Local Development Framework Consultation

I have read the guidance notes

0.0 Whole Document

No

The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy

The Land Allocations Document (DPD) is not within the Local Development Scheme and the key stages have not been followed

The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)

Legal Compliance 1

One of the main common objections to the LDF is the sheer size and scale of the proposed Development within the District.

It would seem right at the very beginning of the LDF process SLDC had the facility to lobby the last Government’s Regional Spatial Strategy for an increase in its allocated figure of 265 dwellings per year and secured a 50% increase to take the District’s housing target to 400 per annum in an attempt to meet the affordable need.
This represented a 33% increase to the original allocated figure of 265 (an extra 133 dwellings per year). Therefore 33% of the 6,000 requirement is to meet the affordable need of 2,000 dwellings. As a result the district will see an accelerated growth increase of 33% above the original Regional Spatial Strategy’s allocated figure.

On the other hand right from the very beginning of this process, we the constituents were denied the facility, via the Consultation Response system, to oppose/question the numbers – informed by the Planners that you could not, they were sacrosanct.
But numbers are one of the major issues residents have about the proposals. This of course is entirely different to SLDC who did seem to have the right to oppose, and subsequently change the figures, a bit one-sided don’t you think?

The LDF does not conform at all to the original (until it is abolished) Regional Spatial Strategy numbers.


Legal Compliance 2

SLDC has failed to deliver appropriate, sufficient and effective methods of engagement in response to the needs of the community.

The public have been asked to submit to the soundness of a DPD comprising approximately 460 technical documents covering 14,500 pages (visually, this would represent a stack of A4 paper approx. 1.5 metres tall). SLDC chose only to allow for the minimally prescribed consultation period of six weeks.

Residents who are less inclined or able to read through a complex set of documents containing thousands of pages of text, tables, maps and appendices (either in paper form or via the SLDC website) have therefore been broadly excluded from making any substantial comments or submissions which are deemed to be ‘viable’ by SLDC.

It has failed to be creative in the way it reaches out to all parts of the community, participation has been limited to the usual ‘informed and active minority’.

Crucially, the disenfranchisement of the older generation from the consultation process has meant that a significant percentage of the population has been under-represented (where currently 29% of the population of South Lakeland is over 60).

Where SLDC have engaged with the public in face to face meetings in the community, it has been with a “presentational style” of plans to be delivered, rather than of options for consultation. It has been alleged that in response to challenges, SLDC representatives have been heard to comment at public meetings that the plans will be delivered ‘regardless of public opposition’. Despite an outward impression of a robust consultation process, it could be said this has simply been a ‘tick-the-box’ exercise.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
in any meaningful way when preparing the final land allocations document. To the contrary, there are instances where additional sites have been added or numbers of dwellings increased in areas where submissions were made opposing original plans.

The delivery of the consultation by SLDC has resulted in a sense of detachment from the planning process as many residents feel marginalised by an ‘indifferent approach’ to their opinions and aspirations for their neighbourhoods. Communities have not been treated as stake-holders in the future success of their towns and villages.

No

The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.

The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.

The LDF housing numbers proposed by SLDC have remained unchanged since the process began a number of years ago.
Kendal Town Council LDF LA Further Consultation Summer 2011 document highlighted the latest forecast produced in Spring 2011 showing a drastically reduced requirement:
• only 360 dwellings across the 20 years, or
• just over 4,000 including migration, projected on the last five years’ evidence.
This suggests that a more appropriate target for the next 5-10 years would be around 200 dwellings per annum.

I recognise the SLDC area needs truly affordable housing and I support that. However there must be concerns on SOUNDNESS about how this is going to be achieved because LA DPD proposes that it can only be delivered by the private sector. This strategy is untried, untested, aspirational and funded by inward migration purchasing market value dwellings on a ratio of two to one at accelerated growth rate.
No mention has been made in regard to the population increase of approx. 8,000 that will accompany this strategy. There appears to be no sound infrastructure delivery plan either to accommodate the increase in dwellings or the population.
Land allocation has been increased by a third, densities increased to 35dph and most of the land has to come from both Green Gap and Greenfield sites. Based on the latest KTC figures this cannot be JUSTIFIED. In addition it cannot be EFFECTIVE as no adjustment has been taken in regard to coherence with the strategies of neighbouring authorities. The Lake District National Park having identified a requirement of 900 affordable dwellings.

Proposed Changes I would like to see would include.
1 A reduction in the housing numbers in line with KTC updated forecast to 200 dwellings per annum.
2 A reduction of (the family jewels) i.e. Green Gap/Green Field Sites.
4 A reduction in housing densities from 35dph to a maximum of 25dph on Greenfield Sites.
5 The provision of affordable housing to include other funding mechanisms.
6 Coherence with the strategies of neighbouring authorities on affordable dwellings.
Why:-
Hope the above is self-explanatory.

NO, I do not wish to participate at the oral examination

Please notify me

I have read the guidance notes

LA1.1 Development Boundaries- KENDAL

No

The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.

The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.

The DPD is not consistent with national policy.

I fully support KENDAL TOWN COUNCIL SUSTAINABLE DEVELOPMENT IN KENDAL Submission to the Planning Inspector SLDC Land Allocations DPD - Submission Edition March 2012 Approved by Council: 2nd April 2012

In particular their comments on:-

Making use of the latest housing forecasts to set short/medium term allocations, rather than the forecasts available at the time the Core Strategy was drawn up.

Recognising forecast errors in the planning process - this means ensuring that the new development can be sustainable within the range of likely outcomes over this period.

Support for and the importance of the Taylor Review 9 pulled together in July 2008 setting out the policy framework necessary to deliver the “vision of a living, working sustainable countryside”. Taylor provided compelling evidence that “doughnut development” was the wrong approach for sustainable rural market towns, and that a “hub and spoke” model represented the best pattern for sustainability.
The evidence in Taylor also shows that adopting this approach would make it considerably easier to deliver the dependent infrastructure.

The Town Council indicates that the LPA has clearly failed in its duty to compare against an alternative which is not only “reasonable”, but according to the best practice collated by Taylor, is also more sustainable, causes less problems with town centre infrastructure, and is more acceptable to residents.

They acknowledge that evidence in the EHLSS indicates that suitable sites could be available (the scope of the SHLAA only covered sites within existing settlement boundaries, and is of less relevance), and there are options both for completely new communities on green field sites, or for breathing new life into existing communities.

They are requesting the Inspector to instruct the LPA to produce a robust evaluation of alternative
approaches to land allocations to meet the housing targets identified for Kendal in the “Core Strategy”, with a particular focus on the recommendations of the Taylor Report.

They acknowledge Kendal residents identify “The level of traffic congestion” as their second highest priority for improvement - coming in just ahead of “Affordable decent housing”. So the LPA has been keen to demonstrate that the developments in the LDF can be delivered without exacerbating congestion in town.

They inform us that in 2009, the LPA commissioned a Kendal Transport Assessment, based on an earlier preliminary land allocation, from independent consultants WS Atkins.

This assessment concluded that the existing highway network plus proposed improvements would just
about accommodate the forecast level of traffic, provided three large sites were removed.

In the “Emerging Options” Land Allocations, these three sites were not only included, but were actually expanded in size. The LPA was challenged by the Town Council to justify this inclusion against the published evidence which the LPA had themselves commissioned from independent consultants.

In reply, the LPA chose not to re-engage independent consultants, but asked Cumbria County Council (CCC) to re-run their traffic models against the latest allocations.

There are two significant differences between the independent consultant’s report and this CCC work.

The CCC study had a significantly different approach to that of Atkins – which appears to result in discounting the LDF impact down from 15.6%/18.7% morning/afternoon down to just 2.3%/6.1%.

KTC then go to say even with this much more generous approach, the Interim study reached much the same conclusion that the existing highway network would not be able to accommodate the proposed levels of LDF

KTC have previously argued that Kendal’s infrastructure requires long term planning, with an evidence-based, published, and defensible roadmap for developing the town and its infrastructure to underpin planning policies.

They argue that with Kendal’s ageing infrastructure, improvements are so substantial that they are likely to need contributions from several partners to deliver and that there needs to be an overall credible plan for infrastructure.

They acknowledge the issues with traffic directly impact on the air quality in Kendal town centre. The air quality in Kendal currently fails statutory guidelines, and has deteriorated since 2008-09. Slow-moving traffic waiting at junction approaches is widely believed to be the major contributory factor.

The road network is already working at capacity, with the effect that NO2 levels in the town centre
are close to or above the Objective.

The CCC modelling work now shows that this “capacity” is simply not deliverable.
Applying the precautionary principle, the Council believes any planned Land Allocations which would be rejected on traffic grounds must also be rejected on air quality until a robust plan is in place.

Without a robust infrastructure “Master Plan” linked to sites, the Council fears it will prove impossible to enforce the necessary Section 106 obligations, which are governed by the government’s Circular 05/2005:20.

The Council asks the Inspector to withhold approval of the DPD until there is a credible infrastructure plan showing the impact of the major sites on the overall town infrastructure, and with high level solutions identified and costed with enough detail to enable the economic deliverability of the sites to be proven.

Proposed Changes I would like to see:-

1. All changes and suggestions as identified within all three of Kendal Town Council’s Sustainable Development in Kendal Submissions to the LPA in their response to the Local Development Framework.

Why - Because their submissions are based on reality and make total sense to me.

NO, I do not wish to participate at the oral examination

Please notify me

I have read the guidance notes

LA2.2 Land North of Laurel Gardens

No

The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.

The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.

The DPD is not consistent with national policy.

1) TRAFFIC
1.i) South Lakeland District Council commissioned an SLDC Transport Assessment Report (Atkins Report – June 2009) for future development in Kendal (see document “Kendal_TAJune_2009.pdf”).
Two of the three main conclusions stated are.
- The volume of development traffic from The Todds site, R170M west of Burneside Road was considered to be inappropriate for this location.
- Recommended that further development in the Shap Road/Appleby Road Corridor should be resisted.

The report (page 7) specifically mentions the Middle Sparrowmire R170M site (referred to as “The Todds”) as being inappropriate because “the Windermere Road corridor already suffers congestion and delays during peak periods, it is considered that additional large-scale development in this area will lead to deterioration in traffic conditions”.
Page 60 suggests site development proposals, which should be reviewed, includes site R170M.
Page 71 states “In addition, it is recommended that the size of residential development at the Todds (Sites R148/R170) and Stonebank Green (Sites M39/R676/R103/R675) should be subject to careful review to ensure that development does not adversely affect the operation of the highway network.”

1.ii) Kendal Town Council Response to Consultation - SLDC "Emerging Options" Land Allocation DPD- April 2011
• The Todds, west of Burneside Road (Sites R148/R170) - 317 houses - has become Sites
R170M/R46/RN169M/R44 - 403 houses, plus Sites sharing the same traffic corridor, R489M and
M38M in Burneside - 102 houses.

The evidence from the previous Assessment is that these latest Allocations currently do not have a traffic solution which would make them deliverable. The Council believes these sites should not be included in Allocations until a solution is put forward which successfully passes the modelling test.
This statement refers to site R170M.

1.iii) Kendal Local Development Framework Transport Study Revised Modelling Results
• Cumbria County Council January 2012 has been put forward as a possible solution to Kendal’s traffic infrastructure including possible traffic solutions for site R170M.
The LDF has been in the consultation stage for 8 years, yet here we are at the 11th hour with a Traffic STUDY including some dubious results (see Kendal Town Council Submission) not a PLAN.

This is a STUDY it is NOT a PLAN – there is no commitment to deliver the schemes mentioned – some of the schemes involved are big, expensive, will require extensive environmental and economic assessment to confirm whether they are practical, justified or even whether they are deliverable. When the studies have been completed they would have to enter some formal forward programme and they would have to go through their own “planning process” including land acquisition which would/could involve compulsory purchase. So there is no commitment – the study even says that they would be expensive and difficult to justify in terms of their benefit to the network in the town.

All of the schemes together only result in “no detriment”. There is no evidence that any of the projects are deliverable. There is no commitment by “partners” ie Cumbria CC to deliver the larger projects.

1.v) The development of site R170M and other sites at Burneside would increase traffic flows along Burneside Road. Burneside Road has many adverse safety features throughout its urban length which simply cannot be addressed by any physical means. Without a credible Transport plan in place, the development of site R170M should be removed from the LA DPD.
Policy LA2.2 is unsound to include site R170M within the LA DPD.

2) TRAFFIC ACCESS
2.i) Access to site R170M would have to be from the already busy ‘C’ class highway, between bends with severely restricted visibility and alongside an expanding Golf Club (Carus Green). It would be difficult if not impossible to achieve safely. Cumbria County Council (Highways) admits - “achieving adequate visibility will be problematic given alignment of road and limited frontage. Such a large site would require a secondary access”.
The Conclusion of a privately commissioned report undertaken by a Chartered Civil Engineer stated :- “There is severely restricted forward visibility on both bends in Burneside Road either side of the proposed access location.
In either scenario tested the visibility from the proposed access towards Kendal falls far short of the standard required.
A new junction cannot be safely introduced in this location.”
2.ii) Cumbria County Council (Highways) state site R170M would require a secondary access route. There is no information available on any Consultation Documentation relating to the reason for this or the location of a secondary access route.
2.iii) To include this ‘C’ class highway as a possible location for access and without an identified location for a secondary access route makes the Policy LA2.2 unsound to include site R170M within the LA DPD.

3) GREEN GAP
3.i) Site R170M is part of a Green Gap retained as Green Gap following the last Public Inquiry (1996).
3.ii) Confusion over Green Gap and Coalescence R170M Site History

Site R170M was removed by SLDC in its Deposit Draft just prior to the public inquiry in 1996. There was an objection to this removal by the land owner Mr Downham. This is what it states on page 137 of the Inspector's Report 1996:
"Inspector's Conclusions:
6.9 The objection by Mr Downham is not concerned with the provision of a green gap, but the extent of that gap. It is argued that the green gap, as shown in the Consultation draft of the Plan, follows a public footpath running between substantial hedges, a clearly defined landscape boundary: whilst the residential allocation at Sparrowmire has been reduced in the Deposit Draft, an equivalent extension to the green gap is not necessary. However, and most importantly in my view, the objection indicates that the "land should remain unallocated as white land so that when the Plan is reviewed in 10 years' time it can be considered as potential residential land". I consider this underlying reason for excluding the land from the green gap identifies the very reason it should remain so designated. Structure Plan Policy 14 and the reasoned justification makes no reference to the length of time during which the vulnerable areas of countryside between settlements should be protected. Although policies and proposals in the Local Plan must clearly relate to the Plan period, and can be subject to review thereafter, it appears to me common sense that what is unacceptable now, will most probably be equally unacceptable at the end of the Plan period: certainly I consider the Plan should seek to engender a degree of public confidence that the separation secured will not, at some future time, be lightly squandered. For these reasons I believe that, where a green gap is seen as necessary, it is more important that the whole gap between the settlements should be designated as green gap than that substantial, but arbitrary landscape features should be rigidly followed. I also consider the inter-visibility of settlements is not a factor which should affect the definition of green gaps."

3.iii) Site R170M should not have been included in proposed policy LA2.2 because it was assessed at the last Public Inquiry (1996). The Public Inspectors conclusion in considering that future plans should seek to engender a degree of public confidence and that the inter-visibility of settlements is not a factor which should affect the definition of green gaps should not be overturned.

3.v) Burneside Parish Council also rejected R170M as this site would further erode the designated Green Gap to prevent coalescence with Burneside.

4) SEWERAGE

4.i) United Utilities state there are major issues on the network with no investment programmed before 2015. These issues relate to problems with the Kentrigg Sewer and that major investment is needed prior to development of site R170M.
Our understanding is that there is no guarantee of investment after 2015 to build the necessary sewerage infrastructure required to develop site R170M and the scale of investment is unlikely to be affordable by any developer.

4.ii) Without the necessary sewerage infrastructure in place policy LA2.2 is unsound and not deliverable in relation to site R170M.

5) FLOODING

5.i) There are known flooding issues on site R170M, which was one of the main reasons this site was rejected some time ago at the last Public Inquiry.
Since the development of the Briarigg estate some 8 years ago there is now new flooding over Burneside Road and into several residential properties adjacent to the bridleway on the west side of Burneside Road. It is inevitable development of site R170M will increase the flood risk to these and even more properties in the area.

7) LANDSCAPE CHARACTER AND PREVIOUS EXPANSION

7.i) Previous expansion in this area includes Moor Field Close, Kettlewell Road, Acre Moss Lane, Overdale Close, Mossghyll, Aysgarth Close, Peat Bank, Newbiggin and the Briarigg Estate.
This amounts to some 400 dwellings over 18 hectares of greenfield sites.
The proposed policy LA2.2 is unsound to include another 197 dwellings over yet another 7.85 hectares of open greenfield Green Gap land.

7.ii) South Lakeland Employment and Housing Land Search Study stated “There is some potential for expansion in the area, although given the scale of previous expansion, this should be limited. This study discounted the site R170M as a potential suitable area for development.”

8) ACCESS TO FACILITIES

8.i) All the main facilities are distant - Doctors, Hospital, Schools, Shops, Supermarkets, Rail Links, Bus Links and employment sites. The inevitable result of this will therefore necessitate yet more journeys across Kendal town breaching sustainability by adding to the already congested highway infrastructure (see Atkins report).
This again makes site R170M unsound and unsustainable.

Proposed Changes I would like to see:-
1 The removal of site R170M from LDF.
Why:-
For all the above reasons.

NO, I do not wish to participate at the oral examination

Please notify me

I have read the guidance notes

LA1.3 Housing Allocations - R170M-mod KENDAL NORTH OF LAUREL GARDENS

No

The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.

The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.

The DPD is not consistent with national policy.

1) TRAFFIC
1.i) South Lakeland District Council commissioned an SLDC Transport Assessment Report (Atkins Report – June 2009) for future development in Kendal (see document “Kendal_TAJune_2009.pdf”).
Two of the three main conclusions stated are.
- The volume of development traffic from The Todds site, R170M west of Burneside Road was considered to be inappropriate for this location.
- Recommended that further development in the Shap Road/Appleby Road Corridor should be resisted.

The report (page 7) specifically mentions the Middle Sparrowmire R170M site (referred to as “The Todds”) as being inappropriate because “the Windermere Road corridor already suffers congestion and delays during peak periods, it is considered that additional large-scale development in this area will lead to deterioration in traffic conditions”.
Page 60 suggests site development proposals, which should be reviewed, includes site R170M.
Page 71 states “In addition, it is recommended that the size of residential development at the Todds (Sites R148/R170) and Stonebank Green (Sites M39/R676/R103/R675) should be subject to careful review to ensure that development does not adversely affect the operation of the highway network.”

1.ii) Kendal Town Council Response to Consultation - SLDC "Emerging Options" Land Allocation DPD- April 2011
• The Todds, west of Burneside Road (Sites R148/R170) - 317 houses - has become Sites
R170M/R46/RN169M/R44 - 403 houses, plus Sites sharing the same traffic corridor, R489M and
M38M in Burneside - 102 houses.

The evidence from the previous Assessment is that these latest Allocations currently do not have a traffic solution which would make them deliverable. The Council believes these sites should not be included in Allocations until a solution is put forward which successfully passes the modelling test.
This statement refers to site R170M.

1.iii) Kendal Local Development Framework Transport Study Revised Modelling Results
• Cumbria County Council January 2012 has been put forward as a possible solution to Kendal’s traffic infrastructure including possible traffic solutions for site R170M.
The LDF has been in the consultation stage for 8 years, yet here we are at the 11th hour with a Traffic STUDY including some dubious results (see Kendal Town Council Submission) not a PLAN.

This is a STUDY it is NOT a PLAN – there is no commitment to deliver the schemes mentioned – some of the schemes involved are big, expensive, will require extensive environmental and economic assessment to confirm whether they are practical, justified or even whether they are deliverable. When the studies have been completed they would have to enter some formal forward programme and they would have to go through their own “planning process” including land acquisition which would/could involve compulsory purchase. So there is no commitment – the study even says that they would be expensive and difficult to justify in terms of their benefit to the network in the town.

All of the schemes together only result in “no detriment”. There is no evidence that any of the projects are deliverable. There is no commitment by “partners” ie Cumbria CC to deliver the larger projects.

1.v) The development of site R170M and other sites at Burneside would increase traffic flows along Burneside Road. Burneside Road has many adverse safety features throughout its urban length which simply cannot be addressed by any physical means. Without a credible Transport plan in place, the development of site R170M should be removed from the LA DPD.
Policy LA2.2 is unsound to include site R170M within the LA DPD.

2) TRAFFIC ACCESS
2.i) Access to site R170M would have to be from the already busy ‘C’ class highway, between bends with severely restricted visibility and alongside an expanding Golf Club (Carus Green). It would be difficult if not impossible to achieve safely. Cumbria County Council (Highways) admits - “achieving adequate visibility will be problematic given alignment of road and limited frontage. Such a large site would require a secondary access”.
The Conclusion of a privately commissioned report undertaken by a Chartered Civil Engineer stated :- “There is severely restricted forward visibility on both bends in Burneside Road either side of the proposed access location.
In either scenario tested the visibility from the proposed access towards Kendal falls far short of the standard required.
A new junction cannot be safely introduced in this location.”
2.ii) Cumbria County Council (Highways) state site R170M would require a secondary access route. There is no information available on any Consultation Documentation relating to the reason for this or the location of a secondary access route.
2.iii) To include this ‘C’ class highway as a possible location for access and without an identified location for a secondary access route makes the Policy LA2.2 unsound to include site R170M within the LA DPD.

3) GREEN GAP
3.i) Site R170M is part of a Green Gap retained as Green Gap following the last Public Inquiry (1996).
3.ii) Confusion over Green Gap and Coalescence R170M Site History

Site R170M was removed by SLDC in its Deposit Draft just prior to the public inquiry in 1996. There was an objection to this removal by the land owner Mr Downham. This is what it states on page 137 of the Inspector's Report 1996:
"Inspector's Conclusions:
6.9 The objection by Mr Downham is not concerned with the provision of a green gap, but the extent of that gap. It is argued that the green gap, as shown in the Consultation draft of the Plan, follows a public footpath running between substantial hedges, a clearly defined landscape boundary: whilst the residential allocation at Sparrowmire has been reduced in the Deposit Draft, an equivalent extension to the green gap is not necessary. However, and most importantly in my view, the objection indicates that the "land should remain unallocated as white land so that when the Plan is reviewed in 10 years' time it can be considered as potential residential land". I consider this underlying reason for excluding the land from the green gap identifies the very reason it should remain so designated. Structure Plan Policy 14 and the reasoned justification makes no reference to the length of time during which the vulnerable areas of countryside between settlements should be protected. Although policies and proposals in the Local Plan must clearly relate to the Plan period, and can be subject to review thereafter, it appears to me common sense that what is unacceptable now, will most probably be equally unacceptable at the end of the Plan period: certainly I consider the Plan should seek to engender a degree of public confidence that the separation secured will not, at some future time, be lightly squandered. For these reasons I believe that, where a green gap is seen as necessary, it is more important that the whole gap between the settlements should be designated as green gap than that substantial, but arbitrary landscape features should be rigidly followed. I also consider the inter-visibility of settlements is not a factor which should affect the definition of green gaps."

3.iii) Site R170M should not have been included in proposed policy LA2.2 because it was assessed at the last Public Inquiry (1996). The Public Inspectors conclusion in considering that future plans should seek to engender a degree of public confidence and that the inter-visibility of settlements is not a factor which should affect the definition of green gaps should not be overturned.

3.v) Burneside Parish Council also rejected R170M as this site would further erode the designated Green Gap to prevent coalescence with Burneside.

4) SEWERAGE

4.i) United Utilities state there are major issues on the network with no investment programmed before 2015. These issues relate to problems with the Kentrigg Sewer and that major investment is needed prior to development of site R170M.
Our understanding is that there is no guarantee of investment after 2015 to build the necessary sewerage infrastructure required to develop site R170M and the scale of investment is unlikely to be affordable by any developer.

4.ii) Without the necessary sewerage infrastructure in place policy LA2.2 is unsound and not deliverable in relation to site R170M.

5) FLOODING

5.i) There are known flooding issues on site R170M, which was one of the main reasons this site was rejected some time ago at the last Public Inquiry.
Since the development of the Briarigg estate some 8 years ago there is now new flooding over Burneside Road and into several residential properties adjacent to the bridleway on the west side of Burneside Road. It is inevitable development of site R170M will increase the flood risk to these and even more properties in the area.

7) LANDSCAPE CHARACTER AND PREVIOUS EXPANSION

7.i) Previous expansion in this area includes Moor Field Close, Kettlewell Road, Acre Moss Lane, Overdale Close, Mossghyll, Aysgarth Close, Peat Bank, Newbiggin and the Briarigg Estate.
This amounts to some 400 dwellings over 18 hectares of greenfield sites.
The proposed policy LA2.2 is unsound to include another 197 dwellings over yet another 7.85 hectares of open greenfield Green Gap land.

7.ii) South Lakeland Employment and Housing Land Search Study stated “There is some potential for expansion in the area, although given the scale of previous expansion, this should be limited. This study discounted the site R170M as a potential suitable area for development.”

8) ACCESS TO FACILITIES

8.i) All the main facilities are distant - Doctors, Hospital, Schools, Shops, Supermarkets, Rail Links, Bus Links and employment sites. The inevitable result of this will therefore necessitate yet more journeys across Kendal town breaching sustainability by adding to the already congested highway infrastructure (see Atkins report).
This again makes site R170M unsound and unsustainable.

Proposed Changes I would like to see:-
1 The removal of site R170M from LDF.
Why:-
For all the above reasons.

NO, I do not wish to participate at the oral examination

Please notify me

I have read the guidance notes

LA1.3 Housing Allocations - All Kendal sites

No

The DPD is not consistent with national policy.

The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.

The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.

I fully support KENDAL TOWN COUNCIL SUSTAINABLE DEVELOPMENT IN KENDAL Submission to the Planning Inspector SLDC Land Allocations DPD - Submission Edition March 2012 Approved by Council: 2nd April 2012

In particular their comments on:-

Making use of the latest housing forecasts to set short/medium term allocations, rather than the forecasts available at the time the Core Strategy was drawn up.

Recognising forecast errors in the planning process - this means ensuring that the new development can be sustainable within the range of likely outcomes over this period.

Support for and the importance of the Taylor Review 9 pulled together in July 2008 setting out the policy framework necessary to deliver the “vision of a living, working sustainable countryside”. Taylor provided compelling evidence that “doughnut development” was the wrong approach for sustainable rural market towns, and that a “hub and spoke” model represented the best pattern for sustainability.
The evidence in Taylor also shows that adopting this approach would make it considerably easier to deliver the dependent infrastructure.

The Town Council indicates that the LPA has clearly failed in its duty to compare against an alternative which is not only “reasonable”, but according to the best practice collated by Taylor, is also more sustainable, causes less problems with town centre infrastructure, and is more acceptable to residents.

They acknowledge that evidence in the EHLSS indicates that suitable sites could be available (the scope of the SHLAA only covered sites within existing settlement boundaries, and is of less relevance), and there are options both for completely new communities on green field sites, or for breathing new life into existing communities.

They are requesting the Inspector to instruct the LPA to produce a robust evaluation of alternative
approaches to land allocations to meet the housing targets identified for Kendal in the “Core Strategy”, with a particular focus on the recommendations of the Taylor Report.

They acknowledge Kendal residents identify “The level of traffic congestion” as their second highest priority for improvement - coming in just ahead of “Affordable decent housing”. So the LPA has been keen to demonstrate that the developments in the LDF can be delivered without exacerbating congestion in town.

They inform us that in 2009, the LPA commissioned a Kendal Transport Assessment, based on an earlier preliminary land allocation, from independent consultants WS Atkins.

This assessment concluded that the existing highway network plus proposed improvements would just
about accommodate the forecast level of traffic, provided three large sites were removed.

In the “Emerging Options” Land Allocations, these three sites were not only included, but were actually expanded in size. The LPA was challenged by the Town Council to justify this inclusion against the published evidence which the LPA had themselves commissioned from independent consultants.

In reply, the LPA chose not to re-engage independent consultants, but asked Cumbria County Council (CCC) to re-run their traffic models against the latest allocations.

There are two significant differences between the independent consultant’s report and this CCC work.

The CCC study had a significantly different approach to that of Atkins – which appears to result in discounting the LDF impact down from 15.6%/18.7% morning/afternoon down to just 2.3%/6.1%.

KTC then go to say even with this much more generous approach, the Interim study reached much the same conclusion that the existing highway network would not be able to accommodate the proposed levels of LDF

KTC have previously argued that Kendal’s infrastructure requires long term planning, with an evidence-based, published, and defensible roadmap for developing the town and its infrastructure to underpin planning policies.

They argue that with Kendal’s ageing infrastructure, improvements are so substantial that they are likely to need contributions from several partners to deliver and that there needs to be an overall credible plan for infrastructure.

They acknowledge the issues with traffic directly impact on the air quality in Kendal town centre. The air quality in Kendal currently fails statutory guidelines, and has deteriorated since 2008-09. Slow-moving traffic waiting at junction approaches is widely believed to be the major contributory factor.

The road network is already working at capacity, with the effect that NO2 levels in the town centre
are close to or above the Objective.

The CCC modelling work now shows that this “capacity” is simply not deliverable.
Applying the precautionary principle, the Council believes any planned Land Allocations which would be rejected on traffic grounds must also be rejected on air quality until a robust plan is in place.

Without a robust infrastructure “Master Plan” linked to sites, the Council fears it will prove impossible to enforce the necessary Section 106 obligations, which are governed by the government’s Circular 05/2005:20.

The Council asks the Inspector to withhold approval of the DPD until there is a credible infrastructure plan showing the impact of the major sites on the overall town infrastructure, and with high level solutions identified and costed with enough detail to enable the economic deliverability of the sites to be proven.

Proposed Changes I would like to see:-

1. All changes and suggestions as identified within all three of Kendal Town Council’s Sustainable Development in Kendal Submissions to the LPA in their response to the Local Development Framework.

Why - Because their submissions are based on reality and make total sense to me.

NO, I do not wish to participate at the oral examination

Please notify me

I have read the guidance notes

LA1.4 - Kendal Sites

No

The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.

The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.

The DPD is not consistent with national policy.

I fully support KENDAL TOWN COUNCIL SUSTAINABLE DEVELOPMENT IN KENDAL Submission to the Planning Inspector SLDC Land Allocations DPD - Submission Edition March 2012 Approved by Council: 2nd April 2012

In particular their comments on:-

Making use of the latest housing forecasts to set short/medium term allocations, rather than the forecasts available at the time the Core Strategy was drawn up.

Recognising forecast errors in the planning process - this means ensuring that the new development can be sustainable within the range of likely outcomes over this period.

Support for and the importance of the Taylor Review 9 pulled together in July 2008 setting out the policy framework necessary to deliver the “vision of a living, working sustainable countryside”. Taylor provided compelling evidence that “doughnut development” was the wrong approach for sustainable rural market towns, and that a “hub and spoke” model represented the best pattern for sustainability.
The evidence in Taylor also shows that adopting this approach would make it considerably easier to deliver the dependent infrastructure.

The Town Council indicates that the LPA has clearly failed in its duty to compare against an alternative which is not only “reasonable”, but according to the best practice collated by Taylor, is also more sustainable, causes less problems with town centre infrastructure, and is more acceptable to residents.

They acknowledge that evidence in the EHLSS indicates that suitable sites could be available (the scope of the SHLAA only covered sites within existing settlement boundaries, and is of less relevance), and there are options both for completely new communities on green field sites, or for breathing new life into existing communities.

They are requesting the Inspector to instruct the LPA to produce a robust evaluation of alternative
approaches to land allocations to meet the housing targets identified for Kendal in the “Core Strategy”, with a particular focus on the recommendations of the Taylor Report.

They acknowledge Kendal residents identify “The level of traffic congestion” as their second highest priority for improvement - coming in just ahead of “Affordable decent housing”. So the LPA has been keen to demonstrate that the developments in the LDF can be delivered without exacerbating congestion in town.

They inform us that in 2009, the LPA commissioned a Kendal Transport Assessment, based on an earlier preliminary land allocation, from independent consultants WS Atkins.

This assessment concluded that the existing highway network plus proposed improvements would just
about accommodate the forecast level of traffic, provided three large sites were removed.

In the “Emerging Options” Land Allocations, these three sites were not only included, but were actually expanded in size. The LPA was challenged by the Town Council to justify this inclusion against the published evidence which the LPA had themselves commissioned from independent consultants.

In reply, the LPA chose not to re-engage independent consultants, but asked Cumbria County Council (CCC) to re-run their traffic models against the latest allocations.

There are two significant differences between the independent consultant’s report and this CCC work.

The CCC study had a significantly different approach to that of Atkins – which appears to result in discounting the LDF impact down from 15.6%/18.7% morning/afternoon down to just 2.3%/6.1%.

KTC then go to say even with this much more generous approach, the Interim study reached much the same conclusion that the existing highway network would not be able to accommodate the proposed levels of LDF

KTC have previously argued that Kendal’s infrastructure requires long term planning, with an evidence-based, published, and defensible roadmap for developing the town and its infrastructure to underpin planning policies.

They argue that with Kendal’s ageing infrastructure, improvements are so substantial that they are likely to need contributions from several partners to deliver and that there needs to be an overall credible plan for infrastructure.

They acknowledge the issues with traffic directly impact on the air quality in Kendal town centre. The air quality in Kendal currently fails statutory guidelines, and has deteriorated since 2008-09. Slow-moving traffic waiting at junction approaches is widely believed to be the major contributory factor.

The road network is already working at capacity, with the effect that NO2 levels in the town centre
are close to or above the Objective.

The CCC modelling work now shows that this “capacity” is simply not deliverable.
Applying the precautionary principle, the Council believes any planned Land Allocations which would be rejected on traffic grounds must also be rejected on air quality until a robust plan is in place.

Without a robust infrastructure “Master Plan” linked to sites, the Council fears it will prove impossible to enforce the necessary Section 106 obligations, which are governed by the government’s Circular 05/2005:20.

The Council asks the Inspector to withhold approval of the DPD until there is a credible infrastructure plan showing the impact of the major sites on the overall town infrastructure, and with high level solutions identified and costed with enough detail to enable the economic deliverability of the sites to be proven.

Proposed Changes I would like to see:-

1. All changes and suggestions as identified within all three of Kendal Town Council’s Sustainable Development in Kendal Submissions to the LPA in their response to the Local Development Framework.

Why - Because their submissions are based on reality and make total sense to me.

NO, I do not wish to participate at the oral examination

Please notify me

I have read the guidance notes

LA1.6 Strategic Employment Sites - E4M KENDAL LAND AT SCROGGS WOOD, MILNTHORPE ROAD

No

The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.

The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.

The DPD is not consistent with national policy.

I fully support KENDAL TOWN COUNCIL SUSTAINABLE DEVELOPMENT IN KENDAL Submission to the Planning Inspector SLDC Land Allocations DPD - Submission Edition March 2012 Approved by Council: 2nd April 2012

In particular their comments on:-

Making use of the latest housing forecasts to set short/medium term allocations, rather than the forecasts available at the time the Core Strategy was drawn up.

Recognising forecast errors in the planning process - this means ensuring that the new development can be sustainable within the range of likely outcomes over this period.

Support for and the importance of the Taylor Review 9 pulled together in July 2008 setting out the policy framework necessary to deliver the “vision of a living, working sustainable countryside”. Taylor provided compelling evidence that “doughnut development” was the wrong approach for sustainable rural market towns, and that a “hub and spoke” model represented the best pattern for sustainability.
The evidence in Taylor also shows that adopting this approach would make it considerably easier to deliver the dependent infrastructure.

The Town Council indicates that the LPA has clearly failed in its duty to compare against an alternative which is not only “reasonable”, but according to the best practice collated by Taylor, is also more sustainable, causes less problems with town centre infrastructure, and is more acceptable to residents.

They acknowledge that evidence in the EHLSS indicates that suitable sites could be available (the scope of the SHLAA only covered sites within existing settlement boundaries, and is of less relevance), and there are options both for completely new communities on green field sites, or for breathing new life into existing communities.

They are requesting the Inspector to instruct the LPA to produce a robust evaluation of alternative
approaches to land allocations to meet the housing targets identified for Kendal in the “Core Strategy”, with a particular focus on the recommendations of the Taylor Report.

They acknowledge Kendal residents identify “The level of traffic congestion” as their second highest priority for improvement - coming in just ahead of “Affordable decent housing”. So the LPA has been keen to demonstrate that the developments in the LDF can be delivered without exacerbating congestion in town.

They inform us that in 2009, the LPA commissioned a Kendal Transport Assessment, based on an earlier preliminary land allocation, from independent consultants WS Atkins.

This assessment concluded that the existing highway network plus proposed improvements would just
about accommodate the forecast level of traffic, provided three large sites were removed.

In the “Emerging Options” Land Allocations, these three sites were not only included, but were actually expanded in size. The LPA was challenged by the Town Council to justify this inclusion against the published evidence which the LPA had themselves commissioned from independent consultants.

In reply, the LPA chose not to re-engage independent consultants, but asked Cumbria County Council (CCC) to re-run their traffic models against the latest allocations.

There are two significant differences between the independent consultant’s report and this CCC work.

The CCC study had a significantly different approach to that of Atkins – which appears to result in discounting the LDF impact down from 15.6%/18.7% morning/afternoon down to just 2.3%/6.1%.

KTC then go to say even with this much more generous approach, the Interim study reached much the same conclusion that the existing highway network would not be able to accommodate the proposed levels of LDF

KTC have previously argued that Kendal’s infrastructure requires long term planning, with an evidence-based, published, and defensible roadmap for developing the town and its infrastructure to underpin planning policies.

They argue that with Kendal’s ageing infrastructure, improvements are so substantial that they are likely to need contributions from several partners to deliver and that there needs to be an overall credible plan for infrastructure.

They acknowledge the issues with traffic directly impact on the air quality in Kendal town centre. The air quality in Kendal currently fails statutory guidelines, and has deteriorated since 2008-09. Slow-moving traffic waiting at junction approaches is widely believed to be the major contributory factor.

The road network is already working at capacity, with the effect that NO2 levels in the town centre
are close to or above the Objective.

The CCC modelling work now shows that this “capacity” is simply not deliverable.
Applying the precautionary principle, the Council believes any planned Land Allocations which would be rejected on traffic grounds must also be rejected on air quality until a robust plan is in place.

Without a robust infrastructure “Master Plan” linked to sites, the Council fears it will prove impossible to enforce the necessary Section 106 obligations, which are governed by the government’s Circular 05/2005:20.

The Council asks the Inspector to withhold approval of the DPD until there is a credible infrastructure plan showing the impact of the major sites on the overall town infrastructure, and with high level solutions identified and costed with enough detail to enable the economic deliverability of the sites to be proven.

Proposed Changes I would like to see:-

1. All changes and suggestions as identified within all three of Kendal Town Council’s Sustainable Development in Kendal Submissions to the LPA in their response to the Local Development Framework.

Why - Because their submissions are based on reality and make total sense to me.

NO, I do not wish to participate at the oral examination

Please notify me

I have read the guidance notes

LA1.7 Business and Science Park Sites - M2M-mod KENDAL LAND EAST OF BURTON ROAD

No

The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.

The DPD is not consistent with national policy.

The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.

I fully support KENDAL TOWN COUNCIL SUSTAINABLE DEVELOPMENT IN KENDAL Submission to the Planning Inspector SLDC Land Allocations DPD - Submission Edition March 2012 Approved by Council: 2nd April 2012

In particular their comments on:-

Making use of the latest housing forecasts to set short/medium term allocations, rather than the forecasts available at the time the Core Strategy was drawn up.

Recognising forecast errors in the planning process - this means ensuring that the new development can be sustainable within the range of likely outcomes over this period.

Support for and the importance of the Taylor Review 9 pulled together in July 2008 setting out the policy framework necessary to deliver the “vision of a living, working sustainable countryside”. Taylor provided compelling evidence that “doughnut development” was the wrong approach for sustainable rural market towns, and that a “hub and spoke” model represented the best pattern for sustainability.
The evidence in Taylor also shows that adopting this approach would make it considerably easier to deliver the dependent infrastructure.

The Town Council indicates that the LPA has clearly failed in its duty to compare against an alternative which is not only “reasonable”, but according to the best practice collated by Taylor, is also more sustainable, causes less problems with town centre infrastructure, and is more acceptable to residents.

They acknowledge that evidence in the EHLSS indicates that suitable sites could be available (the scope of the SHLAA only covered sites within existing settlement boundaries, and is of less relevance), and there are options both for completely new communities on green field sites, or for breathing new life into existing communities.

They are requesting the Inspector to instruct the LPA to produce a robust evaluation of alternative
approaches to land allocations to meet the housing targets identified for Kendal in the “Core Strategy”, with a particular focus on the recommendations of the Taylor Report.

They acknowledge Kendal residents identify “The level of traffic congestion” as their second highest priority for improvement - coming in just ahead of “Affordable decent housing”. So the LPA has been keen to demonstrate that the developments in the LDF can be delivered without exacerbating congestion in town.

They inform us that in 2009, the LPA commissioned a Kendal Transport Assessment, based on an earlier preliminary land allocation, from independent consultants WS Atkins.

This assessment concluded that the existing highway network plus proposed improvements would just
about accommodate the forecast level of traffic, provided three large sites were removed.

In the “Emerging Options” Land Allocations, these three sites were not only included, but were actually expanded in size. The LPA was challenged by the Town Council to justify this inclusion against the published evidence which the LPA had themselves commissioned from independent consultants.

In reply, the LPA chose not to re-engage independent consultants, but asked Cumbria County Council (CCC) to re-run their traffic models against the latest allocations.

There are two significant differences between the independent consultant’s report and this CCC work.

The CCC study had a significantly different approach to that of Atkins – which appears to result in discounting the LDF impact down from 15.6%/18.7% morning/afternoon down to just 2.3%/6.1%.

KTC then go to say even with this much more generous approach, the Interim study reached much the same conclusion that the existing highway network would not be able to accommodate the proposed levels of LDF

KTC have previously argued that Kendal’s infrastructure requires long term planning, with an evidence-based, published, and defensible roadmap for developing the town and its infrastructure to underpin planning policies.

They argue that with Kendal’s ageing infrastructure, improvements are so substantial that they are likely to need contributions from several partners to deliver and that there needs to be an overall credible plan for infrastructure.

They acknowledge the issues with traffic directly impact on the air quality in Kendal town centre. The air quality in Kendal currently fails statutory guidelines, and has deteriorated since 2008-09. Slow-moving traffic waiting at junction approaches is widely believed to be the major contributory factor.

The road network is already working at capacity, with the effect that NO2 levels in the town centre
are close to or above the Objective.

The CCC modelling work now shows that this “capacity” is simply not deliverable.
Applying the precautionary principle, the Council believes any planned Land Allocations which would be rejected on traffic grounds must also be rejected on air quality until a robust plan is in place.

Without a robust infrastructure “Master Plan” linked to sites, the Council fears it will prove impossible to enforce the necessary Section 106 obligations, which are governed by the government’s Circular 05/2005:20.

The Council asks the Inspector to withhold approval of the DPD until there is a credible infrastructure plan showing the impact of the major sites on the overall town infrastructure, and with high level solutions identified and costed with enough detail to enable the economic deliverability of the sites to be proven.

Proposed Changes I would like to see:-

1. All changes and suggestions as identified within all three of Kendal Town Council’s Sustainable Development in Kendal Submissions to the LPA in their response to the Local Development Framework.

Why - Because their submissions are based on reality and make total sense to me.

NO, I do not wish to participate at the oral examination

Please notify me

I have read the guidance notes

LA1.8 Local Employment Sites - All Kendal sites

No

The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.

The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.

The DPD is not consistent with national policy.

I fully support KENDAL TOWN COUNCIL SUSTAINABLE DEVELOPMENT IN KENDAL Submission to the Planning Inspector SLDC Land Allocations DPD - Submission Edition March 2012 Approved by Council: 2nd April 2012

In particular their comments on:-

Making use of the latest housing forecasts to set short/medium term allocations, rather than the forecasts available at the time the Core Strategy was drawn up.

Recognising forecast errors in the planning process - this means ensuring that the new development can be sustainable within the range of likely outcomes over this period.

Support for and the importance of the Taylor Review 9 pulled together in July 2008 setting out the policy framework necessary to deliver the “vision of a living, working sustainable countryside”. Taylor provided compelling evidence that “doughnut development” was the wrong approach for sustainable rural market towns, and that a “hub and spoke” model represented the best pattern for sustainability.
The evidence in Taylor also shows that adopting this approach would make it considerably easier to deliver the dependent infrastructure.

The Town Council indicates that the LPA has clearly failed in its duty to compare against an alternative which is not only “reasonable”, but according to the best practice collated by Taylor, is also more sustainable, causes less problems with town centre infrastructure, and is more acceptable to residents.

They acknowledge that evidence in the EHLSS indicates that suitable sites could be available (the scope of the SHLAA only covered sites within existing settlement boundaries, and is of less relevance), and there are options both for completely new communities on green field sites, or for breathing new life into existing communities.

They are requesting the Inspector to instruct the LPA to produce a robust evaluation of alternative
approaches to land allocations to meet the housing targets identified for Kendal in the “Core Strategy”, with a particular focus on the recommendations of the Taylor Report.

They acknowledge Kendal residents identify “The level of traffic congestion” as their second highest priority for improvement - coming in just ahead of “Affordable decent housing”. So the LPA has been keen to demonstrate that the developments in the LDF can be delivered without exacerbating congestion in town.

They inform us that in 2009, the LPA commissioned a Kendal Transport Assessment, based on an earlier preliminary land allocation, from independent consultants WS Atkins.

This assessment concluded that the existing highway network plus proposed improvements would just
about accommodate the forecast level of traffic, provided three large sites were removed.

In the “Emerging Options” Land Allocations, these three sites were not only included, but were actually expanded in size. The LPA was challenged by the Town Council to justify this inclusion against the published evidence which the LPA had themselves commissioned from independent consultants.

In reply, the LPA chose not to re-engage independent consultants, but asked Cumbria County Council (CCC) to re-run their traffic models against the latest allocations.

There are two significant differences between the independent consultant’s report and this CCC work.

The CCC study had a significantly different approach to that of Atkins – which appears to result in discounting the LDF impact down from 15.6%/18.7% morning/afternoon down to just 2.3%/6.1%.

KTC then go to say even with this much more generous approach, the Interim study reached much the same conclusion that the existing highway network would not be able to accommodate the proposed levels of LDF

KTC have previously argued that Kendal’s infrastructure requires long term planning, with an evidence-based, published, and defensible roadmap for developing the town and its infrastructure to underpin planning policies.

They argue that with Kendal’s ageing infrastructure, improvements are so substantial that they are likely to need contributions from several partners to deliver and that there needs to be an overall credible plan for infrastructure.

They acknowledge the issues with traffic directly impact on the air quality in Kendal town centre. The air quality in Kendal currently fails statutory guidelines, and has deteriorated since 2008-09. Slow-moving traffic waiting at junction approaches is widely believed to be the major contributory factor.

The road network is already working at capacity, with the effect that NO2 levels in the town centre
are close to or above the Objective.

The CCC modelling work now shows that this “capacity” is simply not deliverable.
Applying the precautionary principle, the Council believes any planned Land Allocations which would be rejected on traffic grounds must also be rejected on air quality until a robust plan is in place.

Without a robust infrastructure “Master Plan” linked to sites, the Council fears it will prove impossible to enforce the necessary Section 106 obligations, which are governed by the government’s Circular 05/2005:20.

The Council asks the Inspector to withhold approval of the DPD until there is a credible infrastructure plan showing the impact of the major sites on the overall town infrastructure, and with high level solutions identified and costed with enough detail to enable the economic deliverability of the sites to be proven.

Proposed Changes I would like to see:-

1. All changes and suggestions as identified within all three of Kendal Town Council’s Sustainable Development in Kendal Submissions to the LPA in their response to the Local Development Framework.

Why - Because their submissions are based on reality and make total sense to me.

NO, I do not wish to participate at the oral examination

Please notify me

I have read the guidance notes

1.9

No

The Land Allocations Document (DPD) is not within the Local Development Scheme and the key stages have not been followed

The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)

The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy

Legal Compliance 2

SLDC has failed to deliver appropriate, sufficient and effective methods of engagement in response to the needs of the community.

The public have been asked to submit to the soundness of a DPD comprising approximately 460 technical documents covering 14,500 pages (visually, this would represent a stack of A4 paper approx. 1.5 metres tall). SLDC chose only to allow for the minimally prescribed consultation period of six weeks.

Residents who are less inclined or able to read through a complex set of documents containing thousands of pages of text, tables, maps and appendices (either in paper form or via the SLDC website) have therefore been broadly excluded from making any substantial comments or submissions which are deemed to be ‘viable’ by SLDC.

It has failed to be creative in the way it reaches out to all parts of the community, participation has been limited to the usual ‘informed and active minority’.

Crucially, the disenfranchisement of the older generation from the consultation process has meant that a significant percentage of the population has been under-represented (where currently 29% of the population of South Lakeland is over 60).

Where SLDC have engaged with the public in face to face meetings in the community, it has been with a “presentational style” of plans to be delivered, rather than of options for consultation. It has been alleged that in response to challenges, SLDC representatives have been heard to comment at public meetings that the plans will be delivered ‘regardless of public opposition’. Despite an outward impression of a robust consultation process, it could be said this has simply been a ‘tick-the-box’ exercise.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
in any meaningful way when preparing the final land allocations document. To the contrary, there are instances where additional sites have been added or numbers of dwellings increased in areas where submissions were made opposing original plans.

The delivery of the consultation by SLDC has resulted in a sense of detachment from the planning process as many residents feel marginalised by an ‘indifferent approach’ to their opinions and aspirations for their neighbourhoods. Communities have not been treated as stake-holders in the future success of their towns and villages.

NO, I do not wish to participate at the oral examination

Please notify me

I have read the guidance notes

1.10

No

The Land Allocations Document (DPD) is not within the Local Development Scheme and the key stages have not been followed

The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)

The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy

Legal Compliance 2

SLDC has failed to deliver appropriate, sufficient and effective methods of engagement in response to the needs of the community.

The public have been asked to submit to the soundness of a DPD comprising approximately 460 technical documents covering 14,500 pages (visually, this would represent a stack of A4 paper approx. 1.5 metres tall). SLDC chose only to allow for the minimally prescribed consultation period of six weeks.

Residents who are less inclined or able to read through a complex set of documents containing thousands of pages of text, tables, maps and appendices (either in paper form or via the SLDC website) have therefore been broadly excluded from making any substantial comments or submissions which are deemed to be ‘viable’ by SLDC.

It has failed to be creative in the way it reaches out to all parts of the community, participation has been limited to the usual ‘informed and active minority’.

Crucially, the disenfranchisement of the older generation from the consultation process has meant that a significant percentage of the population has been under-represented (where currently 29% of the population of South Lakeland is over 60).

Where SLDC have engaged with the public in face to face meetings in the community, it has been with a “presentational style” of plans to be delivered, rather than of options for consultation. It has been alleged that in response to challenges, SLDC representatives have been heard to comment at public meetings that the plans will be delivered ‘regardless of public opposition’. Despite an outward impression of a robust consultation process, it could be said this has simply been a ‘tick-the-box’ exercise.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
in any meaningful way when preparing the final land allocations document. To the contrary, there are instances where additional sites have been added or numbers of dwellings increased in areas where submissions were made opposing original plans.

The delivery of the consultation by SLDC has resulted in a sense of detachment from the planning process as many residents feel marginalised by an ‘indifferent approach’ to their opinions and aspirations for their neighbourhoods. Communities have not been treated as stake-holders in the future success of their towns and villages.

NO, I do not wish to participate at the oral examination

Please notify me