Local Development Framework Consultation

LA1.3 Housing Allocations - RN140 MILNTHORPE LAND AT OWLET ASH FIELDS, ACKENTHWAITE

No

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.

YES, I wish to participate at the oral examination

LA1.8 Local Employment Allocations - E13M MILNTHORPE LAND ADJ MAINLINE BUSINESS PARK

No

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.

YES, I wish to participate at the oral examination