
not intensified and the high cost of travelling to work is minimised.
The public transport system is inadequate to support an increase in
commuters with no buses currently running prior to 8.00 or after 18.00. The
trains do provide a more frequent and longer service; but it is a long walk to
the station from Hollins Lane which may be difficult for some such as disabled
people and individuals with young children.
Home Housing recently explored the possibility of building six houses on
Hollins Lane. After considerable time surveying the drainage available they
decided that the sewers did not have the capacity to support the additional
waste from six properties and because of the density of limestone in the field
there was not enough natural rainwater drainage on the land to sustain the
development. This raises questions regarding the feasibility of a development
of 34 properties and the ability to create suitable, sustainable drainage for
domestic waste and rainwater.
The primary school in Arnside, although not full, is nearing capacity and
certainly could not support an influx of possibly 68 new pupils from a
development on Hollins Lane; plus extra pupils from others proposed
developments in Arnside. There is no nursery provision for younger child.
and a limited number of child minders in Arnside.
As discussed in Arnside Looking Forward there is currently an adequate
supply of market housing within the Village, with over 70 dwellings available at
all price levels. The 2009 Arnside Housing Needs Survey (conducted by
Cumbria Rural Housing Trust) has shown that there is a medium-term
demand for 27 officially-rated affordable dwellings in the Village. It also
shows that that demand is mainly for rented accommodation for single adults
currently living with parents (17 out of the 27 are in this category, and 10 of
them were under 19 years of age; possibly students who will probably soon
leave home to study at University). There were only four families with young
children identified by the CRHT study as in need of affordable housing. These
figures have not been updated recently.
The development plans for Arnside do not fully take into account the housing
needs of the local community nor does it respect the opinions and
suggestions of local residents.
716. Ms Margaret Pierce (Individual) : 23 Apr 2012 11:18:00
Policy/Site No.
SO Site Omission
If you have selected a ‘Site omission’ please enter the site reference or location and relevant policy below
MN20
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
One has to question why other more suitable site have not been chosen as there are many other more suitable sites in Arnside. The sites are highlighted in the recent draft document Arnside Looking Forward published by Arnside Parish plan Trust http://arnside.gov.uk/Arnside_Parish_Plan.html
Station Yard - This brownfield site is MN 20 in the SLDC Land Allocations Development Plan Document. (.CU 778804, CU251417
and CU41881).
717. Ms Margaret Pierce (Individual) : 23 Apr 2012 11:20:00
Policy/Site No.
LA1.3 Housing Allocations - Site Omission
If you have selected a ‘Site omission’ please enter the site reference or location and relevant policy below
Trafalgar Garage - This is another brown field site that SDLC did not
initially include this obvious possibility which is now designated RN269
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
One has to question why other more suitable sites have not been chosen as there are
many other more suitable sites in Arnside. The sites are highlighted in the
recent draft document Arnside Looking Forward published by Arnside Parish
Plan Trust http:l/arnside.qov.uk/Arnside Parish Plan.html.
Trafalgar Garage - This is another brown field site that SDLC did not
initially include this obvious possibility which is now designated RN269
718. Ms Margaret Pierce (Individual) : 23 Apr 2012 11:22:00
Policy/Site No.
LA1.3 Housing Allocations - Site Omission
If you have selected a ‘Site omission’ please enter the site reference or location and relevant policy below
The old Telephone Exchange (CU173479 this brownfield and infill site
is part of R393.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
One has to question why other more suitable sites have not been chosen as there are
many other more suitable sites in Arnside. The sites are highlighted in the
recent draft document Arnside Looking Forward published by Arnside Parish
Plan Trust http:l/arnside.qov.uk/Arnside Parish Plan.html.
The old Telephone Exchange (CU173479 this brownfield and infill site
is part of R393.
719. Ms Margaret Pierce (Individual) : 23 Apr 2012 11:24:00
Policy/Site No.
LA1.3 Housing Allocations - Site Omission
If you have selected a ‘Site omission’ please enter the site reference or location and relevant policy below
Land on the south side of Red Hills Road title number CU149475
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
One has to question why other more suitable sites have not been chosen as there are
many other more suitable sites in Arnside. The sites are highlighted in the
recent draft document Arnside Looking Forward published by Arnside Parish
Plan Trust http:l/arnside.qov.uk/Arnside Parish Plan.html.
Land on the south side of Red Hills Road title number CU149475
720. Mr & Mrs Andrew and Jean Platt (Individual) : 8 Apr 2012 18:29:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.1 Development Boundaries- GRANGE-OVER-SANDS
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Assessment of housing need is flawed and the allocation plan does not accurately reflect the needs of the area. Specifically, to increase housing provision in the Grange area by approx. 20% is nonsensical.
It is also nonsensical to increase private housing stock on this scale in an area with considerable stock for sale in an attempt to provide for the small amount of affordable housing required in the area.
The proposals for Kents Bank and Allithwaite mean that the two separate communities are in danger of coalescence, in contradiction of the Council's declared policies. Furthermore, the proposals do not include upgrading the road and service structure, leaving a hazardous 'pinch-point' at the junction of Church Road and the main route through Allithwaite, a junction without pavement or pedestrian access. Given the significant increase in traffic to the village and primary school as a consequence of the proposals this represents a serious danger of accidents. The main road carries large commercial vehicles and buses around an already hazardous corner.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
721. Mr & Mrs Andrew and Jean Platt (Individual) : 11 May 2012 10:13:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - All Grange-over-Sands sites
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Assessment of housing need is flawed and the allocation plan does not accurately reflect the needs of the area. Specifically, to increase housing provision in the Grange area by approx. 20% is nonsensical.
It is also nonsensical to increase private housing stock on this scale in an area with considerable stock for sale in an attempt to provide for the small amount of affordable housing required in the area.
The proposals for Kents Bank and Allithwaite mean that the two separate communities are in danger of coalescence, in contradiction of the Council's declared policies. Furthermore, the proposals do not include upgrading the road and service structure, leaving a hazardous 'pinch-point' at the junction of Church Road and the main route through Allithwaite, a junction without pavement or pedestrian access. Given the significant increase in traffic to the village and primary school as a consequence of the proposals this represents a serious danger of accidents. The main road carries large commercial vehicles and buses around an already hazardous corner.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
722. Mr & Mrs Andrew and Jean Platt (Individual) : 11 May 2012 10:16:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA3.1 Mixed Use Allocation at Berners Pool, Grange-over-Sands
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Assessment of housing need is flawed and the allocation plan does not accurately reflect the needs of the area. Specifically, to increase housing provision in the Grange area by approx. 20% is nonsensical.
It is also nonsensical to increase private housing stock on this scale in an area with considerable stock for sale in an attempt to provide for the small amount of affordable housing required in the area.
The proposals for Kents Bank and Allithwaite mean that the two separate communities are in danger of coalescence, in contradiction of the Council's declared policies. Furthermore, the proposals do not include upgrading the road and service structure, leaving a hazardous 'pinch-point' at the junction of Church Road and the main route through Allithwaite, a junction without pavement or pedestrian access. Given the significant increase in traffic to the village and primary school as a consequence of the proposals this represents a serious danger of accidents. The main road carries large commercial vehicles and buses around an already hazardous corner.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
723. Mr & Mrs Andrew and Jean Platt (Individual) : 11 May 2012 10:17:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA3.2 Mixed Use Allocation at Land South of Allithwaite Road, Kent's Bank, Grange-over-Sands
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Assessment of housing need is flawed and the allocation plan does not accurately reflect the needs of the area. Specifically, to increase housing provision in the Grange area by approx. 20% is nonsensical.
It is also nonsensical to increase private housing stock on this scale in an area with considerable stock for sale in an attempt to provide for the small amount of affordable housing required in the area.
The proposals for Kents Bank and Allithwaite mean that the two separate communities are in danger of coalescence, in contradiction of the Council's declared policies. Furthermore, the proposals do not include upgrading the road and service structure, leaving a hazardous 'pinch-point' at the junction of Church Road and the main route through Allithwaite, a junction without pavement or pedestrian access. Given the significant increase in traffic to the village and primary school as a consequence of the proposals this represents a serious danger of accidents. The main road carries large commercial vehicles and buses around an already hazardous corner.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
724. Mr & Mrs Andrew and Jean Platt (Individual) : 11 May 2012 10:18:00
Policy/Site No.
LA3.3 Mixed Use Allocation at Guide's Lot, Grange-over-Sands
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Assessment of housing need is flawed and the allocation plan does not accurately reflect the needs of the area. Specifically, to increase housing provision in the Grange area by approx. 20% is nonsensical.
It is also nonsensical to increase private housing stock on this scale in an area with considerable stock for sale in an attempt to provide for the small amount of affordable housing required in the area.
The proposals for Kents Bank and Allithwaite mean that the two separate communities are in danger of coalescence, in contradiction of the Council's declared policies. Furthermore, the proposals do not include upgrading the road and service structure, leaving a hazardous 'pinch-point' at the junction of Church Road and the main route through Allithwaite, a junction without pavement or pedestrian access. Given the significant increase in traffic to the village and primary school as a consequence of the proposals this represents a serious danger of accidents. The main road carries large commercial vehicles and buses around an already hazardous corner.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
725. Mr Stephen Pooley (Individual) : 1 May 2012 12:10:00
Policy/Site No.
LA1.3 Housing Allocations - R103M-mod KENDAL STAINBANK GREEN
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I refer to my email of 11 February 2009 sent in the first stage of the consultation process.
Subsequently, and following that consultation, and no doubt after careful consideration and for sound planning reasons, the most southerly part of area R103 was removed from the plan in July 2011.
The next stage of the process was to give consideration to ‘alternative sites’.
Given that amended brief and the decision already taken I was surprised to see the reintroduction of that area in February 2012.
In view of this apparent about turn I took the matter up with my local councillor.
She informs me that the principal reasons for the previous removal of the area were that there is an existing policy to ensure that a green area or wedge remains between the Vicarage Park and Collinfield developments and there were also concerns about the visual impact of any development on such an elevated site.
She tells me that she has had a meeting with you and that you have assured her that both the policy and the concerns remain and, indeed, the reason for the reintroduction of this area is to ensure that they are adhered to by giving the local planning authority wider control over any development in that part of town. This will be achieved by a requirement that a detailed landscaping scheme will need to be submitted and approved before any development is given permission.
I am told that the Council’s considerations with such a scheme are:
• The emphasis of any development and site would face north with the main vehicular access being onto Brigsteer Road.
• There will only be a net developable area of 50% of the whole site with the remaining 50% comprised of landscaping and public open spaces etc.
• The land allocations document requires that the landscape framework be integrated with the Vicarage Road green wedge.
In practice this would mean that much of the western end of the site towards Collinfield would be retained as open space as there would be a need to ensure that the connection with the open countryside was retained.
I ask that the matters raised be given proper consideration. I have my doubts, procedurally, whether an area can be reintroduced once it has been considered and removed. However, if the intent is to ensure eventual compliance with the land allocations document and already stated policy, then for the land allocations DPD to be effective, justified and consistent with that policy, and therefore ‘sound’ it must be a requirement that submission of a detailed landscaping scheme must be made a pre requisite to any development proposals.
726. Mr David John Prescott (Individual) : 17 Apr 2012 14:34:00
A typed or handwritten document was submitted. This has been scanned and can be downloaded below:
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - RN213-mod BRIGSTEER LAND OPPOSITE THE WHEATSHEAF
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not had regard to the Sustainable Community Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
• Test “Evidence of participation of the local community and others having a stake in the area.”
Evidence The proposal does not have the unconditional widespread support that could reasonably be expected to justify the treatment of Brigsteer as an exceptional case:
a) There has been minimal consultation, and no public discussion (original proposal aired at a meeting in Dec 2010 followed by a leaflet and a web-site; there have been no further discussions). The Directors were either absent or did not respond to questions at the Annual Parish meeting held on 10th April 2012. At a parish Meeting on 10th April 2012, the Directors were unable to give an undertaking to review the membership criteria.
b) Membership of the Trust is conditional on the statement “I agree to be bound by the rules, policies and objects of association of the company, to support the provision of all land as the board shall determine and to support all affordable housing proposals brought forward by the board.” (sic) i.e. discussion and democracy are not permitted.
c) The Parish Meeting voted AGAINST the proposed development on site RN213 (Land opposite the Wheatsheaf) by 31 votes to 20.
SLDC development proposals for the village of Brigsteer
A Sustainability Assessment
Foreword
The sections in this report follow the format required by the EU in the Strategic Environmental Assessment (SEA) Directive (2001/42/EC). Assessments of this nature are required for major projects and must include all aspects of the environment that may be affected by the development, such as populations, fauna, flora, air, soil, water, humans, landscape, and cultural heritage.
The author has prepared this report because the Sustainability Appraisal published by SLDC is relatively simplistic in its approach and does not address the wider issues.
1. Description of the Project
The Project under consideration is the proposal by South Lakeland District Council to build new dwellings in the village of Brigsteer. Full details are available at the following url: http://www.southlakeland.gov.uk/services/environment-and-planning/planning/local-development-framework/allocations-of-land-dpd.aspx
In summary, 1 site is identified for development, including affordable housing.
The site is identified as Land opposite Wheatsheaf car park (RN213).
The project will involve the planning, construction and consequent occupation of the dwellings.
Environmental inputs at the planning stage are limited to site survey and office-based design and contract let.
The Construction Phase will involve the following activities which will be sources of environmental disturbance: Clearance of mature woodland and loss of habitat Re-routing of existing overhead and underground power lines Groundwork, site levelling, roadways for site access, excavations for septic tanks, rain water storage, and potentially, boreholes for ground source heat Deliveries of building materials including bricks, blocks, concrete, timber, fixtures and fittings. Construction and assembly of the dwellings
The occupation phase will generate sources of environmental impacts as follows: Personal transportation, i.e. motor cars; vehicle movements, parking Heating of the dwellings Water supply to the dwellings Laundry Visual Drainage Run-off
2. Alternatives that have been considered
No serious alternative strategies have been promoted by SLDC in their consultation. Some alternatives are discussed in Section 5 – Mitigation.
3. Description of the environment
The village of Brigsteer comprises 91 dwellings on the eastern slopes of the Lyth Valley, and 4 miles to the south-west of the town of Kendal.
The community is served with electricity to all households (single phase) and mains water. There is no gas supply or any main drainage – all properties are served either by a septic tank or small treatment unit. The electricity supply is subject to interruption (through high winds for example and several outages are experienced every year, extending from 1 hour to 14 hours in 2010. Water supply to the village is through a single main and was interrupted once for approximately 10 hours in 2010.
There is no school, neither is there a shop. Public transport is minimal: the one bus per week allows less than three hours in Kendal on Wednesday morning.
The village is built at the foot of Burnbarrow Scar and is surrounded by woodland to the east and overlooks the low-lying Moss to the west, draining via the Pool and Gilpin Rivers and pumped drainage to preserve the agricultural value of the land.
The woodland includes mature deciduous woodland, particularly on site RN 213 comprising oak, ash, yew and woodland understorey.
The economy of the area is dominated by agriculture with some 12 farms within the parish boundary, 2 bed and breakfast businesses and one agricultural machinery business. The public house has recently closed, with no apparent prospect of imminent re-opening.
Most roads providing access to the village are narrow, the only 2-way road leads directly from Kendal, but this is routed across the top of Scout Scar and with a 12% gradient into the village, is not easily accessible in ice and snow conditions.
With only 91 existing dwellings, the village is sensitive to the provision of an estate at the edge of the village dedicated to private/affordable housing mix, increasing the number of dwellings by up to 7.7 % in a single development.
4. Description of the significant effects on the environment
4.1. Travel and Transport
The proposal to build up to 7 additional homes brings with it the need for the occupants of the new dwellings to own their own car – depending on the circumstances, this may be 2 cars. (A group of 4 affordable homes already in the village boasts 7 cars). If the whole development were to attract owners and tenants with similar patterns of ownership, there will be at least 12 additional vehicles parked permanently in the village.
4.2. Traffic
Observations of traffic through the village show that there are a disproportionately large number of agricultural vehicle movements (comprising large tractors with trailers), particularly at muck-spreading and grass-cutting times, and cyclists (part of the tourist attractions of the Lyth Valley). There is no speed limit in the village.
This report attempts to model the likely impact of the marginal increase in transport-related emissions as a result of the project proposals described above:
The model is related to:
1. The existing group of affordable homes in Brigsteer
2. The Housing Trust report of Housing Need
3. The additional fuel demand arising from being domiciled in Brigsteer
In the first instance, there are 4 houses (Trinity Cottages) whose occupants operate 7 motor cars.
In the second case, the report 1 identifies a derived gross daily commuting distance to and from work of 1435 miles2. This equates to 1435/17 = 84.4 miles per working day per dwelling. This excludes travel to Kendal or elsewhere for shopping, doctor, dentist or entertainment.
Thus for 7 dwellings, an expected additional car population of some 12 cars must be planned for in terms of parking and additional carbon dioxide and other GHG emissions.
On this basis and using a medium –sized car at 309 g CO2/mile3, the additional emissions due to motor transport equates to 0.183 tonnes CO2 emitted per working day. [As a comparator, it is estimated that each person in the UK on average emits between 5 and 6 tonnes CO2 per annum and this should be around 3 tonnes 4 if we are to manage the UK’s emissions to meet its targets]. Commuting alone will account for 2.86 tonnes per person per annum, assuming 220 working days per year and 2 persons per dwelling.
4.3. Construction of New Build Houses
The proposals envisage the new build of some 7 dwellings (not the conversion or adaptation of existing buildings).
The environmental footprint for the construction (not the ongoing occupation) of new houses is strongly dependent on their design. The main component is ‘embodied energy’ being the energy needed to create bricks and cement.
Published figures5 indicate that an expected 500-1000 kg of CO2 equivalent can be expected per sq m of a house: this equates to 525 tonnes of CO2 equivalent for the whole development using the median value of 750 kg and a typical floor area of 100m2.
4.4. Code for Sustainable Homes
Standards for affordable housing to meet the Code for Sustainable Homes6 incur additional costs – it is usually a condition of Government funding to at least Level 4 of the Code. To achieve this level, dwellings will require as a minimum: 44% improvement over Target Emission Rate (TER) for Energy/CO2 as determined by the Building Regulation Standards Maximum internal potable water consumption measured in litres per person per day (l/p/d) 105 l/p/d The Environmental impact of at least three of the following materials as a key element of construction are specified to achieve a BRE Green Guide 2006 rating of at least D
– Roof structure and finishes
– External walls
– Upper floor
– Internal walls
– Windows and doors Surface water management - ensure that peak run-off rates and annual volumes of run-off will be no greater than the previous conditions for the development site. 100% in areas of high risk of flooding. Household waste storage where there is adequate space for the containment of waste storage for each dwelling.
All these requirements will add to the capital cost of new build: Case Studies7 indicate that a Level 3 house will cost at least £965 per square metre. The special conditions described above about energy infrastructure and water run-off means that Brigsteer location will add considerably to this cost.
In addition, there will be an ongoing social cost for dependant individuals or families (visits by doctors, healthcare professionals, school travel etc.).
4.5. Biodiversity
Another global issue with local action needed is the need to preserve biodiversity – the site is managed woodland with a margin of mature oak trees.
The Cumbria Biodiversity Action Plan identifies key species for protection - these include bats, red squirrels, water voles, barn owls and the juniper tree. Of the nominated species, bats, barn owls and the juniper are present in Brigsteer. Site RN 213 also boasts the presence of bats and lesser spotted woodpeckers, the latter according to the RSPB are now in the danger zone and been referred to the Rare Breeding Birds Panel8 . This may be related to the presence of mature oak trees: surrounding woodland to the north and west does not contain oak trees.
4.6. Energy Sources
The energy needed for heating lighting and operating other domestic appliances is a key issue addressed in the Code for Sustainable homes. Building in Brigsteer poses a problem due to the absence of mains gas – most homes in the village are heated with oil or LPG: as very apparent at the time of writing- the cost of heating by conventional means will require the occupants to spend much more than average on their heating bills than they would elsewhere.
Possible solutions are to install a small-scale district heating scheme using ground source heat pumps: however these are expensive, require 3-phase mains electricity and due to the ground conditions will require deep wells to extract ground heat, all of which is a significant capital spend. Alternative energy sources for heating may also be needed to cope with supply disruptions. Bio-fuelled boilers are another option, but require electricity for ignition and control.
4.7. Water
All properties will require a mains water supply: this is currently supplied from the north along a single pipeline. An increase of more than 7% in the number of dwellings is likely to create the possibility of the need for an increase the demand beyond the capacity of the pipeline to the village. In the past 3 years, bursts in the ageing pipeline have interrupted the supply at least six times.
4.8. Run-off and flooding
The proposed development will be located on the eastern edge of the Lyth Valley. This valley has a drainage system currently operated by the Environment Agency, based on electric pumping stations and a series of levees. In the next two years the Environment Agency will cease to operate the pumping stations; unless operation is assumed by a group of farmers, the risk of flooding in the valley will increase.
Any building will add to the storm water run-off, simply adding to the load on the pumps and making the situation for those attempting to preserve the land as an agriculturally productive area worse.
A typical house will have approximately 30 sq m of roof, and with an annual rainfall of 1,522 mm (average of the last 5 years in Brigsteer), if 7 houses were built the additional storm water load on the valley system would be: 7 x 30 x 1.522 x 0.9 cu. m. = 288 cu. m. [0.9 is the factor intended to take account of evaporation and absorption]. The main problem will occur in periods of high rainfall. As itemised in the Code for Sustainable Homes, this means that 100% attenuation of run-off will need to be achieved; the practical approach being underground storage tanks of around 20,000 litres (i.e. 20 cubic metres) capacity. These tanks could, of course, be used to supply water for non-potable use in the properties. Nonetheless, this will involve considerable ground-work in solid carboniferous limestone rock.
4.9. Sewerage and groundwater pollution
With no sewerage in the village, all properties will need a septic tank or a small sewage treatment plant. The Environment Agency has expressed concern about the need for owners of septic tanks to ensure that they are properly maintained9 – mainly because of groundwater pollution, which is beginning to emerge as a significant environmental hazard.
Discharges from septic tanks and small sewage treatment plants are mainly exempt from the need to have an environmental permit, but they are of concern to the Environment Agency due to European legislation.
4.10. Noise and visual impact
Most noise will be associated with building activity – although as noted above there will be considerable effort associated with cutting large cavities in the rock substrate for sewage and water storage.
Noise apart from construction will arise from occupation, although it is unlikely to be a significant environmental impact.
Development of Site 213 could have a serious visual impact on the northern boundary of the village, currently well defined by the line of mature oak trees bordering the north side of the Underbarrow road. Any felling would materially alter the character of the village on this boundary.
4.11. Land use
Given the national and international concerns about food security (see Annex A), there is some relevance in ensuring that all sites currently available for agriculture are not removed from production.
4.12. Overall marginal Increase in the Carbon footprint
The National Park has published its own Strategy10 for reducing its carbon footprint. This is a response to concerns about climate change, but also because it presents considerable opportunities for people and businesses in Cumbria.
5. Mitigation
The District Council proposals do not include alternatives: however, there is a considerable disconnect between the findings of the Cumbria Rural Housing Trust survey and that of the proposals, which advocate a single tranche of building in Phase 1 of the plan (i.e. by 2015). Local opinion11 contends that this does not meet the need in time or space. The best approach will be to utilise existing properties and land spaces to create genuine infill at a speed which meets the needs identified in the housing needs survey.
Other factors suggest that a development of this scale is best met where the infrastructure is available (particularly mains gas) and distances to work are such that travel by motor car not a necessity. In this respect the comments made by the Homes and Communities Agency 12that “Newer areas, often big estates, are sometimes soulless places, disconnected and car dependent, wasteful of energy and built with little recognition of the wider environment where planning seems to have been an afterthought and public transport connections are poor".
6. Non-technical summary (EIS)
1. Brigsteer, although located near to Kendal in distance, has a very limited infrastructure, having no gas, no shop, no school and no bus service.
2. Affordable homes, by definition have to meet Government Guidelines for sustainable construction. In addition to the sensitivities of the physical environment, all these requirements add considerable financial capital cost to any construction project. If public money is to be used, it will be spent more beneficially (i.e. more homes) in areas with a developed infrastructure.
3. Affordable homes, by definition, are occupied by people on limited incomes: the limitations imposed by the limited (and ageing) infrastructure mean that the cost of living will be higher than other locations better served by utilities and services, and is likely to rise faster than income, particularly as a high percentage of living costs will be geared to oil prices.
4. Any greenfield development will necessarily attract a high cost in terms of carbon footprint, both in the construction and subsequent occupation phases. It will also adversely impact on wildlife, particularly the lesser spotted woodpecker and bats.
7. Lack of know-how/technical difficulties
This report has been prepared on the basis of the references listed and other available information in the public domain. The content has been reviewed by local residents for accuracy and to the best of the author’s knowledge the report is entirely factual.
Annex A
Sustainability Issues in a Policy Context
Sustainable Development
Sustainable Development is a widely- used term originally defined by the United Nations at the World Commission on Environment and Development chaired by Gro Bruntland and reporting in 1987. It defined sustainable development as ‘development which meets the needs of the present without compromising the ability of future generations to meet their own needs.’
Subsequent studies and conferences addressing this issue coined the phrase ‘think globally, act locally’, recognising that, in the end, our own behaviours, particularly in our consumption of global resources, is the only practical way to make a difference.
Sustainable Communities
A concept established in the UK envisaging ‘homes in well-connected, carbon-efficient communities with a range of facilities such as schools, health centres, shops, pubs and parks’ (HCA)
According to the Homes and Communities Agency, ‘Such neighbourhoods – what we call sustainable communities – don’t happen by chance. Some, in towns and cities, have taken years to develop. Others, more recent in origin, were born out of a strong partnership between planners, developers, local authorities and community groups.
Yet too many places are neither cohesive, connected, well-designed nor well-planned. Some, for various reasons, have lost the essential glue that binds them together. Newer areas, often big estates, are sometimes soulless places, disconnected and car dependent, wasteful of energy and built with little recognition of the wider environment where planning seems to have been an afterthought and public transport connections are poor.’ (HCA web-site 2011) http://skills.homesandcommunities.co.uk/sustainable-communities
Affordable Housing
A UK Government Policy for Housing in which it is committed to providing high quality housing for people who are unable to access or afford market housing, for example, vulnerable people and key workers as well as helping people make the step from social-rented housing to home ownership. (Policy Planning Statement 3)
Kyoto - Carbon Reduction Commitment
The UK is a signatory to the Kyoto Protocol and has enshrined this commitment within the Climate Change Act 2008: The Climate Change Act 2008 set legally binding emission reduction targets for 2020 (reduction of 34 percent in greenhouse gas emissions) and for 2050 (reduction of at least 80 percent in
greenhouse gas emissions), and introduced five-yearly carbon budgets to help ensure those targets are met.
Recent commentators have identified additional carbon usage through imported goods, which have a ‘embodied energy’; content – if the UK were measured on this basis, carbon emissions have increased by 30% over the period since Kyoto, not diminished as the Government claims.
Low-Carbon Lake District
The National Park produced a report in 2008 which identified that: ‘The Lake District could stand to gain from some of these trends (Rising energy costs, renewable and nuclear power, low carbon transport, greener choices) – such as the move toward more decentralised energy generation, and greener products and services. A new study on the economic impacts of climate change legislation for Cumbria estimates that, with the right support and encouragement, the county as a whole could benefit from moves to cut carbon. While all businesses will have to adapt to higher prices for carbon, the overall impact is likely to be positive, with the potential for around 1500 new jobs in the sustainable energy and tourism sectors. The study points to a number of areas that should be supported, because of the potential for combined economic, social and environmental gain.’
A full copy of the report is available at: http://www.lakedistrict.gov.uk/lowcarbonlakedistrict
Peak Oil
Most energy commentators and many industry studies have concluded that the rising demand for oil is outstripping the rate of supply and the rate at which new reserves are found and exploited.
Wikipedia has an interesting entry under Peak Oil “Optimistic estimations of peak production forecast the global decline will begin by 2020 or later, and assume major investments in alternatives will occur before a crisis, without requiring major changes in the lifestyle of heavily oil-consuming nations. These models show the price of oil at first escalating and then retreating as other types of fuel and energy sources are used. Pessimistic predictions of future oil production operate on the thesis that either the peak has already occurred, that oil production is on the cusp of the peak, or that it will occur shortly. The International Energy Agency (IEA) says production of conventional crude oil peaked in 2006.
Energy Supplies and Pricing
Due in part to the unrest in the Middle East, the price of oil is at an all-time high at the time of preparing this report: this affects the price of gas and practically all commodities in an oil-dependant economy. Commentators are agreed that a mix of supply-side issues with oil, issues with nuclear (with the Japanese nuclear emergency fresh in European minds) that energy of all kinds will continue to rise in cost.
Embodied Energy
All goods and materials we use carry with them a carbon footprint – building materials are no exception, particularly for bricks and cement: the Housing Corporation estimate that 500-1000 kg CO2 equivalent is emitted per sq. metre of house. However, equally important is the lifetime emissions as a result of occupation, so that over the life of the property, emissions are minimised.
Bio-diversity
A major global issue, discussed at a recent United Nations conference in Rio de Janeiro in 2010. In the UK, local authorities were required to prepare a BioDiversity Action Plan – full details of the plan for Cumbria are reproduced at Annex B
Food Security
A recent UN report on food supplies has highlighted the inadequacy of the current regime for the supply, marketing and distribution of food to support the world’s population. The UK Government has also expressed concern in a recent report – with the UK dependant in food imports to the tune of 60% of food consumed, there is real cause for concern.
"We need to act now," said Caroline Spelman, the secretary of state for environment, food and rural affairs, whose department co-commissioned the report from the government's futures think-tank Foresight. "Farmers have to grow more food at less cost to the environment. In the UK, farmers should produce "more food more sustainably" and she suggested that small price increases represented an economic opportunity for British farmers.”
Flood management
Some 5.2 million homes in the UK are subject to flood risk: the government’s legislative response has been to enact the Flood and Water Management Act 2010. The Act gives local authorities a new role to manage local flood risk in their area.
The Lyth Valley is particularly prone to flood risk, the more so in the next two years the Environment Agency will cease to operate the pumping stations; unless operation is assumed by a group of farmers, the risk of flooding in the valley will increase.
Water resources
“There are significant pressures on water resources which affect both the water environment and water supplies. There are many catchments where there is little or no water available for abstraction during dry periods.
Pressures are greatest in South East and Eastern England because of them being the driest parts of England and Wales, coupled with the highest population density and household water use. The demand for water to irrigate crops in East Anglia also adds to the pressure on resources during the driest times of the year.
Over the next 30 years, there will be increasing pressures from the rising population and associated development. Looking further ahead, the impact of climate change could have a major impact on the water that will be available for all uses.”13
ANNEX B
Cumbria Biodiversity Action Plan
The Cumbria Biodiversity Action Plan (BAP) was published by the Cumbria Biodiversity Partnership in 2001. This local BAP is the means by which national biodiversity targets will be met locally. The document also includes locally important species and habitats that are characteristic to Cumbria but not covered by the national targets.
The Cumbria BAP also aims to raise public awareness and understanding of the natural environment and hopes to encourage local people and politicians to take a closer interest in biodiversity in order to take action to help vulnerable wildlife and threatened habitats.
Biodiversity & Economy
Diverse habitats and communities of plants and animals should be conserved for their own sakes but we often overlook their importance to the economy of our area. It is the range of landscapes and the species they support that bring in the huge numbers of tourists that visit Cumbria throughout the year. These visitors provide a vital source of income to shops, hotels, campsites, B&B’s and cafes and their membership of some of the organisations working to protect the environment of the county is highly significant.
A biologically diverse natural environment also attracts businesses to set up in the county, bringing with them jobs and prosperity for our towns and villages. Many of the habitat management techniques used to help to conserve biodiversity can also benefit the economy such as the production of woodland products like timber and charcoal.
The Action Plan
21 species and 18 habitats have been identified for priority action and targets set for recovery. Species include bats, red squirrels, water voles, barn owls and the juniper. Habitats include nutrient enriched lakes, hay meadows, blanket bog, and upland oak and ash woods.
The Cumbria BAP also lists a number of actions including lobbying to reform the Common Agricultural Policy, influencing industry, utilities, landowners, farmers and the public sector to adopt sympathetic approaches to land management, ensuring that planning policy and practice act to protect biodiversity and securing widespread public interest and involvement in protecting biodiversity.
Further Information and Contacts
To find out more about Cumbria’s Biodiversity Action Plan and biodiversity in Cumbria contact:
Graham Jackson-Pitt (Local Biodiversity Manager)
Cumbria Biodiversity Partnership,
c/o Cumbria Wildlife Trust Plumgarths Crook Road Kendal LA8 8LX
Phone 01539 816300 Email biodiversity@cumbriawildlifetrust
Bibliography
Cumbria Rural Housing Trust, 2008
www.transportdirect.info
RSA CarbonLimited project – ‘A Persuasive Climate’ RSA 2009
Embodied energy in Residential Property Development – A guide for Social Landlords; Housing Corporation 1999
Code for Sustainable Homes - Department for Communities and Local Government: London
Sustainable Homes Case Studies - Department for Communities and Local Government, 2009
Environment Agency web-site http://www.environment-agency.gov.uk/homeandleisure/118753.aspx
Low-carbon Lake District: Responding to climate change in the National Park June 2009
Annual Helsington & Brigsteer Parish meeting, 2 March 2011
Homes & Communities Agency web-site: http://skills.homesandcommunities.co.uk/sustainable-communities
Environment Agency Report - Water resources in England and Wales - current state and future pressures. December 2008
RSPB ‘Birds’ Magazine Spring 2012
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
• Test “most appropriate strategy when considered against reasonable alternatives. These alternatives should be realistic and subject to sustainability appraisal.”
Evidence The Sustainability Appraisal completed by SLDC does not focus in any depth on the issues raised by the construction of 7 new dwellings: it does mention the clearance of woodland and the biodiversity issues. There are however, considerable issues to be considered in both the construction and occupation phases of such a development.
a) In addition to the species mentioned by SLDC, there are lesser spotted woodpeckers (the UK population of which has declined by 80% since the 1970’s RSPB Birds Magazine Spring 2012) and bats.
b) The technical challenges of the site and the obligations imposed by public funding (Code for Sustainable Homes) means that the financial costs are likely to be higher than average, and also the carbon footprint. Public funds will be more effectively deployed in areas with infrastructure in place.
c) Furthermore, the occupation of any new dwellings will generate a higher than average carbon footprint. In the face of historically high and rising oil prices, the cost of living can confidently be predicted to rise sharply in the lifetime of the development.
• Test Sound infrastructure delivery planning
• Evidence Infrastructure is not available and has not been planned for the site. There is:
a) No bus service to Kendal
b) No mains Gas
c) No shop
d) No surgery
e) No main drainage
Furthermore, there will be considerable capital works involved in altering the electricity distribution network, as the proposed access road crosses the underground link to a sub-station.
• Test Having no regulatory or national planning barriers to delivery
• Evidence The area is within the proposed extension to the Lake District National Park: if, as is likely, the Secretary of State approves the proposal, the planning rules for the national Park will apply and no new build will be permitted except for affordable homes. On this basis, the inclusion of the Brigsteer proposals run counter to national planning guidelines.
• Test Delivery partners who are signed up to it
• Evidence The DPD identifies the Helsington Community Land Trust; however, as stated above, this does not as yet enjoy majority support. Further, it is possible that capital will be provided by property developers, which renders the CLT open to the charge that it is creating a profit for non-local entities.
• Test Coherence with the strategies of neighbouring authorities
• Evidence As stated above, the DPD should align with the Lake District National Park. There is no statement that this has been considered.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
727. Mrs Wendy Prescott (Individual) : 17 Apr 2012 14:32:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - RN213-mod BRIGSTEER LAND OPPOSITE THE WHEATSHEAF
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not had regard to the Sustainable Community Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
No other village has been included, and Brigsteer has been included as an exception based on ALLEGED community support. In fact the majority of residents do not suppport proposals for RN213. We had a village consultation in December 2010 which has been ignored, which was overwhelmingly against RN213.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
There is NO evidence that alternatives have been considered. RN 213 is a woodland site with steep access to a road on a bend. Given the whole area is solid rock the build would be disproportionately expensive. The cost of living for the occupants would be far higher than normal due to no shops, buses, schools, mains gas etc.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
728. Mr Michael Prince (Individual) : 17 Apr 2012 13:19:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.1 Development Boundaries- LEVENS
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The views of the community have not been adequately addressed. The evidence base is poor, out of date and does not refelct the current situation nor revised projections.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
729. Mr Michael Prince (Individual) : 17 May 2012 11:36:00
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I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - All Levens sites
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The views of the community have not been adequately addressed. The evidence base is poor, out of date and does not refelct the current situation nor revised projections.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
730. Mr & Mrs R.M. and P.A. Prothero (Individual) : 26 Apr 2012 10:54:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - M41M ENDMOOR NORTH OF SYCAMORE DRIVE
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
DENSITY OF HOUSING:
This proposal has not taken local opinion into consideration and will contribute to destroying the Kendal area, reducing income from tourism.
Increasing the size of K Village has led to a decline in visitors.
Excessive increase in number of houses from 68 to 100, village not consulted on 100, objected to 68 houses.
30 bungalows and affordable housing required for local people with provision for green areas.
INADEQUATE PROVISION OF SEWERAGE AND DRAINAGE:
Sewerage can just about cope now; more houses will create more problems. Smell exists in summer, which resulted in water authority dealing with issue 2 years ago. Could become a public health issue.
The fields flood, which will create a drainage problem.
TRAFFIC AND AIR POLLUTION:
No work or doctors in village; will contribute to increase in traffic, which will create a dangerous junction.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
731. Mr Leslie Pye (Individual) : 6 Mar 2012 12:07:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.1 Development Boundaries- ULVERSTON
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The DPD has not had regard to the Sustainable Community Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
TO MAINTAIN SUSTAINABILITY IN THE COMMUNITY IT WILL BE NECESSARY TO REDUCE SUBSTANTIALLY THE
PRESENT PROPOSALS TO ALLOCATE HUGE AREAS OF GREEN FIELD SITES FOR DEVELOPEMENT.
AS NOW APPROVED BY SLDC THE PROPOSALS WOULD IRREPARABLY DESTROY THE ENVIRONMENTAL CHARACTER OF MANY PARTS OF THE DISTRICT.
VALUABLE AGRICULTRURAL AREAS COULD BE LOST THUS MAKING SOME FARMS ECONOMICALLY UNVIABLE.
THE WHOLE SCHEME HAS NOT BEEN WELL RESEARCHED. THE DEMAND FOR MORE HOUSES HAS BEEN EXAGGERATED.
DEMAND FOR HOUSING IN SOUTH LAKELAND IS INSATIABLE. NEW ESTATES DRAW IN PEOPLE FROM OUTSIDE BECAUSE THE LAKE DISTRICT IS SO ATTRACTIVE. BUT NOT IF FILLED WITH SPRAWLING NEW ESTATES.
1.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
INSOFAR AS IT MAY PROVIDE SITES FOR LOW COST HOUSING IT IS TO BE WELCOMED.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
NO DETAILED EVIDENCE AS TO LOCAL DEMAND HAS BEEN PRODUCED.
AS A FORMER SLDC CHIEF HOUSING OFFICER I WOULD CAUTION HAVING TOO MUCH REGARD TO THE HOUSING WAITING LIST WHICH DOES NOT ALWAYS REFLECT TRUE NEED.
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
INSOFAR AS IT MAKES PROVISION FOR LOW COST HOUSING IT IS GOOD BUT TO WHAT EXTENT AS COMPARED WITH HIGH COST SPECULATIVE DEVELOPMENT ?
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
HAVING LIVED AND WORKED IN THE DISTRCT FOR MOST OF MY LIFE (I AM NOW 85 YEARS OF AGE) I HAVE ALREADY SEEN ENORMOUS HOUSING DEVELOPMENTS WHICH HAVE NEVER SOLVED THE INSATIONABLE DEMAND FOR HOUSING FROM THOSE WHO WISH TO MOVE INTO SOUTH LAKELAND FROM ELSEWHERE.
THE PRESENT PROPOSALS WOULD ENCOURAGE FURTHER FLOODS OF INCOMERS RATHER THAN MEET LOCAL NEEDS.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
732. Mr Leslie Pye (Individual) : 23 May 2012 17:17:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - All Ulverston sites
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The DPD has not had regard to the Sustainable Community Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
TO MAINTAIN SUSTAINABILITY IN THE COMMUNITY IT WILL BE NECESSARY TO REDUCE SUBSTANTIALLY THE
PRESENT PROPOSALS TO ALLOCATE HUGE AREAS OF GREEN FIELD SITES FOR DEVELOPEMENT.
AS NOW APPROVED BY SLDC THE PROPOSALS WOULD IRREPARABLY DESTROY THE ENVIRONMENTAL CHARACTER OF MANY PARTS OF THE DISTRICT.
VALUABLE AGRICULTRURAL AREAS COULD BE LOST THUS MAKING SOME FARMS ECONOMICALLY UNVIABLE.
THE WHOLE SCHEME HAS NOT BEEN WELL RESEARCHED. THE DEMAND FOR MORE HOUSES HAS BEEN EXAGGERATED.
DEMAND FOR HOUSING IN SOUTH LAKELAND IS INSATIABLE. NEW ESTATES DRAW IN PEOPLE FROM OUTSIDE BECAUSE THE LAKE DISTRICT IS SO ATTRACTIVE. BUT NOT IF FILLED WITH SPRAWLING NEW ESTATES.
1.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
INSOFAR AS IT MAY PROVIDE SITES FOR LOW COST HOUSING IT IS TO BE WELCOMED.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
HAVING LIVED AND WORKED IN THE DISTRCT FOR MOST OF MY LIFE (I AM NOW 85 YEARS OF AGE) I HAVE ALREADY SEEN ENORMOUS HOUSING DEVELOPMENTS WHICH HAVE NEVER SOLVED THE INSATIONABLE DEMAND FOR HOUSING FROM THOSE WHO WISH TO MOVE INTO SOUTH LAKELAND FROM ELSEWHERE.
THE PRESENT PROPOSALS WOULD ENCOURAGE FURTHER FLOODS OF INCOMERS RATHER THAN MEET LOCAL NEEDS.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
733. Mr Leslie Pye (Individual) : 23 May 2012 17:22:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
0.0 Whole Document
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The DPD has not had regard to the Sustainable Community Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
THE WHOLE SCHEME HAS NOT BEEN WELL RESEARCHED. THE DEMAND FOR MORE HOUSES HAS BEEN EXAGGERATED.
DEMAND FOR HOUSING IN SOUTH LAKELAND IS INSATIABLE. NEW ESTATES DRAW IN PEOPLE FROM OUTSIDE BECAUSE THE LAKE DISTRICT IS SO ATTRACTIVE. BUT NOT IF FILLED WITH SPRAWLING NEW ESTATES.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
HAVING LIVED AND WORKED IN THE DISTRCT FOR MOST OF MY LIFE (I AM NOW 85 YEARS OF AGE) I HAVE ALREADY SEEN ENORMOUS HOUSING DEVELOPMENTS WHICH HAVE NEVER SOLVED THE INSATIONABLE DEMAND FOR HOUSING FROM THOSE WHO WISH TO MOVE INTO SOUTH LAKELAND FROM ELSEWHERE.
THE PRESENT PROPOSALS WOULD ENCOURAGE FURTHER FLOODS OF INCOMERS RATHER THAN MEET LOCAL NEEDS.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
734. Mr & Mrs Tim & Shirley Pyzniuk (Individual) : 23 Apr 2012 10:43:00
Policy/Site No.
LA1.3 Housing Allocations - RN225-mod ARNSIDE HOLLINS LANE
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I object strongly to the development plan for Arnside; especially to the l development of 34 properties on the field on Hollins Lane. I have many concerns regarding the proposal to allow 34 houses to be built on this field on.
I feel that this development will have a negative effect on the village.
The development on Hollins Lane will have a marked impact on the properties
at the south side of the field; especially because of the gradient of the field. As
a result of the Prescription Act of 1832, the windows of my property have
earned a right of light by having well over the required 20 years of
unobstructed daylight. This law also applies to the garden; which must receive
adequate daylight on March 29th. Because of the slope of the land on Hollins
Lane any development on the field would cast a shadow over my house and
garden restricting the amount of light to my property. Therefore the
development would need to be built Ill away from my property and others on the south side of the field. This would ensure the quantity of light to the
garden and windows is not adversely affected; causing the amount of light to,
fall below the accepted level, constituting an obstruction.
The Human Rights Act 1998, Article 8 offers protection for a person's private
and family life. It has previously been used to extend protection to a person's
office space as Ill as his or her domestic home. I feel that the protection of
private life and the home is relevant to decisions made in the development
plan for Hollins Lane as any development on the field on Hollins Lane would
adversely affect my enjoyment of my property which may be an interference
with my rights under Article 8. Anyone standing in the field at the back of my
house can see directly into my rooms, part way up the field they can see
directly into my Kitchen, lounge, dining room and bedrooms. This is not'
acceptable as it impinges on my privacy.
The case for privacy has recently been highlighted in Cumbria when a
planning officer dismissed an appeal against refusal of permission for three
two-storey terraced houses in Hawkshead. This was because the proposed
development would impact on the privacy of nearby residents.
I feel that the field has been chosen for the development sole[y on the
grounds that it may be available as opposed to being suitable
735. Mr & Mrs Tim & Shirley Pyzniuk (Individual) : 23 Apr 2012 10:50:00
Policy/Site No.
LA1.3 Housing Allocations - All Arnside sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The transportation infrastructure does not adequately support the
developments planned for Arnside. The proposed development for 34 houses
on Hollins Lane will mean a large increase in traffic on Hollins Lane; this could
be as great as an extra 68 vehicles. Hollins Lane is a single-track lane with
limited passing places for vehicles, and currently struggles to accommodate
the traffic that uses it, particularly in rush hour. Hollins Lane is much busier
during the holiday season when it is frequently used as a shortcut from
Silverdale Road to Black Dyke Road by tourists.
There will be an escalation of commuter traffic because there are very few
employment opportunities in Arnside; with only tourism, land management
and local service sectors having a significant presence. The potential
increase in commuter traffic could be hazardous; especially alongside the
possible growth in numbers of young children. The likely increase in
commuter traffic is certainly not environmentally friendly; surely houses should
be built in areas which have employment opportunities so traffic pollution is
not intensified and the high cost of travelling to work is minimised.
The public transport system is inadequate to support an increase in
commuters with no buses currently running prior to 8.00 or after 18.00. The
trains do provide a more frequent and longer service; but it is a long walk to
the station from Hollins Lane which may be difficult for some such as disabled
people and individuals with young children.
Home Housing recently explored the possibility of building six houses on
Hollins Lane. After considerable time surveying the drainage available they
decided that the sewers did not have the capacity to support the additional
waste from six properties and because of the density of limestone in the field
there was not enough natural rainwater drainage on the land to sustain the
development. This raises questions regarding the feasibility of a development
of 34 properties and the ability to create suitable, sustainable drainage for
domestic waste and rainwater.
The primary school in Arnside, although not full, is nearing capacity and
certainly could not support an influx of possibly 68 new pupils from a
development on Hollins Lane; plus extra pupils from others proposed
developments in Arnside. There is no nursery provision for younger child.
and a limited number of child minders in Arnside.
As discussed in Arnside Looking Forward there is currently an adequate
supply of market housing within the Village, with over 70 dwellings available at
all price levels. The 2009 Arnside Housing Needs Survey (conducted by
Cumbria Rural Housing Trust) has shown that there is a medium-term
demand for 27 officially-rated affordable dwellings in the Village. It also
shows that that demand is mainly for rented accommodation for single adults
currently living with parents (17 out of the 27 are in this category, and 10 of
them were under 19 years of age; possibly students who will probably soon
leave home to study at University). There were only four families with young
children identified by the CRHT study as in need of affordable housing. These
figures have not been updated recently.
The development plans for Arnside do not fully take into account the housing
needs of the local community nor does it respect the opinions and
suggestions of local residents.
736. Mr & Mrs Tim & Shirley Pyzniuk (Individual) : 23 Apr 2012 10:57:00
Policy/Site No.
SO Site Omission
If you have selected a ‘Site omission’ please enter the site reference or location and relevant policy below
MN20
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
One has to question why other more suitable site have not been chosen as there are many other more suitable sites in Arnside. The sites are highlighted in the recent draft document Arnside Looking Forward published by Arnside Parish plan Trust http://arnside.gov.uk/Arnside_Parish_Plan.html
Station Yard - This brownfield site is MN 20 in the SLDC Land Allocations Development Plan Document. (.CU 778804, CU251417
and CU41881).
737. Mr & Mrs Tim & Shirley Pyzniuk (Individual) : 23 Apr 2012 11:00:00
Policy/Site No.
LA1.3 Housing Allocations - Site Omission
If you have selected a ‘Site omission’ please enter the site reference or location and relevant policy below
Trafalgar Garage - This is another brown field site that SDLC did not
initially include this obvious possibility which is now designated RN269
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
One has to question why other more suitable sites have not been chosen as there are
many other more suitable sites in Arnside. The sites are highlighted in the
recent draft document Arnside Looking Forward published by Arnside Parish
Plan Trust http:l/arnside.qov.uk/Arnside Parish Plan.html.
Trafalgar Garage - This is another brown field site that SDLC did not
initially include this obvious possibility which is now designated RN269
738. Mr & Mrs Tim & Shirley Pyzniuk (Individual) : 23 Apr 2012 11:04:00
Policy/Site No.
LA1.3 Housing Allocations - Site Omission
If you have selected a ‘Site omission’ please enter the site reference or location and relevant policy below
The old Telephone Exchange (CU173479 this brownfield and infill site
is part of R393.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
One has to question why other more suitable sites have not been chosen as there are
many other more suitable sites in Arnside. The sites are highlighted in the
recent draft document Arnside Looking Forward published by Arnside Parish
Plan Trust http:l/arnside.qov.uk/Arnside Parish Plan.html.
The old Telephone Exchange (CU173479 this brownfield and infill site
is part of R393.
739. Mr & Mrs Tim & Shirley Pyzniuk (Individual) : 23 Apr 2012 11:07:00
Policy/Site No.
LA1.3 Housing Allocations - Site Omission
If you have selected a ‘Site omission’ please enter the site reference or location and relevant policy below
Land on the south side of Red Hills Road title number CU149475
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
One has to question why other more suitable sites have not been chosen as there are
many other more suitable sites in Arnside. The sites are highlighted in the
recent draft document Arnside Looking Forward published by Arnside Parish
Plan Trust http:l/arnside.qov.uk/Arnside Parish Plan.html.
Land on the south side of Red Hills Road title number CU149475
740. Mrs Helen Rawsthorn (Individual) : 11 Apr 2012 17:23:00
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I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - M9M2-mod MILNTHORPE NORTH WEST OF MILNTHORPE
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The scale of proposed development is grossly disproportionate to the size of the site in question and would cause unacceptable negative impact on the village landscape.
As an elevated site, the buildings would be highly visible not only from the neighbouring Dallam Chase and Grisleymires Lane but also from Church Street, Kirkgate and the area to the north of the village and from Dallam Tower Estate and the area to the south, meaning that the impact would be visually intrusive on a wide scale.
The nearby Booths development and the proposed commercial sites next to Houghton's coachworks already detract from the appearance of this corner of the village and more development would only serve to further destroy the character of the village.
Access to this site is already a safety issue due to the business traffic via Grisleymires Lane, that includes many large lorries to both the coachworks and Booths. Further development here would serve to exacerbate the problem.
Drainage and sewerage systems are already highly temperamental and placing any number of houses on this site would add further unnecessary pressure.
This greenfield site is also in constant farming use (for the grazing of both cows and sheep and for silage, cut here several times throughout the year) so is already an active working part of the village and necessary to the essential village character of Milnthorpe.
The hedgerows are full of wildlife and are essential for the bats and birds, which nest and feed. It is vital that they remain in place. Surely there are alternative places and empty buildings available for housing without using vital farmland and wildlife habitat.
741. Mr David Raymond (Individual) : 12 Apr 2012 22:40:00
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I have read the guidance notes
Paragraph No.
0.1 Section 1
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
It is CLEARLY NOT SUSTAINABLE to build 100's of homes year after year on green field sites. It will compromise the ability of futire generations to meet their needs by reducing the amount of land for agriculture, increase the stress on water supplies etc.
The proposed developments are also in conflict with the environmental objectives (section 4.16) and natural resource objectives (section 4.18) of the Sustainability Appraisal.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
742. Mr David Raymond (Individual) : 15 May 2012 13:58:00
Paragraph No.
0.0 Whole Document
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
It is CLEARLY NOT SUSTAINABLE to build 100's of homes year after year on green field sites. It will compromise the ability of futire generations to meet their needs by reducing the amount of land for agriculture, increase the stress on water supplies etc.
The proposed developments are also in conflict with the environmental objectives (section 4.16) and natural resource objectives (section 4.18) of the Sustainability Appraisal.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
743. Mr David Raymond (Individual) : 15 May 2012 13:59:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
1.12
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
It is CLEARLY NOT SUSTAINABLE to build 100's of homes year after year on green field sites. It will compromise the ability of futire generations to meet their needs by reducing the amount of land for agriculture, increase the stress on water supplies etc.
The proposed developments are also in conflict with the environmental objectives (section 4.16) and natural resource objectives (section 4.18) of the Sustainability Appraisal.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
744. Mrs Olive Norma Reddish (Individual) : 23 Mar 2012 00:05:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - R339# ALLITHWAITE LAND SOUTH OF GREEN LANE
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
On the first consultation you asked for comments on Field R339 which we gave. Also our opinions on other sites and the plan in general.
Field R339 then appeared on the next consultation document as an important Green open space giving the impression that it was not going to be considered for housing and field R69 was a proposed site to be considered for housing.
It would appear that after further representation of both the owner of field R339 and of the steering committee that it has been decided to substute R69 for R339.
Due to the fact that I was unavailable to attend the Public meeting and my belief was that the document proposals by South lakeland that R339 would remain a green area would be held.
I was somewhat surprised to find that these proposal had been changed. My concerns are to the change of plans and the effect upon Green Lane/Vicarage Road. I believe that the majority of residents in the Green Lane/ Vicarage Road/ Templand Garth end of the village would also be under the same misapprehension that I was.
The proposal to build more housing in Allithwaite is not proven or justified, especially when the village house is offered for a low rent to local people and the Parish Council says that it is finding it difficult to find a suitable local family.
This tends to indicate that the low cost property will not be set at a price that the local people will be able to buy and the homes will go as 'high price' second homes, further eroding village life. The low cost housing on the Greendales site in the village I believe also had difficulty in attracting local buyers due to their cost. There are still properties in the village that have been for sale for a long period of time which would make one wonder if more housing was necessary.
From past experience once a farmer has sold a couple of fields because 'they were a distance away from the farm' or other such excuses the next step is that it is no longer economical to farm the fields he has left so they become more housing. Boothstown in Lancashire, where we previously lived, increased by at least 4 times it size in 10 years, most of it on green fields. This field is only a stones throw away from it's farm. As our previous comments stated Green Lane/ Vicarage Road are too narrow to take the traffic that not only further housing would bring but also the heavy traffic that the building of such properties would entail. It would remove what is the only green area in this part of the village, a site which would be enjoyed by all Green Lane if the farmer had not obscured the view from its residents by allowing the trees/bushes to remain untrimmed for many years.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
745. Mrs Olive Norma Reddish (Individual) : 10 Apr 2012 22:42:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - R339# ALLITHWAITE LAND SOUTH OF GREEN LANE
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The recent proposal that this site should be accepted in preference to other sites around the village does not take account of previous applications for the field to have houses built upon it which have been refused. The reasons for refusal have not changed as the last decision of the 20/04/1993 stated:-
Planning application No. 5930396
Conditions/Reason for refusal: 5/93/0396 LOWER ALLITHWAITE: Land off Green Lane,Allithwaite. Affordable Housing [18 dwellings] [Listed Building adj] [Priory Building] REFUSED for the reason below:-
[1] The site is not allocated for development in the Cartmel and Furness Local Plan and forms an important open space in the village that development in the form of the submitted location, layout and design would detract from the attractive charactor of this part of the village in a manner which would be unnaceptable even if the dwellings met a local housing need and would moreover by reason of its layout encourage further development to the greater detriment of the charactor of the locality.
Since this refused application the land is now being offered with a proposal for 22 houses, a village green area and an extention to the existing graveyard. This is a hypothetical proposal. If a developer obtains this land it would not be in their financial interest to follow this hyperthetical proposal and would result in the field being developed fully to realise the maximum profit. Property developers are not altruistic. Also it is not as easy to sell properties which encroach upon graveyards, especially one's as St Mary's which is in current use and due to the loss of many trees over recent years the excavation of graves carried out with 'diggers' can already be observed.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
746. Mrs Olive Norma Reddish (Individual) : 11 May 2012 10:32:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - All Allithwaite sites
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The proposal to build more housing in Allithwaite is not proven or justified, especially when the village house is offered for a low rent to local people and the Parish Council says that it is finding it difficult to find a suitable local family.
This tends to indicate that the low cost property will not be set at a price that the local people will be able to buy and the homes will go as 'high price' second homes, further eroding village life. The low cost housing on the Greendales site in the village I believe also had difficulty in attracting local buyers due to their cost. There are still properties in the village that have been for sale for a long period of time which would make one wonder if more housing was necessary.
From past experience once a farmer has sold a couple of fields because 'they were a distance away from the farm' or other such excuses the next step is that it is no longer economical to farm the fields he has left so they become more housing. Boothstown in Lancashire, where we previously lived, increased by at least 4 times it size in 10 years, most of it on green fields. This field is only a stones throw away from it's farm. As our previous comments stated Green Lane/ Vicarage Road are too narrow to take the traffic that not only further housing would bring but also the heavy traffic that the building of such properties would entail. It would remove what is the only green area in this part of the village, a site which would be enjoyed by all Green Lane if the farmer had not obscured the view from its residents by allowing the trees/bushes to remain untrimmed for many years.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
747. Mr Stephen Reed (Individual) : 24 Apr 2012 16:44:00
Paragraph No.
0.0 Whole Document
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
1. The current proposals are based on out-of-date and unreliable evidence: The Strategic Housing Market Assessment (SHMA) is based on out of date statistics, save for the 2011 Housing Survey, which had responses from less than 10% of households in South Lakeland (4,363 responses out of 45,792 occupied dwellings) – a sample both unrepresentative of need and so unreliable as a base for long-term housing policy. Moreover, many of those replies were bald statements of personal wishes (i.e. “I wish to move home.”), and did not inform the debate.
2 The SHMA takes no account of the empty housing stock in South Lakeland in calculating housing requirement. The exact number of empty houses does not appear to have been calculated; SHMA = 1,024, SLDC 18th Jan. 2012 Council meeting = 1,500, Conservative local election leaflet April 2012 = 2,039.
3 There is no evidence that those in need of affordable housing are able to afford to buy or rent the planned “affordable” homes. Recent Westmorland Gazette articles report slow take-up on new developments suggesting that they would not. No evidence has been put forward to demonstrate where increased levels of employment, with secure, long-term, and adequate wage/salary levels, might come from to enable an uptake of such homes
4 The 2006 Housing Needs Survey concluded the area needed “416 affordable new homes every year for the following five years.” There is no evidence to link this statement to the number of people on the Housing List, or the stated target of 8800 houses.
5 The policy for building affordable new homes is entirely dependent on how many open-market houses developers will be allowed in the proposed scheme, creating an unsustainable, and probably unenforceable, “one for three” approach. The policy must demonstrate a robust exploration of all possible methods for constructing affordable homes. Overall forecasts of the need for new housing (open- market & affordable) do not appear to take into account the current economic conditions in Britain let alone in South Lakeland, (very low growth in the economy, generally stagnant personal incomes, average incomes insufficient to meet current mortgage lenders’ criteria).
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
I hereby register a request to make representations at the future public hearings of the Land Allocation DPD procedure. However, I will withdraw this request if Levens Residents Group is allowed to make representations.
748. Mr Stephen Reed (Individual) : 24 Apr 2012 16:47:00
Policy/Site No.
LA1.3 Housing Allocations - All Levens sites
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
6 The consultation documents are so complex that it is almost impossible for the average council tax payer to make a response to the soundness of the Plan, and those without access to the Internet are at an even greater disadvantage given the difficulties in obtaining printed copies of the relevant documents.
7 SLDC have a Statement of Community Involvement yet it appears they have not given full weight to the available Community documents for Levens; the 2008 Levens Village Plan and the 2008 Rural Housing Needs Survey, nor to the views expressed through the Levens Residents Association’s responses throughout the consultation process.
8 Since the consultation commenced the bus service into Levens village has been curtailed such that it is of no use for commuting for employment.The 555 bus services to Kendal & Lancaster do not enter the village and pedestrian access to them is not safe owing to the need to walk along busy roads without footpaths or street lighting. They are also too far away for pedestrian access other than by fit & active people, thereby discriminating against the elderly and disabled. The Rural Wheels scheme does not assist those going to and from work. The inevitable conclusion is that virtually all commuting to Levens by those in the newly planned houses would be by car. How does this meet any reasonable definition of “sustainable”?
9 Levens is designated a Local Service Centre. A criteria of status as a Local Service Centre is “accessibility by public transport to a GP, a hospital, a primary school, a secondary school, areas of employment and a major retail centre....within a 30-minute public transport journey..” Such public transport is no longer available to Levens Residents. In addition, the village Post Office has been lost although a part-time (three afternoons per week) service comes from Grange-over-Sands.
10 The proposed development in Levens will add estates of houses which cannot add to the sustainable community described in Core Strategy section 1.39.
11 Given the history of development in Levens, and the manner in which SLDC have dealt with the Parish Council and individual objections and comments in the past, any further development must only be allowed subject to a Development Brief.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
I hereby register a request to make representations at the future public hearings of the Land Allocation DPD procedure. However, I will withdraw this request if Levens Residents Group is allowed to make representations.
749. Mr Charles Reid (Individual) : 23 Apr 2012 12:35:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - All Grange-over-Sands sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not consistent with national policy.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The plans are not effective, justified or consistent with national strategy for the
following reasons:-
Lib. Dem. Controlled SLDC has completely ignored the wishes of local residents
who are completely opposed to these plans.
The plans are against SLDC's own policies on protecting green gaps and avoiding
Grange over Sands and Allithwaite having no open space between them.
The plan does not suggest other options for providing affordable housing other than
total destruction of green spaces.
The plan is based on the no longer applicable Regional Spatial Strategy and out date figures on population surveys and the number of houses proposed will not be required.
SLDC plans will.harm the local tourist industry which is vital to Grange over Sands and the surroundmg area.
!he cumulative effect of development across the whole Cartmel peninsula has been
ignored.
The infrastructure of Grange over Sands cannot cope with all these extra houses. The
roads in particular could not cope with the extra traffic generated especially in Main Street Grange and Risedale Hill. There would be increased risk of surface water flooding. There would be inadequate school places and primary health care facilities to cope with the extra population. There are no plans to improve any of these.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
750. Mr Charles Reid (Individual) : 23 Apr 2012 12:37:00
Policy/Site No.
LA1.3 Housing Allocations - All Allithwaite sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The plans are against SLDC's own policies on protecting green gaps and avoiding
Grange over Sands and Allithwaite having no open space between them.
The plan does not suggest other options for providing affordable housing other than
total destruction of green spaces.
The plan is based on the no longer applicable Regional Spatial Strategy and out date figures on population surveys and the number of houses proposed will not be required.
SLDC plans will harm the local tourist industry which is vital to Grange over Sands and the surrounding area.
The cumulative effect of development across the whole Cartmel peninsula has been
ignored.
751. Mr Charles Reid (Individual) : 23 Apr 2012 12:39:00
Policy/Site No.
LA1.3 Housing Allocations - All Cartmel sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The plan does not suggest other options for providing affordable housing other than
total destruction of green spaces.
The plan is based on the no longer applicable Regional Spatial Strategy and out date figures on population surveys and the number of houses proposed will not be required.
SLDC plans will harm the local tourist industry which is vital to Grange over Sands and the surrounding area.
The cumulative effect of development across the whole Cartmel peninsula has been
ignored.
752. Mr Charles Reid (Individual) : 23 Apr 2012 12:41:00
Policy/Site No.
LA1.3 Housing Allocations - All Flookburgh sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The plan does not suggest other options for providing affordable housing other than
total destruction of green spaces.
The plan is based on the no longer applicable Regional Spatial Strategy and out date figures on population surveys and the number of houses proposed will not be required.
SLDC plans will harm the local tourist industry which is vital to Grange over Sands and the surrounding area.
The cumulative effect of development across the whole Cartmel peninsula has been
ignored.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
753. Mr Charles Reid (Individual) : 30 Apr 2012 14:09:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA3.1 Mixed Use Allocation at Berners Pool, Grange-over-Sands
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The plans are not effective, justified or consistent with national strategy for the
following reasons:-
Lib. Dem. Controlled SLDC has completely ignored the wishes of local residents
who are completely opposed to these plans.
The plans are against SLDC's own policies on protecting green gaps and avoiding
Grange over Sands and Allithwaite having no open space between them.
The plan does not suggest other options for providing affordable housing other than
total destruction of green spaces.
The plan is based on the no longer applicable Regional Spatial Strategy and out date figures on population surveys and the number of houses proposed will not be required.
SLDC plans will.harm the local tourist industry which is vital to Grange over Sands and the surroundmg area.
!he cumulative effect of development across the whole Cartmel peninsula has been
ignored.
The infrastructure of Grange over Sands cannot cope with all these extra houses. The
roads in particular could not cope with the extra traffic generated especially in Main Street Grange and Risedale Hill. There would be increased risk of surface water flooding. There would be inadequate school places and primary health care facilities to cope with the extra population. There are no plans to improve any of these.
754. Mr Charles Reid (Individual) : 30 Apr 2012 14:11:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA3.2 Mixed Use Allocation at Land South of Allithwaite Road, Kent's Bank, Grange-over-Sands
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The plans are not effective, justified or consistent with national strategy for the
following reasons:-
Lib. Dem. Controlled SLDC has completely ignored the wishes of local residents
who are completely opposed to these plans.
The plans are against SLDC's own policies on protecting green gaps and avoiding
Grange over Sands and Allithwaite having no open space between them.
The plan does not suggest other options for providing affordable housing other than
total destruction of green spaces.
The plan is based on the no longer applicable Regional Spatial Strategy and out date figures on population surveys and the number of houses proposed will not be required.
SLDC plans will.harm the local tourist industry which is vital to Grange over Sands and the surroundmg area.
!he cumulative effect of development across the whole Cartmel peninsula has been
ignored.
The infrastructure of Grange over Sands cannot cope with all these extra houses. The
roads in particular could not cope with the extra traffic generated especially in Main Street Grange and Risedale Hill. There would be increased risk of surface water flooding. There would be inadequate school places and primary health care facilities to cope with the extra population. There are no plans to improve any of these.
755. Mr Charles Reid (Individual) : 30 Apr 2012 14:13:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA3.3 Mixed Use Allocation at Guide's Lot, Grange-over-Sands
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The plans are not effective, justified or consistent with national strategy for the
following reasons:-
Lib. Dem. Controlled SLDC has completely ignored the wishes of local residents
who are completely opposed to these plans.
The plans are against SLDC's own policies on protecting green gaps and avoiding
Grange over Sands and Allithwaite having no open space between them.
The plan does not suggest other options for providing affordable housing other than
total destruction of green spaces.
The plan is based on the no longer applicable Regional Spatial Strategy and out date figures on population surveys and the number of houses proposed will not be required.
SLDC plans will.harm the local tourist industry which is vital to Grange over Sands and the surroundmg area.
!he cumulative effect of development across the whole Cartmel peninsula has been
ignored.
The infrastructure of Grange over Sands cannot cope with all these extra houses. The
roads in particular could not cope with the extra traffic generated especially in Main Street Grange and Risedale Hill. There would be increased risk of surface water flooding. There would be inadequate school places and primary health care facilities to cope with the extra population. There are no plans to improve any of these.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
756. Mr Charles Reid (Individual) : 30 Apr 2012 14:15:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.8 Local Employment Allocations - EN42# CARK STATION YARD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The plans are not effective, justified or consistent with national strategy for the
following reasons:-
Lib. Dem. Controlled SLDC has completely ignored the wishes of local residents
who are completely opposed to these plans.
The plans are against SLDC's own policies on protecting green gaps and avoiding
Grange over Sands and Allithwaite having no open space between them.
The plan does not suggest other options for providing affordable housing other than
total destruction of green spaces.
The plan is based on the no longer applicable Regional Spatial Strategy and out date figures on population surveys and the number of houses proposed will not be required.
SLDC plans will.harm the local tourist industry which is vital to Grange over Sands and the surroundmg area.
!he cumulative effect of development across the whole Cartmel peninsula has been
ignored.
The infrastructure of Grange over Sands cannot cope with all these extra houses. The
roads in particular could not cope with the extra traffic generated especially in Main Street Grange and Risedale Hill. There would be increased risk of surface water flooding. There would be inadequate school places and primary health care facilities to cope with the extra population. There are no plans to improve any of these.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
757. Mr Glenn Rhodes (Individual) : 17 Mar 2012 20:09:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - R697 & part R242 ULVERSTON CROFTLANDS EAST
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The Land Allocations Document (DPD) is not within the Local Development Scheme and the key stages have not been followed
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not been prepared in accordance with the Town & County Planning Regulations 2004 (as amended)
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
The DPD has not had regard to the Sustainable Community Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I have no idea whether its legal or not in the same way that hundreds of other residents wouldn't.
Is it being carried out fairly and in an unbiased and morally correct way (whether legal or not) is a question most would be concerned with.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
This has not been a consultation process but has no doubt satisifed legal requirements as such. To really consult involves letters through doors so that everyone is informed of the plans not just those who have access to the internet or who buy the Evening Mail.
My views are applicable to all of Ulverston and not just to the one boxed area i was permitted to tick.
I am very much in favour of the next generation having work and housing in the area but no evidence is presented that this will be the case as only 35% of housing is designated as being affordable and 60% of that will be social rented (therefore only 21% of all housing will be social rented). What will the rest be, unaffordable AND offensive to the eye? Is it predicted that without these 1193 houses there will be a few thousand homeless people in Ulverston? If not, this is one huge and expensive gamble. If so, demonstrate it. There is no evidence presented of where all the people who will take up these houses will come from. Equally there is no guarantee presented that housing will be taken up by locally employed people and no account of that it will NOT be taken up by rich outsiders looking for a second home?
The local taxpayer will clearly pay for these houses, but who will own them once built? The council or a Private funding initiative (or equivalent) that we will pay extra council tax for generations to come?
This whole document is designed to be only understood by experts and does not allow open and free answers from ordinary people. This is not consultation, its clever and devious manipulation of public opinion to fit a template of pre-designed responses made to be less troublesome to those involved.
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
A sensible plan based upon obvious and DEMONSTRATED local demand would receive my full support. As this does not fit that criterion. It doesn't receive my support.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
So that my views, which represent those of a considerable number of the ordinary community are heard in full.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
758. Mr Glenn Rhodes (Individual) : 15 May 2012 13:51:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - All Ulverston sites
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The Land Allocations Document (DPD) is not within the Local Development Scheme and the key stages have not been followed
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not been prepared in accordance with the Town & County Planning Regulations 2004 (as amended)
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
The DPD has not had regard to the Sustainable Community Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Ihave no idea whether its legal or not in the same way that hundreds of other residents wouldn't.
Is it being carried out fairly and in an unbiased and morally correct way (whether legal or not) is a question most would be concerned with.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
This has not been a consultation process but has no doubt satisifed legal requirements as such. To really consult involves letters through doors so that everyone is informed of the plans not just those who have access to the internet or who buy the Evening Mail.
My views are applicable to all of Ulverston and not just to the one boxed area i was permitted to tick.
I am very much in favour of the next generation having work and housing in the area but no evidence is presented that this will be the case as only 35% of housing is designated as being affordable and 60% of that will be social rented (therefore only 21% of all housing will be social rented). What will the rest be, unaffordable AND offensive to the eye? Is it predicted that without these 1193 houses there will be a few thousand homeless people in Ulverston? If not, this is one huge and expensive gamble. If so, demonstrate it. There is no evidence presented of where all the people who will take up these houses will come from. Equally there is no guarantee presented that housing will be taken up by locally employed people and no account of that it will NOT be taken up by rich outsiders looking for a second home?
The local taxpayer will clearly pay for these houses, but who will own them once built? The council or a Private funding initiative (or equivalent) that we will pay extra council tax for generations to come?
This whole document is designed to be only understood by experts and does not allow open and free answers from ordinary people. This is not consultation, its clever and devious manipulation of public opinion to fit a template of pre-designed responses made to be less troublesome to those involved.
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
A sensible plan based upon obvious and DEMONSTRATED local demand would receive my full support. As this does not fit that criterion. It doesn't receive my support
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
So that my views, which represent those of a considerable number of the ordinary community are heard in full.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
759. Mr Glenn Rhodes (Individual) : 15 May 2012 13:54:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
1.9
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The Land Allocations Document (DPD) is not within the Local Development Scheme and the key stages have not been followed
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not been prepared in accordance with the Town & County Planning Regulations 2004 (as amended)
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
The DPD has not had regard to the Sustainable Community Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I have no idea whether its legal or not in the same way that hundreds of other residents wouldn't.
Is it being carried out fairly and in an unbiased and morally correct way (whether legal or not) is a question most would be concerned with.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
This has not been a consultation process but has no doubt satisifed legal requirements as such. To really consult involves letters through doors so that everyone is informed of the plans not just those who have access to the internet or who buy the Evening Mail.
My views are applicable to all of Ulverston and not just to the one boxed area i was permitted to tick.
I am very much in favour of the next generation having work and housing in the area but no evidence is presented that this will be the case as only 35% of housing is designated as being affordable and 60% of that will be social rented (therefore only 21% of all housing will be social rented). What will the rest be, unaffordable AND offensive to the eye? Is it predicted that without these 1193 houses there will be a few thousand homeless people in Ulverston? If not, this is one huge and expensive gamble. If so, demonstrate it. There is no evidence presented of where all the people who will take up these houses will come from. Equally there is no guarantee presented that housing will be taken up by locally employed people and no account of that it will NOT be taken up by rich outsiders looking for a second home?
The local taxpayer will clearly pay for these houses, but who will own them once built? The council or a Private funding initiative (or equivalent) that we will pay extra council tax for generations to come?
This whole document is designed to be only understood by experts and does not allow open and free answers from ordinary people. This is not consultation, its clever and devious manipulation of public opinion to fit a template of pre-designed responses made to be less troublesome to those involved.
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
A sensible plan based upon obvious and DEMONSTRATED local demand would receive my full support. As this does not fit that criterion. It doesn't receive my support.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
So that my views, which represent those of a considerable number of the ordinary community are heard in full.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
760. Miss Helen Rice (Individual) : 17 Apr 2012 10:35:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.1 Development Boundaries- ULVERSTON
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The number of houses planned for Ulverston is out of proportion to its housing needs, and doesn't take into account the negative effect it would have on the infrastructure to the town - roads and traffic, schools, amenities etc.
Greenfield sites should not be built on when there are brownfield sites available in the local area - the brownfield site running alongside the canal could be regenerated by building affordable apartments, and Barrow-in-Furness, the nearest town to Ulverston, has brownfield sites suitable for housing.
Regarding specifically R242 and adjoining plots - an underground watercourse runs through these plots and floods upto the town boundary after prolonged rainfall. Any building over this watercourse could further restrict drainage and cause flooding to Croftlands estate.
The need for housing should be planned for on a much more local level - the Regional Spatial Strategy for which the DPD was originally instigated has since been retracted from current government policy.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
761. Miss Helen Rice (Individual) : 11 May 2012 08:49:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - R690ulv, R691ULV, R126M, RN184, RN234# & part R242 ULVERSTON CROFTLANDS WEST - NOOK FARM
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Regarding specifically R242 and adjoining plots - an underground watercourse runs through these plots and floods upto the town boundary after prolonged rainfall. Any building over this watercourse could further restrict drainage and cause flooding to Croftlands estate.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
762. Miss Helen Rice (Individual) : 11 May 2012 09:21:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
0.0 Whole Document
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The number of houses planned for Ulverston is out of proportion to its housing needs, and doesn't take into account the negative effect it would have on the infrastructure to the town - roads and traffic, schools, amenities etc.
Greenfield sites should not be built on when there are brownfield sites available in the local area - the brownfield site running alongside the canal could be regenerated by building affordable apartments, and Barrow-in-Furness, the nearest town to Ulverston, has brownfield sites suitable for housing.
Regarding specifically R242 and adjoining plots - an underground watercourse runs through these plots and floods upto the town boundary after prolonged rainfall. Any building over this watercourse could further restrict drainage and cause flooding to Croftlands estate.
The need for housing should be planned for on a much more local level - the Regional Spatial Strategy for which the DPD was originally instigated has since been retracted from current government policy.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
763. Mrs Sharon Ritchie (Individual) : 4 Apr 2012 15:26:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.1 Development Boundaries- PENNY BRIDGE/GREENODD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The DPD has not had regard to the Sustainable Community Strategy
The Land Allocations Document (DPD) is not within the Local Development Scheme and the key stages have not been followed
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not been prepared in accordance with the Town & County Planning Regulations 2004 (as amended)
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The LDF document refers to the site as being an infill site which is inaccurate as ther is no existin development to the south of the field and it can easily be argued that development would not constitute "rounding off" and that it would not be well located in relating to existing services and facilities. There are mature trees boardering two sites shielding the Church and existing dwellings on R291 the beech trees to the south of the field represent a significant danger to any future development. The reference that the development would "safeguard the Crakeside Business Park and Works as local employment areas" is tenuous at best there is available housing in nereby Ulverston, Lowick, Bouth, Haverthwaite but to name a few.
The Parish Council Survey did not reveal a need for housing - in fact there are at least 9 for sale and 4 second homes/holiday lets.
In addition to the above devaluation of existing properties, threat to wildlife, loss of light serious risk of sewage and flooding problems, noise, pollution, no spaces at primary school, traffic, parking problems, total loss of views from the church over the village and beyond loss of peace to people visiting loved ones graves but too name a few.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Buy the properties for sale and rent them out. Find suitable land for building not green agricultrual land.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
764. Mrs Sharon Ritchie (Individual) : 11 May 2012 16:33:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - RN152 GREENODD LAND AT THE OLD VICARAGE
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The Land Allocations Document (DPD) is not within the Local Development Scheme and the key stages have not been followed
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not been prepared in accordance with the Town & County Planning Regulations 2004 (as amended)
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
The DPD has not had regard to the Sustainable Community Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The LDF document refers to the site as being an infill site which is inaccurate as ther is no existin development to the south of the field and it can easily be argued that development would not constitute "rounding off" and that it would not be well located in relating to existing services and facilities. There are mature trees boardering two sites shielding the Church and existing dwellings on R291 the beech trees to the south of the field represent a significant danger to any future development. The reference that the development would "safeguard the Crakeside Business Park and Works as local employment areas" is tenuous at best there is available housing in nereby Ulverston, Lowick, Bouth, Haverthwaite but to name a few.
The Parish Council Survey did not reveal a need for housing - in fact there are at least 9 for sale and 4 second homes/holiday lets.
In addition to the above devaluation of existing properties, threat to wildlife, loss of light serious risk of sewage and flooding problems, noise, pollution, no spaces at primary school, traffic, parking problems, total loss of views from the church over the village and beyond loss of peace to people visiting loved ones graves but too name a few.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Buy the properties for sale and rent them out. Find suitable land for building not green agricultrual land.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
765. Mr & Mrs Tim & Ave Roberts (Individual) : 19 Apr 2012 11:42:00
Policy/Site No.
LA1.3 Housing Allocations - All Grange-over-Sands sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Although there have been some reductions in the sites allocated for development in Grange-over-Sands, the SLDC proposals to
go ahead with 497 houses in this area continue to cause great concerns. The effect on the infrastructure on a small town such as Grange-over-Sands would be disastrous
Whilst supporting the necessity to provide additional housing, the longer considerations of th SLDC do not make immediate sese or logic. There does not appear to be an increase of jobs in the SLDC area and therefore the demands for more houses seems illogical unless there is a further proposal to induce more industry or jobs in South Lakes. Grange-over-Sands without a major restructuring of the town and local district would not lend itself to increasing industry unless it was related to tourism.
At the edge of the National Park further building would defeat the main local industry of tourism as the many visitors come to see the wide open and beautiful contryside not more housing or industrial estates that can be seen in most of the rest of the country.
Before embarking on any further building in the area, the SLDC must take a more considered, long term view of what their present strategy will result in if they wish to maintain the Lakes as a tourist venue.
If there is truly a genuine demand to build additional housing can the SLDC choose areas that are more discreet, closer to main transport arteries and preferably on "brownsite" land that has no impact on environmental, agricultural, historical or geological interestsWe would be grateful to be kept informed of future developments.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
766. Mr & Mrs Tim & Ave Roberts (Individual) : 10 May 2012 14:49:00
Policy/Site No.
LA3.1 Mixed Use Allocation at Berners Pool, Grange-over-Sands
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Although there have been some reductions in the sites allocated for development in Grange-over-Sands, the SLDC proposals to
go ahead with 497 houses in this area continue to cause great concerns. The effect on the infrastructure on a small town such as Grange-over-Sands would be disastrous
Whilst supporting the necessity to provide additional housing, the longer considerations of th SLDC do not make immediate sese or logic. There does not appear to be an increase of jobs in the SLDC area and therefore the demands for more houses seems illogical unless there is a further proposal to induce more industry or jobs in South Lakes. Grange-over-Sands without a major restructuring of the town and local district would not lend itself to increasing industry unless it was related to tourism.
At the edge of the National Park further building would defeat the main local industry of tourism as the many visitors come to see the wide open and beautiful contryside not more housing or industrial estates that can be seen in most of the rest of the country.
Before embarking on any further building in the area, the SLDC must take a more considered, long term view of what their present strategy will result in if they wish to maintain the Lakes as a tourist venue.
If there is truly a genuine demand to build additional housing can the SLDC choose areas that are more discreet, closer to main transport arteries and preferably on "brownsite" land that has no impact on environmental, agricultural, historical or geological interestsWe would be grateful to be kept informed of future developments.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
767. Mr & Mrs Tim & Ave Roberts (Individual) : 10 May 2012 14:50:00
Policy/Site No.
LA3.2 Mixed Use Allocation at Land South of Allithwaite Road, Kent's Bank, Grange-over-Sands
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Although there have been some reductions in the sites allocated for development in Grange-over-Sands, the SLDC proposals to
go ahead with 497 houses in this area continue to cause great concerns. The effect on the infrastructure on a small town such as Grange-over-Sands would be disastrous
Whilst supporting the necessity to provide additional housing, the longer considerations of th SLDC do not make immediate sese or logic. There does not appear to be an increase of jobs in the SLDC area and therefore the demands for more houses seems illogical unless there is a further proposal to induce more industry or jobs in South Lakes. Grange-over-Sands without a major restructuring of the town and local district would not lend itself to increasing industry unless it was related to tourism.
At the edge of the National Park further building would defeat the main local industry of tourism as the many visitors come to see the wide open and beautiful contryside not more housing or industrial estates that can be seen in most of the rest of the country.
Before embarking on any further building in the area, the SLDC must take a more considered, long term view of what their present strategy will result in if they wish to maintain the Lakes as a tourist venue.
If there is truly a genuine demand to build additional housing can the SLDC choose areas that are more discreet, closer to main transport arteries and preferably on "brownsite" land that has no impact on environmental, agricultural, historical or geological interestsWe would be grateful to be kept informed of future developments.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
768. Mr & Mrs Tim & Ave Roberts (Individual) : 10 May 2012 14:51:00
Policy/Site No.
LA3.3 Mixed Use Allocation at Guide's Lot, Grange-over-Sands
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Although there have been some reductions in the sites allocated for development in Grange-over-Sands, the SLDC proposals to
go ahead with 497 houses in this area continue to cause great concerns. The effect on the infrastructure on a small town such as Grange-over-Sands would be disastrous
Whilst supporting the necessity to provide additional housing, the longer considerations of th SLDC do not make immediate sese or logic. There does not appear to be an increase of jobs in the SLDC area and therefore the demands for more houses seems illogical unless there is a further proposal to induce more industry or jobs in South Lakes. Grange-over-Sands without a major restructuring of the town and local district would not lend itself to increasing industry unless it was related to tourism.
At the edge of the National Park further building would defeat the main local industry of tourism as the many visitors come to see the wide open and beautiful contryside not more housing or industrial estates that can be seen in most of the rest of the country.
Before embarking on any further building in the area, the SLDC must take a more considered, long term view of what their present strategy will result in if they wish to maintain the Lakes as a tourist venue.
If there is truly a genuine demand to build additional housing can the SLDC choose areas that are more discreet, closer to main transport arteries and preferably on "brownsite" land that has no impact on environmental, agricultural, historical or geological interestsWe would be grateful to be kept informed of future developments.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
769. Dr Stanley Robinson (Individual) : 19 Mar 2012 16:09:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - Site Omission
If you have selected a ‘Site omission’ please enter the site reference or location and relevant policy below
R144
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The Land Allocations Document (DPD) is not within the Local Development Scheme and the key stages have not been followed
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
The DPD has not had regard to the Sustainable Community Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I consider that the proposed new housing development to the east of Long Meadow Lane (adjacent to my home) should be refused on traffic grounds in that the two main access roads linking Natland with the A65 road - Oxenholme Lane and Holme Lane do not have the capacity to accomodate the new traffic which would be generated by this and other proposed development in and around Natland
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Refrain from additional housing and the other development in the area to the east of Long Meadow Lane and other parts of Natland on traffic grounds. The road links named do not have the capacity to accommodate the additional traffic that would be generated by the proposed developments
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
770. Mrs Marilyn Robinson (Individual) : 9 May 2012 16:01:00
Policy/Site No.
LA1.3 Housing Allocations - R121M-mod KENDAL EAST OF CASTLE GREEN ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I write to object to the continued inclusion ofthe above site in SLDC's plans.
We were told at a meeting of residents that it was likely that because the site would be
difficult and expensive to develop, we could be assured that the houses built on this
site would be larger than average. This suggests that houses built here will not help to
alleviate the problems faced by local people seeking homes in the area.
I think that the plans do not comply with legislation. The council appear not to have
taken into account earlier plans for development, where this site was excluded for
reasons oflandscape. Nor have they had regard to the independent survey
commissioned by Kendal Town Council, nor to the report from the Friends of the
Lake District. This indicates a failure to have a meaningful consultation with the
local community.
There is no evidence that plans to develop this site are deliverable. Earlier objections
referred to concerns regarding the serious flooding risk in this area and the pressure
that further development would put on the Stockbeck Flood Relief scheme. There
were also concerns about access and the provision of basic services. There has been
no attempt in the final document to allay people's concerns in these areas, and the site
still appears difficult to develop without unreasonable and possibly dangerous
disruption to the surrounding area.
771. Mr Austen Robinson (Individual) : 17 May 2012 15:38:00
A typed or handwritten document was submitted. This has been scanned and can be downloaded below:
Policy/Site No.
LA1.3 Housing Allocations - R121M-mod KENDAL EAST OF CASTLE GREEN ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
[The following submission should be read in conjunction with the attached appendices - see attached file)
Please find below my response to the possible inclusion of land off Castle Green Lane for development, and also my/our serious concerns about the unsoundness of the proposals put forward by SLDC for the rest of South Lakes, and Kendal in particular.
I am writing as an individual and also as a committee member of SOLEK (Save Our
Landscape East Kendal).
We consider that the DPD, with reference to Rl2lm and in general, is not justified because:
• Key decisions are not supported by a sufficiently wide evidence base.
• The LPA has not taken on board some very important evidence. \
• Sufficient site preparation has not been undertaken.
• It has failed to provide the most appropriate strategy when considered against reasonable alternatives.
• Landscape and other policies (flooding and biodiversity) are not being adhered to.
The DPD is also not effective in that
• It is not deliverable, because it does not have a robust, realistic and sound infrastructure delivery plan.
Whilst I/we recognise that SLDC has been gradually reducing the size of this site, I will continue to argue very strongly that the site R121M should be removed totally from all consideration for development.
Additional Initial Information/Documentation Required
• I would ask that SLDC provide you with a supplementary map showing the extent of the original site- R56, R141, R121, R677K, R676KE (with separate field designations and contours).
• I would also ask that you and we be provided with a site map that gives some clear indication as to where the diagonal boundary line crosses R56 and R141, an explanation as to why it is a straight line to the top comer of R141 and not one respecting the serious topographical, landscape, flooding, biodiversity and access problems.
• The site map continues to misrepresent the size of the pond(s), the gulley, the water course and the reed beds in R677K, R56 and R141 and the LPA should be asked to provide a corrected and correctly labelled plan/diagram, (including also the orchard at the top of R56). Appendix 6 shows it better, but this representation is well out of date.
Background Information
SLDC Strategic Documentation (2008)
Significantly in April 2008 there was NO indication in the LDF document of that date that this part of Kendal was viewed as an area of potential growth (Appendix 1). This was a strategic document put out by SLDC for comment, and highlighted that, although they saw potential expansion in most directions for Kendal, they did not consider the Castle Green area as suitable for expansion- on sound planning grounds, one must assume.
I would request that this document be used as part of the LPA's evidence base, as it is unsound to exclude it.
Planning History (1997)
SLDC refuses to consider ANY previous planning decisions, and thereby acts in an unreasonable and unsound manner. Matters should be judged on their merits.
In 1997 R56 was put forward for development as part of the local process at the
'deposit stage' but later rejected by the Inspector at the Local Plan Inquiry. The main findings at the Local Inquiry (Appendix 2) were that:
1. "This is a visually important link between the open land west of Castle
Green Lane and the higher slopes of the hillside to the east."
2. "The land is not an infill site. The Oak Tree Road/Rowan Tree Crescent development is already a visually intrusive element in the rising landscape, whilst to the south, the development is quite different; the ten or so houses are traditional cottages and conversions based on a farmstead. They blend into a landscape, which has a rural character quite different from that of Oak Tree Road/Rowan Tree Crescent some
200m to the north."
3. "The allocation site provides an important visual buffer between these distinct locations, particularly to the observer leaving Kendal southwards."
The Inspector concluded that, "the site's value in landscape terms is sufficient to
outweigh its value as a housing allocation. I believe that the allocation site has a visual quality of some considerable importance in the local landscape, which outweighs the very small contribution, which it can make to the housing land need."
SLDC states that 'Changing circumstances need to be taken into account. Past planning decisions may no longer be relevant in context of Adopted Core Strategy and current evidence base' (Appendix 8. Kendal Emerging Options Consultation Stage 1 Page Ill)
There has been no information or explanation as to why this policy shift has taken place. One is left to presume that pressure from developers and landowners for this site, together with convenience, have outweighed logic and sound planning criteria. Nothing has changed in this and the following two sections to warrant a volte-face!
I would request that this document be used as part of the LPA's evidence base, as it is unsound and unreasonable to exclude it.
Local Plan (2006)
And in the Local Plan 2006, SLDC had conceded, that '(the) development of higher hillsides further east would be unduly prominent.' - Section 6.3 Visual Amenity. The hillsides are no less prominent now, and this raising of the building line and roof height, especially at the top of the site, would be incredibly visually intrusive.
I would request that this information be used as part of the LPA's evidence base, as it is unsound and unreasonable to exclude it
County Landscape Designation
R141 had already been designated as worthy of County Landscape status, and
in 1999 I wrote to SLDC's Head of Economy and Development at the time, Richard Greenwood, (Appendix 3), indicating that I would like to see the rest of the prominent land (later R121and R676KE) included within the county landscape boundary- the argument being that this field et al met the criteria, and were continuous with the adjacent county landscape area.
In 2000 I received confirmation of my request (Appendix 4). A few years later I was kindly shown the letter for the first time and the map that had come back from Mike Smith (Appendix 5)- but it showed R121 and R676KE, as expected, but not R56, as had been intended too (cf. the inspector's decision)! Richard certainly intended that the land at the back of Rowan Tree Crescent be included- a fact that he recently confirmed! Had we seen this map earlier we would have raised the issue then.
Nothing of significance in the background and information I have outlined above has changed since 1997. And certainly the quality of the land and how it is perceived has not changed. Interestingly, because of the threat to it, people have probably come to notice it much more as a crucial part of Kendal's setting. So much so, that there were
200 people, very few of whom would be too directly affected, at the public meeting held at Castle Park School in March 2011, attended by the Strategy Team Manager and at which SOLEK was formed.
I would ask that this designation be used as part of the LPA's evidence base, as it is
unsound to exclude it.
The three sub-sections above are important comparators, and should be part of any serious land evaluation. To fail to use them is a very serious example of unsound practice.
The site had/has never been thoronghly and accurately assessed or evidenced. Gillespies Report
The Gillespies Report was not sound as far as their Site 8 was concerned. It had serious errors, for example gardens on Sedbergh Road were put forward as proposals/allocations for consultation, as was the field with the pond in it (677K).
Originally (and apparently based on Google Earth) there were to be 253 dwellings according to Gillespies- on a more extended site, then 147 on a slightly smaller site. Then at a public meeting the Strategy Team Manager said fewer because of the nature of the land, and finally 60 dwellings now appear on the only field(s) left (R121).
A further and more accurate re-assessment needed to take place. Gillespies should be seen as an unsound basis on which to incorporate this site originally.
Previous assessments
At previous stages there were so many concerns and issues raised by so many
different bodies, including SLDC that it was almost impossible to believe that Rl21M was still in the list of proposed sites- cf. Appendix 7. The Enviromnent Agency, the SLDC Enviromnent Protection Officer, Cumbria County Council, United Utilities, Kendal Town Council and so on.
Likewise, the site visit analysis for Rl41, as found in SLDC's consultation on emerging options -Kendal, raised serious concerns. But despite what was said, part ofR141 was still included for development- cf. Appendix 8.
The site was going to be included, whatever. However, based on the evidence provided, the judgement made was totally unsound.
Planners
The first time that the planner responsible for developments in Kendal set foot on the site was 22 July 20II -and that was because he was invited by SOLEK to look round. He had merely viewed this complex site from the road previously. It cannot be seen properly from the road.
For SOLEK the meting we had with the same planner on 20 February 2012 was most unsatisfactory, because we were unable to glean very little detail from him. We did learn from him, however, that suddenly there was a possibility of Oak Tree Road being opened up for access onto the site. Please see below for the follow-up.
(And incidentally, these same planners had been using three different development
boundaries to work from, and it had been necessary for us to point out the only validated one - Appendix I0).
Policy LA2.3 Land East of Castle Green Road (Appendix 11)
This indicates what needs to be done before development takes place. Since this is
such a sensitive site and since it can be seen that insufficient, quality preparatory work has been done, the site should be withdrawn from the final document now, because it
is not viable, and its non-viability and non-deliverability will become even more apparent later. This 'document' allays none of our fears.
Land assembly and development/mitigation costs connected directly and indirectly with R121M would make it unreasonable, unrealistic and unfeasible as a potential site for development.
Access/Highways
There is a total lack of preparation and detail (unsoundness) in these recommendations, especially for such a sensitive site.
For example, SLDC claims to have liaised with the Local Highways Authority (Highways access/safety- Kendal Emerging Options Stage 1 - Appendix 8 Page 110), but in a chance conversation with Keith Masser, CCC Highways Dept (21 February 2012) we discovered that they hadn't even measured the width of Oak Tree Road-their preferred option for access onto the site. (Incidentally there are all sorts of problems with it, including its width, as it so happens). It was astounding to discover that discussions were having to take place mid February 2012!
(The last highways survey of the Castle Green Road area was done 3 years ago, I believe, and neither Atkins (Appendix 9) nor the developers and planners in 1997 even suggested opening up the end of Oak Tree Road for vehicular access).
An access road (with lighting etc.) would cross this most sensitive area (R56 and Rl41) in order to allow access to Rl21, which was worthy of County Landscape designation in 1999, and has subsequently been judged as highly sensitive by CPRE (cf. later) and Galpin (cf. later).
Sound evidence/recommendations not taken into account (Landscape/General!
Kendal Town Council (2009)
Kendal Town Council supported the view that 'Rl21M' should not be developed (2009), because of the importance and sensitivity of the approaches to Kendal, and the importance of Kendal retaining its tradition as a 'market town nestling in a valley'. (Document(s) are available on the Kendal Town Council web-site).
I would ask that this submission help to inform and be part of the LPA's evidence base, as it is unsound not to take it into consideration.
Friends of the Lake District (CPRE)
SLDC did not accept the report from the Friends of the Lake District (CPRE) as part of their
evidence base (March/Apri12011). The latter stated that 'R121M should not be developed,
that being in conflict with RSS Policy EM!, saved Structure Plan Policy E37, Core Strategy
Policy 8.2, and PPS7)'.(cf. Appendix 12).
I would ask that the value of this report be reconsidered. It should carry far greater weight in the landscape assessment process. It would be unsound not to adopt it as part of the evidence base. And the conclusions match very much the following.
The Town Council Landscape Character Assessment (Galpin)
Kendal Town Council undertook a landscape character assessment (The Galpin Report) in order to provide SLDC with additional site information at a local level and to help them with their land allocations (05 April2011). Amongst many findings it highlighted that landscape quality within and without the LDNPA is a movable feast.
More importantly, however, it stressed the importance of not developing this particular tract of land (R121M)- with its highly sensitive landscape and limited capacity for development (Appendix 13)- the most sensitive of the 19 proposed sites for Kendal. I have included the information for Castle Green (K3) as well, since it is very appropriate to juxtapose the information on these two sites and stress the overall quality of the whole area. The recommendations of the Town Council are based on sound evidence and should be taken into consideration as evidence! (cf. Appendix 14, and the full document is available on the Kendal Town Council web-site).
However, SLDC did not accept this document as part of their evidence base, and we happened to come across mention of it in Kendal Emerging Options Consultation Stage I - Appendix 8 Page ll4.
This independent Landscape Character Assessment was commissioned by the Town Council. The brief was looked at, modified and approved by the Strategy Team Manager. The Town Council had made it known that they wished the report to be accepted as part of SLDC's evidence base, so had involved the Strategy Manager in order to ensure that the brief was objective and would be acceptable , as evidence, to SLDC. This was communicated to the Strategy Team Manager.
The LPA should be required to adopt this Landscape Character Assessment as part of their evidence base, as it is unsound not to do so.
Sustainable Development in Kendal- Town Council (April2011)
SLDC swiftly and summarily dismissed the Town Council's submission- Sustainable Development in Kendal- based on the Taylor Review. The Kendal planner had not heard of Taylor until22 July 2011, when it was mentioned to him by members of the SOLEK committee when they showed him round this site.
Taylor illustrated how best to tackle the difficulties faced by market towns, which seemingly needed to be expanded. Rather than add faceless suburbs, create urban and unsustainable sprawl and destroy the integrity and uniqueness of a market town, one should develop other settlements to a position of viability and sustainability and/or create a new settlement from scratch and plan it in such a way that it is sustainable, would co-incidentally and significantly reduce the infrastructure problems that would be insurmountable in the market town itself and be less unpalatable to many more residents- (Taylor Review of Rural Economy and Affordable Housing-July 2008).
The Greater Norwich Development Plan Partnership had serious legal difficulties because
they had failed to look at/assess properly alternative approaches/strategies, and SLDC have certainly failed to look seriously at alternative ways of meeting their perceived building needs.
In general terms SLDC's response to their planning issues would appear reactive, piecemeal and rushed, and shows little or no strategic thinking. Furthermore, it needs stressing that the land allocations were originally in train before the Core Strategy was in place.
I would ask that the Town Council approach be adopted.
Cumbria County Council Local Area Committee
The CCC Local Area Committee recommended, (with no votes against) that SLDC adopt an approach similar to that of Taylor and The Town Council.
I would ask that this information be used to inform the LPA's evidence base.
Policies not being adhered to:
Core strategy policies on green infrastructure, green corridors, watercourses and open spaces (CS8.1) and landscape and settlement character (CS8.2) and others are not being adhered to.
Mike Hyde, our consultant, will develop this area in particular. He has already responded to the two previous land allocation proposals, and will be doing so again, but separately to this response.
The quality of our natural landscape should be 'improved and enhanced.' It should certainly not be compromised, irrevocably changed or destroyed. We must do our utmost to ensure a worthy inheritance for our children and our grandchildren.
I would ask that this be referred back to the LPA.
Isues of Biodiversity:
There are particular concerns over the fact that there is a Great Crested Newt (GCN) colony in the pond in R677K. I have already advised that the LPA provide you with a corrected map showing the size of the. pond and the fact that it and the reed beds now extend into R56 and Rl41.
Great Crested Newt colonies need a distance of 500 meters from their pond for food, habitation, hibernation etc. and they can move typically up to 800 meters/1 km. 'The greatest threat to them in Cumbria is the destruction of their ponds and surrounding terrestrial habitat.' (The Biodiversity Evidence Base (2008)- Appendix 9 Page 35)
The great crested newt is strictly protected under the Wildlife & Countryside Act 1981 (as amended) and the Conservation (Natural Habitats &c.)- Regulations 1994 (as amended). Capturing, disturbing, injuring and killing newts is prohibited, as is damaging or destroying their breeding sites and resting places (Natural England Interim Guidance 2007).
SLDC should already have undertaken a full and proper survey of the GCN colony, the reed beds and the outlying habitats. They are already found in gardens in Oak Tree Road and Rowan Tree Crescent.
We have recently discovered that there is also a colony of GCNs in the pond in Broom Close, which is just the other side of the Old Sedbergh Road (Appendix 5 map) and which needs to be indicated on any new map that SLDC should be providing you with.
SLDC should not be permitted to break this vital green corridor.
The one minute read/index to the LDF is very informative. Under biodiversity it says the number of species in each allocation is an estimate and then states: "For each site proposed for allocation, an ecological survey will be required at detailed planning application stage, to inform appropriate mitigation, enhancement or compensation measures"
The LPA should have carried out all the necessary work at this stage, and not leave it until it is too late to save a site that should be saved (cf. Appendix II again). The same applies to all of our other concerns!
Overall, we believe that the LPA is not adhering to Core Strategy policies and other legal requirements.
Drainage and Flooding
SLDC have not given sufficient consideration to these issues: existing streams; the current flooding issues for houses backing onto the site; the volume and speed of additional run-off caused by building on the land; the importance of R121 to act as a wet sponge even in the summer; the five springs in Rl21 that open up in heavy rain; the run-off from the railway line and above; the existing road drainage problems on Castle Green Road/Lane; a previoushistory of back-up flooding in Ann Street and the view of SLDC's own officers etc.
SLDC recognises publicly that flooding on the eastern side of Kendal is a very serious problem, and all other land potentially flowing into the very expensive Stock Beck Flood
Alleviation system has been removed. So why compromise the scheme with this additional risk? Why would Cumbria County Council want to take on the risks, the responsibilities and the cost?
Only people who live in this part of town fully appreciate the volume of water housed in and coming off these fields.
Climate change, the likelihood of 5-day flash floods and winter rainfall predictions up to 2080 showing marked increases are further reasons to indicate the inappropriateness of this land being developed.
SLDC already recognises that the work would need to be carried out at a level above PPS25. Flood and drainage mitigation costs would be astronomical.
And with other necessary mitigation measures and infrastructure costs, this site is unviable and undeliverable.
The LPA should be required to accept the Preliminary Expert Report by Professor Robert Jackson as part of their evidence base- September 2011 (Appendix 15). Not to do so would be unsound.
There is sufficient already to require the LPA to withdraw the site from its DPD.
Infrastructure
Extract from SLDC document "Kendal Transport Study (Janl2) pdf":
"6.1.6 Furthermore, even with the implementation of these improvement schemes, it is important to note that a large proportion of the key junctions would continue to operate
above capacity, and therefore experience congestion and extensive queuing in the 2022
base situation. This situation would be compounded by the LDF development traffic."
'The existing highway network would not be able to accommodate the proposed levels of LDF development without significant increases in congestion'. No amount of mitigation will be fully successful.
SLDC has failed to come up with an infrastructure delivery plan, a transport plan or an air quality plan to meet the scale of developments proposed. Statements of intent are not acceptable at this stage.
In a similar vein the vision (South Lakeland Core Strategy) states that 'in 2025 Kendal will....... was a pipe-dream in 2010, and 2 years later it still is a pipe-dream. We have no plans as to how it will be achieved (Appendix 16).
One of the reasons for the Town Council to follow Taylor was that there would be no other obvious way to deal with the existing and future infrastructure problems. More of the same is not a solution.
What is needed is a cumulative delivery plan that is realistic, detailed and as accurately costed as possible. Until we have that the DPD should not be accepted.
Well-being and Health
Where is the consideration for the well-being and health of current and future residents? If this DPD is accepted, then the infrastructure problems will cause environmental harm. There will be a serious deterioration in the quality of the but by other people living in the area, tourists and visitors. (We will also see the loss of amenities such as sledging and apple scrumping in Rl21M). The feel-good factor in our lives will be lessened. And what sustainability plans are in place to ensure that Kendal can indeed accommodate these extra 2,000 dwellings over the next 12 or so years? The DPD should be withdrawn on these grounds too.
Community Involvement and Engagement:
Approx 400 people were against the development of R121M and 2 in favour
Conclusion:
SLDC have continued to include the land behind Oak Tree Road and Rowan Tree Crescent in their land allocations. They have reduced the size of the development for very sound reasons, but we believe that they should, for the very same sound reasons, remove the site totally.
Had they hitherto looked at the site in greater detail and with greater care and objectivity on sound planning grounds and used all of the evidence available to them, they would never have put the site forward. The land may be available, but it does not mean it is deliverable.
We also feel that they should not indiscriminately develop the many other sites at the edge of the town- in line with Town Council proposals.
SLDC have taken the easy option, and failed to carry out strategic planning, by, for example, not being effectively pro-active in negotiation with landowners and not going down the possible route of compulsory land purchase.
Bury Green Party submitted that their Draft Publication Core Strategy was unsound and unsustainable. 'It is not based on proper consultation at the preparation stage of the process with Township Forums and local residents. It is unsustainable in terms of transport, flood risk, carbon emission/climate change and wild life links and corridors. It is in breach of both national and local government material policies with regards to the Green Belt.'
How similar to the situation in Kendal, and with respect to R121M!
I or one of the committee members of SOLEK would wish to take part in the oral examination, and we would speak with the backing of 136 residents, who have given SOLEK the authority to speak on their behalf should they not wish to speak for themselves (Appendix 17).
I would also kindly request that you visit the site for yourself, please.
[Submission supported by petition signed by 136 residents]
772. Mr Austen Robinson (Individual) : 17 May 2012 16:25:00
Paragraph No.
1.9
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
- Community involvement means listening, and even modifying plans!
- Minimal changes have been made in general since the first set of land allocations proposed.
- A lack of meaningful dialogue as far as Kendal is concerned- with anybody.
- The number of official bodies / organisations, whose views have had no sway
- The SLDC website is the only means of finding out what is going on. They claim library use is possible, but you never know which version is available to work on there or elsewhere.
- Not everybody has a computer or feels competent to use it, especially in our part of
town that has many older residents.
- Updates and additional material can appear on the website at any time.
- The initial insistence on replies online. I challenged this with the Strategy Team
Manager, and written responses were to be accepted.
- Originally on the form there was a 500 word limit. That was rescinded.
773. Mr Austen Robinson (Individual) : 17 May 2012 16:29:00
Paragraph No.
0.0 Whole Document
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
- Political and planner intransigence. Their inability to revisit, for example, the number of dwellings needed in light of the fact that the figure is now running annually at 205 and not 400 (Strategic Housing Market Assessment - October 2011). There has been
No appropriate / public adjustment to this fact.
- Only the informed minority respond.
- Difficulty/near impossibility of working on data themes, and not on site-specific material.
- The sheer volume of material that you should really consult before responding this time.
- This undemocratic process has been highlighted by the fact that this and all other sites have been put forward by the Strategy Team, but have not been put before the relevant planning committees for assessment.
774. Mr Austen Robinson (Individual) : 17 May 2012 16:31:00
Paragraph No.
1.10
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
- The official line expressed by SLDC (The Portfolio Holder and the Strategy Team Manager) is that they disregard objections from residents who are affected by the developments (cf. Westmorland Gazette and meetings). At least residents know the area and its problems, so they should, at least, be listened to.
- The Kendal Planner consulted only our consultant's document before corning to see us last July, and that hardly inspires confidence that ordinary residents will be listened to.
775. Mr and Mrs Henry and Carol Rogers (Individual) : 26 Apr 2012 16:30:00
Policy/Site No.
LA1.3 Housing Allocations - M41KM KENDAL SOUTH OF LUMLEY ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Loss of green field space is detrimental to the character and heritage of the area. This is contrary to Coalition Government Sustainable Development Policy, which recognizes brown field preference above important countryside areas. The Soundness and legality of the plan is therefore challenged as being contrary to Government Planning Policy.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I wish to object to and challenge the soundness of proposed land allocation for development – to south of Lumley Rd. (M41KM) and Scroggs Wood Light Industrial Site (E4M) on the following grounds:
- The proposed developments would spoil the initial impression to Kendal visitors, being on the main access route and adjacent to the Town boundary. The Lumley road site is steeply graded and properties would impose on the existing view for Kendal visitors. The line of trees acts as a natural barrier between countryside and properties. Building to the South of this line (E4M), would fundamentally change the Kendal “Gateway to the Lakes” character as a valued landscape. This is contrary to the adopted planning Core Strategy. The Soundness of the plan is therefore challenged on visual impact grounds, contrary to planning policy.
- Loss of green field space is detrimental to the character and heritage of the area. This is contrary to Coalition Government Sustainable Development Policy, which recognizes brown field preference above important countryside areas. The Soundness and legality of the plan is therefore challenged as being contrary to Government Planning Policy.
- Milnthorpe road already backs up to the bypass at peak times and cannot accommodate the massive increase that such development, in these locations, would create. Kendal town development to attract visitors is pointless if they cannot obtain satisfactory access. The associated pollution from stationary traffic is incompatible with sustainable development objectives. The soundness of the development is challenged on the basis that there is no traffic plan to address these issues.
- The A6 is a crucial access for emergency services, particularly following the downgrading of Westmorland General Hospital. Further congestion on this route would introduce undue risk. The potential for accidents when joining the main road would also be significantly increased. The Soundness of the plan is therefore challenged on safety grounds.
- The soundness of the development is challenged on the basis that there is inadequate local infrastructure including drainage, sewerage and roads.
- The proposed development is incompatible with the character of the historic Helsington development contrary to planning policy. The Soundness of the plan is therefore challenged as being detrimental to the historical character of the area.
- The site is clearly NOT “in an accessible location or an easily developable level site” (Achievability statement P133 2 C). The Soundness of the plan is therefore challenged as being contrary to this declared planning statement.
- There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of adequate existing residential space and more suitable alternative development sites.
- The Development plan should retain the "Kendal Gateway to the Lakes" image supporting tourism and established Cumbrian employment, not destroy it with unsightly, unnecessary development and traffic jams. You don’t put your wheelie bin on your front door step! The DPD appears to have completely disregarded the massive opposition and valid objections previously made. The soundness of this planned development is challenged as disregarding local opinion contrary to Government Policy.
776. Mr and Mrs Henry and Carol Rogers (Individual) : 26 Apr 2012 16:33:00
Policy/Site No.
LA1.6 Strategic Employment Sites - E4M KENDAL LAND AT SCROGGS WOOD, MILNTHORPE ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I wish to object to and challenge the soundness of proposed land allocation for development – to south of Lumley Rd. (M41KM) and Scroggs Wood Light Industrial Site (E4M) on the following grounds:
- The proposed developments would spoil the initial impression to Kendal visitors, being on the main access route and adjacent to the Town boundary. The Lumley road site is steeply graded and properties would impose on the existing view for Kendal visitors. The line of trees acts as a natural barrier between countryside and properties. Building to the South of this line (E4M), would fundamentally change the Kendal “Gateway to the Lakes” character as a valued landscape. This is contrary to the adopted planning Core Strategy. The Soundness of the plan is therefore challenged on visual impact grounds, contrary to planning policy.
- Loss of green field space is detrimental to the character and heritage of the area. This is contrary to Coalition Government Sustainable Development Policy, which recognizes brown field preference above important countryside areas. The Soundness and legality of the plan is therefore challenged as being contrary to Government Planning Policy.
- Milnthorpe road already backs up to the bypass at peak times and cannot accommodate the massive increase that such development, in these locations, would create. Kendal town development to attract visitors is pointless if they cannot obtain satisfactory access. The associated pollution from stationary traffic is incompatible with sustainable development objectives. The soundness of the development is challenged on the basis that there is no traffic plan to address these issues.
- The A6 is a crucial access for emergency services, particularly following the downgrading of Westmorland General Hospital. Further congestion on this route would introduce undue risk. The potential for accidents when joining the main road would also be significantly increased. The Soundness of the plan is therefore challenged on safety grounds.
- The soundness of the development is challenged on the basis that there is inadequate local infrastructure including drainage, sewerage and roads.
- The proposed development is incompatible with the character of the historic Helsington development contrary to planning policy. The Soundness of the plan is therefore challenged as being detrimental to the historical character of the area.
- The site is clearly NOT “in an accessible location or an easily developable level site” (Achievability statement P133 2 C). The Soundness of the plan is therefore challenged as being contrary to this declared planning statement.
- There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of adequate existing residential space and more suitable alternative development sites.
- There is spare capacity and expansion potential on existing established trading estates on Shap Road. The plan to relocate the Rugby club to Oxenholme and development of the Gilkes site are more suited to development than Scroggs Wood. The soundness of the case for such development is challenged on the basis of existing and more suitable alternative development sites compatible with planning policy.
- The Development plan should retain the "Kendal Gateway to the Lakes" image supporting tourism and established Cumbrian employment, not destroy it with unsightly, unnecessary development and traffic jams. You don’t put your wheelie bin on your front door step! The DPD appears to have completely disregarded the massive opposition and valid objections previously made. The soundness of this planned development is challenged as disregarding local opinion contrary to Government Policy.
777. Mr and Mrs Henry and Carol Rogers (Individual) : 26 Apr 2012 16:35:00
Policy/Site No.
LA1.3 Housing Allocations - All Kendal sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of adequate existing residential space and more suitable alternative development sites.
778. Mr and Mrs Henry and Carol Rogers (Individual) : 26 Apr 2012 16:36:00
Paragraph No.
0.0 Whole Document
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Is there a definition of “affordable housing” in the context of Kendal young person income? Or is this merely a rouse to allow land owners and builders to make massive profits, without any tangible commitment to house the low paid of Kendal? The Soundness is therefore challenged on the basis of no defined affordability test.
779. Mr and Mrs Henry and Carol Rogers (Individual) : 26 Apr 2012 16:37:00
Policy/Site No.
LA1.4 - Kendal Sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of adequate existing residential space and more suitable alternative development sites.
780. Mr & Mrs Frank R & Barbara M Rush (Individual) : 20 Apr 2012 09:51:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA2.13 Mixed Use Allocation at Green Dragon Farm, Burton-in-Kendal
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The DPD has not been prepared in accordance with the Town & County Planning Regulations 2004 (as amended)
The DPD has not had regard to the Sustainable Community Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
"The proposed development in Burton in Kendal far exceeds any needs identified in the Parish Plan or the Cumbria Rural Housing Trust Survey, both of which identified a need for a limited amount of affordable housing for local occupancy. The 2004 Housing Need Survey found a requirement for 12 affordable home and the 2009 survey found a need for 14 affordable home"
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Refer to Burton in Kendal Parish Council Quarterly newsletter spring 2012 (dated 2011 by mistake)
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
781. Mr & Mrs Frank R & Barbara M Rush (Individual) : 16 May 2012 10:36:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - All Burton-in-Kendal sites
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The DPD has not been prepared in accordance with the Town & County Planning Regulations 2004 (as amended)
The DPD has not had regard to the Sustainable Community Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
"The proposed development in Burton in Kendal far exceeds any needs identified in the Parish Plan or the Cumbria Rural Housing Trust Survey, both of which identified a need for a limited amount of affordable housing for local occupancy. The 2004 Housing Need Survey found a requirement for 12 affordable home and the 2009 survey found a need for 14 affordable home"
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Refer to Burton in Kendal Parish Council Quarterly newsletter spring 2012 (dated 2011 by mistake)
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
782. Miss Barbara Rylands (Individual) : 23 Apr 2012 11:54:00
Policy/Site No.
LA1.3 Housing Allocations - All Arnside sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I am extremely concerned to learn from Arnside village Society that South Lakleland District Council are planning to develop and ignore the wishes of the local community that brown field sites should be used before any green field sites in the village.
In an area of outstanding natural beauty surely developments of 81 houses in this village would have to entail a huge change in the infrastructure to support this increase and completely change a village which depends on tourism. I hope the council will re-think the proposals
783. Miss Barbara Rylands (Individual) : 23 Apr 2012 12:00:00
Policy/Site No.
LA1.3 Housing Allocations - Site Omission
If you have selected a ‘Site omission’ please enter the site reference or location and relevant policy below
The old trafalgar garage should be used before any green field sites in the village.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The old trafalgar garage should be used before any green field sites in the village. This site on Ashleigh Road should be a number ine option.
784. Miss Barbara Rylands (Individual) : 23 Apr 2012 12:05:00
Policy/Site No.
LA1.3 Housing Allocations - Site Omission
If you have selected a ‘Site omission’ please enter the site reference or location and relevant policy below
The second possibility (not a brownfield) is at the top of Briery Bank and the old orchard - this could match the affordable housing on the far side.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The second possibility (not a brownfield) is at the top of Briery Bank and the old orchard - this could match the affordable housing on the far side.
785. Ian Sager (Individual) : 11 Apr 2012 12:15:00
Policy/Site No.
LA1.3 Housing Allocations - R129M KENDAL SOUTH OF UNDERBARROW ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
i object specifically to RM129M + RM143 and to the plans in general- they are totally unnecessary.
"These proposals formed the basis of one of SLDC's most extensive ever consultation exercises between January and April of this year. Further consultation was undertaken between July and September on alternative sites and a number of other issues. Responses have been processed and analysed. In response
to concerns raised through consultation"
I wish that was true -like every other consultation that's been held in recent time I am sure you will just make the same decisions that you set out to make in the first place.
there is lots of empty properties in Kendal and lots of brown field sites that you do nothing about. Why not use them instead ofthe monstrous plans to concrete over SLDC so a few rich business men can make a lot of money?
There is lots of properties for sale in Kendal some of which have been for sale for over 4 years so why the continual misinformation about shortage of housing? Why not stop second home owners being allowed to buy up properties in the area and use them part time or as holiday homes?
This is all about you enabling your partners in business to make lots of money- try dealing with existing brownfield sites of which there is many, instead of just destroying Kendal and no doubt other beautiful areas in SLDC.
In my opinion the proposed change to the planning laws and things like this plan are a disgrace.
This whole process is rotten; last year, according to a letter published in the Westmorland Gazette, I am led to believe that Kendal Town Council attempted to try to move the boundary of the National Park to the bypass just so they could get away with building on even more precious green land up to the bypass.
to show what a nonsense the local housing agenda is- we had a church converted near us- it originally had a section 106 condition on the planning permission but this was taken out at a later stage -the conversion was carried out and what was a beautiful building has now been ruined- it is now an eyesorewe have 4 flats- one occupied, two rarely used holiday homes and one that's been left as total eyesore with a window broken and unoccupied for 4 or 5 years despite it being brought to the council's attention many years ago and the council allegedly having someone dealing with empty properties full time and the
council making such a big thing about its efforts on this issue.
786. Ian Sager (Individual) : 11 Apr 2012 13:03:00
Paragraph No.
0.0 Whole Document
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
i object specifically to RM129M + RM143 and to the plans in general- they are totally unnecessary.
"These proposals formed the basis of one of SLDC's most extensive ever consultation exercises between January and April of this year. Further consultation was undertaken between July and September on alternative sites and a number of other issues. Responses have been processed and analysed. In response
to concerns raised through consultation"
I wish that was true -like every other consultation that's been held in recent time I am sure you will just make the same decisions that you set out to make in the first place.
there is lots of empty properties in Kendal and lots of brown field sites that you do nothing about. Why not use them instead ofthe monstrous plans to concrete over SLDC so a few rich business men can make a lot of money?
There is lots of properties for sale in Kendal some of which have been for sale for over 4 years so why the continual misinformation about shortage of housing? Why not stop second home owners being allowed to buy up properties in the area and use them part time or as holiday homes?
This is all about you enabling your partners in business to make lots of money- try dealing with existing brownfield sites of which there is many, instead of just destroying Kendal and no doubt other beautiful areas in SLDC.
In my opinion the proposed change to the planning laws and things like this plan are a disgrace.
This whole process is rotten; last year, according to a letter published in the Westmorland Gazette, I am led to believe that Kendal Town Council attempted to try to move the boundary of the National Park to the bypass just so they could get away with building on even more precious green land up to the bypass.
to show what a nonsense the local housing agenda is- we had a church converted near us- it originally had a section 106 condition on the planning permission but this was taken out at a later stage -the conversion was carried out and what was a beautiful building has now been ruined- it is now an eyesore. we have 4 flats- one occupied, two rarely used holiday homes and one that's been left as total eyesore with a window broken and unoccupied for 4 or 5 years despite it being brought to the council's attention many years ago and the council allegedly having someone dealing with empty properties full time and the
council making such a big thing about its efforts on this issue.
787. Mrs Catherine Saunders (Individual) : 5 Apr 2012 23:17:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - R689 ULVM ULVERSTON NORTH URSWICK ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
The DPD has not had regard to the Sustainable Community Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I believe that R689ULVM North Urswick Road should be removed from the planning map because of the following reasons:
A. Swarthmoor Hall Farm (organic) currently uses this land, and because of it's situation between Ulverston and Swarthmoor, with houses surrounding it, there is limited land available for grazing and winter feed production.To build on this land would affect and threaten the viability of the farmer's herd, through a shortfall of suitable organic grazing pasture and his and his employees livlihoods would be threatened.
Your sustainability document says:
5.1 "support diversification of the agricultural and wider community"
4.12 "need to facilitate continued diversification of farm enterprises on an apropriate scale"
4.1 "prevent loss of existing jobs"
2.37 "existing employment sites to be safeguarded"
2.23 "other demands on the site...and the implications of development for the existing and future use of neighbouring sites", must be taken into consideration.
7.26 "diversify and strengthen local economy" also, "enabling existing businesses to expand into new premises" Instead you will be removing land from this existing business.
As Swarthmoor Hall Farm is diversifying and is now producing it's own cheese, suplies local ice cream producers as well as milk supplied locally throughout Cumbria to as far as Penrith and down the west coast, including more local milk rounds, also local shops and supermarkets, I believe you have not met your own requirements set out in the sustainability document as described above, as developing on site R689ULVM would take away this productive farm land from the present tenant and destroy the business that they have spent 30 years building up.
B. R689ULVM belongs to the Quakers and has close proximity to the historical site of Swarthmoor Hall, original home of the Quaker Movement. It is also part of the Cistercean Way. To build on this land would encroach on the outlook of the hall, compromising the ethos of this religious site.
Your sustainability document says:
5.1 the site must,"protect historic environment from harmful change"
5.6 "Preserving and enhancing Ulverston's built heritage including....Swarthmoor Hall"
C. R689ULVM is currently a green gap between Ulverston and Swarthmoor. If this land is built on there is also a high chance of the remainder of land alongside Urswick road being developed on in a ribbon fashion, as Hall Field and Quaker Fold estates have already been built in this way.
5.1 green gaps..."must ensure they are kept distinct...maintain their individual character"
D. The sewage / drains on Urswick Road are already overloaded, having to be pumped out regularly (more that once a week) by a tanker.
2.9 states that "the capacity of existing services to accommodate development, the site needs the "infrastructure" to cope with incresed houses, i.e increased drain and sewerage capacity.
2.23 "Community infrastructure... impact on local highways, water, sewerage".
E. The increased amount of traffic that would arise from such a development would be intolerable, as volumes and speeds of traffic on Urswick Road are already excessive, due to it being a route from the Croftlands estate, via Main Street, Swarthmoor to ajoin the A590 at Cross-a-Moor through to Barrow. In addition to the housing development proposed on Urswick Road there are another 1000 plus houses proposed South of the current Croftlands Estate, stretching from Priory Road, to Urswick Road. If all these planned houses are built, it is possible that an extra 2000 plus cars could be using the current roads through Croftlands Estate, and joining the A590 at Cross a Moor, also a further 200 houses are planned to be built the other side of Swarthmoor, again ajoining the A590 at Cross a Moor. This surely is not going to be safe, quiet, nor the air clean.
2.23 "Community infrastructure...impact on local highways, water, sewerage"
2.26 Highway capacity of A590 and roads through Croftlands Estate especially..."cumulative impact of sites"
4.18 "reduce need to travel"
Is this plan justified?
1.24 states, "In South Lakeland's case, the Strategic Housing Market Assesment suggests that the amount of housing development proposed in the Core Stategy is necessary to address the Districts housing needs. This must be weighed against clear environmental constraints and the need to support urban regeneration in neighbouring communities"
5.1 "In 2025 Ulverston will have... including helping to meet the housing needs of employees in the regeneration priority area of Barrow." If this is so, why is SLDC going to build houses on green fields in Ulverston and other villages, when Barrow would like some of SLDC's housing numbers and have a good number of brownfied sites that would be suitable.
4.18 "reduce the need to travel"
1.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
I do not support SLDC's Land Allocations DPD.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I believe that the housing numbers for Ulverston are too high, and believe that brownfield sites should be looked at first. R689ULVM should be removed from your plan, to safeguard the livlihoods of the tennant farmers and their employees.
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
Ido not support SLDC's Land allocations DPD in it's current form.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
I don't feel that the public's opinion has been taken into consideration in the previous consultations, and the actual effects on the ground have been disregarded as trivial.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
788. Mr Rodney Sayers (Individual) : 24 Apr 2012 14:33:00
Paragraph No.
0.0 Whole Document
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
On 18'h January 2012, the full Council of the SLDC approved the land Allocations Development Plan Document (DPD), despite the overwhelming opposition of the majority of persons who have taken part in consultations since its inception in 2005.
Please make clear, to the Inspector to be appointed as judge of the 'soundness' of the proposals, my opposition to the proposals. I believe that the process is flawed for the following reasons:
1) The proposals for the allocation of housing land do not reflect the split in the increase in
population as set out in the Core Document.
2) The proposals do not follow the guidelines set out in the Core Document.
3) The proposals are reliant on the fact that all of the approximately 6,000 proposed dwellings need to be built before the target of approximately 2,000 affordable dwellings is achieved and that there is no plan 'B' to accommodate any shortfall.
4) If all 6.000 dwellings are needed then the Council/Officers have not adequately considered alternatives to allocating land in places closer to proposed Industrial Units.
In detail:
1) Councillor Peter Thornton, who is the Portfolio holder for Housing and Development on the SlDC, stated in the Westmorland Gazette of 27'h January 2011, referring to the Land
Allocations Exercise, I quote ' If we don't do this then our young people will continue to
leave, replaced by a continued influx of retirees. Ultimately we will end up with the
equivalent of a huge residential home, but with no one to care for the residents.
a. Howeverthe Core Document clearly shows that the population of the South Lakes is
estimated to increase by 12,000 persons between 2006 and 2026 (From 105,000 to
117,000).
b. Of these 12,000, page 78 of the Core Document shows an estimated increase of
8,000 retirees. If it is assumed that these persons already live in the district, then
they will probably own their homes. If not, then it must be assumed that around
4,000 new homes will be required for the incomers. I.e. Councillor Thornton's
prophecy is self-fulfilled. The proposals should concentrate on the 4,000 remaining
persons in the Core document. These are the young persons and families that we
must retain in the district and who need the 2,000 affordable or low cost
dwellings.
c. The means of building and funding this affordable housing need to be addressed, but
the only method offunding suggested in the exercise seems to be by making the
developers foot the bill. The developers are expected, not only to subsidise the
affordable element but also many of the necessary infrastructure projects.
d. This will have two effects: 1) There is a strong possibility that all 6,000 dwelling will
not be developed due to the cost structure and 2) The mixed dwellings will become
more expensive which, in turn, will lead to problems of young people moving up the
housing ladder. In any case, if the mixed dwellings are required, they must be
suitable for the older persons as set out in the Core Document. This type of dwelling
is not necessarily the same as that required for younger persons.
e. If all 6,000 new homes are not built, then there will be a shortfall in the 2,000
required for the affordable/low cost section. There is no plan 'B' to make up this
shortfall.
2) The proposals in the final land allocation document do not meet the criteria as set out in the Core Document. The document sets out relatively clear guidelines on the amount of land to be set aside for housing and Industrial development and the criteria to be used in proposing developments on this land. However, despite claiming green and 'sustainable' credentials, there are many incidences where allocations appear to be contrary to the guidelines.
a. The relationship between the allocation of new land for new housing and Industry
does not appear to have been addressed. Housing seems to have been allocated
away from industrial sites. This will lead to more traffic between homes and places
of work.
b. If all6,000 new homes are required, then alternative options should have been
considered. For example, a new Auction Mart development is currently being built at
Crooklands, which could grow over the next few years as the site has easy access to
the M6 motorway. There is also a proposal to extend the Main line industrial estate
on the Crooklands to Milnthorpe road. There is little housing around this area, so
virtually all personnel will have to travel to the site. Surely it makes more sense to
create a completely new village to service these sites, which would be large enough
to support its own local services. A similar village could be created between
Ulverston and Barrow to service those industrial hubs.
c. This would leave towns and villages such as Kendal, Grange and Milnthorpe, which
all currently have their own traffic problems to provide some extra housing through
infill and existing sites.
d. A further alternative, would be to create larger 'hubs, just outside the larger towns
with their own services and good infrastructure to provide easy access to the places
of employment
e. The document does not appear to have considered any alternative options
other than increasing the size of already crowded towns and villages through
developments around their fringes.
There are other anomalies In the final proposals which go against the principles of the Core
Document. Together with the main reasons given above, I believe that the proposals are flawed and should be rejected.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
On 18'h January 2012, the full Council of the SLDC approved the land Allocations Development Plan
Document (DPD), despite the overwhelming opposition of the majority of persons who have taken
part in consultations since its inception in 2005.
Please make clear, to the Inspector to be appointed as judge of the 'soundness' of the proposals, my
opposition to the proposals. I believe that the process is flawed for the following reasons:
1) The proposals for the allocation of housing land do not reflect the split in the increase in
population as set out in the Core Document.
2) The proposals do not follow the guidelines set out in the Core Document.
3) The proposals are reliant on the fact that all of the approximately 6,000 proposed dwellings
need to be built before the target of approximately 2,000 affordable dwellings is achieved
and that there is no plan 'B' to accommodate any shortfall.
4) If all 6.000 dwellings are needed then the Council/Officers have not adequately considered
alternatives to allocating land in places closer to proposed Industrial Units.
In detail:
1) Councillor Peter Thornton, who is the Portfolio holder for Housing and Development on the
SlDC, stated in the Westmorland Gazette of 27'h January 2011, referring to the Land
Allocations Exercise, I quote ' If we don't do this then our young people will continue to
leave, replaced by a continued influx of retirees. Ultimately we will end up with the
equivalent of a huge residential home, but with no one to care for the residents.
a. Howeverthe Core Document clearly shows that the population of the South Lakes is
estimated to increase by 12,000 persons between 2006 and 2026 (From 105,000 to
117,000).
b. Of these 12,000, page 78 of the Core Document shows an estimated increase of
8,000 retirees. If it is assumed that these persons already live in the district, then
they will probably own their homes. If not, then it must be assumed that around
4,000 new homes will be required for the incomers. I.e. Councillor Thornton's
prophecy is self-fulfilled. The proposals should concentrate on the 4,000 remaining
persons in the Core document. These are the young persons and families that we
must retain in the district and who need the 2,000 affordable or low cost
dwellings.
c. The means of building and funding this affordable housing need to be addressed, but
the only method offunding suggested in the exercise seems to be by making the
developers foot the bill. The developers are expected, not only to subsidise the
affordable element but also many of the necessary infrastructure projects.
d. This will have two effects: 1) There is a strong possibility that all 6,000 dwelling will
not be developed due to the cost structure and 2) The mixed dwellings will become
more expensive which, in turn, will lead to problems of young people moving up the
housing ladder. In any case, if the mixed dwellings are required, they must be
suitable for the older persons as set out in the Core Document. This type of dwelling
is not necessarily the same as that required for younger persons.
e. If all 6,000 new homes are not built, then there will be a shortfall in the 2,000
required for the affordable/low cost section. There is no plan 'B' to make up this
shortfall.
2) The proposals in the final land allocation document do not meet the criteria as set out in the
Core Document. The document sets out relatively clear guidelines on the amount of land to
be set aside for housing and Industrial development and the criteria to be used in proposing
developments on this land. However, despite claiming green and 'sustainable' credentials,
there are many incidences where allocations appear to be contrary to the guidelines.
a. The relationship between the allocation of new land for new housing and Industry
does not appear to have been addressed. Housing seems to have been allocated
away from industrial sites. This will lead to more traffic between homes and places
of work.
b. If all6,000 new homes are required, then alternative options should have been
considered. For example, a new Auction Mart development is currently being built at
Crooklands, which could grow over the next few years as the site has easy access to
the M6 motorway. There is also a proposal to extend the Main line industrial estate
on the Crooklands to Milnthorpe road. There is little housing around this area, so
virtually all personnel will have to travel to the site. Surely it makes more sense to
create a completely new village to service these sites, which would be large enough
to support its own local services. A similar village could be created between
Ulverston and Barrow to service those industrial hubs.
c. This would leave towns and villages such as Kendal, Grange and Milnthorpe, which
all currently have their own traffic problems to provide some extra housing through
infill and existing sites.
d. A further alternative, would be to create larger 'hubs, just outside the larger towns
with their own services and good infrastructure to provide easy access to the places
of employment
e. The document does not appear to have considered any alternative options
other than increasing the size of already crowded towns and villages through
developments around their fringes.
There are other anomalies In the final proposals which go against the principles of the Core
Document. Together with the main reasons given above, I believe that the proposals are flawed
and should be rejected.
789. Mr Edward Scott (Individual) : 11 Apr 2012 16:12:00
Policy/Site No.
LA1.3 Housing Allocations - All Grange-over-Sands sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I believe the proposals for Grange and District have not taken into account my objection regarding the Cartmel Road location, the distress to wildlife, badgers and now deer, the already extremely awkward junction with Kents Bank Road and access into Cartmel Road itself and furthermore the dreadful pressures of additional homes in addition to the supermarket at the Windermere Road roundabout. I believe a local referendum would show a significant unsound vote.
790. Mr Edward Scott (Individual) : 25 Apr 2012 08:12:00
Policy/Site No.
LA3.1 Mixed Use Allocation at Berners Pool, Grange-over-Sands
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I believe the proposals for Grange and District have not taken into account my objection regarding the Cartmel Road location, the distress to wildlife, badgers and now deer, the already extremely awkward junction with Kents Bank Road and access into Cartmel Road itself and furthermore the dreadful pressures of additional homes in addition to the supermarket at the Windermere Road roundabout. I believe a local referendum would show a significant unsound vote.
791. Mr Edward Scott (Individual) : 25 Apr 2012 08:13:00
Policy/Site No.
LA3.2 Mixed Use Allocation at Land South of Allithwaite Road, Kent's Bank, Grange-over-Sands
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I believe the proposals for Grange and District have not taken into account my objection regarding the Cartmel Road location, the distress to wildlife, badgers and now deer, the already extremely awkward junction with Kents Bank Road and access into Cartmel Road itself and furthermore the dreadful pressures of additional homes in addition to the supermarket at the Windermere Road roundabout. I believe a local referendum would show a significant unsound vote.
792. Mr Edward Scott (Individual) : 25 Apr 2012 08:15:00
Policy/Site No.
LA3.3 Mixed Use Allocation at Guide's Lot, Grange-over-Sands
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I believe the proposals for Grange and District have not taken into account my objection regarding the Cartmel Road location, the distress to wildlife, badgers and now deer, the already extremely awkward junction with Kents Bank Road and access into Cartmel Road itself and furthermore the dreadful pressures of additional homes in addition to the supermarket at the Windermere Road roundabout. I believe a local referendum would show a significant unsound vote.
793. Mr John Seddon (Individual) : 16 Apr 2012 20:32:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - RN213-mod BRIGSTEER LAND OPPOSITE THE WHEATSHEAF
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
SITE RN213, LAND OPPOSITE THE WHEATSHEAF IN BRIGSTEER SHOULD NOT BE ALLOCATED FOR DEVELOPMENT.
Paragraph 3.150 states that 'no development land allocations are proposed in small villages and hamlets and in the open countryside', which I agree with. But, an exceptional allocation is made at land opposite the Wheatsheaf in Brigsteer (RN213). The main reason given for the exception is 'the degree of community involvement and support for this proposal..' This is unsound because:
1. In March 2011 an opinion survey was carried out by local residents. Over half of Brigsteer residents responded, 78% being opposed to the proposed development of RN213. The Parish Meeting on 2nd March 2011, attended by SLDC representatives Alastair McNeill and Iain Withington, clearly concurred with this opinion. The results of this opinion survey were included in a formal consultation response.
2. Helsington Parish Council in their first consultation response gave only conditional support for development of RN213. Smaller scale alternatives would be preferred and in any case development of RN213 should not be before Phase 2.
3. Helsington Parish Council, in September 2011, considered their response to the consultation as to 'Whether sites for development should be allocated in small villages and hamlets' – it was unanimously resolved that the policies in the Core Strategy supported by Neighbourhood Plans would be a more appropriate way of identifying and meeting development needs in small villages and hamlets. This was their official response to SLDC.
4. At a Parish Meeting of the electors of the Parish of Helsington held on the 10th of April 2012, the Parish again confirmed their rejection of proposals to develop site RN213. The votes were:in support of the proposed development on site RN213 20 votes; opposed to the development of site RN213 31 votes; requesting the Parish Council to respond to South lakeland District Council 55 votes.
It is therefore not sound to assert that the development of site RN213 has sufficient community support to justify exceptional allocation. In fact at every opportunity the community has voted against the proposal.
Nor is the provision of affordable housing by means of small estate development the most appropriate strategy for a small village community. Alternatives such as self-build and 'home on the farm' are obviously reasonable alternatives which are better suited to both the needs and the expressed preferences of the community. Presumably this is why centrally allocated development sites have not been proposed by SLDC in the other small villages.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
It appears that, so far, the officials at SLDC have been negligent in not attaching due weight to the abundant evidence of community opposition to allocation of site RN213 as development land. This evidence has been provided provided to them in consultation responses and in meetings which they have attended. Therefore I have no confidence that SLDC will attach due weight to this submission and therefore I wish to take part in an oral examination.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
794. Mr Richard Selvidge (Individual) : 25 Apr 2012 10:24:00
Policy/Site No.
LA1.3 Housing Allocations - R76M BURTON-in-KENDAL EAST OF HUTTON CLOSE
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I am aware that the system will only consider arguments related to the soundness and sustainability of the the proposals but as a preamble I would like to make the observation that the increases in population for Burton proposed by the development of the three parcels of land represents an increase that will change the nature of the village and put pressure on roads and other services if fully adopted. Currently it is proving very difficult for homeowners in Burton to sell their homes and whilst this may be as a result of them seeking too high prices, there is clearly very little demand for housing in this area and given the on-going state of the national economy these conditions are likely to continue for a very long time.
In my view we are in uncharted waters as far as economic development for the national economy is concerned and that coupled with the need to reduce greenhouse gas emissions for fear of climate breakdown behoves us to proceed with great caution and with moderation in setting up any development plans.
I am aware that the council believes that enacting a full framework (rather than burying heads in the sand) is the best way to proceed and I have some support for that viewpoint. However at all costs the continuity and character of village life needs to be sustained and whilst development is needed (for businesses, employment and affordable housing in particular) it is my view that the increase in housing proposed for Burton and several other local villages is by it's very size rendered unsound and unsustainable particularly with regard to likely increase in greenhouse gas emissions which must be the ultimate test of sustainability.
I would like therefore to add my support to the proposals being submitted by Burton in Kendal parish council that the housing proposals R76M and RN226/227 be removed and a phased and limited development of MN26 at Green Dragon Farm (including light employment) be the full extent of development for Burton.
Indeed, before any new development takes place there really must be some resolution of the old Royal Hotel site which is rapidly deteriorating and is proving to be a village eyesore.
795. Mr Richard Selvidge (Individual) : 25 Apr 2012 10:25:00
Policy/Site No.
LA1.3 Housing Allocations - RN226 BURTON-in-KENDAL EAST OF BOON TOWN
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I am aware that the system will only consider arguments related to the soundness and sustainability of the the proposals but as a preamble I would like to make the observation that the increases in population for Burton proposed by the development of the three parcels of land represents an increase that will change the nature of the village and put pressure on roads and other services if fully adopted. Currently it is proving very difficult for homeowners in Burton to sell their homes and whilst this may be as a result of them seeking too high prices, there is clearly very little demand for housing in this area and given the on-going state of the national economy these conditions are likely to continue for a very long time.
In my view we are in uncharted waters as far as economic development for the national economy is concerned and that coupled with the need to reduce greenhouse gas emissions for fear of climate breakdown behoves us to proceed with great caution and with moderation in setting up any development plans.
I am aware that the council believes that enacting a full framework (rather than burying heads in the sand) is the best way to proceed and I have some support for that viewpoint. However at all costs the continuity and character of village life needs to be sustained and whilst development is needed (for businesses, employment and affordable housing in particular) it is my view that the increase in housing proposed for Burton and several other local villages is by it's very size rendered unsound and unsustainable particularly with regard to likely increase in greenhouse gas emissions which must be the ultimate test of sustainability.
I would like therefore to add my support to the proposals being submitted by Burton in Kendal parish council that the housing proposals R76M and RN226/227 be removed and a phased and limited development of MN26 at Green Dragon Farm (including light employment) be the full extent of development for Burton.
Indeed, before any new development takes place there really must be some resolution of the old Royal Hotel site which is rapidly deteriorating and is proving to be a village eyesore.
796. Mr Richard Selvidge (Individual) : 25 Apr 2012 10:27:00
Policy/Site No.
LA2.13 Mixed Use Allocation at Green Dragon Farm, Burton-in-Kendal
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
I am aware that the system will only consider arguments related to the soundness and sustainability of the the proposals but as a preamble I would like to make the observation that the increases in population for Burton proposed by the development of the three parcels of land represents an increase that will change the nature of the village and put pressure on roads and other services if fully adopted. Currently it is proving very difficult for homeowners in Burton to sell their homes and whilst this may be as a result of them seeking too high prices, there is clearly very little demand for housing in this area and given the on-going state of the national economy these conditions are likely to continue for a very long time.
In my view we are in uncharted waters as far as economic development for the national economy is concerned and that coupled with the need to reduce greenhouse gas emissions for fear of climate breakdown behoves us to proceed with great caution and with moderation in setting up any development plans.
I am aware that the council believes that enacting a full framework (rather than burying heads in the sand) is the best way to proceed and I have some support for that viewpoint. However at all costs the continuity and character of village life needs to be sustained and whilst development is needed (for businesses, employment and affordable housing in particular) it is my view that the increase in housing proposed for Burton and several other local villages is by it's very size rendered unsound and unsustainable particularly with regard to likely increase in greenhouse gas emissions which must be the ultimate test of sustainability.
I would like therefore to add my support to the proposals being submitted by Burton in Kendal parish council that the housing proposals R76M and RN226/227 be removed and a phased and limited development of MN26 at Green Dragon Farm (including light employment) be the full extent of development for Burton.
Indeed, before any new development takes place there really must be some resolution of the old Royal Hotel site which is rapidly deteriorating and is proving to be a village eyesore.
797. Mrs Delia Shaw (Individual) : 24 Apr 2012 12:25:00
Policy/Site No.
LA1.3 Housing Allocations - M41KM KENDAL SOUTH OF LUMLEY ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Once again the southern side of this market town is threatened by extended development on open land on either side of the A6, beyond the existing building line. Where is the soundness for this careless decision. Both sites are valuable farm land, cattle are once again emerging after wintering inside under cover. Sheep - ewes and lambs are feeding on the green fields presently. It is a natural line for the border of the town, both physically and visually. How proud we are. How cavalier are you to make these decisions against the will of the townspeople? Industry? no doubt, because there is an open space - no, there is a limit, make homes on the brown sites within walking distance of the services, no longer lines of traffic, queueing to enter the town.
798. Mrs Delia Shaw (Individual) : 24 Apr 2012 12:31:00
Policy/Site No.
LA1.6 Strategic Employment Sites - E4M KENDAL LAND AT SCROGGS WOOD, MILNTHORPE ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Once again the southern side of this market town is threatened by extended development on open land on either side of the A6, beyond the existing building line. Where is the soundness for this careless decision. Both sites are valuable farm land, cattle are once again emerging after wintering inside under cover. Sheep - ewes and lambs are feeding on the green fields presently. It is a natural line for the border of the town, both physically and visually. How proud we are. How cavalier are you to make these decisions against the will of the townspeople? Industry? no doubt, because there is an open space - no, there is a limit, make homes on the brown sites within walking distance of the services, no longer lines of traffic, queueing to enter the town.
799. Mr Richard Simm (Individual) : 23 Mar 2012 14:15:00
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I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - R76M BURTON-in-KENDAL EAST OF HUTTON CLOSE
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
Yes
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
Re Site R76M Land at Church Bank Burton in Kendal
In response please bring it to the planning inspector's attention that in order for the site to be developed planning must be granted for all 31 properties currently envisaged by SLDC from the outset in order to be commercially viable rather than the 2 stage 17 unit
plan initially proposed. Further please also bring it to the planning inspector's attention
that as far as the existing footpath access to the village is concerned:-
1 ) That no new footpath requirement was made for the year 2000 development opposite to the site entrance and the later development of the adjacent former Burton Garage site and therefore inconsistent with previous planning policy and as such amounts to unfair treatment in breach of current national planning policy.
2 ) That footpath access can be provided to the main road from the site on the existing access road and CCC highways can then provide a pavement along the roadside into the village up to that point already existing .
3 ) That the existing access footpath is in any event adequate for the purpose and has been used regularly for many years without complaint and further exits onto a narrow existing pavement on the village main road - so that even if the footpath was wider at it's narrowest point then has been suggested by SLDC ( for example ) two prams or wheelchairs still would not be able to pass each other on the said pavement in any event - thus rendering the wider access footpath argument futile inconsistant and unfair.
800. Mrs Shirley Simm (Individual) : 16 Apr 2012 22:05:00
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Policy/Site No.
LA1.3 Housing Allocations - R163M-mod BROUGHTON-in-FURNESS FOXFIELD RD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
1.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
There is currently a shortage of available housing/sites for new build housing in Broughton in Furness. Development of this site will not greatly extend the village boundary as there are already residential properties on the opposite side of Foxfield Road and beyond (it is in effect infil).
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
Yes
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
I believe that SLDC have achieved the most acceptable proposal available in relation to the site and number of houses. It is likley to be supported by the local community.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
801. Mr James Simm (Individual) : 16 Apr 2012 22:27:00
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I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - R76M BURTON-in-KENDAL EAST OF HUTTON CLOSE
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
Yes
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
I refer to the recent filing by Peter Smith ( PS ) filed on behalf of Burton Parish Council and comment as follows:
1) PS tries to infer that some other commercial system ( other than demand led ) should have been considered which would allow affordable housing - in an effort to reduce the total number of houses to be built in Burton. The commercial reality is that developers need to sell property at commercial rates in order to subsidize the affordable housing. No developer will purchase a site to make a loss. PS objects - but does not offer a serious alternative and then inconsistently suggests that a demand led development is acceptable for site MN26 - but not the other sites.
2) Part of the remit of SLDC is to not only identify sites which might be suitable for housing - but also those sites which are genuinely likley to be developed. In the case of R76M the site is ready and able to be developed without delay - thus providing the required affordable housing sooner rather than later. It is not clear that the other sites identified in Burton- in-Kendal are actually available for development.
3) PS says there is a great deal of opposition to R76M - but a glance at the correspondence from previous SLDC public consultations reveal little objection to the site and so his comments are not supported by the evidence. The site is an infill and rounding off of the village boundaries and its visual impact substantially shielded by the properties already approved by SLDC on the lower slopes of the site.
4) PS also mentioned that Burton would be short of facilities to cope with the demand of extra housing but was only able to mention the GP situation in support. Clearly if the there is a greater demand the doctors would either increase their surgery hours or establish a surgery. The same applies to the bus and other services. It is well arguable that a greater number of people in the village may well sustain more services commercially - not less. SLDC cannot in their planning rely upon subsidies from the state to fund non commercial services or housing - including compulsory purchase of land - as has been suggested elsewhere - SLDC are not developers and have to rely upon the private sector to fulfill their housing needs.
5) With respect to cars - the detailed planning process will ensure sufficient car parking space for any new dwellings and so the village will not be 'swamped'.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
802. Mrs L.C. Sinfield (Individual) : 9 May 2012 16:26:00
Policy/Site No.
LA1.3 Housing Allocations - All Endmoor sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
We are being asked to comment on the 'soundness' of the Land Allocations i.e. that ', the document is justified, effective and consistent with national policy. Unfortunately
we are not familiar with planning procedures so we are writing this as concerned
residents of 36 years and as residents who feels there are not enough answers to the
questions. We apologise in advance for the words exceeding 500!
Question 4: The present water treatment plant of the area is at capacity. There
have been indications that the treatment plant at Low Park would be enlarged
and all sewage from the new development plus from Crooklands would be
piped there. Is it sound to re-route uphill to Low Park? Would it not be a
better option to re-route to the land earmarked for Commercial buildings at
Gatebeck. At least it would be downhill and not need pumping stations. The
proposed extension at Low Park would have a greater impact on the
surrounding area. It would be visible because of its size. At Gate beck it
would be hidden and not overlooked by houses. I imagine the cost of rerouting
to Low Park would be prohibitive due to the distance. Would you be
digging up even more of the drumlins? Have you consulted with the
landowner of the Low Park treatment works? His house overlooks the site so I
can just image his reaction to an extension of the small existing works.
Question 6: It was noted in the Westmorland Gazette that our MP Mr Tim
Farron has said that there are 1000 homes in South Lakeland that are empty.
Why build 125 new homes in Endmoor when there are 1000 already available
in the area? Is it just to fill a quota? The latest edition of the Property
magazine boasts over 2500 houses for sale in the area. Is there a need for
more housing?
Finally can I just conclude by saying that Endmoor is a Village. Increasing the
boundary will make it somewhere between a town and a village. It will lose its
character. Large but having no facilities other than 1 Spar shop, 1 Bakery and 1
Working Mens Club. The Post Office is a limited outreach service at the Village
Hall. Milnthorpe, just a few miles away, for example has shops, banks, a library,
doctors, Post Office, a chemist and within the foreseeable future 2 supermarkets. By
the time SLDC has finished with Endmoor it will be nearly as big as Milnthorpe but
without the facilities. It will be a giant housing estate with a potential youth problem
as there will be nowhere for them to go and nothing for them to do. 'Sound'- Do you
think so?
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
803. Mrs L.C. Sinfield (Individual) : 9 May 2012 16:28:00
Policy/Site No.
LA2.14 Land North of Sycamore Drive, Endmoor
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Question 1: Policy LA2: 14 Land north of sycamore Drive, Endmoor. This is
a Greenfield site, an area of natural beauty as it has Ice Age drumlins along
this stretch. Why has planning been approved for housing when it was denied
for the County Showfield? Why is the SLDC now in effect reversing its
decision on the value of the landscape. The core strategy states it is your
policy "to Protect the network of green infrastructure and important
environmental characteristics". Surely digging up the drumlins is contrary to
this? It is felt this is not sound especially when reading the clause "The
protection, and where appropriate, enhancement of flora, fauna and geological
features". Geographical features being the main focus here. Once a green site
is gone, it is gone for good. You can't recreate drumlins (except by another
ice age). Is the landscape not worth preserving for future generations?
The new estate would also have to provide off road parking for at least 100
cars (though the norm these days is for 2 cars per family). Will there be
enough room? I refer to the CS 10.2 Transport impact of new development
guidelines which states that "The proposal incorporates parking standards that
are in accordance with any adopted and emerging sub-regional and/or local
policy guidance". Also "The proposal is capable of being served by safe
access to the highway network without detriment to the amenity or character
of the locality." Would the access to the A65 and off road parking comply? Is
it sound?
This new area would also have to be blend with the existing village. There are
a lot of nice detached properties in the village - how will the new estate blend
as I understand 35% of the housing is to be restricted to affordable housing
and 55% of this to be social rented as explained in the Core strategy.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
804. Mrs L.C. Sinfield (Individual) : 9 May 2012 16:31:00
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I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - M41M ENDMOOR NORTH OF SYCAMORE DRIVE
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Question 1: Policy LA2: 14 Land north of sycamore Drive, Endmoor. This is
a Greenfield site, an area of natural beauty as it has Ice Age drumlins along
this stretch. Why has planning been approved for housing when it was denied
for the County Showfield? Why is the SLDC now in effect reversing its
decision on the value of the landscape. The core strategy states it is your
policy "to Protect the network of green infrastructure and important
environmental characteristics". Surely digging up the drumlins is contrary to
this? It is felt this is not sound especially when reading the clause "The
protection, and where appropriate, enhancement of flora, fauna and geological
features". Geographical features being the main focus here. Once a green site
is gone, it is gone for good. You can't recreate drumlins (except by another
ice age). Is the landscape not worth preserving for future generations?
• Question 2 : We understand that the proposed density of development is
around 30 houses per hectare (M41M/R670). The village was originally
consulted on around 64 houses for this site but the present indication now
shows up to 100 houses. The goal posts have been changed but residents were
not consulted. Is this lawful within the core strategy? The density is 'unsound'
as it is believed to be more than the guidelines and greater than the original
Sycamore development (which is very crowded and has parking problems).
The visual impact of this housing estate from the A65 would be immense as is
the amount of new traffic onto the A65 from the newly created entrance. The
villagers have not been privy to the composition of housing either. To build
1 00 homes for social housing, affordable homes and then integrate them with
similar houses in the area - plus provide green spaces - in such a small area
does not seem feasible without blocks of Flats. Flats in a village??? Will a set
of plans be made public so that we are able to comment - and have our
comments listened to? Will gardens be small thus creating a privacy problem?
Will roadways be kept clear for emergency vehicular access? This is a
problem already in parts of the village.
The new estate would also have to provide off road parking for at least 100
cars (though the norm these days is for 2 cars per family). Will there be
enough room? I refer to the CS 10.2 Transport impact of new development
guidelines which states that "The proposal incorporates parking standards that
are in accordance with any adopted and emerging sub-regional and/or local
policy guidance". Also "The proposal is capable of being served by safe
access to the highway network without detriment to the amenity or character
of the locality." Would the access to the A65 and off road parking comply? Is
it sound?
This new area would also have to be blend with the existing village. There are
a lot of nice detached properties in the village - how will the new estate blend
as I understand 35% of the housing is to be restricted to affordable housing
and 55% of this to be social rented as explained in the Core strategy.
• Question 3: Has any thought be given to the natural watershed of the land.
When the original Sycamore estate was developed it caused drainage problems
on the village Playing field as the natural watershed was re-routed. There is a
big difference between these 34 houses and the 100 envisaged. Has any
thought been given to how to alleviate any drainage problems which may
occur to existing properties and the school?
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
805. Mrs L.C. Sinfield (Individual) : 9 May 2012 16:35:00
Policy/Site No.
LA1.3 Housing Allocations - R670-mod ENDMOOR SOUTH OF BOWLING GREEN
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Question 2 : We understand that the proposed density of development is
around 30 houses per hectare (M41M/R670). The village was originally
consulted on around 64 houses for this site but the present indication now
shows up to 100 houses. The goal posts have been changed but residents were
not consulted. Is this lawful within the core strategy? The density is 'unsound'
as it is believed to be more than the guidelines and greater than the original
Sycamore development (which is very crowded and has parking problems).
The visual impact of this housing estate from the A65 would be immense as is
the amount of new traffic onto the A65 from the newly created entrance. The
villagers have not been privy to the composition of housing either. To build
1 00 homes for social housing, affordable homes and then integrate them with
similar houses in the area - plus provide green spaces - in such a small area
does not seem feasible without blocks of Flats. Flats in a village??? Will a set
of plans be made public so that we are able to comment - and have our
comments listened to? Will gardens be small thus creating a privacy problem?
Will roadways be kept clear for emergency vehicular access? This is a
problem already in parts of the village.
Question 5: My comment on the 25 new houses to the rear of the Bowling
Club is to question the access. The site access would possibly be onto the
single track road which leads to Kaker Mill. It is narrow and has blind comers
so is already a dangerous lane. Would it be safe to have an access from the
new estate onto a problematic road? The Bowling Club has no designated
parking so everyone parks on the road sides which will just add to ·the
conjestion. The water treatment works which is on the other side ofthe road is
said to be at capacity so again that could cause problems. If it was decided to also re-route that to Low Park, that existing site would have to be even bigger
and more of a blot on the landscape than ever.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
806. Mrs L.C. Sinfield (Individual) : 9 May 2012 16:38:00
Policy/Site No.
LA1.8 Local Employment Allocations - EN20, EN33# ENDMOOR LAND NORTH OF GATEBECK LANE, GATEBECK
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Question 4: The present water treatment plant of the area is at capacity. There
have been indications that the treatment plant at Low Park would be enlarged
and all sewage from the new development plus from Crooklands would be
piped there. Is it sound to re-route uphill to Low Park? Would it not be a
better option to re-route to the land earmarked for Commercial buildings at
Gatebeck. At least it would be downhill and not need pumping stations. The
proposed extension at Low Park would have a greater impact on the
surrounding area. It would be visible because of its size. At Gate beck it
would be hidden and not overlooked by houses. I imagine the cost of rerouting
to Low Park would be prohibitive due to the distance. Would you be
digging up even more of the drumlins? Have you consulted with the
landowner of the Low Park treatment works? His house overlooks the site so I
can just image his reaction to an extension of the small existing works.
Question 5: The creation of any industrial estate at Gate beck could imply that
work will be available to the new inhabitants of the enlarged Endmoor. Whilst
there is no objection to any additional employment prospects, has any indepth
thought been given to the actual siting of any new industrial estate. For
example there is capacity within the Crooklands area to increase warehousing
and light industry. There is a new industrial area being constructed at Moss
End. Both these existing sites have excellent access, both to the M6
motorway, the Yorkshire Dales and all routes east and west plus of course
Kendal. The one proposed at Gate beck would have disastrous access. It
would be serviced down a narrow country lane. The residents of Low Park
already have problems when coming out of Low Park Lane onto Gatebeck
Lane. You have to be nearly in the middle of the road before you can see what
is coming from your left. Gatebeck lane is also narrow especially at the
junction with the A65. Would SLDC widen the lane so that it could take 2
lorries abreast with a bit to spare for pedestrians. This lane is as present used
by lorries from the Quarry, the present industrial site at Gate beck, L& W
Wilson Haulage Contractors, visitors to the various caravan parks, local
residents as well as horses and dog walkers. A new Industrial park would add
even more perils to this road. The traffic problem was raised when a
Crematorium project was proposed for this site. That project was denied
plarming permission. It should also be noted that there are buildings available
to Rent on both the Gatebeck and Summerlands Industrial sites. Question?
Do we need another?
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
807. Mr Jon Slater (Individual) : 16 Apr 2012 10:46:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - All Kendal sites
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I consider that the process has been unsound for the following reasons
1) A largely negative public response has resulted in very little change to the plan and some sites have actually been expanded.
2) A high forecast for population growth has been adopted in the plan, which does not match with current population trends.
3) The proposed allocation for housing appears to be out of balance with the allocation for employment. We are in an area that has consistently lost large employers and only gained small, mainly service work, employment. This will encourage commuting out of the area, which is at odds with the criterion of environmental sustainability. It is also likely to increase second home ownership, which is a major problem in the area, as local people with low paid jobs may be unable to afford the new properties anyway.
4) The addition of 189 new properties in the area referenced R103M-mod will result in even more strain on the local infrastructure, such as school places, public transport and the road network. Access to these households will be via
a) the town centre – already congested particularly at rush hour times
b) Queens Road – already a problem are that has necessitated the introduction of traffic calming in the form of 20mph limit and speed bumps
c) Vicarage Drive – already a problem are that has necessitated the introduction of traffic calming in the form of 20mph limit and speed bumps
5) Green space/town boundaries – the space immediately to the west of Underwood has a tree line that provides a natural boundary to the west of the town. It can be seen from the other side of Kendal and is seen as being so important that the trees have protection orders on them to maintain that tree line. Building beyond this tree line expands the town into green space/belt and reduced the effect of this natural boundary.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
808. Mr Jon Slater (Individual) : 18 May 2012 11:48:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - R103M-mod KENDAL STAINBANK GREEN
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
4) The addition of 189 new properties in the area referenced R103M-mod will result in even more strain on the local infrastructure, such as school places, public transport and the road network. Access to these households will be via
a) the town centre – already congested particularly at rush hour times
b) Queens Road – already a problem are that has necessitated the introduction of traffic calming in the form of 20mph limit and speed bumps
c) Vicarage Drive – already a problem are that has necessitated the introduction of traffic calming in the form of 20mph limit and speed bumps
5) Green space/town boundaries – the space immediately to the west of Underwood has a tree line that provides a natural boundary to the west of the town. It can be seen from the other side of Kendal and is seen as being so important that the trees have protection orders on them to maintain that tree line. Building beyond this tree line expands the town into green space/belt and reduced the effect of this natural boundary.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
809. Mr Ronald Smallshaw (Individual) : 12 Apr 2012 19:48:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
0.0 Whole Document
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
council members on the helsington parish council ,who are also directors of the helsington land trust,appear to be intent on deliberately misleading the SLDC on the matter of local consultation on this matter and on the democratically expressed wishes of the parish electors.The two well attended parish meetings organised to discuss this matter both delivered a clear request/instruction to the council to advise SLDC of local misgivings about the proposals and the undemocratic nature of the Helsington Land Trust.At the meeting called on Tuesday 10th April a large majority of those attending voted to request the council to respond to the SLDC in accordance with the voting at the meeting.This the council voted to ignore - all directors of the Land Trust out voted the rest.These goings on are an affront to democracy.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
810. Mr Ronald Smallshaw (Individual) : 17 May 2012 11:42:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - RN213-mod BRIGSTEER LAND OPPOSITE THE WHEATSHEAF
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
council members on the helsington parish council ,who are also directors of the helsington land trust,appear to be intent on deliberately misleading the SLDC on the matter of local consultation on this matter and on the democratically expressed wishes of the parish electors.The two well attended parish meetings organised to discuss this matter both delivered a clear request/instruction to the council to advise SLDC of local misgivings about the proposals and the undemocratic nature of the Helsington Land Trust.At the meeting called on Tuesday 10th April a large majority of those attending voted to request the council to respond to the SLDC in accordance with the voting at the meeting.This the council voted to ignore - all directors of the Land Trust out voted the rest.These goings on are an affront to democracy.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
811. Mrs Claire Smith (Individual) : 17 Apr 2012 09:51:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.1 Development Boundaries- ENDMOOR
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The current strategy is not justified, evidenced by :-
• SLDC used 2005 Business plans, acknowledged as out of date. Following economic downturn, figures are deficient and do not reflect the current needs.
• SLDC Housing figures provided by Office of National Statistics, updated in 2006. Increases out of date, also out with the CCC projected increases, who deem only 2400 new homes required, not 6000. This represents a 4.6% increase in housing stock, against an 11.5% by SLDC.
• Development des not take into account the 1000 homes identified by Tim Farron in need of refurbishment.
• No requirement for local commercial / industrial development has been demonstrated. Large numbers of vacant commercial property available and already developing Auction Mart site.
• Local meeting held with SLDC. SLDC advised proposed development of M41 site, 68 homes and mixed commercial land not required. Fewer homes and no commercial development suitable for the site. Revised plans see 100 homes. No consultation took place on increases with villagers or PC.
• Sewerage / Waste water requirements show Endmoor STW and Crooklands to be at capacity. Proposed upgrade at Low Park funding in 2014 which is not guaranteed.
• Current Water supply stated by UU in need of network reinforcement..
• At Crematorium proposal, independent consultant concluded application be refused on grounds highway network unsuitable for expected volume of traffic. EN33 Commercial development would entail higher traffic volumes.
• Proposed development of EN33 is outwith Policy CS7.4
• The 30 Houses per hectare in M41M/R670 is contrary to the
? SLDC Dev Framework Section 2 Page 16 Sustainable Development Principles CS1.1 Point 2 & 3
? Land Allocation Dev Plan Doc, Appendix 1 Sustainability Appraisal for Endmoor P187
• Proposed housing density 2.5 times current village density and higher than other local village enlargements proposed.
• M41M , R670 would see 30% increase in village area, 48% increase in homes / population. SLDC stated extensions to LSC’s only permitted where a clear need for development was identified, significant environmental impacts could be avoided and previous developed land utilised.
The plans are not effective, the document is not deliverable, flexible or suitable for monitoring.
This is evidenced by :-
• The Phase 2 development of the M41M site is planned for 2017 – 2025. SLDC state a Development Brief would be required before any development could proceed. However builders interested in developing site, bringing it forward 5 years. There seems to be lack of clarity between SLDC’s phasing of the development and the building of new homes and the sewerage infrastructure
• In January 2010, the SLDC identified key issues for Endmoor included the need for a more satisfactory northern edge and the need to safeguard the surrounding landscape. Replacing a 7 home edge with a 100 home development on greenfield site does not meet these requirements.
To make the DPD legally compliant or sound, the following changes are considered necessary
1) Review design figures based on current housing and business needs
2) Reduce the Density and Number of houses in M41M/R670 to meet Dev Framework
3) Reduce the size of area of the Village Development Boundary such that this will be more compliant with the Sustainable Development Principles CS1.1 -2&3
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
812. Mrs Claire Smith (Individual) : 17 May 2012 08:46:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - All Endmoor sites
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The current strategy is not justified, evidenced by :-
• SLDC used 2005 Business plans, acknowledged as out of date. Following economic downturn, figures are deficient and do not reflect the current needs.
• SLDC Housing figures provided by Office of National Statistics, updated in 2006. Increases out of date, also out with the CCC projected increases, who deem only 2400 new homes required, not 6000. This represents a 4.6% increase in housing stock, against an 11.5% by SLDC.
• Development des not take into account the 1000 homes identified by Tim Farron in need of refurbishment.
• No requirement for local commercial / industrial development has been demonstrated. Large numbers of vacant commercial property available and already developing Auction Mart site.
• Local meeting held with SLDC. SLDC advised proposed development of M41 site, 68 homes and mixed commercial land not required. Fewer homes and no commercial development suitable for the site. Revised plans see 100 homes. No consultation took place on increases with villagers or PC.
• Sewerage / Waste water requirements show Endmoor STW and Crooklands to be at capacity. Proposed upgrade at Low Park funding in 2014 which is not guaranteed.
• Current Water supply stated by UU in need of network reinforcement..
• At Crematorium proposal, independent consultant concluded application be refused on grounds highway network unsuitable for expected volume of traffic. EN33 Commercial development would entail higher traffic volumes.
• Proposed development of EN33 is outwith Policy CS7.4
• The 30 Houses per hectare in M41M/R670 is contrary to the
? SLDC Dev Framework Section 2 Page 16 Sustainable Development Principles CS1.1 Point 2 & 3
? Land Allocation Dev Plan Doc, Appendix 1 Sustainability Appraisal for Endmoor P187
• Proposed housing density 2.5 times current village density and higher than other local village enlargements proposed.
• M41M , R670 would see 30% increase in village area, 48% increase in homes / population. SLDC stated extensions to LSC’s only permitted where a clear need for development was identified, significant environmental impacts could be avoided and previous developed land utilised.
The plans are not effective, the document is not deliverable, flexible or suitable for monitoring.
This is evidenced by :-
• The Phase 2 development of the M41M site is planned for 2017 – 2025. SLDC state a Development Brief would be required before any development could proceed. However builders interested in developing site, bringing it forward 5 years. There seems to be lack of clarity between SLDC’s phasing of the development and the building of new homes and the sewerage infrastructure
• In January 2010, the SLDC identified key issues for Endmoor included the need for a more satisfactory northern edge and the need to safeguard the surrounding landscape. Replacing a 7 home edge with a 100 home development on greenfield site does not meet these requirements.
To make the DPD legally compliant or sound, the following changes are considered necessary
1) Review design figures based on current housing and business needs
2) Reduce the Density and Number of houses in M41M/R670 to meet Dev Framework
3) Reduce the size of area of the Village Development Boundary such that this will be more compliant with the Sustainable Development Principles CS1.1 -2&3
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
813. Mrs Claire Smith (Individual) : 17 May 2012 08:48:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - M41M ENDMOOR NORTH OF SYCAMORE DRIVE
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The current strategy is not justified, evidenced by :-
• SLDC used 2005 Business plans, acknowledged as out of date. Following economic downturn, figures are deficient and do not reflect the current needs.
• SLDC Housing figures provided by Office of National Statistics, updated in 2006. Increases out of date, also out with the CCC projected increases, who deem only 2400 new homes required, not 6000. This represents a 4.6% increase in housing stock, against an 11.5% by SLDC.
• Development des not take into account the 1000 homes identified by Tim Farron in need of refurbishment.
• No requirement for local commercial / industrial development has been demonstrated. Large numbers of vacant commercial property available and already developing Auction Mart site.
• Local meeting held with SLDC. SLDC advised proposed development of M41 site, 68 homes and mixed commercial land not required. Fewer homes and no commercial development suitable for the site. Revised plans see 100 homes. No consultation took place on increases with villagers or PC.
• Sewerage / Waste water requirements show Endmoor STW and Crooklands to be at capacity. Proposed upgrade at Low Park funding in 2014 which is not guaranteed.
• Current Water supply stated by UU in need of network reinforcement..
• At Crematorium proposal, independent consultant concluded application be refused on grounds highway network unsuitable for expected volume of traffic. EN33 Commercial development would entail higher traffic volumes.
• Proposed development of EN33 is outwith Policy CS7.4
• The 30 Houses per hectare in M41M/R670 is contrary to the
? SLDC Dev Framework Section 2 Page 16 Sustainable Development Principles CS1.1 Point 2 & 3
? Land Allocation Dev Plan Doc, Appendix 1 Sustainability Appraisal for Endmoor P187
• Proposed housing density 2.5 times current village density and higher than other local village enlargements proposed.
• M41M , R670 would see 30% increase in village area, 48% increase in homes / population. SLDC stated extensions to LSC’s only permitted where a clear need for development was identified, significant environmental impacts could be avoided and previous developed land utilised.
The plans are not effective, the document is not deliverable, flexible or suitable for monitoring.
This is evidenced by :-
• The Phase 2 development of the M41M site is planned for 2017 – 2025. SLDC state a Development Brief would be required before any development could proceed. However builders interested in developing site, bringing it forward 5 years. There seems to be lack of clarity between SLDC’s phasing of the development and the building of new homes and the sewerage infrastructure
• In January 2010, the SLDC identified key issues for Endmoor included the need for a more satisfactory northern edge and the need to safeguard the surrounding landscape. Replacing a 7 home edge with a 100 home development on greenfield site does not meet these requirements.
To make the DPD legally compliant or sound, the following changes are considered necessary
1) Review design figures based on current housing and business needs
2) Reduce the Density and Number of houses in M41M/R670 to meet Dev Framework
3) Reduce the size of area of the Village Development Boundary such that this will be more compliant with the Sustainable Development Principles CS1.1 -2&3
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
814. Mrs Claire Smith (Individual) : 17 May 2012 08:49:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - R670-mod ENDMOOR SOUTH OF BOWLING GREEN
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The current strategy is not justified, evidenced by :-
• SLDC used 2005 Business plans, acknowledged as out of date. Following economic downturn, figures are deficient and do not reflect the current needs.
• SLDC Housing figures provided by Office of National Statistics, updated in 2006. Increases out of date, also out with the CCC projected increases, who deem only 2400 new homes required, not 6000. This represents a 4.6% increase in housing stock, against an 11.5% by SLDC.
• Development des not take into account the 1000 homes identified by Tim Farron in need of refurbishment.
• No requirement for local commercial / industrial development has been demonstrated. Large numbers of vacant commercial property available and already developing Auction Mart site.
• Local meeting held with SLDC. SLDC advised proposed development of M41 site, 68 homes and mixed commercial land not required. Fewer homes and no commercial development suitable for the site. Revised plans see 100 homes. No consultation took place on increases with villagers or PC.
• Sewerage / Waste water requirements show Endmoor STW and Crooklands to be at capacity. Proposed upgrade at Low Park funding in 2014 which is not guaranteed.
• Current Water supply stated by UU in need of network reinforcement..
• At Crematorium proposal, independent consultant concluded application be refused on grounds highway network unsuitable for expected volume of traffic. EN33 Commercial development would entail higher traffic volumes.
• Proposed development of EN33 is outwith Policy CS7.4
• The 30 Houses per hectare in M41M/R670 is contrary to the
? SLDC Dev Framework Section 2 Page 16 Sustainable Development Principles CS1.1 Point 2 & 3
? Land Allocation Dev Plan Doc, Appendix 1 Sustainability Appraisal for Endmoor P187
• Proposed housing density 2.5 times current village density and higher than other local village enlargements proposed.
• M41M , R670 would see 30% increase in village area, 48% increase in homes / population. SLDC stated extensions to LSC’s only permitted where a clear need for development was identified, significant environmental impacts could be avoided and previous developed land utilised.
The plans are not effective, the document is not deliverable, flexible or suitable for monitoring.
This is evidenced by :-
• The Phase 2 development of the M41M site is planned for 2017 – 2025. SLDC state a Development Brief would be required before any development could proceed. However builders interested in developing site, bringing it forward 5 years. There seems to be lack of clarity between SLDC’s phasing of the development and the building of new homes and the sewerage infrastructure
• In January 2010, the SLDC identified key issues for Endmoor included the need for a more satisfactory northern edge and the need to safeguard the surrounding landscape. Replacing a 7 home edge with a 100 home development on greenfield site does not meet these requirements.
To make the DPD legally compliant or sound, the following changes are considered necessary
1) Review design figures based on current housing and business needs
2) Reduce the Density and Number of houses in M41M/R670 to meet Dev Framework
3) Reduce the size of area of the Village Development Boundary such that this will be more compliant with the Sustainable Development Principles CS1.1 -2&3
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
815. Mrs Claire Smith (Individual) : 17 May 2012 08:51:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.8 Local Employment Allocations - EN20, EN33# ENDMOOR LAND NORTH OF GATEBECK LANE, GATEBECK
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The current strategy is not justified, evidenced by :-
• SLDC used 2005 Business plans, acknowledged as out of date. Following economic downturn, figures are deficient and do not reflect the current needs.
• SLDC Housing figures provided by Office of National Statistics, updated in 2006. Increases out of date, also out with the CCC projected increases, who deem only 2400 new homes required, not 6000. This represents a 4.6% increase in housing stock, against an 11.5% by SLDC.
• Development des not take into account the 1000 homes identified by Tim Farron in need of refurbishment.
• No requirement for local commercial / industrial development has been demonstrated. Large numbers of vacant commercial property available and already developing Auction Mart site.
• Local meeting held with SLDC. SLDC advised proposed development of M41 site, 68 homes and mixed commercial land not required. Fewer homes and no commercial development suitable for the site. Revised plans see 100 homes. No consultation took place on increases with villagers or PC.
• Sewerage / Waste water requirements show Endmoor STW and Crooklands to be at capacity. Proposed upgrade at Low Park funding in 2014 which is not guaranteed.
• Current Water supply stated by UU in need of network reinforcement..
• At Crematorium proposal, independent consultant concluded application be refused on grounds highway network unsuitable for expected volume of traffic. EN33 Commercial development would entail higher traffic volumes.
• Proposed development of EN33 is outwith Policy CS7.4
• The 30 Houses per hectare in M41M/R670 is contrary to the
? SLDC Dev Framework Section 2 Page 16 Sustainable Development Principles CS1.1 Point 2 & 3
? Land Allocation Dev Plan Doc, Appendix 1 Sustainability Appraisal for Endmoor P187
• Proposed housing density 2.5 times current village density and higher than other local village enlargements proposed.
• M41M , R670 would see 30% increase in village area, 48% increase in homes / population. SLDC stated extensions to LSC’s only permitted where a clear need for development was identified, significant environmental impacts could be avoided and previous developed land utilised.
The plans are not effective, the document is not deliverable, flexible or suitable for monitoring.
This is evidenced by :-
• The Phase 2 development of the M41M site is planned for 2017 – 2025. SLDC state a Development Brief would be required before any development could proceed. However builders interested in developing site, bringing it forward 5 years. There seems to be lack of clarity between SLDC’s phasing of the development and the building of new homes and the sewerage infrastructure
• In January 2010, the SLDC identified key issues for Endmoor included the need for a more satisfactory northern edge and the need to safeguard the surrounding landscape. Replacing a 7 home edge with a 100 home development on greenfield site does not meet these requirements.
To make the DPD legally compliant or sound, the following changes are considered necessary
1) Review design figures based on current housing and business needs
2) Reduce the Density and Number of houses in M41M/R670 to meet Dev Framework
3) Reduce the size of area of the Village Development Boundary such that this will be more compliant with the Sustainable Development Principles CS1.1 -2&3
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
816. Mr David Smithson (Individual) : 19 Apr 2012 14:59:00
Policy/Site No.
LA1.3 Housing Allocations - RN213-mod BRIGSTEER LAND OPPOSITE THE WHEATSHEAF
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The allocation is unsound in that undue weight has been given to the opinions of Helsington Community Land Trust which is an unelected unrepresentative body.
This allocation is unsound in that SLDC has given undue weight to the support
given by Helsington Community Land Trust (HCL T).
HLCT is an unelected body, membership of which includes many who are NOT
residents of Brigsteer. Few residents have been invited to join.
At a parish meeting on 2 March 2011, HCLT was castigated by a majority of
attendees for their undemocratic formation (few residents were even aware that a
body purporting to represent them was being formed) and their presumptuous
proposal to SLDC of previously unconsidered sites, including RN 213.
SLDC (lan Withington) attended ,
Opposition to RN213 was confirmed by a village wide opinion survey in March 2011,
which showed 78% of return against development of that site.
This opposition to the site and to the machinations of HLCT was further displayed at
a parish meeting on 10 Apri12012, again attended by lan Withington.
lan Withington is listed on the HLCT web site as being co-opted onto the board of
HLCT to represent SLDC. He is stated to be a previous resident of Brigsteeer
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
817. Mr Mark Southern (Individual) : 24 Apr 2012 08:14:00
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I have read the guidance notes
Paragraph No.
5.62
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
It is difficult for members of the public to comment on legal compliance becuse of the raft of documents, statutes and council documents to which the DPD must comply. It must surely be for the inspector to carefully analyse the DPD against all these criteria to determine its legal compliance or otherwise. Suffice to say, the local community do not believe that the council have complied with the process of community involvement in determining that this additional housing is required in this community, let alone in this location.
818. Mr Mark Southern (Individual) : 24 Apr 2012 08:19:00
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I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - RN152 GREENODD LAND AT THE OLD VICARAGE
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Thee is no current evidence of the need for 22 new dwellings in the area. There are already empty houses, houses to let and for sale. The school is at capacity and already has a wide catchment area . The services, utilities and access to the site are poor. The site is part of church land and has high amenity value to the community. Little account has been paid to these and other issues in including this site in the DPD.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
819. Ms Jennifer Spencer (Individual) : 11 Apr 2012 11:16:00
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Policy/Site No.
LA1.3 Housing Allocations - All Endmoor sites
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The number of houses proposed for Endmoor village is excessive. To increase these by 48% will change the character of the village - the traffic this would generate is a real worry. Enyeat Road would be seriously affected.
Also the A65 - probably produce a rat run to the motorway.
Another concern is the sewage system - I understand they are at capacity now. Village facilities would need to improve e.g. a doctors surgery required, improved bus service, a post office to name a few.
What is required is low cost housing on smaller scale - to encourage the young to stay in the village.
820. Mr and Mrs John and Helen Stafford (Individual) : 10 May 2012 09:37:00
Policy/Site No.
LA1.3 Housing Allocations - R121M-mod KENDAL EAST OF CASTLE GREEN ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I would like to inform you of my objection to the development ofland
adjacent to Castle Green Lane and Oak Tree Road (R121M)
I believe that the impact upon biodiversity, flooding and the landscape
would be such that the proposals cannot be considered to be sound
and goes against all previous assessments.
Protected species such as Great Crested Newts are known to require land
of around 500 metres surrounding their ponds for feeding and
hibernation. The biodiversity evidence base states that
"The greatest threat to them in Cumbria is the destruction of their ponds
and surrounding terrestrial habitat."
The proposals to develop (R121M) would degrade most of the land and
the pond.
The map underestimates the size of the pond which is worrying as it
suggests that the research done to date has not been thorough or accurate
enough and serves as another indication that the proposals are not sound.
The land feeds into the Stock Beck catchment, which has been shown to
be prone to flooding and has required a flood alleviation scheme to be
introduced. Developing this land would exacerbate this flooding problem
and could well undermine all the work that has gone before. This would
have serious implications on nearby properties and as yet no proper
consideration has been given to how this would be dealt with. All other
land draining into the Stock Beck catchment has been removed from
consideration; it is perplexing that R121M is still being put forward.
The land itself has been put forward for county landscape designation in
1999 and a Kendal Town Council Commissioned report called The
Landscape Character Assessment (GALPIH), which SLDC have chosen
to ignore states that R121M was the most sensitive in landscape terms of
all the nineteen possible development sites in Kendal and had a low
capacity for development. Furthermore SLDC local plan 2006 stated that
"Developments of higher hillsides further east (ofR56) would be unduly
prominent"
I believe the proposals are therefore unsound and that any problems and
contradictory evidence has not been given proper consideration before
their advancement.
Indeed it is very telling that the planner responsible did not even step foot on the site until 22 July 2011 and that was at the residents invitation.
821. Mr Colin Stamper (Individual) : 11 Apr 2012 13:58:00
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I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - RN117M KENDAL WEST OF VALLEY DRIVE
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The Land Allocations Document (DPD) is not within the Local Development Scheme and the key stages have not been followed
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Comunity Involvment Process with the DPDis not in accordance with the SCT
1.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
I do not have any support in all the land developement of Kendal and district
No personal involvement with the people near to any developement,
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
No credible evidence has been gathered nor any local community members views gathered. No councillors have bothered to ask the very people who elected them what problems / concers they have.
Reasonable alternatives (Brown Field sites) have not been addressed.
The number of people wanting homes has been vastly overstated, just look at the number of vacant properties in and around Kendal.
It seems that the whole scheme has been pushed through in great hast by a very few councillors. Could this be due to coming government legislation ???????
The wellbeing of Kendalians has been totally overlooked, perhaps the Lib. councillors who voted YES should consider that there is enough disgruntalled voters to take them out of office. Who in their right mind ignores a 98% no.
Simply put Kendal is FULL and does not need or indeed can sustain any more developement, nor do we need these so called representatives on the council who ignore our views.
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
No Support
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
822. Mr Colin Stamper (Individual) : 18 May 2012 11:41:00
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I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - All Kendal sites
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The Land Allocations Document (DPD) is not within the Local Development Scheme and the key stages have not been followed
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Comunity Involvment Process with the DPDis not in accordance with the SCT
1.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
I do not have any support in all the land developement of Kendal and district
No personal involvement with the people near to any developement,
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
No credible evidence has been gathered nor any local community members views gathered. No councillors have bothered to ask the very people who elected them what problems / concers they have.
Reasonable alternatives (Brown Field sites) have not been addressed.
The number of people wanting homes has been vastly overstated, just look at the number of vacant properties in and around Kendal.
It seems that the whole scheme has been pushed through in great hast by a very few councillors. Could this be due to coming government legislation ???????
The wellbeing of Kendalians has been totally overlooked, perhaps the Lib. councillors who voted YES should consider that there is enough disgruntalled voters to take them out of office. Who in their right mind ignores a 98% no.
Simply put Kendal is FULL and does not need or indeed can sustain any more developement, nor do we need these so called representatives on the council who ignore our views.
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
No support
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
823. Mrs Norah S Steer (Individual) : 24 Apr 2012 12:26:00
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I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - RN213-mod BRIGSTEER LAND OPPOSITE THE WHEATSHEAF
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
Yes
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
I am in favour of affordable houses and this seems to be a suitable.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
824. Mrs Norah S Steer (Individual) : 24 Apr 2012 12:30:00
Policy/Site No.
LA1.6 Strategic Employment Sites - E4M KENDAL LAND AT SCROGGS WOOD, MILNTHORPE ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I am not happy with scroggs wood being developed. I think this is E4M & EN33. I don't want to see Kendal extended and i think it is a good place for kendal people to go for a walk.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
825. Mr Peter Stephens (Individual) : 15 Apr 2012 21:08:00
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I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - R81 ARNSIDE REDHILLS ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Withdrawal of all Arnside sites and replacement with sites identified by APPT and Arnside Parish Council.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Withdrawal of R81 from the DPD in that it is at odds with national policy most particularly as expressed in the National Planning Policy Framework.
The proposal for 30 dwellings on land at Redhills Road, Arnside is not ‘sound’ in that it is not, in a number of respects, consistent with national policy as expressed in the National Planning Policy Framework.
1. Part 11 of the NPPF titled Conserving and Enhancing the Natural Environment includes paragraph 115 which says “Great weight should be given to conserving landscape and scenic beauty in National Parks, the Broads and Areas of outstanding Natural Beauty, which have the highest status of protection in relation to landscape and beauty”. The paragraph that follows goes on “Planning permission should be refused for major developments in these designated areas except in exceptional circumstances and where it can be demonstrated they are in the public interest”. There can surely be no doubt that substantial development on this site, in an Area of Outstanding Natural Beauty, would be contrary to the letter and the spirit of these expressions of national policy.
2. Paragraph 28 of the NPPF in the section headed Supporting a Prosperous Rural Economy , includes the wording, “support sustainable rural tourism and leisure developments that benefit businesses in rural areas, communities and visitors and which respect the character of the countryside.” Tourism is, of course, Arnside’s principal industry with businesses in the community heavily dependent on attracting visitors. A major tourist resource for the village is its network of footpaths and one of the most heavily used such paths is that which runs alongside the land proposed for development. This path is a major route for tourists proceeding to and from Arnside Knott and at present it provides for a pleasant walk beside an open field, whereas the building of 30 dwellings would reduce it to a tedious toil through a housing estate. In other words the amenity value of this green field site would be lost, with adverse consequences for tourism.
3. Paragraph 75 of the NPPF in that part concerned with Promoting Healthy Communities notes that “Planning policies should protect and enhance public rights of way and access”. As argued above, far from protecting and enhancing the public right of way in question, housing development would significantly harm it. It is moreover not just a path valued by tourists, it is also extensively used by local residents, by runners and walkers, by people going to the shops or exercising their dogs and by children going back and forth to school.
4. Paragraph 76 of the NPPF emphasises the importance of local communities being “able to identify for special protection green areas of particular importance to them” where new development would be ruled out “other than in very special circumstances”. There is no question but that the particular piece of green space where this development is planned is much valued by the local community. For more than a quarter of a century Arnside residents have fought to fend off development on this site. The Village Society came into being for that very purpose; petitions have been circulated, the most recent raising more than 500 signatures. Arnside Parish Council has repeatedly expressed the view that this is an important open space that should not be built on, a view that Arnside Parish Plan Trust is vigorously restating in its formulation of a new village plan.
5. The plan is unsound because it is undemocratic. APPT and Arnside Parish Council are against it. The 2 district councillors, Pru Jupe and Ian Stewart abstained (by way of absence) from the vote in favour on 18th January 2012. Recent national legislation calls for more "localism", where is the localism in this?
6. SLDC have given insufficient weight to the 550+ signature petition (all one petition and signed by 550+ different individuals) against greenfield development here in Arnside.
7. It is unsound because it fails to measure the impact an increasing population will have on more general services, especially health.
8. It is unsound because it fails to consider and deliver alternative/greener forms of transport and the increased population will add to the carbon footprint of the area. e.g. I see no reference to creating any cycling lanes or rights of way in Arnside (there are currently none).
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
826. Mr Peter Stevens (Individual) : 23 Mar 2012 13:39:00
Policy/Site No.
LA1.3 Housing Allocations - All Kendal sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I believe the plans to build 1961 (local paper) new houses in Kendal to be mistaken. There is now more than enough sprall, and any more would mostly provide for retired folk and second homes in preference to local people who may need lower priced homes. Also the available road network is insuficient for the existing population. Further housing development would spoil our small town.
827. Mr Peter Stevens (Individual) : 20 Apr 2012 11:20:00
Policy/Site No.
LA1.4 - Kendal Sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I believe the plans to build 1961 (local paper) new houses in Kendal to be mistaken. There is now more than enough sprall, and any more would mostly provide for retired folk and second homes in preference to local people who may need lower priced homes. Also the available road network is insuficient for the existing population. Further housing development would spoil our small town.
828. Mr. Allan Steward (Individual) : 12 Apr 2012 15:12:00
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I have read the guidance notes
Paragraph No.
0.0 Whole Document
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Not all Stake-Holders consulted properly re. RN121M-Mod, one of landowners is not a willing seller.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
1. Issues of Justification & Robustness of Evidence base
1.1 The proposals are based on out-of-date and unreliable evidence in the following areas:
The Strategic Housing Market Assessment (SHMA) is largely based on old studies, supplemented by the 2011 Housing Survey for which responses were received from approximately 9.5% of the households in South Lakeland (4,363 responses out of 45,792 occupied dwellings – both figures from SHMA Main Report, October 2011 page 5) . This is too small a sample to be representative of need and to form a reliable base for long-term housing policy. Some of the replies amount to little more than aspirations, e.g. those regarding intention to move.
Other parts of the SHMA are based on out-of-date statistics e.g. para 3.11 Migration Flow (ONS 2000-2010), Paras 4.86/4.89 Projected Numbers of Households (ONS 2006), and Paras 3.33/4 Travel to Work Trends (mainly 2001 Census).
1.2 The SHMA refers to the empty housing stock in South Lakeland but does not, in calculating housing requirement, make any adjustment for such stock. SHMA gives a figure of 1,024 empty homes, but that has been challenged by later estimates. An SLDC Councillor, at the 18th Jan. 2012 Council meeting, quoted 1,500, and a subsequent Conservative local election leaflet (for Brian Rendell – April 2012) asserts that the total is 2,039.
1.3 There is no clear evidence to show how those in need of affordable housing (either on the SLDC Housing List or from Housing Survey responses) would actually be able to afford to buy or rent the planned “affordable” homes. Recent slow take-up on some new developments suggests that they would not. No evidence has been put forward to demonstrate where increased levels of employment, with adequate wage/salary levels, might come from.
1.4 The reliability of the evidence base is diminished by an abrupt reversal of the geographical distribution of proposed development. The Emerging Options Consultation Edition document dated January 2011 (EO), contained an “Adjusted For Need” forecast (Table1, p11) in which the numbers for the “Kendal Rural” area were weighted upwards. This weighting is absent from the Mar. 2012 Land Allocation DPD (table in 1.2 p16) with the result that 350 houses (about a quarter of the allocation in EO) have been reallocated to the Furness area. but why is Levens quota of houses in effect unchanged (down by 1 from 74 to 73)?
1.5 The Core Strategy (adopted version, 20 Oct 2010 p3) states that “The 2006 Housing Needs Survey... concluded that the area needed 416 affordable new homes every year for the following five years.” However, there is no transparent process which connects this statement with the actual number of people on the Housing List, or the total target of 8800 houses (2003 to 2025) formed in response to the Regional Spatial Strategy and now carried forward as SLDC's own policy. The actuality is that provision of “affordables” is dependent on a single financial model, that of how many open-market houses developers can be allowed in order to subsidise some “affordables”. This results in an illogical policy of, “need one house, build three”. This is an unsustainable approach, the tail is wagging the dog.
1.6 Core Strategy section 2.1 (p14) describes sustainability as “development which meets the needs of the present without compromising the ability of future generations to meet their own needs”. I submit that irreversible development done in spite of great uncertainty is contrary to this definition and the proposals are therefore unsound and unsustainable.
2. Issues of Community Involvement
2.1 The documents upon which the Plan is based are so numerous and complex that the average householder does not have the time, experience or ability to make a reasoned judgement as to the soundness of the Plan. It is clearly impossible to complete the form unless you are very well informed and people are not going to have the time or the inclination to spend the sort of time necessary. This discriminates against a large proportion of the population.
All those without access to the Internet are at an even greater disadvantage in view of the difficulties in obtaining printed copies of the relevant documents.
The final consultation document, in form and wording, is too restrictive. This, the complexity of the issues, and the (originally imposed but now lifted) 500 word limit appear to be deliberate attempts to stifle objection.
2.2 It is made clear in the SLDC Statement of Community Involvement that SLDC is committed to certain principles (Paragraph 2.4), specifically, “an opportunity for early and on-going input, at stages where responses can make a difference”. It is less clear that any inputs differing from SLDC presumptions have been considered. From 2005 onwards SLDC actively encouraged Communities to produce a Parish /Village Plan in order to inform future planning, as well as to enhance & protect their environment.
In Dec 2008 Levens Village Plan was published, having consulted every adult in each household in the Parish (857), the Mother & Toddler Group, the Primary School, the 11-18’s and all businesses. The questionnaire return rate was a very high, 76%. (651 out of 857)
In 2008 a Rural Housing Needs Survey (RHNS) was also conducted in the Village, which identified a need for 12 affordable homes for young people in the next 5 years.
SLDC has had a copy of the Levens Village Plan since 2008 & indeed held it up as an excellent example of what a Village Plan should be. Why is it now ignored?
Similarly, SLDC has ignored the wishes of Levens parishioners expressed in responses to previous consultations. The Levens Residents Group surveyed the opinions of all parishioners for the Emerging Options and Alternative Sites consultations, and the views expressed by the vast majority of respondents (all households asked to give opinions, over 35% responded to each survey) were that development envisaged in the SLDC proposals is far too big for the village.
SLDC has allocated 73 houses (23 on site R121M-Mod & 50 on site R51M), whereas all Levens need is 11 Affordables (one of the 12 people identified in the 2008 Rural Housing Needs Survey is known to have obtained a house).
The Village Plan identified “small developments” for future planning. A small development is not a site for 50 houses (Site R51M) in a Parish of 525 dwellings.
If the SLDC policy, as expressed in the Land Allocations DPD, does not reflect local opinion or goes directly against it, and therefore does not reflect the Localism Act, this Policy is rendered unsound.
3. Issues of Sustainable Community Strategy
3.1 Infrastructure Position Statement section 4.68 (p19) states, “Any new housing developments, combined within an ageing population can be expected [to] heighten the requirement for the provision of additional services”. The Core Strategy shirks responsibility for the issue, merely referring to the requirement for “all new houses that are built are suitable, or easily adaptable, for occupation by the elderly and infirm (Lifetime Homes Standard or equivalent).” (CS 7.10 p78). The provision of more specialist accommodation is seen as the responsibility of the County Council Social Services dept. (CS 6.2 p79). SLDC recognises the presence, and future increase, of a large elderly population, but does not take a holistic approach to dealing with the problem. This conflicts with the vision put forward in CS 1.39 (p9) for “people of all ages”.
4. Issues of Sustainability as applied to Levens
4.1 Public Transport. The Village has one bus service (530), running between Kendal and Grange-Over-Sands at times that allow no possibility of its use for commuting to full-time employment.
The 555 bus services to Kendal & Lancaster do not enter the village and pedestrian access to them at the bus stops near Levens Bridge & the Heaves Hotel along the A6/A590/A591 is not safe owing to the need to walk along busy roads (e.g. Levens Lane, Dukes Hill and A6) where there are neither footpaths nor street lighting. They are also too far away for pedestrian access other than by fit & active people, thereby discriminating against the elderly and disabled.
There are no cycling routes from Levens to Key Local Centres that are safe (i.e. avoiding busy “A” roads) , practical and direct.
The conclusion from the above is that virtually all commuting to Key Local Centres by those in the planned houses would be by car. This cannot meet any reasonable definition of “sustainable”, including environmental friendliness and reduction of carbon footprint.
Roads within and leading to and from the village are generally narrow with single width “pinch points” and are therefore unsuitable for a greater density of traffic. I note that one of the main through-roads in the village (Church Rd.) has been reduced in width at one junction by up to 25% by the provision of a pavement leading nowhere (at Greengate Gardens).
The village has only a part-time Post Office (three afternoons per week).
There are no specific proposals to improve the above situation contained in the Infrastructure Position Statement.
A criteria of status as a Local Service Centre (LSC) is the presence of “ 'Good’ public transport links”, these being “accessibility by public transport to a GP, a hospital, a primary school, a secondary school, areas of employment and a major retail centre....within a 30-minute public transport journey of each destination type” (Core Strategy Section 2.13 p19). Such public transport is not available to Levens Residents and only the most cynical interpretation of the criterion would say it is.
4.2 Sustainability as an LSC. Levens is only differentiated from other villages that are not LSCs (e.g. Heversham) in that it has a shop. Heversham indeed has better public transport links. This seems an inadequate qualification for Levens to be assigned Local Service Centre status. LSCs are described as “like Key Service Centres but offer fewer services” (Core Strategy p2). Levens certainly offers fewer services than Kendal, Milnthorpe, Kirkby Lonsdale. Grange etc. but is not at all like any of them except that it contains houses.
The proposed development will merely add estates of houses to Levens. It is difficult to see how this contributes to the sustainable community vision described in Core Strategy section 1.39 (p9), “... to make South Lakeland the best place to live, work and visit”, and become one of the “inclusive, sustainable” communities with, “... a more balanced population, with an increase in the proportion of children and young people, and people of all ages playing a full role in community life”.
4.3 The Core Strategy (sec. 2.14 p19) contains a process for reviewing the hierarchical status of settlements, at 5 year intervals to reflect the gain or loss of qualifying criteria. However, this process will be ineffective in the case of loss of criteria, for the planning permissions for Levens will have been granted within the first 5 years.
5. Issues of Deliverability
5.1 Inadequate Infrastructure. There is no evidence that development will await infrastructure upgrade, and on the basis of past neglect I have no confidence that it will. Levens residents are fully aware of the inadequacy of utilities which have developed haphazardly over the years as the village has grown. On 29th Mar. 2012 the LRG chairman saw a major escape of raw sewage from the main sewer into the Levens Catchwater, repeating an incident on 24th Mar. 2011. His presence on both occasins was a coincidence & no guide to the total of such events.
In drainage as in transport there is no infrastructure plan to provide modern, reliable services. For example, it is well known that the capacity of the sewage system in Milnthorpe (which deals with Levens' sewage) is already overstretched & UU have stated that they have no budget to upgrade it and that “even if a bid is submitted there is no guarantee funding will be approved by OFWAT” (SLDC Land Allocations, Position Statement published March 2012, section 4.23 (p11) & 4.36 (p13).
Another example is the outages suffered by the various separate electricity supplies. This argues that the system is over-stretched & the statement in the Position Statement that “If there are significant demand increases across a local distribution electricity network area then the local network distribution operator may seek reinforcements at an existing substation or a new grid supply point” (Position Statement 4.45 p14) does not encourage us to believe there will be an adequate supply to support the proposed development. This is either unsound or unsustainable or both. The Position Statement is in effect a wish list without proof that all partners are signed up for it and have plans which will deliver the infrastructure.
5.2 Unrealistic model. Overall forecasts of the need for new housing (open- market & affordable) do not appear to take into account the prevailing economic conditions in Britain (very low growth in the economy & generally stagnant personal incomes), yet the target dating back to 2008/9 of 8800 new houses between 2003 & 2025 remains unchanged. I do not believe that SLDC's area is immune from these conditions. SLDC provision of affordables is dependent on a financial model that requires a buoyant housing market, and it assumes that 'if you build it, they will come'. There is far too much uncertainty in this approach for it to be the exclusive basis of a sound policy.
5.3 SLDC seem to have recognised this and have used the word “ambition” regarding the figure of 400 houses per year in the Land Allocations DPD (LADPD p7). The word used in the Core Strategy document is “target” (CS p121). It would appear that SLDC is backtracking on Core Strategy, making the LA DPD unsound.
6. Issues of compatibility with National Policy
6.1 Localism. There is no doubt that the Land Allocations DPD reflects national policy, if that policy is the Regional Spatial Strategy, but, the RSS is no longer national policy, which is now contained in the Localism Act and the National Planning Policy Framework. The imposition of the DPD by SLDC flies in the face of the principle of localism i.e. that “Instead of local people being told what to do, the Government thinks that local communities should have genuine opportunities to influence the future of the places where they live” (Department for Communities and Local Government, A plain English guide to the Localism Act, November 2011 – p15).
The Land Allocations DPD is completely at variance with parishioners desire for “limited development” reflected in the Levens Village Plan (2008), and the 2011 SHMA report does not reveal the figures for housing need obtained from Levens respondents.
7, Issues of consideration of Reasonable Alternatives
7.1 The only evidence of the examination of reasonable alternatives is that of the merits of the various sites in the Levens Fact File. The potential of other large sites becoming available (e.g. the Brettargh Holt Convent due to be offered for sale in July 2012) and affecting decisions re. location of housing, is not recognised in the Land Allocations DPD.
7.2 No evidence is presented of alternative strategies re. financing social housing as a means of providing affordables, or of other models of geographical distribution across the SLDC district e.g. creation of a new settlement or settlements to relieve the pressure on existing villages so that development within them is restricted to satisfying local needs.
7.3 There is no evidence that SLDC has considered using any other powers which are available to them, such as those related to taking over empty properties to increase the housing stock under the provisions of Section 17 of the Housing Act 1985 and those related to taking out an “Empty Dwelling Management Order” under the 2004 Housing Act.
8. Issues of specific sites
8.1Site RN121M-Mod. Since the Alternative Sites Consultation it has come to light that one of the 3 different landowners owning this site is unwilling to sell. This effectively reduces the developable site area by c30% (Levens Fact File, February 2012, p81) and the estimated housing yield accordingly. This and the difficult topography of the site would likely make development of it uneconomic and hence the allocation in the SLDC document is probably undeliverable and therefore unsound. LRG surveys revealed a widespread opinion that the site is an eyesore. The derelict buildings should be dealt with under the provisions of the Buildings Act 1984.
8.2 Site R51M. Development of this site will create a salient projecting eastwards into open country, opening the way for further developments in the fields to its south by partially surrounding site R105 thereby increasing the likelihood of future infill development.
The Levens Fact File (p79) cites “Great bio-diversity value at this site” which contains European protected species and “will need extensive mitigation”. This statement is a form of words that guarantees nothing other than pious hopes and is therefore unsustainable.
8.3 As far as the mitigation of the effect of future development on adjoining households is concerned, I am disappointed to hear that neither RN121M-Mod nor R51M would qualify for a Development Brief.
END
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
I believe that there are fundamental flaws in the soundness of the plans and that these need to be addressed by the Inspector
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
829. Mr. Allan Steward (Individual) : 11 May 2012 16:10:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - All Levens sites
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Not all Stake-Holders consulted properly re. RN121M-Mod, one of landowners is not a willing seller.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
2. Issues of Community Involvement
2.1 The documents upon which the Plan is based are so numerous and complex that the average householder does not have the time, experience or ability to make a reasoned judgement as to the soundness of the Plan. It is clearly impossible to complete the form unless you are very well informed and people are not going to have the time or the inclination to spend the sort of time necessary. This discriminates against a large proportion of the population.
All those without access to the Internet are at an even greater disadvantage in view of the difficulties in obtaining printed copies of the relevant documents.
The final consultation document, in form and wording, is too restrictive. This, the complexity of the issues, and the (originally imposed but now lifted) 500 word limit appear to be deliberate attempts to stifle objection.
2.2 It is made clear in the SLDC Statement of Community Involvement that SLDC is committed to certain principles (Paragraph 2.4), specifically, “an opportunity for early and on-going input, at stages where responses can make a difference”. It is less clear that any inputs differing from SLDC presumptions have been considered. From 2005 onwards SLDC actively encouraged Communities to produce a Parish /Village Plan in order to inform future planning, as well as to enhance & protect their environment.
In Dec 2008 Levens Village Plan was published, having consulted every adult in each household in the Parish (857), the Mother & Toddler Group, the Primary School, the 11-18’s and all businesses. The questionnaire return rate was a very high, 76%. (651 out of 857)
In 2008 a Rural Housing Needs Survey (RHNS) was also conducted in the Village, which identified a need for 12 affordable homes for young people in the next 5 years.
SLDC has had a copy of the Levens Village Plan since 2008 & indeed held it up as an excellent example of what a Village Plan should be. Why is it now ignored?
Similarly, SLDC has ignored the wishes of Levens parishioners expressed in responses to previous consultations. The Levens Residents Group surveyed the opinions of all parishioners for the Emerging Options and Alternative Sites consultations, and the views expressed by the vast majority of respondents (all households asked to give opinions, over 35% responded to each survey) were that development envisaged in the SLDC proposals is far too big for the village.
SLDC has allocated 73 houses (23 on site RN121M-Mod & 50 on site R51M), whereas all Levens need is 11 Affordables (one of the 12 people identified in the 2008 Rural Housing Needs Survey is known to have obtained a house).
The Village Plan identified “small developments” for future planning. A small development is not a site for 50 houses (Site R51M) in a Parish of 525 dwellings.
If the SLDC policy, as expressed in the Land Allocations DPD, does not reflect local opinion or goes directly against it, and therefore does not reflect the Localism Act, this Policy is rendered unsound.
3. Issues of Sustainable Community Strategy
3.1 Infrastructure Position Statement section 4.68 (p19) states, “Any new housing developments, combined within an ageing population can be expected [to] heighten the requirement for the provision of additional services”. The Core Strategy shirks responsibility for the issue, merely referring to the requirement for “all new houses that are built are suitable, or easily adaptable, for occupation by the elderly and infirm (Lifetime Homes Standard or equivalent).” (CS 7.10 p78). The provision of more specialist accommodation is seen as the responsibility of the County Council Social Services dept. (CS 6.2 p79). SLDC recognises the presence, and future increase, of a large elderly population, but does not take a holistic approach to dealing with the problem. This conflicts with the vision put forward in CS 1.39 (p9) for “people of all ages”.
4. Issues of Sustainability as applied to Levens
4.1 Public Transport. The Village has one bus service (530), running between Kendal and Grange-Over-Sands at times that allow no possibility of its use for commuting to full-time employment.
The 555 bus services to Kendal & Lancaster do not enter the village and pedestrian access to them at the bus stops near Levens Bridge & the Heaves Hotel along the A6/A590/A591 is not safe owing to the need to walk along busy roads (e.g. Levens Lane, Dukes Hill and A6) where there are neither footpaths nor street lighting. They are also too far away for pedestrian access other than by fit & active people, thereby discriminating against the elderly and disabled.
There are no cycling routes from Levens to Key Local Centres that are safe (i.e. avoiding busy “A” roads) , practical and direct.
The conclusion from the above is that virtually all commuting to Key Local Centres by those in the planned houses would be by car. This cannot meet any reasonable definition of “sustainable”, including environmental friendliness and reduction of carbon footprint.
Roads within and leading to and from the village are generally narrow with single width “pinch points” and are therefore unsuitable for a greater density of traffic. I note that one of the main through-roads in the village (Church Rd.) has been reduced in width at one junction by up to 25% by the provision of a pavement leading nowhere (at Greengate Gardens).
The village has only a part-time Post Office (three afternoons per week).
There are no specific proposals to improve the above situation contained in the Infrastructure Position Statement.
A criteria of status as a Local Service Centre (LSC) is the presence of “ 'Good’ public transport links”, these being “accessibility by public transport to a GP, a hospital, a primary school, a secondary school, areas of employment and a major retail centre....within a 30-minute public transport journey of each destination type” (Core Strategy Section 2.13 p19). Such public transport is not available to Levens Residents and only the most cynical interpretation of the criterion would say it is.
4.2 Sustainability as an LSC. Levens is only differentiated from other villages that are not LSCs (e.g. Heversham) in that it has a shop. Heversham indeed has better public transport links. This seems an inadequate qualification for Levens to be assigned Local Service Centre status. LSCs are described as “like Key Service Centres but offer fewer services” (Core Strategy p2). Levens certainly offers fewer services than Kendal, Milnthorpe, Kirkby Lonsdale. Grange etc. but is not at all like any of them except that it contains houses.
The proposed development will merely add estates of houses to Levens. It is difficult to see how this contributes to the sustainable community vision described in Core Strategy section 1.39 (p9), “... to make South Lakeland the best place to live, work and visit”, and become one of the “inclusive, sustainable” communities with, “... a more balanced population, with an increase in the proportion of children and young people, and people of all ages playing a full role in community life”.
4.3 The Core Strategy (sec. 2.14 p19) contains a process for reviewing the hierarchical status of settlements, at 5 year intervals to reflect the gain or loss of qualifying criteria. However, this process will be ineffective in the case of loss of criteria, for the planning permissions for Levens will have been granted within the first 5 years.
5. Issues of Deliverability
5.1 Inadequate Infrastructure. There is no evidence that development will await infrastructure upgrade, and on the basis of past neglect I have no confidence that it will. Levens residents are fully aware of the inadequacy of utilities which have developed haphazardly over the years as the village has grown. On 29th Mar. 2012 the LRG chairman saw a major escape of raw sewage from the main sewer into the Levens Catchwater, repeating an incident on 24th Mar. 2011. His presence on both occasins was a coincidence & no guide to the total of such events.
In drainage as in transport there is no infrastructure plan to provide modern, reliable services. For example, it is well known that the capacity of the sewage system in Milnthorpe (which deals with Levens' sewage) is already overstretched & UU have stated that they have no budget to upgrade it and that “even if a bid is submitted there is no guarantee funding will be approved by OFWAT” (SLDC Land Allocations, Position Statement published March 2012, section 4.23 (p11) & 4.36 (p13).
Another example is the outages suffered by the various separate electricity supplies. This argues that the system is over-stretched & the statement in the Position Statement that “If there are significant demand increases across a local distribution electricity network area then the local network distribution operator may seek reinforcements at an existing substation or a new grid supply point” (Position Statement 4.45 p14) does not encourage us to believe there will be an adequate supply to support the proposed development. This is either unsound or unsustainable or both. The Position Statement is in effect a wish list without proof that all partners are signed up for it and have plans which will deliver the infrastructure.
5.2 Unrealistic model. Overall forecasts of the need for new housing (open- market & affordable) do not appear to take into account the prevailing economic conditions in Britain (very low growth in the economy & generally stagnant personal incomes), yet the target dating back to 2008/9 of 8800 new houses between 2003 & 2025 remains unchanged. I do not believe that SLDC's area is immune from these conditions. SLDC provision of affordables is dependent on a financial model that requires a buoyant housing market, and it assumes that 'if you build it, they will come'. There is far too much uncertainty in this approach for it to be the exclusive basis of a sound policy.
5.3 SLDC seem to have recognised this and have used the word “ambition” regarding the figure of 400 houses per year in the Land Allocations DPD (LADPD p7). The word used in the Core Strategy document is “target” (CS p121). It would appear that SLDC is backtracking on Core Strategy, making the LA DPD unsound.
6. Issues of compatibility with National Policy
6.1 Localism. There is no doubt that the Land Allocations DPD reflects national policy, if that policy is the Regional Spatial Strategy, but, the RSS is no longer national policy, which is now contained in the Localism Act and the National Planning Policy Framework. The imposition of the DPD by SLDC flies in the face of the principle of localism i.e. that “Instead of local people being told what to do, the Government thinks that local communities should have genuine opportunities to influence the future of the places where they live” (Department for Communities and Local Government, A plain English guide to the Localism Act, November 2011 – p15).
The Land Allocations DPD is completely at variance with parishioners desire for “limited development” reflected in the Levens Village Plan (2008), and the 2011 SHMA report does not reveal the figures for housing need obtained from Levens respondents.
7, Issues of consideration of Reasonable Alternatives
7.1 The only evidence of the examination of reasonable alternatives is that of the merits of the various sites in the Levens Fact File. The potential of other large sites becoming available (e.g. the Brettargh Holt Convent due to be offered for sale in July 2012) and affecting decisions re. location of housing, is not recognised in the Land Allocations DPD.
7.2 No evidence is presented of alternative strategies re. financing social housing as a means of providing affordables, or of other models of geographical distribution across the SLDC district e.g. creation of a new settlement or settlements to relieve the pressure on existing villages so that development within them is restricted to satisfying local needs.
7.3 There is no evidence that SLDC has considered using any other powers which are available to them, such as those related to taking over empty properties to increase the housing stock under the provisions of Section 17 of the Housing Act 1985 and those related to taking out an “Empty Dwelling Management Order” under the 2004 Housing Act.
8. Issues of specific sites
8.1Site R121M-Mod. Since the Alternative Sites Consultation it has come to light that one of the 3 different landowners owning this site is unwilling to sell. This effectively reduces the developable site area by c30% (Levens Fact File, February 2012, p81) and the estimated housing yield accordingly. This and the difficult topography of the site would likely make development of it uneconomic and hence the allocation in the SLDC document is probably undeliverable and therefore unsound. LRG surveys revealed a widespread opinion that the site is an eyesore. The derelict buildings should be dealt with under the provisions of the Buildings Act 1984.
8.2 Site R51M. Development of this site will create a salient projecting eastwards into open country, opening the way for further developments in the fields to its south by partially surrounding site R105 thereby increasing the likelihood of future infill development.
The Levens Fact File (p79) cites “Great bio-diversity value at this site” which contains European protected species and “will need extensive mitigation”. This statement is a form of words that guarantees nothing other than pious hopes and is therefore unsustainable.
8.3 As far as the mitigation of the effect of future development on adjoining households is concerned, I am disappointed to hear that neither R121M-Mod nor R51M would qualify for a Development Brief.
END
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
I believe that there are fundamental flaws in the soundness of the plans and that these need to be addressed by the Inspector
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
830. Mr Les Stewart (Individual) : 5 Mar 2012 15:28:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.8 Local Employment Allocations - E13M MILNTHORPE LAND ADJ MAINLINE BUSINESS PARK
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
My comment firstly relates specifically to the designation of the Mainline Business Park(ref E13M on map) as being suitable for B8 uses in that:-
1.No evidence has been put forward that more storage and distribution facilities are required in this location.
2.The HGV's of the three large trucking companies already operating from this site pass south through the villages of Ackenthwaite and Milnthorpe 24/7,adversly affecting residents,shoppers and road users. Highway improvements were specified in the PREVIOUS LOCAL PLAN but apart from the painting of white lines to help prevent the stone rampards of the canal ridge to the north from being knocked down by HGV's, nothing has been done.
I submit that a policy that exacerbates an already unsatisfactory situation is wrong and therefore unsound.
3.The site specific problem can be resolved by improving the northern access, which readily links up with the major highway network, in conjunction with restrictions on HGV travel through Milnthorpe. While there is a vague reference to possible highway improvements in the Document, without a firm strategy,commitment and local consultation the Document cannot be considered sound.
Secondly,on a District basis, the document is unsound by failing to allocate APPROPRIATE land for B8 storage and distribution uses. The reasonable alternative, if such need is identified, being land for depots which have close access to the major highway network which the HGV's using their depots invariably require.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
To ensure my objections are recorded.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
831. Mr Peter Sudworth (Individual) : 19 Apr 2012 12:13:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - R675M-mod HOLME WEST OF BURTON ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The choices made inthe plan are not backed up by the facts. The facts are that there is not sufficient infrastructure in Holme to support a further 132 houses. No account has been taken, or mention made, of the access to the development on site R675M-mod. The need for a further 132 properties has not been proven; there are many properties for sale in the area, and many have been on the market for a considerable time.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
832. Mr Peter Sudworth (Individual) : 24 Apr 2012 14:40:00
Policy/Site No.
LA1.3 Housing Allocations - All Holme sites
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
We write to make representations regarding the LDF in relation to Holme Village. We are
totally opposed to the proposed plan and certainly do not consider it to be "sound". We
would comment in particular on the following issues:
1. Has the plan been the subject of a sustainability appraisal?
If the procedure has been followed, then has sufficient consideration been given to the current infrastructure of Holme, and how will it cope with a further 132 properties? The following points appear to be relevant:
There are no medical or health care facilities in Holme
There are no A TM facilities.
There is just one small shop.
Sewerage provision is only just coping with the current population.
Drainage capacity is overburdened. (NB the proposed site R675M-mod is bisected by
a stream).
In addition, there are already problems with traffic congestion in the village centre; there is
limited parking; there are weight restrictions on bridges; in parts of the village there are no
footpaths. What impact will the proposed development have on children returning from
school, older people, horse riders and cyclists? A further 132 houses must result, as a
minimum, in a further 132 vehicles in the village.
Apart from the above, there is also the question (in the case of R675M-mod) of site access-
via Canal Close with a restricted view from both left and right?
2. Is the plan justified?
Whilst affordable houses are needed, there seems to be no "robust and credible evidence
base" available to suggest that a further 89 houses at full market price are required. (This is
assuming that of the 132 houses proposed for the village, approximately 43 will be
affordable). In fact there are at present a large number of houses for sale in the village, some of which are arguably "affordable", but are just not selling. Might a "reasonable alternative" not be to build affordable houses on brown field sites where the cost of land might conceivably be considerably less.
833. Mr Peter Sudworth (Individual) : 24 Apr 2012 14:43:00
Policy/Site No.
LA1.3 Housing Allocations - R675M-mod HOLME WEST OF BURTON ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
In addition, there are already problems with traffic congestion in the village centre; there is
limited parking; there are weight restrictions on bridges; in parts of the village there are no
footpaths. What impact will the proposed development have on children returning from
school, older people, horse riders and cyclists? A further 132 houses must result, as a
minimum, in a further 132 vehicles in the village.
Apart from the above, there is also the question (in the case of R675M-mod) of site access-
via Canal Close with a restricted view from both left and right?
834. Mr Alan Sutcliffe (Individual) : 16 May 2012 12:23:00
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I have read the guidance notes
Policy/Site No.
LA1.10 Existing Green Infrastructure - Site Omission
If you have selected a ‘Site omission’ please enter the site reference or location and relevant policy below
Site omission - M4M
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Field M4M:
This field is open, of attractive appearance and of landscape quality (ref 2.63). To make it 'sound' according to DPD policy, it should be given AS status because:
1. It has similar qualities to the adjacent protected land AS85. As such it would form part of a larger area recognised for its amenity value by walkers and cyclists using the canal and Natland Mill Beck Lane and by members of the local community.
2. In 2006 it was regarded as an I.O.S and, as an AS, its value and quality as an open space (ref 2.64) would be enhanced.
3. It is land locked and
4. There is no public access
835. Mr Ralph Sutton (Individual) : 16 May 2012 12:52:00
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I have read the guidance notes
Paragraph No.
0.0 Whole Document
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
1.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
The Local Planning Authority has been rigorous in meeting its legal requirements in preparing the Land Allocation Development Plan Document. The Authority has been completely transparent in formulating this document. It has encouraged community involvement and it would be fair to say that the community has been actively encouraged to be involved through notices in the local press, meetings and open days in the village halls, mail drops from local councillors, availability of all information online and in local libraries and by email.
The Local Planning Authority has provided a comprehensive sustainability appraisal report which reflects social, environmental and economic factors.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
Yes
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
I believe the DPD to be justified as there has been an indepth participation of the local community at an individual and parish council level. Consideration has been given to all facts revealed by the consultation. All the organisations and individuals consulted regarding the sustainability of the DPD have been carefully listened to and the relevant facts applied to the preparation of the DPD.
I am confident that the DPD is effective and consistent with national policy given the way the Local Planning Authority has conducted the preparation of this document.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
836. Mr & Mrs Will & Ann Sweet (Individual) : 12 Apr 2012 10:24:00
Policy/Site No.
LA1.3 Housing Allocations - RN337# ARNSIDE STATION RD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
If new houses were to be built on the station-field, the chaos would be intensified, because:
* a valuable site for a car-park would be lost, even though parked cars in Station Road already cause minor traffic-jams on too many occasions;
* the residents of the houses would inevitably demand somewhere to park their own cars, thus causing even more congestion.
837. Mr & Mrs Will & Ann Sweet (Individual) : 12 Apr 2012 10:30:00
Paragraph No.
3.91
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The most urgent need in Arnside is for off-street parking in the vicinity of the railway-station and the promenade. This seems to be the only way of avoiding chaos during fine weekends in the Summer.
838. Mr & Mrs Will & Ann Sweet (Individual) : 12 Apr 2012 10:39:00
Paragraph No.
3.86
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I fear that South Lakeland District Council's housing-plans show that it has lost sight of the fact that Arnside is designated as an Area of Outstanding Natural Beauty. Is this designation to be ignored?
839. Mr Peter Tanfield (Individual) : 17 Apr 2012 11:32:00
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I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - RN213-mod BRIGSTEER LAND OPPOSITE THE WHEATSHEAF
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Site RN213 should be rejected.
Affordable housing should be prioritised to low-income families living in poor accommodation. It should be built near places of work with good facilities. There is almost no work in Brigsteer and all services, bar a village hall, are only available in Kendal. As there is only one bus a week, a resident family requires two cars. I understand that Brigsteer was considered as suitable because it is within 5 miles of services, taking no account of lack of transport, hills and winding lanes. Residents of Brigsteer recognise the high costs associated with living there.
The survey by the Cumbria Rural Housing Trust claims to have identified 25 people in 17 households requiring affordable accommodation in the parish of Helsington. (Please note that RN213 is the most remote position in the parish from Kendal.)This means the 17 households include a minimum of 9 single people. When residents replied to the survey there was an assumption that the affordable accommodation would be available for purchase, not just for rental. The survey also shows that 9 people travel more than 50 miles to work, so why supply them with houses in Brigsteer?
Brigsteer is now the only small village retained in the plan. Adoption of site RN213 is justified on the support of the Helsington Community Land Trust (HCLT) and the Parish Council. The HCLT draws much of its own support by people living outside of the parish. A majority of Brigsteer residents have expressed their opposition to use of the site by means of a survey and by a vote at a recent Parish Council general meeting. The parish council is currently controlled by 5 to 2 by directors of the HCLT and refuses to recognise the opinion of the majority of residents. Therefore, the SLDC exception policy for the Brigsteer site is falsely based.
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
The background to my change request is complex. I expect that the composition of the Helsington Parish Council will radically change at the imminent election. I would like the opportunity to explain the Brigsteer situation to the Inspector.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
840. Mrs Margaret Teasdale (Individual) : 7 Apr 2012 12:10:00
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Policy/Site No.
LA1.1 Development Boundaries- SWARTHMOOR.
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
There is no evidence that the views of residents have been properly taken into account. Too much attention has been paid to the requests of the land owners and developer.
1.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
I don't support this DPD as it has already been overtaken by recent changes to planning laws.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Firstly, in the appraisal of responses Catherine Whittaker is shown as supporting RN109M when she clearly indicated “oppose” on the response form.
There were 100 responses to the initial consultation of which only 2 were supporting any development. Of those showing support, one is by the farmer owning the land and the other is by a developer (Story Homes) acting on behalf of the landowners.
The remaining 98 responses, including those by Pennington Parish Council and a local councillor, are all opposing any development, with the exception of that by Bernie Young, who offers “partial support”. Ms Young is a member of the landowner’s family.
In other words, there is absolutely no impartial support for this proposal from any residents of the village. 97% of the responses were firmly against this development, 2% were in favour and 1% in partial support.
Secondly, assessing the result of the further consultation is practically impossible because it contains submissions that have nothing to do with Swarthmoor and shouldn’t be included.
In my view the whole consultation process has been aimed at legitimising the council’s approach and there is no evidence that any of our concerns have been properly addressed.
There are too many examples of particular concerns being dismissed as “noted or taken into account”, without any explanation of the reason for dismissal.
There is no evidence offered to support the number of properties being proposed other than to identify the need for affordable homes. In order to achieve this aim the developer will be allowed to build 3 times as many houses as are needed as compensation for building 35% affordable. This is a crazy way to meet the needs of those needing affordable homes. Also, as this is prime agricultural land, with magnificent views over the surrounding countryside, any houses thereon will attract a premium in value, to the extent that they will not be affordable into the future. If there is a need for affordable homes, they should be built in areas where they will retain affordable status.
There is clear evidence that some of the affordable homes provided as part of the extension to the Trinkeld Park estate, have been massively extended to the point where they will not be affordable when next sold,
I am concerned that the SLDC planner, with responsibility for the Swarthmoor proposals, also has responsibility for the provision of affordable homes in the district. There seems to be a conflict of interest here which must inevitably favour development even though it is clearly against the wishes of local people.
The government is telling us that where possible, development should be on brown field sites and that the wishes of local residents should be taken into account. SLDC has failed miserably on both counts and I believe that the whole process should be abandoned and future development should be under the new planning laws.
Should this development take place then it is inevitable that it will trigger a demand for a bypass of Swarthmoor by the A590, on the grounds that the village will be split by the increasingly busy trunk road. This was the main argument used by the villagers of High and Low Newton in their successful campaign to have their bypass constructed.
This is simply a crude attempt by local politicians to circumvent the recently introduced changes to the planning system and it’s interesting that all Lib Dem councillors voted for and all Conservative councillors voted against.
Politics is being used to the disadvantage of residents and SLDC should be ashamed.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
841. Mr Allan Teasdale (Individual) : 10 Apr 2012 17:37:00
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Policy/Site No.
LA1.3 Housing Allocations - All Swarthmoor sites
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I believe that RN109M should be withdrawn from the plan because due consideration has not been given to the effect of this development on the already overloaded and difficult access to the A590 from the west. Also, no consideration has been given to the effect on “local village children” of the demand for extra places at Pennington Junior School, which is already full to capacity. It seems likely that these children will have to find alternative school places which will involve unnecessary travelling, whereas at present most of them walk to school.
The western boundary to RN109M was set by the SLDC planners as being suitable for the accommodation of the number of houses deemed to be required. I was told by the planner responsible for the Swarthmoor proposal that consideration had been given to setting this boundary as a straight line between the Memorial Hall and Rufus Lane but that because this would have encompassed more land than was needed, it was rejected before the Emerging Options were selected.
The land owner in question had offered all of his land between Pennington Lane and the A590 and it was common knowledge that he wasn’t inclined to accept this proposal (RN109M).This is not speculation; the land owner told me personally at the first drop-in session at Ulverston Coronation Hall that there would be no development of RN109M as identified.
At a late stage of the Initial Consultation, a developer (Story Homes) submitted a report, on behalf of the land owners, in which an additional piece of land (RN315#) was identified that would accommodate substantially more housing than proposed by SLDC. The addition of this land effectively moved the boundary of RN109M to the position previously rejected by the planners.
This proposal was viewed with derision by local residents who had already expressed vigorous objections to any development to the west of the A590 and was dismissed as an attempt by the land owner to create an economically viable option for the disposal of his land.
It came as a great surprise to find that in the final plan, RN315# had been added to RN109M and that the western boundary had been moved exactly to the position initially rejected by the planners. This means the land owner now had a viable proposition and the land would be made available.
There can be little doubt that the land owner made it clear to the council that unless RN109M was significantly increased in size, by relocating the western boundary, the land would not be made available for development. The planner involved, having focussed, to the point of obsession, almost entirely on this particular plot, simply acceded to the land owner’s demands rather than risk losing the entire plot, completely ignoring the overwhelming expressions of concern of local residents.
In view of the extremely high proportion of objections to RN109M, expressed through the previous consultations, it beggars belief that the planners completely ignored the views of the residents who will have to live with the consequences, to ensure that this land, in whatever form, became available.
Other areas of land were identified by residents that wouldn’t involve spreading the village across the A590 and which are already owned by a local builder but for whatever reason and without any real explanation, these have been rejected by SLDC. These areas will no doubt be pursued by the owner under the new planning laws, regardless of the DPD but in the meantime there is a need to establish exactly why the planner decided not to pursue these other options; in particular RN105#, RN106.# and RN328#.
I believe that the planner’s decision to change his carefully considered plan to accommodate the wishes of the owner of RN109M, should be subjected to very careful scrutiny to ensure that the required standard of probity has been observed and that the owner did not receive preferential treatment to the detriment of residents.
It’s worthy of note that there were eight submissions by Storey Homes to the Initial Consultation, ranging throughout the district, and as a consequence areas of land identified as Emerging Options, were significantly increased in size. Whether or not a developer should be able to influence the council’s decisions to this extent is a matter for the inspector to consider.
Finally, what becomes clear when reviewing this issue throughout the SLDC area, is that the basis of the DPD is the availability of land rather than its suitability for development, or indeed whether such development is even justified
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
842. Mr Allan Teasdale (Individual) : 11 Apr 2012 11:47:00
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I have read the guidance notes
Policy/Site No.
LA1.1 Development Boundaries
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I believe that the DPD is unsound because of my concern that a developer may have had an undue influence in the preparation of the Plan, to the benefit of land owners and detriment of residents.
Eight reports were submitted as responses to the Initial Consultation by Story Homes of Carlisle, the result of which is that some sites identified as Emerging Options have been significantly increased in size in accordance with the reports.
The sites subjected to reports by Story Homes are:-
Levens R682LVM
Cartmel R112
Kendal R107M, R150M
Kendal R103M, M39
Kendal R97M
Kendal M41M
Ulverston RN131M
Swarthmoor RN109M
In the case of the last two the sites, they were definitely increased in size as a result of the Story Homes submissions.
I believe that an independent investigation should be carried out to establish the extent of the influence Story Homes has had on the DPD, before it is submitted to the government for approval. It would be foolish to proceed until this matter is resolved.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
843. Mr Allan Teasdale (Individual) : 15 May 2012 15:37:00
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Policy/Site No.
LA1.3 Housing Allocations - RN109M RN315# SWARTHMOOR OFF CROSS-a-MOOR
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
(Extracted from Rep 1) believe that RN109M should be withdrawn from the plan because due consideration has not been given to the effect of this development on the already overloaded and difficult access to the A590 from the west. Also, no consideration has been given to the effect on “local village children” of the demand for extra places at Pennington Junior School, which is already full to capacity. It seems likely that these children will have to find alternative school places which will involve unnecessary travelling, whereas at present most of them walk to school.
The western boundary to RN109M was set by the SLDC planners as being suitable for the accommodation of the number of houses deemed to be required. I was told by the planner responsible for the Swarthmoor proposal that consideration had been given to setting this boundary as a straight line between the Memorial Hall and Rufus Lane but that because this would have encompassed more land than was needed, it was rejected before the Emerging Options were selected.
The land owner in question had offered all of his land between Pennington Lane and the A590 and it was common knowledge that he wasn’t inclined to accept this proposal (RN109M).This is not speculation; the land owner told me personally at the first drop-in session at Ulverston Coronation Hall that there would be no development of RN109M as identified.
At a late stage of the Initial Consultation, a developer (Story Homes) submitted a report, on behalf of the land owners, in which an additional piece of land (RN315#) was identified that would accommodate substantially more housing than proposed by SLDC. The addition of this land effectively moved the boundary of RN109M to the position previously rejected by the planners.
This proposal was viewed with derision by local residents who had already expressed vigorous objections to any development to the west of the A590 and was dismissed as an attempt by the land owner to create an economically viable option for the disposal of his land.
It came as a great surprise to find that in the final plan, RN315# had been added to RN109M and that the western boundary had been moved exactly to the position initially rejected by the planners. This means the land owner now had a viable proposition and the land would be made available.
There can be little doubt that the land owner made it clear to the council that unless RN109M was significantly increased in size, by relocating the western boundary, the land would not be made available for development. The planner involved, having focussed, to the point of obsession, almost entirely on this particular plot, simply acceded to the land owner’s demands rather than risk losing the entire plot, completely ignoring the overwhelming expressions of concern of local residents.
In view of the extremely high proportion of objections to RN109M, expressed through the previous consultations, it beggars belief that the planners completely ignored the views of the residents who will have to live with the consequences, to ensure that this land, in whatever form, became available.
Other areas of land were identified by residents that wouldn’t involve spreading the village across the A590 and which are already owned by a local builder but for whatever reason and without any real explanation, these have been rejected by SLDC. These areas will no doubt be pursued by the owner under the new planning laws, regardless of the DPD but in the meantime there is a need to establish exactly why the planner decided not to pursue these other options; in particular RN105#, RN106.# and RN328#.
I believe that the planner’s decision to change his carefully considered plan to accommodate the wishes of the owner of RN109M, should be subjected to very careful scrutiny to ensure that the required standard of probity has been observed and that the owner did not receive preferential treatment to the detriment of residents.
It’s worthy of note that there were eight submissions by Storey Homes to the Initial Consultation, ranging throughout the district, and as a consequence areas of land identified as Emerging Options, were significantly increased in size. Whether or not a developer should be able to influence the council’s decisions to this extent is a matter for the inspector to consider.
Finally, what becomes clear when reviewing this issue throughout the SLDC area, is that the basis of the DPD is the availability of land rather than its suitability for development, or indeed whether such development is even justified
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
844. Mr Allan Teasdale (Individual) : 15 May 2012 15:40:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
1.10
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
There can be little doubt that the land owner made it clear to the council that unless RN109M was significantly increased in size, by relocating the western boundary, the land would not be made available for development. The planner involved, having focussed, to the point of obsession, almost entirely on this particular plot, simply acceded to the land owner’s demands rather than risk losing the entire plot, completely ignoring the overwhelming expressions of concern of local residents.
In view of the extremely high proportion of objections to RN109M, expressed through the previous consultations, it beggars belief that the planners completely ignored the views of the residents who will have to live with the consequences, to ensure that this land, in whatever form, became available.
Other areas of land were identified by residents that wouldn’t involve spreading the village across the A590 and which are already owned by a local builder but for whatever reason and without any real explanation, these have been rejected by SLDC. These areas will no doubt be pursued by the owner under the new planning laws, regardless of the DPD but in the meantime there is a need to establish exactly why the planner decided not to pursue these other options; in particular RN105#, RN106.# and RN328#.
I believe that the planner’s decision to change his carefully considered plan to accommodate the wishes of the owner of RN109M, should be subjected to very careful scrutiny to ensure that the required standard of probity has been observed and that the owner did not receive preferential treatment to the detriment of residents.
It’s worthy of note that there were eight submissions by Storey Homes to the Initial Consultation, ranging throughout the district, and as a consequence areas of land identified as Emerging Options, were significantly increased in size. Whether or not a developer should be able to influence the council’s decisions to this extent is a matter for the inspector to consider.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
845. Mrs Margaret Teasdale (Individual) : 16 May 2012 09:44:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - All Swarthmoor sites
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
There is no evidence that the views of residents have been properly taken into account. Too much attention has been paid to the requests of the land owners and developer.
1.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
I don't support this DPD as it has already been overtaken by recent changes to planning laws.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
There is no evidence offered to support the number of properties being proposed other than to identify the need for affordable homes. In order to achieve this aim the developer will be allowed to build 3 times as many houses as are needed as compensation for building 35% affordable. This is a crazy way to meet the needs of those needing affordable homes. Also, as this is prime agricultural land, with magnificent views over the surrounding countryside, any houses thereon will attract a premium in value, to the extent that they will not be affordable into the future. If there is a need for affordable homes, they should be built in areas where they will retain affordable status.
There is clear evidence that some of the affordable homes provided as part of the extension to the Trinkeld Park estate, have been massively extended to the point where they will not be affordable when next sold,
I am concerned that the SLDC planner, with responsibility for the Swarthmoor proposals, also has responsibility for the provision of affordable homes in the district. There seems to be a conflict of interest here which must inevitably favour development even though it is clearly against the wishes of local people.
The government is telling us that where possible, development should be on brown field sites and that the wishes of local residents should be taken into account. SLDC has failed miserably on both counts and I believe that the whole process should be abandoned and future development should be under the new planning laws.
Should this development take place then it is inevitable that it will trigger a demand for a bypass of Swarthmoor by the A590, on the grounds that the village will be split by the increasingly busy trunk road. This was the main argument used by the villagers of High and Low Newton in their successful campaign to have their bypass constructed.
This is simply a crude attempt by local politicians to circumvent the recently introduced changes to the planning system and it’s interesting that all Lib Dem councillors voted for and all Conservative councillors voted against.
Politics is being used to the disadvantage of residents and SLDC should be ashamed.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
846. Mrs Margaret Teasdale (Individual) : 16 May 2012 09:47:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
1.10
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
There is no evidence that the views of residents have been properly taken into account. Too much attention has been paid to the requests of the land owners and developer.
1.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
I don't support this DPD as it has already been overtaken by recent changes to planning laws.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Firstly, in the appraisal of responses Catherine Whittaker is shown as supporting RN109M when she clearly indicated “oppose” on the response form.
There were 100 responses to the initial consultation of which only 2 were supporting any development. Of those showing support, one is by the farmer owning the land and the other is by a developer (Story Homes) acting on behalf of the landowners.
The remaining 98 responses, including those by Pennington Parish Council and a local councillor, are all opposing any development, with the exception of that by Bernie Young, who offers “partial support”. Ms Young is a member of the landowner’s family.
In other words, there is absolutely no impartial support for this proposal from any residents of the village. 97% of the responses were firmly against this development, 2% were in favour and 1% in partial support.
Secondly, assessing the result of the further consultation is practically impossible because it contains submissions that have nothing to do with Swarthmoor and shouldn’t be included.
In my view the whole consultation process has been aimed at legitimising the council’s approach and there is no evidence that any of our concerns have been properly addressed.
There are too many examples of particular concerns being dismissed as “noted or taken into account”, without any explanation of the reason for dismissal.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
847. Mrs Margaret Teasdale (Individual) : 16 May 2012 09:50:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
0.0 Whole Document
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
There is no evidence that the views of residents have been properly taken into account. Too much attention has been paid to the requests of the land owners and developer
1.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
I don't support this DPD as it has already been overtaken by recent changes to planning laws.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
There is no evidence offered to support the number of properties being proposed other than to identify the need for affordable homes. In order to achieve this aim the developer will be allowed to build 3 times as many houses as are needed as compensation for building 35% affordable. This is a crazy way to meet the needs of those needing affordable homes. Also, as this is prime agricultural land, with magnificent views over the surrounding countryside, any houses thereon will attract a premium in value, to the extent that they will not be affordable into the future. If there is a need for affordable homes, they should be built in areas where they will retain affordable status.
There is clear evidence that some of the affordable homes provided as part of the extension to the Trinkeld Park estate, have been massively extended to the point where they will not be affordable when next sold,
I am concerned that the SLDC planner, with responsibility for the Swarthmoor proposals, also has responsibility for the provision of affordable homes in the district. There seems to be a conflict of interest here which must inevitably favour development even though it is clearly against the wishes of local people.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
848. Mr Allan Teasdale (Individual) : 18 May 2012 16:06:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
1.10
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I believe that the DPD is unsound because of my concern that a developer may have had an undue influence in the preparation of the Plan, to the benefit of land owners and detriment of residents.
Eight reports were submitted as responses to the Initial Consultation by Story Homes of Carlisle, the result of which is that some sites identified as Emerging Options have been significantly increased in size in accordance with the reports.
The sites subjected to reports by Story Homes are:-
Levens R682LVM
Cartmel R112
Kendal R107M, R150M
Kendal R103M, M39
Kendal R97M
Kendal M41M
Ulverston RN131M
Swarthmoor RN109M
In the case of the last two the sites, they were definitely increased in size as a result of the Story Homes submissions.
I believe that an independent investigation should be carried out to establish the extent of the influence Story Homes has had on the DPD, before it is submitted to the government for approval. It would be foolish to proceed until this matter is resolved.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
849. Ms Susan Teper and Mr M Ferguson (Individual) : 13 Apr 2012 16:48:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
0.0 Whole Document
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I believe SLDC have used outdated statistics and business plans to calculate housing needs, which do not reflect the current economic climate. Current figures would reduce projected needs resulting in them being more in line with what local communities feel appropriate. They would also be more in line with recent changes in Government strategy. Local Town councils and Parish Councils throughout the SLDC area have objected strongly to the DPD. Several have stated that they want housing needs to be managed under the Localism Act, as many residents feel SLDC are not responding adequately to concerns, not just about individual sites but also the scale of the increase and the general impact on the green space around our towns and villages and how this affects their character. A high proportion of residents strongly value the rural nature of the areas where they live.
The Government has stated that as part of its National Planning Policy Framework it wants to create a new designation to protect green areas of particular importance to local communities, that it wants to safeguard and enhance the environment, and that it wants to greatly increase the consultation period on such large-scale developments. SLDC seem to have largely ignored this. A huge percentage of people have objected to the proposed building on green sites, agricultural land and open countryside. SLDC's standard response to this seems to be "The Council looked first at previously used land ... secondly at suitable infill sites ... thirdly at other land which is well located...". This still does not conclude that they can justify any green site they propose.
In some cases a resident has opposed a "green gap" or "green belt" site, when perhaps they simply meant a green area and have used the wrong terminology - SLDC's "the land does not have a green belt allocation" seems more like an arrogant put-down than a valid response to a concern. Several responses to concerns are "Noted" or "have been taken into account", giving no justification or explanation.
For the DPD to be sound it must be justified - there must be evidence of participation of the local community and others having a stake in the area - the choices made in the plan must be backed up by facts. Several residents have written to the SLDC saying that facts have not been taken into account (for example on site visits). Countryside views valued by locals have been mentioned on some site visit reports but omitted on others (eg for site R692ULVM). Hedgerows are mentioned as valuable on some sites but not their existance mentioned on others (eg MN29).
Many residents feel the consultation with the public has been flawed. An SLDC representative confirmed to me that a leaflet drop should have taken place but never happened. A recent leaflet drop by locals has proved that many residents were still unaware of the exact nature of the DPD and are alarmed at the scale of it. A drop-in session in Ulverston's Coronation Hall had a small poorly written board on the pavement outside to alert passers-by which wasn't even in place on the morning of the event. I received an email notification of a consultation meeting only a few hours before the event. Actual consultation and response has been difficult and confusing for those who are not fully computer literate. Drop-in sessions proved frustrating as residents often could not get an informative answer to questions - many questions were merely answered with "that will be dealt with". A question as to how affordable housing would be maintained as affordable wasn't answered at all - this was raised by a resident who has evidence that rules regarding "affordable housing" in Swarthmoor have not been followed.
Government policy states that building in flood risk areas should be avoided, but the DPD includes several areas liable to flooding. SLDC states that one of the mitigation measures for this is to build with raised floor levels. However this does not address the problem of streets and gardens being flooded and the difficulty in obtaining home insurance. When one resident challenged SLDC that the current flooding problems in Ulverston have never been resolved as promised, he was told that new development would bring in money which would allow them to address it. When several residents said that the council currently didn't maintain the current infrastructure (roads, parks, allotments etc), they were told that funding from the new development would ensure infrastructure would be taken care of, but it was not answered as to how long this funding would last and if it would cover the existing problems. SLDC seemed to suggest that if we got behind the DPD then a lot of our current problems could be tackled, which angered many residents. Unfortunately, based on past performance, SLDC often do not follow through, or state there is insufficient budget, which is why so many residents are asking for more specific answers.
With regard to site reports and conclusions, these are inconsistent. For site RN131M (land at Gascow Farm), Cumbria County Council Highways Agency states that this would require "removal of a number of substantial trees". Cumbria Wildlife Trust states "Mature trees and hedgerows surrounding the site should be retained" and that they have "concerns about the felling of trees along Priory Rd ... these should be retained". The SLDC Arboriculturist Officer (Trees) states "Major constraint. TPO on site". However SLDC proposes the site for development, and as mitigation states "Retention of mature trees on the boundary where possible", and retention of apparently only some of the hedgerow. Surely "where possible" indicates that they will go against the recommendations. Consulting with agencies does not validate the DPD if they're prepared to do this. For site R692ULVM Cumbria Wildlife Trust states "hedgerows and mature trees surrounding the site should be retained", and the SLDC Arboriculturalist Officer(Trees) states "Major constraint. TPO on site". SLDC respond that mitigation measures will be needed, but does not state what they are, as it does with other sites (for example MN29), so it is unclear whether or not the Trust's recommendation will be followed.
Returning to general aspects of the DPD, I do not believe that Ulverston's current facilities can cope with such an increase in the size of the town. This concern has been raised by many residents and SLDC's response is that planning and consulting the relevant agencies will allow this to be catered for. However, land does not appear to have been allocated for additional schooling, medical and leisure facilities etc, so the public are unable to comment as to whether they will be located in the right places and whether they will be sufficient. The school serving Swarthmoor is apparently at capacity, but no answers have been given as to whether it is possible to expand that school or if young children would need to travel to a school elsewhere.
All in all, when looking at the concerns raised across the district, they seem to echo the same theme - that residents do not want such a large expansion, that they do not want their green spaces destroyed, and that SLDC are not consulting or responding adequately.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
850. Ms Susan Teper and Mr M Ferguson (Individual) : 15 May 2012 14:48:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
1.10
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I believe SLDC have used outdated statistics and business plans to calculate housing needs, which do not reflect the current economic climate. Current figures would reduce projected needs resulting in them being more in line with what local communities feel appropriate. They would also be more in line with recent changes in Government strategy. Local Town councils and Parish Councils throughout the SLDC area have objected strongly to the DPD. Several have stated that they want housing needs to be managed under the Localism Act, as many residents feel SLDC are not responding adequately to concerns, not just about individual sites but also the scale of the increase and the general impact on the green space around our towns and villages and how this affects their character. A high proportion of residents strongly value the rural nature of the areas where they live.
The Government has stated that as part of its National Planning Policy Framework it wants to create a new designation to protect green areas of particular importance to local communities, that it wants to safeguard and enhance the environment, and that it wants to greatly increase the consultation period on such large-scale developments. SLDC seem to have largely ignored this. A huge percentage of people have objected to the proposed building on green sites, agricultural land and open countryside. SLDC's standard response to this seems to be "The Council looked first at previously used land ... secondly at suitable infill sites ... thirdly at other land which is well located...". This still does not conclude that they can justify any green site they propose.
In some cases a resident has opposed a "green gap" or "green belt" site, when perhaps they simply meant a green area and have used the wrong terminology - SLDC's "the land does not have a green belt allocation" seems more like an arrogant put-down than a valid response to a concern. Several responses to concerns are "Noted" or "have been taken into account", giving no justification or explanation.
For the DPD to be sound it must be justified - there must be evidence of participation of the local community and others having a stake in the area - the choices made in the plan must be backed up by facts. Several residents have written to the SLDC saying that facts have not been taken into account (for example on site visits). Countryside views valued by locals have been mentioned on some site visit reports but omitted on others (eg for site R692ULVM). Hedgerows are mentioned as valuable on some sites but not their existance mentioned on others (eg MN29).
Many residents feel the consultation with the public has been flawed. An SLDC representative confirmed to me that a leaflet drop should have taken place but never happened. A recent leaflet drop by locals has proved that many residents were still unaware of the exact nature of the DPD and are alarmed at the scale of it. A drop-in session in Ulverston's Coronation Hall had a small poorly written board on the pavement outside to alert passers-by which wasn't even in place on the morning of the event. I received an email notification of a consultation meeting only a few hours before the event. Actual consultation and response has been difficult and confusing for those who are not fully computer literate. Drop-in sessions proved frustrating as residents often could not get an informative answer to questions - many questions were merely answered with "that will be dealt with". A question as to how affordable housing would be maintained as affordable wasn't answered at all - this was raised by a resident who has evidence that rules regarding "affordable housing" in Swarthmoor have not been followed.
Government policy states that building in flood risk areas should be avoided, but the DPD includes several areas liable to flooding. SLDC states that one of the mitigation measures for this is to build with raised floor levels. However this does not address the problem of streets and gardens being flooded and the difficulty in obtaining home insurance. When one resident challenged SLDC that the current flooding problems in Ulverston have never been resolved as promised, he was told that new development would bring in money which would allow them to address it. When several residents said that the council currently didn't maintain the current infrastructure (roads, parks, allotments etc), they were told that funding from the new development would ensure infrastructure would be taken care of, but it was not answered as to how long this funding would last and if it would cover the existing problems. SLDC seemed to suggest that if we got behind the DPD then a lot of our current problems could be tackled, which angered many residents. Unfortunately, based on past performance, SLDC often do not follow through, or state there is insufficient budget, which is why so many residents are asking for more specific answers.
With regard to site reports and conclusions, these are inconsistent. For site RN131M (land at Gascow Farm), Cumbria County Council Highways Agency states that this would require "removal of a number of substantial trees". Cumbria Wildlife Trust states "Mature trees and hedgerows surrounding the site should be retained" and that they have "concerns about the felling of trees along Priory Rd ... these should be retained". The SLDC Arboriculturist Officer (Trees) states "Major constraint. TPO on site". However SLDC proposes the site for development, and as mitigation states "Retention of mature trees on the boundary where possible", and retention of apparently only some of the hedgerow. Surely "where possible" indicates that they will go against the recommendations. Consulting with agencies does not validate the DPD if they're prepared to do this. For site R692ULVM Cumbria Wildlife Trust states "hedgerows and mature trees surrounding the site should be retained", and the SLDC Arboriculturalist Officer(Trees) states "Major constraint. TPO on site". SLDC respond that mitigation measures will be needed, but does not state what they are, as it does with other sites (for example MN29), so it is unclear whether or not the Trust's recommendation will be followed.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
851. Ms Susan Teper and Mr M Ferguson (Individual) : 15 May 2012 14:50:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - All Ulverston sites
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I believe SLDC have used outdated statistics and business plans to calculate housing needs, which do not reflect the current economic climate. Current figures would reduce projected needs resulting in them being more in line with what local communities feel appropriate. They would also be more in line with recent changes in Government strategy. Local Town councils and Parish Councils throughout the SLDC area have objected strongly to the DPD. Several have stated that they want housing needs to be managed under the Localism Act, as many residents feel SLDC are not responding adequately to concerns, not just about individual sites but also the scale of the increase and the general impact on the green space around our towns and villages and how this affects their character. A high proportion of residents strongly value the rural nature of the areas where they live.
The Government has stated that as part of its National Planning Policy Framework it wants to create a new designation to protect green areas of particular importance to local communities, that it wants to safeguard and enhance the environment, and that it wants to greatly increase the consultation period on such large-scale developments. SLDC seem to have largely ignored this. A huge percentage of people have objected to the proposed building on green sites, agricultural land and open countryside. SLDC's standard response to this seems to be "The Council looked first at previously used land ... secondly at suitable infill sites ... thirdly at other land which is well located...". This still does not conclude that they can justify any green site they propose.
In some cases a resident has opposed a "green gap" or "green belt" site, when perhaps they simply meant a green area and have used the wrong terminology - SLDC's "the land does not have a green belt allocation" seems more like an arrogant put-down than a valid response to a concern. Several responses to concerns are "Noted" or "have been taken into account", giving no justification or explanation.
For the DPD to be sound it must be justified - there must be evidence of participation of the local community and others having a stake in the area - the choices made in the plan must be backed up by facts. Several residents have written to the SLDC saying that facts have not been taken into account (for example on site visits). Countryside views valued by locals have been mentioned on some site visit reports but omitted on others (eg for site R692ULVM). Hedgerows are mentioned as valuable on some sites but not their existance mentioned on others (eg MN29).
Many residents feel the consultation with the public has been flawed. An SLDC representative confirmed to me that a leaflet drop should have taken place but never happened. A recent leaflet drop by locals has proved that many residents were still unaware of the exact nature of the DPD and are alarmed at the scale of it. A drop-in session in Ulverston's Coronation Hall had a small poorly written board on the pavement outside to alert passers-by which wasn't even in place on the morning of the event. I received an email notification of a consultation meeting only a few hours before the event. Actual consultation and response has been difficult and confusing for those who are not fully computer literate. Drop-in sessions proved frustrating as residents often could not get an informative answer to questions - many questions were merely answered with "that will be dealt with". A question as to how affordable housing would be maintained as affordable wasn't answered at all - this was raised by a resident who has evidence that rules regarding "affordable housing" in Swarthmoor have not been followed.
Government policy states that building in flood risk areas should be avoided, but the DPD includes several areas liable to flooding. SLDC states that one of the mitigation measures for this is to build with raised floor levels. However this does not address the problem of streets and gardens being flooded and the difficulty in obtaining home insurance. When one resident challenged SLDC that the current flooding problems in Ulverston have never been resolved as promised, he was told that new development would bring in money which would allow them to address it. When several residents said that the council currently didn't maintain the current infrastructure (roads, parks, allotments etc), they were told that funding from the new development would ensure infrastructure would be taken care of, but it was not answered as to how long this funding would last and if it would cover the existing problems. SLDC seemed to suggest that if we got behind the DPD then a lot of our current problems could be tackled, which angered many residents. Unfortunately, based on past performance, SLDC often do not follow through, or state there is insufficient budget, which is why so many residents are asking for more specific answers.
With regard to site reports and conclusions, these are inconsistent. For site RN131M (land at Gascow Farm), Cumbria County Council Highways Agency states that this would require "removal of a number of substantial trees". Cumbria Wildlife Trust states "Mature trees and hedgerows surrounding the site should be retained" and that they have "concerns about the felling of trees along Priory Rd ... these should be retained". The SLDC Arboriculturist Officer (Trees) states "Major constraint. TPO on site". However SLDC proposes the site for development, and as mitigation states "Retention of mature trees on the boundary where possible", and retention of apparently only some of the hedgerow. Surely "where possible" indicates that they will go against the recommendations. Consulting with agencies does not validate the DPD if they're prepared to do this. For site R692ULVM Cumbria Wildlife Trust states "hedgerows and mature trees surrounding the site should be retained", and the SLDC Arboriculturalist Officer(Trees) states "Major constraint. TPO on site". SLDC respond that mitigation measures will be needed, but does not state what they are, as it does with other sites (for example MN29), so it is unclear whether or not the Trust's recommendation will be followed.
Returning to general aspects of the DPD, I do not believe that Ulverston's current facilities can cope with such an increase in the size of the town. This concern has been raised by many residents and SLDC's response is that planning and consulting the relevant agencies will allow this to be catered for. However, land does not appear to have been allocated for additional schooling, medical and leisure facilities etc, so the public are unable to comment as to whether they will be located in the right places and whether they will be sufficient. The school serving Swarthmoor is apparently at capacity, but no answers have been given as to whether it is possible to expand that school or if young children would need to travel to a school elsewhere.
All in all, when looking at the concerns raised across the district, they seem to echo the same theme - that residents do not want such a large expansion, that they do not want their green spaces destroyed, and that SLDC are not consulting or responding adequately.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
852. Mr Andrew Thomas (Individual) : 9 May 2012 13:22:00
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I have read the guidance notes
Policy/Site No.
LA1.10 Existing Green Infrastructure - Site Omission
If you have selected a ‘Site omission’ please enter the site reference or location and relevant policy below
Site Omission M4M
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
In the former South Lakeland Local Plan all the land wrapping around
Helme Drive at Kendal was designated as Open Important Space, which
meant there was a presumption against development. In the Land
Allocation Development Plan Document (DPD) only the southern part of
this field is allocated as Amenity Space, which, I understand, means there
is a similar presumption against development.
I believe the northern section of the field should also be designated in this
way as it has similar open space and amenity value. It lies next to the
former Kendal Canal, which may well be re-opened in the future -open
fields adjoining such a canal would have far more amenity value than
houses or other development. The land is close to the historic canal
bridge on Natland Mill Beck Lane and allows open views from that
bridge. The field's unusual mounds and hollows suggest that it would be
worthy of archaeological excavation. It is also close to Natland Mill
Beck, which should be protected.
I believe the DPD is 'unsound' because it fails to recognise the open
space and amenity value of the land to the north of Helme Drive. This
objection would be resolved if the plan was amended so that this land is
also allocated as Amenity Space.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
853. Mrs Cheryl Thompson (Individual) : 28 Mar 2012 20:56:00
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I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - M9M2-mod MILNTHORPE NORTH WEST OF MILNTHORPE
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The scale of proposed development is grossly disproportionate to the size of the site in question and would cause unacceptable negative impact on the village landscape. As an elevated site, the buildings would be highly visible not only from the neighbouring Dallam Chase and Grisleymires Lane but also from Church Street, Kirkgate and the area to the north of the village and from Dallam Tower Estate and the area to the south, meaning that the impact would be visually intrusive on a wide scale. The nearby Booths development and the proposed commercial sites next to Houghton's coachworks already detract from the appearance of this corner of the village and more development would only serve to further destroy the character of the village. Access to this site is already a safety issue due to the business traffic via Grisleymires Lane, that includes many large lorries to both the coachworks and Booths. Further development here would serve to exacerbate the problem. Placing any number of houses on this site would also serve to put further unnecessary pressure on an already temperamental drainage and sewerage system. This greenfield site is also in constant farming use (for the grazing of both cows and sheep and for silage, cut here several times throughout the year) so is already an active working part of the village and necessary to the essential village character of Milnthorpe.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
854. Mr Geoff Thompson (Individual) : 17 Apr 2012 09:51:00
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Policy/Site No.
LA2.6 Land South of Natland Beck Farm
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
See comments in section 2.3 below
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Land off Natland Mill Beck Lane, Kendal…R97M-mod/part MN34-mod
1 It is extremely disappointing that SLDC pursues a Development Strategy of `a dispersed pattern of new development` around the edge of Kendal (para 3.9). This is contrary both to its own Corporate Plan and Core Strategy. The Corporate Plan seeks to protect the local environment in circumstances where, as in the case of the area R97M-mod, part of MN34mod, that land positively contributes to the character and appearance of Kendal. The Core Strategy seeks to achieve ` a superb high quality natural and built environment` which,in my view, is undermined by a significant allocation of land to housing at the periphery. The high quality landscape setting of Kendal should be protected as a non-negotiable element in the Plan as suggested in para 3.6 `
Under the heading of `Local factors influencing the location of development`….`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`. Such an approach is from the Natland Road and the former canal.
2 The land proposed at Natland Mill Farm is prominent and of parkland character with significant trees within the site and to the periphery. The number of houses and the size of land take proposed would be visually intrusive and have an adverse impact on the appearance and character of the area to an unacceptable and harmful degree.
3 It seems that too little encouragement in the use of Brownfield land (required by the NPPF) exists. It will always be more attractive to a developer to develop Greenfield land but the Council has to put the needs of Kendal before the demands/profit of developers. Development of Brownfield Land can be deliverable if the Council has the will to do it. For example, the Council should be proactive it bringing land forward that has remained vacant/under-used in Kendal for significant periods of time , such as ;
*the former `K`shoes employment site off Natland Road
*the former Webbs Garden Centre Land off Burneside Road
*the unsold flats over `K-Village` Retail Site
*the empty Public Houses eg The Bowman, The Feathers
*public utility land used essentially for storage eg off Parkside Road
4 Development within the existing built envelope does not have to lead to town cramming as existing amenity space can be protected. Appropriate redevelopment of land would complement the historic pattern of high density development within the core of Kendal.
5 However, if the Inspector considers that the need for the development outweighs the significant harm to the locality then Policy LA 2.6 is too imprecise. The Policy should require the preparation of a Planning Design Brief for the site. That brief should :
*Require vehicular access only from Natland Road. The appearance and character of Natland Mill Beck Lane as a ;
* rural,
* unlit,
* single width carriageway with no throughway,and with
* no footpath should be preserved.
Only access by foot and cycle to the site from Natland Mill Beck Lane should be allowed. This is in order that the character referred to above and the special features of the mill leat with its edging limestone blocks and the oak trees protected by Tree Preservation Orders are safeguarded as , in my view, any widening of the Lane would, in addition, unacceptably encroach upon the land designated as amenity open space. It is insufficient in the policy to call merely for `the submission and approval of a Transport Assessment`.
*Specify which trees/hedgerows are to be protected and what type and nature of landscaping should be incorporated into the development.
*Limit the height of any new development to 2 storey to respect the surrounding rural nature of the land and the sensitivity of this edge of town site. Here the town should seek a `soft` landscape edge rather than one that is `hard`, urban and uncompromising.
*Indicate the future for the existing farm buildings/land as the proposed development would render them redundant by isolating farm land from the working buildings.
6 In view of the inconsistency of the Council in allocating land for housing near Natland Mill Beck Lane with its own policies and objectives, the Inspector is urged to find this proposal unsound. The Inspector is urged to give greater weight to the importance of safeguarding land of high landscape importance to Kendal than that applied by the Council by rejecting housing on land at R97M-mod/part MN34-mod.
G F Thompson BA, Dip TP, MRTPI( Rtd), DMS
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
If necessary to clarify points raised.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
855. Mr George B. Thompson (Individual) : 26 Apr 2012 08:24:00
Policy/Site No.
LA1.3 Housing Allocations - M41KM KENDAL SOUTH OF LUMLEY ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I would like to add my objection to the proposed development of this area of South Kendal.
1. It would certainly spoil the approach to the town. Imagine the impression on visitors. To be greeted by an industrial estate after a pleasant run in from the M6. If Kendal is trying to attract visitors, this is a mistake. The present approach offers a gentle transition from rural countryside to pleasant town. This is most attractive, with Holy Trinity Church and the River Kent as a grand finale. Why deface it?
2. The road layout to give access to an industrial site and the extra weight of heavy goods traffic will cause delays and frustration. It will move the present problems of early morning congestion and tail backs from Romney Rd traffic lights to Helsington. Any tail backs down the A6 and on to the A591 could affect other traffic into the Lakes. The whole traffic problem has the potential to cause more accidents.
3. Why does the town need another industrial estate when there are unoccupied sites on the existing industrial estates.
In short I don’t think this development is necessary or desirable. It must be purely political.
I would draw attention to
• The problems of closed shops on the main street and the increasing number of Charity Shops.
• The failure of the K Shoe Development to attract businesses and residents.
• The doubtful development of Canal Head.
There are enough problems to be sorted out here.
856. Mr George B. Thompson (Individual) : 26 Apr 2012 08:41:00
Policy/Site No.
LA1.6 Strategic Employment Sites - E4M KENDAL LAND AT SCROGGS WOOD, MILNTHORPE ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I would like to add my objection to the proposed development of this area of South Kendal.
1. It would certainly spoil the approach to the town. Imagine the impression on visitors. To be greeted by an industrial estate after a pleasant run in from the M6. If Kendal is trying to attract visitors, this is a mistake. The present approach offers a gentle transition from rural countryside to pleasant town. This is most attractive, with Holy Trinity Church and the River Kent as a grand finale. Why deface it?
2. The road layout to give access to an industrial site and the extra weight of heavy goods traffic will cause delays and frustration. It will move the present problems of early morning congestion and tail backs from Romney Rd traffic lights to Helsington. Any tail backs down the A6 and on to the A591 could affect other traffic into the Lakes. The whole traffic problem has the potential to cause more accidents.
3. Why does the town need another industrial estate when there are unoccupied sites on the existing industrial estates.
In short I don’t think this development is necessary or desirable. It must be purely political.
I would draw attention to
• The problems of closed shops on the main street and the increasing number of Charity Shops.
• The failure of the K Shoe Development to attract businesses and residents.
• The doubtful development of Canal Head.
There are enough problems to be sorted out here.
857. Mr Geoff Thompson (Individual) : 16 May 2012 14:35:00
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I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - R97 /MN34# KENDAL SOUTH OF NATLAND BECK FARM
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Land off Natland Mill Beck Lane, Kendal…R97M-mod/part MN34-mod
1 It is extremely disappointing that SLDC pursues a Development Strategy of `a dispersed pattern of new development` around the edge of Kendal (para 3.9). This is contrary both to its own Corporate Plan and Core Strategy. The Corporate Plan seeks to protect the local environment in circumstances where, as in the case of the area R97M-mod, part of MN34mod, that land positively contributes to the character and appearance of Kendal. The Core Strategy seeks to achieve ` a superb high quality natural and built environment` which,in my view, is undermined by a significant allocation of land to housing at the periphery. The high quality landscape setting of Kendal should be protected as a non-negotiable element in the Plan as suggested in para 3.6 `
Under the heading of `Local factors influencing the location of development`….`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`. Such an approach is from the Natland Road and the former canal.
2 The land proposed at Natland Mill Farm is prominent and of parkland character with significant trees within the site and to the periphery. The number of houses and the size of land take proposed would be visually intrusive and have an adverse impact on the appearance and character of the area to an unacceptable and harmful degree.
3 It seems that too little encouragement in the use of Brownfield land (required by the NPPF) exists. It will always be more attractive to a developer to develop Greenfield land but the Council has to put the needs of Kendal before the demands/profit of developers. Development of Brownfield Land can be deliverable if the Council has the will to do it. For example, the Council should be proactive it bringing land forward that has remained vacant/under-used in Kendal for significant periods of time , such as ;
*the former `K`shoes employment site off Natland Road
*the former Webbs Garden Centre Land off Burneside Road
*the unsold flats over `K-Village` Retail Site
*the empty Public Houses eg The Bowman, The Feathers
*public utility land used essentially for storage eg off Parkside Road
4 Development within the existing built envelope does not have to lead to town cramming as existing amenity space can be protected. Appropriate redevelopment of land would complement the historic pattern of high density development within the core of Kendal.
5 However, if the Inspector considers that the need for the development outweighs the significant harm to the locality then Policy LA 2.6 is too imprecise. The Policy should require the preparation of a Planning Design Brief for the site. That brief should :
*Require vehicular access only from Natland Road. The appearance and character of Natland Mill Beck Lane as a ;
* rural,
* unlit,
* single width carriageway with no throughway,and with
* no footpath should be preserved.
Only access by foot and cycle to the site from Natland Mill Beck Lane should be allowed. This is in order that the character referred to above and the special features of the mill leat with its edging limestone blocks and the oak trees protected by Tree Preservation Orders are safeguarded as , in my view, any widening of the Lane would, in addition, unacceptably encroach upon the land designated as amenity open space. It is insufficient in the policy to call merely for `the submission and approval of a Transport Assessment`.
*Specify which trees/hedgerows are to be protected and what type and nature of landscaping should be incorporated into the development.
*Limit the height of any new development to 2 storey to respect the surrounding rural nature of the land and the sensitivity of this edge of town site. Here the town should seek a `soft` landscape edge rather than one that is `hard`, urban and uncompromising.
*Indicate the future for the existing farm buildings/land as the proposed development would render them redundant by isolating farm land from the working buildings.
6 In view of the inconsistency of the Council in allocating land for housing near Natland Mill Beck Lane with its own policies and objectives, the Inspector is urged to find this proposal unsound. The Inspector is urged to give greater weight to the importance of safeguarding land of high landscape importance to Kendal than that applied by the Council by rejecting housing on land at R97M-mod/part MN34-mod.
G F Thompson BA, Dip TP, MRTPI( Rtd), DMS
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
If necessary to clarify points raised.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
858. Mrs Kathleen Trimingham (Individual) : 16 Apr 2012 14:08:00
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I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - R103M-mod KENDAL STAINBANK GREEN
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The DPD as it stands does not recognise the intrinsic character and beauty of the countryside around the town. The Land at Stainbank Green (R103m), in its current state as farmland contributes greatly to maintaining Kendal’s identity, landscape setting and character. Building on this site and blocking the view from the dual carriageway across the town to the fells will have a profound detrimental effect on the environment and will damage the tourist industry both for the town and the Lakes.
There is a need to beware of speculative building when there are unsold new properties such as the KVillage development. In addition there are town centre sites that are more suitable for affordable housing development, eg the Kendal Bowman site. Use of such sites would be more sustainable as travel to amenties would be greatly reduced in comparison to an out of town development.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
859. Mr Ivan Trimingham (Individual) : 16 Apr 2012 14:05:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - R103M-mod KENDAL STAINBANK GREEN
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
1.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
I think this document is over complicated and is designed to deter people from being able to make their comments known. How many of the population of the area do not have access to a computer?
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD should not be approved until there is a credible infrastructure plan in place.
No site should be included until it is shown to be deliverable on transport grounds.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
860. Mr Michael Turner (Individual) : 16 May 2012 13:11:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - RN133M KENDAL WEST OF OXENHOLME ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not been prepared in accordance with the Town & County Planning Regulations 2004 (as amended)
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
1) Town's absorption of village: Development on land at Oxenholme Road, Kendal would link the town to Oxenholme village. This is contrary to government policy;
2) Detrimental to tourism: the development would create an unpleasant view for UK and foreign tourists travelling to the Lake District by rail. This triangle of open land was subject to an appeal process some years age. The Inquiry found that openess should be maintained to preserve the character of the area.
3) Justification: increasing the housing stock in this area has not been justified. The need for expansion has not been proven. Disregard for local occupants has been evident.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Land at Oxenholme Road, Kendal should not be developed. Openness in this location is vital to maintain the character of the area. This is particularly important for tourism. The area has been subject to development applications in the past. Inspectors from outside the area have upheld this status.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
861. Mr Michael Turner (Individual) : 16 May 2012 13:13:00
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I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - R97 /MN34# KENDAL SOUTH OF NATLAND BECK FARM
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not been prepared in accordance with the Town & County Planning Regulations 2004 (as amended)
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
1) Town's absorption of village: Development on land at Oxenholme Road, Kendal would link the town to Oxenholme village. This is contrary to government policy;
2) Detrimental to tourism: the development would create an unpleasant view for UK and foreign tourists travelling to the Lake District by rail. This triangle of open land was subject to an appeal process some years age. The Inquiry found that openess should be maintained to preserve the character of the area.
3) Justification: increasing the housing stock in this area has not been justified. The need for expansion has not been proven. Disregard for local occupants has been evident.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Land at Oxenholme Road, Kendal should not be developed. Openness in this location is vital to maintain the character of the area. This is particularly important for tourism. The area has been subject to development applications in the past. Inspectors from outside the area have upheld this status.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
862. Mr Michael Turner (Individual) : 16 May 2012 13:20:00
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I have read the guidance notes
Policy/Site No.
LA1.7 Business and Science Park Sites - M2M-mod KENDAL LAND EAST OF BURTON ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not been prepared in accordance with the Town & County Planning Regulations 2004 (as amended)
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
1) Town's absorption of village: Development on land at Oxenholme Road, Kendal would link the town to Oxenholme village. This is contrary to government policy;
2) Detrimental to tourism: the development would create an unpleasant view for UK and foreign tourists travelling to the Lake District by rail. This triangle of open land was subject to an appeal process some years age. The Inquiry found that openess should be maintained to preserve the character of the area.
3) Justification: increasing the housing stock in this area has not been justified. The need for expansion has not been proven. Disregard for local occupants has been evident.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Land at Oxenholme Road, Kendal should not be developed. Openness in this location is vital to maintain the character of the area. This is particularly important for tourism. The area has been subject to development applications in the past. Inspectors from outside the area have upheld this status.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
863. Mr Michael Turner (Individual) : 16 May 2012 13:22:00
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I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - R107M mod and R150M KENDAL KENDAL PARKS
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not been prepared in accordance with the Town & County Planning Regulations 2004 (as amended)
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
1) Town's absorption of village: Development on land at Oxenholme Road, Kendal would link the town to Oxenholme village. This is contrary to government policy;
2) Detrimental to tourism: the development would create an unpleasant view for UK and foreign tourists travelling to the Lake District by rail. This triangle of open land was subject to an appeal process some years age. The Inquiry found that openess should be maintained to preserve the character of the area.
3) Justification: increasing the housing stock in this area has not been justified. The need for expansion has not been proven. Disregard for local occupants has been evident.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Land at Oxenholme Road, Kendal should not be developed. Openness in this location is vital to maintain the character of the area. This is particularly important for tourism. The area has been subject to development applications in the past. Inspectors from outside the area have upheld this status.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
864. Mrs Tracey Vickers (Individual) : 2 Mar 2012 13:39:00
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I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - R689 ULVM ULVERSTON NORTH URSWICK ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The proposed plans for R689ULVM need to be removed. Urswick Road can not support any more houses.Already the sewers have to be drained regularly as they cannot cope with the demand already.During periods of heavy rain much surface water is on Urswick Road and I worry about where this will then go when the fields are removed. The junction from main road onto ulverston road and towards Pennington C of E school is already hugely dangerous and often cars are sat there for several minutes before they can pull onto the A590 and then turning towards Pennington School. The increase in volume of traffic is only going to make this worse and put peoples lives at risk. Why is more housing being considered when there are already lots of empty houses sitting around Ulverston? People are already struggling to sell there houses on Ulverston Road because of the volume of traffic and these proposals are only going to make this worse. Why should I lose the value of my home because of the addition of new houses. The proposed build at R690ULV, R691ULV,R126M is also ridiculous and will put a huge strain of resources that are already there. Urswick Road is already a cut through for people living in Croftlands and Ulverston and the increase in traffic that new housing will bring is unfair to the people who already live there, will put childrens lives at risk and damage the roads more than they already are. What is wrong is expanding some of the other settlements of gleaston and scales why does Ulverston and Swarthmoor have to be expanded any further. The A590 is a notorious road with the quantity of lorries that travel along it on roads that are unsuitable, further traffic is only going to exacerbate this further. How are the local primary schools suppossed to cope? Most are over subscribed as it is and the beauty of many of these schools is that they are not that large, so the children get a more nurtured start to their schooling. I am oppossed to all the proposed sites around Urswick Road as it will affect the quality of life of those people who have worked hard in order to live here. If only these plans were for the benefit of those who actually already live in these areas and not about other people making money. I am not prepared for my house to lose value and for myself and my family to be out of pocket for all our hard work.
865. Mrs Tracey Vickers (Individual) : 15 May 2012 14:11:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - R690ulv, R691ULV, R126M, RN184, RN234# & part R242 ULVERSTON CROFTLANDS WEST - NOOK FARM
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The proposed plans for R689ULVM need to be removed. Urswick Road can not support any more houses.Already the sewers have to be drained regularly as they cannot cope with the demand already.During periods of heavy rain much surface water is on Urswick Road and I worry about where this will then go when the fields are removed. The junction from main road onto ulverston road and towards Pennington C of E school is already hugely dangerous and often cars are sat there for several minutes before they can pull onto the A590 and then turning towards Pennington School. The increase in volume of traffic is only going to make this worse and put peoples lives at risk. Why is more housing being considered when there are already lots of empty houses sitting around Ulverston? People are already struggling to sell there houses on Ulverston Road because of the volume of traffic and these proposals are only going to make this worse. Why should I lose the value of my home because of the addition of new houses. The proposed build at R690ULV, R691ULV,R126M is also ridiculous and will put a huge strain of resources that are already there. Urswick Road is already a cut through for people living in Croftlands and Ulverston and the increase in traffic that new housing will bring is unfair to the people who already live there, will put childrens lives at risk and damage the roads more than they already are. What is wrong is expanding some of the other settlements of gleaston and scales why does Ulverston and Swarthmoor have to be expanded any further. The A590 is a notorious road with the quantity of lorries that travel along it on roads that are unsuitable, further traffic is only going to exacerbate this further. How are the local primary schools suppossed to cope? Most are over subscribed as it is and the beauty of many of these schools is that they are not that large, so the children get a more nurtured start to their schooling. I am oppossed to all the proposed sites around Urswick Road as it will affect the quality of life of those people who have worked hard in order to live here. If only these plans were for the benefit of those who actually already live in these areas and not about other people making money. I am not prepared for my house to lose value and for myself and my family to be out of pocket for all our hard work.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
866. Mrs Tracey Vickers (Individual) : 15 May 2012 14:12:00
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I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - All Ulverston sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The proposed plans for R689ULVM need to be removed. Urswick Road can not support any more houses.Already the sewers have to be drained regularly as they cannot cope with the demand already.During periods of heavy rain much surface water is on Urswick Road and I worry about where this will then go when the fields are removed. The junction from main road onto ulverston road and towards Pennington C of E school is already hugely dangerous and often cars are sat there for several minutes before they can pull onto the A590 and then turning towards Pennington School. The increase in volume of traffic is only going to make this worse and put peoples lives at risk. Why is more housing being considered when there are already lots of empty houses sitting around Ulverston? People are already struggling to sell there houses on Ulverston Road because of the volume of traffic and these proposals are only going to make this worse. Why should I lose the value of my home because of the addition of new houses. The proposed build at R690ULV, R691ULV,R126M is also ridiculous and will put a huge strain of resources that are already there. Urswick Road is already a cut through for people living in Croftlands and Ulverston and the increase in traffic that new housing will bring is unfair to the people who already live there, will put childrens lives at risk and damage the roads more than they already are. What is wrong is expanding some of the other settlements of gleaston and scales why does Ulverston and Swarthmoor have to be expanded any further. The A590 is a notorious road with the quantity of lorries that travel along it on roads that are unsuitable, further traffic is only going to exacerbate this further. How are the local primary schools suppossed to cope? Most are over subscribed as it is and the beauty of many of these schools is that they are not that large, so the children get a more nurtured start to their schooling. I am oppossed to all the proposed sites around Urswick Road as it will affect the quality of life of those people who have worked hard in order to live here. If only these plans were for the benefit of those who actually already live in these areas and not about other people making money. I am not prepared for my house to lose value and for myself and my family to be out of pocket for all our hard work.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
867. Mrs Tracey Vickers (Individual) : 15 May 2012 14:13:00
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I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - All Swarthmoor sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The proposed plans for R689ULVM need to be removed. Urswick Road can not support any more houses.Already the sewers have to be drained regularly as they cannot cope with the demand already.During periods of heavy rain much surface water is on Urswick Road and I worry about where this will then go when the fields are removed. The junction from main road onto ulverston road and towards Pennington C of E school is already hugely dangerous and often cars are sat there for several minutes before they can pull onto the A590 and then turning towards Pennington School. The increase in volume of traffic is only going to make this worse and put peoples lives at risk. Why is more housing being considered when there are already lots of empty houses sitting around Ulverston? People are already struggling to sell there houses on Ulverston Road because of the volume of traffic and these proposals are only going to make this worse. Why should I lose the value of my home because of the addition of new houses. The proposed build at R690ULV, R691ULV,R126M is also ridiculous and will put a huge strain of resources that are already there. Urswick Road is already a cut through for people living in Croftlands and Ulverston and the increase in traffic that new housing will bring is unfair to the people who already live there, will put childrens lives at risk and damage the roads more than they already are. What is wrong is expanding some of the other settlements of gleaston and scales why does Ulverston and Swarthmoor have to be expanded any further. The A590 is a notorious road with the quantity of lorries that travel along it on roads that are unsuitable, further traffic is only going to exacerbate this further. How are the local primary schools suppossed to cope? Most are over subscribed as it is and the beauty of many of these schools is that they are not that large, so the children get a more nurtured start to their schooling. I am oppossed to all the proposed sites around Urswick Road as it will affect the quality of life of those people who have worked hard in order to live here. If only these plans were for the benefit of those who actually already live in these areas and not about other people making money. I am not prepared for my house to lose value and for myself and my family to be out of pocket for all our hard work.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
868. Mr J Wall (Individual) : 16 Apr 2012 21:09:00
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I have read the guidance notes
Policy/Site No.
LA2.9 Strategic Employment Allocations, Kendal - LAND EAST OF BURTON ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
To make the document sound, the employment allocations need to be reconsidered and the less suitable sites and in particular, site M2M, should be deleted.
The latest employment evidence base study commissioned by the Council and undertaken by Lambert Smith Hampton clearly concludes that the Land Allocations document as it currently stands proposes more land than is required for employment - see for example paras. 9.35, 10.18 and 10.22 of the study. The document cannot be sound, nor can it be environmentally justifed if it advocates the development (and thus the permanent loss) of more greenfield land than is needed. Sites that are less suitable should therefore be removed from the plan in light of this up to date evidence.
M2M is less suitable for many reasons - a) the latest study concludes that this site is assessed as 'orange' in terms of suitability as an employment site (i.e. not green); b)the site has biodiversity value, including great crested newts and nesting waders as confirmed by responsese to earlier consultations; c) it forms a key part of the green gap which separates Kendal from the village of Oxenholme (development here would contribute to the coalescence of Oxenholme and Nataland as well as Oxenholme and Kendal) and inter and intra-visibility within the gap would be significantly increased rendering the integrity of the remaining bit of green gap compromised beyond the point at which the gap would become null and void; d) Cumbria County Council object to the development of this site due to coalescence; e) the only supporters of the site's proposed development have vested financial interests in the development of the site; f) there has been significant objection to/concerns raised about the development of this site from locals as well as organisations such as CCC and CWT; g) the site would be an extension to Oxenholme - this is a small village that does not even have the level of services required to qualify as a local service centre as set out in the adopted Core Strategy and therefore should actually have no allocations, additionally it would breach the railway line which currently acts as the currently unbreached and very defined boundary to this linear village; h) Cumbria Landscape Character Guidance and Toolkit (CLCGT) March 2011 identifies that M2M falls within 'Drumlin Field'. Importantly, this makes clear that in landscape terms, the area M2M is not part of the urban area of Kendal or indeed it's urban fringe - the document has a separate classification for urban areas. This site is part of an important area in landscape terms in that it provides a key part of the setting for Kendal - The Gateway to the Lakes - it has a rural feel and you get the sense of having left the urban environment. The CLCGT identifies that: areas of Drumln Field are quite rare in Cumbria, this area i8s one of only two tracts in the County, "the distinctive grain and interlocking appearance of the drumlin forms are sensitive to development that would change their appearance in the landscape", "The strong matrix of hedges and walls that criss cross and roller coaster up and down the drumlins are sensitive to changes to land management", " the rivers and watercourses that intersect the drumlins reinforce a sense of tranquility and are sensitive to....changes in land management" - the CLCGT vision for the Drumlin Field landscape is that it will be "conserved and enhanced to retain it's distinctive characteristics....It's unique topography will be maintained and enhanced as a striking asset" - it even says that "the intrusion of new farm buildings will be minimised" and that "any small scale development will be sited and aligned to complement the grain and form of the drumlins and that a good network of paths and recreational route will exist" so surely the intrusion of a large employment area that will remove a footpath is not conducive to this vision - this is a particularly sensitive tract as it's proximity to Kendal means it has already been compromised - any further compromise will mean that this tract is segregated from the main part of the typology to the south and thus it's integrity will be destroyed. The development of M2M will cut across a steep slope and sit very uncomfortably in the landscape whilst thr CLCGT states that development in this landscape typology should "Avoid prominent hill tops or cutting across slopes". There are further details in the CLCGT for this typology that identify that development in this location would be inappropriate.The fact file for Kendal suggests that mitigation measures would avoid harm to the landscape but a cursory glance would demonstrate that no amount of mitigation measures, even if all the new buildings had green roofs and walls, which I doubt would be a requirement, this valuable and sensitive tract of a rare landscape would be harmed beyond repair.
I would urge the Inspector to:
- consider the previous appeal decisions made on this site in the past, in all of which the relevant Inspector concluded that this site should not be developed
- view the site from Burton Road, junction of Oxenholme Road and Hayclose Road, several points on the Helm and from the railway bridge at the northern end of Oxenholme. Viewing the site from these points and in the context of the CLCGT clearly demonstrates the harm that development of this site would cause to the landscape and character of this area.
- Walk up Oxenholme Road at dusk to experience the surreal sense of wonderment at hearing the nesting / roosting waders chattering away to one another as they settle down for the night - you are momentarily transported to some wild location listening to exotic creatures and it is amazing when you realise you are actually on your own 'doorstep'.
- Recommend to the Council the removal of this site from the plan and reinstate the land as part of the Green Gap.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
869. Ms Diane Wall (Individual) : 19 Apr 2012 10:52:00
Policy/Site No.
LA1.3 Housing Allocations - All Arnside sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I have given some considerable thought to the proposed development Land Allocation plans regarding Arnside village.
I would like to make the following points;
1. Arnside village has been designated an Area of Outstanding Natural Beauty ("AONB") and should continue to be protected as such under the development laws.
I would ask you to either re-consider the entire development plan or at the very minimum reduce the number of houses being proposed on the Red Hills Road site.
870. Ms Diane Wall (Individual) : 19 Apr 2012 10:58:00
Policy/Site No.
LA1.3 Housing Allocations - R81 ARNSIDE REDHILLS ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I have given some considerable thought to the proposed development Land Allocation plans regarding Arnside village.
I would like to make the following points;
1. Arnside village has been designated an Area of Outstanding Natural Beauty ("AONB") and should continue to be protected as such under the development laws.
2. The proposed number of houses to be constructed on the site adjacent to Red Hills Road (42 houses) is grossly out of proportion to the land size and reference to the number of houses proposed to be constructed on other sites within the village (which are of a larger size e.g. adjacent to Black Dyke Road - 30 houses).
3. The access road (Red Hills Road) is a small lane which cannot sustain the increase volume of traffic should the development go ahead. Furthermore, it is adjacent to an elderly people's home (Inglemere Close) and close to a school (Silverdale Road) - both of which present safety hazards with an increase traffic volume.
I would ask you to either re-consider the entire development plan or at the very minimum reduce the number of houses being proposed on the Red Hills Road site.
871. Mr J Wall (Individual) : 15 May 2012 14:24:00
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I have read the guidance notes
Policy/Site No.
LA1.7 Business and Science Park Sites - M2M-mod KENDAL LAND EAST OF BURTON ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
To make the document sound, the employment allocations need to be reconsidered and the less suitable sites and in particular, site M2M, should be deleted.
The latest employment evidence base study commissioned by the Council and undertaken by Lambert Smith Hampton clearly concludes that the Land Allocations document as it currently stands proposes more land than is required for employment - see for example paras. 9.35, 10.18 and 10.22 of the study. The document cannot be sound, nor can it be environmentally justifed if it advocates the development (and thus the permanent loss) of more greenfield land than is needed. Sites that are less suitable should therefore be removed from the plan in light of this up to date evidence.
M2M is less suitable for many reasons - a) the latest study concludes that this site is assessed as 'orange' in terms of suitability as an employment site (i.e. not green); b)the site has biodiversity value, including great crested newts and nesting waders as confirmed by responsese to earlier consultations; c) it forms a key part of the green gap which separates Kendal from the village of Oxenholme (development here would contribute to the coalescence of Oxenholme and Nataland as well as Oxenholme and Kendal) and inter and intra-visibility within the gap would be significantly increased rendering the integrity of the remaining bit of green gap compromised beyond the point at which the gap would become null and void; d) Cumbria County Council object to the development of this site due to coalescence; e) the only supporters of the site's proposed development have vested financial interests in the development of the site; f) there has been significant objection to/concerns raised about the development of this site from locals as well as organisations such as CCC and CWT; g) the site would be an extension to Oxenholme - this is a small village that does not even have the level of services required to qualify as a local service centre as set out in the adopted Core Strategy and therefore should actually have no allocations, additionally it would breach the railway line which currently acts as the currently unbreached and very defined boundary to this linear village; h) Cumbria Landscape Character Guidance and Toolkit (CLCGT) March 2011 identifies that M2M falls within 'Drumlin Field'. Importantly, this makes clear that in landscape terms, the area M2M is not part of the urban area of Kendal or indeed it's urban fringe - the document has a separate classification for urban areas. This site is part of an important area in landscape terms in that it provides a key part of the setting for Kendal - The Gateway to the Lakes - it has a rural feel and you get the sense of having left the urban environment. The CLCGT identifies that: areas of Drumln Field are quite rare in Cumbria, this area i8s one of only two tracts in the County, "the distinctive grain and interlocking appearance of the drumlin forms are sensitive to development that would change their appearance in the landscape", "The strong matrix of hedges and walls that criss cross and roller coaster up and down the drumlins are sensitive to changes to land management", " the rivers and watercourses that intersect the drumlins reinforce a sense of tranquility and are sensitive to....changes in land management" - the CLCGT vision for the Drumlin Field landscape is that it will be "conserved and enhanced to retain it's distinctive characteristics....It's unique topography will be maintained and enhanced as a striking asset" - it even says that "the intrusion of new farm buildings will be minimised" and that "any small scale development will be sited and aligned to complement the grain and form of the drumlins and that a good network of paths and recreational route will exist" so surely the intrusion of a large employment area that will remove a footpath is not conducive to this vision - this is a particularly sensitive tract as it's proximity to Kendal means it has already been compromised - any further compromise will mean that this tract is segregated from the main part of the typology to the south and thus it's integrity will be destroyed. The development of M2M will cut across a steep slope and sit very uncomfortably in the landscape whilst thr CLCGT states that development in this landscape typology should "Avoid prominent hill tops or cutting across slopes". There are further details in the CLCGT for this typology that identify that development in this location would be inappropriate.The fact file for Kendal suggests that mitigation measures would avoid harm to the landscape but a cursory glance would demonstrate that no amount of mitigation measures, even if all the new buildings had green roofs and walls, which I doubt would be a requirement, this valuable and sensitive tract of a rare landscape would be harmed beyond repair.
I would urge the Inspector to:
- consider the previous appeal decisions made on this site in the past, in all of which the relevant Inspector concluded that this site should not be developed
- view the site from Burton Road, junction of Oxenholme Road and Hayclose Road, several points on the Helm and from the railway bridge at the northern end of Oxenholme. Viewing the site from these points and in the context of the CLCGT clearly demonstrates the harm that development of this site would cause to the landscape and character of this area.
- Walk up Oxenholme Road at dusk to experience the surreal sense of wonderment at hearing the nesting / roosting waders chattering away to one another as they settle down for the night - you are momentarily transported to some wild location listening to exotic creatures and it is amazing when you realise you are actually on your own 'doorstep'.
- Recommend to the Council the removal of this site from the plan and reinstate the land as part of the Green Gap.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
872. Mr TIM WALLIS (Individual) : 17 Apr 2012 11:53:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - RN121M-mod LEVENS FORMER POULTRY SHEDS, BRIGSTEER ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not been prepared in accordance with the Town & County Planning Regulations 2004 (as amended)
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Inadequate consultation. It is hard to understand an argument that there was adequate consultation when one of the landowners concerned was not asked about the proposal. The late amendment adding this site was no doubt made for honest reasons, but it has had the effect of an ambush. The recent petition shows the views of people in the immediately local area. The fact of the matter is that those who live nearby were not adequately consulted about this proposal. The petition shows that, had they been consulted, any question of "support" for this proposal would have been highly doubtful.
The village "support" quoted in favour of this site should be scrutinised closely: any such support does not come from those who live nearby.
The input of the Parish Council is also, in my opinion, open to question; I refer here to the mismatch between the PC minutes, the statement to Levens Residents Group that it was "neutral" and its correspondence with the council.
(Incidentally, the complicated nature of this process and the consultation make it inaccessible, in my view, to a significant proportion of the population.)
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The problems with compliance/inadequate consultation impact on soundness - the evidence base was not robust or credible. It is certainly not an appropriate strategy to build urban density housing in the open countryside on the grounds put forward. The site is adjacent to the proposed boundary of the National Park and, as has been previously mentioned by planners, any development here would be unduly prominent when viewed from the National Park. The road and drainage systems are inadequate - and there has been no commitment/costings in relation to the formulaic mitigation measures refered to.
No consideration appears to have been given to the obvious consequence of allowing such development, namely the infilling by way of further development between this site and the village proper which is some distance away.
Such support as there is for this site appears to be influenced by the fact that on some portions of it there are derelict buildings. It is perverse to consider this to be a good reason for urban density house building when the council has powers which it could and should have used to deal with this problem in this area of scenic beauty.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
I wish to state my view.
I wish to question those who assert the proposals are compliant and sound.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
873. Stephen & Marion Wallwork (Individual) : 25 Apr 2012 08:23:00
Policy/Site No.
LA1.3 Housing Allocations - All Grange-over-Sands sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
We write with reference to the plans for house building in the Grange over Sands area.
We are very unhappy with the proposals for the following reasons:
1. We are not persuaded of the need for hundreds of new homes in this area.
2. We have seen no compelling reason for accepting the Government's statistics on
which all the development plans of SLDC are based.
3. We understand that there are over one hundred and twenty dwellings for sale in
Grange at present.
4. The green spaces that remain in the area are precious both in separating various
conununities, and in allowing invaluable views over the bay.
5. The roads in Grange, in particular Main Street and Risedale Hill, are already
overloaded and often congested.
6. New residential development should take place on brown field sites before anything
is built on green field sites.
7. Empty spaces above shops should be converted into living space.
8. Long term empty properties should be brought back into use.
It would appear to us that the desires of developers are being put before the more important
feelings of residents. We should be glad if you would put this letter before the councillors
who are involved in decision making.
874. Stephen & Marion Wallwork (Individual) : 10 May 2012 12:21:00
Policy/Site No.
LA3.1 Mixed Use Allocation at Berners Pool, Grange-over-Sands
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
We write with reference to the plans for house building in the Grange over Sands area.
We are very unhappy with the proposals for the following reasons:
1. We are not persuaded of the need for hundreds of new homes in this area.
2. We have seen no compelling reason for accepting the Government's statistics on
which all the development plans of SLDC are based.
3. We understand that there are over one hundred and twenty dwellings for sale in
Grange at present.
4. The green spaces that remain in the area are precious both in separating various
conununities, and in allowing invaluable views over the bay.
5. The roads in Grange, in particular Main Street and Risedale Hill, are already
overloaded and often congested.
6. New residential development should take place on brown field sites before anything
is built on green field sites.
7. Empty spaces above shops should be converted into living space.
8. Long term empty properties should be brought back into use.
It would appear to us that the desires of developers are being put before the more important
feelings of residents. We should be glad if you would put this letter before the councillors
who are involved in decision making.
875. Stephen & Marion Wallwork (Individual) : 10 May 2012 12:22:00
Policy/Site No.
LA3.2 Mixed Use Allocation at Land South of Allithwaite Road, Kent's Bank, Grange-over-Sands
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
We write with reference to the plans for house building in the Grange over Sands area.
We are very unhappy with the proposals for the following reasons:
1. We are not persuaded of the need for hundreds of new homes in this area.
2. We have seen no compelling reason for accepting the Government's statistics on
which all the development plans of SLDC are based.
3. We understand that there are over one hundred and twenty dwellings for sale in
Grange at present.
4. The green spaces that remain in the area are precious both in separating various
conununities, and in allowing invaluable views over the bay.
5. The roads in Grange, in particular Main Street and Risedale Hill, are already
overloaded and often congested.
6. New residential development should take place on brown field sites before anything
is built on green field sites.
7. Empty spaces above shops should be converted into living space.
8. Long term empty properties should be brought back into use.
It would appear to us that the desires of developers are being put before the more important
feelings of residents. We should be glad if you would put this letter before the councillors
who are involved in decision making.
876. Stephen & Marion Wallwork (Individual) : 10 May 2012 12:24:00
Policy/Site No.
LA3.3 Mixed Use Allocation at Guide's Lot, Grange-over-Sands
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
We write with reference to the plans for house building in the Grange over Sands area.
We are very unhappy with the proposals for the following reasons:
1. We are not persuaded of the need for hundreds of new homes in this area.
2. We have seen no compelling reason for accepting the Government's statistics on
which all the development plans of SLDC are based.
3. We understand that there are over one hundred and twenty dwellings for sale in
Grange at present.
4. The green spaces that remain in the area are precious both in separating various
conununities, and in allowing invaluable views over the bay.
5. The roads in Grange, in particular Main Street and Risedale Hill, are already
overloaded and often congested.
6. New residential development should take place on brown field sites before anything
is built on green field sites.
7. Empty spaces above shops should be converted into living space.
8. Long term empty properties should be brought back into use.
It would appear to us that the desires of developers are being put before the more important
feelings of residents. We should be glad if you would put this letter before the councillors
who are involved in decision making.
877. Mrs Anne Walsh (Individual) : 27 Apr 2012 12:08:00
Policy/Site No.
LA1.3 Housing Allocations - M41KM KENDAL SOUTH OF LUMLEY ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I wish to object to and challenge the soundness of proposal 2C – Land to south of Lumley Rd. and Scroggs Wood Light industrial Site on the following grounds:
- Inadequate local infrastructure including schools, health care, sewerage and roads.
- Milnthorpe road already backs up to the bypass at peak times and cannot accommodate the massive increase that such development, in these locations, would create. Kendal town development to attract visitors is pointless if they cannot obtain satisfactory access. The associated pollution from stationary traffic is incompatible with sustainable development objectives. The soundness of the development is challenged on the basis that there is no traffic plan to address these issues.
- The A6 is a crucial access for emergency services, particularly following the downgrading of Westmorland General Hospital. Further congestion on this route would introduce undue risk. The Soundness of the plan is therefore challenged on safety grounds. To South Lakeland District Council, Development Strategy Team, South Lakeland House, Lowther Street, Kendal, LA9 4UD
- The proposed 2C developments would spoil the initial impression to Kendal visitors, being on the main access route and adjacent to the Town boundary. The Lumley road site is steeply graded and properties would impose on the existing views for existing residents and visitors. The line of trees acts as a natural barrier to the Bellingham Estate. Building to the South of this line would fundamentally change the Kendal “Gateway to the Lakes” character. The Soundness of the plan is therefore challenged on visual impact grounds.
- Loss of green field space is detrimental to the character of the area and contrary to Coalition Government Sustainable Development Policy, which recognizes brown field preference. The Soundness of the plan is therefore challenged as being contrary to Government Planning Policy.
- The proposed mixed use development is incompatible with the character of the historic Helsington development and other existing properties. The Soundness of the plan is therefore challenged as being detrimental to the historical character of the area.
- The site is clearly NOT “in an accessible location or an easily developable level site” (Achievability statement P133 2 C). The Soundness of the plan is therefore challenged as being contrary to this declared planning statement.
- There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of existing residential space and more suitable alternative development sites.
- The Development plan should retain the "Kendal Gateway to the Lakes" image supporting tourism and established Cumbrian employment, not destroy it with unsightly, unnecessary development and traffic jams. You don’t put your wheelie bin on your front door step. I have an alternative suggestion for this site – why not continue its use as sheep farming land?
878. Mrs Anne Walsh (Individual) : 27 Apr 2012 12:11:00
Policy/Site No.
LA1.6 Strategic Employment Sites - E4M KENDAL LAND AT SCROGGS WOOD, MILNTHORPE ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I wish to object to and challenge the soundness of proposal 2C – Land to south of Lumley Rd. and Scroggs Wood Light industrial Site on the following grounds:
- Inadequate local infrastructure including schools, health care, sewerage and roads.
- Milnthorpe road already backs up to the bypass at peak times and cannot accommodate the massive increase that such development, in these locations, would create. Kendal town development to attract visitors is pointless if they cannot obtain satisfactory access. The associated pollution from stationary traffic is incompatible with sustainable development objectives. The soundness of the development is challenged on the basis that there is no traffic plan to address these issues.
- The A6 is a crucial access for emergency services, particularly following the downgrading of Westmorland General Hospital. Further congestion on this route would introduce undue risk. The Soundness of the plan is therefore challenged on safety grounds. To South Lakeland District Council, Development Strategy Team, South Lakeland House, Lowther Street, Kendal, LA9 4UD
- The proposed 2C developments would spoil the initial impression to Kendal visitors, being on the main access route and adjacent to the Town boundary. The Lumley road site is steeply graded and properties would impose on the existing views for existing residents and visitors. The line of trees acts as a natural barrier to the Bellingham Estate. Building to the South of this line would fundamentally change the Kendal “Gateway to the Lakes” character. The Soundness of the plan is therefore challenged on visual impact grounds.
- Loss of green field space is detrimental to the character of the area and contrary to Coalition Government Sustainable Development Policy, which recognizes brown field preference. The Soundness of the plan is therefore challenged as being contrary to Government Planning Policy.
- The proposed mixed use development is incompatible with the character of the historic Helsington development and other existing properties. The Soundness of the plan is therefore challenged as being detrimental to the historical character of the area.
- The site is clearly NOT “in an accessible location or an easily developable level site” (Achievability statement P133 2 C). The Soundness of the plan is therefore challenged as being contrary to this declared planning statement.
- There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of existing residential space and more suitable alternative development sites.
- There is spare capacity and expansion potential on existing established trading estates on Shap Road. The plan to relocate the Rugby club to Oxenholme and development of the Gilkes site are more suited to development than Scroggs Wood. The soundness of the case for such development is challenged on the basis of existing and more suitable alternative development sites.
- What and where is the business case and demand for a further speculative light industrial business park? Why would UK businesses move to such a park when financial assistance and tax breaks are available for designated City areas such as the Manchester Enterprise Zone? The soundness of this planned development is challenged on the basis of no demand or business case.
- The Development plan should retain the "Kendal Gateway to the Lakes" image supporting tourism and established Cumbrian employment, not destroy it with unsightly, unnecessary development and traffic jams. You don’t put your wheelie bin on your front door step. I have an alternative suggestion for this site – why not continue its use as sheep farming land?
879. Mrs Anne Walsh (Individual) : 27 Apr 2012 12:12:00
Policy/Site No.
LA1.3 Housing Allocations - All Kendal sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of existing residential space and more suitable alternative development sites.
880. Mrs Anne Walsh (Individual) : 27 Apr 2012 12:13:00
Paragraph No.
0.0 Whole Document
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Is there a definition of “affordable housing” in the context of Kendal young person income? Or is this merely a rouse to allow land owners and builders to make massive profits, without any tangible commitment to house the low paid of Kendal? The Soundness is therefore challenged on the basis of no defined affordability test.
881. Mrs Anne Walsh (Individual) : 27 Apr 2012 12:14:00
Policy/Site No.
LA1.4 - Kendal Sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of existing residential space and more suitable alternative development sites.
882. Mr Derrick Walsh (Individual) : 27 Apr 2012 12:18:00
Policy/Site No.
LA1.3 Housing Allocations - M41KM KENDAL SOUTH OF LUMLEY ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I wish to object to and challenge the soundness of proposal 2C – Land to south of Lumley Rd. and Scroggs Wood Light industrial Site on the following grounds:
- Inadequate local infrastructure including schools, health care, sewerage and roads.
- Milnthorpe road already backs up to the bypass at peak times and cannot accommodate the massive increase that such development, in these locations, would create. Kendal town development to attract visitors is pointless if they cannot obtain satisfactory access. The associated pollution from stationary traffic is incompatible with sustainable development objectives. The soundness of the development is challenged on the basis that there is no traffic plan to address these issues.
- The A6 is a crucial access for emergency services, particularly following the downgrading of Westmorland General Hospital. Further congestion on this route would introduce undue risk. The Soundness of the plan is therefore challenged on safety grounds. To South Lakeland District Council, Development Strategy Team, South Lakeland House, Lowther Street, Kendal, LA9 4UD
- The proposed 2C developments would spoil the initial impression to Kendal visitors, being on the main access route and adjacent to the Town boundary. The Lumley road site is steeply graded and properties would impose on the existing views for existing residents and visitors. The line of trees acts as a natural barrier to the Bellingham Estate. Building to the South of this line would fundamentally change the Kendal “Gateway to the Lakes” character. The Soundness of the plan is therefore challenged on visual impact grounds.
- Loss of green field space is detrimental to the character of the area and contrary to Coalition Government Sustainable Development Policy, which recognizes brown field preference. The Soundness of the plan is therefore challenged as being contrary to Government Planning Policy.
- The proposed mixed use development is incompatible with the character of the historic Helsington development and other existing properties. The Soundness of the plan is therefore challenged as being detrimental to the historical character of the area.
- The site is clearly NOT “in an accessible location or an easily developable level site” (Achievability statement P133 2 C). The Soundness of the plan is therefore challenged as being contrary to this declared planning statement.
- There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of existing residential space and more suitable alternative development sites.
- The Development plan should retain the "Kendal Gateway to the Lakes" image supporting tourism and established Cumbrian employment, not destroy it with unsightly, unnecessary development and traffic jams. You don’t put your wheelie bin on your front door step. I have an alternative suggestion for this site – why not continue its use as sheep farming land?
883. Mr Derrick Walsh (Individual) : 27 Apr 2012 12:20:00
Policy/Site No.
LA1.6 Strategic Employment Sites - E4M KENDAL LAND AT SCROGGS WOOD, MILNTHORPE ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I wish to object to and challenge the soundness of proposal 2C – Land to south of Lumley Rd. and Scroggs Wood Light industrial Site on the following grounds:
- Inadequate local infrastructure including schools, health care, sewerage and roads.
- Milnthorpe road already backs up to the bypass at peak times and cannot accommodate the massive increase that such development, in these locations, would create. Kendal town development to attract visitors is pointless if they cannot obtain satisfactory access. The associated pollution from stationary traffic is incompatible with sustainable development objectives. The soundness of the development is challenged on the basis that there is no traffic plan to address these issues.
- The A6 is a crucial access for emergency services, particularly following the downgrading of Westmorland General Hospital. Further congestion on this route would introduce undue risk. The Soundness of the plan is therefore challenged on safety grounds. To South Lakeland District Council, Development Strategy Team, South Lakeland House, Lowther Street, Kendal, LA9 4UD
- The proposed 2C developments would spoil the initial impression to Kendal visitors, being on the main access route and adjacent to the Town boundary. The Lumley road site is steeply graded and properties would impose on the existing views for existing residents and visitors. The line of trees acts as a natural barrier to the Bellingham Estate. Building to the South of this line would fundamentally change the Kendal “Gateway to the Lakes” character. The Soundness of the plan is therefore challenged on visual impact grounds.
- Loss of green field space is detrimental to the character of the area and contrary to Coalition Government Sustainable Development Policy, which recognizes brown field preference. The Soundness of the plan is therefore challenged as being contrary to Government Planning Policy.
- The proposed mixed use development is incompatible with the character of the historic Helsington development and other existing properties. The Soundness of the plan is therefore challenged as being detrimental to the historical character of the area.
- The site is clearly NOT “in an accessible location or an easily developable level site” (Achievability statement P133 2 C). The Soundness of the plan is therefore challenged as being contrary to this declared planning statement.
- There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of existing residential space and more suitable alternative development sites.
- There is spare capacity and expansion potential on existing established trading estates on Shap Road. The plan to relocate the Rugby club to Oxenholme and development of the Gilkes site are more suited to development than Scroggs Wood. The soundness of the case for such development is challenged on the basis of existing and more suitable alternative development sites.
- What and where is the business case and demand for a further speculative light industrial business park? Why would UK businesses move to such a park when financial assistance and tax breaks are available for designated City areas such as the Manchester Enterprise Zone? The soundness of this planned development is challenged on the basis of no demand or business case.
- The Development plan should retain the "Kendal Gateway to the Lakes" image supporting tourism and established Cumbrian employment, not destroy it with unsightly, unnecessary development and traffic jams. You don’t put your wheelie bin on your front door step. I have an alternative suggestion for this site – why not continue its use as sheep farming land?
884. Mr Derrick Walsh (Individual) : 27 Apr 2012 12:21:00
Policy/Site No.
LA1.3 Housing Allocations - All Kendal sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of existing residential space and more suitable alternative development sites.
885. Mr Derrick Walsh (Individual) : 27 Apr 2012 12:22:00
Paragraph No.
0.0 Whole Document
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Is there a definition of “affordable housing” in the context of Kendal young person income? Or is this merely a rouse to allow land owners and builders to make massive profits, without any tangible commitment to house the low paid of Kendal? The Soundness is therefore challenged on the basis of no defined affordability test.
886. Mr Derrick Walsh (Individual) : 27 Apr 2012 12:23:00
Policy/Site No.
LA1.4 - Kendal Sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
There are high numbers of unoccupied residential properties in Kendal, much in new developments such as K village and the Burneside road former Garden Centre site. Furthermore there are currently several new developments in construction at the former John Boste Centre site, Cock and Dolphin area and opposite the church halls (how and when did this change from a new medical centre?) . Expansion of existing housing estates would be more appropriate. What affordable housing is contained within these developments? The soundness of the case for such development is challenged on the basis of existing residential space and more suitable alternative development sites.
887. Mr Michael Waterton (Individual) : 19 Mar 2012 15:19:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
0.0 Whole Document
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
It is my opinion that the SLDC Land Allocations Development Plan Document as approved at the meeting of the Full Council on 18'" January 2012 is fundamentally unsound, because it is not justified and not effective (as defined in the form). I have set out my reasons below.
It is also my opinion that the decision to put forward the 'Land East of Castle Green Road' (R121M, R56 and part of R141) as being suitable for housing is unsound because the decision is not justified. (also see Representation 2)
1. Why is the DPD as a whole fundamentally unsound?
a. The consultation process consisted of a number of discrete stages, with each involving a request for consultation from interested parties. Many people devoted a lot of time, effort and research to prepare their submissions but, as each stage of the process concluded and a new stage began, SLDC announced that information submitted in respect of previous stages would not be automatically carried into the next stage. This approach did not embrace the true spirit of consultation and could be interpreted as a rather cynical means of encouraging a diminution of responses as the stages proceeded.
b. SLDC appear to have allocated their own arbitrary weightings to the individual results of public consultation. More than one SLDC councillor has said (and this can be verified from a study of the discussion on the Westmorland Gazette website relating to the DPD) that the views of people who are local to proposed development sites can be ignored on the basis that those individuals are inevitably biased against development and are solely protecting their personal interests. This approach undermines the entire consultation process. People are invariably going to feel strongest about those sites which are in their neighbourhoods and those people will be the best informed to comment upon the pros and cons of each site. It is a highly undemocratic state of affairs if officers and councillors can abuse the consultation process by filtering out those comments which do not support their proposals. To make matters even worse, the submissions from potential developers, in whose interests it is for as much land as possible to be zoned for residential development, appear to have been taken fully into account. Given that at least one councillor has made the point about ignoring the views of local residents in public without there being any form of comment or rebuke from SLDC as a whole, then surely this on its own is sufficient to conclude that the DPD is unsound.
c. Based upon my experience in respect of site R121M, it would appear that the DPD as a whole has not been founded on a robust and credible evidence base. The SLDC has undertaken a wide-ranging exercise which, if implemented, will transform the face of Kendal without apparently having carried out sufficiently rigorous research to ensure that their proposals were appropriate and credible. I can say with firsthand experience that the first time one of the planning officers set foot on fields that the SLDC had already proposed could accommodate 145 houses was when the consultation process was almost complete. Those of us local residents who had requested that he visit the site and accompanied him on his tour were dismayed to hear him express concerns at the steepness and poor drainage of the site and the fact that it would be visible from large areas of the outskirts of Kendal. This suggests that the initial process was based around a desk top exercise which was largely determined at the outset and which has not been adjusted in the light of detailed information as the consultation process proceeded. This is hardly the basis for a robust and credible plan.
d. The world has moved on since SLDC decided that thousands of new houses were required in South Lakeland. We are in the middle of a global recession which shows no sign of abating. The effects are being felt in South Lakeland and what may have been a suitable target for new houses at the start of the process is now a grotesque and pointless overstatement. The proposals are no longer realistic and sustainable and are no longer justified.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
888. Mr Michael Waterton (Individual) : 30 Mar 2012 09:14:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - R121M-mod KENDAL EAST OF CASTLE GREEN ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
2. Why is the decision to recommend the land East of Castle Green Road (R121M) unsound?
a. I believe very strongly that this particular decision is not founded on a robust and credible evidence base and that the proposals are not deliverable. Some 400 submissions have been made regarding the reasons why the site is completely unsuitable for development. The reasons include:
i. this site was recently deemed worthy of 'county landscape' status;
ii. it is a steep site which is visible from many parts of town and the surrounding valley;
iii. it floods regularly and severely;
iv. the fields act as an essential 'sponge' to slow down the movement of water towards the houses below
v. it drains into the Stock Beck flood relief scheme, which is already overloaded; and.
vi. the site is a home for many forms of wildlife including protected great crested newts.
The reasons why this site is inappropriate are numerous and compelling and have been made at each stage of the consultation process. There are no apparent reasons why this site is suitable for development, either in absolute terms or when compared to various other sites in the town which do not have the same long lists of negative features. These factors were alluded to in the SLDC's evidence base, together with the views of utility providers and other SLDC departments, which shared the view that it would be inappropriate to develop this site. It defies logic why SLDC has continued to include this site in the face of such compelling reasons to the contrary from a range of parties.
b. It is a requirement of a sound DPD that it embraces sound infrastructure delivery
planning. The SLDC's Fact File for site R121M at an earlier stage in the consultation
process about suggested site allocations included a statement from the National
Grid that the site 'is unfeasible' and a further statement that major infrastructure/service development would be needed to the gas network. Why is it not the case that the National Grid's statement is enough to rule this out as a suitable site, or is it to be developed with none of the houses having electricity? I believe that the DPD fails the soundness test on this point because it does not demonstrate sound infrastructure delivery planning.
c. The R121M Fact File referred to in b. above painted an exclusively negative assessment of the suitability of this site for development from all parties, but the SLDC planners' written conclusion at the bottom of the R121M Fact File was that 'In view of the above it is suggested the site be considered as an emerging site option for housing development'. As I said in my representation to the SLDC on 27th January 2011, this is a perverse comment because there is nothing in 'the above' which suggests anything of the sort! Rl21M should have been discounted as a potential site at that stage in the process, and it is unsound that it remains as a recommended site.
d. The DPD includes a section headed 'Policy LA2.3 Land East of Castle Green Road'
which sets out various actions which would need to take place prior to development. These include:
i. Mitigation measures to address potential impact on the great crested newts which inhabit the site;
ii. A flood risk assessment to assess and determine flood constraints and opportunities; and
iii. A transport assessment.
I fully agree that all of these are required. You could also add assessments from the electricity and gas companies, given their views expressed earlier in the process. However, common sense surely says that these are required before SLDC can make a meaningful decision about whether R121M is a potentially suitable development site, not once that decision has already been taken. The SLDC glibly says that 'attenuation measures' will be needed to address any problem which the consultation process has highlighted, but there should be a point in respect of a specific site or sites when there are so many factors which would require attenuation that serious consideration has to be given to the viability of that site. I believe that we should have reached that stage in respect of site R121M before the
proposals were finalised.
e. Whilst I believe that R121M is wholly unsuitable as a site for housing development for a number of reasons, I can see no justification for other potentially more suitable sites having been discarded during the consultation process whilst Rl21M has been retained. This appears to indicate either a lack of a proper process to benchmark and prioritise potential sites or an agenda that R121M was going to be included in the final proposals come what may. Neither explanation is acceptable and is another reason why the DPD is unsound.
Thank you for having given me an opportunity to make my views known. I hope that
common sense will prevail eventually.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
889. Mrs Caroline Waterton (Individual) : 12 Apr 2012 12:47:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - R121M-mod KENDAL EAST OF CASTLE GREEN ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
I believe the DPD for R121M is unsound because:-
• SLDC planning department have not carried out a survey of R121M to ascertain gradient,
the number of springs travelling through the land and volume of water and the wildlife
which currently enjoys it. I believe SLDC can not make a decision on their criteria of
soundness or justification without this survey and information gathering process. Why is
SLDC changing the status of land on which it does NOT have factual information? Surely,
this is UNSOUND.
• SLDC's criteria of providing affordable homes will not be met by building 60 homes on
R121M allocation. This is mainly because the "attenuation" (infrastructure- roads,
drainage, maintenance of stone walls, wildlife reserves etc) is going to be so costly on this
site.
• History of this site shows it is a valuable resource in that the land takes up and holds rainfall in its contours/undulating landscape releasing it at a sustainable rate to allow for slower drainage to the Stock Beck drainage facility. This facility has been very close to being
overwhelmed by the rate of rainfall coming off Sedbergh Road and Castle Green Lane areas. SLDC have been made aware of this siguificant problem and have chosen to ignore it.
• SLDC do not have a sufficient understanding of the drainage of this land and should not
make any changes of status to R121M until they have.
I also attach a copy of my letter sent to SLDC on 21" March 2011 which gives additional
information.
Thank you for giving me this opportunity to voice my opinions.
Dear Mr Hudson
Proposed Land Allocatious Development Rl21M -Castle Ward
Thank you very much for attending the meeting at Castle Park School on Thursday, 3rd March to explain the proposed change of use of Rl21M from agricultural land outside the town boundary to proposed land allocation suitable for the building of 147 dwellings.
Giving us the background information and the build up to the current position was most enlightening.
It was particularly helpful that you confirmed that permission for access from and to Rl21M onto Sedbergh Road for traffic would be denied, because of the narrowness of Sedbergh Road and the lack of pavements.
I wish to object to the development of R121M for the following reasons:-
Hopefully you will have walked across this site and therefore will understand the steepness of it which means that any buildings will be very visible from the Kendal Castle hill and further afield. This will change the visual appearance of this side of Kendal substantially as agricultural land will no longer be visible as you travel along Castle Green Lane and Sedbergh Road making Kendal less appealing to residents and visitors alike.
Rl21M is not just agricultural land for the grazing of sheep, cows and donkeys but the home of wild life such as rabbits, rooks, crows, newts, buzzards, woodpeckers, finches, woodpigeons, magpies and we have even had visitors such as Jays.
Rl21M also has a great use in holding water during spates of rainy weather. On the many occasions when it rains for several days, this land becomes very wet and the contours of the land means that a lot of water is held in a dip. Being released down into the valley over a period of two to three days. When the land can not absorb any more rainfull it streams down to the front of my property and through a drain and gathers in a large pool at the bottom of my garden. The avenue of trees also takes a lot of this water. Rl21M holds back considerable amounts of water both in the fields themselves, at the base of the hill amongst the trees and at the end of my garden. This water drains away down to the Stock
Beck Flood Relief catchment area behiod the allotments on Sedbergh Rood over a perind of two plus days. This is a very valuable resource helping to prevent the flood relief catchment from being overwhelmed and therefore flooding surrounding areas such as Lowther Park.
Attenuation was your response to the comments such as the above at the Castle Park School meeting. I need SLDCs guarantee that any development of R121M will not cause flooding to my home. To date, this property has never flooded, mainly because we ensure that the drain at the front of our garage is never allowed to silt-up from material washed down from the fields and that the flow/run off is slowed due to the land taking up the rainfaII.
Please assure me that SLDC will take responsibility for the attenuation facilities required to control the fast run off of drainage from Rl21M.
SLDCs attenuation will probably be very costly to adapt drainage to take such large quantities of run off of water both in the Rl21M development and further down the valley.
I am surprised and disappointed that information and comments submitted as part of the earlier process inviting land for consideration has not been carried forward into this process. There will be valuable information being ignored and I would like to propose that SLDC commit to review this information again as part of this current process.
I hope the above information will be useful and look forward to receiving your replies and assurances that SLDC will take responsibility for any future water damage to local properties.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
890. Mr Philip Watkinson (Individual) : 17 Apr 2012 16:24:00
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I have read the guidance notes
Paragraph No.
0.0 Whole Document
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The Land Allocations Document (DPD) is not within the Local Development Scheme and the key stages have not been followed
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
South Lakeland Local Development Framework
Land Allocations
Ref: Roosebeck RN207 & RN208
(On behalf of Mrs J.M. Newton, 1 West Meadows Road, Cleadon, Sunderland, SR6 7TX : proposer/landowner)
Sound ? Absolutely not.
The proposal submitted in respect of the above sites was included in a fully comprehensive document, which was detailed and specific, and aligned with the relevant national, regional and local planning ‘targets’, thus making the proposal a wholly valid one for inclusion within the LDF. (i.e. befitting with the aims and objectives as set down within the Local Plan, Structure Plan, IPATH & RSS). Each aspect of the proposal was given ‘sound’ planning reasons (i.e. detail of planning compliance specified) within this proposal document.
i.e. The submission gave full and detailed reasoning to support how appropriate it was on all the required planning levels.
The response to this submission was not even an acknowledgement ? No contact was made directly with me, or Mrs J.M. Newton (the landowner) by South Lakeland District Council (SLDC).
The next stage was the ‘consultation’ feedback, in response to comments/reasons given online (not following any direct discussion/consultation with myself or the ‘proposer’) as to why the sites might be excluded from the next stage of the process.
I therefore gave my response to these ‘reasons’ on 15th April 2011. I gave full, detailed and valid reasons to counter each and every one of the points in question, consequent from which there was no apparent/valid reason for SLDC to even consider the exclusion of these sites, certainly not at that stage and without discussing the issues directly and without giving a (written) response to the ‘counter’ points that I had set out in my response.
The only response from SLDC was an acknowledgement of receipt (26.4.11) wrongly referring to me as Mr Wilkinson, not Mr Watkinson. In hindsight this was indicative of the cursory consideration which this proposal has received generally, and the nature by which the matter has been handled, i.e. poorly, if at all, and in an inappropriately dismissive manner.
This is self-evident from the fact that no response whatsoever has ever been given, either to the proposal itself, nor the wholly valid response I had given to the ‘initial’ consultation period, as referred to above.
No response at all during this whole so called ‘consultation’ period(s) – neither to myself, nor the landowner (proposer).
In these circumstances it can in no way represent any form of consultation. It is insulting to suggest that it has been.
On 19th July 2011, Mrs Newton received a ‘standard’ letter advising of the ‘process’ for the next stage of public consultation. There was no reference to the specific sites proposed by Mrs Newton, the initial document submitted, or the comments made in regard to the initial consultation period.
On 29th July 2011 a request was received (via e-mail & a letter dated 28th July 2011 to Mrs Newton) for ‘general’ views on ‘peripheral’ / procedural matters of the process, but still no mention of, or response to, any of the representation made on behalf of Mrs Newton in respect of the site proposals put forward.
I then submitted comments in regard to each of the three items for which such comments had been requested. This was on 9th September 2011, having waited patiently for ‘feedback’ from SLDC on the specific representation previously submitted, but not a thing had been forthcoming from them.
In my response (9th Sept 2011) I expressed my surprise that neither myself or Mrs Newton had been contacted at all in regard to the proposal, and reminded SLDC that the offer had been made to discuss the proposal, and the willingness had been expressed for myself and Mrs Newton to meet with them, on site, or wherever else they felt appropriate to do so.
I also reiterated this willingness to meet/discuss at the end of my e-mail to SLDC.
I again made representation to support and justify the appropriateness of the sites for inclusion within the LDF.
The SLDC response ? Nothing (again), other than the posting of my e-mail on their website, which in summary stated my (Mrs Newton’s) opposition to our own site !
In response to the fully justified proposal, and the wholly valid counter arguments to SLDC’s attempts to justify exclusion of these sites, no response at all was forthcoming from SLDC. In all that time, there had been nothing, nor had they responded to the repeated offers for a meeting to discuss the proposal put to them.
The only ‘response’ had been an acknowledgement of receipt addressing me by the wrong name, and a posting on their website stating ‘opposition’ to our own proposal ?
This has not only been unprofessional, it has been incompetent, and the total lack of any form of communication, as well as being entirely inappropriate, renders SLDC incapable of making any judgement as regards the exclusion of these sites from the LDF without first having done this. It should have been discussed, in detail, and in person, with myself and the proposer, and any decision (whatever that may have been) should have been confirmed, with full reasoning given (for or against), in writing.
The LDF is an ‘in principle’ document, subject to the agreement thereafter of site specific details of any development, and it has also been made clear throughout that there was an entirely flexible approach to these sites, in regard to all facets of any proposed development, from the overall size (both area and number of units), percentage of affordable housing provision, etc.
All of this could (and should) have been discussed between the parties. No decision as regards allocation could have been rightly made without this dialogue, but the attitude/approach by SLDC (i.e. none) has not facilitated these necessary consultations, which would have constituted an appropriate consultation process, rather than the farcical and inappropriate ‘consultation process’ which has become apparent through this absence of dialogue, of any description, with the actual landowner/proposer.
This does not constitute a proper consultation process, let alone a ‘sound’ one, but instead represents only the ‘appearance’ of a due process. They have failed to give full and considered appraisal to all sites, evidenced through the absence of any form of communication, dialogue or response to representations made, specific site proposals, and their proposers.
Consultation ? What consultation ?
Farcical, inappropriate and far from ‘sound’.
3.1 DPD Justified
Research/fact finding: the choices made in the plan are backed up by facts.
Failure to undertake any communication with a proposer/landowner cannot possibly satisfy a criteria for research/fact finding.
Robust and credible evidence ? Research ? Fact Finding ?
In case there is still any lingering doubts as to my opinion on the Land Allocations DPD - process/consultation:
NOT SOUND
(The sound of silence)
N.B. Immediate confirmation of receipt of this document is required.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
see above (1.3)
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
891. Mr Philip Watkinson (Individual) : 11 May 2012 15:40:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - Site Omission
If you have selected a ‘Site omission’ please enter the site reference or location and relevant policy below
RN207
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The Land Allocations Document (DPD) is not within the Local Development Scheme and the key stages have not been followed
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
South Lakeland Local Development Framework
Land Allocations
Ref: Roosebeck RN207 & RN208
(On behalf of Mrs J.M. Newton, 1 West Meadows Road, Cleadon, Sunderland, SR6 7TX : proposer/landowner)
Sound ? Absolutely not.
The proposal submitted in respect of the above sites was included in a fully comprehensive document, which was detailed and specific, and aligned with the relevant national, regional and local planning ‘targets’, thus making the proposal a wholly valid one for inclusion within the LDF. (i.e. befitting with the aims and objectives as set down within the Local Plan, Structure Plan, IPATH & RSS). Each aspect of the proposal was given ‘sound’ planning reasons (i.e. detail of planning compliance specified) within this proposal document.
i.e. The submission gave full and detailed reasoning to support how appropriate it was on all the required planning levels.
The response to this submission was not even an acknowledgement ? No contact was made directly with me, or Mrs J.M. Newton (the landowner) by South Lakeland District Council (SLDC).
The next stage was the ‘consultation’ feedback, in response to comments/reasons given online (not following any direct discussion/consultation with myself or the ‘proposer’) as to why the sites might be excluded from the next stage of the process.
I therefore gave my response to these ‘reasons’ on 15th April 2011. I gave full, detailed and valid reasons to counter each and every one of the points in question, consequent from which there was no apparent/valid reason for SLDC to even consider the exclusion of these sites, certainly not at that stage and without discussing the issues directly and without giving a (written) response to the ‘counter’ points that I had set out in my response.
The only response from SLDC was an acknowledgement of receipt (26.4.11) wrongly referring to me as Mr Wilkinson, not Mr Watkinson. In hindsight this was indicative of the cursory consideration which this proposal has received generally, and the nature by which the matter has been handled, i.e. poorly, if at all, and in an inappropriately dismissive manner.
This is self-evident from the fact that no response whatsoever has ever been given, either to the proposal itself, nor the wholly valid response I had given to the ‘initial’ consultation period, as referred to above.
No response at all during this whole so called ‘consultation’ period(s) – neither to myself, nor the landowner (proposer).
In these circumstances it can in no way represent any form of consultation. It is insulting to suggest that it has been.
On 19th July 2011, Mrs Newton received a ‘standard’ letter advising of the ‘process’ for the next stage of public consultation. There was no reference to the specific sites proposed by Mrs Newton, the initial document submitted, or the comments made in regard to the initial consultation period.
On 29th July 2011 a request was received (via e-mail & a letter dated 28th July 2011 to Mrs Newton) for ‘general’ views on ‘peripheral’ / procedural matters of the process, but still no mention of, or response to, any of the representation made on behalf of Mrs Newton in respect of the site proposals put forward.
I then submitted comments in regard to each of the three items for which such comments had been requested. This was on 9th September 2011, having waited patiently for ‘feedback’ from SLDC on the specific representation previously submitted, but not a thing had been forthcoming from them.
In my response (9th Sept 2011) I expressed my surprise that neither myself or Mrs Newton had been contacted at all in regard to the proposal, and reminded SLDC that the offer had been made to discuss the proposal, and the willingness had been expressed for myself and Mrs Newton to meet with them, on site, or wherever else they felt appropriate to do so.
I also reiterated this willingness to meet/discuss at the end of my e-mail to SLDC.
I again made representation to support and justify the appropriateness of the sites for inclusion within the LDF.
The SLDC response ? Nothing (again), other than the posting of my e-mail on their website, which in summary stated my (Mrs Newton’s) opposition to our own site !
In response to the fully justified proposal, and the wholly valid counter arguments to SLDC’s attempts to justify exclusion of these sites, no response at all was forthcoming from SLDC. In all that time, there had been nothing, nor had they responded to the repeated offers for a meeting to discuss the proposal put to them.
The only ‘response’ had been an acknowledgement of receipt addressing me by the wrong name, and a posting on their website stating ‘opposition’ to our own proposal ?
This has not only been unprofessional, it has been incompetent, and the total lack of any form of communication, as well as being entirely inappropriate, renders SLDC incapable of making any judgement as regards the exclusion of these sites from the LDF without first having done this. It should have been discussed, in detail, and in person, with myself and the proposer, and any decision (whatever that may have been) should have been confirmed, with full reasoning given (for or against), in writing.
The LDF is an ‘in principle’ document, subject to the agreement thereafter of site specific details of any development, and it has also been made clear throughout that there was an entirely flexible approach to these sites, in regard to all facets of any proposed development, from the overall size (both area and number of units), percentage of affordable housing provision, etc.
All of this could (and should) have been discussed between the parties. No decision as regards allocation could have been rightly made without this dialogue, but the attitude/approach by SLDC (i.e. none) has not facilitated these necessary consultations, which would have constituted an appropriate consultation process, rather than the farcical and inappropriate ‘consultation process’ which has become apparent through this absence of dialogue, of any description, with the actual landowner/proposer.
This does not constitute a proper consultation process, let alone a ‘sound’ one, but instead represents only the ‘appearance’ of a due process. They have failed to give full and considered appraisal to all sites, evidenced through the absence of any form of communication, dialogue or response to representations made, specific site proposals, and their proposers.
Consultation ? What consultation ?
Farcical, inappropriate and far from ‘sound’.
3.1 DPD Justified
Research/fact finding: the choices made in the plan are backed up by facts.
Failure to undertake any communication with a proposer/landowner cannot possibly satisfy a criteria for research/fact finding.
Robust and credible evidence ? Research ? Fact Finding ?
In case there is still any lingering doubts as to my opinion on the Land Allocations DPD - process/consultation:
NOT SOUND
(The sound of silence)
N.B. Immediate confirmation of receipt of this document is required.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
Yes
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
see above (1.3)
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
892. Mr Philip Watkinson (Individual) : 11 May 2012 15:43:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - Site Omission
If you have selected a ‘Site omission’ please enter the site reference or location and relevant policy below
RN208
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The Land Allocations Document (DPD) is not within the Local Development Scheme and the key stages have not been followed
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
South Lakeland Local Development Framework
Land Allocations
Ref: Roosebeck RN207 & RN208
(On behalf of Mrs J.M. Newton, 1 West Meadows Road, Cleadon, Sunderland, SR6 7TX : proposer/landowner)
Sound ? Absolutely not.
The proposal submitted in respect of the above sites was included in a fully comprehensive document, which was detailed and specific, and aligned with the relevant national, regional and local planning ‘targets’, thus making the proposal a wholly valid one for inclusion within the LDF. (i.e. befitting with the aims and objectives as set down within the Local Plan, Structure Plan, IPATH & RSS). Each aspect of the proposal was given ‘sound’ planning reasons (i.e. detail of planning compliance specified) within this proposal document.
i.e. The submission gave full and detailed reasoning to support how appropriate it was on all the required planning levels.
The response to this submission was not even an acknowledgement ? No contact was made directly with me, or Mrs J.M. Newton (the landowner) by South Lakeland District Council (SLDC).
The next stage was the ‘consultation’ feedback, in response to comments/reasons given online (not following any direct discussion/consultation with myself or the ‘proposer’) as to why the sites might be excluded from the next stage of the process.
I therefore gave my response to these ‘reasons’ on 15th April 2011. I gave full, detailed and valid reasons to counter each and every one of the points in question, consequent from which there was no apparent/valid reason for SLDC to even consider the exclusion of these sites, certainly not at that stage and without discussing the issues directly and without giving a (written) response to the ‘counter’ points that I had set out in my response.
The only response from SLDC was an acknowledgement of receipt (26.4.11) wrongly referring to me as Mr Wilkinson, not Mr Watkinson. In hindsight this was indicative of the cursory consideration which this proposal has received generally, and the nature by which the matter has been handled, i.e. poorly, if at all, and in an inappropriately dismissive manner.
This is self-evident from the fact that no response whatsoever has ever been given, either to the proposal itself, nor the wholly valid response I had given to the ‘initial’ consultation period, as referred to above.
No response at all during this whole so called ‘consultation’ period(s) – neither to myself, nor the landowner (proposer).
In these circumstances it can in no way represent any form of consultation. It is insulting to suggest that it has been.
On 19th July 2011, Mrs Newton received a ‘standard’ letter advising of the ‘process’ for the next stage of public consultation. There was no reference to the specific sites proposed by Mrs Newton, the initial document submitted, or the comments made in regard to the initial consultation period.
On 29th July 2011 a request was received (via e-mail & a letter dated 28th July 2011 to Mrs Newton) for ‘general’ views on ‘peripheral’ / procedural matters of the process, but still no mention of, or response to, any of the representation made on behalf of Mrs Newton in respect of the site proposals put forward.
I then submitted comments in regard to each of the three items for which such comments had been requested. This was on 9th September 2011, having waited patiently for ‘feedback’ from SLDC on the specific representation previously submitted, but not a thing had been forthcoming from them.
In my response (9th Sept 2011) I expressed my surprise that neither myself or Mrs Newton had been contacted at all in regard to the proposal, and reminded SLDC that the offer had been made to discuss the proposal, and the willingness had been expressed for myself and Mrs Newton to meet with them, on site, or wherever else they felt appropriate to do so.
I also reiterated this willingness to meet/discuss at the end of my e-mail to SLDC.
I again made representation to support and justify the appropriateness of the sites for inclusion within the LDF.
The SLDC response ? Nothing (again), other than the posting of my e-mail on their website, which in summary stated my (Mrs Newton’s) opposition to our own site !
In response to the fully justified proposal, and the wholly valid counter arguments to SLDC’s attempts to justify exclusion of these sites, no response at all was forthcoming from SLDC. In all that time, there had been nothing, nor had they responded to the repeated offers for a meeting to discuss the proposal put to them.
The only ‘response’ had been an acknowledgement of receipt addressing me by the wrong name, and a posting on their website stating ‘opposition’ to our own proposal ?
This has not only been unprofessional, it has been incompetent, and the total lack of any form of communication, as well as being entirely inappropriate, renders SLDC incapable of making any judgement as regards the exclusion of these sites from the LDF without first having done this. It should have been discussed, in detail, and in person, with myself and the proposer, and any decision (whatever that may have been) should have been confirmed, with full reasoning given (for or against), in writing.
The LDF is an ‘in principle’ document, subject to the agreement thereafter of site specific details of any development, and it has also been made clear throughout that there was an entirely flexible approach to these sites, in regard to all facets of any proposed development, from the overall size (both area and number of units), percentage of affordable housing provision, etc.
All of this could (and should) have been discussed between the parties. No decision as regards allocation could have been rightly made without this dialogue, but the attitude/approach by SLDC (i.e. none) has not facilitated these necessary consultations, which would have constituted an appropriate consultation process, rather than the farcical and inappropriate ‘consultation process’ which has become apparent through this absence of dialogue, of any description, with the actual landowner/proposer.
This does not constitute a proper consultation process, let alone a ‘sound’ one, but instead represents only the ‘appearance’ of a due process. They have failed to give full and considered appraisal to all sites, evidenced through the absence of any form of communication, dialogue or response to representations made, specific site proposals, and their proposers.
Consultation ? What consultation ?
Farcical, inappropriate and far from ‘sound’.
3.1 DPD Justified
Research/fact finding: the choices made in the plan are backed up by facts.
Failure to undertake any communication with a proposer/landowner cannot possibly satisfy a criteria for research/fact finding.
Robust and credible evidence ? Research ? Fact Finding ?
In case there is still any lingering doubts as to my opinion on the Land Allocations DPD - process/consultation:
NOT SOUND
(The sound of silence)
N.B. Immediate confirmation of receipt of this document is required.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
see above (1.3)
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
893. Mr Peter Watson (Individual) : 24 Apr 2012 11:34:00
Paragraph No.
1.9
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
1.1 Whilst South Lakeland District Council ("SLDC") has carried out a Consultation
Process over the last 2 years, when endeavouring to respond to Parish Council/
Parishioners concerns, it recently significantly altered proposals on Land
Allocations which left insufficient time for further consultation on these changes,
e.g. nomination for employment purposes of land at Gatebeck (sites EN20 and
N 33#) that have fundamental drawbacks (see Section 3 below).
In this regard I consider that the consultation process is UNSOUND as not being in
accordance with SLDC's Statement of Community Involvement
1.2 The representation process adopted, involving complex tests of soundness, is part
of the national planning system, but it is not designed for general ease of use . It
was personally distressing to encounter older parishioners, wishing to submit
comments on late proposals affecting them, (see Section 4 below), admitting that it
was beyond them. In such cases a lack of response cannot be taken as a lack of
interest or concern.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
In order to respond to any questions from the inspector
894. Mr Peter Watson (Individual) : 24 Apr 2012 11:39:00
Policy/Site No.
LA1.3 Housing Allocations - All Endmoor sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
With reference to South Lakeland District Council's recent invitation I would like to submit
my Representation regarding the Land Allocations Development Plan Document dated
March2012.
You should be aware that I was approached, along with other parishioners, in December
2011 to assist Preston Richard Parish Council in the final stages of the consultation
process and culminating in the drafting, on its behalf, of its own representation. This draft
was approved at a special meeting of the Parish Council on April1 ih 2012.
In view of the above I can confirm that I totally support the Parish Council's
representation and wish to limit my own representation comments as a resident of this
parish which should be considered as complementary:
2. Housing Sites M41 M and R670
I have considerable concerns over the process. u~e,d.to determine the numbers of (0\
dwellings deemed appropriate to meet the f!Jtures rie.eds of the village, and of the @.J
appropriateness of the chosen sites. ·
2.1 There is no empirical evidence to support a future increase in demand of 38% in
dwelling numbers within the village development boundary. In fact, contrary to
SLDC's Sustainability Analysis, there has been a decline over the last 10 years in
demand for social facilities such as doctors, and post offices, and a failure to find a
buyer for the village shop. I don't believe this is a temporary 'blip' which would be
rectified simply by building more houses. I submit, that in a village so close to good
social and retail facilities in Kendal, Milnthorpe and Kirkby Lonsdale, and in an age
when travel, particularly by public transport is becoming increasingly expensive,
housing demand (particularly of affordable type) will be greater closer to /or in
these settlements. It follows that any new housing development in the village
should be on a reduced scale and of a type that is "marketable."
2.2 SLDC's Sustainability Appraisal points to specific low scores on 'green issues' for
these development sites which are adjacent to very sensitive landscape and which
is inappropriate for a new, substantial built-environment, however landscaped. Such
an Appraisal Process is underminded unless as a result development is very
limited and handled with utmost care.
The DPD proposals are, in my opinion, not JUSTIFIED with robust evidence
4.1 Waste Water Treatment
One of the most concerning aspects of SLDC's Land Allocations Process has been a
complete lack of consultation on the proposed (by SLDC) water treatment works at Low
Park, and a disregard for its potential impact on landscape (Type 7b Drumlin field) and
highway/safety isses. Moreover, there is ambiguity and a lack of consistency in the
various positions taken by both SLDC and United Utilities PLC on status of studies
investigations in the DPD and the DPD Consultation Statement as well as in the United
Utilities PLC letter 29 February 2012. The DPD fails to provide parishioners with an
agreed position between SLDC and United Utilities PLC. This has resulted in
considerable worry and concern for many village residents, particularly those living on
Low Park who could, potentially, be adversely affected.
Without an agreed strategy on the critical path issue of waste water treatment further
development in End moor is not deliverable.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
895. Mr Peter Watson (Individual) : 24 Apr 2012 11:44:00
Policy/Site No.
LA1.8 Local Employment Allocations - EN20, EN33# ENDMOOR LAND NORTH OF GATEBECK LANE, GATEBECK
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
3 Employment Sites EN 20 and EN 33#
3.1 The approach taken by SLDC over the nomination and notification of these sites at
Gatebeck for employment gives me considerable concern
3.1.1 The fundamental change from a mixed commercial/housing land allocation at
M41 (admittedly made in order to address parishioner concerns) to a large
B2/B8 use at Gatebeck was proposed by SLDC in a draft DPD issued in
January 2012 so public consultation on this issue was impossible.
3.1.2 It is difficult to understand why SLDC should offer this site when there are ;}_
(three) existing sites within% mile (Gatebeck Business Park, Gatebeck Industrial
Site and Summerlands) as well as a further site at Crooklands. Considerable
empty space continues to be available. The local supply of employment land is
dramatically increased by the doubling in size of the Mainline site some 41/2 km
away to 16ha.
3.1.3 The DPD earmarks this site close to Endmoor village which would result in a
disproportionate allocation of industrial/storage/distribution for Endmoor and
nearby Crooklands when compared to nearby larger villages.
Population Current ha Additional ha Total ha
Burneside 1500 9.28 1.2 10.48
Burton 1400 1.00 - 1.00
Endmoor/
Crooklands 1250 7.79 3.79 11.58
3.1.4 SLDC's decision to offer this site is extremely questionable in light of comments
made by HM Inspectorate on its total unsuitability for development as a
crematorium due to highway/safety and landscape considerations (see Preston
Richard Parish Council Representation)
I have to conclude that the proposal for Gatebeck site is not SOUND due to inadequate
consultation (Statement of Community Involvement) ; it is not based on robust and
credible evidence and is not consistent with national policy (Core Strategies CS8.2 and
CS10.2)
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
896. Mr S T Wayles (Individual) : 4 May 2012 15:22:00
Policy/Site No.
LA1.3 Housing Allocations - RN11# KIRKBY-in- FURNESS LAND ADJACENT TO BURLINGTON C OF E SCHOOL
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Site RN11#, Policy LA1.3
Not objecting to the site in principle, but raising an issue with soundness regarding the following aspects of the site’s implementation:
• Based on local knowledge, it may not be possible to connect the site to the high pressure waste water sewer along the A595
• The site adjoins a high voltage power line. If the line is upgraded to meet the needs of the proposed nuclear power station at Sellafield, there is concern about the resulting health impact of increased radiation
897. Mr S T Wayles (Individual) : 4 May 2012 15:23:00
Policy/Site No.
LA1.3 Housing Allocations - R29M KIRKBY-in- FURNESS FOUR LANE ENDS
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Site R29, Policy LA1.3
Not objecting to the site in principle, but raising an issue with soundness regarding the following aspects of the site’s implementation:
• As the site falls away to the south, it may be difficult to connect to the foul sewer under the road to the north on Askewgate Brow.
• Askewgate Road to the north of the site, is narrow and may need to be widened.
898. Mr Martin Weeks (Individual) : 15 Apr 2012 21:47:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.1 Development Boundaries- ENDMOOR
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The Land Allocations Document (DPD) is not within the Local Development Scheme and the key stages have not been followed
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
The DPD has not had regard to the Sustainable Community Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
See 2.3 below
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Factual Data
The DPD is expected to be backed by “research/fact finding: the choices made in the plan are backed up by facts”. The following bullets illustrate that this has not been done properly and all these points need to be addressed to justify the DPD. The DPD currently is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
• There has been no evidence provided of consultation with statutory bodies such as Highways, Utilities, Network Rail, Bus operators etc.
• SLDC used 2005 Business plans, acknowledged as out of date. Following the economic downturn, figures are deficient and do not reflect the current needs.
• SLDC Housing figures provided by the Office for National Statistics, were last updated in 2006. Cumbria CC deem only 2,400 new homes required, not 6,000 as portrayed by SLDC. This represents a 4.6% increase in housing stock, against an 11.5% increase using SLDC figures. I therefore question the need for 6,000 new homes in South Lakeland now that the Regional Spatial Strategy has been removed by the current Government. I ask that SLDC halts the publication of the LDP, pending implementation of the Localism Bill and the introduction of Neighbourhood Planning”.
• Development does not take into account the 1000 homes identified by the local MP (Tim Farron) as in need of refurbishment.
• There is already an adequate supply of market housing available for sale of all types and price ranges, so there is no “exceptional need” to allocate land for market housing. Some property has been on the market for 2 years in Endmoor.
• No requirement for local commercial/industrial development has been demonstrated. Large numbers of vacant commercial property are available now locally at Summerlands and Gatebeck and further development is included in the already developing Auction Mart site.
• In the case of Endmoor, and M41M in particular, there will be significant impact with the proposed size of developments on the village and surrounding drumlin landscape which has previously been acknowledged as an Area of Great Landscape Value and a Landscape of County Importance which is supported by recent Inspectors reports:-
– County Showfield - Ref 5/89/4103
– Crematorium - T/APP/M0933/A/99/1017017/P2
– Sillfield Wind Turbines - Ref: SL/2008/0900
• In addition to the above, area M41M is visible from a very wide area ranging from public roads paths close to local summits such as The Helm, Scout Hill, Warth Hill and even as far away as Scout Scar. A development would be a major visible intrusion on the landscape, which no tree planting scheme would hide.
• In January 2010, SLDC identified key issues for Endmoor included the need for a more satisfactory northern edge and the need to safeguard the surrounding landscape. Replacing a 7 home edge with a 100 home development on a greenfield site does not meet these requirements. This could be achieved simply by planting more trees.
• The 30 houses per hectare in M41M/R670 is contrary to the SLDC Development Framework Section 2 Page 16 Sustainable Development Principles CS1.1 Point 2 & 3 and Land Allocation Development Plan Doc, Appendix 1 Sustainability Appraisal for Endmoor P187. Proposed housing density is 2.5 times the current village density and higher than other local village enlargements proposed. M41M /R670 would see a 30% increase in Endmoor village area and a 48% increase in homes/population. SLDC stated that extensions to LSC’s are only permitted where a clear need for development was identified, significant environmental impacts could be avoided and previously developed land utilised.
• It has never been explained why Endmoor has been allocated 125 new dwelling when Milnthorpe and Kirby Lonsdale have more infrastructure in place such as water drainage, shops, amenities etc., but have fewer new houses proposed.
• I question whether Endmoor can be considered as an LSC - the village shop is up for sale (and has been for several years) and the Post Office closed last year.
• Sewerage/Waste water requirements show Endmoor Sewage Works and Crooklands to be at capacity. United Utilities have not agreed to develop any existing or new sewerage works – United Utilities Letter Ref DC/12/882
• Current Water supply stated by United Utilities as in need of network reinforcement. We have lots of supply interruptions now due to burst pipes.
• At the recent Crematorium proposal, independent consultants concluded that the application be refused on the grounds that the highway network was unsuitable for expected volume of traffic. EN33 Commercial development would entail even higher traffic volumes. I also believe that the inclusion of EN33 in the DPD is outwith Policy CS7.4
To make the DPD legally compliant or sound, the following changes are considered necessary:
1) Review design figures based on current housing and business needs. This applies across the whole DPD.
2) More locally for Endmoor, remove M41M and R670 from the DPD , noting that M41M site has previously been identified as an Area of Great Landscape Value in the County Showfield Inspectors report - Ref 5/89/4103. They should be replaced with the ‘Fishing Tarn’ field and Birchfield area or area EN33, with reduced the density and number of houses to meet Development Framework criteria3) Reduce the size of area of the Village Development Boundary such that this will be more compliant with the Sustainable Development Principles CS1.1 -2&3.
Consultation
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
I believe SLDC have failed to deliver an effective and adequate consultation with the community resulting in no real and meaningful dialogue. The consultation has not been in accordance with the SCI and as such is unsound.
Some consultation has taken place but where alternatives have been suggested they have been ignored. For example the ‘Fishing Tarn’ fields and land at Birchfield in Endmoor were suggested as an alternative for development but ignored, no feedback was given. SLDC have refused to consider the views of local people on the negative environmental and landscape impact the schemes will create. In particular the people of Endmoor were not consulted on choice of EN20 & EN33 as an employment site and there is no business case to support this choice of location. As a brownfield site it would be far better allocated as housing land. Other issues with this land are contained in the Crematorium Inspectors findings (T/APP/M0933/A/99/1017615/P2).
In summary, the proposals now put forward do not bear any resemblance to the original proposals we were asked to comment upon. Furthermore little attention appears to be given to the people who are unable to make their comments electronically. A limited number of consultative style meetings have taken place but there has been an obsessive style adopted to make people comment back via the internet.
At a local consultative meeting SLDC advised the proposed development of M41M site originally as 68 homes and mixed commercial land. They then said there would be fewer homes and no commercial development but the final revised plans now show 100 homes. No consultation took place on increases with villagers.
The current land owner for M41M is a member of Preston Richard Parish Council (Endmoor) and has considerable but unrepresentative political influence over local decisions. He has, perhaps unsurprisingly, been very vociferous during consultations in promoting the development of this site (often drowning out local opinion). He has had Storey Homes of Carlisle on the site to develop a proposal. Indeed there were eight submissions by Storey Homes to the Initial Consultation across the district and as a consequence many areas of land identified as Emerging Options were significantly increased in size. This private consultation and lobbying does not represent proper public consultation. Whether or not a landowner and developer should be able to influence the council’s decisions to this extent is a matter which I request that the inspector considers. The sites subjected to reports by Story Homes are believed to include:-
Levens R682LVM
Cartmel R112
Kendal R107M, R150M
Kendal R103M, M39
Kendal R97M
Kendal (Endmoor) M41M
Ulverston RN131M
Swarthmoor RN109M
The Phase 2 development of the M41M site is planned for 2017 – 2025. SLDC state a Development Brief would be required before any development could proceed. However Storey’s are known to want to bring it forward 5 years.
It is also somewhat concerning that a piece of land off Birchfield in Endmoor (known as R83)which has been suggested as a development opportunity – meeting all the criteria required - has been rejected outright without explanation. My concern centres on the fact that the vice-chair of SLDC Planning Committee lives on the existing Birchfield site.
Hence I believe that the DPD is unsound due to my concern that a developer and landowner and possibly a Planning Committee member may have had an undue influence in the preparation of the Plan, to their benefit and detriment of residents with the resultant polarisation of the consultative process. Just because a piece of land is available for sale should not be an influencing criteria for inclusion in the DPD. With this in mind an independent investigation should be carried out to establish the extent of the influence that these parties have had on the DPD, before it is submitted to the government for approval.
In order to be legally compliant I believe SLDC need to honestly listen to the community (rather than landowners desperate to sell) and accept the fact that they need to adopt an alternative strategy rather than making minor changes to their current unsound strategy, in the hope that this will be acceptable.
Affordable Housing
A major thrust of the Council's policies has been the provision of affordable housing - it is not disputed that there is such a need but this often repeated phrase has not been satisfactorily defined. Wages are low in this area (as is the case in any area where tourism is the main economic driver) and in the continuing poor fiscal climate there is no reason to believe that Kendal will be able to attract large employers paying much over minimum wage. Also there continue to be large numbers of vacant or unsold properties in the area. Young people cannot afford ‘affordable’ housing. It is with much regret that our own children have had to go south for challenging work which pays well enough to secure a mortgage. The reality is that new housing in the SLDC area will largely just bring in better off commuters from Preston and Lancaster or attract more retirees and do nothing for locals.
Yorkshire Dales and Lake District National Parks take up a large proportion of SLDC area. SLDC housing (and industrial) numbers have been concentrated into the relatively small areas outside the Park boundaries in part to accommodate needs that arise from within the Parks. Consequently an excessive concentration is proposed which will place overwhelming pressures on the infrastructure (transport, education, health etc) within those small areas. Doctors, dentists and such like already have closed lists. Recently a fundamental policy change was made by LDNP within their LDF to permit 900 affordable houses to be built within the Park. SLDC proposed housing numbers should have been reduced proportionately. The basic housing numbers proposed by SLDC have remained unchanged throughout the long LDF process.
In Endmoor there is no evidence for such high numbers of new affordable housing in the village
• Only 4 families in the Parish on Housing waiting list
• Recent Housing Needs Survey found only 10 families in the Parish in need of affordable housing
• Services in the village do not match the needs of families in these houses.
There is also a history within the village of affordable housing being built but failing to be maintained as part of the ongoing affordable housing stock because it has been traded on as holiday homes and general market housing.
Infrastructure
There is no sound infrastructure development plan. It is clear that the issue of road safety on the A65 from which M41M would be accessed has not been addressed (two people have been killed in separate incidents on this stretch of road in the last few years). The transport study, with initial modeling results, is very much work in progress and the Executive Summary states that "overall the level of congestion resulting from the LDF development is not fully mitigated by any of the improvement schemes". On this basis alone the DPD should be referred back as unsound.
Utility supplies have not been addressed. Water is at capacity and the sewage requires extension, United Utilities have said that none of these are in their plan. Network Rail have not been consulted over level crossings and passenger train use. These would be particularly relevant on the Carnforth to Barrow line where overcrowding already occurs on morning trains and there are many level crossings.
An infrastructure delivery plan was promised as long ago as the summer of 2011 and we were told it would accompany the published DPD. Instead a "position statement" has been published which gives no answers to pressing questions such as:
• Air Quality (where Kendal is already breaching the law)
• Sewerage (where the system is already under strain as discussed above)
• Education Places (particularly pressure on primary school places)
• Flooding (there is often visible flooding in respect of M41M)
• Primary care health facilities (where some practices are full)
The DPD should not be approved until a viable infrastructure delivery plan is in place on all these issues, otherwise piecemeal developments, without a mitigating strategy, will have an adverse impact on quality of life for all Kendal residents.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
I have made a number of serious point in my response and I want to ensure they are taken into account, noting that the inspector will no doubt be swamped with information.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
899. Mr Martin Weeks (Individual) : 15 May 2012 16:03:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - All Endmoor sites
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The Land Allocations Document (DPD) is not within the Local Development Scheme and the key stages have not been followed
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
The DPD has not had regard to the Sustainable Community Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
See 2.3 below
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
• There is already an adequate supply of market housing available for sale of all types and price ranges, so there is no “exceptional need” to allocate land for market housing. Some property has been on the market for 2 years in Endmoor.
• No requirement for local commercial/industrial development has been demonstrated. Large numbers of vacant commercial property are available now locally at Summerlands and Gatebeck and further development is included in the already developing Auction Mart site.
• In the case of Endmoor, and M41M in particular, there will be significant impact with the proposed size of developments on the village and surrounding drumlin landscape which has previously been acknowledged as an Area of Great Landscape Value and a Landscape of County Importance which is supported by recent Inspectors reports:-
– County Showfield - Ref 5/89/4103
– Crematorium - T/APP/M0933/A/99/1017017/P2
– Sillfield Wind Turbines - Ref: SL/2008/0900
• In addition to the above, area M41M is visible from a very wide area ranging from public roads paths close to local summits such as The Helm, Scout Hill, Warth Hill and even as far away as Scout Scar. A development would be a major visible intrusion on the landscape, which no tree planting scheme would hide.
• In January 2010, SLDC identified key issues for Endmoor included the need for a more satisfactory northern edge and the need to safeguard the surrounding landscape. Replacing a 7 home edge with a 100 home development on a greenfield site does not meet these requirements. This could be achieved simply by planting more trees.
• The 30 houses per hectare in M41M/R670 is contrary to the SLDC Development Framework Section 2 Page 16 Sustainable Development Principles CS1.1 Point 2 & 3 and Land Allocation Development Plan Doc, Appendix 1 Sustainability Appraisal for Endmoor P187. Proposed housing density is 2.5 times the current village density and higher than other local village enlargements proposed. M41M /R670 would see a 30% increase in Endmoor village area and a 48% increase in homes/population. SLDC stated that extensions to LSC’s are only permitted where a clear need for development was identified, significant environmental impacts could be avoided and previously developed land utilised.
• It has never been explained why Endmoor has been allocated 125 new dwelling when Milnthorpe and Kirby Lonsdale have more infrastructure in place such as water drainage, shops, amenities etc., but have fewer new houses proposed.
• I question whether Endmoor can be considered as an LSC - the village shop is up for sale (and has been for several years) and the Post Office closed last year.
• Sewerage/Waste water requirements show Endmoor Sewage Works and Crooklands to be at capacity. United Utilities have not agreed to develop any existing or new sewerage works – United Utilities Letter Ref DC/12/882
• Current Water supply stated by United Utilities as in need of network reinforcement. We have lots of supply interruptions now due to burst pipes.
• At the recent Crematorium proposal, independent consultants concluded that the application be refused on the grounds that the highway network was unsuitable for expected volume of traffic. EN33 Commercial development would entail even higher traffic volumes. I also believe that the inclusion of EN33 in the DPD is outwith Policy CS7.4
It is also somewhat concerning that a piece of land off Birchfield in Endmoor (known as R83)which has been suggested as a development opportunity – meeting all the criteria required - has been rejected outright without explanation. My concern centres on the fact that the vice-chair of SLDC Planning Committee lives on the existing Birchfield site.
Hence I believe that the DPD is unsound due to my concern that a developer and landowner and possibly a Planning Committee member may have had an undue influence in the preparation of the Plan, to their benefit and detriment of residents with the resultant polarisation of the consultative process. Just because a piece of land is available for sale should not be an influencing criteria for inclusion in the DPD. With this in mind an independent investigation should be carried out to establish the extent of the influence that these parties have had on the DPD, before it is submitted to the government for approval.
In order to be legally compliant I believe SLDC need to honestly listen to the community (rather than landowners desperate to sell) and accept the fact that they need to adopt an alternative strategy rather than making minor changes to their current unsound strategy, in the hope that this will be acceptable.
Affordable Housing
A major thrust of the Council's policies has been the provision of affordable housing - it is not disputed that there is such a need but this often repeated phrase has not been satisfactorily defined. Wages are low in this area (as is the case in any area where tourism is the main economic driver) and in the continuing poor fiscal climate there is no reason to believe that Kendal will be able to attract large employers paying much over minimum wage. Also there continue to be large numbers of vacant or unsold properties in the area. Young people cannot afford ‘affordable’ housing. It is with much regret that our own children have had to go south for challenging work which pays well enough to secure a mortgage. The reality is that new housing in the SLDC area will largely just bring in better off commuters from Preston and Lancaster or attract more retirees and do nothing for locals.
Yorkshire Dales and Lake District National Parks take up a large proportion of SLDC area. SLDC housing (and industrial) numbers have been concentrated into the relatively small areas outside the Park boundaries in part to accommodate needs that arise from within the Parks. Consequently an excessive concentration is proposed which will place overwhelming pressures on the infrastructure (transport, education, health etc) within those small areas. Doctors, dentists and such like already have closed lists. Recently a fundamental policy change was made by LDNP within their LDF to permit 900 affordable houses to be built within the Park. SLDC proposed housing numbers should have been reduced proportionately. The basic housing numbers proposed by SLDC have remained unchanged throughout the long LDF process.
In Endmoor there is no evidence for such high numbers of new affordable housing in the village
• Only 4 families in the Parish on Housing waiting list
• Recent Housing Needs Survey found only 10 families in the Parish in need of affordable housing
• Services in the village do not match the needs of families in these houses.
There is also a history within the village of affordable housing being built but failing to be maintained as part of the ongoing affordable housing stock because it has been traded on as holiday homes and general market housing.
Infrastructure
There is no sound infrastructure development plan. It is clear that the issue of road safety on the A65 from which M41M would be accessed has not been addressed (two people have been killed in separate incidents on this stretch of road in the last few years). The transport study, with initial modeling results, is very much work in progress and the Executive Summary states that "overall the level of congestion resulting from the LDF development is not fully mitigated by any of the improvement schemes". On this basis alone the DPD should be referred back as unsound.
Utility supplies have not been addressed. Water is at capacity and the sewage requires extension, United Utilities have said that none of these are in their plan. Network Rail have not been consulted over level crossings and passenger train use. These would be particularly relevant on the Carnforth to Barrow line where overcrowding already occurs on morning trains and there are many level crossings.
An infrastructure delivery plan was promised as long ago as the summer of 2011 and we were told it would accompany the published DPD. Instead a "position statement" has been published which gives no answers to pressing questions such as:
• Air Quality (where Kendal is already breaching the law)
• Sewerage (where the system is already under strain as discussed above)
• Education Places (particularly pressure on primary school places)
• Flooding (there is often visible flooding in respect of M41M)
• Primary care health facilities (where some practices are full)
The DPD should not be approved until a viable infrastructure delivery plan is in place on all these issues, otherwise piecemeal developments, without a mitigating strategy, will have an adverse impact on quality of life for all Kendal residents.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
I have made a number of serious point in my response and I want to ensure they are taken into account, noting that the inspector will no doubt be swamped with information.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
900. Mr Martin Weeks (Individual) : 15 May 2012 16:07:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - M41M ENDMOOR NORTH OF SYCAMORE DRIVE
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
The DPD has not had regard to the Sustainable Community Strategy
The Land Allocations Document (DPD) is not within the Local Development Scheme and the key stages have not been followed
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
See 2.3 below
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
To make the DPD legally compliant or sound, the following changes are considered necessary:
1) Review design figures based on current housing and business needs. This applies across the whole DPD.
2) More locally for Endmoor, remove M41M and R670 from the DPD , noting that M41M site has previously been identified as an Area of Great Landscape Value in the County Showfield Inspectors report - Ref 5/89/4103. They should be replaced with the ‘Fishing Tarn’ field and Birchfield area or area EN33, with reduced the density and number of houses to meet Development Framework criteria3) Reduce the size of area of the Village Development Boundary such that this will be more compliant with the Sustainable Development Principles CS1.1 -2&3.
In summary, the proposals now put forward do not bear any resemblance to the original proposals we were asked to comment upon. Furthermore little attention appears to be given to the people who are unable to make their comments electronically. A limited number of consultative style meetings have taken place but there has been an obsessive style adopted to make people comment back via the internet.
At a local consultative meeting SLDC advised the proposed development of M41M site originally as 68 homes and mixed commercial land. They then said there would be fewer homes and no commercial development but the final revised plans now show 100 homes. No consultation took place on increases with villagers.
The current land owner for M41M is a member of Preston Richard Parish Council (Endmoor) and has considerable but unrepresentative political influence over local decisions. He has, perhaps unsurprisingly, been very vociferous during consultations in promoting the development of this site (often drowning out local opinion). He has had Storey Homes of Carlisle on the site to develop a proposal. Indeed there were eight submissions by Storey Homes to the Initial Consultation across the district and as a consequence many areas of land identified as Emerging Options were significantly increased in size. This private consultation and lobbying does not represent proper public consultation. Whether or not a landowner and developer should be able to influence the council’s decisions to this extent is a matter which I request that the inspector considers. The sites subjected to reports by Story Homes are believed to include:-
Levens R682LVM
Cartmel R112
Kendal R107M, R150M
Kendal R103M, M39
Kendal R97M
Kendal (Endmoor) M41M
Ulverston RN131M
Swarthmoor RN109M
The Phase 2 development of the M41M site is planned for 2017 – 2025. SLDC state a Development Brief would be required before any development could proceed. However Storey’s are known to want to bring it forward 5 years.
It is also somewhat concerning that a piece of land off Birchfield in Endmoor (known as R83)which has been suggested as a development opportunity – meeting all the criteria required - has been rejected outright without explanation. My concern centres on the fact that the vice-chair of SLDC Planning Committee lives on the existing Birchfield site.
Hence I believe that the DPD is unsound due to my concern that a developer and landowner and possibly a Planning Committee member may have had an undue influence in the preparation of the Plan, to their benefit and detriment of residents with the resultant polarisation of the consultative process. Just because a piece of land is available for sale should not be an influencing criteria for inclusion in the DPD. With this in mind an independent investigation should be carried out to establish the extent of the influence that these parties have had on the DPD, before it is submitted to the government for approval.
In order to be legally compliant I believe SLDC need to honestly listen to the community (rather than landowners desperate to sell) and accept the fact that they need to adopt an alternative strategy rather than making minor changes to their current unsound strategy, in the hope that this will be acceptable.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
I have made a number of serious point in my response and I want to ensure they are taken into account, noting that the inspector will no doubt be swamped with information.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
901. Mr Martin Weeks (Individual) : 15 May 2012 16:23:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - R670-mod ENDMOOR SOUTH OF BOWLING GREEN
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The Land Allocations Document (DPD) is not within the Local Development Scheme and the key stages have not been followed
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
The DPD has not had regard to the Sustainable Community Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
See 2.3 below
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
To make the DPD legally compliant or sound, the following changes are considered necessary:
1) Review design figures based on current housing and business needs. This applies across the whole DPD.
2) More locally for Endmoor, remove M41M and R670 from the DPD , noting that M41M site has previously been identified as an Area of Great Landscape Value in the County Showfield Inspectors report - Ref 5/89/4103. They should be replaced with the ‘Fishing Tarn’ field and Birchfield area or area EN33, with reduced the density and number of houses to meet Development Framework criteria3) Reduce the size of area of the Village Development Boundary such that this will be more compliant with the Sustainable Development Principles CS1.1 -2&3.
In summary, the proposals now put forward do not bear any resemblance to the original proposals we were asked to comment upon. Furthermore little attention appears to be given to the people who are unable to make their comments electronically. A limited number of consultative style meetings have taken place but there has been an obsessive style adopted to make people comment back via the internet.
At a local consultative meeting SLDC advised the proposed development of M41M site originally as 68 homes and mixed commercial land. They then said there would be fewer homes and no commercial development but the final revised plans now show 100 homes. No consultation took place on increases with villagers.
The current land owner for M41M is a member of Preston Richard Parish Council (Endmoor) and has considerable but unrepresentative political influence over local decisions. He has, perhaps unsurprisingly, been very vociferous during consultations in promoting the development of this site (often drowning out local opinion). He has had Storey Homes of Carlisle on the site to develop a proposal. Indeed there were eight submissions by Storey Homes to the Initial Consultation across the district and as a consequence many areas of land identified as Emerging Options were significantly increased in size. This private consultation and lobbying does not represent proper public consultation. Whether or not a landowner and developer should be able to influence the council’s decisions to this extent is a matter which I request that the inspector considers. The sites subjected to reports by Story Homes are believed to include:-
Levens R682LVM
Cartmel R112
Kendal R107M, R150M
Kendal R103M, M39
Kendal R97M
Kendal (Endmoor) M41M
Ulverston RN131M
Swarthmoor RN109M
The Phase 2 development of the M41M site is planned for 2017 – 2025. SLDC state a Development Brief would be required before any development could proceed. However Storey’s are known to want to bring it forward 5 years.
It is also somewhat concerning that a piece of land off Birchfield in Endmoor (known as R83)which has been suggested as a development opportunity – meeting all the criteria required - has been rejected outright without explanation. My concern centres on the fact that the vice-chair of SLDC Planning Committee lives on the existing Birchfield site.
Hence I believe that the DPD is unsound due to my concern that a developer and landowner and possibly a Planning Committee member may have had an undue influence in the preparation of the Plan, to their benefit and detriment of residents with the resultant polarisation of the consultative process. Just because a piece of land is available for sale should not be an influencing criteria for inclusion in the DPD. With this in mind an independent investigation should be carried out to establish the extent of the influence that these parties have had on the DPD, before it is submitted to the government for approval.
In order to be legally compliant I believe SLDC need to honestly listen to the community (rather than landowners desperate to sell) and accept the fact that they need to adopt an alternative strategy rather than making minor changes to their current unsound strategy, in the hope that this will be acceptable.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
I have made a number of serious point in my response and I want to ensure they are taken into account, noting that the inspector will no doubt be swamped with information.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
902. Mr Martin Weeks (Individual) : 15 May 2012 16:28:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.8 Local Employment Allocations - EN20, EN33# ENDMOOR LAND NORTH OF GATEBECK LANE, GATEBECK
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The Land Allocations Document (DPD) is not within the Local Development Scheme and the key stages have not been followed
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
The DPD has not had regard to the Sustainable Community Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
See 2.3 below
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
• There is already an adequate supply of market housing available for sale of all types and price ranges, so there is no “exceptional need” to allocate land for market housing. Some property has been on the market for 2 years in Endmoor.
• No requirement for local commercial/industrial development has been demonstrated. Large numbers of vacant commercial property are available now locally at Summerlands and Gatebeck and further development is included in the already developing Auction Mart site.
• In the case of Endmoor, and M41M in particular, there will be significant impact with the proposed size of developments on the village and surrounding drumlin landscape which has previously been acknowledged as an Area of Great Landscape Value and a Landscape of County Importance which is supported by recent Inspectors reports:-
– County Showfield - Ref 5/89/4103
– Crematorium - T/APP/M0933/A/99/1017017/P2
– Sillfield Wind Turbines - Ref: SL/2008/0900
• In addition to the above, area M41M is visible from a very wide area ranging from public roads paths close to local summits such as The Helm, Scout Hill, Warth Hill and even as far away as Scout Scar. A development would be a major visible intrusion on the landscape, which no tree planting scheme would hide.
• In January 2010, SLDC identified key issues for Endmoor included the need for a more satisfactory northern edge and the need to safeguard the surrounding landscape. Replacing a 7 home edge with a 100 home development on a greenfield site does not meet these requirements. This could be achieved simply by planting more trees.
• The 30 houses per hectare in M41M/R670 is contrary to the SLDC Development Framework Section 2 Page 16 Sustainable Development Principles CS1.1 Point 2 & 3 and Land Allocation Development Plan Doc, Appendix 1 Sustainability Appraisal for Endmoor P187. Proposed housing density is 2.5 times the current village density and higher than other local village enlargements proposed. M41M /R670 would see a 30% increase in Endmoor village area and a 48% increase in homes/population. SLDC stated that extensions to LSC’s are only permitted where a clear need for development was identified, significant environmental impacts could be avoided and previously developed land utilised.
• It has never been explained why Endmoor has been allocated 125 new dwelling when Milnthorpe and Kirby Lonsdale have more infrastructure in place such as water drainage, shops, amenities etc., but have fewer new houses proposed.
• I question whether Endmoor can be considered as an LSC - the village shop is up for sale (and has been for several years) and the Post Office closed last year.
• Sewerage/Waste water requirements show Endmoor Sewage Works and Crooklands to be at capacity. United Utilities have not agreed to develop any existing or new sewerage works – United Utilities Letter Ref DC/12/882
• Current Water supply stated by United Utilities as in need of network reinforcement. We have lots of supply interruptions now due to burst pipes.
• At the recent Crematorium proposal, independent consultants concluded that the application be refused on the grounds that the highway network was unsuitable for expected volume of traffic. EN33 Commercial development would entail even higher traffic volumes. I also believe that the inclusion of EN33 in the DPD is outwith Policy CS7.4
To make the DPD legally compliant or sound, the following changes are considered necessary:
1) Review design figures based on current housing and business needs. This applies across the whole DPD.
2) More locally for Endmoor, remove M41M and R670 from the DPD , noting that M41M site has previously been identified as an Area of Great Landscape Value in the County Showfield Inspectors report - Ref 5/89/4103. They should be replaced with the ‘Fishing Tarn’ field and Birchfield area or area EN33, with reduced the density and number of houses to meet Development Framework criteria3) Reduce the size of area of the Village Development Boundary such that this will be more compliant with the Sustainable Development Principles CS1.1 -2&3.
In summary, the proposals now put forward do not bear any resemblance to the original proposals we were asked to comment upon. Furthermore little attention appears to be given to the people who are unable to make their comments electronically. A limited number of consultative style meetings have taken place but there has been an obsessive style adopted to make people comment back via the internet.
At a local consultative meeting SLDC advised the proposed development of M41M site originally as 68 homes and mixed commercial land. They then said there would be fewer homes and no commercial development but the final revised plans now show 100 homes. No consultation took place on increases with villagers.
The current land owner for M41M is a member of Preston Richard Parish Council (Endmoor) and has considerable but unrepresentative political influence over local decisions. He has, perhaps unsurprisingly, been very vociferous during consultations in promoting the development of this site (often drowning out local opinion). He has had Storey Homes of Carlisle on the site to develop a proposal. Indeed there were eight submissions by Storey Homes to the Initial Consultation across the district and as a consequence many areas of land identified as Emerging Options were significantly increased in size. This private consultation and lobbying does not represent proper public consultation. Whether or not a landowner and developer should be able to influence the council’s decisions to this extent is a matter which I request that the inspector considers. The sites subjected to reports by Story Homes are believed to include:-
Levens R682LVM
Cartmel R112
Kendal R107M, R150M
Kendal R103M, M39
Kendal R97M
Kendal (Endmoor) M41M
Ulverston RN131M
Swarthmoor RN109M
The Phase 2 development of the M41M site is planned for 2017 – 2025. SLDC state a Development Brief would be required before any development could proceed. However Storey’s are known to want to bring it forward 5 years.
It is also somewhat concerning that a piece of land off Birchfield in Endmoor (known as R83)which has been suggested as a development opportunity – meeting all the criteria required - has been rejected outright without explanation. My concern centres on the fact that the vice-chair of SLDC Planning Committee lives on the existing Birchfield site.
Hence I believe that the DPD is unsound due to my concern that a developer and landowner and possibly a Planning Committee member may have had an undue influence in the preparation of the Plan, to their benefit and detriment of residents with the resultant polarisation of the consultative process. Just because a piece of land is available for sale should not be an influencing criteria for inclusion in the DPD. With this in mind an independent investigation should be carried out to establish the extent of the influence that these parties have had on the DPD, before it is submitted to the government for approval.
In order to be legally compliant I believe SLDC need to honestly listen to the community (rather than landowners desperate to sell) and accept the fact that they need to adopt an alternative strategy rather than making minor changes to their current unsound strategy, in the hope that this will be acceptable.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
I have made a number of serious point in my response and I want to ensure they are taken into account, noting that the inspector will no doubt be swamped with information.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
903. Mr Martin Weeks (Individual) : 15 May 2012 16:32:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
0.0 Whole Document
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The Land Allocations Document (DPD) is not within the Local Development Scheme and the key stages have not been followed
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
The DPD has not had regard to the Sustainable Community Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
See 2.3 below
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Factual Data
The DPD is expected to be backed by “research/fact finding: the choices made in the plan are backed up by facts”. The following bullets illustrate that this has not been done properly and all these points need to be addressed to justify the DPD. The DPD currently is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
• There has been no evidence provided of consultation with statutory bodies such as Highways, Utilities, Network Rail, Bus operators etc.
• SLDC used 2005 Business plans, acknowledged as out of date. Following the economic downturn, figures are deficient and do not reflect the current needs.
• SLDC Housing figures provided by the Office for National Statistics, were last updated in 2006. Cumbria CC deem only 2,400 new homes required, not 6,000 as portrayed by SLDC. This represents a 4.6% increase in housing stock, against an 11.5% increase using SLDC figures. I therefore question the need for 6,000 new homes in South Lakeland now that the Regional Spatial Strategy has been removed by the current Government. I ask that SLDC halts the publication of the LDP, pending implementation of the Localism Bill and the introduction of Neighbourhood Planning”.
• Development does not take into account the 1000 homes identified by the local MP (Tim Farron) as in need of refurbishment.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
I have made a number of serious point in my response and I want to ensure they are taken into account, noting that the inspector will no doubt be swamped with information.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
904. Mr Martin Weeks (Individual) : 15 May 2012 16:46:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
1.9
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The Land Allocations Document (DPD) is not within the Local Development Scheme and the key stages have not been followed
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
The DPD has not had regard to the Sustainable Community Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
See 2.3 below
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Consultation
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
I believe SLDC have failed to deliver an effective and adequate consultation with the community resulting in no real and meaningful dialogue. The consultation has not been in accordance with the SCI and as such is unsound.
Some consultation has taken place but where alternatives have been suggested they have been ignored. For example the ‘Fishing Tarn’ fields and land at Birchfield in Endmoor were suggested as an alternative for development but ignored, no feedback was given. SLDC have refused to consider the views of local people on the negative environmental and landscape impact the schemes will create. In particular the people of Endmoor were not consulted on choice of EN20 & EN33 as an employment site and there is no business case to support this choice of location. As a brownfield site it would be far better allocated as housing land. Other issues with this land are contained in the Crematorium Inspectors findings (T/APP/M0933/A/99/1017615/P2).
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
I have made a number of serious point in my response and I want to ensure they are taken into account, noting that the inspector will no doubt be swamped with information.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
905. Mr Martin Weeks (Individual) : 15 May 2012 16:48:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
1.10
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The Land Allocations Document (DPD) is not within the Local Development Scheme and the key stages have not been followed
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
The DPD has not had regard to the Sustainable Community Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
See 2.3 below
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
In summary, the proposals now put forward do not bear any resemblance to the original proposals we were asked to comment upon. Furthermore little attention appears to be given to the people who are unable to make their comments electronically. A limited number of consultative style meetings have taken place but there has been an obsessive style adopted to make people comment back via the internet.
At a local consultative meeting SLDC advised the proposed development of M41M site originally as 68 homes and mixed commercial land. They then said there would be fewer homes and no commercial development but the final revised plans now show 100 homes. No consultation took place on increases with villagers.
The current land owner for M41M is a member of Preston Richard Parish Council (Endmoor) and has considerable but unrepresentative political influence over local decisions. He has, perhaps unsurprisingly, been very vociferous during consultations in promoting the development of this site (often drowning out local opinion). He has had Storey Homes of Carlisle on the site to develop a proposal. Indeed there were eight submissions by Storey Homes to the Initial Consultation across the district and as a consequence many areas of land identified as Emerging Options were significantly increased in size. This private consultation and lobbying does not represent proper public consultation. Whether or not a landowner and developer should be able to influence the council’s decisions to this extent is a matter which I request that the inspector considers. The sites subjected to reports by Story Homes are believed to include:-
Levens R682LVM
Cartmel R112
Kendal R107M, R150M
Kendal R103M, M39
Kendal R97M
Kendal (Endmoor) M41M
Ulverston RN131M
Swarthmoor RN109M
The Phase 2 development of the M41M site is planned for 2017 – 2025. SLDC state a Development Brief would be required before any development could proceed. However Storey’s are known to want to bring it forward 5 years.
It is also somewhat concerning that a piece of land off Birchfield in Endmoor (known as R83)which has been suggested as a development opportunity – meeting all the criteria required - has been rejected outright without explanation. My concern centres on the fact that the vice-chair of SLDC Planning Committee lives on the existing Birchfield site.
Hence I believe that the DPD is unsound due to my concern that a developer and landowner and possibly a Planning Committee member may have had an undue influence in the preparation of the Plan, to their benefit and detriment of residents with the resultant polarisation of the consultative process. Just because a piece of land is available for sale should not be an influencing criteria for inclusion in the DPD. With this in mind an independent investigation should be carried out to establish the extent of the influence that these parties have had on the DPD, before it is submitted to the government for approval.
In order to be legally compliant I believe SLDC need to honestly listen to the community (rather than landowners desperate to sell) and accept the fact that they need to adopt an alternative strategy rather than making minor changes to their current unsound strategy, in the hope that this will be acceptable.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
I have made a number of serious point in my response and I want to ensure they are taken into account, noting that the inspector will no doubt be swamped with information.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
906. Mr Martin Weeks (Individual) : 15 May 2012 16:51:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - Site Omission
If you have selected a ‘Site omission’ please enter the site reference or location and relevant policy below
R83
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The Land Allocations Document (DPD) is not within the Local Development Scheme and the key stages have not been followed
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
The DPD has not had regard to the Sustainable Community Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
See 2.3 below
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Consultation
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
I believe SLDC have failed to deliver an effective and adequate consultation with the community resulting in no real and meaningful dialogue. The consultation has not been in accordance with the SCI and as such is unsound.
Some consultation has taken place but where alternatives have been suggested they have been ignored. For example the ‘Fishing Tarn’ fields and land at Birchfield in Endmoor were suggested as an alternative for development but ignored, no feedback was given. SLDC have refused to consider the views of local people on the negative environmental and landscape impact the schemes will create. In particular the people of Endmoor were not consulted on choice of EN20 & EN33 as an employment site and there is no business case to support this choice of location. As a brownfield site it would be far better allocated as housing land. Other issues with this land are contained in the Crematorium Inspectors findings (T/APP/M0933/A/99/1017615/P2).
It is also somewhat concerning that a piece of land off Birchfield in Endmoor (known as R83)which has been suggested as a development opportunity – meeting all the criteria required - has been rejected outright without explanation. My concern centres on the fact that the vice-chair of SLDC Planning Committee lives on the existing Birchfield site.
Hence I believe that the DPD is unsound due to my concern that a developer and landowner and possibly a Planning Committee member may have had an undue influence in the preparation of the Plan, to their benefit and detriment of residents with the resultant polarisation of the consultative process. Just because a piece of land is available for sale should not be an influencing criteria for inclusion in the DPD. With this in mind an independent investigation should be carried out to establish the extent of the influence that these parties have had on the DPD, before it is submitted to the government for approval.
In order to be legally compliant I believe SLDC need to honestly listen to the community (rather than landowners desperate to sell) and accept the fact that they need to adopt an alternative strategy rather than making minor changes to their current unsound strategy, in the hope that this will be acceptable.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
I have made a number of serious point in my response and I want to ensure they are taken into account, noting that the inspector will no doubt be swamped with information.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
907. Mr Martin Weeks (Individual) : 18 May 2012 14:57:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - Site Omission
If you have selected a ‘Site omission’ please enter the site reference or location and relevant policy below
Site omission - Ref. RN239#
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The Land Allocations Document (DPD) is not within the Local Development Scheme and the key stages have not been followed
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
The DPD has not had regard to the Sustainable Community Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
See 2.3 below.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
To make the DPD legally compliant or sound, the following changes are considered necessary:
1) Review design figures based on current housing and business needs. This applies across the whole DPD.
2) More locally for Endmoor, remove M41M and R670 from the DPD , noting that M41M site has previously been identified as an Area of Great Landscape Value in the County Showfield Inspectors report - Ref 5/89/4103. They should be replaced with the ‘Fishing Tarn’ field and Birchfield area or area EN33, with reduced the density and number of houses to meet Development Framework criteria3) Reduce the size of area of the Village Development Boundary such that this will be more compliant with the Sustainable Development Principles CS1.1 -2&3.
Consultation
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
I believe SLDC have failed to deliver an effective and adequate consultation with the community resulting in no real and meaningful dialogue. The consultation has not been in accordance with the SCI and as such is unsound.
Some consultation has taken place but where alternatives have been suggested they have been ignored. For example the ‘Fishing Tarn’ fields and land at Birchfield in Endmoor were suggested as an alternative for development but ignored, no feedback was given. SLDC have refused to consider the views of local people on the negative environmental and landscape impact the schemes will create. In particular the people of Endmoor were not consulted on choice of EN20 & EN33 as an employment site and there is no business case to support this choice of location. As a brownfield site it would be far better allocated as housing land. Other issues with this land are contained in the Crematorium Inspectors findings (T/APP/M0933/A/99/1017615/P2).
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
I have made a number of serious points in my response and I want to ensure they are taken into account, noting that the inspector will no doubt be swamped with information.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
908. Mr and Mrs John Whitehead (Individual) : 10 May 2012 12:39:00
Paragraph No.
0.0 Whole Document
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
We wish to make the following response to the Publication Stage - having
read the guidance notes.
We do not consider the document to be sustainable for the following
reasons:-
1 The Council have persisted in demanding 8800 houses plus
industrial/commercial development land between 2003 and
2025 without producing sound evidence of the need for this
scale of development for public review.
2 The Council says that 3080 'affordable' houses are needed out
of the above total without, again, producing evidence of need.
3 An SLDC Councillor for our area said that the Council accepted
that no developer would build more than 35% of a given
development as 'affordable'. It is notable therefore that 35% of
8800 just happens to be 3080. On what grounds does the
Council justify the building of 5720 house at open market prices
in order to achieve 3080 'affordable' houses? Where is the
proof of the demand for 5720 open market houses?
4 The Council has actively encouraged people to live in S Lakes
and work in Barrow-in-Furness, Carlisle, Preston, Blackburn
and Skipton. This is sure against all national policy and is not
green or sustainable.
5 The 8800 houses, the Planning Department agreed, suggests
about 35,000 more people in addition to the existing population
in South Lakes of about 165,000. Where are the thousands of
jobs, the hospitals, roads, schools, social facilities, etc to
support this increase?
6. The roads available are already overstretched, often with no
pavements. To superimpose 35,000 more people and their cars
on the infrasture is not sustainable- we already have 2 of the
most dangerous roads in the UK. inS Lakes ie A65 and A590.
To add more traffic to these roads is not sound.
7. One of the SLDC definitions of 'sustainability' is that new
residents can travel to work by public transport in 30-minutes.
This would not seem likely.
8. The Council has not specified brownfield land. Green fields are
more important than ever for FARMING as the ever growing
population needs more food. Sources overseas may not be
sustained in future.
9. In view of the economic climate likely for the next 10 years the
scale of development is much less likely to be justified and
many thought it was unjustified back in 2008.
10. The SLDC 'Consultation' has been a very expensive drawn out
process which has shown the Council to have not changed its
plans in any significant way.
The policy documents are in our view unsustainable.
909. Mr Derek Whitmore (Individual) : 17 Apr 2012 09:47:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA2.2 Land North of Laurel Gardens
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
1.0 Consultation
1.1 SLDC did not change the proposals in-line with the citizens important wishes.
The Government Planning Advisory Service (PAS) defines the requirements for Legal Compliance in it’s document – "legal.doc” (Legal Compliance Tool from http://www.pas.gov.uk/pas/aio/85651 )
Extract from Stage 2: Plan preparation - frontloading phase (page 7):
“6. Does the consultation contribute to the development and sustainability appraisal of alternatives?”
This has not been carried out correctly, alternatives have not been seriously considered. In particular the Kendal Town Council’s excellent reports, containing good alternatives, have been ignored.
The vast majority of the oppose responses made in the SLDC consultations were noted, listed in the consultation documents and then almost totally ignored. In my view these consultations were just so that SLDC could “tick the box” for the government inspector and therefore were a waste of taxpayers money.
I have done a detailed examination of the SLDC Consultation Database and these are my findings:
On 11th August 2011 (after the closing date) there were 2986 responses from the Kendal settlement. 98% of these responses opposed the proposals in their neighbourhood. Most of those that “support in part” did not support housing. Most of the few indicating “support” were representatives of the land owner, potential builder, Kendal Futures Board or the North West Development Agency.
The main reasons for the respondents opposition was the increase in traffic that these proposed developments would cause, and the affect they would have on the landscape character of Kendal. Better alternative sites were suggested, noted and then ignored. The present proposals will not “satisfy the needs of future generations” and are therefore NOT SUSTAINABLE.
Issues raised in the consultations would have contributed greatly to the development and sustainability of alternatives but the alternatives put forward have been ignored (also see other evidence 2.3 below). Therefore the LA DPD it is not Legally Compliant.
I would like to see alternatives discussed with Kendal Town Council and the Green Spaces group. Then any changes agreed included in the LA DPD.
2.0 Alternative plan
2.1 Law must be obeyed.
Extract from Stage 2: Plan preparation - frontloading phase (legal.doc page 5):
“* developing alternatives and options and appraising them through sustainability appraisal and against evidence.”
The SLDC Air Quality reports show that SLDC have been breaking the Law on Air Quality for many years. It means that SLDC must use an alternative plan for Kendal until it is proven that the law is being obeyed (with spare capacity for proposed development). The reason the law must be proven is that action plans have not worked for at least 14 years (before 1998). In the meantime affordable houses can be built in other areas of SLDC which have low traffic.
Until an alternative plan is in position to ensure the law on Air Quality is obeyed (with spare capacity for the proposed development) the LA DPD is not Legally Compliant.
-----------------------------------------------------------------------------------------------
These Legal Compliance requirements are not definitive or closed questions; they are open to personal interpretation, so I will not make any further comment in these sections.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Personal Comments:- From my experience of the Core Strategy hearings and the SLDC consultations I know my response will be ignored. The changes to Kendal’s infrastructure, that the new SLDC Transport Study (Jan12) states are required (see below), is just one example of this. I am therefore taking this opportunity to place on record all the relevant evidence I have gathered on why site R170M (policy LA2.2) should not be included in the LA DPD. Quotes from certain documents have been added to make it easier for the reader. There is repetition of some issues but this is because I have added different sources of evidence throughout the document.
It is undemocratic just to include Legal Compliance and Soundness in this consultation. In a democratic society the wishes of the majority of local people would have priority over these criteria. Also criteria such as “Justice” and “Fairness” should be considered. These were totally ignored in the Core Strategy consultation and hearings.
Test of Soundness
1.0 Not justified
1.1 Health and well-being of citizens in Kendal.
I have been informed that a developer does not have to fix an existing problem he just needs to show that he will not make it any worse. This is ridiculous, while SLDC are breaking the law on Air Quality developers must not be allowed to build on site R170M and other Kendal sites until the law is obeyed. SLDC breaking the law must surely be enough to prevent developers from winning an appeal. The people’s health and well-being must have top priority over everything else in the LA DPD.
The latest Cumbria County Council’s transport plan LPT3 does not include plans for the necessary infrastructure to fix existing problems neither does the SLDC Core Strategy. It was only after pressure from the public that SLDC & CCC produced the Transport Study (which is only a study) and after all this time the Transport Plan has not yet been made available to the public. Without a Transport Plan (including committed funding) signed off by all the participants the LA DPD is UNDELIVERABLE within the current timescales (2025) and is UNSOUND.
Before the year 2000 the SLDC objective was to meet the law on Air Quality by the year 2005 but air pollution has continually increased and the AQMA (Air Quality Management Area) has even been made larger. This shows that SLDC are not serious in meeting their objectives where the health and well-being of citizens, or obeying the law, are concerned.
A typical example is the approval of the Planning Application for the old Auction Mart site. Also planning approval is certain to go ahead for the Canal Head development. These will make the air pollution worse in the AQMA. The worst pollution occurs when junctions are grid-locked and tinkering with traffic lights will not fix this problem. It will take major infrastructure changes to fix the existing traffic problems and allow for proposed LDF expansion. The Transport Study even admits that none of the improvements schemes will meet SLDC objectives.
Extract from SLDC document "Kendal Transport Study (Jan12).pdf ”:
“6.1.6 Furthermore, even with the implementation of these improvement schemes, it is important to note that a large proportion of the key junctions would continue to operate above capacity, and therefore experience congestion and extensive queuing in the 2022 base situation. This situation would be compounded by the LDF development traffic.”
More building is planned in Kendal within the next few years (phase 1). This will make the major traffic problems worse. Infrastructure should already be in place to cope. Instead there is not even an approved Transport Plan in place, never mind the infrastructure that will be needed to meet SLDC standards and objectives.
The Transport Study is stating that further modelling is required. This shows that SLDC do not yet know at the present time if their proposals can be implemented or if funding will be available within the LDF timeframe (year 2025), therefore the LA DPD is UNSOUND. Once money has been spent on major infrastructure changes it will be expected that these changes will last for at least 15 years (through the next LDF) therefore any further modelling must use a date of 2040 or beyond. These results will prove that the Taylor “hub & spoke” must be started now (see more evidence below).
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. The health of residents of Kendal town should also cause great concern; a lot of them are elderly and frail.
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.
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 LA DPD maps for the SLDC district, have not been included on the latest maps. It is not fair that these traffic problems are not shared throughout the entire SLDC district. This is another reason why the hub & spoke system must be adopted – FAIRNESS.
The health and well-being of the people due to air pollution must have top priority over everything else in the LDF. This is not happening with the current proposals. Proving the law is being obeyed must come second on the priority list after health. If it does not already do so the “Soundness” examination must take account of these two very important issues.
The evidence above shows that these traffic problems in Kendal will not be fixed without major infrastructure changes which are not in Cumbria County Council’s LTP3.
Site R170M will add further traffic to the streets of Kendal. Therefore the LA DPD is UNSOUND and site R170M must be removed from the LA DPD until the Northern Development Route has an approved construction plan and funding (see above).
For more evidence see extracts from the SLDC Transport Study (Jan12) below.
1.2 Alternative strategy.
Although SLDC have carried out consultations they have ignored the major objections. They have even ignored the alternatives put forward by Kendal Town Council in their excellent reports - “KTC_Response.pdf ”, “KTCResponsePart2toLandAllocation.pdf ” & “Land Allocations Representation (2).pdf. ". To avoid even more “urban sprawl” of Kendal the Taylor “hub & spoke” strategy must be adopted and not the current “doughnut” strategy. Kendal will be around for many thousands of years to come, which makes the “doughnut” strategy UNSUSTAINABLE (i.e. will not satisfy the needs of future generations). Only the “hub & spoke” is sustainable in the years to come because extra “satellites” can be added. By then the proposed “doughnut” system will make Kendal such an urban sprawl that very few people will wish to live there. To prevent this happening the “hub & spoke” system must be started NOW.
Money is being put before what is best for the health and well-being of the people of Kendal now and in the future (beyond 2025).
The Taylor Report, which puts forward compelling evidence in favour of the “hub & spoke” system, shows that the proposed “doughnut” system is UNSUSTAINABLE and therefore the development of site R170 (being a peripheral Green Gap site) is UNSOUND and must be removed from the LA DPD.
2.0 Not effective
2.1 Not meeting definitions of soundness.
The Government Planning Advisory Service (PAS) defines the requirements for Soundness in the document - "soundness.doc" (Soundness Tool from: http://www.pas.gov.uk/pas/aio/85673 )
Extract from page 6 - Deliverable:
"21. Are there realistic timescales related to the objectives?
i. Sections of the development plan document which address delivery and the timescales for key developments and initiatives.
ii. Confirmation from the local strategic partnership and partner organisations that the timescales are realistic in terms of their contribution to delivery."
Extract from page 8 - Deliverable:
“28. Is it clear who is going to deliver the required infrastructure and does the timing of the provision complement the timescale of the strategy/policies?
i. Confirmation from infrastructure providers that they support the solutions proposed and the identified means and timescales for their delivery.
ii. Representations in respect of infrastructure.
iii. Reports or copies of correspondence on how representations in relation to infrastructure and its timing have been considered and dealt with.”
Extract from page 5 of SLDC document "Kendal Transport Study (Jan12).pdf ”:
Exec Summary (see also 6.1.6 on page 18)
“12. Furthermore, even with the implementation of these improvement schemes, it is important to note that a large proportion of the key junctions would continue to operate above capacity, and therefore experience congestion and extensive queuing in the 2022 base situation. This situation would be compounded by the LDF development traffic.”
I have only selected this one paragraph; there are numerous other paragraphs which support these conclusions. In particular Page 15, Item 5.2.1, Table 5.1 which confirms that all schemes fail to meet SLDC’s objective. The results in Tables 5.2 & 5.3 are even worse.
SLDC’s objective is to meet “Acceptable junction performance” which is defined on page 9, item 4.1.5.
I'm not sure why the year 2022 was chosen as base-line, whatever major infrastructure is planned must enable SLDC to meet their objectives for years beyond 2025. In my opinion until 2040, the end of the next LDF.
Schemes 4, 5 & 6 require major investment and are not in the Core Strategy and therefore must be excluded from the Transport Plan when it is published. Note that the Transport Plan should incorporate extra capacity to cope with the “doughnut” system which, if approved, will undoubtedly continue after 2025.
The SLDC Air Quality Reports show that air pollution is getting worse in Kendal and also the AQMA has been increased.
Extract from page 27 of Air Quality Report (PR_Report_Template_2010.pdf)
(see http://www.southlakeland.gov.uk/downloads/page857/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”. Over many previous years this is typical of SLDC’s attitude towards obeying the law on Air Quality. SLDC action plans have not worked in the past and this is proved by the fact that the AQMA has recently been made larger.
The SLDC document "ED43_Housing Completions 1999 to 2010.doc" plus SLDC updates show that from the beginning of plan period 2003 to end of 2011 (8 years results) the total for South Lakeland is 1690 / 8 = 211 average and of these affordable are 406 / 8 = 51 average (or 24%). Figures for 2006 to 2011 (last 5 years results) are 934 / 5 = 187 average and of these affordable are 264 / 5 = 53 average (or 28%).
Between 2003 and 2011 the number of completions was 1690. At 400 per year the objective was 3200 over this 8 year period, a difference of 1510. To make up this deficit means that over the remaining 14 years (up to 2025) an extra 1510 / 14 = 107 per year will be required. This extra number per year will get a lot higher when the build rate stays below 400 per year.
This is nowhere near the Core Strategy figure of 400 dwellings per year or the percentage affordable figure of 35% and therefore the LA DPD is UNDELIVERABLE. 200 dwellings per year would be a more realistic figure and this is the latest figure that is necessary according to a Kendal Town Council Report (see below).
SLDC have recognised this and have added the word “ambition” to build this number of houses to the LA DPD (see page 7 of the “Land Allocations DPD [Feb 12].pdf ” as an example). This word is not used in this context with regard to numbers in the Core Strategy document. Therefore the LA DPD is UNSOUND with respect to the Core Strategy. The Leader of the Council insisted the numbers in the Core Strategy were achievable within the timescales of the LDF.
The above figures show there was an inward migration of 3 (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 all the partners involved have “signed on the dotted line” that they will meet the LA DPD milestones for all the necessary infrastructure (roads, sewerage, doctors, dentists, schools, etc) that is required. With the proviso that the build will actually take place in the timescales planned. It causes unnecessary stress to local people when unachievable targets are proposed or planned.
Another issue that affects DELIVERABILITY is Brownfield sites (or previously developed land).
It states in "SLDC_Core_Strategy_Document_March2011_sm4web2.pdf " (page 17):
"CS1.2 – The Development Strategy
Priority will be given to the reuse of existing buildings and previously developed land for all new housing development, with a target of ensuring that at least 28% of new housing development takes place on such sites."
The “at least 28%” is also mentioned in CS6.6 (page 85). The 50% in item 7.14 is a mistake, it was the previous target. Now the target has been lowered, and "at least 28%" is said by SLDC to be achievable, the LA DPD must indicate the amount of Brownfield land that is currently available and the targets in each area. The Core Strategy and LA DPD have a requirement to be monitored and targets at least progressed vigorously.
The LA DPD does not mention this requirement; therefore it does not conform to the Core Strategy and is UNSOUND. Also these monitored figures need to be published and available to the public.
The SLDC Transport Report (Atkins 2009) 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." There are more similar comments on pages 60 & 71.
Site R170M feeds traffic into Windermere Road and therefore must be removed from the LA DPD until SLDC have met their objectives on Air Quality and Junction Congestion.
Extract from SLDC document "Kendal Transport Study (Jan12).pdf ” page 5 (Exec Summary):
"However, the provision of a new route along Dowker’s Lane (scheme 4) would be required if the Rugby Club development is included. If the Canal Head development is included, the proposed Kendal Northern Development Route (Scheme 5) would be required."
The Canal Head development is more important to Kendal than site R170M therefore because site R170M will add more traffic to Kendal streets it is UNSOUND to build on it. It must be removed from the LA DPD until the Northern Development Route has an approved construction plan and committed funding.
Page 115 of the document “KENDAL Appendix 1.pdf ” (Appendix 1B – Consultation Responses after October 2010) for site R170M states:
“Achieving adequate visibility will be problematic given alignment of road and limited frontage. Such a large site would require a secondary access (Cumbria County Council – Highways).”
The conclusions reached by a chartered civil engineer who has carried out measurements to Transport Standards of the proposed access to site R170M are as follows:
“There is severely restricted forward visibility on both bends in Burneside Road either side of the proposed access location.
In either scenario tested the visibility from the proposed access towards Kendal falls far short of the standard required.
A new junction cannot be safely introduced in this location.”
This report can be supplied if required.
It cannot be right not to identify this secondary access. When it is identified there will be a lot more opposition to site R170 than is currently expressed.
As I said at the beginning of this response about including “JUSTICE” and “FAIRNESS”, it is not FAIR to include a site which is likely to have “show stopping” problems without first carrying out a thorough investigation into these particular problems.
Given the evidence above, until it can be proved that both access roads can be built to meet the Transport Standards, the development of the site R170 is UNSOUND and it must be removed from the LA DPD.
The site R170M is still 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 site R170M is not removed from the LA DPD.
This is a very important reason why site R170M should not be developed – JUSTICE.
Extract from page 137 item 6.9 of the Inspector's Report on the public enquiry in 1996. Green Gap site R170M is the site mentioned below.
"Inspector's Conclusions:
6.9 The objection by Mr Downham [biased land owner] is not concerned with the provision of a green gap, but the extent of that gap. It is argued [land owner’s words] that the green gap, as shown in the Consultation draft of the Plan, follows a public footpath running between substantial hedges, a clearly defined landscape boundary: whilst the residential allocation at Sparrowmire has been reduced in the Deposit Draft, an equivalent extension to the green gap is not necessary. ^However, and most importantly in my view, the objection indicates that the "land should remain unallocated as white land so that when the Plan is reviewed in 10 years' time it can be considered as potential residential land" [land owner’s words]. I consider this underlying reason for excluding the land from the green gap identifies the very reason it should remain so designated. Structure Plan Policy 14 and the reasoned justification makes no reference to the length of time during which the vulnerable areas of countryside between settlements should be protected.^ Although policies and proposals in the Local Plan must clearly relate to the Plan period, and can be subject to review thereafter, it appears to me common sense that what is unacceptable now, will most probably be equally unacceptable at the end of the Plan period: certainly I consider the Plan should seek to engender a degree of public confidence that the separation secured will not, at some future time, be lightly squandered. ^For these reasons I believe that, where a green gap is seen as necessary, it is more important that the whole gap between the settlements should be designated as green gap than that substantial, but arbitrary landscape features should be rigidly followed. I also consider the inter-visibility of settlements is not a factor which should affect the definition of green gaps."^
I have marked with ^...^ the most important words in the above paragraph and my clarifying words are in square brackets.
The first group of sentences marked ^...^ indicates that the owner wished to leave the remaining land (now site R170M) as white land, so it can sold as high priced building land at a later date. The inspector states that this is the very reason it must remain as a Green Gap and because of this statement it is Green Gap. The LA DPD only includes Green Gap site R170M because the owner is keen to sell and make a large profit, if he didn’t it would not be included.
The second group of sentences marked ^...^ indicates that “the whole gap between the settlements should be designated as green gap”. It must not depend on “landscape features” or “inter-visibility of settlements”, but these are the very reasons that SLDC state as to why site R170M can be built-on.
Site R170M is still currently a Green Gap site and by definition has more protection than all Greenfields.
A Government Inspector’s words made the white land (now site R170M) into Green Gap and must not be ignored. Therefore to include site R170M in the LA DPD until all the more suitable Greenfield sites have been built-on is UNSOUND.
This R170M Green Gap is also land of most value to the existing community as backed up by this statement in ‘The Taylor Review’ (Page 58):
“20. Government policy is to increase the density of new housing as a means to maximising land use and better support local services. New extensions to settlements therefore may be relatively densely designed and built right up against the existing settlement to minimise the number of green fields ‘swallowed up’. However, this will mean they are built on exactly the land of most value to the existing community – the fields or woods at the ends of their gardens, the green edge to the town. Local residents against new development may be accused of ignoring the needs of others for housing, but they have a genuine point. They may not have bought the right to their countryside views, but they certainly have paid for them, and these developments are on exactly the fields of most landscape value to existing residents."
Taylor gives a valid reason why local people should not be labelled with the scorning name NIMBYs’ when they have a good reason and evidence to oppose development in their neighbourhood.
The evidence above shows that the proposed LA DPD numbers for dwellings to be built are UNDELIVERABLE before 2025. If the numbers were reduced to ones that were deliverable and sound there would be no reason to include the peripheral site R170M in the last phase (2022-25) of the LA DPD, since it is a Green Gap and hence has a higher protection than any of the proposed Greenfield sites. Note at this point in time site R170M is still part of a Green Gap.
“The Community Infrastructure Levy is a new levy that local authorities in England and Wales can choose to charge on new developments in their area. The money can be used to support development by funding infrastructure that the council, local community and neighbourhoods.”
(see http://www.communities.gov.uk/planningandbuilding/planningsystem/communityinfrastructurelevy/ )
There is absolutely no evidence in the LA DPD about how much funding SLDC are capable of obtaining from developers from the levy. Their track record in the past has been very poor when negotiating for affordable dwelling percentages. The target over previous years has been 50% but SLDC of only achieved 28%. The target is now 35% which from past results is still just wishful thinking. SLDC are relying on this money to fund infrastructure and other projects. Until SLDC publish real evidence that the money raised from this levy is in excess (there will always be an overspend) of that required, for all the proposals in the LA DPD it is intended for, then the LA DPD is UNDELIVERABLE and UNSOUND.
With the excessive financial demands that will inevitably be placed on each development in terms of school places, direct highway consequences, a 35% affordable housing contribution etc, it seems highly likely that any contribution to an Infrastructure Levy for wider scale projects would be relatively modest and inadequate. These financial implications appear to again confirm that the proposals are UNSOUND.
Until it is certain that the required infrastructure funding will be available within the planned timescales, in order that SLDC meet their objectives on Air Quality and Junction Congestion, then the LA DPD is UNSOUND.
Site R170M will add further traffic to the streets of Kendal. Therefore site R170M must be removed from the LA DPD until the Northern Development Route has a approved construction plan and committed funding in place (see above). Also that it is shown to decrease the traffic levels in the Windermere Road corridor enough for SLDC traffic objectives are met in this area.
3.0 Further evidence in support of why Policy LA2.2 (site R170M) should be removed from the LA DPD.
3.1 Extracts from Kendal Town Council document "KTC_Response.pdf " (Apr 2011)
Page 8 Transport Improvements.
“The Assessment then looked at the impact of the various possible development sites which were then under discussion. The Assessment modelled the impact of various remedial measures that could be taken, ranging from junction improvements to the building of the Inner Relief Road. It concluded that the existing highway network plus proposed improvements would just about accommodate the forecast level of traffic, provided three sites were removed:
• Land within the Shap Road/Appleby Road corridor (Site E23/49 and Sites M8/M35/ M36)
• The Todds, west of Burneside Road (Sites R148/R170)
• Stonebank Green (Sites M39/R676/R103/R675)
There was no solution which permitted these sites to be developed within the parameters given for the Assessment (e.g. no compulsory purchase orders for major junction redevelopment).”
This supports previous evidence that the development of site R170M (The Todds) is UNSOUND
Page 9 section on “Sewer Capacity”
“In addition, United Utilities has concerns about the capacity of the Waste Water Treatment Works, located to the south of Kendal, for which process modelling needs to be carried out. This impacts all the potential development sites in the town.”
I have an email from SLDC dated 27Apr2011 which states:
“The following is based on information and advice provided by United Utilities.
1. United Utilities cannot determine the number of dwellings that will cause Kendal Wastewater Treatment Works (WwTW) to reach process capacity without conducting modelling. The threshold for when capacity is reached is determined by the design capacity of the WwTW and the population that it serves with some headroom designed in to the calculations. This headroom is not excessive as United Utilities cannot design and build for a population that is not already there or where development is not definite.
2. There are local network issues in respect of sewer capacity in the Kendal area . They are primarily centred around the Burneside area as evidenced in the Core Strategy and supporting Land Allocations Document material.
3. South Lakeland District Council does not hold or have access to data/information regarding the catchment area of the Kendal Sewerage Works.”
SLDC/UU admit that the headroom (i.e. spare capacity) is not excessive. Despite this SLDC have no results of any modelling and have not insisted that this modelling be carried out by UU. SLDC do not even know the catchment area for Kendal Sewage Works. There is nothing in the documentation on the SLDC web site to indicate that SLDC do have this information today (a year later). Therefore SLDC do not know how many dwellings can be built before Kendal Sewage Works needs a major upgrade costing many millions of pounds.
United Utilities move their funding from year to year as they see their immediate priorities change, so until they actual “sign on the dotted line” to meet certain dates then their current dates can “be taken with a pinch of salt”. As evidence to support this, the paying customers of Burneside have been waiting over 20 years to get their sewerage fixed and they still have sewage on the streets during heavy rain. So there is no guarantee that the North West Kendal problem will be fixed before 2025.
Site R170M is one of the last sites in the plan to be developed therefore until the above figures are known for the whole of the catchment area and UU & OFWAT have “signed on the dotted line” to meet their agreed dates then the site R170M is UNDELIVERABLE and the LA DPD is UNSOUND.
Page 9 section on “Hydrologic Considerations”.
“However, the mechanisms (some man-made, mostly natural) which are currently managing to keep Kendal free of floods are not well understood. Several of the sites included in the Land Allocations have a history of being badly affected by rainfall. This suggests they have a role to play in mitigating surface run-off and hence flood prevention. If this is correct, development of such sites could trigger flooding in the town - and making the sites themselves flood proof would certainly involve additional expense for developers.
Kendal Town Council believes this is an important omission from the current evidence base, and calls on SLDC to commission a full hydrology study of the area before including the affected sites in any final land allocation. Any remedial infrastructure required to allow these sites to be developed safely would need to be included in the overall infrastructure programme.
Land Allocations affected by this consideration are the lower Hallgarth sites (R169M and R170M), Appleby Road (MK35KM), Natland Beck at Kendal Parks (R107M, R150M), Stock Beck at Castle Green Road (R121M), and Stonecross (R103M), and Blind Beck (R129M)”
There is nothing in the documentation on the SLDC web site to indicate that SLDC have commissioned this study or have any results. Site R170M is mentioned in quote above and so until this study is carried out development of site R170M is UNDELIVERABLE and UNSOUND.
Page 10 Infrastructure.
“3. Sites should not be included in a Final Land Allocations document unless their impact on Kendal’s transport is understood, solutions are agreed with partners, and the impact has successfully passed a rerun of the Transport Assessment. ‘Emerging Option’ sites affected by this are indicated are indicated by an ‘X’ in the ‘Traffic’ column in the Detail by each Land Allocation site starting on page 11.”
Note site R170M has an ‘X’ in the Traffic column, so this site should be removed from the LA DPD until its impact on Kendal’s junction congestion is fully understood.
This section supports previous evidence that site R170M is UNDELIVERABLE and UNSOUND.
3.2 Extracts from Kendal Town Council doc. "KTCResponsePart2toLandAllocation.pdf" (Sep 2011)
Page 5 Doughnut Development
“Taylor contends: ...these developments undermine sustainability. They invariably encourage car use, especially if there are no services or employment within walking distance, with resulting congestion on roads into town. And without local and community facilities of their own, there is little to build social sustainability and cohesion or links between new and existing settlements as there will be little in the way of community life.
This approach to planning is also a recipe for confrontation, “developing exactly the land of most value to the existing community – the fields or woods at the ends of their gardens, the green edge to the town”
(as has been amply demonstrated in Kendal by the response to the Emerging Options consultation process).
Without change we will simply repeat the mistakes of recent decades, creating unattractive developments of housing estates encircling our rural towns and larger villages, and we will fail to stem the trend of smaller villages becoming dormitory settlements of commuters and the retired, ever less affordable for those who work within them. This is not a sustainable future for rural England.
Without strong Land Allocation policies from the Planning Authority, Kendal is heading towards an unsustainable “doughnutted” future.”
This confirms that development of the peripheral Green Gap site R170M is UNSUSTAINABLE and therefore UNSOUND.
Page 6 Recommendation for Kendal
“The Council believes the Planning Authority should follow Taylor and adopt this model in preparing its final Land Allocations policies for Kendal, as the only way in which the NPPF demand for sustainable development can be achieved in the town. It is important to note that this is not in conflict with the Core Strategy positioning of Kendal as a Principal Service Centre, or with the requirements for meeting forecast housing demand. From Taylor, the requirements for sustainable development in rural market towns is clear: it cannot be delivered by allocating isolated sites around the town; a hub and spoke model is required. Even without the NPPF’s insistence on sustainable development, there are other intrinsic advantages to the hub and spoke model for Kendal. The Council’s previous Response to Consultation highlighted the major infrastructure challenges to be overcome in the town. These become far more soluble if development proceeds on hub-by-hub basis, when the infrastructure work can be concentrated on the corresponding spokes. For example, it is far simpler to improve bus services, cycling provision, etc. if only one or two ‘spokes’ have to be addressed.
The evidence in the EHLSS shows that there are suitable sites available (the scope of the SHLAS only covered sites within existing settlement boundaries, and is of less relevance), and there are options both for completely new communities on green field sites, or for breathing new life into existing communities.”
This confirms that the “doughnut” strategy is incorrect for Kendal and should be replaced by the “hub & spoke” strategy. It also confirms that the peripheral Green Gap site R170M is unsustainable and therefore UNSOUND.
Page 10 Latest Forecasts (2011)
“The latest forecast in this series was produced in Spring 2011. It shows a drastically reduced requirement:
• only 360 dwellings across the 20 years, or
• just over 4,000 including migration, projected on the last five years’ evidence.
This suggests that a more appropriate target for the next 5-10 years would be around 200 dwellings per annum.”
This confirms the evidence given above that 200 per year is what is required and this number would be deliverable. If this number was planned then the peripheral Green Gap site R170M would not be required and being in the last phase would not be needed in this LA DPD.
This section supports previous evidence that the LA DPD is UNSUSTAINABLE and UNSOUND.
3.3 Extracts from Kendal Town Council doc. “Land Allocations Representation (2).pdf “ (Mar 2012)
Page 4 Summary
“The Council believes that the DPD is not justified because it fails the following tests of soundness:
• the LPA has failed in its duty to compare against reasonable alternatives
• key decisions are not supported by the evidence base or the evidence supports a different conclusion
• the evidence base is incomplete
The DPD is also not effective in that it is not deliverable, with key elements of the dependent infrastructure
not understood.”
This confirms the LA DPD is NOT DELIVERABLE.
Page 4
“For rural market towns, the evidence was pulled together in July 2008 by the Taylor Review9, setting out the policy framework necessary to deliver the “vision of a living, working sustainable countryside”. Taylor provided compelling evidence that “doughnut development” was the wrong approach for sustainable rural market towns, and that a “hub and spoke” model represented the best pattern for sustainability.”
The two KTC paragraphs above confirm that an alternative system must be adopted now, which will “meet the needs of future generations” of Kendal (i.e. BE SUSTAINABLE”) for the many thousands of years to come.
Page 4
“The evidence in the EHLSS indicates that suitable sites could be available (the scope of the SHLAA only covered sites within existing settlement boundaries, and is of less relevance), and there are options both for completely new communities on green field sites, or for breathing new life into existing communities.”
This confirms that a “hub & spoke” is viable.
Page 5
“The Assessment concluded that the existing highway network plus proposed improvements would just about accommodate the forecast level of traffic, provided three large sites were removed. The consultants could find no mitigation which would permit these sites to be developed within the parameters given for the Assessment (e.g. no compulsory purchase orders for major junction redevelopment.)”
This confirms that site R170M must be removed from this LA DPD because it is one of the three sites.
Page 5
“Given that this approach has differed significantly from the independent consultants’, the Council asks the Inspector to order an independent audit of this latest work by W.S.Atkins or equivalent to ensure it meets accepted professional standards of objectivity and integrity. The Council further asks the Inspector to ensure that no sites are included in the DPD which the evidence shows are not deliverable on transport grounds.”
This confirms that site R170M must be removed from this LA DPD, because it is one of the sites which “are not deliverable on transport grounds.”
Page 7
“The Council asks the Inspector to withhold approval of the DPD until there is a credible infrastructure plan showing the impact of the major sites on the overall town infrastructure, and with high level solutions identified and costed with enough detail to enable the economic deliverability of the sites to be proven.”
This adds to the evidence given above that there must be signatures, to supply the necessary infrastructure and funding, must be in place before this LA DPD is approved by the Government. Until this is done site R170M is UNDELIVERABLE and UNSOUND.
This section supports previous evidence that site R170M is UNDELIVERABLE and UNSOUND.
3.4 Extracts from SLDC document "Kendal Transport Study (Jan12).pdf ”:
Page 5 Exec Summary (see also 6.1.6 on page 18)
"10. The LDF developments have a more notable impact in the AM peak compared to the base situation. The model results indicate that the provision of sustainable transport improvements (Scheme 2) would be required to support LDF development to nil-detriment compared to the 2022 base situation in the AM peak. However, the provision of a new route along Dowker’s Lane (scheme 4) would be required if the Rugby Club development is included. If the Canal Head development is included, the proposed Kendal Northern Development Route (Scheme 5) would be required.
11. It should be noted that although these schemes are required to achieve nil-detriment, these improvements are only demonstrated to offer marginal benefits to the performance of junctions in Kendal. These infrastructure schemes would be expensive and may not be a cost-effective solution to congestion in Kendal town centre.
12. Furthermore, even with the implementation of these improvement schemes, it is important to note that a large proportion of the key junctions would continue to operate above capacity, and therefore experience congestion and extensive queuing in the 2022 base situation. This situation would be compounded by the LDF development traffic.
13. It is recommended that further modelling work is undertaken"
The Transport Study shows that the objectives cannot be achieved before 2025 therefore the problems are going to be much worse in the years 2026 onwards.
SLDC do not have signed-off solutions and timescales in place to meet the plan phases, therefore the LA DPD is UNDELIVERABLE and UNSOUND.
Page 9 This page gives the CCC/SLDC definition for Junction Congestion limits.
"Acceptable junction performance is indicated by a degree of saturation below 90 percent for signal-controlled junctions, or an RFC below 85 percent for priority junctions and roundabouts."
The Atkins report uses a Volume/Capacity ratio of 90 as acceptable for a junction approach, which is similar.
The Study shows that these objectives will not be met by 2025 so this, along with page 10 (see below) adds evidence to the above.
Page 10
"4.2.2 In total 13 junctions are indicated to have a maximum RFC greater than or equal to 90% in the 2010 base year, in either the AM or PM peak period. These are:Junction1: A5284 Stricklandgate/Sandes AvenueJunction 2: A5284 Sandes Avenue / A6 Blackhall Road signalised junction
Junction 5: A6 Longpool / Station Road mini-roundabout junction
Junction 12: A6 Highgate / Lowther Street signalised junction
Junction 22: Parkside Road / Valley Drive priority junction
Junction 16: A6 Milnthorpe Road / Romney Road signalised junction
Junction 17: A5284 Windermere Road/Queens Road
Junction 18: A5284 Windermere Road/Burneside Road
Junction 21: A65 Burton Road / Oxenholme Road signalised junction
Junction 27: A684 Sedbergh Road / Sandylands Road priority junction
Junction 29: A6 Shap Road / A685 Appleby Road (north) priority junction
Junction 30: A6 Shap Road / A685 Appleby Road (south) priority junction
Junction 31: A685 Appleby Road/Sandylands Road"
“Measures must be in place” to fix these major problems first (i.e. meet SLDC objectives). They have a huge bearing on why SLDC is still breaking the law on Air Quality.
Page 14
“* Scheme 6: Scheme 5, plus a potential Kendal Southern Link Road, which comprises a new single-carriageway road linking the A6 Milnthorpe Road with the A65 Burton Road south of Kendal town centre.”
This new road proposal has never been mentioned before; it is not in the Core Strategy and therefore, as we have been told before, it cannot be considered in this LDF.
This section supports previous evidence that site R170M is UNDELIVERABLE and UNSOUND.
3.5 Extracts from SLDC document "06 Infrastructure Position Statement.pdf ”:
Page 10
"4.19 United Utilities has a statutory duty to develop and maintain an efficient and economical system of water supply within its area. A proposal for expenditure in the years 2010 – 2015 is contained within the published five years Investment Plan (Asset Management programme). The plan can be found at the following website link: http://www.unitedutilities.com/Documents/Detailed_plan.pdf "
There is nothing in this PDF document that is specific to Kendal.
UU may have "a statutory duty to develop and maintain an efficient and economical system of water supply within its area" but it is very poor at obeying this duty as is verified by the > 20 years Burnside have been suffering sewage problems (and still are).
Until UU actually “sign on the dotted line” to meet the required planned timescales and commit funding, the LA DPD is UNDELIVERABLE and UNSOUND.
Page 11
"4.23 Funding is more likely to be acquired in cases where there is development certainty (i.e. clear evidence of developer interest).
* UU reiterate that even if a bid is submitted there is no guarantee funding will be approved by OFWAT. The speed at which approved schemes are implemented will depend on the priority given to schemes within the 5-year programme and the time required to design, obtain planning permission and construct."
This backs previous evidence, never mind “development certainty” what about the existing paying customers who are still suffering sewage and flooding problems due to lack of investment.
Until United Utilities “sign on the dotted line” and commit to planned dates and funding the LA DPD is UNDELIVERABLE and UNSOUND.
Page 11
"4.24 There is currently loading capacity at Kendal Waste water Treatment Works (WwTW), however, for the number of dwellings that are proposed a full process and hydraulic survey of the Works will have to be undertaken before UU could comfortably approve the Planning Applications. As the sewer network is at capacity in North Kendal, UU could not agree to any significant development until after 2015 in this part of the town. Providing UU obtain funding through OFWAT to undertake the necessary upgrades etc. UU will be building into the 2014 Business Submission to OFWAT a case for funding to provide the means to accommodate development, which will boost the economy.
4.25 A feasibility study is being undertaken on the Kendal WwTW. Recommended phosphorous levels are set by Environment Agency (EA) through discharge consents, and until EA impose a new requirement for a lowered rate, UU will continue to discharge at the current rate. UU stated achieving any required lower rates would depend on new/better technology. Further Phosphorous removal would only be undertaken if UU were required to achieve a tighter standard as set by the EA following their review of water quality. Newer technology, which is not currently available, would be required to achieve any standard below 1mg/l. UU has advised development in the Kendal area should be capped at 2000 properties unless a more stringent phosphorus effluent standard can be achieved.
4.26 UU has advised that sites in North Kendal should only come forward in the latter periods of the plan period when sewage network improvements are in place.
4.27 Strategically there is enough water supply to accommodate levels of new development, but there are potential risks of deterioration of water quality."
Until OFWAT “sign on the dotted line” and commit to planned dates and funding the LA DPD is UNSOUND.
Page 14
"4.45 Electricity North West Ltd manage infrastructure and distribute and transmit electricity throughout South Lakeland. The regulator determines the amount of funding, however, it is not known what the next round of funding may or may not allow for investment in improvements. Information relating to substation capacity has not been ascertained. Evidence when exploring options for the Canal Head Area of Kendal shows that the Kendal Primary substation is currently operating close to or at capacity. It is possible that significant development in Kendal would require investment for network reinforcement and that a new Primary Substation would be required although Electricity North West Ltd does not confirm this. No information has been made available stating whether this is the case. Only when the customer has firm load requirements and location details can a system study be undertaken to ascertain the scale of impact of potential new development."
What if the system study states it cannot be done or they cannot obtain the funding within the plan timescales? Electricity North West Ltd already has the number of houses proposed and their locations so they must commit to a system study and confirm that the proposed developments are deliverable. Until then the LA DPD is UNSOUND.
Page 15
"4.48 National Grid Gas Distribution own and operate the local gas distribution network in South Lakeland. The confidential nature of the process means National Grid are unable to confirm whether they are currently processing or have made any offers for connection within Cumbria."
The document states nothing about National Grid Gas Distribution having a statutory duty to develop and maintain an efficient and economical system of gas supply within its area.
The LA DPD cannot possibly be monitored correctly until all the Gas company has “signed on the dotted line” to meet the timescales required. Until then the LA DPD is UNDELIVERABLE and UNSOUND.
This Infrastructure document is only a statement; there is no indication when the Infrastructure Delivery Plan will be available to the public or any indication that the timescales can be met. The LA DPD is UNSOUND until the Infrastructure Delivery Plan and the Kendal Transport Plan are available with all milestones agreed, funding committed and both signed off by the respective utility companies. They can have the proviso that it depends on the build going ahead as planned.
3.6 Extracts from SLDC document “01 Consultation Report.pdf ”:
Page 19
“In their response the Highways Agency identified those sites it considers (if developed, due to cumulative impact with other sites) may impact upon the capacity, operation and safety of the strategic road network (SRN) (A590 and M6) within South Lakeland. As a consequence, the Agency has stated that the cumulative impact of development of sites under consideration in the following settlements (see below) may result in some impact to the SRN: Burneside, Crooklands, Endmoor, Kendal, Kirkby Lonsdale, Levens, Milnthorpe and Ulverston alongside the sites suggested for strategic employment use (in Ulverston and Kendal area).”
Note the word “may” on the second line. They either do or they don’t. After all these years of the LDF there is no excuse for this information not being available. SLDC must obtain an answer to this issue immediately and publish it. If any of the developments proposed within the LA DPD do affect the Strategic Road Network then any changes necessary must be included in the LA DPD and the Transport Plan (which must be issued before the hearings). Note the Strategic Road Network is NOT currently mentioned in the LA DPD.
Page 21
This page with reference to Burneside states:
“.....this is no guarantee that funding will be approved by OFWAT”.
Until OFWAT “sign on the dotted” line to meet the planned timescales the LA DPD is UNSOUND.
Page 21
“Additional work is needed by UU to check if cumulative impact on treatment works may raise capacity issues
SLDC must publish how many houses can be built in the Kendal catchment area before a major upgrade to the sewage works is required. Until UU know their total funding requirements the LA DPD is UNSOUND.
Page 34
KENDAL
“Many people believe development of the sites suggested would harm the landscape character of the town, worsen air quality, exacerbate current flooding problems, harm biodiversity, generate unacceptable levels of traffic congestion, and place further strains on a heavily constrained sewerage system. Some people questioned the need for additional housing believing there are enough empty properties in the town to meet current and future housing demands. A number of people stated development should be prioritised on brownfield sites and meet primarily local needs.”
“Many people including Kendal Town Council and Burneside and Natland Parish Council’s supported the concept of green gaps to protect Kendal coalescing with neighbouring settlements. However, a significant number of people and Kendal Town Council and Natland Parish Council believed the suggested emerging options would not prevent coalescence from happening. There was general widespread support for the open space designations suggested, however, many people believed the emerging options sites should also be designated open space.”
“Kendal Town Council expressed serious concerns with the overall approach being suggested for the town, believing the amounts of developments and the emerging option sites suggested would damage the landscape character of the town, and put unnecessary strain on an inadequate infrastructure system. The Town Council has suggested an alternative strategy/approach for the town this being to protect existing green space/countryside surrounding the town and to look at alternative sites adjacent to nearby settlements and possibly further afield where development would have less impact on the town’s infrastructure, air quality and its high quality landscape value.”
These three paragraphs confirm that the wishes of the majority of local people have been ignored and adds support to the evidence given above concerning Consultation and Legal Compliance.
Page 46
On this page it states “UU is currently considering lists of projects that will require major capital investment in Asset Management Plan 6 period 2015-2020.” and “UU reiterate that even if a bid is submitted there is no guarantee funding will be approved by OFWAT. The speed at which approved schemes are implemented will depend on the priority given to schemes within the 5-year programme and the time required to design, obtain planning permission and construct.”
Until United Utilities and OFWAT “sign on the dotted line” to meet the planned timescales and commit funding, the LA DPD is UNDELIVERABLE and UNSOUND.
This section supports previous evidence that site R170M is UNDELIVERABLE, UNSOUND and that consultation process was not Legally Compliant.
3.7 Extracts from SLDC document “Land Allocations DPD.pdf ” [Mar12]:
Pages 51 & 52
Item 3.6 - Key local factors influencing the location of new development in Kendal:
“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; Avoiding coalescence between Kendal, Oxenholme, Burneside and Natland and maintaining the separate identities of these settlements;
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;
Infrastructure constraints including sewage capacity at Kentrigg and Steele's Row and the implications for development in northwest Kendal.”
One of the main comments of the people who responded to the SLDC consultations and opposed them was the character and appearance of Kendal. This is imbedded in the above paragraph and has been totally ignored. The LA DPD is therefore not Legally Compliant.
The site R170M is close to Kentrigg (mentioned above) and so it is UNSOUND to include it in the LA DPD until United Utilities are fully committed (i.e. signed on the dotted line) to the LA DPD timescales.
The sentence “Minimising the impact of development on Kendal’s central traffic system, …..” is not definitive it should state “Meet and maintain SLDC’s standards and objectives with regard to Kendal’s central traffic system, …..”
Page 163 APPENDIX 4 - HOUSING TRAJECTORY
A graph on this page it shows the following numbers over the years 2003 – 2025 (22 years).
Maximum number of dwellings ever built in one year was 300 in year 2005/06 and even this did not reach the target of 400 per year.
Extrapolating from the graphs the average number of dwellings built per year for the first 8 years was 100+280+150+150+240+300+230+220 = 1670 / 8 = 209 per year. In the terms of this graph there are already an extra 1530 dwellings (109/yr on top of the 400/yr) that have built just to catch up. This compares well with the more accurate figures in section 2.1 above.
The figure of 720 per year for the three years 2022 – 2025 is just WISHFULL THINKING.
One of the questions that must be asked to confirm SOUNDNESS is “Are there realistic timescales related to the objectives”. The above numbers are clearly not realistic therefore the current LA DPD is UNSOUND.
This section supports previous evidence that site R170M is UNDELIVERABLE and UNSOUND within the timescales of this LA DPD (2025).
4.0 Changes required to the LA DPD document title “Land Allocations DPD.pdf ” [Mar12]:
4.1 During the recent SLDC consultation 98% of the local neighbourhood who responded OPPOSED the proposals for site R170M. In a door-door poll of over 400 neighbours during 2011 approximately 80% of those asked OPPOSED the proposal to build on site R170M. Of the remaining 20% most did not care one way or the other. The Localism Bill is a Con Trick (nice pun); it promises much but does not actually support what the majority of the people in the neighbourhood want.
To prove SLDC are DEMOCRATIC they must be serious about responding to the majority of the local neighbourhood’s wishes. Also the TOTAL CONCLUSIVE EVIDENCE ABOVE PROVES THAT SLDC MUST REMOVE THE PERIPHERAL GREEN GAP SITE R170M FROM THE LA DPD TO MAKE IT SOUND. THIS IS HOW THE LA DPD MUST BE CHANGED.
4.2 After many years (before year 2000) of knowing about the traffic problems in Kendal, SLDC have failed to produce a transport plan or action plan that enabled them to meet their standards and objectives for Air Quality and Junction Congestion. This must NOT be allowed to continue. Only when these standards and objectives have been PROVEN to have been met (with spare capacity for expansion) will the people believe SLDC are serious about tackling these major problems. The recent SLDC consultations show that increase in traffic was one of main reasons why 98% of the people (that responded) OPPOSE the proposals to build on sites in their area of Kendal.
Previous experience with Core Strategy has shown me that all my evidence will be ignored and that site R170M will not be removed from the LA DPD. If this is to be repeated then I would like to see the following changes to LA DPD.
There is a note on page 57 (item 3.18) of the LA DPD (policy LA2.2 site R170M) which states:
"DEVELOPMENT OF THIS SITE CANNOT TAKE PLACE UNTIL MEASURES ARE IN PLACE TO RESOLVE PRESSURE ON THE SEWERAGE NETWORK IN NORTH KENDAL."
This means existing problems will be fixed before building starts.
THIS SETS A PRECEDENT WHICH MUST CONTINUE WITH REGARD TO OTHER MAJOR PROBLEMS.
The threat to the health of people due to air pollution is of as much importance as sewage on the streets. Site R170M will add more traffic to the streets of Kendal and make air pollution worse. Therefore a note must be added to Policy LA2.2 (item 3.18) that states:
"DEVELOPMENT OF THIS SITE CANNOT TAKE PLACE UNTIL MEASURES ARE IN PLACE TO SHOW THAT THE LAW ON AIR QUALITY HAS BEEN MET IN KENDAL."
Increase in traffic, which leads to more junction congestion and a deterioration in the well-being of local people, was one of the major complaints in the recent SLDC consultations. Site R170M will add more traffic to the streets of Kendal and make junction congestion worse. Therefore a note must be added to Policy LA2.2 (item 3.18) that states:
"DEVELOPMENT OF THIS SITE CANNOT TAKE PLACE UNTIL MEASURES ARE IN PLACE TO SHOW THAT SLDC’S DEFINITION OF “ACCEPTABLE JUNCTION PERFORMANCE” HAS BEEN MET IN KENDAL."
For definition see page 9 of “Kendal Transport Study (Jan12).pdf”.
“4.1.5 An RFC or DoS of 100% indicates that an approach is operating at maximum capacity. Acceptable junction performance is indicated by a degree of saturation below 90 percent for signal-controlled junctions, or an RFC below 85 percent for priority junctions and roundabouts. Above this level, an approach is likely to begin to experience congestion as there is insufficient spare capacity to cope with fluctuations in traffic flow.”
4.3 Page 51 item 3.6:
The sentence “Minimising the impact of development on Kendal’s central traffic system, …..” is not definitive. The word “Minimising” is just not good enough to meet the people’s wishes. It must state “Meet and maintain SLDC’s standards and objectives with regard to Kendal’s central traffic system, …..”
4.4 Page 163 APPENDIX 4 - HOUSING TRAJECTORY
This Appendix 4 must be changed and other pages which quote these figures. The SLDC evidence does not support the requirement that anywhere near the 8800 dwellings can be built before 2025. The numbers in the graph are not realistic (a SOUNDNESS word), therefore NOT DELIVERABLE and UNSOUND. 720/year for last three years is just wishful thinking, it is not realistic; this graph shows that the maximum that has ever been built within the last 8 years is 300 per year for the year 2005/06. The developers will not build 750 per year because it would swamp the market and they would be left with a large number of empty houses.
There is no point in just stating on page 7 of the LA DPD that it is “the ambition to deliver 400 dwellings each year” if these numbers cannot realistically be built and sold. There is also no point in just monitoring these numbers just so a box can be ticked to say they have been monitored. The numbers must be realistic so that they can be monitored and vigorously progressed.
Kendal Town Council have stated in one of their reports [Sep2011 see above] that only around 200 dwellings per year is the number required. SLDC must discuss this issue with KTC and reduce the current total figure of 8800 to a number that can realistically be built & sold before 2025 and not one that is just WISHFULL THINKING.
4.5 There is a requirement in the Core Strategy for Brownfield land to be used for “at least 28%” of the number of dwellings built. Note the words are “at least” not it is the “ambition to use”. To be SOUND the LA DPD must indicate the amount of Brownfield land that is currently available and the targets for each area. These figures must be monitored, vigorously progressed and be made available to the public.
4.6 SLDC must discuss Kendal Town Council’s three reports in detail with the town council and members of opposition groups (e.g. Green Spaces). I would like to see the LA DPD changed to incorporate as much as possible of that which is agreed in these discussions.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
THE HEALTH AND WELL-BEING OF LOCAL PEOPLE MUST BE AT THE TOP OF SLDC's PRIORITY LIST and despite all my emails and protest at the Core Strategy hearings this has not yet been done in Kendal.
So I wish to speak face to face with the inspector and ask him personally if he will recommend in his report that notes be added to the LA DPD stating that SLDC must fix their major existing problems first and meet the SLDC/CCC definition for "Acceptable Junction Congestion" and the Law on Air Quality before allowing actual build of site R170M, which will add to these problems (see examples of notes in section 4.2 above).
A PRECEDENT has already been set by a note in Policy LA2.2 for site R170M relating to the sewerage network in North Kendal. If United Utilities have to fix their major existing problems first before building is allowed then so must SLDC, this is logical and should not need a political decision.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
910. Mr Derek Whitmore (Individual) : 17 May 2012 10:40:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - R170M-mod KENDAL NORTH OF LAUREL GARDENS
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
1.0 Consultation
1.1 SLDC did not change the proposals in-line with the citizens important wishes.
The Government Planning Advisory Service (PAS) defines the requirements for Legal Compliance in it’s document – "legal.doc” (Legal Compliance Tool from http://www.pas.gov.uk/pas/aio/85651 )
Extract from Stage 2: Plan preparation - frontloading phase (page 7):
“6. Does the consultation contribute to the development and sustainability appraisal of alternatives?”
This has not been carried out correctly, alternatives have not been seriously considered. In particular the Kendal Town Council’s excellent reports, containing good alternatives, have been ignored.
The vast majority of the oppose responses made in the SLDC consultations were noted, listed in the consultation documents and then almost totally ignored. In my view these consultations were just so that SLDC could “tick the box” for the government inspector and therefore were a waste of taxpayers money.
I have done a detailed examination of the SLDC Consultation Database and these are my findings:
On 11th August 2011 (after the closing date) there were 2986 responses from the Kendal settlement. 98% of these responses opposed the proposals in their neighbourhood. Most of those that “support in part” did not support housing. Most of the few indicating “support” were representatives of the land owner, potential builder, Kendal Futures Board or the North West Development Agency.
The main reasons for the respondents opposition was the increase in traffic that these proposed developments would cause, and the affect they would have on the landscape character of Kendal. Better alternative sites were suggested, noted and then ignored. The present proposals will not “satisfy the needs of future generations” and are therefore NOT SUSTAINABLE.
Issues raised in the consultations would have contributed greatly to the development and sustainability of alternatives but the alternatives put forward have been ignored (also see other evidence 2.3 below). Therefore the LA DPD it is not Legally Compliant.
I would like to see alternatives discussed with Kendal Town Council and the Green Spaces group. Then any changes agreed included in the LA DPD.
2.0 Alternative plan
2.1 Law must be obeyed.
Extract from Stage 2: Plan preparation - frontloading phase (legal.doc page 5):
“* developing alternatives and options and appraising them through sustainability appraisal and against evidence.”
The SLDC Air Quality reports show that SLDC have been breaking the Law on Air Quality for many years. It means that SLDC must use an alternative plan for Kendal until it is proven that the law is being obeyed (with spare capacity for proposed development). The reason the law must be proven is that action plans have not worked for at least 14 years (before 1998). In the meantime affordable houses can be built in other areas of SLDC which have low traffic.
Until an alternative plan is in position to ensure the law on Air Quality is obeyed (with spare capacity for the proposed development) the LA DPD is not Legally Compliant.
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These Legal Compliance requirements are not definitive or closed questions; they are open to personal interpretation, so I will not make any further comment in these sections.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Personal Comments:- From my experience of the Core Strategy hearings and the SLDC consultations I know my response will be ignored. The changes to Kendal’s infrastructure, that the new SLDC Transport Study (Jan12) states are required (see below), is just one example of this. I am therefore taking this opportunity to place on record all the relevant evidence I have gathered on why site R170M (policy LA2.2) should not be included in the LA DPD. Quotes from certain documents have been added to make it easier for the reader. There is repetition of some issues but this is because I have added different sources of evidence throughout the document.
It is undemocratic just to include Legal Compliance and Soundness in this consultation. In a democratic society the wishes of the majority of local people would have priority over these criteria. Also criteria such as “Justice” and “Fairness” should be considered. These were totally ignored in the Core Strategy consultation and hearings.
Test of Soundness
1.0 Not justified
1.1 Health and well-being of citizens in Kendal.
I have been informed that a developer does not have to fix an existing problem he just needs to show that he will not make it any worse. This is ridiculous, while SLDC are breaking the law on Air Quality developers must not be allowed to build on site R170M and other Kendal sites until the law is obeyed. SLDC breaking the law must surely be enough to prevent developers from winning an appeal. The people’s health and well-being must have top priority over everything else in the LA DPD.
The latest Cumbria County Council’s transport plan LPT3 does not include plans for the necessary infrastructure to fix existing problems neither does the SLDC Core Strategy. It was only after pressure from the public that SLDC & CCC produced the Transport Study (which is only a study) and after all this time the Transport Plan has not yet been made available to the public. Without a Transport Plan (including committed funding) signed off by all the participants the LA DPD is UNDELIVERABLE within the current timescales (2025) and is UNSOUND.
Before the year 2000 the SLDC objective was to meet the law on Air Quality by the year 2005 but air pollution has continually increased and the AQMA (Air Quality Management Area) has even been made larger. This shows that SLDC are not serious in meeting their objectives where the health and well-being of citizens, or obeying the law, are concerned.
A typical example is the approval of the Planning Application for the old Auction Mart site. Also planning approval is certain to go ahead for the Canal Head development. These will make the air pollution worse in the AQMA. The worst pollution occurs when junctions are grid-locked and tinkering with traffic lights will not fix this problem. It will take major infrastructure changes to fix the existing traffic problems and allow for proposed LDF expansion. The Transport Study even admits that none of the improvements schemes will meet SLDC objectives.
Extract from SLDC document "Kendal Transport Study (Jan12).pdf ”:
“6.1.6 Furthermore, even with the implementation of these improvement schemes, it is important to note that a large proportion of the key junctions would continue to operate above capacity, and therefore experience congestion and extensive queuing in the 2022 base situation. This situation would be compounded by the LDF development traffic.”
More building is planned in Kendal within the next few years (phase 1). This will make the major traffic problems worse. Infrastructure should already be in place to cope. Instead there is not even an approved Transport Plan in place, never mind the infrastructure that will be needed to meet SLDC standards and objectives.
The Transport Study is stating that further modelling is required. This shows that SLDC do not yet know at the present time if their proposals can be implemented or if funding will be available within the LDF timeframe (year 2025), therefore the LA DPD is UNSOUND. Once money has been spent on major infrastructure changes it will be expected that these changes will last for at least 15 years (through the next LDF) therefore any further modelling must use a date of 2040 or beyond. These results will prove that the Taylor “hub & spoke” must be started now (see more evidence below).
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. The health of residents of Kendal town should also cause great concern; a lot of them are elderly and frail.
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.
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 LA DPD maps for the SLDC district, have not been included on the latest maps. It is not fair that these traffic problems are not shared throughout the entire SLDC district. This is another reason why the hub & spoke system must be adopted – FAIRNESS.
The health and well-being of the people due to air pollution must have top priority over everything else in the LDF. This is not happening with the current proposals. Proving the law is being obeyed must come second on the priority list after health. If it does not already do so the “Soundness” examination must take account of these two very important issues.
The evidence above shows that these traffic problems in Kendal will not be fixed without major infrastructure changes which are not in Cumbria County Council’s LTP3.
Site R170M will add further traffic to the streets of Kendal. Therefore the LA DPD is UNSOUND and site R170M must be removed from the LA DPD until the Northern Development Route has an approved construction plan and funding (see above).
For more evidence see extracts from the SLDC Transport Study (Jan12) below.
1.2 Alternative strategy.
Although SLDC have carried out consultations they have ignored the major objections. They have even ignored the alternatives put forward by Kendal Town Council in their excellent reports - “KTC_Response.pdf ”, “KTCResponsePart2toLandAllocation.pdf ” & “Land Allocations Representation (2).pdf. ". To avoid even more “urban sprawl” of Kendal the Taylor “hub & spoke” strategy must be adopted and not the current “doughnut” strategy. Kendal will be around for many thousands of years to come, which makes the “doughnut” strategy UNSUSTAINABLE (i.e. will not satisfy the needs of future generations). Only the “hub & spoke” is sustainable in the years to come because extra “satellites” can be added. By then the proposed “doughnut” system will make Kendal such an urban sprawl that very few people will wish to live there. To prevent this happening the “hub & spoke” system must be started NOW.
Money is being put before what is best for the health and well-being of the people of Kendal now and in the future (beyond 2025).
The Taylor Report, which puts forward compelling evidence in favour of the “hub & spoke” system, shows that the proposed “doughnut” system is UNSUSTAINABLE and therefore the development of site R170 (being a peripheral Green Gap site) is UNSOUND and must be removed from the LA DPD.
2.0 Not effective
2.1 Not meeting definitions of soundness.
The Government Planning Advisory Service (PAS) defines the requirements for Soundness in the document - "soundness.doc" (Soundness Tool from: http://www.pas.gov.uk/pas/aio/85673 )
Extract from page 6 - Deliverable:
"21. Are there realistic timescales related to the objectives?
i. Sections of the development plan document which address delivery and the timescales for key developments and initiatives.
ii. Confirmation from the local strategic partnership and partner organisations that the timescales are realistic in terms of their contribution to delivery."
Extract from page 8 - Deliverable:
“28. Is it clear who is going to deliver the required infrastructure and does the timing of the provision complement the timescale of the strategy/policies?
i. Confirmation from infrastructure providers that they support the solutions proposed and the identified means and timescales for their delivery.
ii. Representations in respect of infrastructure.
iii. Reports or copies of correspondence on how representations in relation to infrastructure and its timing have been considered and dealt with.”
Extract from page 5 of SLDC document "Kendal Transport Study (Jan12).pdf ”:
Exec Summary (see also 6.1.6 on page 18)
“12. Furthermore, even with the implementation of these improvement schemes, it is important to note that a large proportion of the key junctions would continue to operate above capacity, and therefore experience congestion and extensive queuing in the 2022 base situation. This situation would be compounded by the LDF development traffic.”
I have only selected this one paragraph; there are numerous other paragraphs which support these conclusions. In particular Page 15, Item 5.2.1, Table 5.1 which confirms that all schemes fail to meet SLDC’s objective. The results in Tables 5.2 & 5.3 are even worse.
SLDC’s objective is to meet “Acceptable junction performance” which is defined on page 9, item 4.1.5.
I'm not sure why the year 2022 was chosen as base-line, whatever major infrastructure is planned must enable SLDC to meet their objectives for years beyond 2025. In my opinion until 2040, the end of the next LDF.
Schemes 4, 5 & 6 require major investment and are not in the Core Strategy and therefore must be excluded from the Transport Plan when it is published. Note that the Transport Plan should incorporate extra capacity to cope with the “doughnut” system which, if approved, will undoubtedly continue after 2025.
The SLDC Air Quality Reports show that air pollution is getting worse in Kendal and also the AQMA has been increased.
Extract from page 27 of Air Quality Report (PR_Report_Template_2010.pdf)
(see http://www.southlakeland.gov.uk/downloads/page857/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”. Over many previous years this is typical of SLDC’s attitude towards obeying the law on Air Quality. SLDC action plans have not worked in the past and this is proved by the fact that the AQMA has recently been made larger.
The SLDC document "ED43_Housing Completions 1999 to 2010.doc" plus SLDC updates show that from the beginning of plan period 2003 to end of 2011 (8 years results) the total for South Lakeland is 1690 / 8 = 211 average and of these affordable are 406 / 8 = 51 average (or 24%). Figures for 2006 to 2011 (last 5 years results) are 934 / 5 = 187 average and of these affordable are 264 / 5 = 53 average (or 28%).
Between 2003 and 2011 the number of completions was 1690. At 400 per year the objective was 3200 over this 8 year period, a difference of 1510. To make up this deficit means that over the remaining 14 years (up to 2025) an extra 1510 / 14 = 107 per year will be required. This extra number per year will get a lot higher when the build rate stays below 400 per year.
This is nowhere near the Core Strategy figure of 400 dwellings per year or the percentage affordable figure of 35% and therefore the LA DPD is UNDELIVERABLE. 200 dwellings per year would be a more realistic figure and this is the latest figure that is necessary according to a Kendal Town Council Report (see below).
SLDC have recognised this and have added the word “ambition” to build this number of houses to the LA DPD (see page 7 of the “Land Allocations DPD [Feb 12].pdf ” as an example). This word is not used in this context with regard to numbers in the Core Strategy document. Therefore the LA DPD is UNSOUND with respect to the Core Strategy. The Leader of the Council insisted the numbers in the Core Strategy were achievable within the timescales of the LDF.
The above figures show there was an inward migration of 3 (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 all the partners involved have “signed on the dotted line” that they will meet the LA DPD milestones for all the necessary infrastructure (roads, sewerage, doctors, dentists, schools, etc) that is required. With the proviso that the build will actually take place in the timescales planned. It causes unnecessary stress to local people when unachievable targets are proposed or planned.
Another issue that affects DELIVERABILITY is Brownfield sites (or previously developed land).
It states in "SLDC_Core_Strategy_Document_March2011_sm4web2.pdf " (page 17):
"CS1.2 – The Development Strategy
Priority will be given to the reuse of existing buildings and previously developed land for all new housing development, with a target of ensuring that at least 28% of new housing development takes place on such sites."
The “at least 28%” is also mentioned in CS6.6 (page 85). The 50% in item 7.14 is a mistake, it was the previous target. Now the target has been lowered, and "at least 28%" is said by SLDC to be achievable, the LA DPD must indicate the amount of Brownfield land that is currently available and the targets in each area. The Core Strategy and LA DPD have a requirement to be monitored and targets at least progressed vigorously.
The LA DPD does not mention this requirement; therefore it does not conform to the Core Strategy and is UNSOUND. Also these monitored figures need to be published and available to the public.
The SLDC Transport Report (Atkins 2009) 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." There are more similar comments on pages 60 & 71.
Site R170M feeds traffic into Windermere Road and therefore must be removed from the LA DPD until SLDC have met their objectives on Air Quality and Junction Congestion.
Extract from SLDC document "Kendal Transport Study (Jan12).pdf ” page 5 (Exec Summary):
"However, the provision of a new route along Dowker’s Lane (scheme 4) would be required if the Rugby Club development is included. If the Canal Head development is included, the proposed Kendal Northern Development Route (Scheme 5) would be required."
The Canal Head development is more important to Kendal than site R170M therefore because site R170M will add more traffic to Kendal streets it is UNSOUND to build on it. It must be removed from the LA DPD until the Northern Development Route has an approved construction plan and committed funding.
Page 115 of the document “KENDAL Appendix 1.pdf ” (Appendix 1B – Consultation Responses after October 2010) for site R170M states:
“Achieving adequate visibility will be problematic given alignment of road and limited frontage. Such a large site would require a secondary access (Cumbria County Council – Highways).”
The conclusions reached by a chartered civil engineer who has carried out measurements to Transport Standards of the proposed access to site R170M are as follows:
“There is severely restricted forward visibility on both bends in Burneside Road either side of the proposed access location.
In either scenario tested the visibility from the proposed access towards Kendal falls far short of the standard required.
A new junction cannot be safely introduced in this location.”
This report can be supplied if required.
It cannot be right not to identify this secondary access. When it is identified there will be a lot more opposition to site R170 than is currently expressed.
As I said at the beginning of this response about including “JUSTICE” and “FAIRNESS”, it is not FAIR to include a site which is likely to have “show stopping” problems without first carrying out a thorough investigation into these particular problems.
Given the evidence above, until it can be proved that both access roads can be built to meet the Transport Standards, the development of the site R170 is UNSOUND and it must be removed from the LA DPD.
The site R170M is still 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 site R170M is not removed from the LA DPD.
This is a very important reason why site R170M should not be developed – JUSTICE.
Extract from page 137 item 6.9 of the Inspector's Report on the public enquiry in 1996. Green Gap site R170M is the site mentioned below.
"Inspector's Conclusions:
6.9 The objection by Mr Downham [biased land owner] is not concerned with the provision of a green gap, but the extent of that gap. It is argued [land owner’s words] that the green gap, as shown in the Consultation draft of the Plan, follows a public footpath running between substantial hedges, a clearly defined landscape boundary: whilst the residential allocation at Sparrowmire has been reduced in the Deposit Draft, an equivalent extension to the green gap is not necessary. ^However, and most importantly in my view, the objection indicates that the "land should remain unallocated as white land so that when the Plan is reviewed in 10 years' time it can be considered as potential residential land" [land owner’s words]. I consider this underlying reason for excluding the land from the green gap identifies the very reason it should remain so designated. Structure Plan Policy 14 and the reasoned justification makes no reference to the length of time during which the vulnerable areas of countryside between settlements should be protected.^ Although policies and proposals in the Local Plan must clearly relate to the Plan period, and can be subject to review thereafter, it appears to me common sense that what is unacceptable now, will most probably be equally unacceptable at the end of the Plan period: certainly I consider the Plan should seek to engender a degree of public confidence that the separation secured will not, at some future time, be lightly squandered. ^For these reasons I believe that, where a green gap is seen as necessary, it is more important that the whole gap between the settlements should be designated as green gap than that substantial, but arbitrary landscape features should be rigidly followed. I also consider the inter-visibility of settlements is not a factor which should affect the definition of green gaps."^
I have marked with ^...^ the most important words in the above paragraph and my clarifying words are in square brackets.
The first group of sentences marked ^...^ indicates that the owner wished to leave the remaining land (now site R170M) as white land, so it can sold as high priced building land at a later date. The inspector states that this is the very reason it must remain as a Green Gap and because of this statement it is Green Gap. The LA DPD only includes Green Gap site R170M because the owner is keen to sell and make a large profit, if he didn’t it would not be included.
The second group of sentences marked ^...^ indicates that “the whole gap between the settlements should be designated as green gap”. It must not depend on “landscape features” or “inter-visibility of settlements”, but these are the very reasons that SLDC state as to why site R170M can be built-on.
Site R170M is still currently a Green Gap site and by definition has more protection than all Greenfields.
A Government Inspector’s words made the white land (now site R170M) into Green Gap and must not be ignored. Therefore to include site R170M in the LA DPD until all the more suitable Greenfield sites have been built-on is UNSOUND.
This R170M Green Gap is also land of most value to the existing community as backed up by this statement in ‘The Taylor Review’ (Page 58):
“20. Government policy is to increase the density of new housing as a means to maximising land use and better support local services. New extensions to settlements therefore may be relatively densely designed and built right up against the existing settlement to minimise the number of green fields ‘swallowed up’. However, this will mean they are built on exactly the land of most value to the existing community – the fields or woods at the ends of their gardens, the green edge to the town. Local residents against new development may be accused of ignoring the needs of others for housing, but they have a genuine point. They may not have bought the right to their countryside views, but they certainly have paid for them, and these developments are on exactly the fields of most landscape value to existing residents."
Taylor gives a valid reason why local people should not be labelled with the scorning name NIMBYs’ when they have a good reason and evidence to oppose development in their neighbourhood.
The evidence above shows that the proposed LA DPD numbers for dwellings to be built are UNDELIVERABLE before 2025. If the numbers were reduced to ones that were deliverable and sound there would be no reason to include the peripheral site R170M in the last phase (2022-25) of the LA DPD, since it is a Green Gap and hence has a higher protection than any of the proposed Greenfield sites. Note at this point in time site R170M is still part of a Green Gap.
“The Community Infrastructure Levy is a new levy that local authorities in England and Wales can choose to charge on new developments in their area. The money can be used to support development by funding infrastructure that the council, local community and neighbourhoods.”
(see http://www.communities.gov.uk/planningandbuilding/planningsystem/communityinfrastructurelevy/ )
There is absolutely no evidence in the LA DPD about how much funding SLDC are capable of obtaining from developers from the levy. Their track record in the past has been very poor when negotiating for affordable dwelling percentages. The target over previous years has been 50% but SLDC of only achieved 28%. The target is now 35% which from past results is still just wishful thinking. SLDC are relying on this money to fund infrastructure and other projects. Until SLDC publish real evidence that the money raised from this levy is in excess (there will always be an overspend) of that required, for all the proposals in the LA DPD it is intended for, then the LA DPD is UNDELIVERABLE and UNSOUND.
With the excessive financial demands that will inevitably be placed on each development in terms of school places, direct highway consequences, a 35% affordable housing contribution etc, it seems highly likely that any contribution to an Infrastructure Levy for wider scale projects would be relatively modest and inadequate. These financial implications appear to again confirm that the proposals are UNSOUND.
Until it is certain that the required infrastructure funding will be available within the planned timescales, in order that SLDC meet their objectives on Air Quality and Junction Congestion, then the LA DPD is UNSOUND.
Site R170M will add further traffic to the streets of Kendal. Therefore site R170M must be removed from the LA DPD until the Northern Development Route has a approved construction plan and committed funding in place (see above). Also that it is shown to decrease the traffic levels in the Windermere Road corridor enough for SLDC traffic objectives are met in this area.
3.0 Further evidence in support of why Policy LA2.2 (site R170M) should be removed from the LA DPD.
3.1 Extracts from Kendal Town Council document "KTC_Response.pdf " (Apr 2011)
Page 8 Transport Improvements.
“The Assessment then looked at the impact of the various possible development sites which were then under discussion. The Assessment modelled the impact of various remedial measures that could be taken, ranging from junction improvements to the building of the Inner Relief Road. It concluded that the existing highway network plus proposed improvements would just about accommodate the forecast level of traffic, provided three sites were removed:
• Land within the Shap Road/Appleby Road corridor (Site E23/49 and Sites M8/M35/ M36)
• The Todds, west of Burneside Road (Sites R148/R170)
• Stonebank Green (Sites M39/R676/R103/R675)
There was no solution which permitted these sites to be developed within the parameters given for the Assessment (e.g. no compulsory purchase orders for major junction redevelopment).”
This supports previous evidence that the development of site R170M (The Todds) is UNSOUND
Page 9 section on “Sewer Capacity”
“In addition, United Utilities has concerns about the capacity of the Waste Water Treatment Works, located to the south of Kendal, for which process modelling needs to be carried out. This impacts all the potential development sites in the town.”
I have an email from SLDC dated 27Apr2011 which states:
“The following is based on information and advice provided by United Utilities.
1. United Utilities cannot determine the number of dwellings that will cause Kendal Wastewater Treatment Works (WwTW) to reach process capacity without conducting modelling. The threshold for when capacity is reached is determined by the design capacity of the WwTW and the population that it serves with some headroom designed in to the calculations. This headroom is not excessive as United Utilities cannot design and build for a population that is not already there or where development is not definite.
2. There are local network issues in respect of sewer capacity in the Kendal area . They are primarily centred around the Burneside area as evidenced in the Core Strategy and supporting Land Allocations Document material.
3. South Lakeland District Council does not hold or have access to data/information regarding the catchment area of the Kendal Sewerage Works.”
SLDC/UU admit that the headroom (i.e. spare capacity) is not excessive. Despite this SLDC have no results of any modelling and have not insisted that this modelling be carried out by UU. SLDC do not even know the catchment area for Kendal Sewage Works. There is nothing in the documentation on the SLDC web site to indicate that SLDC do have this information today (a year later). Therefore SLDC do not know how many dwellings can be built before Kendal Sewage Works needs a major upgrade costing many millions of pounds.
United Utilities move their funding from year to year as they see their immediate priorities change, so until they actual “sign on the dotted line” to meet certain dates then their current dates can “be taken with a pinch of salt”. As evidence to support this, the paying customers of Burneside have been waiting over 20 years to get their sewerage fixed and they still have sewage on the streets during heavy rain. So there is no guarantee that the North West Kendal problem will be fixed before 2025.
Site R170M is one of the last sites in the plan to be developed therefore until the above figures are known for the whole of the catchment area and UU & OFWAT have “signed on the dotted line” to meet their agreed dates then the site R170M is UNDELIVERABLE and the LA DPD is UNSOUND.
Page 9 section on “Hydrologic Considerations”.
“However, the mechanisms (some man-made, mostly natural) which are currently managing to keep Kendal free of floods are not well understood. Several of the sites included in the Land Allocations have a history of being badly affected by rainfall. This suggests they have a role to play in mitigating surface run-off and hence flood prevention. If this is correct, development of such sites could trigger flooding in the town - and making the sites themselves flood proof would certainly involve additional expense for developers.
Kendal Town Council believes this is an important omission from the current evidence base, and calls on SLDC to commission a full hydrology study of the area before including the affected sites in any final land allocation. Any remedial infrastructure required to allow these sites to be developed safely would need to be included in the overall infrastructure programme.
Land Allocations affected by this consideration are the lower Hallgarth sites (R169M and R170M), Appleby Road (MK35KM), Natland Beck at Kendal Parks (R107M, R150M), Stock Beck at Castle Green Road (R121M), and Stonecross (R103M), and Blind Beck (R129M)”
There is nothing in the documentation on the SLDC web site to indicate that SLDC have commissioned this study or have any results. Site R170M is mentioned in quote above and so until this study is carried out development of site R170M is UNDELIVERABLE and UNSOUND.
Page 10 Infrastructure.
“3. Sites should not be included in a Final Land Allocations document unless their impact on Kendal’s transport is understood, solutions are agreed with partners, and the impact has successfully passed a rerun of the Transport Assessment. ‘Emerging Option’ sites affected by this are indicated are indicated by an ‘X’ in the ‘Traffic’ column in the Detail by each Land Allocation site starting on page 11.”
Note site R170M has an ‘X’ in the Traffic column, so this site should be removed from the LA DPD until its impact on Kendal’s junction congestion is fully understood.
This section supports previous evidence that site R170M is UNDELIVERABLE and UNSOUND.
3.2 Extracts from Kendal Town Council doc. "KTCResponsePart2toLandAllocation.pdf" (Sep 2011)
Page 5 Doughnut Development
“Taylor contends: ...these developments undermine sustainability. They invariably encourage car use, especially if there are no services or employment within walking distance, with resulting congestion on roads into town. And without local and community facilities of their own, there is little to build social sustainability and cohesion or links between new and existing settlements as there will be little in the way of community life.
This approach to planning is also a recipe for confrontation, “developing exactly the land of most value to the existing community – the fields or woods at the ends of their gardens, the green edge to the town”
(as has been amply demonstrated in Kendal by the response to the Emerging Options consultation process).
Without change we will simply repeat the mistakes of recent decades, creating unattractive developments of housing estates encircling our rural towns and larger villages, and we will fail to stem the trend of smaller villages becoming dormitory settlements of commuters and the retired, ever less affordable for those who work within them. This is not a sustainable future for rural England.
Without strong Land Allocation policies from the Planning Authority, Kendal is heading towards an unsustainable “doughnutted” future.”
This confirms that development of the peripheral Green Gap site R170M is UNSUSTAINABLE and therefore UNSOUND.
Page 6 Recommendation for Kendal
“The Council believes the Planning Authority should follow Taylor and adopt this model in preparing its final Land Allocations policies for Kendal, as the only way in which the NPPF demand for sustainable development can be achieved in the town. It is important to note that this is not in conflict with the Core Strategy positioning of Kendal as a Principal Service Centre, or with the requirements for meeting forecast housing demand. From Taylor, the requirements for sustainable development in rural market towns is clear: it cannot be delivered by allocating isolated sites around the town; a hub and spoke model is required. Even without the NPPF’s insistence on sustainable development, there are other intrinsic advantages to the hub and spoke model for Kendal. The Council’s previous Response to Consultation highlighted the major infrastructure challenges to be overcome in the town. These become far more soluble if development proceeds on hub-by-hub basis, when the infrastructure work can be concentrated on the corresponding spokes. For example, it is far simpler to improve bus services, cycling provision, etc. if only one or two ‘spokes’ have to be addressed.
The evidence in the EHLSS shows that there are suitable sites available (the scope of the SHLAS only covered sites within existing settlement boundaries, and is of less relevance), and there are options both for completely new communities on green field sites, or for breathing new life into existing communities.”
This confirms that the “doughnut” strategy is incorrect for Kendal and should be replaced by the “hub & spoke” strategy. It also confirms that the peripheral Green Gap site R170M is unsustainable and therefore UNSOUND.
Page 10 Latest Forecasts (2011)
“The latest forecast in this series was produced in Spring 2011. It shows a drastically reduced requirement:
• only 360 dwellings across the 20 years, or
• just over 4,000 including migration, projected on the last five years’ evidence.
This suggests that a more appropriate target for the next 5-10 years would be around 200 dwellings per annum.”
This confirms the evidence given above that 200 per year is what is required and this number would be deliverable. If this number was planned then the peripheral Green Gap site R170M would not be required and being in the last phase would not be needed in this LA DPD.
This section supports previous evidence that the LA DPD is UNSUSTAINABLE and UNSOUND.
3.3 Extracts from Kendal Town Council doc. “Land Allocations Representation (2).pdf “ (Mar 2012)
Page 4 Summary
“The Council believes that the DPD is not justified because it fails the following tests of soundness:
• the LPA has failed in its duty to compare against reasonable alternatives
• key decisions are not supported by the evidence base or the evidence supports a different conclusion
• the evidence base is incomplete
The DPD is also not effective in that it is not deliverable, with key elements of the dependent infrastructure
not understood.”
This confirms the LA DPD is NOT DELIVERABLE.
Page 4
“For rural market towns, the evidence was pulled together in July 2008 by the Taylor Review9, setting out the policy framework necessary to deliver the “vision of a living, working sustainable countryside”. Taylor provided compelling evidence that “doughnut development” was the wrong approach for sustainable rural market towns, and that a “hub and spoke” model represented the best pattern for sustainability.”
The two KTC paragraphs above confirm that an alternative system must be adopted now, which will “meet the needs of future generations” of Kendal (i.e. BE SUSTAINABLE”) for the many thousands of years to come.
Page 4
“The evidence in the EHLSS indicates that suitable sites could be available (the scope of the SHLAA only covered sites within existing settlement boundaries, and is of less relevance), and there are options both for completely new communities on green field sites, or for breathing new life into existing communities.”
This confirms that a “hub & spoke” is viable.
Page 5
“The Assessment concluded that the existing highway network plus proposed improvements would just about accommodate the forecast level of traffic, provided three large sites were removed. The consultants could find no mitigation which would permit these sites to be developed within the parameters given for the Assessment (e.g. no compulsory purchase orders for major junction redevelopment.)”
This confirms that site R170M must be removed from this LA DPD because it is one of the three sites.
Page 5
“Given that this approach has differed significantly from the independent consultants’, the Council asks the Inspector to order an independent audit of this latest work by W.S.Atkins or equivalent to ensure it meets accepted professional standards of objectivity and integrity. The Council further asks the Inspector to ensure that no sites are included in the DPD which the evidence shows are not deliverable on transport grounds.”
This confirms that site R170M must be removed from this LA DPD, because it is one of the sites which “are not deliverable on transport grounds.”
Page 7
“The Council asks the Inspector to withhold approval of the DPD until there is a credible infrastructure plan showing the impact of the major sites on the overall town infrastructure, and with high level solutions identified and costed with enough detail to enable the economic deliverability of the sites to be proven.”
This adds to the evidence given above that there must be signatures, to supply the necessary infrastructure and funding, must be in place before this LA DPD is approved by the Government. Until this is done site R170M is UNDELIVERABLE and UNSOUND.
This section supports previous evidence that site R170M is UNDELIVERABLE and UNSOUND.
3.4 Extracts from SLDC document "Kendal Transport Study (Jan12).pdf ”:
Page 5 Exec Summary (see also 6.1.6 on page 18)
"10. The LDF developments have a more notable impact in the AM peak compared to the base situation. The model results indicate that the provision of sustainable transport improvements (Scheme 2) would be required to support LDF development to nil-detriment compared to the 2022 base situation in the AM peak. However, the provision of a new route along Dowker’s Lane (scheme 4) would be required if the Rugby Club development is included. If the Canal Head development is included, the proposed Kendal Northern Development Route (Scheme 5) would be required.
11. It should be noted that although these schemes are required to achieve nil-detriment, these improvements are only demonstrated to offer marginal benefits to the performance of junctions in Kendal. These infrastructure schemes would be expensive and may not be a cost-effective solution to congestion in Kendal town centre.
12. Furthermore, even with the implementation of these improvement schemes, it is important to note that a large proportion of the key junctions would continue to operate above capacity, and therefore experience congestion and extensive queuing in the 2022 base situation. This situation would be compounded by the LDF development traffic.
13. It is recommended that further modelling work is undertaken"
The Transport Study shows that the objectives cannot be achieved before 2025 therefore the problems are going to be much worse in the years 2026 onwards.
SLDC do not have signed-off solutions and timescales in place to meet the plan phases, therefore the LA DPD is UNDELIVERABLE and UNSOUND.
Page 9 This page gives the CCC/SLDC definition for Junction Congestion limits.
"Acceptable junction performance is indicated by a degree of saturation below 90 percent for signal-controlled junctions, or an RFC below 85 percent for priority junctions and roundabouts."
The Atkins report uses a Volume/Capacity ratio of 90 as acceptable for a junction approach, which is similar.
The Study shows that these objectives will not be met by 2025 so this, along with page 10 (see below) adds evidence to the above.
Page 10
"4.2.2 In total 13 junctions are indicated to have a maximum RFC greater than or equal to 90% in the 2010 base year, in either the AM or PM peak period. These are:Junction1: A5284 Stricklandgate/Sandes AvenueJunction 2: A5284 Sandes Avenue / A6 Blackhall Road signalised junction
Junction 5: A6 Longpool / Station Road mini-roundabout junction
Junction 12: A6 Highgate / Lowther Street signalised junction
Junction 22: Parkside Road / Valley Drive priority junction
Junction 16: A6 Milnthorpe Road / Romney Road signalised junction
Junction 17: A5284 Windermere Road/Queens Road
Junction 18: A5284 Windermere Road/Burneside Road
Junction 21: A65 Burton Road / Oxenholme Road signalised junction
Junction 27: A684 Sedbergh Road / Sandylands Road priority junction
Junction 29: A6 Shap Road / A685 Appleby Road (north) priority junction
Junction 30: A6 Shap Road / A685 Appleby Road (south) priority junction
Junction 31: A685 Appleby Road/Sandylands Road"
“Measures must be in place” to fix these major problems first (i.e. meet SLDC objectives). They have a huge bearing on why SLDC is still breaking the law on Air Quality.
Page 14
“* Scheme 6: Scheme 5, plus a potential Kendal Southern Link Road, which comprises a new single-carriageway road linking the A6 Milnthorpe Road with the A65 Burton Road south of Kendal town centre.”
This new road proposal has never been mentioned before; it is not in the Core Strategy and therefore, as we have been told before, it cannot be considered in this LDF.
This section supports previous evidence that site R170M is UNDELIVERABLE and UNSOUND.
3.5 Extracts from SLDC document "06 Infrastructure Position Statement.pdf ”:
Page 10
"4.19 United Utilities has a statutory duty to develop and maintain an efficient and economical system of water supply within its area. A proposal for expenditure in the years 2010 – 2015 is contained within the published five years Investment Plan (Asset Management programme). The plan can be found at the following website link: http://www.unitedutilities.com/Documents/Detailed_plan.pdf "
There is nothing in this PDF document that is specific to Kendal.
UU may have "a statutory duty to develop and maintain an efficient and economical system of water supply within its area" but it is very poor at obeying this duty as is verified by the > 20 years Burnside have been suffering sewage problems (and still are).
Until UU actually “sign on the dotted line” to meet the required planned timescales and commit funding, the LA DPD is UNDELIVERABLE and UNSOUND.
Page 11
"4.23 Funding is more likely to be acquired in cases where there is development certainty (i.e. clear evidence of developer interest).
* UU reiterate that even if a bid is submitted there is no guarantee funding will be approved by OFWAT. The speed at which approved schemes are implemented will depend on the priority given to schemes within the 5-year programme and the time required to design, obtain planning permission and construct."
This backs previous evidence, never mind “development certainty” what about the existing paying customers who are still suffering sewage and flooding problems due to lack of investment.
Until United Utilities “sign on the dotted line” and commit to planned dates and funding the LA DPD is UNDELIVERABLE and UNSOUND.
Page 11
"4.24 There is currently loading capacity at Kendal Waste water Treatment Works (WwTW), however, for the number of dwellings that are proposed a full process and hydraulic survey of the Works will have to be undertaken before UU could comfortably approve the Planning Applications. As the sewer network is at capacity in North Kendal, UU could not agree to any significant development until after 2015 in this part of the town. Providing UU obtain funding through OFWAT to undertake the necessary upgrades etc. UU will be building into the 2014 Business Submission to OFWAT a case for funding to provide the means to accommodate development, which will boost the economy.
4.25 A feasibility study is being undertaken on the Kendal WwTW. Recommended phosphorous levels are set by Environment Agency (EA) through discharge consents, and until EA impose a new requirement for a lowered rate, UU will continue to discharge at the current rate. UU stated achieving any required lower rates would depend on new/better technology. Further Phosphorous removal would only be undertaken if UU were required to achieve a tighter standard as set by the EA following their review of water quality. Newer technology, which is not currently available, would be required to achieve any standard below 1mg/l. UU has advised development in the Kendal area should be capped at 2000 properties unless a more stringent phosphorus effluent standard can be achieved.
4.26 UU has advised that sites in North Kendal should only come forward in the latter periods of the plan period when sewage network improvements are in place.
4.27 Strategically there is enough water supply to accommodate levels of new development, but there are potential risks of deterioration of water quality."
Until OFWAT “sign on the dotted line” and commit to planned dates and funding the LA DPD is UNSOUND.
Page 14
"4.45 Electricity North West Ltd manage infrastructure and distribute and transmit electricity throughout South Lakeland. The regulator determines the amount of funding, however, it is not known what the next round of funding may or may not allow for investment in improvements. Information relating to substation capacity has not been ascertained. Evidence when exploring options for the Canal Head Area of Kendal shows that the Kendal Primary substation is currently operating close to or at capacity. It is possible that significant development in Kendal would require investment for network reinforcement and that a new Primary Substation would be required although Electricity North West Ltd does not confirm this. No information has been made available stating whether this is the case. Only when the customer has firm load requirements and location details can a system study be undertaken to ascertain the scale of impact of potential new development."
What if the system study states it cannot be done or they cannot obtain the funding within the plan timescales? Electricity North West Ltd already has the number of houses proposed and their locations so they must commit to a system study and confirm that the proposed developments are deliverable. Until then the LA DPD is UNSOUND.
Page 15
"4.48 National Grid Gas Distribution own and operate the local gas distribution network in South Lakeland. The confidential nature of the process means National Grid are unable to confirm whether they are currently processing or have made any offers for connection within Cumbria."
The document states nothing about National Grid Gas Distribution having a statutory duty to develop and maintain an efficient and economical system of gas supply within its area.
The LA DPD cannot possibly be monitored correctly until all the Gas company has “signed on the dotted line” to meet the timescales required. Until then the LA DPD is UNDELIVERABLE and UNSOUND.
This Infrastructure document is only a statement; there is no indication when the Infrastructure Delivery Plan will be available to the public or any indication that the timescales can be met. The LA DPD is UNSOUND until the Infrastructure Delivery Plan and the Kendal Transport Plan are available with all milestones agreed, funding committed and both signed off by the respective utility companies. They can have the proviso that it depends on the build going ahead as planned.
3.6 Extracts from SLDC document “01 Consultation Report.pdf ”:
Page 19
“In their response the Highways Agency identified those sites it considers (if developed, due to cumulative impact with other sites) may impact upon the capacity, operation and safety of the strategic road network (SRN) (A590 and M6) within South Lakeland. As a consequence, the Agency has stated that the cumulative impact of development of sites under consideration in the following settlements (see below) may result in some impact to the SRN: Burneside, Crooklands, Endmoor, Kendal, Kirkby Lonsdale, Levens, Milnthorpe and Ulverston alongside the sites suggested for strategic employment use (in Ulverston and Kendal area).”
Note the word “may” on the second line. They either do or they don’t. After all these years of the LDF there is no excuse for this information not being available. SLDC must obtain an answer to this issue immediately and publish it. If any of the developments proposed within the LA DPD do affect the Strategic Road Network then any changes necessary must be included in the LA DPD and the Transport Plan (which must be issued before the hearings). Note the Strategic Road Network is NOT currently mentioned in the LA DPD.
Page 21
This page with reference to Burneside states:
“.....this is no guarantee that funding will be approved by OFWAT”.
Until OFWAT “sign on the dotted” line to meet the planned timescales the LA DPD is UNSOUND.
Page 21
“Additional work is needed by UU to check if cumulative impact on treatment works may raise capacity issues
SLDC must publish how many houses can be built in the Kendal catchment area before a major upgrade to the sewage works is required. Until UU know their total funding requirements the LA DPD is UNSOUND.
Page 34
KENDAL
“Many people believe development of the sites suggested would harm the landscape character of the town, worsen air quality, exacerbate current flooding problems, harm biodiversity, generate unacceptable levels of traffic congestion, and place further strains on a heavily constrained sewerage system. Some people questioned the need for additional housing believing there are enough empty properties in the town to meet current and future housing demands. A number of people stated development should be prioritised on brownfield sites and meet primarily local needs.”
“Many people including Kendal Town Council and Burneside and Natland Parish Council’s supported the concept of green gaps to protect Kendal coalescing with neighbouring settlements. However, a significant number of people and Kendal Town Council and Natland Parish Council believed the suggested emerging options would not prevent coalescence from happening. There was general widespread support for the open space designations suggested, however, many people believed the emerging options sites should also be designated open space.”
“Kendal Town Council expressed serious concerns with the overall approach being suggested for the town, believing the amounts of developments and the emerging option sites suggested would damage the landscape character of the town, and put unnecessary strain on an inadequate infrastructure system. The Town Council has suggested an alternative strategy/approach for the town this being to protect existing green space/countryside surrounding the town and to look at alternative sites adjacent to nearby settlements and possibly further afield where development would have less impact on the town’s infrastructure, air quality and its high quality landscape value.”
These three paragraphs confirm that the wishes of the majority of local people have been ignored and adds support to the evidence given above concerning Consultation and Legal Compliance.
Page 46
On this page it states “UU is currently considering lists of projects that will require major capital investment in Asset Management Plan 6 period 2015-2020.” and “UU reiterate that even if a bid is submitted there is no guarantee funding will be approved by OFWAT. The speed at which approved schemes are implemented will depend on the priority given to schemes within the 5-year programme and the time required to design, obtain planning permission and construct.”
Until United Utilities and OFWAT “sign on the dotted line” to meet the planned timescales and commit funding, the LA DPD is UNDELIVERABLE and UNSOUND.
This section supports previous evidence that site R170M is UNDELIVERABLE, UNSOUND and that consultation process was not Legally Compliant.
3.7 Extracts from SLDC document “Land Allocations DPD.pdf ” [Mar12]:
Pages 51 & 52
Item 3.6 - Key local factors influencing the location of new development in Kendal:
“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; Avoiding coalescence between Kendal, Oxenholme, Burneside and Natland and maintaining the separate identities of these settlements;
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;
Infrastructure constraints including sewage capacity at Kentrigg and Steele's Row and the implications for development in northwest Kendal.”
One of the main comments of the people who responded to the SLDC consultations and opposed them was the character and appearance of Kendal. This is imbedded in the above paragraph and has been totally ignored. The LA DPD is therefore not Legally Compliant.
The site R170M is close to Kentrigg (mentioned above) and so it is UNSOUND to include it in the LA DPD until United Utilities are fully committed (i.e. signed on the dotted line) to the LA DPD timescales.
The sentence “Minimising the impact of development on Kendal’s central traffic system, …..” is not definitive it should state “Meet and maintain SLDC’s standards and objectives with regard to Kendal’s central traffic system, …..”
Page 163 APPENDIX 4 - HOUSING TRAJECTORY
A graph on this page it shows the following numbers over the years 2003 – 2025 (22 years).
Maximum number of dwellings ever built in one year was 300 in year 2005/06 and even this did not reach the target of 400 per year.
Extrapolating from the graphs the average number of dwellings built per year for the first 8 years was 100+280+150+150+240+300+230+220 = 1670 / 8 = 209 per year. In the terms of this graph there are already an extra 1530 dwellings (109/yr on top of the 400/yr) that have built just to catch up. This compares well with the more accurate figures in section 2.1 above.
The figure of 720 per year for the three years 2022 – 2025 is just WISHFULL THINKING.
One of the questions that must be asked to confirm SOUNDNESS is “Are there realistic timescales related to the objectives”. The above numbers are clearly not realistic therefore the current LA DPD is UNSOUND.
This section supports previous evidence that site R170M is UNDELIVERABLE and UNSOUND within the timescales of this LA DPD (2025).
4.0 Changes required to the LA DPD document title “Land Allocations DPD.pdf ” [Mar12]:
4.1 During the recent SLDC consultation 98% of the local neighbourhood who responded OPPOSED the proposals for site R170M. In a door-door poll of over 400 neighbours during 2011 approximately 80% of those asked OPPOSED the proposal to build on site R170M. Of the remaining 20% most did not care one way or the other. The Localism Bill is a Con Trick (nice pun); it promises much but does not actually support what the majority of the people in the neighbourhood want.
To prove SLDC are DEMOCRATIC they must be serious about responding to the majority of the local neighbourhood’s wishes. Also the TOTAL CONCLUSIVE EVIDENCE ABOVE PROVES THAT SLDC MUST REMOVE THE PERIPHERAL GREEN GAP SITE R170M FROM THE LA DPD TO MAKE IT SOUND. THIS IS HOW THE LA DPD MUST BE CHANGED.
4.2 After many years (before year 2000) of knowing about the traffic problems in Kendal, SLDC have failed to produce a transport plan or action plan that enabled them to meet their standards and objectives for Air Quality and Junction Congestion. This must NOT be allowed to continue. Only when these standards and objectives have been PROVEN to have been met (with spare capacity for expansion) will the people believe SLDC are serious about tackling these major problems. The recent SLDC consultations show that increase in traffic was one of main reasons why 98% of the people (that responded) OPPOSE the proposals to build on sites in their area of Kendal.
Previous experience with Core Strategy has shown me that all my evidence will be ignored and that site R170M will not be removed from the LA DPD. If this is to be repeated then I would like to see the following changes to LA DPD.
There is a note on page 57 (item 3.18) of the LA DPD (policy LA2.2 site R170M) which states:
"DEVELOPMENT OF THIS SITE CANNOT TAKE PLACE UNTIL MEASURES ARE IN PLACE TO RESOLVE PRESSURE ON THE SEWERAGE NETWORK IN NORTH KENDAL."
This means existing problems will be fixed before building starts.
THIS SETS A PRECEDENT WHICH MUST CONTINUE WITH REGARD TO OTHER MAJOR PROBLEMS.
The threat to the health of people due to air pollution is of as much importance as sewage on the streets. Site R170M will add more traffic to the streets of Kendal and make air pollution worse. Therefore a note must be added to Policy LA2.2 (item 3.18) that states:
"DEVELOPMENT OF THIS SITE CANNOT TAKE PLACE UNTIL MEASURES ARE IN PLACE TO SHOW THAT THE LAW ON AIR QUALITY HAS BEEN MET IN KENDAL."
Increase in traffic, which leads to more junction congestion and a deterioration in the well-being of local people, was one of the major complaints in the recent SLDC consultations. Site R170M will add more traffic to the streets of Kendal and make junction congestion worse. Therefore a note must be added to Policy LA2.2 (item 3.18) that states:
"DEVELOPMENT OF THIS SITE CANNOT TAKE PLACE UNTIL MEASURES ARE IN PLACE TO SHOW THAT SLDC’S DEFINITION OF “ACCEPTABLE JUNCTION PERFORMANCE” HAS BEEN MET IN KENDAL."
For definition see page 9 of “Kendal Transport Study (Jan12).pdf”.
“4.1.5 An RFC or DoS of 100% indicates that an approach is operating at maximum capacity. Acceptable junction performance is indicated by a degree of saturation below 90 percent for signal-controlled junctions, or an RFC below 85 percent for priority junctions and roundabouts. Above this level, an approach is likely to begin to experience congestion as there is insufficient spare capacity to cope with fluctuations in traffic flow.”
4.3 Page 51 item 3.6:
The sentence “Minimising the impact of development on Kendal’s central traffic system, …..” is not definitive. The word “Minimising” is just not good enough to meet the people’s wishes. It must state “Meet and maintain SLDC’s standards and objectives with regard to Kendal’s central traffic system, …..”
4.4 Page 163 APPENDIX 4 - HOUSING TRAJECTORY
This Appendix 4 must be changed and other pages which quote these figures. The SLDC evidence does not support the requirement that anywhere near the 8800 dwellings can be built before 2025. The numbers in the graph are not realistic (a SOUNDNESS word), therefore NOT DELIVERABLE and UNSOUND. 720/year for last three years is just wishful thinking, it is not realistic; this graph shows that the maximum that has ever been built within the last 8 years is 300 per year for the year 2005/06. The developers will not build 750 per year because it would swamp the market and they would be left with a large number of empty houses.
There is no point in just stating on page 7 of the LA DPD that it is “the ambition to deliver 400 dwellings each year” if these numbers cannot realistically be built and sold. There is also no point in just monitoring these numbers just so a box can be ticked to say they have been monitored. The numbers must be realistic so that they can be monitored and vigorously progressed.
Kendal Town Council have stated in one of their reports [Sep2011 see above] that only around 200 dwellings per year is the number required. SLDC must discuss this issue with KTC and reduce the current total figure of 8800 to a number that can realistically be built & sold before 2025 and not one that is just WISHFULL THINKING.
4.5 There is a requirement in the Core Strategy for Brownfield land to be used for “at least 28%” of the number of dwellings built. Note the words are “at least” not it is the “ambition to use”. To be SOUND the LA DPD must indicate the amount of Brownfield land that is currently available and the targets for each area. These figures must be monitored, vigorously progressed and be made available to the public.
4.6 SLDC must discuss Kendal Town Council’s three reports in detail with the town council and members of opposition groups (e.g. Green Spaces). I would like to see the LA DPD changed to incorporate as much as possible of that which is agreed in these discussions
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
THE HEALTH AND WELL-BEING OF LOCAL PEOPLE MUST BE AT THE TOP OF SLDC's PRIORITY LIST and despite all my emails and protest at the Core Strategy hearings this has not yet been done in Kendal.
So I wish to speak face to face with the inspector and ask him personally if he will recommend in his report that notes be added to the LA DPD stating that SLDC must fix their major existing problems first and meet the SLDC/CCC definition for "Acceptable Junction Congestion" and the Law on Air Quality before allowing actual build of site R170M, which will add to these problems (see examples of notes in section 4.2 above).
A PRECEDENT has already been set by a note in Policy LA2.2 for site R170M relating to the sewerage network in North Kendal. If United Utilities have to fix their major existing problems first before building is allowed then so must SLDC, this is logical and should not need a political decision.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
911. Mr Derek Whitmore (Individual) : 17 May 2012 10:45:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - All Kendal sites
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
1.0 Consultation
1.1 SLDC did not change the proposals in-line with the citizens important wishes.
The Government Planning Advisory Service (PAS) defines the requirements for Legal Compliance in it’s document – "legal.doc” (Legal Compliance Tool from http://www.pas.gov.uk/pas/aio/85651 )
Extract from Stage 2: Plan preparation - frontloading phase (page 7):
“6. Does the consultation contribute to the development and sustainability appraisal of alternatives?”
This has not been carried out correctly, alternatives have not been seriously considered. In particular the Kendal Town Council’s excellent reports, containing good alternatives, have been ignored.
The vast majority of the oppose responses made in the SLDC consultations were noted, listed in the consultation documents and then almost totally ignored. In my view these consultations were just so that SLDC could “tick the box” for the government inspector and therefore were a waste of taxpayers money.
I have done a detailed examination of the SLDC Consultation Database and these are my findings:
On 11th August 2011 (after the closing date) there were 2986 responses from the Kendal settlement. 98% of these responses opposed the proposals in their neighbourhood. Most of those that “support in part” did not support housing. Most of the few indicating “support” were representatives of the land owner, potential builder, Kendal Futures Board or the North West Development Agency.
The main reasons for the respondents opposition was the increase in traffic that these proposed developments would cause, and the affect they would have on the landscape character of Kendal. Better alternative sites were suggested, noted and then ignored. The present proposals will not “satisfy the needs of future generations” and are therefore NOT SUSTAINABLE.
Issues raised in the consultations would have contributed greatly to the development and sustainability of alternatives but the alternatives put forward have been ignored (also see other evidence 2.3 below). Therefore the LA DPD it is not Legally Compliant.
I would like to see alternatives discussed with Kendal Town Council and the Green Spaces group. Then any changes agreed included in the LA DPD.
2.0 Alternative plan
2.1 Law must be obeyed.
Extract from Stage 2: Plan preparation - frontloading phase (legal.doc page 5):
“* developing alternatives and options and appraising them through sustainability appraisal and against evidence.”
The SLDC Air Quality reports show that SLDC have been breaking the Law on Air Quality for many years. It means that SLDC must use an alternative plan for Kendal until it is proven that the law is being obeyed (with spare capacity for proposed development). The reason the law must be proven is that action plans have not worked for at least 14 years (before 1998). In the meantime affordable houses can be built in other areas of SLDC which have low traffic.
Until an alternative plan is in position to ensure the law on Air Quality is obeyed (with spare capacity for the proposed development) the LA DPD is not Legally Compliant.
-----------------------------------------------------------------------------------------------
These Legal Compliance requirements are not definitive or closed questions; they are open to personal interpretation, so I will not make any further comment in these sections.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Personal Comments:- From my experience of the Core Strategy hearings and the SLDC consultations I know my response will be ignored. The changes to Kendal’s infrastructure, that the new SLDC Transport Study (Jan12) states are required (see below), is just one example of this. I am therefore taking this opportunity to place on record all the relevant evidence I have gathered on why site R170M (policy LA2.2) should not be included in the LA DPD. Quotes from certain documents have been added to make it easier for the reader. There is repetition of some issues but this is because I have added different sources of evidence throughout the document.
It is undemocratic just to include Legal Compliance and Soundness in this consultation. In a democratic society the wishes of the majority of local people would have priority over these criteria. Also criteria such as “Justice” and “Fairness” should be considered. These were totally ignored in the Core Strategy consultation and hearings.
Test of Soundness
1.0 Not justified
1.1 Health and well-being of citizens in Kendal.
I have been informed that a developer does not have to fix an existing problem he just needs to show that he will not make it any worse. This is ridiculous, while SLDC are breaking the law on Air Quality developers must not be allowed to build on site R170M and other Kendal sites until the law is obeyed. SLDC breaking the law must surely be enough to prevent developers from winning an appeal. The people’s health and well-being must have top priority over everything else in the LA DPD.
The latest Cumbria County Council’s transport plan LPT3 does not include plans for the necessary infrastructure to fix existing problems neither does the SLDC Core Strategy. It was only after pressure from the public that SLDC & CCC produced the Transport Study (which is only a study) and after all this time the Transport Plan has not yet been made available to the public. Without a Transport Plan (including committed funding) signed off by all the participants the LA DPD is UNDELIVERABLE within the current timescales (2025) and is UNSOUND.
Before the year 2000 the SLDC objective was to meet the law on Air Quality by the year 2005 but air pollution has continually increased and the AQMA (Air Quality Management Area) has even been made larger. This shows that SLDC are not serious in meeting their objectives where the health and well-being of citizens, or obeying the law, are concerned.
A typical example is the approval of the Planning Application for the old Auction Mart site. Also planning approval is certain to go ahead for the Canal Head development. These will make the air pollution worse in the AQMA. The worst pollution occurs when junctions are grid-locked and tinkering with traffic lights will not fix this problem. It will take major infrastructure changes to fix the existing traffic problems and allow for proposed LDF expansion. The Transport Study even admits that none of the improvements schemes will meet SLDC objectives.
Extract from SLDC document "Kendal Transport Study (Jan12).pdf ”:
“6.1.6 Furthermore, even with the implementation of these improvement schemes, it is important to note that a large proportion of the key junctions would continue to operate above capacity, and therefore experience congestion and extensive queuing in the 2022 base situation. This situation would be compounded by the LDF development traffic.”
More building is planned in Kendal within the next few years (phase 1). This will make the major traffic problems worse. Infrastructure should already be in place to cope. Instead there is not even an approved Transport Plan in place, never mind the infrastructure that will be needed to meet SLDC standards and objectives.
The Transport Study is stating that further modelling is required. This shows that SLDC do not yet know at the present time if their proposals can be implemented or if funding will be available within the LDF timeframe (year 2025), therefore the LA DPD is UNSOUND. Once money has been spent on major infrastructure changes it will be expected that these changes will last for at least 15 years (through the next LDF) therefore any further modelling must use a date of 2040 or beyond. These results will prove that the Taylor “hub & spoke” must be started now (see more evidence below).
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. The health of residents of Kendal town should also cause great concern; a lot of them are elderly and frail.
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.
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 LA DPD maps for the SLDC district, have not been included on the latest maps. It is not fair that these traffic problems are not shared throughout the entire SLDC district. This is another reason why the hub & spoke system must be adopted – FAIRNESS.
The health and well-being of the people due to air pollution must have top priority over everything else in the LDF. This is not happening with the current proposals. Proving the law is being obeyed must come second on the priority list after health. If it does not already do so the “Soundness” examination must take account of these two very important issues.
The evidence above shows that these traffic problems in Kendal will not be fixed without major infrastructure changes which are not in Cumbria County Council’s LTP3.
Site R170M will add further traffic to the streets of Kendal. Therefore the LA DPD is UNSOUND and site R170M must be removed from the LA DPD until the Northern Development Route has an approved construction plan and funding (see above).
For more evidence see extracts from the SLDC Transport Study (Jan12) below.
1.2 Alternative strategy.
Although SLDC have carried out consultations they have ignored the major objections. They have even ignored the alternatives put forward by Kendal Town Council in their excellent reports - “KTC_Response.pdf ”, “KTCResponsePart2toLandAllocation.pdf ” & “Land Allocations Representation (2).pdf. ". To avoid even more “urban sprawl” of Kendal the Taylor “hub & spoke” strategy must be adopted and not the current “doughnut” strategy. Kendal will be around for many thousands of years to come, which makes the “doughnut” strategy UNSUSTAINABLE (i.e. will not satisfy the needs of future generations). Only the “hub & spoke” is sustainable in the years to come because extra “satellites” can be added. By then the proposed “doughnut” system will make Kendal such an urban sprawl that very few people will wish to live there. To prevent this happening the “hub & spoke” system must be started NOW.
Money is being put before what is best for the health and well-being of the people of Kendal now and in the future (beyond 2025).
The Taylor Report, which puts forward compelling evidence in favour of the “hub & spoke” system, shows that the proposed “doughnut” system is UNSUSTAINABLE and therefore the development of site R170 (being a peripheral Green Gap site) is UNSOUND and must be removed from the LA DPD.
2.0 Not effective
2.1 Not meeting definitions of soundness.
The Government Planning Advisory Service (PAS) defines the requirements for Soundness in the document - "soundness.doc" (Soundness Tool from: http://www.pas.gov.uk/pas/aio/85673 )
Extract from page 6 - Deliverable:
"21. Are there realistic timescales related to the objectives?
i. Sections of the development plan document which address delivery and the timescales for key developments and initiatives.
ii. Confirmation from the local strategic partnership and partner organisations that the timescales are realistic in terms of their contribution to delivery."
Extract from page 8 - Deliverable:
“28. Is it clear who is going to deliver the required infrastructure and does the timing of the provision complement the timescale of the strategy/policies?
i. Confirmation from infrastructure providers that they support the solutions proposed and the identified means and timescales for their delivery.
ii. Representations in respect of infrastructure.
iii. Reports or copies of correspondence on how representations in relation to infrastructure and its timing have been considered and dealt with.”
Extract from page 5 of SLDC document "Kendal Transport Study (Jan12).pdf ”:
Exec Summary (see also 6.1.6 on page 18)
“12. Furthermore, even with the implementation of these improvement schemes, it is important to note that a large proportion of the key junctions would continue to operate above capacity, and therefore experience congestion and extensive queuing in the 2022 base situation. This situation would be compounded by the LDF development traffic.”
I have only selected this one paragraph; there are numerous other paragraphs which support these conclusions. In particular Page 15, Item 5.2.1, Table 5.1 which confirms that all schemes fail to meet SLDC’s objective. The results in Tables 5.2 & 5.3 are even worse.
SLDC’s objective is to meet “Acceptable junction performance” which is defined on page 9, item 4.1.5.
I'm not sure why the year 2022 was chosen as base-line, whatever major infrastructure is planned must enable SLDC to meet their objectives for years beyond 2025. In my opinion until 2040, the end of the next LDF.
Schemes 4, 5 & 6 require major investment and are not in the Core Strategy and therefore must be excluded from the Transport Plan when it is published. Note that the Transport Plan should incorporate extra capacity to cope with the “doughnut” system which, if approved, will undoubtedly continue after 2025.
The SLDC Air Quality Reports show that air pollution is getting worse in Kendal and also the AQMA has been increased.
Extract from page 27 of Air Quality Report (PR_Report_Template_2010.pdf)
(see http://www.southlakeland.gov.uk/downloads/page857/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”. Over many previous years this is typical of SLDC’s attitude towards obeying the law on Air Quality. SLDC action plans have not worked in the past and this is proved by the fact that the AQMA has recently been made larger.
The SLDC document "ED43_Housing Completions 1999 to 2010.doc" plus SLDC updates show that from the beginning of plan period 2003 to end of 2011 (8 years results) the total for South Lakeland is 1690 / 8 = 211 average and of these affordable are 406 / 8 = 51 average (or 24%). Figures for 2006 to 2011 (last 5 years results) are 934 / 5 = 187 average and of these affordable are 264 / 5 = 53 average (or 28%).
Between 2003 and 2011 the number of completions was 1690. At 400 per year the objective was 3200 over this 8 year period, a difference of 1510. To make up this deficit means that over the remaining 14 years (up to 2025) an extra 1510 / 14 = 107 per year will be required. This extra number per year will get a lot higher when the build rate stays below 400 per year.
This is nowhere near the Core Strategy figure of 400 dwellings per year or the percentage affordable figure of 35% and therefore the LA DPD is UNDELIVERABLE. 200 dwellings per year would be a more realistic figure and this is the latest figure that is necessary according to a Kendal Town Council Report (see below).
SLDC have recognised this and have added the word “ambition” to build this number of houses to the LA DPD (see page 7 of the “Land Allocations DPD [Feb 12].pdf ” as an example). This word is not used in this context with regard to numbers in the Core Strategy document. Therefore the LA DPD is UNSOUND with respect to the Core Strategy. The Leader of the Council insisted the numbers in the Core Strategy were achievable within the timescales of the LDF.
The above figures show there was an inward migration of 3 (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 all the partners involved have “signed on the dotted line” that they will meet the LA DPD milestones for all the necessary infrastructure (roads, sewerage, doctors, dentists, schools, etc) that is required. With the proviso that the build will actually take place in the timescales planned. It causes unnecessary stress to local people when unachievable targets are proposed or planned.
Another issue that affects DELIVERABILITY is Brownfield sites (or previously developed land).
It states in "SLDC_Core_Strategy_Document_March2011_sm4web2.pdf " (page 17):
"CS1.2 – The Development Strategy
Priority will be given to the reuse of existing buildings and previously developed land for all new housing development, with a target of ensuring that at least 28% of new housing development takes place on such sites."
The “at least 28%” is also mentioned in CS6.6 (page 85). The 50% in item 7.14 is a mistake, it was the previous target. Now the target has been lowered, and "at least 28%" is said by SLDC to be achievable, the LA DPD must indicate the amount of Brownfield land that is currently available and the targets in each area. The Core Strategy and LA DPD have a requirement to be monitored and targets at least progressed vigorously.
The LA DPD does not mention this requirement; therefore it does not conform to the Core Strategy and is UNSOUND. Also these monitored figures need to be published and available to the public.
The SLDC Transport Report (Atkins 2009) 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." There are more similar comments on pages 60 & 71.
Site R170M feeds traffic into Windermere Road and therefore must be removed from the LA DPD until SLDC have met their objectives on Air Quality and Junction Congestion.
Extract from SLDC document "Kendal Transport Study (Jan12).pdf ” page 5 (Exec Summary):
"However, the provision of a new route along Dowker’s Lane (scheme 4) would be required if the Rugby Club development is included. If the Canal Head development is included, the proposed Kendal Northern Development Route (Scheme 5) would be required."
The Canal Head development is more important to Kendal than site R170M therefore because site R170M will add more traffic to Kendal streets it is UNSOUND to build on it. It must be removed from the LA DPD until the Northern Development Route has an approved construction plan and committed funding.
Page 115 of the document “KENDAL Appendix 1.pdf ” (Appendix 1B – Consultation Responses after October 2010) for site R170M states:
“Achieving adequate visibility will be problematic given alignment of road and limited frontage. Such a large site would require a secondary access (Cumbria County Council – Highways).”
The conclusions reached by a chartered civil engineer who has carried out measurements to Transport Standards of the proposed access to site R170M are as follows:
“There is severely restricted forward visibility on both bends in Burneside Road either side of the proposed access location.
In either scenario tested the visibility from the proposed access towards Kendal falls far short of the standard required.
A new junction cannot be safely introduced in this location.”
This report can be supplied if required.
It cannot be right not to identify this secondary access. When it is identified there will be a lot more opposition to site R170 than is currently expressed.
As I said at the beginning of this response about including “JUSTICE” and “FAIRNESS”, it is not FAIR to include a site which is likely to have “show stopping” problems without first carrying out a thorough investigation into these particular problems.
Given the evidence above, until it can be proved that both access roads can be built to meet the Transport Standards, the development of the site R170 is UNSOUND and it must be removed from the LA DPD.
The site R170M is still 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 site R170M is not removed from the LA DPD.
This is a very important reason why site R170M should not be developed – JUSTICE.
Extract from page 137 item 6.9 of the Inspector's Report on the public enquiry in 1996. Green Gap site R170M is the site mentioned below.
"Inspector's Conclusions:
6.9 The objection by Mr Downham [biased land owner] is not concerned with the provision of a green gap, but the extent of that gap. It is argued [land owner’s words] that the green gap, as shown in the Consultation draft of the Plan, follows a public footpath running between substantial hedges, a clearly defined landscape boundary: whilst the residential allocation at Sparrowmire has been reduced in the Deposit Draft, an equivalent extension to the green gap is not necessary. ^However, and most importantly in my view, the objection indicates that the "land should remain unallocated as white land so that when the Plan is reviewed in 10 years' time it can be considered as potential residential land" [land owner’s words]. I consider this underlying reason for excluding the land from the green gap identifies the very reason it should remain so designated. Structure Plan Policy 14 and the reasoned justification makes no reference to the length of time during which the vulnerable areas of countryside between settlements should be protected.^ Although policies and proposals in the Local Plan must clearly relate to the Plan period, and can be subject to review thereafter, it appears to me common sense that what is unacceptable now, will most probably be equally unacceptable at the end of the Plan period: certainly I consider the Plan should seek to engender a degree of public confidence that the separation secured will not, at some future time, be lightly squandered. ^For these reasons I believe that, where a green gap is seen as necessary, it is more important that the whole gap between the settlements should be designated as green gap than that substantial, but arbitrary landscape features should be rigidly followed. I also consider the inter-visibility of settlements is not a factor which should affect the definition of green gaps."^
I have marked with ^...^ the most important words in the above paragraph and my clarifying words are in square brackets.
The first group of sentences marked ^...^ indicates that the owner wished to leave the remaining land (now site R170M) as white land, so it can sold as high priced building land at a later date. The inspector states that this is the very reason it must remain as a Green Gap and because of this statement it is Green Gap. The LA DPD only includes Green Gap site R170M because the owner is keen to sell and make a large profit, if he didn’t it would not be included.
The second group of sentences marked ^...^ indicates that “the whole gap between the settlements should be designated as green gap”. It must not depend on “landscape features” or “inter-visibility of settlements”, but these are the very reasons that SLDC state as to why site R170M can be built-on.
Site R170M is still currently a Green Gap site and by definition has more protection than all Greenfields.
A Government Inspector’s words made the white land (now site R170M) into Green Gap and must not be ignored. Therefore to include site R170M in the LA DPD until all the more suitable Greenfield sites have been built-on is UNSOUND.
This R170M Green Gap is also land of most value to the existing community as backed up by this statement in ‘The Taylor Review’ (Page 58):
“20. Government policy is to increase the density of new housing as a means to maximising land use and better support local services. New extensions to settlements therefore may be relatively densely designed and built right up against the existing settlement to minimise the number of green fields ‘swallowed up’. However, this will mean they are built on exactly the land of most value to the existing community – the fields or woods at the ends of their gardens, the green edge to the town. Local residents against new development may be accused of ignoring the needs of others for housing, but they have a genuine point. They may not have bought the right to their countryside views, but they certainly have paid for them, and these developments are on exactly the fields of most landscape value to existing residents."
Taylor gives a valid reason why local people should not be labelled with the scorning name NIMBYs’ when they have a good reason and evidence to oppose development in their neighbourhood.
The evidence above shows that the proposed LA DPD numbers for dwellings to be built are UNDELIVERABLE before 2025. If the numbers were reduced to ones that were deliverable and sound there would be no reason to include the peripheral site R170M in the last phase (2022-25) of the LA DPD, since it is a Green Gap and hence has a higher protection than any of the proposed Greenfield sites. Note at this point in time site R170M is still part of a Green Gap.
“The Community Infrastructure Levy is a new levy that local authorities in England and Wales can choose to charge on new developments in their area. The money can be used to support development by funding infrastructure that the council, local community and neighbourhoods.”
(see http://www.communities.gov.uk/planningandbuilding/planningsystem/communityinfrastructurelevy/ )
There is absolutely no evidence in the LA DPD about how much funding SLDC are capable of obtaining from developers from the levy. Their track record in the past has been very poor when negotiating for affordable dwelling percentages. The target over previous years has been 50% but SLDC of only achieved 28%. The target is now 35% which from past results is still just wishful thinking. SLDC are relying on this money to fund infrastructure and other projects. Until SLDC publish real evidence that the money raised from this levy is in excess (there will always be an overspend) of that required, for all the proposals in the LA DPD it is intended for, then the LA DPD is UNDELIVERABLE and UNSOUND.
With the excessive financial demands that will inevitably be placed on each development in terms of school places, direct highway consequences, a 35% affordable housing contribution etc, it seems highly likely that any contribution to an Infrastructure Levy for wider scale projects would be relatively modest and inadequate. These financial implications appear to again confirm that the proposals are UNSOUND.
Until it is certain that the required infrastructure funding will be available within the planned timescales, in order that SLDC meet their objectives on Air Quality and Junction Congestion, then the LA DPD is UNSOUND.
Site R170M will add further traffic to the streets of Kendal. Therefore site R170M must be removed from the LA DPD until the Northern Development Route has a approved construction plan and committed funding in place (see above). Also that it is shown to decrease the traffic levels in the Windermere Road corridor enough for SLDC traffic objectives are met in this area.
3.0 Further evidence in support of why Policy LA2.2 (site R170M) should be removed from the LA DPD.
3.1 Extracts from Kendal Town Council document "KTC_Response.pdf " (Apr 2011)
Page 8 Transport Improvements.
“The Assessment then looked at the impact of the various possible development sites which were then under discussion. The Assessment modelled the impact of various remedial measures that could be taken, ranging from junction improvements to the building of the Inner Relief Road. It concluded that the existing highway network plus proposed improvements would just about accommodate the forecast level of traffic, provided three sites were removed:
• Land within the Shap Road/Appleby Road corridor (Site E23/49 and Sites M8/M35/ M36)
• The Todds, west of Burneside Road (Sites R148/R170)
• Stonebank Green (Sites M39/R676/R103/R675)
There was no solution which permitted these sites to be developed within the parameters given for the Assessment (e.g. no compulsory purchase orders for major junction redevelopment).”
This supports previous evidence that the development of site R170M (The Todds) is UNSOUND
Page 9 section on “Sewer Capacity”
“In addition, United Utilities has concerns about the capacity of the Waste Water Treatment Works, located to the south of Kendal, for which process modelling needs to be carried out. This impacts all the potential development sites in the town.”
I have an email from SLDC dated 27Apr2011 which states:
“The following is based on information and advice provided by United Utilities.
1. United Utilities cannot determine the number of dwellings that will cause Kendal Wastewater Treatment Works (WwTW) to reach process capacity without conducting modelling. The threshold for when capacity is reached is determined by the design capacity of the WwTW and the population that it serves with some headroom designed in to the calculations. This headroom is not excessive as United Utilities cannot design and build for a population that is not already there or where development is not definite.
2. There are local network issues in respect of sewer capacity in the Kendal area . They are primarily centred around the Burneside area as evidenced in the Core Strategy and supporting Land Allocations Document material.
3. South Lakeland District Council does not hold or have access to data/information regarding the catchment area of the Kendal Sewerage Works.”
SLDC/UU admit that the headroom (i.e. spare capacity) is not excessive. Despite this SLDC have no results of any modelling and have not insisted that this modelling be carried out by UU. SLDC do not even know the catchment area for Kendal Sewage Works. There is nothing in the documentation on the SLDC web site to indicate that SLDC do have this information today (a year later). Therefore SLDC do not know how many dwellings can be built before Kendal Sewage Works needs a major upgrade costing many millions of pounds.
United Utilities move their funding from year to year as they see their immediate priorities change, so until they actual “sign on the dotted line” to meet certain dates then their current dates can “be taken with a pinch of salt”. As evidence to support this, the paying customers of Burneside have been waiting over 20 years to get their sewerage fixed and they still have sewage on the streets during heavy rain. So there is no guarantee that the North West Kendal problem will be fixed before 2025.
Site R170M is one of the last sites in the plan to be developed therefore until the above figures are known for the whole of the catchment area and UU & OFWAT have “signed on the dotted line” to meet their agreed dates then the site R170M is UNDELIVERABLE and the LA DPD is UNSOUND.
Page 9 section on “Hydrologic Considerations”.
“However, the mechanisms (some man-made, mostly natural) which are currently managing to keep Kendal free of floods are not well understood. Several of the sites included in the Land Allocations have a history of being badly affected by rainfall. This suggests they have a role to play in mitigating surface run-off and hence flood prevention. If this is correct, development of such sites could trigger flooding in the town - and making the sites themselves flood proof would certainly involve additional expense for developers.
Kendal Town Council believes this is an important omission from the current evidence base, and calls on SLDC to commission a full hydrology study of the area before including the affected sites in any final land allocation. Any remedial infrastructure required to allow these sites to be developed safely would need to be included in the overall infrastructure programme.
Land Allocations affected by this consideration are the lower Hallgarth sites (R169M and R170M), Appleby Road (MK35KM), Natland Beck at Kendal Parks (R107M, R150M), Stock Beck at Castle Green Road (R121M), and Stonecross (R103M), and Blind Beck (R129M)”
There is nothing in the documentation on the SLDC web site to indicate that SLDC have commissioned this study or have any results. Site R170M is mentioned in quote above and so until this study is carried out development of site R170M is UNDELIVERABLE and UNSOUND.
Page 10 Infrastructure.
“3. Sites should not be included in a Final Land Allocations document unless their impact on Kendal’s transport is understood, solutions are agreed with partners, and the impact has successfully passed a rerun of the Transport Assessment. ‘Emerging Option’ sites affected by this are indicated are indicated by an ‘X’ in the ‘Traffic’ column in the Detail by each Land Allocation site starting on page 11.”
Note site R170M has an ‘X’ in the Traffic column, so this site should be removed from the LA DPD until its impact on Kendal’s junction congestion is fully understood.
This section supports previous evidence that site R170M is UNDELIVERABLE and UNSOUND.
3.2 Extracts from Kendal Town Council doc. "KTCResponsePart2toLandAllocation.pdf" (Sep 2011)
Page 5 Doughnut Development
“Taylor contends: ...these developments undermine sustainability. They invariably encourage car use, especially if there are no services or employment within walking distance, with resulting congestion on roads into town. And without local and community facilities of their own, there is little to build social sustainability and cohesion or links between new and existing settlements as there will be little in the way of community life.
This approach to planning is also a recipe for confrontation, “developing exactly the land of most value to the existing community – the fields or woods at the ends of their gardens, the green edge to the town”
(as has been amply demonstrated in Kendal by the response to the Emerging Options consultation process).
Without change we will simply repeat the mistakes of recent decades, creating unattractive developments of housing estates encircling our rural towns and larger villages, and we will fail to stem the trend of smaller villages becoming dormitory settlements of commuters and the retired, ever less affordable for those who work within them. This is not a sustainable future for rural England.
Without strong Land Allocation policies from the Planning Authority, Kendal is heading towards an unsustainable “doughnutted” future.”
This confirms that development of the peripheral Green Gap site R170M is UNSUSTAINABLE and therefore UNSOUND.
Page 6 Recommendation for Kendal
“The Council believes the Planning Authority should follow Taylor and adopt this model in preparing its final Land Allocations policies for Kendal, as the only way in which the NPPF demand for sustainable development can be achieved in the town. It is important to note that this is not in conflict with the Core Strategy positioning of Kendal as a Principal Service Centre, or with the requirements for meeting forecast housing demand. From Taylor, the requirements for sustainable development in rural market towns is clear: it cannot be delivered by allocating isolated sites around the town; a hub and spoke model is required. Even without the NPPF’s insistence on sustainable development, there are other intrinsic advantages to the hub and spoke model for Kendal. The Council’s previous Response to Consultation highlighted the major infrastructure challenges to be overcome in the town. These become far more soluble if development proceeds on hub-by-hub basis, when the infrastructure work can be concentrated on the corresponding spokes. For example, it is far simpler to improve bus services, cycling provision, etc. if only one or two ‘spokes’ have to be addressed.
The evidence in the EHLSS shows that there are suitable sites available (the scope of the SHLAS only covered sites within existing settlement boundaries, and is of less relevance), and there are options both for completely new communities on green field sites, or for breathing new life into existing communities.”
This confirms that the “doughnut” strategy is incorrect for Kendal and should be replaced by the “hub & spoke” strategy. It also confirms that the peripheral Green Gap site R170M is unsustainable and therefore UNSOUND.
Page 10 Latest Forecasts (2011)
“The latest forecast in this series was produced in Spring 2011. It shows a drastically reduced requirement:
• only 360 dwellings across the 20 years, or
• just over 4,000 including migration, projected on the last five years’ evidence.
This suggests that a more appropriate target for the next 5-10 years would be around 200 dwellings per annum.”
This confirms the evidence given above that 200 per year is what is required and this number would be deliverable. If this number was planned then the peripheral Green Gap site R170M would not be required and being in the last phase would not be needed in this LA DPD.
This section supports previous evidence that the LA DPD is UNSUSTAINABLE and UNSOUND.
3.3 Extracts from Kendal Town Council doc. “Land Allocations Representation (2).pdf “ (Mar 2012)
Page 4 Summary
“The Council believes that the DPD is not justified because it fails the following tests of soundness:
• the LPA has failed in its duty to compare against reasonable alternatives
• key decisions are not supported by the evidence base or the evidence supports a different conclusion
• the evidence base is incomplete
The DPD is also not effective in that it is not deliverable, with key elements of the dependent infrastructure
not understood.”
This confirms the LA DPD is NOT DELIVERABLE.
Page 4
“For rural market towns, the evidence was pulled together in July 2008 by the Taylor Review9, setting out the policy framework necessary to deliver the “vision of a living, working sustainable countryside”. Taylor provided compelling evidence that “doughnut development” was the wrong approach for sustainable rural market towns, and that a “hub and spoke” model represented the best pattern for sustainability.”
The two KTC paragraphs above confirm that an alternative system must be adopted now, which will “meet the needs of future generations” of Kendal (i.e. BE SUSTAINABLE”) for the many thousands of years to come.
Page 4
“The evidence in the EHLSS indicates that suitable sites could be available (the scope of the SHLAA only covered sites within existing settlement boundaries, and is of less relevance), and there are options both for completely new communities on green field sites, or for breathing new life into existing communities.”
This confirms that a “hub & spoke” is viable.
Page 5
“The Assessment concluded that the existing highway network plus proposed improvements would just about accommodate the forecast level of traffic, provided three large sites were removed. The consultants could find no mitigation which would permit these sites to be developed within the parameters given for the Assessment (e.g. no compulsory purchase orders for major junction redevelopment.)”
This confirms that site R170M must be removed from this LA DPD because it is one of the three sites.
Page 5
“Given that this approach has differed significantly from the independent consultants’, the Council asks the Inspector to order an independent audit of this latest work by W.S.Atkins or equivalent to ensure it meets accepted professional standards of objectivity and integrity. The Council further asks the Inspector to ensure that no sites are included in the DPD which the evidence shows are not deliverable on transport grounds.”
This confirms that site R170M must be removed from this LA DPD, because it is one of the sites which “are not deliverable on transport grounds.”
Page 7
“The Council asks the Inspector to withhold approval of the DPD until there is a credible infrastructure plan showing the impact of the major sites on the overall town infrastructure, and with high level solutions identified and costed with enough detail to enable the economic deliverability of the sites to be proven.”
This adds to the evidence given above that there must be signatures, to supply the necessary infrastructure and funding, must be in place before this LA DPD is approved by the Government. Until this is done site R170M is UNDELIVERABLE and UNSOUND.
This section supports previous evidence that site R170M is UNDELIVERABLE and UNSOUND.
3.4 Extracts from SLDC document "Kendal Transport Study (Jan12).pdf ”:
Page 5 Exec Summary (see also 6.1.6 on page 18)
"10. The LDF developments have a more notable impact in the AM peak compared to the base situation. The model results indicate that the provision of sustainable transport improvements (Scheme 2) would be required to support LDF development to nil-detriment compared to the 2022 base situation in the AM peak. However, the provision of a new route along Dowker’s Lane (scheme 4) would be required if the Rugby Club development is included. If the Canal Head development is included, the proposed Kendal Northern Development Route (Scheme 5) would be required.
11. It should be noted that although these schemes are required to achieve nil-detriment, these improvements are only demonstrated to offer marginal benefits to the performance of junctions in Kendal. These infrastructure schemes would be expensive and may not be a cost-effective solution to congestion in Kendal town centre.
12. Furthermore, even with the implementation of these improvement schemes, it is important to note that a large proportion of the key junctions would continue to operate above capacity, and therefore experience congestion and extensive queuing in the 2022 base situation. This situation would be compounded by the LDF development traffic.
13. It is recommended that further modelling work is undertaken"
The Transport Study shows that the objectives cannot be achieved before 2025 therefore the problems are going to be much worse in the years 2026 onwards.
SLDC do not have signed-off solutions and timescales in place to meet the plan phases, therefore the LA DPD is UNDELIVERABLE and UNSOUND.
Page 9 This page gives the CCC/SLDC definition for Junction Congestion limits.
"Acceptable junction performance is indicated by a degree of saturation below 90 percent for signal-controlled junctions, or an RFC below 85 percent for priority junctions and roundabouts."
The Atkins report uses a Volume/Capacity ratio of 90 as acceptable for a junction approach, which is similar.
The Study shows that these objectives will not be met by 2025 so this, along with page 10 (see below) adds evidence to the above.
Page 10
"4.2.2 In total 13 junctions are indicated to have a maximum RFC greater than or equal to 90% in the 2010 base year, in either the AM or PM peak period. These are:Junction1: A5284 Stricklandgate/Sandes AvenueJunction 2: A5284 Sandes Avenue / A6 Blackhall Road signalised junction
Junction 5: A6 Longpool / Station Road mini-roundabout junction
Junction 12: A6 Highgate / Lowther Street signalised junction
Junction 22: Parkside Road / Valley Drive priority junction
Junction 16: A6 Milnthorpe Road / Romney Road signalised junction
Junction 17: A5284 Windermere Road/Queens Road
Junction 18: A5284 Windermere Road/Burneside Road
Junction 21: A65 Burton Road / Oxenholme Road signalised junction
Junction 27: A684 Sedbergh Road / Sandylands Road priority junction
Junction 29: A6 Shap Road / A685 Appleby Road (north) priority junction
Junction 30: A6 Shap Road / A685 Appleby Road (south) priority junction
Junction 31: A685 Appleby Road/Sandylands Road"
“Measures must be in place” to fix these major problems first (i.e. meet SLDC objectives). They have a huge bearing on why SLDC is still breaking the law on Air Quality.
Page 14
“* Scheme 6: Scheme 5, plus a potential Kendal Southern Link Road, which comprises a new single-carriageway road linking the A6 Milnthorpe Road with the A65 Burton Road south of Kendal town centre.”
This new road proposal has never been mentioned before; it is not in the Core Strategy and therefore, as we have been told before, it cannot be considered in this LDF.
This section supports previous evidence that site R170M is UNDELIVERABLE and UNSOUND.
3.5 Extracts from SLDC document "06 Infrastructure Position Statement.pdf ”:
Page 10
"4.19 United Utilities has a statutory duty to develop and maintain an efficient and economical system of water supply within its area. A proposal for expenditure in the years 2010 – 2015 is contained within the published five years Investment Plan (Asset Management programme). The plan can be found at the following website link: http://www.unitedutilities.com/Documents/Detailed_plan.pdf "
There is nothing in this PDF document that is specific to Kendal.
UU may have "a statutory duty to develop and maintain an efficient and economical system of water supply within its area" but it is very poor at obeying this duty as is verified by the > 20 years Burnside have been suffering sewage problems (and still are).
Until UU actually “sign on the dotted line” to meet the required planned timescales and commit funding, the LA DPD is UNDELIVERABLE and UNSOUND.
Page 11
"4.23 Funding is more likely to be acquired in cases where there is development certainty (i.e. clear evidence of developer interest).
* UU reiterate that even if a bid is submitted there is no guarantee funding will be approved by OFWAT. The speed at which approved schemes are implemented will depend on the priority given to schemes within the 5-year programme and the time required to design, obtain planning permission and construct."
This backs previous evidence, never mind “development certainty” what about the existing paying customers who are still suffering sewage and flooding problems due to lack of investment.
Until United Utilities “sign on the dotted line” and commit to planned dates and funding the LA DPD is UNDELIVERABLE and UNSOUND.
Page 11
"4.24 There is currently loading capacity at Kendal Waste water Treatment Works (WwTW), however, for the number of dwellings that are proposed a full process and hydraulic survey of the Works will have to be undertaken before UU could comfortably approve the Planning Applications. As the sewer network is at capacity in North Kendal, UU could not agree to any significant development until after 2015 in this part of the town. Providing UU obtain funding through OFWAT to undertake the necessary upgrades etc. UU will be building into the 2014 Business Submission to OFWAT a case for funding to provide the means to accommodate development, which will boost the economy.
4.25 A feasibility study is being undertaken on the Kendal WwTW. Recommended phosphorous levels are set by Environment Agency (EA) through discharge consents, and until EA impose a new requirement for a lowered rate, UU will continue to discharge at the current rate. UU stated achieving any required lower rates would depend on new/better technology. Further Phosphorous removal would only be undertaken if UU were required to achieve a tighter standard as set by the EA following their review of water quality. Newer technology, which is not currently available, would be required to achieve any standard below 1mg/l. UU has advised development in the Kendal area should be capped at 2000 properties unless a more stringent phosphorus effluent standard can be achieved.
4.26 UU has advised that sites in North Kendal should only come forward in the latter periods of the plan period when sewage network improvements are in place.
4.27 Strategically there is enough water supply to accommodate levels of new development, but there are potential risks of deterioration of water quality."
Until OFWAT “sign on the dotted line” and commit to planned dates and funding the LA DPD is UNSOUND.
Page 14
"4.45 Electricity North West Ltd manage infrastructure and distribute and transmit electricity throughout South Lakeland. The regulator determines the amount of funding, however, it is not known what the next round of funding may or may not allow for investment in improvements. Information relating to substation capacity has not been ascertained. Evidence when exploring options for the Canal Head Area of Kendal shows that the Kendal Primary substation is currently operating close to or at capacity. It is possible that significant development in Kendal would require investment for network reinforcement and that a new Primary Substation would be required although Electricity North West Ltd does not confirm this. No information has been made available stating whether this is the case. Only when the customer has firm load requirements and location details can a system study be undertaken to ascertain the scale of impact of potential new development."
What if the system study states it cannot be done or they cannot obtain the funding within the plan timescales? Electricity North West Ltd already has the number of houses proposed and their locations so they must commit to a system study and confirm that the proposed developments are deliverable. Until then the LA DPD is UNSOUND.
Page 15
"4.48 National Grid Gas Distribution own and operate the local gas distribution network in South Lakeland. The confidential nature of the process means National Grid are unable to confirm whether they are currently processing or have made any offers for connection within Cumbria."
The document states nothing about National Grid Gas Distribution having a statutory duty to develop and maintain an efficient and economical system of gas supply within its area.
The LA DPD cannot possibly be monitored correctly until all the Gas company has “signed on the dotted line” to meet the timescales required. Until then the LA DPD is UNDELIVERABLE and UNSOUND.
This Infrastructure document is only a statement; there is no indication when the Infrastructure Delivery Plan will be available to the public or any indication that the timescales can be met. The LA DPD is UNSOUND until the Infrastructure Delivery Plan and the Kendal Transport Plan are available with all milestones agreed, funding committed and both signed off by the respective utility companies. They can have the proviso that it depends on the build going ahead as planned.
3.6 Extracts from SLDC document “01 Consultation Report.pdf ”:
Page 19
“In their response the Highways Agency identified those sites it considers (if developed, due to cumulative impact with other sites) may impact upon the capacity, operation and safety of the strategic road network (SRN) (A590 and M6) within South Lakeland. As a consequence, the Agency has stated that the cumulative impact of development of sites under consideration in the following settlements (see below) may result in some impact to the SRN: Burneside, Crooklands, Endmoor, Kendal, Kirkby Lonsdale, Levens, Milnthorpe and Ulverston alongside the sites suggested for strategic employment use (in Ulverston and Kendal area).”
Note the word “may” on the second line. They either do or they don’t. After all these years of the LDF there is no excuse for this information not being available. SLDC must obtain an answer to this issue immediately and publish it. If any of the developments proposed within the LA DPD do affect the Strategic Road Network then any changes necessary must be included in the LA DPD and the Transport Plan (which must be issued before the hearings). Note the Strategic Road Network is NOT currently mentioned in the LA DPD.
Page 21
This page with reference to Burneside states:
“.....this is no guarantee that funding will be approved by OFWAT”.
Until OFWAT “sign on the dotted” line to meet the planned timescales the LA DPD is UNSOUND.
Page 21
“Additional work is needed by UU to check if cumulative impact on treatment works may raise capacity issues
SLDC must publish how many houses can be built in the Kendal catchment area before a major upgrade to the sewage works is required. Until UU know their total funding requirements the LA DPD is UNSOUND.
Page 34
KENDAL
“Many people believe development of the sites suggested would harm the landscape character of the town, worsen air quality, exacerbate current flooding problems, harm biodiversity, generate unacceptable levels of traffic congestion, and place further strains on a heavily constrained sewerage system. Some people questioned the need for additional housing believing there are enough empty properties in the town to meet current and future housing demands. A number of people stated development should be prioritised on brownfield sites and meet primarily local needs.”
“Many people including Kendal Town Council and Burneside and Natland Parish Council’s supported the concept of green gaps to protect Kendal coalescing with neighbouring settlements. However, a significant number of people and Kendal Town Council and Natland Parish Council believed the suggested emerging options would not prevent coalescence from happening. There was general widespread support for the open space designations suggested, however, many people believed the emerging options sites should also be designated open space.”
“Kendal Town Council expressed serious concerns with the overall approach being suggested for the town, believing the amounts of developments and the emerging option sites suggested would damage the landscape character of the town, and put unnecessary strain on an inadequate infrastructure system. The Town Council has suggested an alternative strategy/approach for the town this being to protect existing green space/countryside surrounding the town and to look at alternative sites adjacent to nearby settlements and possibly further afield where development would have less impact on the town’s infrastructure, air quality and its high quality landscape value.”
These three paragraphs confirm that the wishes of the majority of local people have been ignored and adds support to the evidence given above concerning Consultation and Legal Compliance.
Page 46
On this page it states “UU is currently considering lists of projects that will require major capital investment in Asset Management Plan 6 period 2015-2020.” and “UU reiterate that even if a bid is submitted there is no guarantee funding will be approved by OFWAT. The speed at which approved schemes are implemented will depend on the priority given to schemes within the 5-year programme and the time required to design, obtain planning permission and construct.”
Until United Utilities and OFWAT “sign on the dotted line” to meet the planned timescales and commit funding, the LA DPD is UNDELIVERABLE and UNSOUND.
This section supports previous evidence that site R170M is UNDELIVERABLE, UNSOUND and that consultation process was not Legally Compliant.
3.7 Extracts from SLDC document “Land Allocations DPD.pdf ” [Mar12]:
Pages 51 & 52
Item 3.6 - Key local factors influencing the location of new development in Kendal:
“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; Avoiding coalescence between Kendal, Oxenholme, Burneside and Natland and maintaining the separate identities of these settlements;
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;
Infrastructure constraints including sewage capacity at Kentrigg and Steele's Row and the implications for development in northwest Kendal.”
One of the main comments of the people who responded to the SLDC consultations and opposed them was the character and appearance of Kendal. This is imbedded in the above paragraph and has been totally ignored. The LA DPD is therefore not Legally Compliant.
The site R170M is close to Kentrigg (mentioned above) and so it is UNSOUND to include it in the LA DPD until United Utilities are fully committed (i.e. signed on the dotted line) to the LA DPD timescales.
The sentence “Minimising the impact of development on Kendal’s central traffic system, …..” is not definitive it should state “Meet and maintain SLDC’s standards and objectives with regard to Kendal’s central traffic system, …..”
Page 163 APPENDIX 4 - HOUSING TRAJECTORY
A graph on this page it shows the following numbers over the years 2003 – 2025 (22 years).
Maximum number of dwellings ever built in one year was 300 in year 2005/06 and even this did not reach the target of 400 per year.
Extrapolating from the graphs the average number of dwellings built per year for the first 8 years was 100+280+150+150+240+300+230+220 = 1670 / 8 = 209 per year. In the terms of this graph there are already an extra 1530 dwellings (109/yr on top of the 400/yr) that have built just to catch up. This compares well with the more accurate figures in section 2.1 above.
The figure of 720 per year for the three years 2022 – 2025 is just WISHFULL THINKING.
One of the questions that must be asked to confirm SOUNDNESS is “Are there realistic timescales related to the objectives”. The above numbers are clearly not realistic therefore the current LA DPD is UNSOUND.
This section supports previous evidence that site R170M is UNDELIVERABLE and UNSOUND within the timescales of this LA DPD (2025).
4.0 Changes required to the LA DPD document title “Land Allocations DPD.pdf ” [Mar12]:
4.1 During the recent SLDC consultation 98% of the local neighbourhood who responded OPPOSED the proposals for site R170M. In a door-door poll of over 400 neighbours during 2011 approximately 80% of those asked OPPOSED the proposal to build on site R170M. Of the remaining 20% most did not care one way or the other. The Localism Bill is a Con Trick (nice pun); it promises much but does not actually support what the majority of the people in the neighbourhood want.
To prove SLDC are DEMOCRATIC they must be serious about responding to the majority of the local neighbourhood’s wishes. Also the TOTAL CONCLUSIVE EVIDENCE ABOVE PROVES THAT SLDC MUST REMOVE THE PERIPHERAL GREEN GAP SITE R170M FROM THE LA DPD TO MAKE IT SOUND. THIS IS HOW THE LA DPD MUST BE CHANGED.
4.2 After many years (before year 2000) of knowing about the traffic problems in Kendal, SLDC have failed to produce a transport plan or action plan that enabled them to meet their standards and objectives for Air Quality and Junction Congestion. This must NOT be allowed to continue. Only when these standards and objectives have been PROVEN to have been met (with spare capacity for expansion) will the people believe SLDC are serious about tackling these major problems. The recent SLDC consultations show that increase in traffic was one of main reasons why 98% of the people (that responded) OPPOSE the proposals to build on sites in their area of Kendal.
Previous experience with Core Strategy has shown me that all my evidence will be ignored and that site R170M will not be removed from the LA DPD. If this is to be repeated then I would like to see the following changes to LA DPD.
There is a note on page 57 (item 3.18) of the LA DPD (policy LA2.2 site R170M) which states:
"DEVELOPMENT OF THIS SITE CANNOT TAKE PLACE UNTIL MEASURES ARE IN PLACE TO RESOLVE PRESSURE ON THE SEWERAGE NETWORK IN NORTH KENDAL."
This means existing problems will be fixed before building starts.
THIS SETS A PRECEDENT WHICH MUST CONTINUE WITH REGARD TO OTHER MAJOR PROBLEMS.
The threat to the health of people due to air pollution is of as much importance as sewage on the streets. Site R170M will add more traffic to the streets of Kendal and make air pollution worse. Therefore a note must be added to Policy LA2.2 (item 3.18) that states:
"DEVELOPMENT OF THIS SITE CANNOT TAKE PLACE UNTIL MEASURES ARE IN PLACE TO SHOW THAT THE LAW ON AIR QUALITY HAS BEEN MET IN KENDAL."
Increase in traffic, which leads to more junction congestion and a deterioration in the well-being of local people, was one of the major complaints in the recent SLDC consultations. Site R170M will add more traffic to the streets of Kendal and make junction congestion worse. Therefore a note must be added to Policy LA2.2 (item 3.18) that states:
"DEVELOPMENT OF THIS SITE CANNOT TAKE PLACE UNTIL MEASURES ARE IN PLACE TO SHOW THAT SLDC’S DEFINITION OF “ACCEPTABLE JUNCTION PERFORMANCE” HAS BEEN MET IN KENDAL."
For definition see page 9 of “Kendal Transport Study (Jan12).pdf”.
“4.1.5 An RFC or DoS of 100% indicates that an approach is operating at maximum capacity. Acceptable junction performance is indicated by a degree of saturation below 90 percent for signal-controlled junctions, or an RFC below 85 percent for priority junctions and roundabouts. Above this level, an approach is likely to begin to experience congestion as there is insufficient spare capacity to cope with fluctuations in traffic flow.”
4.3 Page 51 item 3.6:
The sentence “Minimising the impact of development on Kendal’s central traffic system, …..” is not definitive. The word “Minimising” is just not good enough to meet the people’s wishes. It must state “Meet and maintain SLDC’s standards and objectives with regard to Kendal’s central traffic system, …..”
4.4 Page 163 APPENDIX 4 - HOUSING TRAJECTORY
This Appendix 4 must be changed and other pages which quote these figures. The SLDC evidence does not support the requirement that anywhere near the 8800 dwellings can be built before 2025. The numbers in the graph are not realistic (a SOUNDNESS word), therefore NOT DELIVERABLE and UNSOUND. 720/year for last three years is just wishful thinking, it is not realistic; this graph shows that the maximum that has ever been built within the last 8 years is 300 per year for the year 2005/06. The developers will not build 750 per year because it would swamp the market and they would be left with a large number of empty houses.
There is no point in just stating on page 7 of the LA DPD that it is “the ambition to deliver 400 dwellings each year” if these numbers cannot realistically be built and sold. There is also no point in just monitoring these numbers just so a box can be ticked to say they have been monitored. The numbers must be realistic so that they can be monitored and vigorously progressed.
Kendal Town Council have stated in one of their reports [Sep2011 see above] that only around 200 dwellings per year is the number required. SLDC must discuss this issue with KTC and reduce the current total figure of 8800 to a number that can realistically be built & sold before 2025 and not one that is just WISHFULL THINKING.
4.5 There is a requirement in the Core Strategy for Brownfield land to be used for “at least 28%” of the number of dwellings built. Note the words are “at least” not it is the “ambition to use”. To be SOUND the LA DPD must indicate the amount of Brownfield land that is currently available and the targets for each area. These figures must be monitored, vigorously progressed and be made available to the public.
4.6 SLDC must discuss Kendal Town Council’s three reports in detail with the town council and members of opposition groups (e.g. Green Spaces). I would like to see the LA DPD changed to incorporate as much as possible of that which is agreed in these discussions.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
THE HEALTH AND WELL-BEING OF LOCAL PEOPLE MUST BE AT THE TOP OF SLDC's PRIORITY LIST and despite all my emails and protest at the Core Strategy hearings this has not yet been done in Kendal.
So I wish to speak face to face with the inspector and ask him personally if he will recommend in his report that notes be added to the LA DPD stating that SLDC must fix their major existing problems first and meet the SLDC/CCC definition for "Acceptable Junction Congestion" and the Law on Air Quality before allowing actual build of site R170M, which will add to these problems (see examples of notes in section 4.2 above).
A PRECEDENT has already been set by a note in Policy LA2.2 for site R170M relating to the sewerage network in North Kendal. If United Utilities have to fix their major existing problems first before building is allowed then so must SLDC, this is logical and should not need a political decision.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
912. Mr Derek Whitmore (Individual) : 17 May 2012 10:52:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.4 - Kendal Sites
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
1.0 Consultation
1.1 SLDC did not change the proposals in-line with the citizens important wishes.
The Government Planning Advisory Service (PAS) defines the requirements for Legal Compliance in it’s document – "legal.doc” (Legal Compliance Tool from http://www.pas.gov.uk/pas/aio/85651 )
Extract from Stage 2: Plan preparation - frontloading phase (page 7):
“6. Does the consultation contribute to the development and sustainability appraisal of alternatives?”
This has not been carried out correctly, alternatives have not been seriously considered. In particular the Kendal Town Council’s excellent reports, containing good alternatives, have been ignored.
The vast majority of the oppose responses made in the SLDC consultations were noted, listed in the consultation documents and then almost totally ignored. In my view these consultations were just so that SLDC could “tick the box” for the government inspector and therefore were a waste of taxpayers money.
I have done a detailed examination of the SLDC Consultation Database and these are my findings:
On 11th August 2011 (after the closing date) there were 2986 responses from the Kendal settlement. 98% of these responses opposed the proposals in their neighbourhood. Most of those that “support in part” did not support housing. Most of the few indicating “support” were representatives of the land owner, potential builder, Kendal Futures Board or the North West Development Agency.
The main reasons for the respondents opposition was the increase in traffic that these proposed developments would cause, and the affect they would have on the landscape character of Kendal. Better alternative sites were suggested, noted and then ignored. The present proposals will not “satisfy the needs of future generations” and are therefore NOT SUSTAINABLE.
Issues raised in the consultations would have contributed greatly to the development and sustainability of alternatives but the alternatives put forward have been ignored (also see other evidence 2.3 below). Therefore the LA DPD it is not Legally Compliant.
I would like to see alternatives discussed with Kendal Town Council and the Green Spaces group. Then any changes agreed included in the LA DPD.
2.0 Alternative plan
2.1 Law must be obeyed.
Extract from Stage 2: Plan preparation - frontloading phase (legal.doc page 5):
“* developing alternatives and options and appraising them through sustainability appraisal and against evidence.”
The SLDC Air Quality reports show that SLDC have been breaking the Law on Air Quality for many years. It means that SLDC must use an alternative plan for Kendal until it is proven that the law is being obeyed (with spare capacity for proposed development). The reason the law must be proven is that action plans have not worked for at least 14 years (before 1998). In the meantime affordable houses can be built in other areas of SLDC which have low traffic.
Until an alternative plan is in position to ensure the law on Air Quality is obeyed (with spare capacity for the proposed development) the LA DPD is not Legally Compliant.
-----------------------------------------------------------------------------------------------
These Legal Compliance requirements are not definitive or closed questions; they are open to personal interpretation, so I will not make any further comment in these sections.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Personal Comments:- From my experience of the Core Strategy hearings and the SLDC consultations I know my response will be ignored. The changes to Kendal’s infrastructure, that the new SLDC Transport Study (Jan12) states are required (see below), is just one example of this. I am therefore taking this opportunity to place on record all the relevant evidence I have gathered on why site R170M (policy LA2.2) should not be included in the LA DPD. Quotes from certain documents have been added to make it easier for the reader. There is repetition of some issues but this is because I have added different sources of evidence throughout the document.
It is undemocratic just to include Legal Compliance and Soundness in this consultation. In a democratic society the wishes of the majority of local people would have priority over these criteria. Also criteria such as “Justice” and “Fairness” should be considered. These were totally ignored in the Core Strategy consultation and hearings.
Test of Soundness
1.0 Not justified
1.1 Health and well-being of citizens in Kendal.
I have been informed that a developer does not have to fix an existing problem he just needs to show that he will not make it any worse. This is ridiculous, while SLDC are breaking the law on Air Quality developers must not be allowed to build on site R170M and other Kendal sites until the law is obeyed. SLDC breaking the law must surely be enough to prevent developers from winning an appeal. The people’s health and well-being must have top priority over everything else in the LA DPD.
The latest Cumbria County Council’s transport plan LPT3 does not include plans for the necessary infrastructure to fix existing problems neither does the SLDC Core Strategy. It was only after pressure from the public that SLDC & CCC produced the Transport Study (which is only a study) and after all this time the Transport Plan has not yet been made available to the public. Without a Transport Plan (including committed funding) signed off by all the participants the LA DPD is UNDELIVERABLE within the current timescales (2025) and is UNSOUND.
Before the year 2000 the SLDC objective was to meet the law on Air Quality by the year 2005 but air pollution has continually increased and the AQMA (Air Quality Management Area) has even been made larger. This shows that SLDC are not serious in meeting their objectives where the health and well-being of citizens, or obeying the law, are concerned.
A typical example is the approval of the Planning Application for the old Auction Mart site. Also planning approval is certain to go ahead for the Canal Head development. These will make the air pollution worse in the AQMA. The worst pollution occurs when junctions are grid-locked and tinkering with traffic lights will not fix this problem. It will take major infrastructure changes to fix the existing traffic problems and allow for proposed LDF expansion. The Transport Study even admits that none of the improvements schemes will meet SLDC objectives.
Extract from SLDC document "Kendal Transport Study (Jan12).pdf ”:
“6.1.6 Furthermore, even with the implementation of these improvement schemes, it is important to note that a large proportion of the key junctions would continue to operate above capacity, and therefore experience congestion and extensive queuing in the 2022 base situation. This situation would be compounded by the LDF development traffic.”
More building is planned in Kendal within the next few years (phase 1). This will make the major traffic problems worse. Infrastructure should already be in place to cope. Instead there is not even an approved Transport Plan in place, never mind the infrastructure that will be needed to meet SLDC standards and objectives.
The Transport Study is stating that further modelling is required. This shows that SLDC do not yet know at the present time if their proposals can be implemented or if funding will be available within the LDF timeframe (year 2025), therefore the LA DPD is UNSOUND. Once money has been spent on major infrastructure changes it will be expected that these changes will last for at least 15 years (through the next LDF) therefore any further modelling must use a date of 2040 or beyond. These results will prove that the Taylor “hub & spoke” must be started now (see more evidence below).
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. The health of residents of Kendal town should also cause great concern; a lot of them are elderly and frail.
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.
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 LA DPD maps for the SLDC district, have not been included on the latest maps. It is not fair that these traffic problems are not shared throughout the entire SLDC district. This is another reason why the hub & spoke system must be adopted – FAIRNESS.
The health and well-being of the people due to air pollution must have top priority over everything else in the LDF. This is not happening with the current proposals. Proving the law is being obeyed must come second on the priority list after health. If it does not already do so the “Soundness” examination must take account of these two very important issues.
The evidence above shows that these traffic problems in Kendal will not be fixed without major infrastructure changes which are not in Cumbria County Council’s LTP3.
Site R170M will add further traffic to the streets of Kendal. Therefore the LA DPD is UNSOUND and site R170M must be removed from the LA DPD until the Northern Development Route has an approved construction plan and funding (see above).
For more evidence see extracts from the SLDC Transport Study (Jan12) below.
1.2 Alternative strategy.
Although SLDC have carried out consultations they have ignored the major objections. They have even ignored the alternatives put forward by Kendal Town Council in their excellent reports - “KTC_Response.pdf ”, “KTCResponsePart2toLandAllocation.pdf ” & “Land Allocations Representation (2).pdf. ". To avoid even more “urban sprawl” of Kendal the Taylor “hub & spoke” strategy must be adopted and not the current “doughnut” strategy. Kendal will be around for many thousands of years to come, which makes the “doughnut” strategy UNSUSTAINABLE (i.e. will not satisfy the needs of future generations). Only the “hub & spoke” is sustainable in the years to come because extra “satellites” can be added. By then the proposed “doughnut” system will make Kendal such an urban sprawl that very few people will wish to live there. To prevent this happening the “hub & spoke” system must be started NOW.
Money is being put before what is best for the health and well-being of the people of Kendal now and in the future (beyond 2025).
The Taylor Report, which puts forward compelling evidence in favour of the “hub & spoke” system, shows that the proposed “doughnut” system is UNSUSTAINABLE and therefore the development of site R170 (being a peripheral Green Gap site) is UNSOUND and must be removed from the LA DPD.
2.0 Not effective
2.1 Not meeting definitions of soundness.
The Government Planning Advisory Service (PAS) defines the requirements for Soundness in the document - "soundness.doc" (Soundness Tool from: http://www.pas.gov.uk/pas/aio/85673 )
Extract from page 6 - Deliverable:
"21. Are there realistic timescales related to the objectives?
i. Sections of the development plan document which address delivery and the timescales for key developments and initiatives.
ii. Confirmation from the local strategic partnership and partner organisations that the timescales are realistic in terms of their contribution to delivery."
Extract from page 8 - Deliverable:
“28. Is it clear who is going to deliver the required infrastructure and does the timing of the provision complement the timescale of the strategy/policies?
i. Confirmation from infrastructure providers that they support the solutions proposed and the identified means and timescales for their delivery.
ii. Representations in respect of infrastructure.
iii. Reports or copies of correspondence on how representations in relation to infrastructure and its timing have been considered and dealt with.”
Extract from page 5 of SLDC document "Kendal Transport Study (Jan12).pdf ”:
Exec Summary (see also 6.1.6 on page 18)
“12. Furthermore, even with the implementation of these improvement schemes, it is important to note that a large proportion of the key junctions would continue to operate above capacity, and therefore experience congestion and extensive queuing in the 2022 base situation. This situation would be compounded by the LDF development traffic.”
I have only selected this one paragraph; there are numerous other paragraphs which support these conclusions. In particular Page 15, Item 5.2.1, Table 5.1 which confirms that all schemes fail to meet SLDC’s objective. The results in Tables 5.2 & 5.3 are even worse.
SLDC’s objective is to meet “Acceptable junction performance” which is defined on page 9, item 4.1.5.
I'm not sure why the year 2022 was chosen as base-line, whatever major infrastructure is planned must enable SLDC to meet their objectives for years beyond 2025. In my opinion until 2040, the end of the next LDF.
Schemes 4, 5 & 6 require major investment and are not in the Core Strategy and therefore must be excluded from the Transport Plan when it is published. Note that the Transport Plan should incorporate extra capacity to cope with the “doughnut” system which, if approved, will undoubtedly continue after 2025.
The SLDC Air Quality Reports show that air pollution is getting worse in Kendal and also the AQMA has been increased.
Extract from page 27 of Air Quality Report (PR_Report_Template_2010.pdf)
(see http://www.southlakeland.gov.uk/downloads/page857/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”. Over many previous years this is typical of SLDC’s attitude towards obeying the law on Air Quality. SLDC action plans have not worked in the past and this is proved by the fact that the AQMA has recently been made larger.
The SLDC document "ED43_Housing Completions 1999 to 2010.doc" plus SLDC updates show that from the beginning of plan period 2003 to end of 2011 (8 years results) the total for South Lakeland is 1690 / 8 = 211 average and of these affordable are 406 / 8 = 51 average (or 24%). Figures for 2006 to 2011 (last 5 years results) are 934 / 5 = 187 average and of these affordable are 264 / 5 = 53 average (or 28%).
Between 2003 and 2011 the number of completions was 1690. At 400 per year the objective was 3200 over this 8 year period, a difference of 1510. To make up this deficit means that over the remaining 14 years (up to 2025) an extra 1510 / 14 = 107 per year will be required. This extra number per year will get a lot higher when the build rate stays below 400 per year.
This is nowhere near the Core Strategy figure of 400 dwellings per year or the percentage affordable figure of 35% and therefore the LA DPD is UNDELIVERABLE. 200 dwellings per year would be a more realistic figure and this is the latest figure that is necessary according to a Kendal Town Council Report (see below).
SLDC have recognised this and have added the word “ambition” to build this number of houses to the LA DPD (see page 7 of the “Land Allocations DPD [Feb 12].pdf ” as an example). This word is not used in this context with regard to numbers in the Core Strategy document. Therefore the LA DPD is UNSOUND with respect to the Core Strategy. The Leader of the Council insisted the numbers in the Core Strategy were achievable within the timescales of the LDF.
The above figures show there was an inward migration of 3 (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 all the partners involved have “signed on the dotted line” that they will meet the LA DPD milestones for all the necessary infrastructure (roads, sewerage, doctors, dentists, schools, etc) that is required. With the proviso that the build will actually take place in the timescales planned. It causes unnecessary stress to local people when unachievable targets are proposed or planned.
Another issue that affects DELIVERABILITY is Brownfield sites (or previously developed land).
It states in "SLDC_Core_Strategy_Document_March2011_sm4web2.pdf " (page 17):
"CS1.2 – The Development Strategy
Priority will be given to the reuse of existing buildings and previously developed land for all new housing development, with a target of ensuring that at least 28% of new housing development takes place on such sites."
The “at least 28%” is also mentioned in CS6.6 (page 85). The 50% in item 7.14 is a mistake, it was the previous target. Now the target has been lowered, and "at least 28%" is said by SLDC to be achievable, the LA DPD must indicate the amount of Brownfield land that is currently available and the targets in each area. The Core Strategy and LA DPD have a requirement to be monitored and targets at least progressed vigorously.
The LA DPD does not mention this requirement; therefore it does not conform to the Core Strategy and is UNSOUND. Also these monitored figures need to be published and available to the public.
The SLDC Transport Report (Atkins 2009) 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." There are more similar comments on pages 60 & 71.
Site R170M feeds traffic into Windermere Road and therefore must be removed from the LA DPD until SLDC have met their objectives on Air Quality and Junction Congestion.
Extract from SLDC document "Kendal Transport Study (Jan12).pdf ” page 5 (Exec Summary):
"However, the provision of a new route along Dowker’s Lane (scheme 4) would be required if the Rugby Club development is included. If the Canal Head development is included, the proposed Kendal Northern Development Route (Scheme 5) would be required."
The Canal Head development is more important to Kendal than site R170M therefore because site R170M will add more traffic to Kendal streets it is UNSOUND to build on it. It must be removed from the LA DPD until the Northern Development Route has an approved construction plan and committed funding.
Page 115 of the document “KENDAL Appendix 1.pdf ” (Appendix 1B – Consultation Responses after October 2010) for site R170M states:
“Achieving adequate visibility will be problematic given alignment of road and limited frontage. Such a large site would require a secondary access (Cumbria County Council – Highways).”
The conclusions reached by a chartered civil engineer who has carried out measurements to Transport Standards of the proposed access to site R170M are as follows:
“There is severely restricted forward visibility on both bends in Burneside Road either side of the proposed access location.
In either scenario tested the visibility from the proposed access towards Kendal falls far short of the standard required.
A new junction cannot be safely introduced in this location.”
This report can be supplied if required.
It cannot be right not to identify this secondary access. When it is identified there will be a lot more opposition to site R170 than is currently expressed.
As I said at the beginning of this response about including “JUSTICE” and “FAIRNESS”, it is not FAIR to include a site which is likely to have “show stopping” problems without first carrying out a thorough investigation into these particular problems.
Given the evidence above, until it can be proved that both access roads can be built to meet the Transport Standards, the development of the site R170 is UNSOUND and it must be removed from the LA DPD.
The site R170M is still 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 site R170M is not removed from the LA DPD.
This is a very important reason why site R170M should not be developed – JUSTICE.
Extract from page 137 item 6.9 of the Inspector's Report on the public enquiry in 1996. Green Gap site R170M is the site mentioned below.
"Inspector's Conclusions:
6.9 The objection by Mr Downham [biased land owner] is not concerned with the provision of a green gap, but the extent of that gap. It is argued [land owner’s words] that the green gap, as shown in the Consultation draft of the Plan, follows a public footpath running between substantial hedges, a clearly defined landscape boundary: whilst the residential allocation at Sparrowmire has been reduced in the Deposit Draft, an equivalent extension to the green gap is not necessary. ^However, and most importantly in my view, the objection indicates that the "land should remain unallocated as white land so that when the Plan is reviewed in 10 years' time it can be considered as potential residential land" [land owner’s words]. I consider this underlying reason for excluding the land from the green gap identifies the very reason it should remain so designated. Structure Plan Policy 14 and the reasoned justification makes no reference to the length of time during which the vulnerable areas of countryside between settlements should be protected.^ Although policies and proposals in the Local Plan must clearly relate to the Plan period, and can be subject to review thereafter, it appears to me common sense that what is unacceptable now, will most probably be equally unacceptable at the end of the Plan period: certainly I consider the Plan should seek to engender a degree of public confidence that the separation secured will not, at some future time, be lightly squandered. ^For these reasons I believe that, where a green gap is seen as necessary, it is more important that the whole gap between the settlements should be designated as green gap than that substantial, but arbitrary landscape features should be rigidly followed. I also consider the inter-visibility of settlements is not a factor which should affect the definition of green gaps."^
I have marked with ^...^ the most important words in the above paragraph and my clarifying words are in square brackets.
The first group of sentences marked ^...^ indicates that the owner wished to leave the remaining land (now site R170M) as white land, so it can sold as high priced building land at a later date. The inspector states that this is the very reason it must remain as a Green Gap and because of this statement it is Green Gap. The LA DPD only includes Green Gap site R170M because the owner is keen to sell and make a large profit, if he didn’t it would not be included.
The second group of sentences marked ^...^ indicates that “the whole gap between the settlements should be designated as green gap”. It must not depend on “landscape features” or “inter-visibility of settlements”, but these are the very reasons that SLDC state as to why site R170M can be built-on.
Site R170M is still currently a Green Gap site and by definition has more protection than all Greenfields.
A Government Inspector’s words made the white land (now site R170M) into Green Gap and must not be ignored. Therefore to include site R170M in the LA DPD until all the more suitable Greenfield sites have been built-on is UNSOUND.
This R170M Green Gap is also land of most value to the existing community as backed up by this statement in ‘The Taylor Review’ (Page 58):
“20. Government policy is to increase the density of new housing as a means to maximising land use and better support local services. New extensions to settlements therefore may be relatively densely designed and built right up against the existing settlement to minimise the number of green fields ‘swallowed up’. However, this will mean they are built on exactly the land of most value to the existing community – the fields or woods at the ends of their gardens, the green edge to the town. Local residents against new development may be accused of ignoring the needs of others for housing, but they have a genuine point. They may not have bought the right to their countryside views, but they certainly have paid for them, and these developments are on exactly the fields of most landscape value to existing residents."
Taylor gives a valid reason why local people should not be labelled with the scorning name NIMBYs’ when they have a good reason and evidence to oppose development in their neighbourhood.
The evidence above shows that the proposed LA DPD numbers for dwellings to be built are UNDELIVERABLE before 2025. If the numbers were reduced to ones that were deliverable and sound there would be no reason to include the peripheral site R170M in the last phase (2022-25) of the LA DPD, since it is a Green Gap and hence has a higher protection than any of the proposed Greenfield sites. Note at this point in time site R170M is still part of a Green Gap.
“The Community Infrastructure Levy is a new levy that local authorities in England and Wales can choose to charge on new developments in their area. The money can be used to support development by funding infrastructure that the council, local community and neighbourhoods.”
(see http://www.communities.gov.uk/planningandbuilding/planningsystem/communityinfrastructurelevy/ )
There is absolutely no evidence in the LA DPD about how much funding SLDC are capable of obtaining from developers from the levy. Their track record in the past has been very poor when negotiating for affordable dwelling percentages. The target over previous years has been 50% but SLDC of only achieved 28%. The target is now 35% which from past results is still just wishful thinking. SLDC are relying on this money to fund infrastructure and other projects. Until SLDC publish real evidence that the money raised from this levy is in excess (there will always be an overspend) of that required, for all the proposals in the LA DPD it is intended for, then the LA DPD is UNDELIVERABLE and UNSOUND.
With the excessive financial demands that will inevitably be placed on each development in terms of school places, direct highway consequences, a 35% affordable housing contribution etc, it seems highly likely that any contribution to an Infrastructure Levy for wider scale projects would be relatively modest and inadequate. These financial implications appear to again confirm that the proposals are UNSOUND.
Until it is certain that the required infrastructure funding will be available within the planned timescales, in order that SLDC meet their objectives on Air Quality and Junction Congestion, then the LA DPD is UNSOUND.
Site R170M will add further traffic to the streets of Kendal. Therefore site R170M must be removed from the LA DPD until the Northern Development Route has a approved construction plan and committed funding in place (see above). Also that it is shown to decrease the traffic levels in the Windermere Road corridor enough for SLDC traffic objectives are met in this area.
3.0 Further evidence in support of why Policy LA2.2 (site R170M) should be removed from the LA DPD.
3.1 Extracts from Kendal Town Council document "KTC_Response.pdf " (Apr 2011)
Page 8 Transport Improvements.
“The Assessment then looked at the impact of the various possible development sites which were then under discussion. The Assessment modelled the impact of various remedial measures that could be taken, ranging from junction improvements to the building of the Inner Relief Road. It concluded that the existing highway network plus proposed improvements would just about accommodate the forecast level of traffic, provided three sites were removed:
• Land within the Shap Road/Appleby Road corridor (Site E23/49 and Sites M8/M35/ M36)
• The Todds, west of Burneside Road (Sites R148/R170)
• Stonebank Green (Sites M39/R676/R103/R675)
There was no solution which permitted these sites to be developed within the parameters given for the Assessment (e.g. no compulsory purchase orders for major junction redevelopment).”
This supports previous evidence that the development of site R170M (The Todds) is UNSOUND
Page 9 section on “Sewer Capacity”
“In addition, United Utilities has concerns about the capacity of the Waste Water Treatment Works, located to the south of Kendal, for which process modelling needs to be carried out. This impacts all the potential development sites in the town.”
I have an email from SLDC dated 27Apr2011 which states:
“The following is based on information and advice provided by United Utilities.
1. United Utilities cannot determine the number of dwellings that will cause Kendal Wastewater Treatment Works (WwTW) to reach process capacity without conducting modelling. The threshold for when capacity is reached is determined by the design capacity of the WwTW and the population that it serves with some headroom designed in to the calculations. This headroom is not excessive as United Utilities cannot design and build for a population that is not already there or where development is not definite.
2. There are local network issues in respect of sewer capacity in the Kendal area . They are primarily centred around the Burneside area as evidenced in the Core Strategy and supporting Land Allocations Document material.
3. South Lakeland District Council does not hold or have access to data/information regarding the catchment area of the Kendal Sewerage Works.”
SLDC/UU admit that the headroom (i.e. spare capacity) is not excessive. Despite this SLDC have no results of any modelling and have not insisted that this modelling be carried out by UU. SLDC do not even know the catchment area for Kendal Sewage Works. There is nothing in the documentation on the SLDC web site to indicate that SLDC do have this information today (a year later). Therefore SLDC do not know how many dwellings can be built before Kendal Sewage Works needs a major upgrade costing many millions of pounds.
United Utilities move their funding from year to year as they see their immediate priorities change, so until they actual “sign on the dotted line” to meet certain dates then their current dates can “be taken with a pinch of salt”. As evidence to support this, the paying customers of Burneside have been waiting over 20 years to get their sewerage fixed and they still have sewage on the streets during heavy rain. So there is no guarantee that the North West Kendal problem will be fixed before 2025.
Site R170M is one of the last sites in the plan to be developed therefore until the above figures are known for the whole of the catchment area and UU & OFWAT have “signed on the dotted line” to meet their agreed dates then the site R170M is UNDELIVERABLE and the LA DPD is UNSOUND.
Page 9 section on “Hydrologic Considerations”.
“However, the mechanisms (some man-made, mostly natural) which are currently managing to keep Kendal free of floods are not well understood. Several of the sites included in the Land Allocations have a history of being badly affected by rainfall. This suggests they have a role to play in mitigating surface run-off and hence flood prevention. If this is correct, development of such sites could trigger flooding in the town - and making the sites themselves flood proof would certainly involve additional expense for developers.
Kendal Town Council believes this is an important omission from the current evidence base, and calls on SLDC to commission a full hydrology study of the area before including the affected sites in any final land allocation. Any remedial infrastructure required to allow these sites to be developed safely would need to be included in the overall infrastructure programme.
Land Allocations affected by this consideration are the lower Hallgarth sites (R169M and R170M), Appleby Road (MK35KM), Natland Beck at Kendal Parks (R107M, R150M), Stock Beck at Castle Green Road (R121M), and Stonecross (R103M), and Blind Beck (R129M)”
There is nothing in the documentation on the SLDC web site to indicate that SLDC have commissioned this study or have any results. Site R170M is mentioned in quote above and so until this study is carried out development of site R170M is UNDELIVERABLE and UNSOUND.
Page 10 Infrastructure.
“3. Sites should not be included in a Final Land Allocations document unless their impact on Kendal’s transport is understood, solutions are agreed with partners, and the impact has successfully passed a rerun of the Transport Assessment. ‘Emerging Option’ sites affected by this are indicated are indicated by an ‘X’ in the ‘Traffic’ column in the Detail by each Land Allocation site starting on page 11.”
Note site R170M has an ‘X’ in the Traffic column, so this site should be removed from the LA DPD until its impact on Kendal’s junction congestion is fully understood.
This section supports previous evidence that site R170M is UNDELIVERABLE and UNSOUND.
3.2 Extracts from Kendal Town Council doc. "KTCResponsePart2toLandAllocation.pdf" (Sep 2011)
Page 5 Doughnut Development
“Taylor contends: ...these developments undermine sustainability. They invariably encourage car use, especially if there are no services or employment within walking distance, with resulting congestion on roads into town. And without local and community facilities of their own, there is little to build social sustainability and cohesion or links between new and existing settlements as there will be little in the way of community life.
This approach to planning is also a recipe for confrontation, “developing exactly the land of most value to the existing community – the fields or woods at the ends of their gardens, the green edge to the town”
(as has been amply demonstrated in Kendal by the response to the Emerging Options consultation process).
Without change we will simply repeat the mistakes of recent decades, creating unattractive developments of housing estates encircling our rural towns and larger villages, and we will fail to stem the trend of smaller villages becoming dormitory settlements of commuters and the retired, ever less affordable for those who work within them. This is not a sustainable future for rural England.
Without strong Land Allocation policies from the Planning Authority, Kendal is heading towards an unsustainable “doughnutted” future.”
This confirms that development of the peripheral Green Gap site R170M is UNSUSTAINABLE and therefore UNSOUND.
Page 6 Recommendation for Kendal
“The Council believes the Planning Authority should follow Taylor and adopt this model in preparing its final Land Allocations policies for Kendal, as the only way in which the NPPF demand for sustainable development can be achieved in the town. It is important to note that this is not in conflict with the Core Strategy positioning of Kendal as a Principal Service Centre, or with the requirements for meeting forecast housing demand. From Taylor, the requirements for sustainable development in rural market towns is clear: it cannot be delivered by allocating isolated sites around the town; a hub and spoke model is required. Even without the NPPF’s insistence on sustainable development, there are other intrinsic advantages to the hub and spoke model for Kendal. The Council’s previous Response to Consultation highlighted the major infrastructure challenges to be overcome in the town. These become far more soluble if development proceeds on hub-by-hub basis, when the infrastructure work can be concentrated on the corresponding spokes. For example, it is far simpler to improve bus services, cycling provision, etc. if only one or two ‘spokes’ have to be addressed.
The evidence in the EHLSS shows that there are suitable sites available (the scope of the SHLAS only covered sites within existing settlement boundaries, and is of less relevance), and there are options both for completely new communities on green field sites, or for breathing new life into existing communities.”
This confirms that the “doughnut” strategy is incorrect for Kendal and should be replaced by the “hub & spoke” strategy. It also confirms that the peripheral Green Gap site R170M is unsustainable and therefore UNSOUND.
Page 10 Latest Forecasts (2011)
“The latest forecast in this series was produced in Spring 2011. It shows a drastically reduced requirement:
• only 360 dwellings across the 20 years, or
• just over 4,000 including migration, projected on the last five years’ evidence.
This suggests that a more appropriate target for the next 5-10 years would be around 200 dwellings per annum.”
This confirms the evidence given above that 200 per year is what is required and this number would be deliverable. If this number was planned then the peripheral Green Gap site R170M would not be required and being in the last phase would not be needed in this LA DPD.
This section supports previous evidence that the LA DPD is UNSUSTAINABLE and UNSOUND.
3.3 Extracts from Kendal Town Council doc. “Land Allocations Representation (2).pdf “ (Mar 2012)
Page 4 Summary
“The Council believes that the DPD is not justified because it fails the following tests of soundness:
• the LPA has failed in its duty to compare against reasonable alternatives
• key decisions are not supported by the evidence base or the evidence supports a different conclusion
• the evidence base is incomplete
The DPD is also not effective in that it is not deliverable, with key elements of the dependent infrastructure
not understood.”
This confirms the LA DPD is NOT DELIVERABLE.
Page 4
“For rural market towns, the evidence was pulled together in July 2008 by the Taylor Review9, setting out the policy framework necessary to deliver the “vision of a living, working sustainable countryside”. Taylor provided compelling evidence that “doughnut development” was the wrong approach for sustainable rural market towns, and that a “hub and spoke” model represented the best pattern for sustainability.”
The two KTC paragraphs above confirm that an alternative system must be adopted now, which will “meet the needs of future generations” of Kendal (i.e. BE SUSTAINABLE”) for the many thousands of years to come.
Page 4
“The evidence in the EHLSS indicates that suitable sites could be available (the scope of the SHLAA only covered sites within existing settlement boundaries, and is of less relevance), and there are options both for completely new communities on green field sites, or for breathing new life into existing communities.”
This confirms that a “hub & spoke” is viable.
Page 5
“The Assessment concluded that the existing highway network plus proposed improvements would just about accommodate the forecast level of traffic, provided three large sites were removed. The consultants could find no mitigation which would permit these sites to be developed within the parameters given for the Assessment (e.g. no compulsory purchase orders for major junction redevelopment.)”
This confirms that site R170M must be removed from this LA DPD because it is one of the three sites.
Page 5
“Given that this approach has differed significantly from the independent consultants’, the Council asks the Inspector to order an independent audit of this latest work by W.S.Atkins or equivalent to ensure it meets accepted professional standards of objectivity and integrity. The Council further asks the Inspector to ensure that no sites are included in the DPD which the evidence shows are not deliverable on transport grounds.”
This confirms that site R170M must be removed from this LA DPD, because it is one of the sites which “are not deliverable on transport grounds.”
Page 7
“The Council asks the Inspector to withhold approval of the DPD until there is a credible infrastructure plan showing the impact of the major sites on the overall town infrastructure, and with high level solutions identified and costed with enough detail to enable the economic deliverability of the sites to be proven.”
This adds to the evidence given above that there must be signatures, to supply the necessary infrastructure and funding, must be in place before this LA DPD is approved by the Government. Until this is done site R170M is UNDELIVERABLE and UNSOUND.
This section supports previous evidence that site R170M is UNDELIVERABLE and UNSOUND.
3.4 Extracts from SLDC document "Kendal Transport Study (Jan12).pdf ”:
Page 5 Exec Summary (see also 6.1.6 on page 18)
"10. The LDF developments have a more notable impact in the AM peak compared to the base situation. The model results indicate that the provision of sustainable transport improvements (Scheme 2) would be required to support LDF development to nil-detriment compared to the 2022 base situation in the AM peak. However, the provision of a new route along Dowker’s Lane (scheme 4) would be required if the Rugby Club development is included. If the Canal Head development is included, the proposed Kendal Northern Development Route (Scheme 5) would be required.
11. It should be noted that although these schemes are required to achieve nil-detriment, these improvements are only demonstrated to offer marginal benefits to the performance of junctions in Kendal. These infrastructure schemes would be expensive and may not be a cost-effective solution to congestion in Kendal town centre.
12. Furthermore, even with the implementation of these improvement schemes, it is important to note that a large proportion of the key junctions would continue to operate above capacity, and therefore experience congestion and extensive queuing in the 2022 base situation. This situation would be compounded by the LDF development traffic.
13. It is recommended that further modelling work is undertaken"
The Transport Study shows that the objectives cannot be achieved before 2025 therefore the problems are going to be much worse in the years 2026 onwards.
SLDC do not have signed-off solutions and timescales in place to meet the plan phases, therefore the LA DPD is UNDELIVERABLE and UNSOUND.
Page 9 This page gives the CCC/SLDC definition for Junction Congestion limits.
"Acceptable junction performance is indicated by a degree of saturation below 90 percent for signal-controlled junctions, or an RFC below 85 percent for priority junctions and roundabouts."
The Atkins report uses a Volume/Capacity ratio of 90 as acceptable for a junction approach, which is similar.
The Study shows that these objectives will not be met by 2025 so this, along with page 10 (see below) adds evidence to the above.
Page 10
"4.2.2 In total 13 junctions are indicated to have a maximum RFC greater than or equal to 90% in the 2010 base year, in either the AM or PM peak period. These are:Junction1: A5284 Stricklandgate/Sandes AvenueJunction 2: A5284 Sandes Avenue / A6 Blackhall Road signalised junction
Junction 5: A6 Longpool / Station Road mini-roundabout junction
Junction 12: A6 Highgate / Lowther Street signalised junction
Junction 22: Parkside Road / Valley Drive priority junction
Junction 16: A6 Milnthorpe Road / Romney Road signalised junction
Junction 17: A5284 Windermere Road/Queens Road
Junction 18: A5284 Windermere Road/Burneside Road
Junction 21: A65 Burton Road / Oxenholme Road signalised junction
Junction 27: A684 Sedbergh Road / Sandylands Road priority junction
Junction 29: A6 Shap Road / A685 Appleby Road (north) priority junction
Junction 30: A6 Shap Road / A685 Appleby Road (south) priority junction
Junction 31: A685 Appleby Road/Sandylands Road"
“Measures must be in place” to fix these major problems first (i.e. meet SLDC objectives). They have a huge bearing on why SLDC is still breaking the law on Air Quality.
Page 14
“* Scheme 6: Scheme 5, plus a potential Kendal Southern Link Road, which comprises a new single-carriageway road linking the A6 Milnthorpe Road with the A65 Burton Road south of Kendal town centre.”
This new road proposal has never been mentioned before; it is not in the Core Strategy and therefore, as we have been told before, it cannot be considered in this LDF.
This section supports previous evidence that site R170M is UNDELIVERABLE and UNSOUND.
3.5 Extracts from SLDC document "06 Infrastructure Position Statement.pdf ”:
Page 10
"4.19 United Utilities has a statutory duty to develop and maintain an efficient and economical system of water supply within its area. A proposal for expenditure in the years 2010 – 2015 is contained within the published five years Investment Plan (Asset Management programme). The plan can be found at the following website link: http://www.unitedutilities.com/Documents/Detailed_plan.pdf "
There is nothing in this PDF document that is specific to Kendal.
UU may have "a statutory duty to develop and maintain an efficient and economical system of water supply within its area" but it is very poor at obeying this duty as is verified by the > 20 years Burnside have been suffering sewage problems (and still are).
Until UU actually “sign on the dotted line” to meet the required planned timescales and commit funding, the LA DPD is UNDELIVERABLE and UNSOUND.
Page 11
"4.23 Funding is more likely to be acquired in cases where there is development certainty (i.e. clear evidence of developer interest).
* UU reiterate that even if a bid is submitted there is no guarantee funding will be approved by OFWAT. The speed at which approved schemes are implemented will depend on the priority given to schemes within the 5-year programme and the time required to design, obtain planning permission and construct."
This backs previous evidence, never mind “development certainty” what about the existing paying customers who are still suffering sewage and flooding problems due to lack of investment.
Until United Utilities “sign on the dotted line” and commit to planned dates and funding the LA DPD is UNDELIVERABLE and UNSOUND.
Page 11
"4.24 There is currently loading capacity at Kendal Waste water Treatment Works (WwTW), however, for the number of dwellings that are proposed a full process and hydraulic survey of the Works will have to be undertaken before UU could comfortably approve the Planning Applications. As the sewer network is at capacity in North Kendal, UU could not agree to any significant development until after 2015 in this part of the town. Providing UU obtain funding through OFWAT to undertake the necessary upgrades etc. UU will be building into the 2014 Business Submission to OFWAT a case for funding to provide the means to accommodate development, which will boost the economy.
4.25 A feasibility study is being undertaken on the Kendal WwTW. Recommended phosphorous levels are set by Environment Agency (EA) through discharge consents, and until EA impose a new requirement for a lowered rate, UU will continue to discharge at the current rate. UU stated achieving any required lower rates would depend on new/better technology. Further Phosphorous removal would only be undertaken if UU were required to achieve a tighter standard as set by the EA following their review of water quality. Newer technology, which is not currently available, would be required to achieve any standard below 1mg/l. UU has advised development in the Kendal area should be capped at 2000 properties unless a more stringent phosphorus effluent standard can be achieved.
4.26 UU has advised that sites in North Kendal should only come forward in the latter periods of the plan period when sewage network improvements are in place.
4.27 Strategically there is enough water supply to accommodate levels of new development, but there are potential risks of deterioration of water quality."
Until OFWAT “sign on the dotted line” and commit to planned dates and funding the LA DPD is UNSOUND.
Page 14
"4.45 Electricity North West Ltd manage infrastructure and distribute and transmit electricity throughout South Lakeland. The regulator determines the amount of funding, however, it is not known what the next round of funding may or may not allow for investment in improvements. Information relating to substation capacity has not been ascertained. Evidence when exploring options for the Canal Head Area of Kendal shows that the Kendal Primary substation is currently operating close to or at capacity. It is possible that significant development in Kendal would require investment for network reinforcement and that a new Primary Substation would be required although Electricity North West Ltd does not confirm this. No information has been made available stating whether this is the case. Only when the customer has firm load requirements and location details can a system study be undertaken to ascertain the scale of impact of potential new development."
What if the system study states it cannot be done or they cannot obtain the funding within the plan timescales? Electricity North West Ltd already has the number of houses proposed and their locations so they must commit to a system study and confirm that the proposed developments are deliverable. Until then the LA DPD is UNSOUND.
Page 15
"4.48 National Grid Gas Distribution own and operate the local gas distribution network in South Lakeland. The confidential nature of the process means National Grid are unable to confirm whether they are currently processing or have made any offers for connection within Cumbria."
The document states nothing about National Grid Gas Distribution having a statutory duty to develop and maintain an efficient and economical system of gas supply within its area.
The LA DPD cannot possibly be monitored correctly until all the Gas company has “signed on the dotted line” to meet the timescales required. Until then the LA DPD is UNDELIVERABLE and UNSOUND.
This Infrastructure document is only a statement; there is no indication when the Infrastructure Delivery Plan will be available to the public or any indication that the timescales can be met. The LA DPD is UNSOUND until the Infrastructure Delivery Plan and the Kendal Transport Plan are available with all milestones agreed, funding committed and both signed off by the respective utility companies. They can have the proviso that it depends on the build going ahead as planned.
3.6 Extracts from SLDC document “01 Consultation Report.pdf ”:
Page 19
“In their response the Highways Agency identified those sites it considers (if developed, due to cumulative impact with other sites) may impact upon the capacity, operation and safety of the strategic road network (SRN) (A590 and M6) within South Lakeland. As a consequence, the Agency has stated that the cumulative impact of development of sites under consideration in the following settlements (see below) may result in some impact to the SRN: Burneside, Crooklands, Endmoor, Kendal, Kirkby Lonsdale, Levens, Milnthorpe and Ulverston alongside the sites suggested for strategic employment use (in Ulverston and Kendal area).”
Note the word “may” on the second line. They either do or they don’t. After all these years of the LDF there is no excuse for this information not being available. SLDC must obtain an answer to this issue immediately and publish it. If any of the developments proposed within the LA DPD do affect the Strategic Road Network then any changes necessary must be included in the LA DPD and the Transport Plan (which must be issued before the hearings). Note the Strategic Road Network is NOT currently mentioned in the LA DPD.
Page 21
This page with reference to Burneside states:
“.....this is no guarantee that funding will be approved by OFWAT”.
Until OFWAT “sign on the dotted” line to meet the planned timescales the LA DPD is UNSOUND.
Page 21
“Additional work is needed by UU to check if cumulative impact on treatment works may raise capacity issues
SLDC must publish how many houses can be built in the Kendal catchment area before a major upgrade to the sewage works is required. Until UU know their total funding requirements the LA DPD is UNSOUND.
Page 34
KENDAL
“Many people believe development of the sites suggested would harm the landscape character of the town, worsen air quality, exacerbate current flooding problems, harm biodiversity, generate unacceptable levels of traffic congestion, and place further strains on a heavily constrained sewerage system. Some people questioned the need for additional housing believing there are enough empty properties in the town to meet current and future housing demands. A number of people stated development should be prioritised on brownfield sites and meet primarily local needs.”
“Many people including Kendal Town Council and Burneside and Natland Parish Council’s supported the concept of green gaps to protect Kendal coalescing with neighbouring settlements. However, a significant number of people and Kendal Town Council and Natland Parish Council believed the suggested emerging options would not prevent coalescence from happening. There was general widespread support for the open space designations suggested, however, many people believed the emerging options sites should also be designated open space.”
“Kendal Town Council expressed serious concerns with the overall approach being suggested for the town, believing the amounts of developments and the emerging option sites suggested would damage the landscape character of the town, and put unnecessary strain on an inadequate infrastructure system. The Town Council has suggested an alternative strategy/approach for the town this being to protect existing green space/countryside surrounding the town and to look at alternative sites adjacent to nearby settlements and possibly further afield where development would have less impact on the town’s infrastructure, air quality and its high quality landscape value.”
These three paragraphs confirm that the wishes of the majority of local people have been ignored and adds support to the evidence given above concerning Consultation and Legal Compliance.
Page 46
On this page it states “UU is currently considering lists of projects that will require major capital investment in Asset Management Plan 6 period 2015-2020.” and “UU reiterate that even if a bid is submitted there is no guarantee funding will be approved by OFWAT. The speed at which approved schemes are implemented will depend on the priority given to schemes within the 5-year programme and the time required to design, obtain planning permission and construct.”
Until United Utilities and OFWAT “sign on the dotted line” to meet the planned timescales and commit funding, the LA DPD is UNDELIVERABLE and UNSOUND.
This section supports previous evidence that site R170M is UNDELIVERABLE, UNSOUND and that consultation process was not Legally Compliant.
3.7 Extracts from SLDC document “Land Allocations DPD.pdf ” [Mar12]:
Pages 51 & 52
Item 3.6 - Key local factors influencing the location of new development in Kendal:
“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; Avoiding coalescence between Kendal, Oxenholme, Burneside and Natland and maintaining the separate identities of these settlements;
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;
Infrastructure constraints including sewage capacity at Kentrigg and Steele's Row and the implications for development in northwest Kendal.”
One of the main comments of the people who responded to the SLDC consultations and opposed them was the character and appearance of Kendal. This is imbedded in the above paragraph and has been totally ignored. The LA DPD is therefore not Legally Compliant.
The site R170M is close to Kentrigg (mentioned above) and so it is UNSOUND to include it in the LA DPD until United Utilities are fully committed (i.e. signed on the dotted line) to the LA DPD timescales.
The sentence “Minimising the impact of development on Kendal’s central traffic system, …..” is not definitive it should state “Meet and maintain SLDC’s standards and objectives with regard to Kendal’s central traffic system, …..”
Page 163 APPENDIX 4 - HOUSING TRAJECTORY
A graph on this page it shows the following numbers over the years 2003 – 2025 (22 years).
Maximum number of dwellings ever built in one year was 300 in year 2005/06 and even this did not reach the target of 400 per year.
Extrapolating from the graphs the average number of dwellings built per year for the first 8 years was 100+280+150+150+240+300+230+220 = 1670 / 8 = 209 per year. In the terms of this graph there are already an extra 1530 dwellings (109/yr on top of the 400/yr) that have built just to catch up. This compares well with the more accurate figures in section 2.1 above.
The figure of 720 per year for the three years 2022 – 2025 is just WISHFULL THINKING.
One of the questions that must be asked to confirm SOUNDNESS is “Are there realistic timescales related to the objectives”. The above numbers are clearly not realistic therefore the current LA DPD is UNSOUND.
This section supports previous evidence that site R170M is UNDELIVERABLE and UNSOUND within the timescales of this LA DPD (2025).
4.0 Changes required to the LA DPD document title “Land Allocations DPD.pdf ” [Mar12]:
4.1 During the recent SLDC consultation 98% of the local neighbourhood who responded OPPOSED the proposals for site R170M. In a door-door poll of over 400 neighbours during 2011 approximately 80% of those asked OPPOSED the proposal to build on site R170M. Of the remaining 20% most did not care one way or the other. The Localism Bill is a Con Trick (nice pun); it promises much but does not actually support what the majority of the people in the neighbourhood want.
To prove SLDC are DEMOCRATIC they must be serious about responding to the majority of the local neighbourhood’s wishes. Also the TOTAL CONCLUSIVE EVIDENCE ABOVE PROVES THAT SLDC MUST REMOVE THE PERIPHERAL GREEN GAP SITE R170M FROM THE LA DPD TO MAKE IT SOUND. THIS IS HOW THE LA DPD MUST BE CHANGED.
4.2 After many years (before year 2000) of knowing about the traffic problems in Kendal, SLDC have failed to produce a transport plan or action plan that enabled them to meet their standards and objectives for Air Quality and Junction Congestion. This must NOT be allowed to continue. Only when these standards and objectives have been PROVEN to have been met (with spare capacity for expansion) will the people believe SLDC are serious about tackling these major problems. The recent SLDC consultations show that increase in traffic was one of main reasons why 98% of the people (that responded) OPPOSE the proposals to build on sites in their area of Kendal.
Previous experience with Core Strategy has shown me that all my evidence will be ignored and that site R170M will not be removed from the LA DPD. If this is to be repeated then I would like to see the following changes to LA DPD.
There is a note on page 57 (item 3.18) of the LA DPD (policy LA2.2 site R170M) which states:
"DEVELOPMENT OF THIS SITE CANNOT TAKE PLACE UNTIL MEASURES ARE IN PLACE TO RESOLVE PRESSURE ON THE SEWERAGE NETWORK IN NORTH KENDAL."
This means existing problems will be fixed before building starts.
THIS SETS A PRECEDENT WHICH MUST CONTINUE WITH REGARD TO OTHER MAJOR PROBLEMS.
The threat to the health of people due to air pollution is of as much importance as sewage on the streets. Site R170M will add more traffic to the streets of Kendal and make air pollution worse. Therefore a note must be added to Policy LA2.2 (item 3.18) that states:
"DEVELOPMENT OF THIS SITE CANNOT TAKE PLACE UNTIL MEASURES ARE IN PLACE TO SHOW THAT THE LAW ON AIR QUALITY HAS BEEN MET IN KENDAL."
Increase in traffic, which leads to more junction congestion and a deterioration in the well-being of local people, was one of the major complaints in the recent SLDC consultations. Site R170M will add more traffic to the streets of Kendal and make junction congestion worse. Therefore a note must be added to Policy LA2.2 (item 3.18) that states:
"DEVELOPMENT OF THIS SITE CANNOT TAKE PLACE UNTIL MEASURES ARE IN PLACE TO SHOW THAT SLDC’S DEFINITION OF “ACCEPTABLE JUNCTION PERFORMANCE” HAS BEEN MET IN KENDAL."
For definition see page 9 of “Kendal Transport Study (Jan12).pdf”.
“4.1.5 An RFC or DoS of 100% indicates that an approach is operating at maximum capacity. Acceptable junction performance is indicated by a degree of saturation below 90 percent for signal-controlled junctions, or an RFC below 85 percent for priority junctions and roundabouts. Above this level, an approach is likely to begin to experience congestion as there is insufficient spare capacity to cope with fluctuations in traffic flow.”
4.3 Page 51 item 3.6:
The sentence “Minimising the impact of development on Kendal’s central traffic system, …..” is not definitive. The word “Minimising” is just not good enough to meet the people’s wishes. It must state “Meet and maintain SLDC’s standards and objectives with regard to Kendal’s central traffic system, …..”
4.4 Page 163 APPENDIX 4 - HOUSING TRAJECTORY
This Appendix 4 must be changed and other pages which quote these figures. The SLDC evidence does not support the requirement that anywhere near the 8800 dwellings can be built before 2025. The numbers in the graph are not realistic (a SOUNDNESS word), therefore NOT DELIVERABLE and UNSOUND. 720/year for last three years is just wishful thinking, it is not realistic; this graph shows that the maximum that has ever been built within the last 8 years is 300 per year for the year 2005/06. The developers will not build 750 per year because it would swamp the market and they would be left with a large number of empty houses.
There is no point in just stating on page 7 of the LA DPD that it is “the ambition to deliver 400 dwellings each year” if these numbers cannot realistically be built and sold. There is also no point in just monitoring these numbers just so a box can be ticked to say they have been monitored. The numbers must be realistic so that they can be monitored and vigorously progressed.
Kendal Town Council have stated in one of their reports [Sep2011 see above] that only around 200 dwellings per year is the number required. SLDC must discuss this issue with KTC and reduce the current total figure of 8800 to a number that can realistically be built & sold before 2025 and not one that is just WISHFULL THINKING.
4.5 There is a requirement in the Core Strategy for Brownfield land to be used for “at least 28%” of the number of dwellings built. Note the words are “at least” not it is the “ambition to use”. To be SOUND the LA DPD must indicate the amount of Brownfield land that is currently available and the targets for each area. These figures must be monitored, vigorously progressed and be made available to the public.
4.6 SLDC must discuss Kendal Town Council’s three reports in detail with the town council and members of opposition groups (e.g. Green Spaces). I would like to see the LA DPD changed to incorporate as much as possible of that which is agreed in these discussions.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
THE HEALTH AND WELL-BEING OF LOCAL PEOPLE MUST BE AT THE TOP OF SLDC's PRIORITY LIST and despite all my emails and protest at the Core Strategy hearings this has not yet been done in Kendal.
So I wish to speak face to face with the inspector and ask him personally if he will recommend in his report that notes be added to the LA DPD stating that SLDC must fix their major existing problems first and meet the SLDC/CCC definition for "Acceptable Junction Congestion" and the Law on Air Quality before allowing actual build of site R170M, which will add to these problems (see examples of notes in section 4.2 above).
A PRECEDENT has already been set by a note in Policy LA2.2 for site R170M relating to the sewerage network in North Kendal. If United Utilities have to fix their major existing problems first before building is allowed then so must SLDC, this is logical and should not need a political decision.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
913. Mr Derek Whitmore (Individual) : 17 May 2012 10:54:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.6 Strategic Employment Sites - E4M KENDAL LAND AT SCROGGS WOOD, MILNTHORPE ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
1.0 Consultation
1.1 SLDC did not change the proposals in-line with the citizens important wishes.
The Government Planning Advisory Service (PAS) defines the requirements for Legal Compliance in it’s document – "legal.doc” (Legal Compliance Tool from http://www.pas.gov.uk/pas/aio/85651 )
Extract from Stage 2: Plan preparation - frontloading phase (page 7):
“6. Does the consultation contribute to the development and sustainability appraisal of alternatives?”
This has not been carried out correctly, alternatives have not been seriously considered. In particular the Kendal Town Council’s excellent reports, containing good alternatives, have been ignored.
The vast majority of the oppose responses made in the SLDC consultations were noted, listed in the consultation documents and then almost totally ignored. In my view these consultations were just so that SLDC could “tick the box” for the government inspector and therefore were a waste of taxpayers money.
I have done a detailed examination of the SLDC Consultation Database and these are my findings:
On 11th August 2011 (after the closing date) there were 2986 responses from the Kendal settlement. 98% of these responses opposed the proposals in their neighbourhood. Most of those that “support in part” did not support housing. Most of the few indicating “support” were representatives of the land owner, potential builder, Kendal Futures Board or the North West Development Agency.
The main reasons for the respondents opposition was the increase in traffic that these proposed developments would cause, and the affect they would have on the landscape character of Kendal. Better alternative sites were suggested, noted and then ignored. The present proposals will not “satisfy the needs of future generations” and are therefore NOT SUSTAINABLE.
Issues raised in the consultations would have contributed greatly to the development and sustainability of alternatives but the alternatives put forward have been ignored (also see other evidence 2.3 below). Therefore the LA DPD it is not Legally Compliant.
I would like to see alternatives discussed with Kendal Town Council and the Green Spaces group. Then any changes agreed included in the LA DPD.
2.0 Alternative plan
2.1 Law must be obeyed.
Extract from Stage 2: Plan preparation - frontloading phase (legal.doc page 5):
“* developing alternatives and options and appraising them through sustainability appraisal and against evidence.”
The SLDC Air Quality reports show that SLDC have been breaking the Law on Air Quality for many years. It means that SLDC must use an alternative plan for Kendal until it is proven that the law is being obeyed (with spare capacity for proposed development). The reason the law must be proven is that action plans have not worked for at least 14 years (before 1998). In the meantime affordable houses can be built in other areas of SLDC which have low traffic.
Until an alternative plan is in position to ensure the law on Air Quality is obeyed (with spare capacity for the proposed development) the LA DPD is not Legally Compliant.
-----------------------------------------------------------------------------------------------
These Legal Compliance requirements are not definitive or closed questions; they are open to personal interpretation, so I will not make any further comment in these sections.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Personal Comments:- From my experience of the Core Strategy hearings and the SLDC consultations I know my response will be ignored. The changes to Kendal’s infrastructure, that the new SLDC Transport Study (Jan12) states are required (see below), is just one example of this. I am therefore taking this opportunity to place on record all the relevant evidence I have gathered on why site R170M (policy LA2.2) should not be included in the LA DPD. Quotes from certain documents have been added to make it easier for the reader. There is repetition of some issues but this is because I have added different sources of evidence throughout the document.
It is undemocratic just to include Legal Compliance and Soundness in this consultation. In a democratic society the wishes of the majority of local people would have priority over these criteria. Also criteria such as “Justice” and “Fairness” should be considered. These were totally ignored in the Core Strategy consultation and hearings.
Test of Soundness
1.0 Not justified
1.1 Health and well-being of citizens in Kendal.
I have been informed that a developer does not have to fix an existing problem he just needs to show that he will not make it any worse. This is ridiculous, while SLDC are breaking the law on Air Quality developers must not be allowed to build on site R170M and other Kendal sites until the law is obeyed. SLDC breaking the law must surely be enough to prevent developers from winning an appeal. The people’s health and well-being must have top priority over everything else in the LA DPD.
The latest Cumbria County Council’s transport plan LPT3 does not include plans for the necessary infrastructure to fix existing problems neither does the SLDC Core Strategy. It was only after pressure from the public that SLDC & CCC produced the Transport Study (which is only a study) and after all this time the Transport Plan has not yet been made available to the public. Without a Transport Plan (including committed funding) signed off by all the participants the LA DPD is UNDELIVERABLE within the current timescales (2025) and is UNSOUND.
Before the year 2000 the SLDC objective was to meet the law on Air Quality by the year 2005 but air pollution has continually increased and the AQMA (Air Quality Management Area) has even been made larger. This shows that SLDC are not serious in meeting their objectives where the health and well-being of citizens, or obeying the law, are concerned.
A typical example is the approval of the Planning Application for the old Auction Mart site. Also planning approval is certain to go ahead for the Canal Head development. These will make the air pollution worse in the AQMA. The worst pollution occurs when junctions are grid-locked and tinkering with traffic lights will not fix this problem. It will take major infrastructure changes to fix the existing traffic problems and allow for proposed LDF expansion. The Transport Study even admits that none of the improvements schemes will meet SLDC objectives.
Extract from SLDC document "Kendal Transport Study (Jan12).pdf ”:
“6.1.6 Furthermore, even with the implementation of these improvement schemes, it is important to note that a large proportion of the key junctions would continue to operate above capacity, and therefore experience congestion and extensive queuing in the 2022 base situation. This situation would be compounded by the LDF development traffic.”
More building is planned in Kendal within the next few years (phase 1). This will make the major traffic problems worse. Infrastructure should already be in place to cope. Instead there is not even an approved Transport Plan in place, never mind the infrastructure that will be needed to meet SLDC standards and objectives.
The Transport Study is stating that further modelling is required. This shows that SLDC do not yet know at the present time if their proposals can be implemented or if funding will be available within the LDF timeframe (year 2025), therefore the LA DPD is UNSOUND. Once money has been spent on major infrastructure changes it will be expected that these changes will last for at least 15 years (through the next LDF) therefore any further modelling must use a date of 2040 or beyond. These results will prove that the Taylor “hub & spoke” must be started now (see more evidence below).
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. The health of residents of Kendal town should also cause great concern; a lot of them are elderly and frail.
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.
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 LA DPD maps for the SLDC district, have not been included on the latest maps. It is not fair that these traffic problems are not shared throughout the entire SLDC district. This is another reason why the hub & spoke system must be adopted – FAIRNESS.
The health and well-being of the people due to air pollution must have top priority over everything else in the LDF. This is not happening with the current proposals. Proving the law is being obeyed must come second on the priority list after health. If it does not already do so the “Soundness” examination must take account of these two very important issues.
The evidence above shows that these traffic problems in Kendal will not be fixed without major infrastructure changes which are not in Cumbria County Council’s LTP3.
Site R170M will add further traffic to the streets of Kendal. Therefore the LA DPD is UNSOUND and site R170M must be removed from the LA DPD until the Northern Development Route has an approved construction plan and funding (see above).
For more evidence see extracts from the SLDC Transport Study (Jan12) below.
1.2 Alternative strategy.
Although SLDC have carried out consultations they have ignored the major objections. They have even ignored the alternatives put forward by Kendal Town Council in their excellent reports - “KTC_Response.pdf ”, “KTCResponsePart2toLandAllocation.pdf ” & “Land Allocations Representation (2).pdf. ". To avoid even more “urban sprawl” of Kendal the Taylor “hub & spoke” strategy must be adopted and not the current “doughnut” strategy. Kendal will be around for many thousands of years to come, which makes the “doughnut” strategy UNSUSTAINABLE (i.e. will not satisfy the needs of future generations). Only the “hub & spoke” is sustainable in the years to come because extra “satellites” can be added. By then the proposed “doughnut” system will make Kendal such an urban sprawl that very few people will wish to live there. To prevent this happening the “hub & spoke” system must be started NOW.
Money is being put before what is best for the health and well-being of the people of Kendal now and in the future (beyond 2025).
The Taylor Report, which puts forward compelling evidence in favour of the “hub & spoke” system, shows that the proposed “doughnut” system is UNSUSTAINABLE and therefore the development of site R170 (being a peripheral Green Gap site) is UNSOUND and must be removed from the LA DPD.
2.0 Not effective
2.1 Not meeting definitions of soundness.
The Government Planning Advisory Service (PAS) defines the requirements for Soundness in the document - "soundness.doc" (Soundness Tool from: http://www.pas.gov.uk/pas/aio/85673 )
Extract from page 6 - Deliverable:
"21. Are there realistic timescales related to the objectives?
i. Sections of the development plan document which address delivery and the timescales for key developments and initiatives.
ii. Confirmation from the local strategic partnership and partner organisations that the timescales are realistic in terms of their contribution to delivery."
Extract from page 8 - Deliverable:
“28. Is it clear who is going to deliver the required infrastructure and does the timing of the provision complement the timescale of the strategy/policies?
i. Confirmation from infrastructure providers that they support the solutions proposed and the identified means and timescales for their delivery.
ii. Representations in respect of infrastructure.
iii. Reports or copies of correspondence on how representations in relation to infrastructure and its timing have been considered and dealt with.”
Extract from page 5 of SLDC document "Kendal Transport Study (Jan12).pdf ”:
Exec Summary (see also 6.1.6 on page 18)
“12. Furthermore, even with the implementation of these improvement schemes, it is important to note that a large proportion of the key junctions would continue to operate above capacity, and therefore experience congestion and extensive queuing in the 2022 base situation. This situation would be compounded by the LDF development traffic.”
I have only selected this one paragraph; there are numerous other paragraphs which support these conclusions. In particular Page 15, Item 5.2.1, Table 5.1 which confirms that all schemes fail to meet SLDC’s objective. The results in Tables 5.2 & 5.3 are even worse.
SLDC’s objective is to meet “Acceptable junction performance” which is defined on page 9, item 4.1.5.
I'm not sure why the year 2022 was chosen as base-line, whatever major infrastructure is planned must enable SLDC to meet their objectives for years beyond 2025. In my opinion until 2040, the end of the next LDF.
Schemes 4, 5 & 6 require major investment and are not in the Core Strategy and therefore must be excluded from the Transport Plan when it is published. Note that the Transport Plan should incorporate extra capacity to cope with the “doughnut” system which, if approved, will undoubtedly continue after 2025.
The SLDC Air Quality Reports show that air pollution is getting worse in Kendal and also the AQMA has been increased.
Extract from page 27 of Air Quality Report (PR_Report_Template_2010.pdf)
(see http://www.southlakeland.gov.uk/downloads/page857/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”. Over many previous years this is typical of SLDC’s attitude towards obeying the law on Air Quality. SLDC action plans have not worked in the past and this is proved by the fact that the AQMA has recently been made larger.
The SLDC document "ED43_Housing Completions 1999 to 2010.doc" plus SLDC updates show that from the beginning of plan period 2003 to end of 2011 (8 years results) the total for South Lakeland is 1690 / 8 = 211 average and of these affordable are 406 / 8 = 51 average (or 24%). Figures for 2006 to 2011 (last 5 years results) are 934 / 5 = 187 average and of these affordable are 264 / 5 = 53 average (or 28%).
Between 2003 and 2011 the number of completions was 1690. At 400 per year the objective was 3200 over this 8 year period, a difference of 1510. To make up this deficit means that over the remaining 14 years (up to 2025) an extra 1510 / 14 = 107 per year will be required. This extra number per year will get a lot higher when the build rate stays below 400 per year.
This is nowhere near the Core Strategy figure of 400 dwellings per year or the percentage affordable figure of 35% and therefore the LA DPD is UNDELIVERABLE. 200 dwellings per year would be a more realistic figure and this is the latest figure that is necessary according to a Kendal Town Council Report (see below).
SLDC have recognised this and have added the word “ambition” to build this number of houses to the LA DPD (see page 7 of the “Land Allocations DPD [Feb 12].pdf ” as an example). This word is not used in this context with regard to numbers in the Core Strategy document. Therefore the LA DPD is UNSOUND with respect to the Core Strategy. The Leader of the Council insisted the numbers in the Core Strategy were achievable within the timescales of the LDF.
The above figures show there was an inward migration of 3 (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 all the partners involved have “signed on the dotted line” that they will meet the LA DPD milestones for all the necessary infrastructure (roads, sewerage, doctors, dentists, schools, etc) that is required. With the proviso that the build will actually take place in the timescales planned. It causes unnecessary stress to local people when unachievable targets are proposed or planned.
Another issue that affects DELIVERABILITY is Brownfield sites (or previously developed land).
It states in "SLDC_Core_Strategy_Document_March2011_sm4web2.pdf " (page 17):
"CS1.2 – The Development Strategy
Priority will be given to the reuse of existing buildings and previously developed land for all new housing development, with a target of ensuring that at least 28% of new housing development takes place on such sites."
The “at least 28%” is also mentioned in CS6.6 (page 85). The 50% in item 7.14 is a mistake, it was the previous target. Now the target has been lowered, and "at least 28%" is said by SLDC to be achievable, the LA DPD must indicate the amount of Brownfield land that is currently available and the targets in each area. The Core Strategy and LA DPD have a requirement to be monitored and targets at least progressed vigorously.
The LA DPD does not mention this requirement; therefore it does not conform to the Core Strategy and is UNSOUND. Also these monitored figures need to be published and available to the public.
The SLDC Transport Report (Atkins 2009) 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." There are more similar comments on pages 60 & 71.
Site R170M feeds traffic into Windermere Road and therefore must be removed from the LA DPD until SLDC have met their objectives on Air Quality and Junction Congestion.
Extract from SLDC document "Kendal Transport Study (Jan12).pdf ” page 5 (Exec Summary):
"However, the provision of a new route along Dowker’s Lane (scheme 4) would be required if the Rugby Club development is included. If the Canal Head development is included, the proposed Kendal Northern Development Route (Scheme 5) would be required."
The Canal Head development is more important to Kendal than site R170M therefore because site R170M will add more traffic to Kendal streets it is UNSOUND to build on it. It must be removed from the LA DPD until the Northern Development Route has an approved construction plan and committed funding.
Page 115 of the document “KENDAL Appendix 1.pdf ” (Appendix 1B – Consultation Responses after October 2010) for site R170M states:
“Achieving adequate visibility will be problematic given alignment of road and limited frontage. Such a large site would require a secondary access (Cumbria County Council – Highways).”
The conclusions reached by a chartered civil engineer who has carried out measurements to Transport Standards of the proposed access to site R170M are as follows:
“There is severely restricted forward visibility on both bends in Burneside Road either side of the proposed access location.
In either scenario tested the visibility from the proposed access towards Kendal falls far short of the standard required.
A new junction cannot be safely introduced in this location.”
This report can be supplied if required.
It cannot be right not to identify this secondary access. When it is identified there will be a lot more opposition to site R170 than is currently expressed.
As I said at the beginning of this response about including “JUSTICE” and “FAIRNESS”, it is not FAIR to include a site which is likely to have “show stopping” problems without first carrying out a thorough investigation into these particular problems.
Given the evidence above, until it can be proved that both access roads can be built to meet the Transport Standards, the development of the site R170 is UNSOUND and it must be removed from the LA DPD.
The site R170M is still 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 site R170M is not removed from the LA DPD.
This is a very important reason why site R170M should not be developed – JUSTICE.
Extract from page 137 item 6.9 of the Inspector's Report on the public enquiry in 1996. Green Gap site R170M is the site mentioned below.
"Inspector's Conclusions:
6.9 The objection by Mr Downham [biased land owner] is not concerned with the provision of a green gap, but the extent of that gap. It is argued [land owner’s words] that the green gap, as shown in the Consultation draft of the Plan, follows a public footpath running between substantial hedges, a clearly defined landscape boundary: whilst the residential allocation at Sparrowmire has been reduced in the Deposit Draft, an equivalent extension to the green gap is not necessary. ^However, and most importantly in my view, the objection indicates that the "land should remain unallocated as white land so that when the Plan is reviewed in 10 years' time it can be considered as potential residential land" [land owner’s words]. I consider this underlying reason for excluding the land from the green gap identifies the very reason it should remain so designated. Structure Plan Policy 14 and the reasoned justification makes no reference to the length of time during which the vulnerable areas of countryside between settlements should be protected.^ Although policies and proposals in the Local Plan must clearly relate to the Plan period, and can be subject to review thereafter, it appears to me common sense that what is unacceptable now, will most probably be equally unacceptable at the end of the Plan period: certainly I consider the Plan should seek to engender a degree of public confidence that the separation secured will not, at some future time, be lightly squandered. ^For these reasons I believe that, where a green gap is seen as necessary, it is more important that the whole gap between the settlements should be designated as green gap than that substantial, but arbitrary landscape features should be rigidly followed. I also consider the inter-visibility of settlements is not a factor which should affect the definition of green gaps."^
I have marked with ^...^ the most important words in the above paragraph and my clarifying words are in square brackets.
The first group of sentences marked ^...^ indicates that the owner wished to leave the remaining land (now site R170M) as white land, so it can sold as high priced building land at a later date. The inspector states that this is the very reason it must remain as a Green Gap and because of this statement it is Green Gap. The LA DPD only includes Green Gap site R170M because the owner is keen to sell and make a large profit, if he didn’t it would not be included.
The second group of sentences marked ^...^ indicates that “the whole gap between the settlements should be designated as green gap”. It must not depend on “landscape features” or “inter-visibility of settlements”, but these are the very reasons that SLDC state as to why site R170M can be built-on.
Site R170M is still currently a Green Gap site and by definition has more protection than all Greenfields.
A Government Inspector’s words made the white land (now site R170M) into Green Gap and must not be ignored. Therefore to include site R170M in the LA DPD until all the more suitable Greenfield sites have been built-on is UNSOUND.
This R170M Green Gap is also land of most value to the existing community as backed up by this statement in ‘The Taylor Review’ (Page 58):
“20. Government policy is to increase the density of new housing as a means to maximising land use and better support local services. New extensions to settlements therefore may be relatively densely designed and built right up against the existing settlement to minimise the number of green fields ‘swallowed up’. However, this will mean they are built on exactly the land of most value to the existing community – the fields or woods at the ends of their gardens, the green edge to the town. Local residents against new development may be accused of ignoring the needs of others for housing, but they have a genuine point. They may not have bought the right to their countryside views, but they certainly have paid for them, and these developments are on exactly the fields of most landscape value to existing residents."
Taylor gives a valid reason why local people should not be labelled with the scorning name NIMBYs’ when they have a good reason and evidence to oppose development in their neighbourhood.
The evidence above shows that the proposed LA DPD numbers for dwellings to be built are UNDELIVERABLE before 2025. If the numbers were reduced to ones that were deliverable and sound there would be no reason to include the peripheral site R170M in the last phase (2022-25) of the LA DPD, since it is a Green Gap and hence has a higher protection than any of the proposed Greenfield sites. Note at this point in time site R170M is still part of a Green Gap.
“The Community Infrastructure Levy is a new levy that local authorities in England and Wales can choose to charge on new developments in their area. The money can be used to support development by funding infrastructure that the council, local community and neighbourhoods.”
(see http://www.communities.gov.uk/planningandbuilding/planningsystem/communityinfrastructurelevy/ )
There is absolutely no evidence in the LA DPD about how much funding SLDC are capable of obtaining from developers from the levy. Their track record in the past has been very poor when negotiating for affordable dwelling percentages. The target over previous years has been 50% but SLDC of only achieved 28%. The target is now 35% which from past results is still just wishful thinking. SLDC are relying on this money to fund infrastructure and other projects. Until SLDC publish real evidence that the money raised from this levy is in excess (there will always be an overspend) of that required, for all the proposals in the LA DPD it is intended for, then the LA DPD is UNDELIVERABLE and UNSOUND.
With the excessive financial demands that will inevitably be placed on each development in terms of school places, direct highway consequences, a 35% affordable housing contribution etc, it seems highly likely that any contribution to an Infrastructure Levy for wider scale projects would be relatively modest and inadequate. These financial implications appear to again confirm that the proposals are UNSOUND.
Until it is certain that the required infrastructure funding will be available within the planned timescales, in order that SLDC meet their objectives on Air Quality and Junction Congestion, then the LA DPD is UNSOUND.
Site R170M will add further traffic to the streets of Kendal. Therefore site R170M must be removed from the LA DPD until the Northern Development Route has a approved construction plan and committed funding in place (see above). Also that it is shown to decrease the traffic levels in the Windermere Road corridor enough for SLDC traffic objectives are met in this area.
3.0 Further evidence in support of why Policy LA2.2 (site R170M) should be removed from the LA DPD.
3.1 Extracts from Kendal Town Council document "KTC_Response.pdf " (Apr 2011)
Page 8 Transport Improvements.
“The Assessment then looked at the impact of the various possible development sites which were then under discussion. The Assessment modelled the impact of various remedial measures that could be taken, ranging from junction improvements to the building of the Inner Relief Road. It concluded that the existing highway network plus proposed improvements would just about accommodate the forecast level of traffic, provided three sites were removed:
• Land within the Shap Road/Appleby Road corridor (Site E23/49 and Sites M8/M35/ M36)
• The Todds, west of Burneside Road (Sites R148/R170)
• Stonebank Green (Sites M39/R676/R103/R675)
There was no solution which permitted these sites to be developed within the parameters given for the Assessment (e.g. no compulsory purchase orders for major junction redevelopment).”
This supports previous evidence that the development of site R170M (The Todds) is UNSOUND
Page 9 section on “Sewer Capacity”
“In addition, United Utilities has concerns about the capacity of the Waste Water Treatment Works, located to the south of Kendal, for which process modelling needs to be carried out. This impacts all the potential development sites in the town.”
I have an email from SLDC dated 27Apr2011 which states:
“The following is based on information and advice provided by United Utilities.
1. United Utilities cannot determine the number of dwellings that will cause Kendal Wastewater Treatment Works (WwTW) to reach process capacity without conducting modelling. The threshold for when capacity is reached is determined by the design capacity of the WwTW and the population that it serves with some headroom designed in to the calculations. This headroom is not excessive as United Utilities cannot design and build for a population that is not already there or where development is not definite.
2. There are local network issues in respect of sewer capacity in the Kendal area . They are primarily centred around the Burneside area as evidenced in the Core Strategy and supporting Land Allocations Document material.
3. South Lakeland District Council does not hold or have access to data/information regarding the catchment area of the Kendal Sewerage Works.”
SLDC/UU admit that the headroom (i.e. spare capacity) is not excessive. Despite this SLDC have no results of any modelling and have not insisted that this modelling be carried out by UU. SLDC do not even know the catchment area for Kendal Sewage Works. There is nothing in the documentation on the SLDC web site to indicate that SLDC do have this information today (a year later). Therefore SLDC do not know how many dwellings can be built before Kendal Sewage Works needs a major upgrade costing many millions of pounds.
United Utilities move their funding from year to year as they see their immediate priorities change, so until they actual “sign on the dotted line” to meet certain dates then their current dates can “be taken with a pinch of salt”. As evidence to support this, the paying customers of Burneside have been waiting over 20 years to get their sewerage fixed and they still have sewage on the streets during heavy rain. So there is no guarantee that the North West Kendal problem will be fixed before 2025.
Site R170M is one of the last sites in the plan to be developed therefore until the above figures are known for the whole of the catchment area and UU & OFWAT have “signed on the dotted line” to meet their agreed dates then the site R170M is UNDELIVERABLE and the LA DPD is UNSOUND.
Page 9 section on “Hydrologic Considerations”.
“However, the mechanisms (some man-made, mostly natural) which are currently managing to keep Kendal free of floods are not well understood. Several of the sites included in the Land Allocations have a history of being badly affected by rainfall. This suggests they have a role to play in mitigating surface run-off and hence flood prevention. If this is correct, development of such sites could trigger flooding in the town - and making the sites themselves flood proof would certainly involve additional expense for developers.
Kendal Town Council believes this is an important omission from the current evidence base, and calls on SLDC to commission a full hydrology study of the area before including the affected sites in any final land allocation. Any remedial infrastructure required to allow these sites to be developed safely would need to be included in the overall infrastructure programme.
Land Allocations affected by this consideration are the lower Hallgarth sites (R169M and R170M), Appleby Road (MK35KM), Natland Beck at Kendal Parks (R107M, R150M), Stock Beck at Castle Green Road (R121M), and Stonecross (R103M), and Blind Beck (R129M)”
There is nothing in the documentation on the SLDC web site to indicate that SLDC have commissioned this study or have any results. Site R170M is mentioned in quote above and so until this study is carried out development of site R170M is UNDELIVERABLE and UNSOUND.
Page 10 Infrastructure.
“3. Sites should not be included in a Final Land Allocations document unless their impact on Kendal’s transport is understood, solutions are agreed with partners, and the impact has successfully passed a rerun of the Transport Assessment. ‘Emerging Option’ sites affected by this are indicated are indicated by an ‘X’ in the ‘Traffic’ column in the Detail by each Land Allocation site starting on page 11.”
Note site R170M has an ‘X’ in the Traffic column, so this site should be removed from the LA DPD until its impact on Kendal’s junction congestion is fully understood.
This section supports previous evidence that site R170M is UNDELIVERABLE and UNSOUND.
3.2 Extracts from Kendal Town Council doc. "KTCResponsePart2toLandAllocation.pdf" (Sep 2011)
Page 5 Doughnut Development
“Taylor contends: ...these developments undermine sustainability. They invariably encourage car use, especially if there are no services or employment within walking distance, with resulting congestion on roads into town. And without local and community facilities of their own, there is little to build social sustainability and cohesion or links between new and existing settlements as there will be little in the way of community life.
This approach to planning is also a recipe for confrontation, “developing exactly the land of most value to the existing community – the fields or woods at the ends of their gardens, the green edge to the town”
(as has been amply demonstrated in Kendal by the response to the Emerging Options consultation process).
Without change we will simply repeat the mistakes of recent decades, creating unattractive developments of housing estates encircling our rural towns and larger villages, and we will fail to stem the trend of smaller villages becoming dormitory settlements of commuters and the retired, ever less affordable for those who work within them. This is not a sustainable future for rural England.
Without strong Land Allocation policies from the Planning Authority, Kendal is heading towards an unsustainable “doughnutted” future.”
This confirms that development of the peripheral Green Gap site R170M is UNSUSTAINABLE and therefore UNSOUND.
Page 6 Recommendation for Kendal
“The Council believes the Planning Authority should follow Taylor and adopt this model in preparing its final Land Allocations policies for Kendal, as the only way in which the NPPF demand for sustainable development can be achieved in the town. It is important to note that this is not in conflict with the Core Strategy positioning of Kendal as a Principal Service Centre, or with the requirements for meeting forecast housing demand. From Taylor, the requirements for sustainable development in rural market towns is clear: it cannot be delivered by allocating isolated sites around the town; a hub and spoke model is required. Even without the NPPF’s insistence on sustainable development, there are other intrinsic advantages to the hub and spoke model for Kendal. The Council’s previous Response to Consultation highlighted the major infrastructure challenges to be overcome in the town. These become far more soluble if development proceeds on hub-by-hub basis, when the infrastructure work can be concentrated on the corresponding spokes. For example, it is far simpler to improve bus services, cycling provision, etc. if only one or two ‘spokes’ have to be addressed.
The evidence in the EHLSS shows that there are suitable sites available (the scope of the SHLAS only covered sites within existing settlement boundaries, and is of less relevance), and there are options both for completely new communities on green field sites, or for breathing new life into existing communities.”
This confirms that the “doughnut” strategy is incorrect for Kendal and should be replaced by the “hub & spoke” strategy. It also confirms that the peripheral Green Gap site R170M is unsustainable and therefore UNSOUND.
Page 10 Latest Forecasts (2011)
“The latest forecast in this series was produced in Spring 2011. It shows a drastically reduced requirement:
• only 360 dwellings across the 20 years, or
• just over 4,000 including migration, projected on the last five years’ evidence.
This suggests that a more appropriate target for the next 5-10 years would be around 200 dwellings per annum.”
This confirms the evidence given above that 200 per year is what is required and this number would be deliverable. If this number was planned then the peripheral Green Gap site R170M would not be required and being in the last phase would not be needed in this LA DPD.
This section supports previous evidence that the LA DPD is UNSUSTAINABLE and UNSOUND.
3.3 Extracts from Kendal Town Council doc. “Land Allocations Representation (2).pdf “ (Mar 2012)
Page 4 Summary
“The Council believes that the DPD is not justified because it fails the following tests of soundness:
• the LPA has failed in its duty to compare against reasonable alternatives
• key decisions are not supported by the evidence base or the evidence supports a different conclusion
• the evidence base is incomplete
The DPD is also not effective in that it is not deliverable, with key elements of the dependent infrastructure
not understood.”
This confirms the LA DPD is NOT DELIVERABLE.
Page 4
“For rural market towns, the evidence was pulled together in July 2008 by the Taylor Review9, setting out the policy framework necessary to deliver the “vision of a living, working sustainable countryside”. Taylor provided compelling evidence that “doughnut development” was the wrong approach for sustainable rural market towns, and that a “hub and spoke” model represented the best pattern for sustainability.”
The two KTC paragraphs above confirm that an alternative system must be adopted now, which will “meet the needs of future generations” of Kendal (i.e. BE SUSTAINABLE”) for the many thousands of years to come.
Page 4
“The evidence in the EHLSS indicates that suitable sites could be available (the scope of the SHLAA only covered sites within existing settlement boundaries, and is of less relevance), and there are options both for completely new communities on green field sites, or for breathing new life into existing communities.”
This confirms that a “hub & spoke” is viable.
Page 5
“The Assessment concluded that the existing highway network plus proposed improvements would just about accommodate the forecast level of traffic, provided three large sites were removed. The consultants could find no mitigation which would permit these sites to be developed within the parameters given for the Assessment (e.g. no compulsory purchase orders for major junction redevelopment.)”
This confirms that site R170M must be removed from this LA DPD because it is one of the three sites.
Page 5
“Given that this approach has differed significantly from the independent consultants’, the Council asks the Inspector to order an independent audit of this latest work by W.S.Atkins or equivalent to ensure it meets accepted professional standards of objectivity and integrity. The Council further asks the Inspector to ensure that no sites are included in the DPD which the evidence shows are not deliverable on transport grounds.”
This confirms that site R170M must be removed from this LA DPD, because it is one of the sites which “are not deliverable on transport grounds.”
Page 7
“The Council asks the Inspector to withhold approval of the DPD until there is a credible infrastructure plan showing the impact of the major sites on the overall town infrastructure, and with high level solutions identified and costed with enough detail to enable the economic deliverability of the sites to be proven.”
This adds to the evidence given above that there must be signatures, to supply the necessary infrastructure and funding, must be in place before this LA DPD is approved by the Government. Until this is done site R170M is UNDELIVERABLE and UNSOUND.
This section supports previous evidence that site R170M is UNDELIVERABLE and UNSOUND.
3.4 Extracts from SLDC document "Kendal Transport Study (Jan12).pdf ”:
Page 5 Exec Summary (see also 6.1.6 on page 18)
"10. The LDF developments have a more notable impact in the AM peak compared to the base situation. The model results indicate that the provision of sustainable transport improvements (Scheme 2) would be required to support LDF development to nil-detriment compared to the 2022 base situation in the AM peak. However, the provision of a new route along Dowker’s Lane (scheme 4) would be required if the Rugby Club development is included. If the Canal Head development is included, the proposed Kendal Northern Development Route (Scheme 5) would be required.
11. It should be noted that although these schemes are required to achieve nil-detriment, these improvements are only demonstrated to offer marginal benefits to the performance of junctions in Kendal. These infrastructure schemes would be expensive and may not be a cost-effective solution to congestion in Kendal town centre.
12. Furthermore, even with the implementation of these improvement schemes, it is important to note that a large proportion of the key junctions would continue to operate above capacity, and therefore experience congestion and extensive queuing in the 2022 base situation. This situation would be compounded by the LDF development traffic.
13. It is recommended that further modelling work is undertaken"
The Transport Study shows that the objectives cannot be achieved before 2025 therefore the problems are going to be much worse in the years 2026 onwards.
SLDC do not have signed-off solutions and timescales in place to meet the plan phases, therefore the LA DPD is UNDELIVERABLE and UNSOUND.
Page 9 This page gives the CCC/SLDC definition for Junction Congestion limits.
"Acceptable junction performance is indicated by a degree of saturation below 90 percent for signal-controlled junctions, or an RFC below 85 percent for priority junctions and roundabouts."
The Atkins report uses a Volume/Capacity ratio of 90 as acceptable for a junction approach, which is similar.
The Study shows that these objectives will not be met by 2025 so this, along with page 10 (see below) adds evidence to the above.
Page 10
"4.2.2 In total 13 junctions are indicated to have a maximum RFC greater than or equal to 90% in the 2010 base year, in either the AM or PM peak period. These are:Junction1: A5284 Stricklandgate/Sandes AvenueJunction 2: A5284 Sandes Avenue / A6 Blackhall Road signalised junction
Junction 5: A6 Longpool / Station Road mini-roundabout junction
Junction 12: A6 Highgate / Lowther Street signalised junction
Junction 22: Parkside Road / Valley Drive priority junction
Junction 16: A6 Milnthorpe Road / Romney Road signalised junction
Junction 17: A5284 Windermere Road/Queens Road
Junction 18: A5284 Windermere Road/Burneside Road
Junction 21: A65 Burton Road / Oxenholme Road signalised junction
Junction 27: A684 Sedbergh Road / Sandylands Road priority junction
Junction 29: A6 Shap Road / A685 Appleby Road (north) priority junction
Junction 30: A6 Shap Road / A685 Appleby Road (south) priority junction
Junction 31: A685 Appleby Road/Sandylands Road"
“Measures must be in place” to fix these major problems first (i.e. meet SLDC objectives). They have a huge bearing on why SLDC is still breaking the law on Air Quality.
Page 14
“* Scheme 6: Scheme 5, plus a potential Kendal Southern Link Road, which comprises a new single-carriageway road linking the A6 Milnthorpe Road with the A65 Burton Road south of Kendal town centre.”
This new road proposal has never been mentioned before; it is not in the Core Strategy and therefore, as we have been told before, it cannot be considered in this LDF.
This section supports previous evidence that site R170M is UNDELIVERABLE and UNSOUND.
3.5 Extracts from SLDC document "06 Infrastructure Position Statement.pdf ”:
Page 10
"4.19 United Utilities has a statutory duty to develop and maintain an efficient and economical system of water supply within its area. A proposal for expenditure in the years 2010 – 2015 is contained within the published five years Investment Plan (Asset Management programme). The plan can be found at the following website link: http://www.unitedutilities.com/Documents/Detailed_plan.pdf "
There is nothing in this PDF document that is specific to Kendal.
UU may have "a statutory duty to develop and maintain an efficient and economical system of water supply within its area" but it is very poor at obeying this duty as is verified by the > 20 years Burnside have been suffering sewage problems (and still are).
Until UU actually “sign on the dotted line” to meet the required planned timescales and commit funding, the LA DPD is UNDELIVERABLE and UNSOUND.
Page 11
"4.23 Funding is more likely to be acquired in cases where there is development certainty (i.e. clear evidence of developer interest).
* UU reiterate that even if a bid is submitted there is no guarantee funding will be approved by OFWAT. The speed at which approved schemes are implemented will depend on the priority given to schemes within the 5-year programme and the time required to design, obtain planning permission and construct."
This backs previous evidence, never mind “development certainty” what about the existing paying customers who are still suffering sewage and flooding problems due to lack of investment.
Until United Utilities “sign on the dotted line” and commit to planned dates and funding the LA DPD is UNDELIVERABLE and UNSOUND.
Page 11
"4.24 There is currently loading capacity at Kendal Waste water Treatment Works (WwTW), however, for the number of dwellings that are proposed a full process and hydraulic survey of the Works will have to be undertaken before UU could comfortably approve the Planning Applications. As the sewer network is at capacity in North Kendal, UU could not agree to any significant development until after 2015 in this part of the town. Providing UU obtain funding through OFWAT to undertake the necessary upgrades etc. UU will be building into the 2014 Business Submission to OFWAT a case for funding to provide the means to accommodate development, which will boost the economy.
4.25 A feasibility study is being undertaken on the Kendal WwTW. Recommended phosphorous levels are set by Environment Agency (EA) through discharge consents, and until EA impose a new requirement for a lowered rate, UU will continue to discharge at the current rate. UU stated achieving any required lower rates would depend on new/better technology. Further Phosphorous removal would only be undertaken if UU were required to achieve a tighter standard as set by the EA following their review of water quality. Newer technology, which is not currently available, would be required to achieve any standard below 1mg/l. UU has advised development in the Kendal area should be capped at 2000 properties unless a more stringent phosphorus effluent standard can be achieved.
4.26 UU has advised that sites in North Kendal should only come forward in the latter periods of the plan period when sewage network improvements are in place.
4.27 Strategically there is enough water supply to accommodate levels of new development, but there are potential risks of deterioration of water quality."
Until OFWAT “sign on the dotted line” and commit to planned dates and funding the LA DPD is UNSOUND.
Page 14
"4.45 Electricity North West Ltd manage infrastructure and distribute and transmit electricity throughout South Lakeland. The regulator determines the amount of funding, however, it is not known what the next round of funding may or may not allow for investment in improvements. Information relating to substation capacity has not been ascertained. Evidence when exploring options for the Canal Head Area of Kendal shows that the Kendal Primary substation is currently operating close to or at capacity. It is possible that significant development in Kendal would require investment for network reinforcement and that a new Primary Substation would be required although Electricity North West Ltd does not confirm this. No information has been made available stating whether this is the case. Only when the customer has firm load requirements and location details can a system study be undertaken to ascertain the scale of impact of potential new development."
What if the system study states it cannot be done or they cannot obtain the funding within the plan timescales? Electricity North West Ltd already has the number of houses proposed and their locations so they must commit to a system study and confirm that the proposed developments are deliverable. Until then the LA DPD is UNSOUND.
Page 15
"4.48 National Grid Gas Distribution own and operate the local gas distribution network in South Lakeland. The confidential nature of the process means National Grid are unable to confirm whether they are currently processing or have made any offers for connection within Cumbria."
The document states nothing about National Grid Gas Distribution having a statutory duty to develop and maintain an efficient and economical system of gas supply within its area.
The LA DPD cannot possibly be monitored correctly until all the Gas company has “signed on the dotted line” to meet the timescales required. Until then the LA DPD is UNDELIVERABLE and UNSOUND.
This Infrastructure document is only a statement; there is no indication when the Infrastructure Delivery Plan will be available to the public or any indication that the timescales can be met. The LA DPD is UNSOUND until the Infrastructure Delivery Plan and the Kendal Transport Plan are available with all milestones agreed, funding committed and both signed off by the respective utility companies. They can have the proviso that it depends on the build going ahead as planned.
3.6 Extracts from SLDC document “01 Consultation Report.pdf ”:
Page 19
“In their response the Highways Agency identified those sites it considers (if developed, due to cumulative impact with other sites) may impact upon the capacity, operation and safety of the strategic road network (SRN) (A590 and M6) within South Lakeland. As a consequence, the Agency has stated that the cumulative impact of development of sites under consideration in the following settlements (see below) may result in some impact to the SRN: Burneside, Crooklands, Endmoor, Kendal, Kirkby Lonsdale, Levens, Milnthorpe and Ulverston alongside the sites suggested for strategic employment use (in Ulverston and Kendal area).”
Note the word “may” on the second line. They either do or they don’t. After all these years of the LDF there is no excuse for this information not being available. SLDC must obtain an answer to this issue immediately and publish it. If any of the developments proposed within the LA DPD do affect the Strategic Road Network then any changes necessary must be included in the LA DPD and the Transport Plan (which must be issued before the hearings). Note the Strategic Road Network is NOT currently mentioned in the LA DPD.
Page 21
This page with reference to Burneside states:
“.....this is no guarantee that funding will be approved by OFWAT”.
Until OFWAT “sign on the dotted” line to meet the planned timescales the LA DPD is UNSOUND.
Page 21
“Additional work is needed by UU to check if cumulative impact on treatment works may raise capacity issues
SLDC must publish how many houses can be built in the Kendal catchment area before a major upgrade to the sewage works is required. Until UU know their total funding requirements the LA DPD is UNSOUND.
Page 34
KENDAL
“Many people believe development of the sites suggested would harm the landscape character of the town, worsen air quality, exacerbate current flooding problems, harm biodiversity, generate unacceptable levels of traffic congestion, and place further strains on a heavily constrained sewerage system. Some people questioned the need for additional housing believing there are enough empty properties in the town to meet current and future housing demands. A number of people stated development should be prioritised on brownfield sites and meet primarily local needs.”
“Many people including Kendal Town Council and Burneside and Natland Parish Council’s supported the concept of green gaps to protect Kendal coalescing with neighbouring settlements. However, a significant number of people and Kendal Town Council and Natland Parish Council believed the suggested emerging options would not prevent coalescence from happening. There was general widespread support for the open space designations suggested, however, many people believed the emerging options sites should also be designated open space.”
“Kendal Town Council expressed serious concerns with the overall approach being suggested for the town, believing the amounts of developments and the emerging option sites suggested would damage the landscape character of the town, and put unnecessary strain on an inadequate infrastructure system. The Town Council has suggested an alternative strategy/approach for the town this being to protect existing green space/countryside surrounding the town and to look at alternative sites adjacent to nearby settlements and possibly further afield where development would have less impact on the town’s infrastructure, air quality and its high quality landscape value.”
These three paragraphs confirm that the wishes of the majority of local people have been ignored and adds support to the evidence given above concerning Consultation and Legal Compliance.
Page 46
On this page it states “UU is currently considering lists of projects that will require major capital investment in Asset Management Plan 6 period 2015-2020.” and “UU reiterate that even if a bid is submitted there is no guarantee funding will be approved by OFWAT. The speed at which approved schemes are implemented will depend on the priority given to schemes within the 5-year programme and the time required to design, obtain planning permission and construct.”
Until United Utilities and OFWAT “sign on the dotted line” to meet the planned timescales and commit funding, the LA DPD is UNDELIVERABLE and UNSOUND.
This section supports previous evidence that site R170M is UNDELIVERABLE, UNSOUND and that consultation process was not Legally Compliant.
3.7 Extracts from SLDC document “Land Allocations DPD.pdf ” [Mar12]:
Pages 51 & 52
Item 3.6 - Key local factors influencing the location of new development in Kendal:
“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; Avoiding coalescence between Kendal, Oxenholme, Burneside and Natland and maintaining the separate identities of these settlements;
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;
Infrastructure constraints including sewage capacity at Kentrigg and Steele's Row and the implications for development in northwest Kendal.”
One of the main comments of the people who responded to the SLDC consultations and opposed them was the character and appearance of Kendal. This is imbedded in the above paragraph and has been totally ignored. The LA DPD is therefore not Legally Compliant.
The site R170M is close to Kentrigg (mentioned above) and so it is UNSOUND to include it in the LA DPD until United Utilities are fully committed (i.e. signed on the dotted line) to the LA DPD timescales.
The sentence “Minimising the impact of development on Kendal’s central traffic system, …..” is not definitive it should state “Meet and maintain SLDC’s standards and objectives with regard to Kendal’s central traffic system, …..”
Page 163 APPENDIX 4 - HOUSING TRAJECTORY
A graph on this page it shows the following numbers over the years 2003 – 2025 (22 years).
Maximum number of dwellings ever built in one year was 300 in year 2005/06 and even this did not reach the target of 400 per year.
Extrapolating from the graphs the average number of dwellings built per year for the first 8 years was 100+280+150+150+240+300+230+220 = 1670 / 8 = 209 per year. In the terms of this graph there are already an extra 1530 dwellings (109/yr on top of the 400/yr) that have built just to catch up. This compares well with the more accurate figures in section 2.1 above.
The figure of 720 per year for the three years 2022 – 2025 is just WISHFULL THINKING.
One of the questions that must be asked to confirm SOUNDNESS is “Are there realistic timescales related to the objectives”. The above numbers are clearly not realistic therefore the current LA DPD is UNSOUND.
This section supports previous evidence that site R170M is UNDELIVERABLE and UNSOUND within the timescales of this LA DPD (2025).
4.0 Changes required to the LA DPD document title “Land Allocations DPD.pdf ” [Mar12]:
4.1 During the recent SLDC consultation 98% of the local neighbourhood who responded OPPOSED the proposals for site R170M. In a door-door poll of over 400 neighbours during 2011 approximately 80% of those asked OPPOSED the proposal to build on site R170M. Of the remaining 20% most did not care one way or the other. The Localism Bill is a Con Trick (nice pun); it promises much but does not actually support what the majority of the people in the neighbourhood want.
To prove SLDC are DEMOCRATIC they must be serious about responding to the majority of the local neighbourhood’s wishes. Also the TOTAL CONCLUSIVE EVIDENCE ABOVE PROVES THAT SLDC MUST REMOVE THE PERIPHERAL GREEN GAP SITE R170M FROM THE LA DPD TO MAKE IT SOUND. THIS IS HOW THE LA DPD MUST BE CHANGED.
4.2 After many years (before year 2000) of knowing about the traffic problems in Kendal, SLDC have failed to produce a transport plan or action plan that enabled them to meet their standards and objectives for Air Quality and Junction Congestion. This must NOT be allowed to continue. Only when these standards and objectives have been PROVEN to have been met (with spare capacity for expansion) will the people believe SLDC are serious about tackling these major problems. The recent SLDC consultations show that increase in traffic was one of main reasons why 98% of the people (that responded) OPPOSE the proposals to build on sites in their area of Kendal.
Previous experience with Core Strategy has shown me that all my evidence will be ignored and that site R170M will not be removed from the LA DPD. If this is to be repeated then I would like to see the following changes to LA DPD.
There is a note on page 57 (item 3.18) of the LA DPD (policy LA2.2 site R170M) which states:
"DEVELOPMENT OF THIS SITE CANNOT TAKE PLACE UNTIL MEASURES ARE IN PLACE TO RESOLVE PRESSURE ON THE SEWERAGE NETWORK IN NORTH KENDAL."
This means existing problems will be fixed before building starts.
THIS SETS A PRECEDENT WHICH MUST CONTINUE WITH REGARD TO OTHER MAJOR PROBLEMS.
The threat to the health of people due to air pollution is of as much importance as sewage on the streets. Site R170M will add more traffic to the streets of Kendal and make air pollution worse. Therefore a note must be added to Policy LA2.2 (item 3.18) that states:
"DEVELOPMENT OF THIS SITE CANNOT TAKE PLACE UNTIL MEASURES ARE IN PLACE TO SHOW THAT THE LAW ON AIR QUALITY HAS BEEN MET IN KENDAL."
Increase in traffic, which leads to more junction congestion and a deterioration in the well-being of local people, was one of the major complaints in the recent SLDC consultations. Site R170M will add more traffic to the streets of Kendal and make junction congestion worse. Therefore a note must be added to Policy LA2.2 (item 3.18) that states:
"DEVELOPMENT OF THIS SITE CANNOT TAKE PLACE UNTIL MEASURES ARE IN PLACE TO SHOW THAT SLDC’S DEFINITION OF “ACCEPTABLE JUNCTION PERFORMANCE” HAS BEEN MET IN KENDAL."
For definition see page 9 of “Kendal Transport Study (Jan12).pdf”.
“4.1.5 An RFC or DoS of 100% indicates that an approach is operating at maximum capacity. Acceptable junction performance is indicated by a degree of saturation below 90 percent for signal-controlled junctions, or an RFC below 85 percent for priority junctions and roundabouts. Above this level, an approach is likely to begin to experience congestion as there is insufficient spare capacity to cope with fluctuations in traffic flow.”
4.3 Page 51 item 3.6:
The sentence “Minimising the impact of development on Kendal’s central traffic system, …..” is not definitive. The word “Minimising” is just not good enough to meet the people’s wishes. It must state “Meet and maintain SLDC’s standards and objectives with regard to Kendal’s central traffic system, …..”
4.4 Page 163 APPENDIX 4 - HOUSING TRAJECTORY
This Appendix 4 must be changed and other pages which quote these figures. The SLDC evidence does not support the requirement that anywhere near the 8800 dwellings can be built before 2025. The numbers in the graph are not realistic (a SOUNDNESS word), therefore NOT DELIVERABLE and UNSOUND. 720/year for last three years is just wishful thinking, it is not realistic; this graph shows that the maximum that has ever been built within the last 8 years is 300 per year for the year 2005/06. The developers will not build 750 per year because it would swamp the market and they would be left with a large number of empty houses.
There is no point in just stating on page 7 of the LA DPD that it is “the ambition to deliver 400 dwellings each year” if these numbers cannot realistically be built and sold. There is also no point in just monitoring these numbers just so a box can be ticked to say they have been monitored. The numbers must be realistic so that they can be monitored and vigorously progressed.
Kendal Town Council have stated in one of their reports [Sep2011 see above] that only around 200 dwellings per year is the number required. SLDC must discuss this issue with KTC and reduce the current total figure of 8800 to a number that can realistically be built & sold before 2025 and not one that is just WISHFULL THINKING.
4.5 There is a requirement in the Core Strategy for Brownfield land to be used for “at least 28%” of the number of dwellings built. Note the words are “at least” not it is the “ambition to use”. To be SOUND the LA DPD must indicate the amount of Brownfield land that is currently available and the targets for each area. These figures must be monitored, vigorously progressed and be made available to the public.
4.6 SLDC must discuss Kendal Town Council’s three reports in detail with the town council and members of opposition groups (e.g. Green Spaces). I would like to see the LA DPD changed to incorporate as much as possible of that which is agreed in these discussions.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
THE HEALTH AND WELL-BEING OF LOCAL PEOPLE MUST BE AT THE TOP OF SLDC's PRIORITY LIST and despite all my emails and protest at the Core Strategy hearings this has not yet been done in Kendal.
So I wish to speak face to face with the inspector and ask him personally if he will recommend in his report that notes be added to the LA DPD stating that SLDC must fix their major existing problems first and meet the SLDC/CCC definition for "Acceptable Junction Congestion" and the Law on Air Quality before allowing actual build of site R170M, which will add to these problems (see examples of notes in section 4.2 above).
A PRECEDENT has already been set by a note in Policy LA2.2 for site R170M relating to the sewerage network in North Kendal. If United Utilities have to fix their major existing problems first before building is allowed then so must SLDC, this is logical and should not need a political decision.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
914. Mr Derek Whitmore (Individual) : 17 May 2012 10:58:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.7 Business and Science Park Sites - M2M-mod KENDAL LAND EAST OF BURTON ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
1.0 Consultation
1.1 SLDC did not change the proposals in-line with the citizens important wishes.
The Government Planning Advisory Service (PAS) defines the requirements for Legal Compliance in it’s document – "legal.doc” (Legal Compliance Tool from http://www.pas.gov.uk/pas/aio/85651 )
Extract from Stage 2: Plan preparation - frontloading phase (page 7):
“6. Does the consultation contribute to the development and sustainability appraisal of alternatives?”
This has not been carried out correctly, alternatives have not been seriously considered. In particular the Kendal Town Council’s excellent reports, containing good alternatives, have been ignored.
The vast majority of the oppose responses made in the SLDC consultations were noted, listed in the consultation documents and then almost totally ignored. In my view these consultations were just so that SLDC could “tick the box” for the government inspector and therefore were a waste of taxpayers money.
I have done a detailed examination of the SLDC Consultation Database and these are my findings:
On 11th August 2011 (after the closing date) there were 2986 responses from the Kendal settlement. 98% of these responses opposed the proposals in their neighbourhood. Most of those that “support in part” did not support housing. Most of the few indicating “support” were representatives of the land owner, potential builder, Kendal Futures Board or the North West Development Agency.
The main reasons for the respondents opposition was the increase in traffic that these proposed developments would cause, and the affect they would have on the landscape character of Kendal. Better alternative sites were suggested, noted and then ignored. The present proposals will not “satisfy the needs of future generations” and are therefore NOT SUSTAINABLE.
Issues raised in the consultations would have contributed greatly to the development and sustainability of alternatives but the alternatives put forward have been ignored (also see other evidence 2.3 below). Therefore the LA DPD it is not Legally Compliant.
I would like to see alternatives discussed with Kendal Town Council and the Green Spaces group. Then any changes agreed included in the LA DPD.
2.0 Alternative plan
2.1 Law must be obeyed.
Extract from Stage 2: Plan preparation - frontloading phase (legal.doc page 5):
“* developing alternatives and options and appraising them through sustainability appraisal and against evidence.”
The SLDC Air Quality reports show that SLDC have been breaking the Law on Air Quality for many years. It means that SLDC must use an alternative plan for Kendal until it is proven that the law is being obeyed (with spare capacity for proposed development). The reason the law must be proven is that action plans have not worked for at least 14 years (before 1998). In the meantime affordable houses can be built in other areas of SLDC which have low traffic.
Until an alternative plan is in position to ensure the law on Air Quality is obeyed (with spare capacity for the proposed development) the LA DPD is not Legally Compliant.
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These Legal Compliance requirements are not definitive or closed questions; they are open to personal interpretation, so I will not make any further comment in these sections.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Personal Comments:- From my experience of the Core Strategy hearings and the SLDC consultations I know my response will be ignored. The changes to Kendal’s infrastructure, that the new SLDC Transport Study (Jan12) states are required (see below), is just one example of this. I am therefore taking this opportunity to place on record all the relevant evidence I have gathered on why site R170M (policy LA2.2) should not be included in the LA DPD. Quotes from certain documents have been added to make it easier for the reader. There is repetition of some issues but this is because I have added different sources of evidence throughout the document.
It is undemocratic just to include Legal Compliance and Soundness in this consultation. In a democratic society the wishes of the majority of local people would have priority over these criteria. Also criteria such as “Justice” and “Fairness” should be considered. These were totally ignored in the Core Strategy consultation and hearings.
Test of Soundness
1.0 Not justified
1.1 Health and well-being of citizens in Kendal.
I have been informed that a developer does not have to fix an existing problem he just needs to show that he will not make it any worse. This is ridiculous, while SLDC are breaking the law on Air Quality developers must not be allowed to build on site R170M and other Kendal sites until the law is obeyed. SLDC breaking the law must surely be enough to prevent developers from winning an appeal. The people’s health and well-being must have top priority over everything else in the LA DPD.
The latest Cumbria County Council’s transport plan LPT3 does not include plans for the necessary infrastructure to fix existing problems neither does the SLDC Core Strategy. It was only after pressure from the public that SLDC & CCC produced the Transport Study (which is only a study) and after all this time the Transport Plan has not yet been made available to the public. Without a Transport Plan (including committed funding) signed off by all the participants the LA DPD is UNDELIVERABLE within the current timescales (2025) and is UNSOUND.
Before the year 2000 the SLDC objective was to meet the law on Air Quality by the year 2005 but air pollution has continually increased and the AQMA (Air Quality Management Area) has even been made larger. This shows that SLDC are not serious in meeting their objectives where the health and well-being of citizens, or obeying the law, are concerned.
A typical example is the approval of the Planning Application for the old Auction Mart site. Also planning approval is certain to go ahead for the Canal Head development. These will make the air pollution worse in the AQMA. The worst pollution occurs when junctions are grid-locked and tinkering with traffic lights will not fix this problem. It will take major infrastructure changes to fix the existing traffic problems and allow for proposed LDF expansion. The Transport Study even admits that none of the improvements schemes will meet SLDC objectives.
Extract from SLDC document "Kendal Transport Study (Jan12).pdf ”:
“6.1.6 Furthermore, even with the implementation of these improvement schemes, it is important to note that a large proportion of the key junctions would continue to operate above capacity, and therefore experience congestion and extensive queuing in the 2022 base situation. This situation would be compounded by the LDF development traffic.”
More building is planned in Kendal within the next few years (phase 1). This will make the major traffic problems worse. Infrastructure should already be in place to cope. Instead there is not even an approved Transport Plan in place, never mind the infrastructure that will be needed to meet SLDC standards and objectives.
The Transport Study is stating that further modelling is required. This shows that SLDC do not yet know at the present time if their proposals can be implemented or if funding will be available within the LDF timeframe (year 2025), therefore the LA DPD is UNSOUND. Once money has been spent on major infrastructure changes it will be expected that these changes will last for at least 15 years (through the next LDF) therefore any further modelling must use a date of 2040 or beyond. These results will prove that the Taylor “hub & spoke” must be started now (see more evidence below).
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. The health of residents of Kendal town should also cause great concern; a lot of them are elderly and frail.
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.
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 LA DPD maps for the SLDC district, have not been included on the latest maps. It is not fair that these traffic problems are not shared throughout the entire SLDC district. This is another reason why the hub & spoke system must be adopted – FAIRNESS.
The health and well-being of the people due to air pollution must have top priority over everything else in the LDF. This is not happening with the current proposals. Proving the law is being obeyed must come second on the priority list after health. If it does not already do so the “Soundness” examination must take account of these two very important issues.
The evidence above shows that these traffic problems in Kendal will not be fixed without major infrastructure changes which are not in Cumbria County Council’s LTP3.
Site R170M will add further traffic to the streets of Kendal. Therefore the LA DPD is UNSOUND and site R170M must be removed from the LA DPD until the Northern Development Route has an approved construction plan and funding (see above).
For more evidence see extracts from the SLDC Transport Study (Jan12) below.
1.2 Alternative strategy.
Although SLDC have carried out consultations they have ignored the major objections. They have even ignored the alternatives put forward by Kendal Town Council in their excellent reports - “KTC_Response.pdf ”, “KTCResponsePart2toLandAllocation.pdf ” & “Land Allocations Representation (2).pdf. ". To avoid even more “urban sprawl” of Kendal the Taylor “hub & spoke” strategy must be adopted and not the current “doughnut” strategy. Kendal will be around for many thousands of years to come, which makes the “doughnut” strategy UNSUSTAINABLE (i.e. will not satisfy the needs of future generations). Only the “hub & spoke” is sustainable in the years to come because extra “satellites” can be added. By then the proposed “doughnut” system will make Kendal such an urban sprawl that very few people will wish to live there. To prevent this happening the “hub & spoke” system must be started NOW.
Money is being put before what is best for the health and well-being of the people of Kendal now and in the future (beyond 2025).
The Taylor Report, which puts forward compelling evidence in favour of the “hub & spoke” system, shows that the proposed “doughnut” system is UNSUSTAINABLE and therefore the development of site R170 (being a peripheral Green Gap site) is UNSOUND and must be removed from the LA DPD.
2.0 Not effective
2.1 Not meeting definitions of soundness.
The Government Planning Advisory Service (PAS) defines the requirements for Soundness in the document - "soundness.doc" (Soundness Tool from: http://www.pas.gov.uk/pas/aio/85673 )
Extract from page 6 - Deliverable:
"21. Are there realistic timescales related to the objectives?
i. Sections of the development plan document which address delivery and the timescales for key developments and initiatives.
ii. Confirmation from the local strategic partnership and partner organisations that the timescales are realistic in terms of their contribution to delivery."
Extract from page 8 - Deliverable:
“28. Is it clear who is going to deliver the required infrastructure and does the timing of the provision complement the timescale of the strategy/policies?
i. Confirmation from infrastructure providers that they support the solutions proposed and the identified means and timescales for their delivery.
ii. Representations in respect of infrastructure.
iii. Reports or copies of correspondence on how representations in relation to infrastructure and its timing have been considered and dealt with.”
Extract from page 5 of SLDC document "Kendal Transport Study (Jan12).pdf ”:
Exec Summary (see also 6.1.6 on page 18)
“12. Furthermore, even with the implementation of these improvement schemes, it is important to note that a large proportion of the key junctions would continue to operate above capacity, and therefore experience congestion and extensive queuing in the 2022 base situation. This situation would be compounded by the LDF development traffic.”
I have only selected this one paragraph; there are numerous other paragraphs which support these conclusions. In particular Page 15, Item 5.2.1, Table 5.1 which confirms that all schemes fail to meet SLDC’s objective. The results in Tables 5.2 & 5.3 are even worse.
SLDC’s objective is to meet “Acceptable junction performance” which is defined on page 9, item 4.1.5.
I'm not sure why the year 2022 was chosen as base-line, whatever major infrastructure is planned must enable SLDC to meet their objectives for years beyond 2025. In my opinion until 2040, the end of the next LDF.
Schemes 4, 5 & 6 require major investment and are not in the Core Strategy and therefore must be excluded from the Transport Plan when it is published. Note that the Transport Plan should incorporate extra capacity to cope with the “doughnut” system which, if approved, will undoubtedly continue after 2025.
The SLDC Air Quality Reports show that air pollution is getting worse in Kendal and also the AQMA has been increased.
Extract from page 27 of Air Quality Report (PR_Report_Template_2010.pdf)
(see http://www.southlakeland.gov.uk/downloads/page857/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”. Over many previous years this is typical of SLDC’s attitude towards obeying the law on Air Quality. SLDC action plans have not worked in the past and this is proved by the fact that the AQMA has recently been made larger.
The SLDC document "ED43_Housing Completions 1999 to 2010.doc" plus SLDC updates show that from the beginning of plan period 2003 to end of 2011 (8 years results) the total for South Lakeland is 1690 / 8 = 211 average and of these affordable are 406 / 8 = 51 average (or 24%). Figures for 2006 to 2011 (last 5 years results) are 934 / 5 = 187 average and of these affordable are 264 / 5 = 53 average (or 28%).
Between 2003 and 2011 the number of completions was 1690. At 400 per year the objective was 3200 over this 8 year period, a difference of 1510. To make up this deficit means that over the remaining 14 years (up to 2025) an extra 1510 / 14 = 107 per year will be required. This extra number per year will get a lot higher when the build rate stays below 400 per year.
This is nowhere near the Core Strategy figure of 400 dwellings per year or the percentage affordable figure of 35% and therefore the LA DPD is UNDELIVERABLE. 200 dwellings per year would be a more realistic figure and this is the latest figure that is necessary according to a Kendal Town Council Report (see below).
SLDC have recognised this and have added the word “ambition” to build this number of houses to the LA DPD (see page 7 of the “Land Allocations DPD [Feb 12].pdf ” as an example). This word is not used in this context with regard to numbers in the Core Strategy document. Therefore the LA DPD is UNSOUND with respect to the Core Strategy. The Leader of the Council insisted the numbers in the Core Strategy were achievable within the timescales of the LDF.
The above figures show there was an inward migration of 3 (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 all the partners involved have “signed on the dotted line” that they will meet the LA DPD milestones for all the necessary infrastructure (roads, sewerage, doctors, dentists, schools, etc) that is required. With the proviso that the build will actually take place in the timescales planned. It causes unnecessary stress to local people when unachievable targets are proposed or planned.
Another issue that affects DELIVERABILITY is Brownfield sites (or previously developed land).
It states in "SLDC_Core_Strategy_Document_March2011_sm4web2.pdf " (page 17):
"CS1.2 – The Development Strategy
Priority will be given to the reuse of existing buildings and previously developed land for all new housing development, with a target of ensuring that at least 28% of new housing development takes place on such sites."
The “at least 28%” is also mentioned in CS6.6 (page 85). The 50% in item 7.14 is a mistake, it was the previous target. Now the target has been lowered, and "at least 28%" is said by SLDC to be achievable, the LA DPD must indicate the amount of Brownfield land that is currently available and the targets in each area. The Core Strategy and LA DPD have a requirement to be monitored and targets at least progressed vigorously.
The LA DPD does not mention this requirement; therefore it does not conform to the Core Strategy and is UNSOUND. Also these monitored figures need to be published and available to the public.
The SLDC Transport Report (Atkins 2009) 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." There are more similar comments on pages 60 & 71.
Site R170M feeds traffic into Windermere Road and therefore must be removed from the LA DPD until SLDC have met their objectives on Air Quality and Junction Congestion.
Extract from SLDC document "Kendal Transport Study (Jan12).pdf ” page 5 (Exec Summary):
"However, the provision of a new route along Dowker’s Lane (scheme 4) would be required if the Rugby Club development is included. If the Canal Head development is included, the proposed Kendal Northern Development Route (Scheme 5) would be required."
The Canal Head development is more important to Kendal than site R170M therefore because site R170M will add more traffic to Kendal streets it is UNSOUND to build on it. It must be removed from the LA DPD until the Northern Development Route has an approved construction plan and committed funding.
Page 115 of the document “KENDAL Appendix 1.pdf ” (Appendix 1B – Consultation Responses after October 2010) for site R170M states:
“Achieving adequate visibility will be problematic given alignment of road and limited frontage. Such a large site would require a secondary access (Cumbria County Council – Highways).”
The conclusions reached by a chartered civil engineer who has carried out measurements to Transport Standards of the proposed access to site R170M are as follows:
“There is severely restricted forward visibility on both bends in Burneside Road either side of the proposed access location.
In either scenario tested the visibility from the proposed access towards Kendal falls far short of the standard required.
A new junction cannot be safely introduced in this location.”
This report can be supplied if required.
It cannot be right not to identify this secondary access. When it is identified there will be a lot more opposition to site R170 than is currently expressed.
As I said at the beginning of this response about including “JUSTICE” and “FAIRNESS”, it is not FAIR to include a site which is likely to have “show stopping” problems without first carrying out a thorough investigation into these particular problems.
Given the evidence above, until it can be proved that both access roads can be built to meet the Transport Standards, the development of the site R170 is UNSOUND and it must be removed from the LA DPD.
The site R170M is still 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 site R170M is not removed from the LA DPD.
This is a very important reason why site R170M should not be developed – JUSTICE.
Extract from page 137 item 6.9 of the Inspector's Report on the public enquiry in 1996. Green Gap site R170M is the site mentioned below.
"Inspector's Conclusions:
6.9 The objection by Mr Downham [biased land owner] is not concerned with the provision of a green gap, but the extent of that gap. It is argued [land owner’s words] that the green gap, as shown in the Consultation draft of the Plan, follows a public footpath running between substantial hedges, a clearly defined landscape boundary: whilst the residential allocation at Sparrowmire has been reduced in the Deposit Draft, an equivalent extension to the green gap is not necessary. ^However, and most importantly in my view, the objection indicates that the "land should remain unallocated as white land so that when the Plan is reviewed in 10 years' time it can be considered as potential residential land" [land owner’s words]. I consider this underlying reason for excluding the land from the green gap identifies the very reason it should remain so designated. Structure Plan Policy 14 and the reasoned justification makes no reference to the length of time during which the vulnerable areas of countryside between settlements should be protected.^ Although policies and proposals in the Local Plan must clearly relate to the Plan period, and can be subject to review thereafter, it appears to me common sense that what is unacceptable now, will most probably be equally unacceptable at the end of the Plan period: certainly I consider the Plan should seek to engender a degree of public confidence that the separation secured will not, at some future time, be lightly squandered. ^For these reasons I believe that, where a green gap is seen as necessary, it is more important that the whole gap between the settlements should be designated as green gap than that substantial, but arbitrary landscape features should be rigidly followed. I also consider the inter-visibility of settlements is not a factor which should affect the definition of green gaps."^
I have marked with ^...^ the most important words in the above paragraph and my clarifying words are in square brackets.
The first group of sentences marked ^...^ indicates that the owner wished to leave the remaining land (now site R170M) as white land, so it can sold as high priced building land at a later date. The inspector states that this is the very reason it must remain as a Green Gap and because of this statement it is Green Gap. The LA DPD only includes Green Gap site R170M because the owner is keen to sell and make a large profit, if he didn’t it would not be included.
The second group of sentences marked ^...^ indicates that “the whole gap between the settlements should be designated as green gap”. It must not depend on “landscape features” or “inter-visibility of settlements”, but these are the very reasons that SLDC state as to why site R170M can be built-on.
Site R170M is still currently a Green Gap site and by definition has more protection than all Greenfields.
A Government Inspector’s words made the white land (now site R170M) into Green Gap and must not be ignored. Therefore to include site R170M in the LA DPD until all the more suitable Greenfield sites have been built-on is UNSOUND.
This R170M Green Gap is also land of most value to the existing community as backed up by this statement in ‘The Taylor Review’ (Page 58):
“20. Government policy is to increase the density of new housing as a means to maximising land use and better support local services. New extensions to settlements therefore may be relatively densely designed and built right up against the existing settlement to minimise the number of green fields ‘swallowed up’. However, this will mean they are built on exactly the land of most value to the existing community – the fields or woods at the ends of their gardens, the green edge to the town. Local residents against new development may be accused of ignoring the needs of others for housing, but they have a genuine point. They may not have bought the right to their countryside views, but they certainly have paid for them, and these developments are on exactly the fields of most landscape value to existing residents."
Taylor gives a valid reason why local people should not be labelled with the scorning name NIMBYs’ when they have a good reason and evidence to oppose development in their neighbourhood.
The evidence above shows that the proposed LA DPD numbers for dwellings to be built are UNDELIVERABLE before 2025. If the numbers were reduced to ones that were deliverable and sound there would be no reason to include the peripheral site R170M in the last phase (2022-25) of the LA DPD, since it is a Green Gap and hence has a higher protection than any of the proposed Greenfield sites. Note at this point in time site R170M is still part of a Green Gap.
“The Community Infrastructure Levy is a new levy that local authorities in England and Wales can choose to charge on new developments in their area. The money can be used to support development by funding infrastructure that the council, local community and neighbourhoods.”
(see http://www.communities.gov.uk/planningandbuilding/planningsystem/communityinfrastructurelevy/ )
There is absolutely no evidence in the LA DPD about how much funding SLDC are capable of obtaining from developers from the levy. Their track record in the past has been very poor when negotiating for affordable dwelling percentages. The target over previous years has been 50% but SLDC of only achieved 28%. The target is now 35% which from past results is still just wishful thinking. SLDC are relying on this money to fund infrastructure and other projects. Until SLDC publish real evidence that the money raised from this levy is in excess (there will always be an overspend) of that required, for all the proposals in the LA DPD it is intended for, then the LA DPD is UNDELIVERABLE and UNSOUND.
With the excessive financial demands that will inevitably be placed on each development in terms of school places, direct highway consequences, a 35% affordable housing contribution etc, it seems highly likely that any contribution to an Infrastructure Levy for wider scale projects would be relatively modest and inadequate. These financial implications appear to again confirm that the proposals are UNSOUND.
Until it is certain that the required infrastructure funding will be available within the planned timescales, in order that SLDC meet their objectives on Air Quality and Junction Congestion, then the LA DPD is UNSOUND.
Site R170M will add further traffic to the streets of Kendal. Therefore site R170M must be removed from the LA DPD until the Northern Development Route has a approved construction plan and committed funding in place (see above). Also that it is shown to decrease the traffic levels in the Windermere Road corridor enough for SLDC traffic objectives are met in this area.
3.0 Further evidence in support of why Policy LA2.2 (site R170M) should be removed from the LA DPD.
3.1 Extracts from Kendal Town Council document "KTC_Response.pdf " (Apr 2011)
Page 8 Transport Improvements.
“The Assessment then looked at the impact of the various possible development sites which were then under discussion. The Assessment modelled the impact of various remedial measures that could be taken, ranging from junction improvements to the building of the Inner Relief Road. It concluded that the existing highway network plus proposed improvements would just about accommodate the forecast level of traffic, provided three sites were removed:
• Land within the Shap Road/Appleby Road corridor (Site E23/49 and Sites M8/M35/ M36)
• The Todds, west of Burneside Road (Sites R148/R170)
• Stonebank Green (Sites M39/R676/R103/R675)
There was no solution which permitted these sites to be developed within the parameters given for the Assessment (e.g. no compulsory purchase orders for major junction redevelopment).”
This supports previous evidence that the development of site R170M (The Todds) is UNSOUND
Page 9 section on “Sewer Capacity”
“In addition, United Utilities has concerns about the capacity of the Waste Water Treatment Works, located to the south of Kendal, for which process modelling needs to be carried out. This impacts all the potential development sites in the town.”
I have an email from SLDC dated 27Apr2011 which states:
“The following is based on information and advice provided by United Utilities.
1. United Utilities cannot determine the number of dwellings that will cause Kendal Wastewater Treatment Works (WwTW) to reach process capacity without conducting modelling. The threshold for when capacity is reached is determined by the design capacity of the WwTW and the population that it serves with some headroom designed in to the calculations. This headroom is not excessive as United Utilities cannot design and build for a population that is not already there or where development is not definite.
2. There are local network issues in respect of sewer capacity in the Kendal area . They are primarily centred around the Burneside area as evidenced in the Core Strategy and supporting Land Allocations Document material.
3. South Lakeland District Council does not hold or have access to data/information regarding the catchment area of the Kendal Sewerage Works.”
SLDC/UU admit that the headroom (i.e. spare capacity) is not excessive. Despite this SLDC have no results of any modelling and have not insisted that this modelling be carried out by UU. SLDC do not even know the catchment area for Kendal Sewage Works. There is nothing in the documentation on the SLDC web site to indicate that SLDC do have this information today (a year later). Therefore SLDC do not know how many dwellings can be built before Kendal Sewage Works needs a major upgrade costing many millions of pounds.
United Utilities move their funding from year to year as they see their immediate priorities change, so until they actual “sign on the dotted line” to meet certain dates then their current dates can “be taken with a pinch of salt”. As evidence to support this, the paying customers of Burneside have been waiting over 20 years to get their sewerage fixed and they still have sewage on the streets during heavy rain. So there is no guarantee that the North West Kendal problem will be fixed before 2025.
Site R170M is one of the last sites in the plan to be developed therefore until the above figures are known for the whole of the catchment area and UU & OFWAT have “signed on the dotted line” to meet their agreed dates then the site R170M is UNDELIVERABLE and the LA DPD is UNSOUND.
Page 9 section on “Hydrologic Considerations”.
“However, the mechanisms (some man-made, mostly natural) which are currently managing to keep Kendal free of floods are not well understood. Several of the sites included in the Land Allocations have a history of being badly affected by rainfall. This suggests they have a role to play in mitigating surface run-off and hence flood prevention. If this is correct, development of such sites could trigger flooding in the town - and making the sites themselves flood proof would certainly involve additional expense for developers.
Kendal Town Council believes this is an important omission from the current evidence base, and calls on SLDC to commission a full hydrology study of the area before including the affected sites in any final land allocation. Any remedial infrastructure required to allow these sites to be developed safely would need to be included in the overall infrastructure programme.
Land Allocations affected by this consideration are the lower Hallgarth sites (R169M and R170M), Appleby Road (MK35KM), Natland Beck at Kendal Parks (R107M, R150M), Stock Beck at Castle Green Road (R121M), and Stonecross (R103M), and Blind Beck (R129M)”
There is nothing in the documentation on the SLDC web site to indicate that SLDC have commissioned this study or have any results. Site R170M is mentioned in quote above and so until this study is carried out development of site R170M is UNDELIVERABLE and UNSOUND.
Page 10 Infrastructure.
“3. Sites should not be included in a Final Land Allocations document unless their impact on Kendal’s transport is understood, solutions are agreed with partners, and the impact has successfully passed a rerun of the Transport Assessment. ‘Emerging Option’ sites affected by this are indicated are indicated by an ‘X’ in the ‘Traffic’ column in the Detail by each Land Allocation site starting on page 11.”
Note site R170M has an ‘X’ in the Traffic column, so this site should be removed from the LA DPD until its impact on Kendal’s junction congestion is fully understood.
This section supports previous evidence that site R170M is UNDELIVERABLE and UNSOUND.
3.2 Extracts from Kendal Town Council doc. "KTCResponsePart2toLandAllocation.pdf" (Sep 2011)
Page 5 Doughnut Development
“Taylor contends: ...these developments undermine sustainability. They invariably encourage car use, especially if there are no services or employment within walking distance, with resulting congestion on roads into town. And without local and community facilities of their own, there is little to build social sustainability and cohesion or links between new and existing settlements as there will be little in the way of community life.
This approach to planning is also a recipe for confrontation, “developing exactly the land of most value to the existing community – the fields or woods at the ends of their gardens, the green edge to the town”
(as has been amply demonstrated in Kendal by the response to the Emerging Options consultation process).
Without change we will simply repeat the mistakes of recent decades, creating unattractive developments of housing estates encircling our rural towns and larger villages, and we will fail to stem the trend of smaller villages becoming dormitory settlements of commuters and the retired, ever less affordable for those who work within them. This is not a sustainable future for rural England.
Without strong Land Allocation policies from the Planning Authority, Kendal is heading towards an unsustainable “doughnutted” future.”
This confirms that development of the peripheral Green Gap site R170M is UNSUSTAINABLE and therefore UNSOUND.
Page 6 Recommendation for Kendal
“The Council believes the Planning Authority should follow Taylor and adopt this model in preparing its final Land Allocations policies for Kendal, as the only way in which the NPPF demand for sustainable development can be achieved in the town. It is important to note that this is not in conflict with the Core Strategy positioning of Kendal as a Principal Service Centre, or with the requirements for meeting forecast housing demand. From Taylor, the requirements for sustainable development in rural market towns is clear: it cannot be delivered by allocating isolated sites around the town; a hub and spoke model is required. Even without the NPPF’s insistence on sustainable development, there are other intrinsic advantages to the hub and spoke model for Kendal. The Council’s previous Response to Consultation highlighted the major infrastructure challenges to be overcome in the town. These become far more soluble if development proceeds on hub-by-hub basis, when the infrastructure work can be concentrated on the corresponding spokes. For example, it is far simpler to improve bus services, cycling provision, etc. if only one or two ‘spokes’ have to be addressed.
The evidence in the EHLSS shows that there are suitable sites available (the scope of the SHLAS only covered sites within existing settlement boundaries, and is of less relevance), and there are options both for completely new communities on green field sites, or for breathing new life into existing communities.”
This confirms that the “doughnut” strategy is incorrect for Kendal and should be replaced by the “hub & spoke” strategy. It also confirms that the peripheral Green Gap site R170M is unsustainable and therefore UNSOUND.
Page 10 Latest Forecasts (2011)
“The latest forecast in this series was produced in Spring 2011. It shows a drastically reduced requirement:
• only 360 dwellings across the 20 years, or
• just over 4,000 including migration, projected on the last five years’ evidence.
This suggests that a more appropriate target for the next 5-10 years would be around 200 dwellings per annum.”
This confirms the evidence given above that 200 per year is what is required and this number would be deliverable. If this number was planned then the peripheral Green Gap site R170M would not be required and being in the last phase would not be needed in this LA DPD.
This section supports previous evidence that the LA DPD is UNSUSTAINABLE and UNSOUND.
3.3 Extracts from Kendal Town Council doc. “Land Allocations Representation (2).pdf “ (Mar 2012)
Page 4 Summary
“The Council believes that the DPD is not justified because it fails the following tests of soundness:
• the LPA has failed in its duty to compare against reasonable alternatives
• key decisions are not supported by the evidence base or the evidence supports a different conclusion
• the evidence base is incomplete
The DPD is also not effective in that it is not deliverable, with key elements of the dependent infrastructure
not understood.”
This confirms the LA DPD is NOT DELIVERABLE.
Page 4
“For rural market towns, the evidence was pulled together in July 2008 by the Taylor Review9, setting out the policy framework necessary to deliver the “vision of a living, working sustainable countryside”. Taylor provided compelling evidence that “doughnut development” was the wrong approach for sustainable rural market towns, and that a “hub and spoke” model represented the best pattern for sustainability.”
The two KTC paragraphs above confirm that an alternative system must be adopted now, which will “meet the needs of future generations” of Kendal (i.e. BE SUSTAINABLE”) for the many thousands of years to come.
Page 4
“The evidence in the EHLSS indicates that suitable sites could be available (the scope of the SHLAA only covered sites within existing settlement boundaries, and is of less relevance), and there are options both for completely new communities on green field sites, or for breathing new life into existing communities.”
This confirms that a “hub & spoke” is viable.
Page 5
“The Assessment concluded that the existing highway network plus proposed improvements would just about accommodate the forecast level of traffic, provided three large sites were removed. The consultants could find no mitigation which would permit these sites to be developed within the parameters given for the Assessment (e.g. no compulsory purchase orders for major junction redevelopment.)”
This confirms that site R170M must be removed from this LA DPD because it is one of the three sites.
Page 5
“Given that this approach has differed significantly from the independent consultants’, the Council asks the Inspector to order an independent audit of this latest work by W.S.Atkins or equivalent to ensure it meets accepted professional standards of objectivity and integrity. The Council further asks the Inspector to ensure that no sites are included in the DPD which the evidence shows are not deliverable on transport grounds.”
This confirms that site R170M must be removed from this LA DPD, because it is one of the sites which “are not deliverable on transport grounds.”
Page 7
“The Council asks the Inspector to withhold approval of the DPD until there is a credible infrastructure plan showing the impact of the major sites on the overall town infrastructure, and with high level solutions identified and costed with enough detail to enable the economic deliverability of the sites to be proven.”
This adds to the evidence given above that there must be signatures, to supply the necessary infrastructure and funding, must be in place before this LA DPD is approved by the Government. Until this is done site R170M is UNDELIVERABLE and UNSOUND.
This section supports previous evidence that site R170M is UNDELIVERABLE and UNSOUND.
3.4 Extracts from SLDC document "Kendal Transport Study (Jan12).pdf ”:
Page 5 Exec Summary (see also 6.1.6 on page 18)
"10. The LDF developments have a more notable impact in the AM peak compared to the base situation. The model results indicate that the provision of sustainable transport improvements (Scheme 2) would be required to support LDF development to nil-detriment compared to the 2022 base situation in the AM peak. However, the provision of a new route along Dowker’s Lane (scheme 4) would be required if the Rugby Club development is included. If the Canal Head development is included, the proposed Kendal Northern Development Route (Scheme 5) would be required.
11. It should be noted that although these schemes are required to achieve nil-detriment, these improvements are only demonstrated to offer marginal benefits to the performance of junctions in Kendal. These infrastructure schemes would be expensive and may not be a cost-effective solution to congestion in Kendal town centre.
12. Furthermore, even with the implementation of these improvement schemes, it is important to note that a large proportion of the key junctions would continue to operate above capacity, and therefore experience congestion and extensive queuing in the 2022 base situation. This situation would be compounded by the LDF development traffic.
13. It is recommended that further modelling work is undertaken"
The Transport Study shows that the objectives cannot be achieved before 2025 therefore the problems are going to be much worse in the years 2026 onwards.
SLDC do not have signed-off solutions and timescales in place to meet the plan phases, therefore the LA DPD is UNDELIVERABLE and UNSOUND.
Page 9 This page gives the CCC/SLDC definition for Junction Congestion limits.
"Acceptable junction performance is indicated by a degree of saturation below 90 percent for signal-controlled junctions, or an RFC below 85 percent for priority junctions and roundabouts."
The Atkins report uses a Volume/Capacity ratio of 90 as acceptable for a junction approach, which is similar.
The Study shows that these objectives will not be met by 2025 so this, along with page 10 (see below) adds evidence to the above.
Page 10
"4.2.2 In total 13 junctions are indicated to have a maximum RFC greater than or equal to 90% in the 2010 base year, in either the AM or PM peak period. These are:Junction1: A5284 Stricklandgate/Sandes AvenueJunction 2: A5284 Sandes Avenue / A6 Blackhall Road signalised junction
Junction 5: A6 Longpool / Station Road mini-roundabout junction
Junction 12: A6 Highgate / Lowther Street signalised junction
Junction 22: Parkside Road / Valley Drive priority junction
Junction 16: A6 Milnthorpe Road / Romney Road signalised junction
Junction 17: A5284 Windermere Road/Queens Road
Junction 18: A5284 Windermere Road/Burneside Road
Junction 21: A65 Burton Road / Oxenholme Road signalised junction
Junction 27: A684 Sedbergh Road / Sandylands Road priority junction
Junction 29: A6 Shap Road / A685 Appleby Road (north) priority junction
Junction 30: A6 Shap Road / A685 Appleby Road (south) priority junction
Junction 31: A685 Appleby Road/Sandylands Road"
“Measures must be in place” to fix these major problems first (i.e. meet SLDC objectives). They have a huge bearing on why SLDC is still breaking the law on Air Quality.
Page 14
“* Scheme 6: Scheme 5, plus a potential Kendal Southern Link Road, which comprises a new single-carriageway road linking the A6 Milnthorpe Road with the A65 Burton Road south of Kendal town centre.”
This new road proposal has never been mentioned before; it is not in the Core Strategy and therefore, as we have been told before, it cannot be considered in this LDF.
This section supports previous evidence that site R170M is UNDELIVERABLE and UNSOUND.
3.5 Extracts from SLDC document "06 Infrastructure Position Statement.pdf ”:
Page 10
"4.19 United Utilities has a statutory duty to develop and maintain an efficient and economical system of water supply within its area. A proposal for expenditure in the years 2010 – 2015 is contained within the published five years Investment Plan (Asset Management programme). The plan can be found at the following website link: http://www.unitedutilities.com/Documents/Detailed_plan.pdf "
There is nothing in this PDF document that is specific to Kendal.
UU may have "a statutory duty to develop and maintain an efficient and economical system of water supply within its area" but it is very poor at obeying this duty as is verified by the > 20 years Burnside have been suffering sewage problems (and still are).
Until UU actually “sign on the dotted line” to meet the required planned timescales and commit funding, the LA DPD is UNDELIVERABLE and UNSOUND.
Page 11
"4.23 Funding is more likely to be acquired in cases where there is development certainty (i.e. clear evidence of developer interest).
* UU reiterate that even if a bid is submitted there is no guarantee funding will be approved by OFWAT. The speed at which approved schemes are implemented will depend on the priority given to schemes within the 5-year programme and the time required to design, obtain planning permission and construct."
This backs previous evidence, never mind “development certainty” what about the existing paying customers who are still suffering sewage and flooding problems due to lack of investment.
Until United Utilities “sign on the dotted line” and commit to planned dates and funding the LA DPD is UNDELIVERABLE and UNSOUND.
Page 11
"4.24 There is currently loading capacity at Kendal Waste water Treatment Works (WwTW), however, for the number of dwellings that are proposed a full process and hydraulic survey of the Works will have to be undertaken before UU could comfortably approve the Planning Applications. As the sewer network is at capacity in North Kendal, UU could not agree to any significant development until after 2015 in this part of the town. Providing UU obtain funding through OFWAT to undertake the necessary upgrades etc. UU will be building into the 2014 Business Submission to OFWAT a case for funding to provide the means to accommodate development, which will boost the economy.
4.25 A feasibility study is being undertaken on the Kendal WwTW. Recommended phosphorous levels are set by Environment Agency (EA) through discharge consents, and until EA impose a new requirement for a lowered rate, UU will continue to discharge at the current rate. UU stated achieving any required lower rates would depend on new/better technology. Further Phosphorous removal would only be undertaken if UU were required to achieve a tighter standard as set by the EA following their review of water quality. Newer technology, which is not currently available, would be required to achieve any standard below 1mg/l. UU has advised development in the Kendal area should be capped at 2000 properties unless a more stringent phosphorus effluent standard can be achieved.
4.26 UU has advised that sites in North Kendal should only come forward in the latter periods of the plan period when sewage network improvements are in place.
4.27 Strategically there is enough water supply to accommodate levels of new development, but there are potential risks of deterioration of water quality."
Until OFWAT “sign on the dotted line” and commit to planned dates and funding the LA DPD is UNSOUND.
Page 14
"4.45 Electricity North West Ltd manage infrastructure and distribute and transmit electricity throughout South Lakeland. The regulator determines the amount of funding, however, it is not known what the next round of funding may or may not allow for investment in improvements. Information relating to substation capacity has not been ascertained. Evidence when exploring options for the Canal Head Area of Kendal shows that the Kendal Primary substation is currently operating close to or at capacity. It is possible that significant development in Kendal would require investment for network reinforcement and that a new Primary Substation would be required although Electricity North West Ltd does not confirm this. No information has been made available stating whether this is the case. Only when the customer has firm load requirements and location details can a system study be undertaken to ascertain the scale of impact of potential new development."
What if the system study states it cannot be done or they cannot obtain the funding within the plan timescales? Electricity North West Ltd already has the number of houses proposed and their locations so they must commit to a system study and confirm that the proposed developments are deliverable. Until then the LA DPD is UNSOUND.
Page 15
"4.48 National Grid Gas Distribution own and operate the local gas distribution network in South Lakeland. The confidential nature of the process means National Grid are unable to confirm whether they are currently processing or have made any offers for connection within Cumbria."
The document states nothing about National Grid Gas Distribution having a statutory duty to develop and maintain an efficient and economical system of gas supply within its area.
The LA DPD cannot possibly be monitored correctly until all the Gas company has “signed on the dotted line” to meet the timescales required. Until then the LA DPD is UNDELIVERABLE and UNSOUND.
This Infrastructure document is only a statement; there is no indication when the Infrastructure Delivery Plan will be available to the public or any indication that the timescales can be met. The LA DPD is UNSOUND until the Infrastructure Delivery Plan and the Kendal Transport Plan are available with all milestones agreed, funding committed and both signed off by the respective utility companies. They can have the proviso that it depends on the build going ahead as planned.
3.6 Extracts from SLDC document “01 Consultation Report.pdf ”:
Page 19
“In their response the Highways Agency identified those sites it considers (if developed, due to cumulative impact with other sites) may impact upon the capacity, operation and safety of the strategic road network (SRN) (A590 and M6) within South Lakeland. As a consequence, the Agency has stated that the cumulative impact of development of sites under consideration in the following settlements (see below) may result in some impact to the SRN: Burneside, Crooklands, Endmoor, Kendal, Kirkby Lonsdale, Levens, Milnthorpe and Ulverston alongside the sites suggested for strategic employment use (in Ulverston and Kendal area).”
Note the word “may” on the second line. They either do or they don’t. After all these years of the LDF there is no excuse for this information not being available. SLDC must obtain an answer to this issue immediately and publish it. If any of the developments proposed within the LA DPD do affect the Strategic Road Network then any changes necessary must be included in the LA DPD and the Transport Plan (which must be issued before the hearings). Note the Strategic Road Network is NOT currently mentioned in the LA DPD.
Page 21
This page with reference to Burneside states:
“.....this is no guarantee that funding will be approved by OFWAT”.
Until OFWAT “sign on the dotted” line to meet the planned timescales the LA DPD is UNSOUND.
Page 21
“Additional work is needed by UU to check if cumulative impact on treatment works may raise capacity issues
SLDC must publish how many houses can be built in the Kendal catchment area before a major upgrade to the sewage works is required. Until UU know their total funding requirements the LA DPD is UNSOUND.
Page 34
KENDAL
“Many people believe development of the sites suggested would harm the landscape character of the town, worsen air quality, exacerbate current flooding problems, harm biodiversity, generate unacceptable levels of traffic congestion, and place further strains on a heavily constrained sewerage system. Some people questioned the need for additional housing believing there are enough empty properties in the town to meet current and future housing demands. A number of people stated development should be prioritised on brownfield sites and meet primarily local needs.”
“Many people including Kendal Town Council and Burneside and Natland Parish Council’s supported the concept of green gaps to protect Kendal coalescing with neighbouring settlements. However, a significant number of people and Kendal Town Council and Natland Parish Council believed the suggested emerging options would not prevent coalescence from happening. There was general widespread support for the open space designations suggested, however, many people believed the emerging options sites should also be designated open space.”
“Kendal Town Council expressed serious concerns with the overall approach being suggested for the town, believing the amounts of developments and the emerging option sites suggested would damage the landscape character of the town, and put unnecessary strain on an inadequate infrastructure system. The Town Council has suggested an alternative strategy/approach for the town this being to protect existing green space/countryside surrounding the town and to look at alternative sites adjacent to nearby settlements and possibly further afield where development would have less impact on the town’s infrastructure, air quality and its high quality landscape value.”
These three paragraphs confirm that the wishes of the majority of local people have been ignored and adds support to the evidence given above concerning Consultation and Legal Compliance.
Page 46
On this page it states “UU is currently considering lists of projects that will require major capital investment in Asset Management Plan 6 period 2015-2020.” and “UU reiterate that even if a bid is submitted there is no guarantee funding will be approved by OFWAT. The speed at which approved schemes are implemented will depend on the priority given to schemes within the 5-year programme and the time required to design, obtain planning permission and construct.”
Until United Utilities and OFWAT “sign on the dotted line” to meet the planned timescales and commit funding, the LA DPD is UNDELIVERABLE and UNSOUND.
This section supports previous evidence that site R170M is UNDELIVERABLE, UNSOUND and that consultation process was not Legally Compliant.
3.7 Extracts from SLDC document “Land Allocations DPD.pdf ” [Mar12]:
Pages 51 & 52
Item 3.6 - Key local factors influencing the location of new development in Kendal:
“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; Avoiding coalescence between Kendal, Oxenholme, Burneside and Natland and maintaining the separate identities of these settlements;
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;
Infrastructure constraints including sewage capacity at Kentrigg and Steele's Row and the implications for development in northwest Kendal.”
One of the main comments of the people who responded to the SLDC consultations and opposed them was the character and appearance of Kendal. This is imbedded in the above paragraph and has been totally ignored. The LA DPD is therefore not Legally Compliant.
The site R170M is close to Kentrigg (mentioned above) and so it is UNSOUND to include it in the LA DPD until United Utilities are fully committed (i.e. signed on the dotted line) to the LA DPD timescales.
The sentence “Minimising the impact of development on Kendal’s central traffic system, …..” is not definitive it should state “Meet and maintain SLDC’s standards and objectives with regard to Kendal’s central traffic system, …..”
Page 163 APPENDIX 4 - HOUSING TRAJECTORY
A graph on this page it shows the following numbers over the years 2003 – 2025 (22 years).
Maximum number of dwellings ever built in one year was 300 in year 2005/06 and even this did not reach the target of 400 per year.
Extrapolating from the graphs the average number of dwellings built per year for the first 8 years was 100+280+150+150+240+300+230+220 = 1670 / 8 = 209 per year. In the terms of this graph there are already an extra 1530 dwellings (109/yr on top of the 400/yr) that have built just to catch up. This compares well with the more accurate figures in section 2.1 above.
The figure of 720 per year for the three years 2022 – 2025 is just WISHFULL THINKING.
One of the questions that must be asked to confirm SOUNDNESS is “Are there realistic timescales related to the objectives”. The above numbers are clearly not realistic therefore the current LA DPD is UNSOUND.
This section supports previous evidence that site R170M is UNDELIVERABLE and UNSOUND within the timescales of this LA DPD (2025).
4.0 Changes required to the LA DPD document title “Land Allocations DPD.pdf ” [Mar12]:
4.1 During the recent SLDC consultation 98% of the local neighbourhood who responded OPPOSED the proposals for site R170M. In a door-door poll of over 400 neighbours during 2011 approximately 80% of those asked OPPOSED the proposal to build on site R170M. Of the remaining 20% most did not care one way or the other. The Localism Bill is a Con Trick (nice pun); it promises much but does not actually support what the majority of the people in the neighbourhood want.
To prove SLDC are DEMOCRATIC they must be serious about responding to the majority of the local neighbourhood’s wishes. Also the TOTAL CONCLUSIVE EVIDENCE ABOVE PROVES THAT SLDC MUST REMOVE THE PERIPHERAL GREEN GAP SITE R170M FROM THE LA DPD TO MAKE IT SOUND. THIS IS HOW THE LA DPD MUST BE CHANGED.
4.2 After many years (before year 2000) of knowing about the traffic problems in Kendal, SLDC have failed to produce a transport plan or action plan that enabled them to meet their standards and objectives for Air Quality and Junction Congestion. This must NOT be allowed to continue. Only when these standards and objectives have been PROVEN to have been met (with spare capacity for expansion) will the people believe SLDC are serious about tackling these major problems. The recent SLDC consultations show that increase in traffic was one of main reasons why 98% of the people (that responded) OPPOSE the proposals to build on sites in their area of Kendal.
Previous experience with Core Strategy has shown me that all my evidence will be ignored and that site R170M will not be removed from the LA DPD. If this is to be repeated then I would like to see the following changes to LA DPD.
There is a note on page 57 (item 3.18) of the LA DPD (policy LA2.2 site R170M) which states:
"DEVELOPMENT OF THIS SITE CANNOT TAKE PLACE UNTIL MEASURES ARE IN PLACE TO RESOLVE PRESSURE ON THE SEWERAGE NETWORK IN NORTH KENDAL."
This means existing problems will be fixed before building starts.
THIS SETS A PRECEDENT WHICH MUST CONTINUE WITH REGARD TO OTHER MAJOR PROBLEMS.
The threat to the health of people due to air pollution is of as much importance as sewage on the streets. Site R170M will add more traffic to the streets of Kendal and make air pollution worse. Therefore a note must be added to Policy LA2.2 (item 3.18) that states:
"DEVELOPMENT OF THIS SITE CANNOT TAKE PLACE UNTIL MEASURES ARE IN PLACE TO SHOW THAT THE LAW ON AIR QUALITY HAS BEEN MET IN KENDAL."
Increase in traffic, which leads to more junction congestion and a deterioration in the well-being of local people, was one of the major complaints in the recent SLDC consultations. Site R170M will add more traffic to the streets of Kendal and make junction congestion worse. Therefore a note must be added to Policy LA2.2 (item 3.18) that states:
"DEVELOPMENT OF THIS SITE CANNOT TAKE PLACE UNTIL MEASURES ARE IN PLACE TO SHOW THAT SLDC’S DEFINITION OF “ACCEPTABLE JUNCTION PERFORMANCE” HAS BEEN MET IN KENDAL."
For definition see page 9 of “Kendal Transport Study (Jan12).pdf”.
“4.1.5 An RFC or DoS of 100% indicates that an approach is operating at maximum capacity. Acceptable junction performance is indicated by a degree of saturation below 90 percent for signal-controlled junctions, or an RFC below 85 percent for priority junctions and roundabouts. Above this level, an approach is likely to begin to experience congestion as there is insufficient spare capacity to cope with fluctuations in traffic flow.”
4.3 Page 51 item 3.6:
The sentence “Minimising the impact of development on Kendal’s central traffic system, …..” is not definitive. The word “Minimising” is just not good enough to meet the people’s wishes. It must state “Meet and maintain SLDC’s standards and objectives with regard to Kendal’s central traffic system, …..”
4.4 Page 163 APPENDIX 4 - HOUSING TRAJECTORY
This Appendix 4 must be changed and other pages which quote these figures. The SLDC evidence does not support the requirement that anywhere near the 8800 dwellings can be built before 2025. The numbers in the graph are not realistic (a SOUNDNESS word), therefore NOT DELIVERABLE and UNSOUND. 720/year for last three years is just wishful thinking, it is not realistic; this graph shows that the maximum that has ever been built within the last 8 years is 300 per year for the year 2005/06. The developers will not build 750 per year because it would swamp the market and they would be left with a large number of empty houses.
There is no point in just stating on page 7 of the LA DPD that it is “the ambition to deliver 400 dwellings each year” if these numbers cannot realistically be built and sold. There is also no point in just monitoring these numbers just so a box can be ticked to say they have been monitored. The numbers must be realistic so that they can be monitored and vigorously progressed.
Kendal Town Council have stated in one of their reports [Sep2011 see above] that only around 200 dwellings per year is the number required. SLDC must discuss this issue with KTC and reduce the current total figure of 8800 to a number that can realistically be built & sold before 2025 and not one that is just WISHFULL THINKING.
4.5 There is a requirement in the Core Strategy for Brownfield land to be used for “at least 28%” of the number of dwellings built. Note the words are “at least” not it is the “ambition to use”. To be SOUND the LA DPD must indicate the amount of Brownfield land that is currently available and the targets for each area. These figures must be monitored, vigorously progressed and be made available to the public.
4.6 SLDC must discuss Kendal Town Council’s three reports in detail with the town council and members of opposition groups (e.g. Green Spaces). I would like to see the LA DPD changed to incorporate as much as possible of that which is agreed in these discussions.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
THE HEALTH AND WELL-BEING OF LOCAL PEOPLE MUST BE AT THE TOP OF SLDC's PRIORITY LIST and despite all my emails and protest at the Core Strategy hearings this has not yet been done in Kendal.
So I wish to speak face to face with the inspector and ask him personally if he will recommend in his report that notes be added to the LA DPD stating that SLDC must fix their major existing problems first and meet the SLDC/CCC definition for "Acceptable Junction Congestion" and the Law on Air Quality before allowing actual build of site R170M, which will add to these problems (see examples of notes in section 4.2 above).
A PRECEDENT has already been set by a note in Policy LA2.2 for site R170M relating to the sewerage network in North Kendal. If United Utilities have to fix their major existing problems first before building is allowed then so must SLDC, this is logical and should not need a political decision.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
915. Mr Derek Whitmore (Individual) : 17 May 2012 11:03:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.8 Local Employment Sites - All Kendal sites
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
1.0 Consultation
1.1 SLDC did not change the proposals in-line with the citizens important wishes.
The Government Planning Advisory Service (PAS) defines the requirements for Legal Compliance in it’s document – "legal.doc” (Legal Compliance Tool from http://www.pas.gov.uk/pas/aio/85651 )
Extract from Stage 2: Plan preparation - frontloading phase (page 7):
“6. Does the consultation contribute to the development and sustainability appraisal of alternatives?”
This has not been carried out correctly, alternatives have not been seriously considered. In particular the Kendal Town Council’s excellent reports, containing good alternatives, have been ignored.
The vast majority of the oppose responses made in the SLDC consultations were noted, listed in the consultation documents and then almost totally ignored. In my view these consultations were just so that SLDC could “tick the box” for the government inspector and therefore were a waste of taxpayers money.
I have done a detailed examination of the SLDC Consultation Database and these are my findings:
On 11th August 2011 (after the closing date) there were 2986 responses from the Kendal settlement. 98% of these responses opposed the proposals in their neighbourhood. Most of those that “support in part” did not support housing. Most of the few indicating “support” were representatives of the land owner, potential builder, Kendal Futures Board or the North West Development Agency.
The main reasons for the respondents opposition was the increase in traffic that these proposed developments would cause, and the affect they would have on the landscape character of Kendal. Better alternative sites were suggested, noted and then ignored. The present proposals will not “satisfy the needs of future generations” and are therefore NOT SUSTAINABLE.
Issues raised in the consultations would have contributed greatly to the development and sustainability of alternatives but the alternatives put forward have been ignored (also see other evidence 2.3 below). Therefore the LA DPD it is not Legally Compliant.
I would like to see alternatives discussed with Kendal Town Council and the Green Spaces group. Then any changes agreed included in the LA DPD.
2.0 Alternative plan
2.1 Law must be obeyed.
Extract from Stage 2: Plan preparation - frontloading phase (legal.doc page 5):
“* developing alternatives and options and appraising them through sustainability appraisal and against evidence.”
The SLDC Air Quality reports show that SLDC have been breaking the Law on Air Quality for many years. It means that SLDC must use an alternative plan for Kendal until it is proven that the law is being obeyed (with spare capacity for proposed development). The reason the law must be proven is that action plans have not worked for at least 14 years (before 1998). In the meantime affordable houses can be built in other areas of SLDC which have low traffic.
Until an alternative plan is in position to ensure the law on Air Quality is obeyed (with spare capacity for the proposed development) the LA DPD is not Legally Compliant.
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These Legal Compliance requirements are not definitive or closed questions; they are open to personal interpretation, so I will not make any further comment in these sections.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Personal Comments:- From my experience of the Core Strategy hearings and the SLDC consultations I know my response will be ignored. The changes to Kendal’s infrastructure, that the new SLDC Transport Study (Jan12) states are required (see below), is just one example of this. I am therefore taking this opportunity to place on record all the relevant evidence I have gathered on why site R170M (policy LA2.2) should not be included in the LA DPD. Quotes from certain documents have been added to make it easier for the reader. There is repetition of some issues but this is because I have added different sources of evidence throughout the document.
It is undemocratic just to include Legal Compliance and Soundness in this consultation. In a democratic society the wishes of the majority of local people would have priority over these criteria. Also criteria such as “Justice” and “Fairness” should be considered. These were totally ignored in the Core Strategy consultation and hearings.
Test of Soundness
1.0 Not justified
1.1 Health and well-being of citizens in Kendal.
I have been informed that a developer does not have to fix an existing problem he just needs to show that he will not make it any worse. This is ridiculous, while SLDC are breaking the law on Air Quality developers must not be allowed to build on site R170M and other Kendal sites until the law is obeyed. SLDC breaking the law must surely be enough to prevent developers from winning an appeal. The people’s health and well-being must have top priority over everything else in the LA DPD.
The latest Cumbria County Council’s transport plan LPT3 does not include plans for the necessary infrastructure to fix existing problems neither does the SLDC Core Strategy. It was only after pressure from the public that SLDC & CCC produced the Transport Study (which is only a study) and after all this time the Transport Plan has not yet been made available to the public. Without a Transport Plan (including committed funding) signed off by all the participants the LA DPD is UNDELIVERABLE within the current timescales (2025) and is UNSOUND.
Before the year 2000 the SLDC objective was to meet the law on Air Quality by the year 2005 but air pollution has continually increased and the AQMA (Air Quality Management Area) has even been made larger. This shows that SLDC are not serious in meeting their objectives where the health and well-being of citizens, or obeying the law, are concerned.
A typical example is the approval of the Planning Application for the old Auction Mart site. Also planning approval is certain to go ahead for the Canal Head development. These will make the air pollution worse in the AQMA. The worst pollution occurs when junctions are grid-locked and tinkering with traffic lights will not fix this problem. It will take major infrastructure changes to fix the existing traffic problems and allow for proposed LDF expansion. The Transport Study even admits that none of the improvements schemes will meet SLDC objectives.
Extract from SLDC document "Kendal Transport Study (Jan12).pdf ”:
“6.1.6 Furthermore, even with the implementation of these improvement schemes, it is important to note that a large proportion of the key junctions would continue to operate above capacity, and therefore experience congestion and extensive queuing in the 2022 base situation. This situation would be compounded by the LDF development traffic.”
More building is planned in Kendal within the next few years (phase 1). This will make the major traffic problems worse. Infrastructure should already be in place to cope. Instead there is not even an approved Transport Plan in place, never mind the infrastructure that will be needed to meet SLDC standards and objectives.
The Transport Study is stating that further modelling is required. This shows that SLDC do not yet know at the present time if their proposals can be implemented or if funding will be available within the LDF timeframe (year 2025), therefore the LA DPD is UNSOUND. Once money has been spent on major infrastructure changes it will be expected that these changes will last for at least 15 years (through the next LDF) therefore any further modelling must use a date of 2040 or beyond. These results will prove that the Taylor “hub & spoke” must be started now (see more evidence below).
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. The health of residents of Kendal town should also cause great concern; a lot of them are elderly and frail.
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.
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 LA DPD maps for the SLDC district, have not been included on the latest maps. It is not fair that these traffic problems are not shared throughout the entire SLDC district. This is another reason why the hub & spoke system must be adopted – FAIRNESS.
The health and well-being of the people due to air pollution must have top priority over everything else in the LDF. This is not happening with the current proposals. Proving the law is being obeyed must come second on the priority list after health. If it does not already do so the “Soundness” examination must take account of these two very important issues.
The evidence above shows that these traffic problems in Kendal will not be fixed without major infrastructure changes which are not in Cumbria County Council’s LTP3.
Site R170M will add further traffic to the streets of Kendal. Therefore the LA DPD is UNSOUND and site R170M must be removed from the LA DPD until the Northern Development Route has an approved construction plan and funding (see above).
For more evidence see extracts from the SLDC Transport Study (Jan12) below.
1.2 Alternative strategy.
Although SLDC have carried out consultations they have ignored the major objections. They have even ignored the alternatives put forward by Kendal Town Council in their excellent reports - “KTC_Response.pdf ”, “KTCResponsePart2toLandAllocation.pdf ” & “Land Allocations Representation (2).pdf. ". To avoid even more “urban sprawl” of Kendal the Taylor “hub & spoke” strategy must be adopted and not the current “doughnut” strategy. Kendal will be around for many thousands of years to come, which makes the “doughnut” strategy UNSUSTAINABLE (i.e. will not satisfy the needs of future generations). Only the “hub & spoke” is sustainable in the years to come because extra “satellites” can be added. By then the proposed “doughnut” system will make Kendal such an urban sprawl that very few people will wish to live there. To prevent this happening the “hub & spoke” system must be started NOW.
Money is being put before what is best for the health and well-being of the people of Kendal now and in the future (beyond 2025).
The Taylor Report, which puts forward compelling evidence in favour of the “hub & spoke” system, shows that the proposed “doughnut” system is UNSUSTAINABLE and therefore the development of site R170 (being a peripheral Green Gap site) is UNSOUND and must be removed from the LA DPD.
2.0 Not effective
2.1 Not meeting definitions of soundness.
The Government Planning Advisory Service (PAS) defines the requirements for Soundness in the document - "soundness.doc" (Soundness Tool from: http://www.pas.gov.uk/pas/aio/85673 )
Extract from page 6 - Deliverable:
"21. Are there realistic timescales related to the objectives?
i. Sections of the development plan document which address delivery and the timescales for key developments and initiatives.
ii. Confirmation from the local strategic partnership and partner organisations that the timescales are realistic in terms of their contribution to delivery."
Extract from page 8 - Deliverable:
“28. Is it clear who is going to deliver the required infrastructure and does the timing of the provision complement the timescale of the strategy/policies?
i. Confirmation from infrastructure providers that they support the solutions proposed and the identified means and timescales for their delivery.
ii. Representations in respect of infrastructure.
iii. Reports or copies of correspondence on how representations in relation to infrastructure and its timing have been considered and dealt with.”
Extract from page 5 of SLDC document "Kendal Transport Study (Jan12).pdf ”:
Exec Summary (see also 6.1.6 on page 18)
“12. Furthermore, even with the implementation of these improvement schemes, it is important to note that a large proportion of the key junctions would continue to operate above capacity, and therefore experience congestion and extensive queuing in the 2022 base situation. This situation would be compounded by the LDF development traffic.”
I have only selected this one paragraph; there are numerous other paragraphs which support these conclusions. In particular Page 15, Item 5.2.1, Table 5.1 which confirms that all schemes fail to meet SLDC’s objective. The results in Tables 5.2 & 5.3 are even worse.
SLDC’s objective is to meet “Acceptable junction performance” which is defined on page 9, item 4.1.5.
I'm not sure why the year 2022 was chosen as base-line, whatever major infrastructure is planned must enable SLDC to meet their objectives for years beyond 2025. In my opinion until 2040, the end of the next LDF.
Schemes 4, 5 & 6 require major investment and are not in the Core Strategy and therefore must be excluded from the Transport Plan when it is published. Note that the Transport Plan should incorporate extra capacity to cope with the “doughnut” system which, if approved, will undoubtedly continue after 2025.
The SLDC Air Quality Reports show that air pollution is getting worse in Kendal and also the AQMA has been increased.
Extract from page 27 of Air Quality Report (PR_Report_Template_2010.pdf)
(see http://www.southlakeland.gov.uk/downloads/page857/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”. Over many previous years this is typical of SLDC’s attitude towards obeying the law on Air Quality. SLDC action plans have not worked in the past and this is proved by the fact that the AQMA has recently been made larger.
The SLDC document "ED43_Housing Completions 1999 to 2010.doc" plus SLDC updates show that from the beginning of plan period 2003 to end of 2011 (8 years results) the total for South Lakeland is 1690 / 8 = 211 average and of these affordable are 406 / 8 = 51 average (or 24%). Figures for 2006 to 2011 (last 5 years results) are 934 / 5 = 187 average and of these affordable are 264 / 5 = 53 average (or 28%).
Between 2003 and 2011 the number of completions was 1690. At 400 per year the objective was 3200 over this 8 year period, a difference of 1510. To make up this deficit means that over the remaining 14 years (up to 2025) an extra 1510 / 14 = 107 per year will be required. This extra number per year will get a lot higher when the build rate stays below 400 per year.
This is nowhere near the Core Strategy figure of 400 dwellings per year or the percentage affordable figure of 35% and therefore the LA DPD is UNDELIVERABLE. 200 dwellings per year would be a more realistic figure and this is the latest figure that is necessary according to a Kendal Town Council Report (see below).
SLDC have recognised this and have added the word “ambition” to build this number of houses to the LA DPD (see page 7 of the “Land Allocations DPD [Feb 12].pdf ” as an example). This word is not used in this context with regard to numbers in the Core Strategy document. Therefore the LA DPD is UNSOUND with respect to the Core Strategy. The Leader of the Council insisted the numbers in the Core Strategy were achievable within the timescales of the LDF.
The above figures show there was an inward migration of 3 (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 all the partners involved have “signed on the dotted line” that they will meet the LA DPD milestones for all the necessary infrastructure (roads, sewerage, doctors, dentists, schools, etc) that is required. With the proviso that the build will actually take place in the timescales planned. It causes unnecessary stress to local people when unachievable targets are proposed or planned.
Another issue that affects DELIVERABILITY is Brownfield sites (or previously developed land).
It states in "SLDC_Core_Strategy_Document_March2011_sm4web2.pdf " (page 17):
"CS1.2 – The Development Strategy
Priority will be given to the reuse of existing buildings and previously developed land for all new housing development, with a target of ensuring that at least 28% of new housing development takes place on such sites."
The “at least 28%” is also mentioned in CS6.6 (page 85). The 50% in item 7.14 is a mistake, it was the previous target. Now the target has been lowered, and "at least 28%" is said by SLDC to be achievable, the LA DPD must indicate the amount of Brownfield land that is currently available and the targets in each area. The Core Strategy and LA DPD have a requirement to be monitored and targets at least progressed vigorously.
The LA DPD does not mention this requirement; therefore it does not conform to the Core Strategy and is UNSOUND. Also these monitored figures need to be published and available to the public.
The SLDC Transport Report (Atkins 2009) 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." There are more similar comments on pages 60 & 71.
Site R170M feeds traffic into Windermere Road and therefore must be removed from the LA DPD until SLDC have met their objectives on Air Quality and Junction Congestion.
Extract from SLDC document "Kendal Transport Study (Jan12).pdf ” page 5 (Exec Summary):
"However, the provision of a new route along Dowker’s Lane (scheme 4) would be required if the Rugby Club development is included. If the Canal Head development is included, the proposed Kendal Northern Development Route (Scheme 5) would be required."
The Canal Head development is more important to Kendal than site R170M therefore because site R170M will add more traffic to Kendal streets it is UNSOUND to build on it. It must be removed from the LA DPD until the Northern Development Route has an approved construction plan and committed funding.
Page 115 of the document “KENDAL Appendix 1.pdf ” (Appendix 1B – Consultation Responses after October 2010) for site R170M states:
“Achieving adequate visibility will be problematic given alignment of road and limited frontage. Such a large site would require a secondary access (Cumbria County Council – Highways).”
The conclusions reached by a chartered civil engineer who has carried out measurements to Transport Standards of the proposed access to site R170M are as follows:
“There is severely restricted forward visibility on both bends in Burneside Road either side of the proposed access location.
In either scenario tested the visibility from the proposed access towards Kendal falls far short of the standard required.
A new junction cannot be safely introduced in this location.”
This report can be supplied if required.
It cannot be right not to identify this secondary access. When it is identified there will be a lot more opposition to site R170 than is currently expressed.
As I said at the beginning of this response about including “JUSTICE” and “FAIRNESS”, it is not FAIR to include a site which is likely to have “show stopping” problems without first carrying out a thorough investigation into these particular problems.
Given the evidence above, until it can be proved that both access roads can be built to meet the Transport Standards, the development of the site R170 is UNSOUND and it must be removed from the LA DPD.
The site R170M is still 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 site R170M is not removed from the LA DPD.
This is a very important reason why site R170M should not be developed – JUSTICE.
Extract from page 137 item 6.9 of the Inspector's Report on the public enquiry in 1996. Green Gap site R170M is the site mentioned below.
"Inspector's Conclusions:
6.9 The objection by Mr Downham [biased land owner] is not concerned with the provision of a green gap, but the extent of that gap. It is argued [land owner’s words] that the green gap, as shown in the Consultation draft of the Plan, follows a public footpath running between substantial hedges, a clearly defined landscape boundary: whilst the residential allocation at Sparrowmire has been reduced in the Deposit Draft, an equivalent extension to the green gap is not necessary. ^However, and most importantly in my view, the objection indicates that the "land should remain unallocated as white land so that when the Plan is reviewed in 10 years' time it can be considered as potential residential land" [land owner’s words]. I consider this underlying reason for excluding the land from the green gap identifies the very reason it should remain so designated. Structure Plan Policy 14 and the reasoned justification makes no reference to the length of time during which the vulnerable areas of countryside between settlements should be protected.^ Although policies and proposals in the Local Plan must clearly relate to the Plan period, and can be subject to review thereafter, it appears to me common sense that what is unacceptable now, will most probably be equally unacceptable at the end of the Plan period: certainly I consider the Plan should seek to engender a degree of public confidence that the separation secured will not, at some future time, be lightly squandered. ^For these reasons I believe that, where a green gap is seen as necessary, it is more important that the whole gap between the settlements should be designated as green gap than that substantial, but arbitrary landscape features should be rigidly followed. I also consider the inter-visibility of settlements is not a factor which should affect the definition of green gaps."^
I have marked with ^...^ the most important words in the above paragraph and my clarifying words are in square brackets.
The first group of sentences marked ^...^ indicates that the owner wished to leave the remaining land (now site R170M) as white land, so it can sold as high priced building land at a later date. The inspector states that this is the very reason it must remain as a Green Gap and because of this statement it is Green Gap. The LA DPD only includes Green Gap site R170M because the owner is keen to sell and make a large profit, if he didn’t it would not be included.
The second group of sentences marked ^...^ indicates that “the whole gap between the settlements should be designated as green gap”. It must not depend on “landscape features” or “inter-visibility of settlements”, but these are the very reasons that SLDC state as to why site R170M can be built-on.
Site R170M is still currently a Green Gap site and by definition has more protection than all Greenfields.
A Government Inspector’s words made the white land (now site R170M) into Green Gap and must not be ignored. Therefore to include site R170M in the LA DPD until all the more suitable Greenfield sites have been built-on is UNSOUND.
This R170M Green Gap is also land of most value to the existing community as backed up by this statement in ‘The Taylor Review’ (Page 58):
“20. Government policy is to increase the density of new housing as a means to maximising land use and better support local services. New extensions to settlements therefore may be relatively densely designed and built right up against the existing settlement to minimise the number of green fields ‘swallowed up’. However, this will mean they are built on exactly the land of most value to the existing community – the fields or woods at the ends of their gardens, the green edge to the town. Local residents against new development may be accused of ignoring the needs of others for housing, but they have a genuine point. They may not have bought the right to their countryside views, but they certainly have paid for them, and these developments are on exactly the fields of most landscape value to existing residents."
Taylor gives a valid reason why local people should not be labelled with the scorning name NIMBYs’ when they have a good reason and evidence to oppose development in their neighbourhood.
The evidence above shows that the proposed LA DPD numbers for dwellings to be built are UNDELIVERABLE before 2025. If the numbers were reduced to ones that were deliverable and sound there would be no reason to include the peripheral site R170M in the last phase (2022-25) of the LA DPD, since it is a Green Gap and hence has a higher protection than any of the proposed Greenfield sites. Note at this point in time site R170M is still part of a Green Gap.
“The Community Infrastructure Levy is a new levy that local authorities in England and Wales can choose to charge on new developments in their area. The money can be used to support development by funding infrastructure that the council, local community and neighbourhoods.”
(see http://www.communities.gov.uk/planningandbuilding/planningsystem/communityinfrastructurelevy/ )
There is absolutely no evidence in the LA DPD about how much funding SLDC are capable of obtaining from developers from the levy. Their track record in the past has been very poor when negotiating for affordable dwelling percentages. The target over previous years has been 50% but SLDC of only achieved 28%. The target is now 35% which from past results is still just wishful thinking. SLDC are relying on this money to fund infrastructure and other projects. Until SLDC publish real evidence that the money raised from this levy is in excess (there will always be an overspend) of that required, for all the proposals in the LA DPD it is intended for, then the LA DPD is UNDELIVERABLE and UNSOUND.
With the excessive financial demands that will inevitably be placed on each development in terms of school places, direct highway consequences, a 35% affordable housing contribution etc, it seems highly likely that any contribution to an Infrastructure Levy for wider scale projects would be relatively modest and inadequate. These financial implications appear to again confirm that the proposals are UNSOUND.
Until it is certain that the required infrastructure funding will be available within the planned timescales, in order that SLDC meet their objectives on Air Quality and Junction Congestion, then the LA DPD is UNSOUND.
Site R170M will add further traffic to the streets of Kendal. Therefore site R170M must be removed from the LA DPD until the Northern Development Route has a approved construction plan and committed funding in place (see above). Also that it is shown to decrease the traffic levels in the Windermere Road corridor enough for SLDC traffic objectives are met in this area.
3.0 Further evidence in support of why Policy LA2.2 (site R170M) should be removed from the LA DPD.
3.1 Extracts from Kendal Town Council document "KTC_Response.pdf " (Apr 2011)
Page 8 Transport Improvements.
“The Assessment then looked at the impact of the various possible development sites which were then under discussion. The Assessment modelled the impact of various remedial measures that could be taken, ranging from junction improvements to the building of the Inner Relief Road. It concluded that the existing highway network plus proposed improvements would just about accommodate the forecast level of traffic, provided three sites were removed:
• Land within the Shap Road/Appleby Road corridor (Site E23/49 and Sites M8/M35/ M36)
• The Todds, west of Burneside Road (Sites R148/R170)
• Stonebank Green (Sites M39/R676/R103/R675)
There was no solution which permitted these sites to be developed within the parameters given for the Assessment (e.g. no compulsory purchase orders for major junction redevelopment).”
This supports previous evidence that the development of site R170M (The Todds) is UNSOUND
Page 9 section on “Sewer Capacity”
“In addition, United Utilities has concerns about the capacity of the Waste Water Treatment Works, located to the south of Kendal, for which process modelling needs to be carried out. This impacts all the potential development sites in the town.”
I have an email from SLDC dated 27Apr2011 which states:
“The following is based on information and advice provided by United Utilities.
1. United Utilities cannot determine the number of dwellings that will cause Kendal Wastewater Treatment Works (WwTW) to reach process capacity without conducting modelling. The threshold for when capacity is reached is determined by the design capacity of the WwTW and the population that it serves with some headroom designed in to the calculations. This headroom is not excessive as United Utilities cannot design and build for a population that is not already there or where development is not definite.
2. There are local network issues in respect of sewer capacity in the Kendal area . They are primarily centred around the Burneside area as evidenced in the Core Strategy and supporting Land Allocations Document material.
3. South Lakeland District Council does not hold or have access to data/information regarding the catchment area of the Kendal Sewerage Works.”
SLDC/UU admit that the headroom (i.e. spare capacity) is not excessive. Despite this SLDC have no results of any modelling and have not insisted that this modelling be carried out by UU. SLDC do not even know the catchment area for Kendal Sewage Works. There is nothing in the documentation on the SLDC web site to indicate that SLDC do have this information today (a year later). Therefore SLDC do not know how many dwellings can be built before Kendal Sewage Works needs a major upgrade costing many millions of pounds.
United Utilities move their funding from year to year as they see their immediate priorities change, so until they actual “sign on the dotted line” to meet certain dates then their current dates can “be taken with a pinch of salt”. As evidence to support this, the paying customers of Burneside have been waiting over 20 years to get their sewerage fixed and they still have sewage on the streets during heavy rain. So there is no guarantee that the North West Kendal problem will be fixed before 2025.
Site R170M is one of the last sites in the plan to be developed therefore until the above figures are known for the whole of the catchment area and UU & OFWAT have “signed on the dotted line” to meet their agreed dates then the site R170M is UNDELIVERABLE and the LA DPD is UNSOUND.
Page 9 section on “Hydrologic Considerations”.
“However, the mechanisms (some man-made, mostly natural) which are currently managing to keep Kendal free of floods are not well understood. Several of the sites included in the Land Allocations have a history of being badly affected by rainfall. This suggests they have a role to play in mitigating surface run-off and hence flood prevention. If this is correct, development of such sites could trigger flooding in the town - and making the sites themselves flood proof would certainly involve additional expense for developers.
Kendal Town Council believes this is an important omission from the current evidence base, and calls on SLDC to commission a full hydrology study of the area before including the affected sites in any final land allocation. Any remedial infrastructure required to allow these sites to be developed safely would need to be included in the overall infrastructure programme.
Land Allocations affected by this consideration are the lower Hallgarth sites (R169M and R170M), Appleby Road (MK35KM), Natland Beck at Kendal Parks (R107M, R150M), Stock Beck at Castle Green Road (R121M), and Stonecross (R103M), and Blind Beck (R129M)”
There is nothing in the documentation on the SLDC web site to indicate that SLDC have commissioned this study or have any results. Site R170M is mentioned in quote above and so until this study is carried out development of site R170M is UNDELIVERABLE and UNSOUND.
Page 10 Infrastructure.
“3. Sites should not be included in a Final Land Allocations document unless their impact on Kendal’s transport is understood, solutions are agreed with partners, and the impact has successfully passed a rerun of the Transport Assessment. ‘Emerging Option’ sites affected by this are indicated are indicated by an ‘X’ in the ‘Traffic’ column in the Detail by each Land Allocation site starting on page 11.”
Note site R170M has an ‘X’ in the Traffic column, so this site should be removed from the LA DPD until its impact on Kendal’s junction congestion is fully understood.
This section supports previous evidence that site R170M is UNDELIVERABLE and UNSOUND.
3.2 Extracts from Kendal Town Council doc. "KTCResponsePart2toLandAllocation.pdf" (Sep 2011)
Page 5 Doughnut Development
“Taylor contends: ...these developments undermine sustainability. They invariably encourage car use, especially if there are no services or employment within walking distance, with resulting congestion on roads into town. And without local and community facilities of their own, there is little to build social sustainability and cohesion or links between new and existing settlements as there will be little in the way of community life.
This approach to planning is also a recipe for confrontation, “developing exactly the land of most value to the existing community – the fields or woods at the ends of their gardens, the green edge to the town”
(as has been amply demonstrated in Kendal by the response to the Emerging Options consultation process).
Without change we will simply repeat the mistakes of recent decades, creating unattractive developments of housing estates encircling our rural towns and larger villages, and we will fail to stem the trend of smaller villages becoming dormitory settlements of commuters and the retired, ever less affordable for those who work within them. This is not a sustainable future for rural England.
Without strong Land Allocation policies from the Planning Authority, Kendal is heading towards an unsustainable “doughnutted” future.”
This confirms that development of the peripheral Green Gap site R170M is UNSUSTAINABLE and therefore UNSOUND.
Page 6 Recommendation for Kendal
“The Council believes the Planning Authority should follow Taylor and adopt this model in preparing its final Land Allocations policies for Kendal, as the only way in which the NPPF demand for sustainable development can be achieved in the town. It is important to note that this is not in conflict with the Core Strategy positioning of Kendal as a Principal Service Centre, or with the requirements for meeting forecast housing demand. From Taylor, the requirements for sustainable development in rural market towns is clear: it cannot be delivered by allocating isolated sites around the town; a hub and spoke model is required. Even without the NPPF’s insistence on sustainable development, there are other intrinsic advantages to the hub and spoke model for Kendal. The Council’s previous Response to Consultation highlighted the major infrastructure challenges to be overcome in the town. These become far more soluble if development proceeds on hub-by-hub basis, when the infrastructure work can be concentrated on the corresponding spokes. For example, it is far simpler to improve bus services, cycling provision, etc. if only one or two ‘spokes’ have to be addressed.
The evidence in the EHLSS shows that there are suitable sites available (the scope of the SHLAS only covered sites within existing settlement boundaries, and is of less relevance), and there are options both for completely new communities on green field sites, or for breathing new life into existing communities.”
This confirms that the “doughnut” strategy is incorrect for Kendal and should be replaced by the “hub & spoke” strategy. It also confirms that the peripheral Green Gap site R170M is unsustainable and therefore UNSOUND.
Page 10 Latest Forecasts (2011)
“The latest forecast in this series was produced in Spring 2011. It shows a drastically reduced requirement:
• only 360 dwellings across the 20 years, or
• just over 4,000 including migration, projected on the last five years’ evidence.
This suggests that a more appropriate target for the next 5-10 years would be around 200 dwellings per annum.”
This confirms the evidence given above that 200 per year is what is required and this number would be deliverable. If this number was planned then the peripheral Green Gap site R170M would not be required and being in the last phase would not be needed in this LA DPD.
This section supports previous evidence that the LA DPD is UNSUSTAINABLE and UNSOUND.
3.3 Extracts from Kendal Town Council doc. “Land Allocations Representation (2).pdf “ (Mar 2012)
Page 4 Summary
“The Council believes that the DPD is not justified because it fails the following tests of soundness:
• the LPA has failed in its duty to compare against reasonable alternatives
• key decisions are not supported by the evidence base or the evidence supports a different conclusion
• the evidence base is incomplete
The DPD is also not effective in that it is not deliverable, with key elements of the dependent infrastructure
not understood.”
This confirms the LA DPD is NOT DELIVERABLE.
Page 4
“For rural market towns, the evidence was pulled together in July 2008 by the Taylor Review9, setting out the policy framework necessary to deliver the “vision of a living, working sustainable countryside”. Taylor provided compelling evidence that “doughnut development” was the wrong approach for sustainable rural market towns, and that a “hub and spoke” model represented the best pattern for sustainability.”
The two KTC paragraphs above confirm that an alternative system must be adopted now, which will “meet the needs of future generations” of Kendal (i.e. BE SUSTAINABLE”) for the many thousands of years to come.
Page 4
“The evidence in the EHLSS indicates that suitable sites could be available (the scope of the SHLAA only covered sites within existing settlement boundaries, and is of less relevance), and there are options both for completely new communities on green field sites, or for breathing new life into existing communities.”
This confirms that a “hub & spoke” is viable.
Page 5
“The Assessment concluded that the existing highway network plus proposed improvements would just about accommodate the forecast level of traffic, provided three large sites were removed. The consultants could find no mitigation which would permit these sites to be developed within the parameters given for the Assessment (e.g. no compulsory purchase orders for major junction redevelopment.)”
This confirms that site R170M must be removed from this LA DPD because it is one of the three sites.
Page 5
“Given that this approach has differed significantly from the independent consultants’, the Council asks the Inspector to order an independent audit of this latest work by W.S.Atkins or equivalent to ensure it meets accepted professional standards of objectivity and integrity. The Council further asks the Inspector to ensure that no sites are included in the DPD which the evidence shows are not deliverable on transport grounds.”
This confirms that site R170M must be removed from this LA DPD, because it is one of the sites which “are not deliverable on transport grounds.”
Page 7
“The Council asks the Inspector to withhold approval of the DPD until there is a credible infrastructure plan showing the impact of the major sites on the overall town infrastructure, and with high level solutions identified and costed with enough detail to enable the economic deliverability of the sites to be proven.”
This adds to the evidence given above that there must be signatures, to supply the necessary infrastructure and funding, must be in place before this LA DPD is approved by the Government. Until this is done site R170M is UNDELIVERABLE and UNSOUND.
This section supports previous evidence that site R170M is UNDELIVERABLE and UNSOUND.
3.4 Extracts from SLDC document "Kendal Transport Study (Jan12).pdf ”:
Page 5 Exec Summary (see also 6.1.6 on page 18)
"10. The LDF developments have a more notable impact in the AM peak compared to the base situation. The model results indicate that the provision of sustainable transport improvements (Scheme 2) would be required to support LDF development to nil-detriment compared to the 2022 base situation in the AM peak. However, the provision of a new route along Dowker’s Lane (scheme 4) would be required if the Rugby Club development is included. If the Canal Head development is included, the proposed Kendal Northern Development Route (Scheme 5) would be required.
11. It should be noted that although these schemes are required to achieve nil-detriment, these improvements are only demonstrated to offer marginal benefits to the performance of junctions in Kendal. These infrastructure schemes would be expensive and may not be a cost-effective solution to congestion in Kendal town centre.
12. Furthermore, even with the implementation of these improvement schemes, it is important to note that a large proportion of the key junctions would continue to operate above capacity, and therefore experience congestion and extensive queuing in the 2022 base situation. This situation would be compounded by the LDF development traffic.
13. It is recommended that further modelling work is undertaken"
The Transport Study shows that the objectives cannot be achieved before 2025 therefore the problems are going to be much worse in the years 2026 onwards.
SLDC do not have signed-off solutions and timescales in place to meet the plan phases, therefore the LA DPD is UNDELIVERABLE and UNSOUND.
Page 9 This page gives the CCC/SLDC definition for Junction Congestion limits.
"Acceptable junction performance is indicated by a degree of saturation below 90 percent for signal-controlled junctions, or an RFC below 85 percent for priority junctions and roundabouts."
The Atkins report uses a Volume/Capacity ratio of 90 as acceptable for a junction approach, which is similar.
The Study shows that these objectives will not be met by 2025 so this, along with page 10 (see below) adds evidence to the above.
Page 10
"4.2.2 In total 13 junctions are indicated to have a maximum RFC greater than or equal to 90% in the 2010 base year, in either the AM or PM peak period. These are:Junction1: A5284 Stricklandgate/Sandes AvenueJunction 2: A5284 Sandes Avenue / A6 Blackhall Road signalised junction
Junction 5: A6 Longpool / Station Road mini-roundabout junction
Junction 12: A6 Highgate / Lowther Street signalised junction
Junction 22: Parkside Road / Valley Drive priority junction
Junction 16: A6 Milnthorpe Road / Romney Road signalised junction
Junction 17: A5284 Windermere Road/Queens Road
Junction 18: A5284 Windermere Road/Burneside Road
Junction 21: A65 Burton Road / Oxenholme Road signalised junction
Junction 27: A684 Sedbergh Road / Sandylands Road priority junction
Junction 29: A6 Shap Road / A685 Appleby Road (north) priority junction
Junction 30: A6 Shap Road / A685 Appleby Road (south) priority junction
Junction 31: A685 Appleby Road/Sandylands Road"
“Measures must be in place” to fix these major problems first (i.e. meet SLDC objectives). They have a huge bearing on why SLDC is still breaking the law on Air Quality.
Page 14
“* Scheme 6: Scheme 5, plus a potential Kendal Southern Link Road, which comprises a new single-carriageway road linking the A6 Milnthorpe Road with the A65 Burton Road south of Kendal town centre.”
This new road proposal has never been mentioned before; it is not in the Core Strategy and therefore, as we have been told before, it cannot be considered in this LDF.
This section supports previous evidence that site R170M is UNDELIVERABLE and UNSOUND.
3.5 Extracts from SLDC document "06 Infrastructure Position Statement.pdf ”:
Page 10
"4.19 United Utilities has a statutory duty to develop and maintain an efficient and economical system of water supply within its area. A proposal for expenditure in the years 2010 – 2015 is contained within the published five years Investment Plan (Asset Management programme). The plan can be found at the following website link: http://www.unitedutilities.com/Documents/Detailed_plan.pdf "
There is nothing in this PDF document that is specific to Kendal.
UU may have "a statutory duty to develop and maintain an efficient and economical system of water supply within its area" but it is very poor at obeying this duty as is verified by the > 20 years Burnside have been suffering sewage problems (and still are).
Until UU actually “sign on the dotted line” to meet the required planned timescales and commit funding, the LA DPD is UNDELIVERABLE and UNSOUND.
Page 11
"4.23 Funding is more likely to be acquired in cases where there is development certainty (i.e. clear evidence of developer interest).
* UU reiterate that even if a bid is submitted there is no guarantee funding will be approved by OFWAT. The speed at which approved schemes are implemented will depend on the priority given to schemes within the 5-year programme and the time required to design, obtain planning permission and construct."
This backs previous evidence, never mind “development certainty” what about the existing paying customers who are still suffering sewage and flooding problems due to lack of investment.
Until United Utilities “sign on the dotted line” and commit to planned dates and funding the LA DPD is UNDELIVERABLE and UNSOUND.
Page 11
"4.24 There is currently loading capacity at Kendal Waste water Treatment Works (WwTW), however, for the number of dwellings that are proposed a full process and hydraulic survey of the Works will have to be undertaken before UU could comfortably approve the Planning Applications. As the sewer network is at capacity in North Kendal, UU could not agree to any significant development until after 2015 in this part of the town. Providing UU obtain funding through OFWAT to undertake the necessary upgrades etc. UU will be building into the 2014 Business Submission to OFWAT a case for funding to provide the means to accommodate development, which will boost the economy.
4.25 A feasibility study is being undertaken on the Kendal WwTW. Recommended phosphorous levels are set by Environment Agency (EA) through discharge consents, and until EA impose a new requirement for a lowered rate, UU will continue to discharge at the current rate. UU stated achieving any required lower rates would depend on new/better technology. Further Phosphorous removal would only be undertaken if UU were required to achieve a tighter standard as set by the EA following their review of water quality. Newer technology, which is not currently available, would be required to achieve any standard below 1mg/l. UU has advised development in the Kendal area should be capped at 2000 properties unless a more stringent phosphorus effluent standard can be achieved.
4.26 UU has advised that sites in North Kendal should only come forward in the latter periods of the plan period when sewage network improvements are in place.
4.27 Strategically there is enough water supply to accommodate levels of new development, but there are potential risks of deterioration of water quality."
Until OFWAT “sign on the dotted line” and commit to planned dates and funding the LA DPD is UNSOUND.
Page 14
"4.45 Electricity North West Ltd manage infrastructure and distribute and transmit electricity throughout South Lakeland. The regulator determines the amount of funding, however, it is not known what the next round of funding may or may not allow for investment in improvements. Information relating to substation capacity has not been ascertained. Evidence when exploring options for the Canal Head Area of Kendal shows that the Kendal Primary substation is currently operating close to or at capacity. It is possible that significant development in Kendal would require investment for network reinforcement and that a new Primary Substation would be required although Electricity North West Ltd does not confirm this. No information has been made available stating whether this is the case. Only when the customer has firm load requirements and location details can a system study be undertaken to ascertain the scale of impact of potential new development."
What if the system study states it cannot be done or they cannot obtain the funding within the plan timescales? Electricity North West Ltd already has the number of houses proposed and their locations so they must commit to a system study and confirm that the proposed developments are deliverable. Until then the LA DPD is UNSOUND.
Page 15
"4.48 National Grid Gas Distribution own and operate the local gas distribution network in South Lakeland. The confidential nature of the process means National Grid are unable to confirm whether they are currently processing or have made any offers for connection within Cumbria."
The document states nothing about National Grid Gas Distribution having a statutory duty to develop and maintain an efficient and economical system of gas supply within its area.
The LA DPD cannot possibly be monitored correctly until all the Gas company has “signed on the dotted line” to meet the timescales required. Until then the LA DPD is UNDELIVERABLE and UNSOUND.
This Infrastructure document is only a statement; there is no indication when the Infrastructure Delivery Plan will be available to the public or any indication that the timescales can be met. The LA DPD is UNSOUND until the Infrastructure Delivery Plan and the Kendal Transport Plan are available with all milestones agreed, funding committed and both signed off by the respective utility companies. They can have the proviso that it depends on the build going ahead as planned.
3.6 Extracts from SLDC document “01 Consultation Report.pdf ”:
Page 19
“In their response the Highways Agency identified those sites it considers (if developed, due to cumulative impact with other sites) may impact upon the capacity, operation and safety of the strategic road network (SRN) (A590 and M6) within South Lakeland. As a consequence, the Agency has stated that the cumulative impact of development of sites under consideration in the following settlements (see below) may result in some impact to the SRN: Burneside, Crooklands, Endmoor, Kendal, Kirkby Lonsdale, Levens, Milnthorpe and Ulverston alongside the sites suggested for strategic employment use (in Ulverston and Kendal area).”
Note the word “may” on the second line. They either do or they don’t. After all these years of the LDF there is no excuse for this information not being available. SLDC must obtain an answer to this issue immediately and publish it. If any of the developments proposed within the LA DPD do affect the Strategic Road Network then any changes necessary must be included in the LA DPD and the Transport Plan (which must be issued before the hearings). Note the Strategic Road Network is NOT currently mentioned in the LA DPD.
Page 21
This page with reference to Burneside states:
“.....this is no guarantee that funding will be approved by OFWAT”.
Until OFWAT “sign on the dotted” line to meet the planned timescales the LA DPD is UNSOUND.
Page 21
“Additional work is needed by UU to check if cumulative impact on treatment works may raise capacity issues
SLDC must publish how many houses can be built in the Kendal catchment area before a major upgrade to the sewage works is required. Until UU know their total funding requirements the LA DPD is UNSOUND.
Page 34
KENDAL
“Many people believe development of the sites suggested would harm the landscape character of the town, worsen air quality, exacerbate current flooding problems, harm biodiversity, generate unacceptable levels of traffic congestion, and place further strains on a heavily constrained sewerage system. Some people questioned the need for additional housing believing there are enough empty properties in the town to meet current and future housing demands. A number of people stated development should be prioritised on brownfield sites and meet primarily local needs.”
“Many people including Kendal Town Council and Burneside and Natland Parish Council’s supported the concept of green gaps to protect Kendal coalescing with neighbouring settlements. However, a significant number of people and Kendal Town Council and Natland Parish Council believed the suggested emerging options would not prevent coalescence from happening. There was general widespread support for the open space designations suggested, however, many people believed the emerging options sites should also be designated open space.”
“Kendal Town Council expressed serious concerns with the overall approach being suggested for the town, believing the amounts of developments and the emerging option sites suggested would damage the landscape character of the town, and put unnecessary strain on an inadequate infrastructure system. The Town Council has suggested an alternative strategy/approach for the town this being to protect existing green space/countryside surrounding the town and to look at alternative sites adjacent to nearby settlements and possibly further afield where development would have less impact on the town’s infrastructure, air quality and its high quality landscape value.”
These three paragraphs confirm that the wishes of the majority of local people have been ignored and adds support to the evidence given above concerning Consultation and Legal Compliance.
Page 46
On this page it states “UU is currently considering lists of projects that will require major capital investment in Asset Management Plan 6 period 2015-2020.” and “UU reiterate that even if a bid is submitted there is no guarantee funding will be approved by OFWAT. The speed at which approved schemes are implemented will depend on the priority given to schemes within the 5-year programme and the time required to design, obtain planning permission and construct.”
Until United Utilities and OFWAT “sign on the dotted line” to meet the planned timescales and commit funding, the LA DPD is UNDELIVERABLE and UNSOUND.
This section supports previous evidence that site R170M is UNDELIVERABLE, UNSOUND and that consultation process was not Legally Compliant.
3.7 Extracts from SLDC document “Land Allocations DPD.pdf ” [Mar12]:
Pages 51 & 52
Item 3.6 - Key local factors influencing the location of new development in Kendal:
“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; Avoiding coalescence between Kendal, Oxenholme, Burneside and Natland and maintaining the separate identities of these settlements;
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;
Infrastructure constraints including sewage capacity at Kentrigg and Steele's Row and the implications for development in northwest Kendal.”
One of the main comments of the people who responded to the SLDC consultations and opposed them was the character and appearance of Kendal. This is imbedded in the above paragraph and has been totally ignored. The LA DPD is therefore not Legally Compliant.
The site R170M is close to Kentrigg (mentioned above) and so it is UNSOUND to include it in the LA DPD until United Utilities are fully committed (i.e. signed on the dotted line) to the LA DPD timescales.
The sentence “Minimising the impact of development on Kendal’s central traffic system, …..” is not definitive it should state “Meet and maintain SLDC’s standards and objectives with regard to Kendal’s central traffic system, …..”
Page 163 APPENDIX 4 - HOUSING TRAJECTORY
A graph on this page it shows the following numbers over the years 2003 – 2025 (22 years).
Maximum number of dwellings ever built in one year was 300 in year 2005/06 and even this did not reach the target of 400 per year.
Extrapolating from the graphs the average number of dwellings built per year for the first 8 years was 100+280+150+150+240+300+230+220 = 1670 / 8 = 209 per year. In the terms of this graph there are already an extra 1530 dwellings (109/yr on top of the 400/yr) that have built just to catch up. This compares well with the more accurate figures in section 2.1 above.
The figure of 720 per year for the three years 2022 – 2025 is just WISHFULL THINKING.
One of the questions that must be asked to confirm SOUNDNESS is “Are there realistic timescales related to the objectives”. The above numbers are clearly not realistic therefore the current LA DPD is UNSOUND.
This section supports previous evidence that site R170M is UNDELIVERABLE and UNSOUND within the timescales of this LA DPD (2025).
4.0 Changes required to the LA DPD document title “Land Allocations DPD.pdf ” [Mar12]:
4.1 During the recent SLDC consultation 98% of the local neighbourhood who responded OPPOSED the proposals for site R170M. In a door-door poll of over 400 neighbours during 2011 approximately 80% of those asked OPPOSED the proposal to build on site R170M. Of the remaining 20% most did not care one way or the other. The Localism Bill is a Con Trick (nice pun); it promises much but does not actually support what the majority of the people in the neighbourhood want.
To prove SLDC are DEMOCRATIC they must be serious about responding to the majority of the local neighbourhood’s wishes. Also the TOTAL CONCLUSIVE EVIDENCE ABOVE PROVES THAT SLDC MUST REMOVE THE PERIPHERAL GREEN GAP SITE R170M FROM THE LA DPD TO MAKE IT SOUND. THIS IS HOW THE LA DPD MUST BE CHANGED.
4.2 After many years (before year 2000) of knowing about the traffic problems in Kendal, SLDC have failed to produce a transport plan or action plan that enabled them to meet their standards and objectives for Air Quality and Junction Congestion. This must NOT be allowed to continue. Only when these standards and objectives have been PROVEN to have been met (with spare capacity for expansion) will the people believe SLDC are serious about tackling these major problems. The recent SLDC consultations show that increase in traffic was one of main reasons why 98% of the people (that responded) OPPOSE the proposals to build on sites in their area of Kendal.
Previous experience with Core Strategy has shown me that all my evidence will be ignored and that site R170M will not be removed from the LA DPD. If this is to be repeated then I would like to see the following changes to LA DPD.
There is a note on page 57 (item 3.18) of the LA DPD (policy LA2.2 site R170M) which states:
"DEVELOPMENT OF THIS SITE CANNOT TAKE PLACE UNTIL MEASURES ARE IN PLACE TO RESOLVE PRESSURE ON THE SEWERAGE NETWORK IN NORTH KENDAL."
This means existing problems will be fixed before building starts.
THIS SETS A PRECEDENT WHICH MUST CONTINUE WITH REGARD TO OTHER MAJOR PROBLEMS.
The threat to the health of people due to air pollution is of as much importance as sewage on the streets. Site R170M will add more traffic to the streets of Kendal and make air pollution worse. Therefore a note must be added to Policy LA2.2 (item 3.18) that states:
"DEVELOPMENT OF THIS SITE CANNOT TAKE PLACE UNTIL MEASURES ARE IN PLACE TO SHOW THAT THE LAW ON AIR QUALITY HAS BEEN MET IN KENDAL."
Increase in traffic, which leads to more junction congestion and a deterioration in the well-being of local people, was one of the major complaints in the recent SLDC consultations. Site R170M will add more traffic to the streets of Kendal and make junction congestion worse. Therefore a note must be added to Policy LA2.2 (item 3.18) that states:
"DEVELOPMENT OF THIS SITE CANNOT TAKE PLACE UNTIL MEASURES ARE IN PLACE TO SHOW THAT SLDC’S DEFINITION OF “ACCEPTABLE JUNCTION PERFORMANCE” HAS BEEN MET IN KENDAL."
For definition see page 9 of “Kendal Transport Study (Jan12).pdf”.
“4.1.5 An RFC or DoS of 100% indicates that an approach is operating at maximum capacity. Acceptable junction performance is indicated by a degree of saturation below 90 percent for signal-controlled junctions, or an RFC below 85 percent for priority junctions and roundabouts. Above this level, an approach is likely to begin to experience congestion as there is insufficient spare capacity to cope with fluctuations in traffic flow.”
4.3 Page 51 item 3.6:
The sentence “Minimising the impact of development on Kendal’s central traffic system, …..” is not definitive. The word “Minimising” is just not good enough to meet the people’s wishes. It must state “Meet and maintain SLDC’s standards and objectives with regard to Kendal’s central traffic system, …..”
4.4 Page 163 APPENDIX 4 - HOUSING TRAJECTORY
This Appendix 4 must be changed and other pages which quote these figures. The SLDC evidence does not support the requirement that anywhere near the 8800 dwellings can be built before 2025. The numbers in the graph are not realistic (a SOUNDNESS word), therefore NOT DELIVERABLE and UNSOUND. 720/year for last three years is just wishful thinking, it is not realistic; this graph shows that the maximum that has ever been built within the last 8 years is 300 per year for the year 2005/06. The developers will not build 750 per year because it would swamp the market and they would be left with a large number of empty houses.
There is no point in just stating on page 7 of the LA DPD that it is “the ambition to deliver 400 dwellings each year” if these numbers cannot realistically be built and sold. There is also no point in just monitoring these numbers just so a box can be ticked to say they have been monitored. The numbers must be realistic so that they can be monitored and vigorously progressed.
Kendal Town Council have stated in one of their reports [Sep2011 see above] that only around 200 dwellings per year is the number required. SLDC must discuss this issue with KTC and reduce the current total figure of 8800 to a number that can realistically be built & sold before 2025 and not one that is just WISHFULL THINKING.
4.5 There is a requirement in the Core Strategy for Brownfield land to be used for “at least 28%” of the number of dwellings built. Note the words are “at least” not it is the “ambition to use”. To be SOUND the LA DPD must indicate the amount of Brownfield land that is currently available and the targets for each area. These figures must be monitored, vigorously progressed and be made available to the public.
4.6 SLDC must discuss Kendal Town Council’s three reports in detail with the town council and members of opposition groups (e.g. Green Spaces). I would like to see the LA DPD changed to incorporate as much as possible of that which is agreed in these discussions.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
THE HEALTH AND WELL-BEING OF LOCAL PEOPLE MUST BE AT THE TOP OF SLDC's PRIORITY LIST and despite all my emails and protest at the Core Strategy hearings this has not yet been done in Kendal.
So I wish to speak face to face with the inspector and ask him personally if he will recommend in his report that notes be added to the LA DPD stating that SLDC must fix their major existing problems first and meet the SLDC/CCC definition for "Acceptable Junction Congestion" and the Law on Air Quality before allowing actual build of site R170M, which will add to these problems (see examples of notes in section 4.2 above).
A PRECEDENT has already been set by a note in Policy LA2.2 for site R170M relating to the sewerage network in North Kendal. If United Utilities have to fix their major existing problems first before building is allowed then so must SLDC, this is logical and should not need a political decision.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
916. Mr Derek Whitmore (Individual) : 17 May 2012 11:06:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Paragraph No.
0.0 Whole Document
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
1.0 Consultation
1.1 SLDC did not change the proposals in-line with the citizens important wishes.
The Government Planning Advisory Service (PAS) defines the requirements for Legal Compliance in it’s document – "legal.doc” (Legal Compliance Tool from http://www.pas.gov.uk/pas/aio/85651 )
Extract from Stage 2: Plan preparation - frontloading phase (page 7):
“6. Does the consultation contribute to the development and sustainability appraisal of alternatives?”
This has not been carried out correctly, alternatives have not been seriously considered. In particular the Kendal Town Council’s excellent reports, containing good alternatives, have been ignored.
The vast majority of the oppose responses made in the SLDC consultations were noted, listed in the consultation documents and then almost totally ignored. In my view these consultations were just so that SLDC could “tick the box” for the government inspector and therefore were a waste of taxpayers money.
I have done a detailed examination of the SLDC Consultation Database and these are my findings:
On 11th August 2011 (after the closing date) there were 2986 responses from the Kendal settlement. 98% of these responses opposed the proposals in their neighbourhood. Most of those that “support in part” did not support housing. Most of the few indicating “support” were representatives of the land owner, potential builder, Kendal Futures Board or the North West Development Agency.
The main reasons for the respondents opposition was the increase in traffic that these proposed developments would cause, and the affect they would have on the landscape character of Kendal. Better alternative sites were suggested, noted and then ignored. The present proposals will not “satisfy the needs of future generations” and are therefore NOT SUSTAINABLE.
Issues raised in the consultations would have contributed greatly to the development and sustainability of alternatives but the alternatives put forward have been ignored (also see other evidence 2.3 below). Therefore the LA DPD it is not Legally Compliant.
I would like to see alternatives discussed with Kendal Town Council and the Green Spaces group. Then any changes agreed included in the LA DPD.
2.0 Alternative plan
2.1 Law must be obeyed.
Extract from Stage 2: Plan preparation - frontloading phase (legal.doc page 5):
“* developing alternatives and options and appraising them through sustainability appraisal and against evidence.”
The SLDC Air Quality reports show that SLDC have been breaking the Law on Air Quality for many years. It means that SLDC must use an alternative plan for Kendal until it is proven that the law is being obeyed (with spare capacity for proposed development). The reason the law must be proven is that action plans have not worked for at least 14 years (before 1998). In the meantime affordable houses can be built in other areas of SLDC which have low traffic.
Until an alternative plan is in position to ensure the law on Air Quality is obeyed (with spare capacity for the proposed development) the LA DPD is not Legally Compliant.
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These Legal Compliance requirements are not definitive or closed questions; they are open to personal interpretation, so I will not make any further comment in these sections.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Personal Comments:- From my experience of the Core Strategy hearings and the SLDC consultations I know my response will be ignored. The changes to Kendal’s infrastructure, that the new SLDC Transport Study (Jan12) states are required (see below), is just one example of this. I am therefore taking this opportunity to place on record all the relevant evidence I have gathered on why site R170M (policy LA2.2) should not be included in the LA DPD. Quotes from certain documents have been added to make it easier for the reader. There is repetition of some issues but this is because I have added different sources of evidence throughout the document.
It is undemocratic just to include Legal Compliance and Soundness in this consultation. In a democratic society the wishes of the majority of local people would have priority over these criteria. Also criteria such as “Justice” and “Fairness” should be considered. These were totally ignored in the Core Strategy consultation and hearings.
Test of Soundness
1.0 Not justified
1.1 Health and well-being of citizens in Kendal.
I have been informed that a developer does not have to fix an existing problem he just needs to show that he will not make it any worse. This is ridiculous, while SLDC are breaking the law on Air Quality developers must not be allowed to build on site R170M and other Kendal sites until the law is obeyed. SLDC breaking the law must surely be enough to prevent developers from winning an appeal. The people’s health and well-being must have top priority over everything else in the LA DPD.
The latest Cumbria County Council’s transport plan LPT3 does not include plans for the necessary infrastructure to fix existing problems neither does the SLDC Core Strategy. It was only after pressure from the public that SLDC & CCC produced the Transport Study (which is only a study) and after all this time the Transport Plan has not yet been made available to the public. Without a Transport Plan (including committed funding) signed off by all the participants the LA DPD is UNDELIVERABLE within the current timescales (2025) and is UNSOUND.
Before the year 2000 the SLDC objective was to meet the law on Air Quality by the year 2005 but air pollution has continually increased and the AQMA (Air Quality Management Area) has even been made larger. This shows that SLDC are not serious in meeting their objectives where the health and well-being of citizens, or obeying the law, are concerned.
A typical example is the approval of the Planning Application for the old Auction Mart site. Also planning approval is certain to go ahead for the Canal Head development. These will make the air pollution worse in the AQMA. The worst pollution occurs when junctions are grid-locked and tinkering with traffic lights will not fix this problem. It will take major infrastructure changes to fix the existing traffic problems and allow for proposed LDF expansion. The Transport Study even admits that none of the improvements schemes will meet SLDC objectives.
Extract from SLDC document "Kendal Transport Study (Jan12).pdf ”:
“6.1.6 Furthermore, even with the implementation of these improvement schemes, it is important to note that a large proportion of the key junctions would continue to operate above capacity, and therefore experience congestion and extensive queuing in the 2022 base situation. This situation would be compounded by the LDF development traffic.”
More building is planned in Kendal within the next few years (phase 1). This will make the major traffic problems worse. Infrastructure should already be in place to cope. Instead there is not even an approved Transport Plan in place, never mind the infrastructure that will be needed to meet SLDC standards and objectives.
The Transport Study is stating that further modelling is required. This shows that SLDC do not yet know at the present time if their proposals can be implemented or if funding will be available within the LDF timeframe (year 2025), therefore the LA DPD is UNSOUND. Once money has been spent on major infrastructure changes it will be expected that these changes will last for at least 15 years (through the next LDF) therefore any further modelling must use a date of 2040 or beyond. These results will prove that the Taylor “hub & spoke” must be started now (see more evidence below).
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. The health of residents of Kendal town should also cause great concern; a lot of them are elderly and frail.
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.
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 LA DPD maps for the SLDC district, have not been included on the latest maps. It is not fair that these traffic problems are not shared throughout the entire SLDC district. This is another reason why the hub & spoke system must be adopted – FAIRNESS.
The health and well-being of the people due to air pollution must have top priority over everything else in the LDF. This is not happening with the current proposals. Proving the law is being obeyed must come second on the priority list after health. If it does not already do so the “Soundness” examination must take account of these two very important issues.
The evidence above shows that these traffic problems in Kendal will not be fixed without major infrastructure changes which are not in Cumbria County Council’s LTP3.
Site R170M will add further traffic to the streets of Kendal. Therefore the LA DPD is UNSOUND and site R170M must be removed from the LA DPD until the Northern Development Route has an approved construction plan and funding (see above).
For more evidence see extracts from the SLDC Transport Study (Jan12) below.
1.2 Alternative strategy.
Although SLDC have carried out consultations they have ignored the major objections. They have even ignored the alternatives put forward by Kendal Town Council in their excellent reports - “KTC_Response.pdf ”, “KTCResponsePart2toLandAllocation.pdf ” & “Land Allocations Representation (2).pdf. ". To avoid even more “urban sprawl” of Kendal the Taylor “hub & spoke” strategy must be adopted and not the current “doughnut” strategy. Kendal will be around for many thousands of years to come, which makes the “doughnut” strategy UNSUSTAINABLE (i.e. will not satisfy the needs of future generations). Only the “hub & spoke” is sustainable in the years to come because extra “satellites” can be added. By then the proposed “doughnut” system will make Kendal such an urban sprawl that very few people will wish to live there. To prevent this happening the “hub & spoke” system must be started NOW.
Money is being put before what is best for the health and well-being of the people of Kendal now and in the future (beyond 2025).
The Taylor Report, which puts forward compelling evidence in favour of the “hub & spoke” system, shows that the proposed “doughnut” system is UNSUSTAINABLE and therefore the development of site R170 (being a peripheral Green Gap site) is UNSOUND and must be removed from the LA DPD.
2.0 Not effective
2.1 Not meeting definitions of soundness.
The Government Planning Advisory Service (PAS) defines the requirements for Soundness in the document - "soundness.doc" (Soundness Tool from: http://www.pas.gov.uk/pas/aio/85673 )
Extract from page 6 - Deliverable:
"21. Are there realistic timescales related to the objectives?
i. Sections of the development plan document which address delivery and the timescales for key developments and initiatives.
ii. Confirmation from the local strategic partnership and partner organisations that the timescales are realistic in terms of their contribution to delivery."
Extract from page 8 - Deliverable:
“28. Is it clear who is going to deliver the required infrastructure and does the timing of the provision complement the timescale of the strategy/policies?
i. Confirmation from infrastructure providers that they support the solutions proposed and the identified means and timescales for their delivery.
ii. Representations in respect of infrastructure.
iii. Reports or copies of correspondence on how representations in relation to infrastructure and its timing have been considered and dealt with.”
Extract from page 5 of SLDC document "Kendal Transport Study (Jan12).pdf ”:
Exec Summary (see also 6.1.6 on page 18)
“12. Furthermore, even with the implementation of these improvement schemes, it is important to note that a large proportion of the key junctions would continue to operate above capacity, and therefore experience congestion and extensive queuing in the 2022 base situation. This situation would be compounded by the LDF development traffic.”
I have only selected this one paragraph; there are numerous other paragraphs which support these conclusions. In particular Page 15, Item 5.2.1, Table 5.1 which confirms that all schemes fail to meet SLDC’s objective. The results in Tables 5.2 & 5.3 are even worse.
SLDC’s objective is to meet “Acceptable junction performance” which is defined on page 9, item 4.1.5.
I'm not sure why the year 2022 was chosen as base-line, whatever major infrastructure is planned must enable SLDC to meet their objectives for years beyond 2025. In my opinion until 2040, the end of the next LDF.
Schemes 4, 5 & 6 require major investment and are not in the Core Strategy and therefore must be excluded from the Transport Plan when it is published. Note that the Transport Plan should incorporate extra capacity to cope with the “doughnut” system which, if approved, will undoubtedly continue after 2025.
The SLDC Air Quality Reports show that air pollution is getting worse in Kendal and also the AQMA has been increased.
Extract from page 27 of Air Quality Report (PR_Report_Template_2010.pdf)
(see http://www.southlakeland.gov.uk/downloads/page857/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”. Over many previous years this is typical of SLDC’s attitude towards obeying the law on Air Quality. SLDC action plans have not worked in the past and this is proved by the fact that the AQMA has recently been made larger.
The SLDC document "ED43_Housing Completions 1999 to 2010.doc" plus SLDC updates show that from the beginning of plan period 2003 to end of 2011 (8 years results) the total for South Lakeland is 1690 / 8 = 211 average and of these affordable are 406 / 8 = 51 average (or 24%). Figures for 2006 to 2011 (last 5 years results) are 934 / 5 = 187 average and of these affordable are 264 / 5 = 53 average (or 28%).
Between 2003 and 2011 the number of completions was 1690. At 400 per year the objective was 3200 over this 8 year period, a difference of 1510. To make up this deficit means that over the remaining 14 years (up to 2025) an extra 1510 / 14 = 107 per year will be required. This extra number per year will get a lot higher when the build rate stays below 400 per year.
This is nowhere near the Core Strategy figure of 400 dwellings per year or the percentage affordable figure of 35% and therefore the LA DPD is UNDELIVERABLE. 200 dwellings per year would be a more realistic figure and this is the latest figure that is necessary according to a Kendal Town Council Report (see below).
SLDC have recognised this and have added the word “ambition” to build this number of houses to the LA DPD (see page 7 of the “Land Allocations DPD [Feb 12].pdf ” as an example). This word is not used in this context with regard to numbers in the Core Strategy document. Therefore the LA DPD is UNSOUND with respect to the Core Strategy. The Leader of the Council insisted the numbers in the Core Strategy were achievable within the timescales of the LDF.
The above figures show there was an inward migration of 3 (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 all the partners involved have “signed on the dotted line” that they will meet the LA DPD milestones for all the necessary infrastructure (roads, sewerage, doctors, dentists, schools, etc) that is required. With the proviso that the build will actually take place in the timescales planned. It causes unnecessary stress to local people when unachievable targets are proposed or planned.
Another issue that affects DELIVERABILITY is Brownfield sites (or previously developed land).
It states in "SLDC_Core_Strategy_Document_March2011_sm4web2.pdf " (page 17):
"CS1.2 – The Development Strategy
Priority will be given to the reuse of existing buildings and previously developed land for all new housing development, with a target of ensuring that at least 28% of new housing development takes place on such sites."
The “at least 28%” is also mentioned in CS6.6 (page 85). The 50% in item 7.14 is a mistake, it was the previous target. Now the target has been lowered, and "at least 28%" is said by SLDC to be achievable, the LA DPD must indicate the amount of Brownfield land that is currently available and the targets in each area. The Core Strategy and LA DPD have a requirement to be monitored and targets at least progressed vigorously.
The LA DPD does not mention this requirement; therefore it does not conform to the Core Strategy and is UNSOUND. Also these monitored figures need to be published and available to the public.
The SLDC Transport Report (Atkins 2009) 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." There are more similar comments on pages 60 & 71.
Site R170M feeds traffic into Windermere Road and therefore must be removed from the LA DPD until SLDC have met their objectives on Air Quality and Junction Congestion.
Extract from SLDC document "Kendal Transport Study (Jan12).pdf ” page 5 (Exec Summary):
"However, the provision of a new route along Dowker’s Lane (scheme 4) would be required if the Rugby Club development is included. If the Canal Head development is included, the proposed Kendal Northern Development Route (Scheme 5) would be required."
The Canal Head development is more important to Kendal than site R170M therefore because site R170M will add more traffic to Kendal streets it is UNSOUND to build on it. It must be removed from the LA DPD until the Northern Development Route has an approved construction plan and committed funding.
Page 115 of the document “KENDAL Appendix 1.pdf ” (Appendix 1B – Consultation Responses after October 2010) for site R170M states:
“Achieving adequate visibility will be problematic given alignment of road and limited frontage. Such a large site would require a secondary access (Cumbria County Council – Highways).”
The conclusions reached by a chartered civil engineer who has carried out measurements to Transport Standards of the proposed access to site R170M are as follows:
“There is severely restricted forward visibility on both bends in Burneside Road either side of the proposed access location.
In either scenario tested the visibility from the proposed access towards Kendal falls far short of the standard required.
A new junction cannot be safely introduced in this location.”
This report can be supplied if required.
It cannot be right not to identify this secondary access. When it is identified there will be a lot more opposition to site R170 than is currently expressed.
As I said at the beginning of this response about including “JUSTICE” and “FAIRNESS”, it is not FAIR to include a site which is likely to have “show stopping” problems without first carrying out a thorough investigation into these particular problems.
Given the evidence above, until it can be proved that both access roads can be built to meet the Transport Standards, the development of the site R170 is UNSOUND and it must be removed from the LA DPD.
The site R170M is still 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 site R170M is not removed from the LA DPD.
This is a very important reason why site R170M should not be developed – JUSTICE.
Extract from page 137 item 6.9 of the Inspector's Report on the public enquiry in 1996. Green Gap site R170M is the site mentioned below.
"Inspector's Conclusions:
6.9 The objection by Mr Downham [biased land owner] is not concerned with the provision of a green gap, but the extent of that gap. It is argued [land owner’s words] that the green gap, as shown in the Consultation draft of the Plan, follows a public footpath running between substantial hedges, a clearly defined landscape boundary: whilst the residential allocation at Sparrowmire has been reduced in the Deposit Draft, an equivalent extension to the green gap is not necessary. ^However, and most importantly in my view, the objection indicates that the "land should remain unallocated as white land so that when the Plan is reviewed in 10 years' time it can be considered as potential residential land" [land owner’s words]. I consider this underlying reason for excluding the land from the green gap identifies the very reason it should remain so designated. Structure Plan Policy 14 and the reasoned justification makes no reference to the length of time during which the vulnerable areas of countryside between settlements should be protected.^ Although policies and proposals in the Local Plan must clearly relate to the Plan period, and can be subject to review thereafter, it appears to me common sense that what is unacceptable now, will most probably be equally unacceptable at the end of the Plan period: certainly I consider the Plan should seek to engender a degree of public confidence that the separation secured will not, at some future time, be lightly squandered. ^For these reasons I believe that, where a green gap is seen as necessary, it is more important that the whole gap between the settlements should be designated as green gap than that substantial, but arbitrary landscape features should be rigidly followed. I also consider the inter-visibility of settlements is not a factor which should affect the definition of green gaps."^
I have marked with ^...^ the most important words in the above paragraph and my clarifying words are in square brackets.
The first group of sentences marked ^...^ indicates that the owner wished to leave the remaining land (now site R170M) as white land, so it can sold as high priced building land at a later date. The inspector states that this is the very reason it must remain as a Green Gap and because of this statement it is Green Gap. The LA DPD only includes Green Gap site R170M because the owner is keen to sell and make a large profit, if he didn’t it would not be included.
The second group of sentences marked ^...^ indicates that “the whole gap between the settlements should be designated as green gap”. It must not depend on “landscape features” or “inter-visibility of settlements”, but these are the very reasons that SLDC state as to why site R170M can be built-on.
Site R170M is still currently a Green Gap site and by definition has more protection than all Greenfields.
A Government Inspector’s words made the white land (now site R170M) into Green Gap and must not be ignored. Therefore to include site R170M in the LA DPD until all the more suitable Greenfield sites have been built-on is UNSOUND.
This R170M Green Gap is also land of most value to the existing community as backed up by this statement in ‘The Taylor Review’ (Page 58):
“20. Government policy is to increase the density of new housing as a means to maximising land use and better support local services. New extensions to settlements therefore may be relatively densely designed and built right up against the existing settlement to minimise the number of green fields ‘swallowed up’. However, this will mean they are built on exactly the land of most value to the existing community – the fields or woods at the ends of their gardens, the green edge to the town. Local residents against new development may be accused of ignoring the needs of others for housing, but they have a genuine point. They may not have bought the right to their countryside views, but they certainly have paid for them, and these developments are on exactly the fields of most landscape value to existing residents."
Taylor gives a valid reason why local people should not be labelled with the scorning name NIMBYs’ when they have a good reason and evidence to oppose development in their neighbourhood.
The evidence above shows that the proposed LA DPD numbers for dwellings to be built are UNDELIVERABLE before 2025. If the numbers were reduced to ones that were deliverable and sound there would be no reason to include the peripheral site R170M in the last phase (2022-25) of the LA DPD, since it is a Green Gap and hence has a higher protection than any of the proposed Greenfield sites. Note at this point in time site R170M is still part of a Green Gap.
“The Community Infrastructure Levy is a new levy that local authorities in England and Wales can choose to charge on new developments in their area. The money can be used to support development by funding infrastructure that the council, local community and neighbourhoods.”
(see http://www.communities.gov.uk/planningandbuilding/planningsystem/communityinfrastructurelevy/ )
There is absolutely no evidence in the LA DPD about how much funding SLDC are capable of obtaining from developers from the levy. Their track record in the past has been very poor when negotiating for affordable dwelling percentages. The target over previous years has been 50% but SLDC of only achieved 28%. The target is now 35% which from past results is still just wishful thinking. SLDC are relying on this money to fund infrastructure and other projects. Until SLDC publish real evidence that the money raised from this levy is in excess (there will always be an overspend) of that required, for all the proposals in the LA DPD it is intended for, then the LA DPD is UNDELIVERABLE and UNSOUND.
With the excessive financial demands that will inevitably be placed on each development in terms of school places, direct highway consequences, a 35% affordable housing contribution etc, it seems highly likely that any contribution to an Infrastructure Levy for wider scale projects would be relatively modest and inadequate. These financial implications appear to again confirm that the proposals are UNSOUND.
Until it is certain that the required infrastructure funding will be available within the planned timescales, in order that SLDC meet their objectives on Air Quality and Junction Congestion, then the LA DPD is UNSOUND.
Site R170M will add further traffic to the streets of Kendal. Therefore site R170M must be removed from the LA DPD until the Northern Development Route has a approved construction plan and committed funding in place (see above). Also that it is shown to decrease the traffic levels in the Windermere Road corridor enough for SLDC traffic objectives are met in this area.
3.0 Further evidence in support of why Policy LA2.2 (site R170M) should be removed from the LA DPD.
3.1 Extracts from Kendal Town Council document "KTC_Response.pdf " (Apr 2011)
Page 8 Transport Improvements.
“The Assessment then looked at the impact of the various possible development sites which were then under discussion. The Assessment modelled the impact of various remedial measures that could be taken, ranging from junction improvements to the building of the Inner Relief Road. It concluded that the existing highway network plus proposed improvements would just about accommodate the forecast level of traffic, provided three sites were removed:
• Land within the Shap Road/Appleby Road corridor (Site E23/49 and Sites M8/M35/ M36)
• The Todds, west of Burneside Road (Sites R148/R170)
• Stonebank Green (Sites M39/R676/R103/R675)
There was no solution which permitted these sites to be developed within the parameters given for the Assessment (e.g. no compulsory purchase orders for major junction redevelopment).”
This supports previous evidence that the development of site R170M (The Todds) is UNSOUND
Page 9 section on “Sewer Capacity”
“In addition, United Utilities has concerns about the capacity of the Waste Water Treatment Works, located to the south of Kendal, for which process modelling needs to be carried out. This impacts all the potential development sites in the town.”
I have an email from SLDC dated 27Apr2011 which states:
“The following is based on information and advice provided by United Utilities.
1. United Utilities cannot determine the number of dwellings that will cause Kendal Wastewater Treatment Works (WwTW) to reach process capacity without conducting modelling. The threshold for when capacity is reached is determined by the design capacity of the WwTW and the population that it serves with some headroom designed in to the calculations. This headroom is not excessive as United Utilities cannot design and build for a population that is not already there or where development is not definite.
2. There are local network issues in respect of sewer capacity in the Kendal area . They are primarily centred around the Burneside area as evidenced in the Core Strategy and supporting Land Allocations Document material.
3. South Lakeland District Council does not hold or have access to data/information regarding the catchment area of the Kendal Sewerage Works.”
SLDC/UU admit that the headroom (i.e. spare capacity) is not excessive. Despite this SLDC have no results of any modelling and have not insisted that this modelling be carried out by UU. SLDC do not even know the catchment area for Kendal Sewage Works. There is nothing in the documentation on the SLDC web site to indicate that SLDC do have this information today (a year later). Therefore SLDC do not know how many dwellings can be built before Kendal Sewage Works needs a major upgrade costing many millions of pounds.
United Utilities move their funding from year to year as they see their immediate priorities change, so until they actual “sign on the dotted line” to meet certain dates then their current dates can “be taken with a pinch of salt”. As evidence to support this, the paying customers of Burneside have been waiting over 20 years to get their sewerage fixed and they still have sewage on the streets during heavy rain. So there is no guarantee that the North West Kendal problem will be fixed before 2025.
Site R170M is one of the last sites in the plan to be developed therefore until the above figures are known for the whole of the catchment area and UU & OFWAT have “signed on the dotted line” to meet their agreed dates then the site R170M is UNDELIVERABLE and the LA DPD is UNSOUND.
Page 9 section on “Hydrologic Considerations”.
“However, the mechanisms (some man-made, mostly natural) which are currently managing to keep Kendal free of floods are not well understood. Several of the sites included in the Land Allocations have a history of being badly affected by rainfall. This suggests they have a role to play in mitigating surface run-off and hence flood prevention. If this is correct, development of such sites could trigger flooding in the town - and making the sites themselves flood proof would certainly involve additional expense for developers.
Kendal Town Council believes this is an important omission from the current evidence base, and calls on SLDC to commission a full hydrology study of the area before including the affected sites in any final land allocation. Any remedial infrastructure required to allow these sites to be developed safely would need to be included in the overall infrastructure programme.
Land Allocations affected by this consideration are the lower Hallgarth sites (R169M and R170M), Appleby Road (MK35KM), Natland Beck at Kendal Parks (R107M, R150M), Stock Beck at Castle Green Road (R121M), and Stonecross (R103M), and Blind Beck (R129M)”
There is nothing in the documentation on the SLDC web site to indicate that SLDC have commissioned this study or have any results. Site R170M is mentioned in quote above and so until this study is carried out development of site R170M is UNDELIVERABLE and UNSOUND.
Page 10 Infrastructure.
“3. Sites should not be included in a Final Land Allocations document unless their impact on Kendal’s transport is understood, solutions are agreed with partners, and the impact has successfully passed a rerun of the Transport Assessment. ‘Emerging Option’ sites affected by this are indicated are indicated by an ‘X’ in the ‘Traffic’ column in the Detail by each Land Allocation site starting on page 11.”
Note site R170M has an ‘X’ in the Traffic column, so this site should be removed from the LA DPD until its impact on Kendal’s junction congestion is fully understood.
This section supports previous evidence that site R170M is UNDELIVERABLE and UNSOUND.
3.2 Extracts from Kendal Town Council doc. "KTCResponsePart2toLandAllocation.pdf" (Sep 2011)
Page 5 Doughnut Development
“Taylor contends: ...these developments undermine sustainability. They invariably encourage car use, especially if there are no services or employment within walking distance, with resulting congestion on roads into town. And without local and community facilities of their own, there is little to build social sustainability and cohesion or links between new and existing settlements as there will be little in the way of community life.
This approach to planning is also a recipe for confrontation, “developing exactly the land of most value to the existing community – the fields or woods at the ends of their gardens, the green edge to the town”
(as has been amply demonstrated in Kendal by the response to the Emerging Options consultation process).
Without change we will simply repeat the mistakes of recent decades, creating unattractive developments of housing estates encircling our rural towns and larger villages, and we will fail to stem the trend of smaller villages becoming dormitory settlements of commuters and the retired, ever less affordable for those who work within them. This is not a sustainable future for rural England.
Without strong Land Allocation policies from the Planning Authority, Kendal is heading towards an unsustainable “doughnutted” future.”
This confirms that development of the peripheral Green Gap site R170M is UNSUSTAINABLE and therefore UNSOUND.
Page 6 Recommendation for Kendal
“The Council believes the Planning Authority should follow Taylor and adopt this model in preparing its final Land Allocations policies for Kendal, as the only way in which the NPPF demand for sustainable development can be achieved in the town. It is important to note that this is not in conflict with the Core Strategy positioning of Kendal as a Principal Service Centre, or with the requirements for meeting forecast housing demand. From Taylor, the requirements for sustainable development in rural market towns is clear: it cannot be delivered by allocating isolated sites around the town; a hub and spoke model is required. Even without the NPPF’s insistence on sustainable development, there are other intrinsic advantages to the hub and spoke model for Kendal. The Council’s previous Response to Consultation highlighted the major infrastructure challenges to be overcome in the town. These become far more soluble if development proceeds on hub-by-hub basis, when the infrastructure work can be concentrated on the corresponding spokes. For example, it is far simpler to improve bus services, cycling provision, etc. if only one or two ‘spokes’ have to be addressed.
The evidence in the EHLSS shows that there are suitable sites available (the scope of the SHLAS only covered sites within existing settlement boundaries, and is of less relevance), and there are options both for completely new communities on green field sites, or for breathing new life into existing communities.”
This confirms that the “doughnut” strategy is incorrect for Kendal and should be replaced by the “hub & spoke” strategy. It also confirms that the peripheral Green Gap site R170M is unsustainable and therefore UNSOUND.
Page 10 Latest Forecasts (2011)
“The latest forecast in this series was produced in Spring 2011. It shows a drastically reduced requirement:
• only 360 dwellings across the 20 years, or
• just over 4,000 including migration, projected on the last five years’ evidence.
This suggests that a more appropriate target for the next 5-10 years would be around 200 dwellings per annum.”
This confirms the evidence given above that 200 per year is what is required and this number would be deliverable. If this number was planned then the peripheral Green Gap site R170M would not be required and being in the last phase would not be needed in this LA DPD.
This section supports previous evidence that the LA DPD is UNSUSTAINABLE and UNSOUND.
3.3 Extracts from Kendal Town Council doc. “Land Allocations Representation (2).pdf “ (Mar 2012)
Page 4 Summary
“The Council believes that the DPD is not justified because it fails the following tests of soundness:
• the LPA has failed in its duty to compare against reasonable alternatives
• key decisions are not supported by the evidence base or the evidence supports a different conclusion
• the evidence base is incomplete
The DPD is also not effective in that it is not deliverable, with key elements of the dependent infrastructure
not understood.”
This confirms the LA DPD is NOT DELIVERABLE.
Page 4
“For rural market towns, the evidence was pulled together in July 2008 by the Taylor Review9, setting out the policy framework necessary to deliver the “vision of a living, working sustainable countryside”. Taylor provided compelling evidence that “doughnut development” was the wrong approach for sustainable rural market towns, and that a “hub and spoke” model represented the best pattern for sustainability.”
The two KTC paragraphs above confirm that an alternative system must be adopted now, which will “meet the needs of future generations” of Kendal (i.e. BE SUSTAINABLE”) for the many thousands of years to come.
Page 4
“The evidence in the EHLSS indicates that suitable sites could be available (the scope of the SHLAA only covered sites within existing settlement boundaries, and is of less relevance), and there are options both for completely new communities on green field sites, or for breathing new life into existing communities.”
This confirms that a “hub & spoke” is viable.
Page 5
“The Assessment concluded that the existing highway network plus proposed improvements would just about accommodate the forecast level of traffic, provided three large sites were removed. The consultants could find no mitigation which would permit these sites to be developed within the parameters given for the Assessment (e.g. no compulsory purchase orders for major junction redevelopment.)”
This confirms that site R170M must be removed from this LA DPD because it is one of the three sites.
Page 5
“Given that this approach has differed significantly from the independent consultants’, the Council asks the Inspector to order an independent audit of this latest work by W.S.Atkins or equivalent to ensure it meets accepted professional standards of objectivity and integrity. The Council further asks the Inspector to ensure that no sites are included in the DPD which the evidence shows are not deliverable on transport grounds.”
This confirms that site R170M must be removed from this LA DPD, because it is one of the sites which “are not deliverable on transport grounds.”
Page 7
“The Council asks the Inspector to withhold approval of the DPD until there is a credible infrastructure plan showing the impact of the major sites on the overall town infrastructure, and with high level solutions identified and costed with enough detail to enable the economic deliverability of the sites to be proven.”
This adds to the evidence given above that there must be signatures, to supply the necessary infrastructure and funding, must be in place before this LA DPD is approved by the Government. Until this is done site R170M is UNDELIVERABLE and UNSOUND.
This section supports previous evidence that site R170M is UNDELIVERABLE and UNSOUND.
3.4 Extracts from SLDC document "Kendal Transport Study (Jan12).pdf ”:
Page 5 Exec Summary (see also 6.1.6 on page 18)
"10. The LDF developments have a more notable impact in the AM peak compared to the base situation. The model results indicate that the provision of sustainable transport improvements (Scheme 2) would be required to support LDF development to nil-detriment compared to the 2022 base situation in the AM peak. However, the provision of a new route along Dowker’s Lane (scheme 4) would be required if the Rugby Club development is included. If the Canal Head development is included, the proposed Kendal Northern Development Route (Scheme 5) would be required.
11. It should be noted that although these schemes are required to achieve nil-detriment, these improvements are only demonstrated to offer marginal benefits to the performance of junctions in Kendal. These infrastructure schemes would be expensive and may not be a cost-effective solution to congestion in Kendal town centre.
12. Furthermore, even with the implementation of these improvement schemes, it is important to note that a large proportion of the key junctions would continue to operate above capacity, and therefore experience congestion and extensive queuing in the 2022 base situation. This situation would be compounded by the LDF development traffic.
13. It is recommended that further modelling work is undertaken"
The Transport Study shows that the objectives cannot be achieved before 2025 therefore the problems are going to be much worse in the years 2026 onwards.
SLDC do not have signed-off solutions and timescales in place to meet the plan phases, therefore the LA DPD is UNDELIVERABLE and UNSOUND.
Page 9 This page gives the CCC/SLDC definition for Junction Congestion limits.
"Acceptable junction performance is indicated by a degree of saturation below 90 percent for signal-controlled junctions, or an RFC below 85 percent for priority junctions and roundabouts."
The Atkins report uses a Volume/Capacity ratio of 90 as acceptable for a junction approach, which is similar.
The Study shows that these objectives will not be met by 2025 so this, along with page 10 (see below) adds evidence to the above.
Page 10
"4.2.2 In total 13 junctions are indicated to have a maximum RFC greater than or equal to 90% in the 2010 base year, in either the AM or PM peak period. These are:Junction1: A5284 Stricklandgate/Sandes AvenueJunction 2: A5284 Sandes Avenue / A6 Blackhall Road signalised junction
Junction 5: A6 Longpool / Station Road mini-roundabout junction
Junction 12: A6 Highgate / Lowther Street signalised junction
Junction 22: Parkside Road / Valley Drive priority junction
Junction 16: A6 Milnthorpe Road / Romney Road signalised junction
Junction 17: A5284 Windermere Road/Queens Road
Junction 18: A5284 Windermere Road/Burneside Road
Junction 21: A65 Burton Road / Oxenholme Road signalised junction
Junction 27: A684 Sedbergh Road / Sandylands Road priority junction
Junction 29: A6 Shap Road / A685 Appleby Road (north) priority junction
Junction 30: A6 Shap Road / A685 Appleby Road (south) priority junction
Junction 31: A685 Appleby Road/Sandylands Road"
“Measures must be in place” to fix these major problems first (i.e. meet SLDC objectives). They have a huge bearing on why SLDC is still breaking the law on Air Quality.
Page 14
“* Scheme 6: Scheme 5, plus a potential Kendal Southern Link Road, which comprises a new single-carriageway road linking the A6 Milnthorpe Road with the A65 Burton Road south of Kendal town centre.”
This new road proposal has never been mentioned before; it is not in the Core Strategy and therefore, as we have been told before, it cannot be considered in this LDF.
This section supports previous evidence that site R170M is UNDELIVERABLE and UNSOUND.
3.5 Extracts from SLDC document "06 Infrastructure Position Statement.pdf ”:
Page 10
"4.19 United Utilities has a statutory duty to develop and maintain an efficient and economical system of water supply within its area. A proposal for expenditure in the years 2010 – 2015 is contained within the published five years Investment Plan (Asset Management programme). The plan can be found at the following website link: http://www.unitedutilities.com/Documents/Detailed_plan.pdf "
There is nothing in this PDF document that is specific to Kendal.
UU may have "a statutory duty to develop and maintain an efficient and economical system of water supply within its area" but it is very poor at obeying this duty as is verified by the > 20 years Burnside have been suffering sewage problems (and still are).
Until UU actually “sign on the dotted line” to meet the required planned timescales and commit funding, the LA DPD is UNDELIVERABLE and UNSOUND.
Page 11
"4.23 Funding is more likely to be acquired in cases where there is development certainty (i.e. clear evidence of developer interest).
* UU reiterate that even if a bid is submitted there is no guarantee funding will be approved by OFWAT. The speed at which approved schemes are implemented will depend on the priority given to schemes within the 5-year programme and the time required to design, obtain planning permission and construct."
This backs previous evidence, never mind “development certainty” what about the existing paying customers who are still suffering sewage and flooding problems due to lack of investment.
Until United Utilities “sign on the dotted line” and commit to planned dates and funding the LA DPD is UNDELIVERABLE and UNSOUND.
Page 11
"4.24 There is currently loading capacity at Kendal Waste water Treatment Works (WwTW), however, for the number of dwellings that are proposed a full process and hydraulic survey of the Works will have to be undertaken before UU could comfortably approve the Planning Applications. As the sewer network is at capacity in North Kendal, UU could not agree to any significant development until after 2015 in this part of the town. Providing UU obtain funding through OFWAT to undertake the necessary upgrades etc. UU will be building into the 2014 Business Submission to OFWAT a case for funding to provide the means to accommodate development, which will boost the economy.
4.25 A feasibility study is being undertaken on the Kendal WwTW. Recommended phosphorous levels are set by Environment Agency (EA) through discharge consents, and until EA impose a new requirement for a lowered rate, UU will continue to discharge at the current rate. UU stated achieving any required lower rates would depend on new/better technology. Further Phosphorous removal would only be undertaken if UU were required to achieve a tighter standard as set by the EA following their review of water quality. Newer technology, which is not currently available, would be required to achieve any standard below 1mg/l. UU has advised development in the Kendal area should be capped at 2000 properties unless a more stringent phosphorus effluent standard can be achieved.
4.26 UU has advised that sites in North Kendal should only come forward in the latter periods of the plan period when sewage network improvements are in place.
4.27 Strategically there is enough water supply to accommodate levels of new development, but there are potential risks of deterioration of water quality."
Until OFWAT “sign on the dotted line” and commit to planned dates and funding the LA DPD is UNSOUND.
Page 14
"4.45 Electricity North West Ltd manage infrastructure and distribute and transmit electricity throughout South Lakeland. The regulator determines the amount of funding, however, it is not known what the next round of funding may or may not allow for investment in improvements. Information relating to substation capacity has not been ascertained. Evidence when exploring options for the Canal Head Area of Kendal shows that the Kendal Primary substation is currently operating close to or at capacity. It is possible that significant development in Kendal would require investment for network reinforcement and that a new Primary Substation would be required although Electricity North West Ltd does not confirm this. No information has been made available stating whether this is the case. Only when the customer has firm load requirements and location details can a system study be undertaken to ascertain the scale of impact of potential new development."
What if the system study states it cannot be done or they cannot obtain the funding within the plan timescales? Electricity North West Ltd already has the number of houses proposed and their locations so they must commit to a system study and confirm that the proposed developments are deliverable. Until then the LA DPD is UNSOUND.
Page 15
"4.48 National Grid Gas Distribution own and operate the local gas distribution network in South Lakeland. The confidential nature of the process means National Grid are unable to confirm whether they are currently processing or have made any offers for connection within Cumbria."
The document states nothing about National Grid Gas Distribution having a statutory duty to develop and maintain an efficient and economical system of gas supply within its area.
The LA DPD cannot possibly be monitored correctly until all the Gas company has “signed on the dotted line” to meet the timescales required. Until then the LA DPD is UNDELIVERABLE and UNSOUND.
This Infrastructure document is only a statement; there is no indication when the Infrastructure Delivery Plan will be available to the public or any indication that the timescales can be met. The LA DPD is UNSOUND until the Infrastructure Delivery Plan and the Kendal Transport Plan are available with all milestones agreed, funding committed and both signed off by the respective utility companies. They can have the proviso that it depends on the build going ahead as planned.
3.6 Extracts from SLDC document “01 Consultation Report.pdf ”:
Page 19
“In their response the Highways Agency identified those sites it considers (if developed, due to cumulative impact with other sites) may impact upon the capacity, operation and safety of the strategic road network (SRN) (A590 and M6) within South Lakeland. As a consequence, the Agency has stated that the cumulative impact of development of sites under consideration in the following settlements (see below) may result in some impact to the SRN: Burneside, Crooklands, Endmoor, Kendal, Kirkby Lonsdale, Levens, Milnthorpe and Ulverston alongside the sites suggested for strategic employment use (in Ulverston and Kendal area).”
Note the word “may” on the second line. They either do or they don’t. After all these years of the LDF there is no excuse for this information not being available. SLDC must obtain an answer to this issue immediately and publish it. If any of the developments proposed within the LA DPD do affect the Strategic Road Network then any changes necessary must be included in the LA DPD and the Transport Plan (which must be issued before the hearings). Note the Strategic Road Network is NOT currently mentioned in the LA DPD.
Page 21
This page with reference to Burneside states:
“.....this is no guarantee that funding will be approved by OFWAT”.
Until OFWAT “sign on the dotted” line to meet the planned timescales the LA DPD is UNSOUND.
Page 21
“Additional work is needed by UU to check if cumulative impact on treatment works may raise capacity issues
SLDC must publish how many houses can be built in the Kendal catchment area before a major upgrade to the sewage works is required. Until UU know their total funding requirements the LA DPD is UNSOUND.
Page 34
KENDAL
“Many people believe development of the sites suggested would harm the landscape character of the town, worsen air quality, exacerbate current flooding problems, harm biodiversity, generate unacceptable levels of traffic congestion, and place further strains on a heavily constrained sewerage system. Some people questioned the need for additional housing believing there are enough empty properties in the town to meet current and future housing demands. A number of people stated development should be prioritised on brownfield sites and meet primarily local needs.”
“Many people including Kendal Town Council and Burneside and Natland Parish Council’s supported the concept of green gaps to protect Kendal coalescing with neighbouring settlements. However, a significant number of people and Kendal Town Council and Natland Parish Council believed the suggested emerging options would not prevent coalescence from happening. There was general widespread support for the open space designations suggested, however, many people believed the emerging options sites should also be designated open space.”
“Kendal Town Council expressed serious concerns with the overall approach being suggested for the town, believing the amounts of developments and the emerging option sites suggested would damage the landscape character of the town, and put unnecessary strain on an inadequate infrastructure system. The Town Council has suggested an alternative strategy/approach for the town this being to protect existing green space/countryside surrounding the town and to look at alternative sites adjacent to nearby settlements and possibly further afield where development would have less impact on the town’s infrastructure, air quality and its high quality landscape value.”
These three paragraphs confirm that the wishes of the majority of local people have been ignored and adds support to the evidence given above concerning Consultation and Legal Compliance.
Page 46
On this page it states “UU is currently considering lists of projects that will require major capital investment in Asset Management Plan 6 period 2015-2020.” and “UU reiterate that even if a bid is submitted there is no guarantee funding will be approved by OFWAT. The speed at which approved schemes are implemented will depend on the priority given to schemes within the 5-year programme and the time required to design, obtain planning permission and construct.”
Until United Utilities and OFWAT “sign on the dotted line” to meet the planned timescales and commit funding, the LA DPD is UNDELIVERABLE and UNSOUND.
This section supports previous evidence that site R170M is UNDELIVERABLE, UNSOUND and that consultation process was not Legally Compliant.
3.7 Extracts from SLDC document “Land Allocations DPD.pdf ” [Mar12]:
Pages 51 & 52
Item 3.6 - Key local factors influencing the location of new development in Kendal:
“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; Avoiding coalescence between Kendal, Oxenholme, Burneside and Natland and maintaining the separate identities of these settlements;
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;
Infrastructure constraints including sewage capacity at Kentrigg and Steele's Row and the implications for development in northwest Kendal.”
One of the main comments of the people who responded to the SLDC consultations and opposed them was the character and appearance of Kendal. This is imbedded in the above paragraph and has been totally ignored. The LA DPD is therefore not Legally Compliant.
The site R170M is close to Kentrigg (mentioned above) and so it is UNSOUND to include it in the LA DPD until United Utilities are fully committed (i.e. signed on the dotted line) to the LA DPD timescales.
The sentence “Minimising the impact of development on Kendal’s central traffic system, …..” is not definitive it should state “Meet and maintain SLDC’s standards and objectives with regard to Kendal’s central traffic system, …..”
Page 163 APPENDIX 4 - HOUSING TRAJECTORY
A graph on this page it shows the following numbers over the years 2003 – 2025 (22 years).
Maximum number of dwellings ever built in one year was 300 in year 2005/06 and even this did not reach the target of 400 per year.
Extrapolating from the graphs the average number of dwellings built per year for the first 8 years was 100+280+150+150+240+300+230+220 = 1670 / 8 = 209 per year. In the terms of this graph there are already an extra 1530 dwellings (109/yr on top of the 400/yr) that have built just to catch up. This compares well with the more accurate figures in section 2.1 above.
The figure of 720 per year for the three years 2022 – 2025 is just WISHFULL THINKING.
One of the questions that must be asked to confirm SOUNDNESS is “Are there realistic timescales related to the objectives”. The above numbers are clearly not realistic therefore the current LA DPD is UNSOUND.
This section supports previous evidence that site R170M is UNDELIVERABLE and UNSOUND within the timescales of this LA DPD (2025).
4.0 Changes required to the LA DPD document title “Land Allocations DPD.pdf ” [Mar12]:
4.1 During the recent SLDC consultation 98% of the local neighbourhood who responded OPPOSED the proposals for site R170M. In a door-door poll of over 400 neighbours during 2011 approximately 80% of those asked OPPOSED the proposal to build on site R170M. Of the remaining 20% most did not care one way or the other. The Localism Bill is a Con Trick (nice pun); it promises much but does not actually support what the majority of the people in the neighbourhood want.
To prove SLDC are DEMOCRATIC they must be serious about responding to the majority of the local neighbourhood’s wishes. Also the TOTAL CONCLUSIVE EVIDENCE ABOVE PROVES THAT SLDC MUST REMOVE THE PERIPHERAL GREEN GAP SITE R170M FROM THE LA DPD TO MAKE IT SOUND. THIS IS HOW THE LA DPD MUST BE CHANGED.
4.2 After many years (before year 2000) of knowing about the traffic problems in Kendal, SLDC have failed to produce a transport plan or action plan that enabled them to meet their standards and objectives for Air Quality and Junction Congestion. This must NOT be allowed to continue. Only when these standards and objectives have been PROVEN to have been met (with spare capacity for expansion) will the people believe SLDC are serious about tackling these major problems. The recent SLDC consultations show that increase in traffic was one of main reasons why 98% of the people (that responded) OPPOSE the proposals to build on sites in their area of Kendal.
Previous experience with Core Strategy has shown me that all my evidence will be ignored and that site R170M will not be removed from the LA DPD. If this is to be repeated then I would like to see the following changes to LA DPD.
There is a note on page 57 (item 3.18) of the LA DPD (policy LA2.2 site R170M) which states:
"DEVELOPMENT OF THIS SITE CANNOT TAKE PLACE UNTIL MEASURES ARE IN PLACE TO RESOLVE PRESSURE ON THE SEWERAGE NETWORK IN NORTH KENDAL."
This means existing problems will be fixed before building starts.
THIS SETS A PRECEDENT WHICH MUST CONTINUE WITH REGARD TO OTHER MAJOR PROBLEMS.
The threat to the health of people due to air pollution is of as much importance as sewage on the streets. Site R170M will add more traffic to the streets of Kendal and make air pollution worse. Therefore a note must be added to Policy LA2.2 (item 3.18) that states:
"DEVELOPMENT OF THIS SITE CANNOT TAKE PLACE UNTIL MEASURES ARE IN PLACE TO SHOW THAT THE LAW ON AIR QUALITY HAS BEEN MET IN KENDAL."
Increase in traffic, which leads to more junction congestion and a deterioration in the well-being of local people, was one of the major complaints in the recent SLDC consultations. Site R170M will add more traffic to the streets of Kendal and make junction congestion worse. Therefore a note must be added to Policy LA2.2 (item 3.18) that states:
"DEVELOPMENT OF THIS SITE CANNOT TAKE PLACE UNTIL MEASURES ARE IN PLACE TO SHOW THAT SLDC’S DEFINITION OF “ACCEPTABLE JUNCTION PERFORMANCE” HAS BEEN MET IN KENDAL."
For definition see page 9 of “Kendal Transport Study (Jan12).pdf”.
“4.1.5 An RFC or DoS of 100% indicates that an approach is operating at maximum capacity. Acceptable junction performance is indicated by a degree of saturation below 90 percent for signal-controlled junctions, or an RFC below 85 percent for priority junctions and roundabouts. Above this level, an approach is likely to begin to experience congestion as there is insufficient spare capacity to cope with fluctuations in traffic flow.”
4.3 Page 51 item 3.6:
The sentence “Minimising the impact of development on Kendal’s central traffic system, …..” is not definitive. The word “Minimising” is just not good enough to meet the people’s wishes. It must state “Meet and maintain SLDC’s standards and objectives with regard to Kendal’s central traffic system, …..”
4.4 Page 163 APPENDIX 4 - HOUSING TRAJECTORY
This Appendix 4 must be changed and other pages which quote these figures. The SLDC evidence does not support the requirement that anywhere near the 8800 dwellings can be built before 2025. The numbers in the graph are not realistic (a SOUNDNESS word), therefore NOT DELIVERABLE and UNSOUND. 720/year for last three years is just wishful thinking, it is not realistic; this graph shows that the maximum that has ever been built within the last 8 years is 300 per year for the year 2005/06. The developers will not build 750 per year because it would swamp the market and they would be left with a large number of empty houses.
There is no point in just stating on page 7 of the LA DPD that it is “the ambition to deliver 400 dwellings each year” if these numbers cannot realistically be built and sold. There is also no point in just monitoring these numbers just so a box can be ticked to say they have been monitored. The numbers must be realistic so that they can be monitored and vigorously progressed.
Kendal Town Council have stated in one of their reports [Sep2011 see above] that only around 200 dwellings per year is the number required. SLDC must discuss this issue with KTC and reduce the current total figure of 8800 to a number that can realistically be built & sold before 2025 and not one that is just WISHFULL THINKING.
4.5 There is a requirement in the Core Strategy for Brownfield land to be used for “at least 28%” of the number of dwellings built. Note the words are “at least” not it is the “ambition to use”. To be SOUND the LA DPD must indicate the amount of Brownfield land that is currently available and the targets for each area. These figures must be monitored, vigorously progressed and be made available to the public.
4.6 SLDC must discuss Kendal Town Council’s three reports in detail with the town council and members of opposition groups (e.g. Green Spaces). I would like to see the LA DPD changed to incorporate as much as possible of that which is agreed in these discussions.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
THE HEALTH AND WELL-BEING OF LOCAL PEOPLE MUST BE AT THE TOP OF SLDC's PRIORITY LIST and despite all my emails and protest at the Core Strategy hearings this has not yet been done in Kendal.
So I wish to speak face to face with the inspector and ask him personally if he will recommend in his report that notes be added to the LA DPD stating that SLDC must fix their major existing problems first and meet the SLDC/CCC definition for "Acceptable Junction Congestion" and the Law on Air Quality before allowing actual build of site R170M, which will add to these problems (see examples of notes in section 4.2 above).
A PRECEDENT has already been set by a note in Policy LA2.2 for site R170M relating to the sewerage network in North Kendal. If United Utilities have to fix their major existing problems first before building is allowed then so must SLDC, this is logical and should not need a political decision.
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Please notify me
917. Mr Michael Whorwood (Individual) : 16 Apr 2012 11:38:00
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I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - RN213-mod BRIGSTEER LAND OPPOSITE THE WHEATSHEAF
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
n/a
1.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
The plot of land identified as RN213 represents a unique opportunity to provide a small number of affordable homes on a site located at the heart of the community behind a screen of mature trees where the impact on the environmental and social fabric of the existing village would be minimal.
This together with the gererosity and sympathetic support of the local landowner in making the land available at nominal cost does indeed make this an opportunity not to be squandered.
A Community Land Trust has been set up, supported by 68 local fully paid up share holders individuals accepting that the land will be developed and wanting a constructive involvement in how it is developed.The CLT has commissioned a topographical survey to confirm that the site will accomodate 7 homes. A traffic survey was also carried out the detail of which satisfied Cumbria County Council Highways Department that safe access and exit from the site was possible.
I doubt that there is another site in the whole of South Lakes where the aspiration for an affordable home can be met at so little cost to the local community.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
Yes
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
It is not acceptable that local people are being driven out of their communities by an influx of wealthy retirees and second homers who drive house prices way beyond their financial ability to compete.It is essential that the Local Authority intervenes to redress this inequality, if not them then who else. These are local people in housing need not second class citizens.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
You need to understand what it is costing people to stand up and be counted in a community where the honest endevour of the CLT is villified,where they are subjected to gratuitous assaults on their personal integrity simple because they recognise the needs of people less fortunate than themslves and choose to do something about it.
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Please notify me
918. Mr Michael Whorwood (Individual) : 19 Apr 2012 12:49:00
Policy/Site No.
LA1.3 Housing Allocations - RN213-mod BRIGSTEER LAND OPPOSITE THE WHEATSHEAF
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
Yes
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
I am writing in support of the site identified as RN 213 and its continued inclusion in the Development Framework'
This site represents an almost unique opportunity to provide a small number of affordable homes in the centre of an existing village, located behind a screen of mature trees where the impact on the environmental or social fabric of the village would be minimal. This together with the sympathetic generosity and support of the local landowner Hal Bagot in making the land available at nominal cost does indeed make this an opportunity not to be squandered .
To withdraw RN213 from the framework at this late stage would be an act of betrayal of the efforts of the Helsington Community Land Trust. Their honest endeavour in recognising the housing needs of local people and attempting to do something about it, despite gratuitous assaults on both their personal integrity and motivation, should be applauded and given every possible support and encouragement.
919. Mr Robert Wilde (Individual) : 3 Apr 2012 15:03:00
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I have read the guidance notes
Policy/Site No.
LA1.1 Development Boundaries- HOLME
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The Land Allocations Document (DPD) is not within the Local Development Scheme and the key stages have not been followed
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
The map I used as a basis to make my representations to the "Local Development Framework Land Allocations - Consultation on Emerging Options" process in March 2011 was taken from the Holme Community Hall at the SLDC Development Framework Roadshow that took place in March 2011, this map matched the larger maps then on display in the hall.
I discussed this map and its implications with a member of the planning team at the roadshow. This map clearly shows that the proposed housing development 653M (shown in red) starts on the East side of Milnthorpe road and finishes WEST of the electricity transmission lines. The rest of of the development areas shown on the map as PS251,R560,R72 and R73 are designated as open public space. The latest map now being submitted shows the housing area reaching from the Milnthorpe road to Pear Tree Park/Mayfield Avenue (except for about 25% which as yet is not indicated).
The Development Plan Document paragraph 3.129 states that the Housing Allocation for land east of Milnthorpe road is 49 dwellings. However, paragraph 3.130 states that 73 dwellings are going to be built on the 3.63ha site. Also, the latest map shows 73 dwellings to be built in three phases, this is consistent with more land being used for housing than indicated in the map from last year shown at the roadshow.
All this is at best is very confusing and in the worst case misleading. My proposal is that the map used for the roadshow should be used i.e. Housing stops west of the electricity lines. This will leave a large public open space protecting hedgerows, trees, orchards and avoidance of development close to power lines.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Besides not protecting hedgerows,trees and wildlife as indicated in policy LA2.15 ful
