5 responses from Mr Anthony Cousins (Individual)
1. 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.
2. 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.
3. 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.
4. 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.
5. 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.
