4 responses from Mr John P Lyons (Individual)
1. Mr John P Lyons (Individual) : 10 May 2012 08:32:00
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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
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy 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
2. 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
3. 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
4. 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