8 responses from Mr & Mrs R Harvey (Individual)
1. Mr & Mrs R Harvey (Individual) : 4 May 2012 11:12:00
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Paragraph No.
0.0 Whole Document
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
The processes of community involvement in developing the DPD are not in general accordance of the Statement of Community Involvement (SCI)
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
The DPD has not had regard to the Sustainable Community Strategy
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
It is remarkable that the opposition, by the electorate, of this plan has not had a corresponding result for its outcome. The evidence and costings and detail needed to allocate land for large scale development is remarkably absent. The infrastructure growth to cope with 6000 new homes and their occupants etc is remarkably absent.
1. A Special Case for South Lakeland District(SLD)
1.1 Two different National Park Authorities (NPs) have control of two large sectors of South Lakeland, and if we consider the AONBs and SSSis and other protected areas within SLD's landscape, then there is little room for development left on the scale apparently demanded by National and Local Government.
1.2 Why should SLD outside of the NPs become overdeveloped to its detriment, compared with SLD within NPs, when there is as much need for housing and employment in the valleys of National Parks? The monoculture of Tourism, and that as many as 4 in I 0 houses in some cases are second or holiday homes, within a National Park, is unsustainable. Many of those who live in NPs travel outside its boundary for work. Whither the daffodils? they grow on both sides of the line.
1.3 Any legislation driving this LDF and DPD should take these administrative and landscape constraints, and their effects
upon local communities within a single District Council's area, into account as a special case and exception.
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Have any alternatives (other than differant sites) been considered at all? is large scale greenfield development most appropriate in the landscape? in order to build 2000 affordable homes is it necessary to build 5000 more for profit?
SOUNDNESS comments
2. More specifically commenting upon this DPD (for SLD outside of National Parks), and in particular for Kendal town.
We find this DPD Unsound because:-
2.1 There is no costed, reasoned, evidence for social, environmental and economic sustainability, beyond the length of a "housing list".
2.2 The infrastructure of water and energy supplies, drainage and sewerage system, schools and health and emergency care will not be sufficient for daily needs with this level of proposed development, and there is no evidence that any has been planned or costed.
2.3 The landscape character will be changed irreparably. The impact on the local community will cause significant harm. It does not protect the open countryside, nor does it prevent sprawl or safeguard an historic landscape, especially on the Underbarrow Road.
2.4 The majority of people will probably find employment outside of Kendal.
2.5 There is no evidence of the impact on air quality or of a suitable new transport plan.
2.6 There is little evidence that the local electorate support this Plan. In fact more seem to be against it.
The actual housing demand is as likely to be half what is proposed. This is exacerbated by the need to build, say, 65 houses for every 35 affordable ones, to attract the developers.
2.7 The LPA is being railroaded into approving large-scale developments on greenfield sites with very little evidence but rather more conjecture.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
The issue is too important to be left to planners and politicians only. I care about the landscape of SLDC
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2. Mr & Mrs R Harvey (Individual) : 4 May 2012 11:36:00
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Policy/Site No.
LA1.3 Housing Allocations - All Kendal sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
SOUNDNESS comments
2. More specifically commenting upon this DPD (for SLD outside of National Parks), and in particular for Kendal town.
We find this DPD Unsound because:-
2.1 There is no costed, reasoned, evidence for social, environmental and economic sustainability, beyond the length of a "housing list".
2.2 The infrastructure of water and energy supplies, drainage and sewerage system, schools and health and emergency care will not be sufficient for daily needs with this level of proposed development, and there is no evidence that any has been planned or costed.
2.3 The landscape character will be changed irreparably. The impact on the local community will cause significant harm. It does not protect the open countryside, nor does it prevent sprawl or safeguard an historic landscape, especially on the Underbarrow Road.
2.4 The majority of people will probably find employment outside of Kendal.
2.5 There is no evidence of the impact on air quality or of a suitable new transport plan.
2.6 There is little evidence that the local electorate support this Plan. In fact more seem to be against it.
The actual housing demand is as likely to be half what is proposed. This is exacerbated by the need to build, say, 65 houses for every 35 affordable ones, to attract the developers.
2.7 The LPA is being railroaded into approving large-scale developments on greenfield sites with very little evidence but rather more conjecture.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
see rep 1
3. Mr & Mrs R Harvey (Individual) : 4 May 2012 11:38:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.4 - Kendal Sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
SOUNDNESS comments
2. More specifically commenting upon this DPD (for SLD outside of National Parks), and in particular for Kendal town.
We find this DPD Unsound because:-
2.1 There is no costed, reasoned, evidence for social, environmental and economic sustainability, beyond the length of a "housing list".
2.2 The infrastructure of water and energy supplies, drainage and sewerage system, schools and health and emergency care will not be sufficient for daily needs with this level of proposed development, and there is no evidence that any has been planned or costed.
2.3 The landscape character will be changed irreparably. The impact on the local community will cause significant harm. It does not protect the open countryside, nor does it prevent sprawl or safeguard an historic landscape, especially on the Underbarrow Road.
2.4 The majority of people will probably find employment outside of Kendal.
2.5 There is no evidence of the impact on air quality or of a suitable new transport plan.
2.6 There is little evidence that the local electorate support this Plan. In fact more seem to be against it.
The actual housing demand is as likely to be half what is proposed. This is exacerbated by the need to build, say, 65 houses for every 35 affordable ones, to attract the developers.
2.7 The LPA is being railroaded into approving large-scale developments on greenfield sites with very little evidence but rather more conjecture.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
see rep 1
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
4. Mr & Mrs R Harvey (Individual) : 4 May 2012 11:39:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.6 Strategic Employment Sites - E4M KENDAL LAND AT SCROGGS WOOD, MILNTHORPE ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
SOUNDNESS comments
2. More specifically commenting upon this DPD (for SLD outside of National Parks), and in particular for Kendal town.
We find this DPD Unsound because:-
2.1 There is no costed, reasoned, evidence for social, environmental and economic sustainability, beyond the length of a "housing list".
2.2 The infrastructure of water and energy supplies, drainage and sewerage system, schools and health and emergency care will not be sufficient for daily needs with this level of proposed development, and there is no evidence that any has been planned or costed.
2.3 The landscape character will be changed irreparably. The impact on the local community will cause significant harm. It does not protect the open countryside, nor does it prevent sprawl or safeguard an historic landscape, especially on the Underbarrow Road.
2.4 The majority of people will probably find employment outside of Kendal.
2.5 There is no evidence of the impact on air quality or of a suitable new transport plan.
2.6 There is little evidence that the local electorate support this Plan. In fact more seem to be against it.
The actual housing demand is as likely to be half what is proposed. This is exacerbated by the need to build, say, 65 houses for every 35 affordable ones, to attract the developers.
2.7 The LPA is being railroaded into approving large-scale developments on greenfield sites with very little evidence but rather more conjecture.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
see rep 1
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
5. Mr & Mrs R Harvey (Individual) : 4 May 2012 11:41:00
Policy/Site No.
LA1.7 Business and Science Park Sites - M2M-mod KENDAL LAND EAST OF BURTON ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
SOUNDNESS comments
2. More specifically commenting upon this DPD (for SLD outside of National Parks), and in particular for Kendal town.
We find this DPD Unsound because:-
2.1 There is no costed, reasoned, evidence for social, environmental and economic sustainability, beyond the length of a "housing list".
2.2 The infrastructure of water and energy supplies, drainage and sewerage system, schools and health and emergency care will not be sufficient for daily needs with this level of proposed development, and there is no evidence that any has been planned or costed.
2.3 The landscape character will be changed irreparably. The impact on the local community will cause significant harm. It does not protect the open countryside, nor does it prevent sprawl or safeguard an historic landscape, especially on the Underbarrow Road.
2.4 The majority of people will probably find employment outside of Kendal.
2.5 There is no evidence of the impact on air quality or of a suitable new transport plan.
2.6 There is little evidence that the local electorate support this Plan. In fact more seem to be against it.
The actual housing demand is as likely to be half what is proposed. This is exacerbated by the need to build, say, 65 houses for every 35 affordable ones, to attract the developers.
2.7 The LPA is being railroaded into approving large-scale developments on greenfield sites with very little evidence but rather more conjecture.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
see rep 1
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
6. Mr & Mrs R Harvey (Individual) : 4 May 2012 11:42:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.8 Local Employment Sites - All Kendal sites
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
SOUNDNESS comments
2. More specifically commenting upon this DPD (for SLD outside of National Parks), and in particular for Kendal town.
We find this DPD Unsound because:-
2.1 There is no costed, reasoned, evidence for social, environmental and economic sustainability, beyond the length of a "housing list".
2.2 The infrastructure of water and energy supplies, drainage and sewerage system, schools and health and emergency care will not be sufficient for daily needs with this level of proposed development, and there is no evidence that any has been planned or costed.
2.3 The landscape character will be changed irreparably. The impact on the local community will cause significant harm. It does not protect the open countryside, nor does it prevent sprawl or safeguard an historic landscape, especially on the Underbarrow Road.
2.4 The majority of people will probably find employment outside of Kendal.
2.5 There is no evidence of the impact on air quality or of a suitable new transport plan.
2.6 There is little evidence that the local electorate support this Plan. In fact more seem to be against it.
The actual housing demand is as likely to be half what is proposed. This is exacerbated by the need to build, say, 65 houses for every 35 affordable ones, to attract the developers.
2.7 The LPA is being railroaded into approving large-scale developments on greenfield sites with very little evidence but rather more conjecture.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
see rep 1
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
7. Mr & Mrs R Harvey (Individual) : 4 May 2012 11:44:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.3 Housing Allocations - R121M-mod KENDAL EAST OF CASTLE GREEN ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
SOUNDNESS: JUSTIFIED, EFFECTIVE comments
3. With particular reference to modified site R121M (lncluding parts of exR56 and exR141)
We fid Rl21M of this DPD Unsound because:
3.1 It disregards Kendal Town Council's preferences. We say it is not deliverable, not sustainable and there is no evidence base to support its inclusion in the DPD.
3.2 It is not the best location in sustainability and planning terms. The northern two fields make a land-locked site that is totally dependent upon access to a road via sites previously called R56 and Rl41. Without those pieces of land there can be no site access. If the triangle of land made up of exR56 and exR141 is removed then the whole site fails.
3.3 ExR56 and exR141 were previously marked as possible sites for housing, but they have now been deemed to be unsuitable far housing and are included in Rl21M purely to facilitate access. On the one hand there is the implied admission that that land cannot be suitable or damaged for houses, but may be suitable and damaged merely for a road and utility services.
3.4 The cost per unit length of road, lighting, water, electricity and gas, and Sustainable Urban Drainage System, before the proposed site for houses is reached, would probably take up a large proportion of the costs of such services over the whole site. The site is probably uneconomic.
3.5 ExR56 has been refused planning permission in the past and although circumstances may have changed the reasons and principles that informed that earlier decision probably have not To say that those Inspector's reasons "may no longer be relevant" could equally well be wrong. Reasons for giving planning permission, or not, surely are consistent over time?
3.6 ExR56 and exR141 are the most visible, and potentially most damaging to biodiversity, of the amended Rl21M. Street lighting alone will light up hitherto dark fields and woods and pond to the detriment of the landscape and the wildlife, especially Triturus cristatus. Local Environmental Groups have characterised this site as Sensitive. The proposed development is insensitive.
3. 7 The additional waste of 60 houses per year could amount to ( 60x507kg) =30420kg The additional water requirements per year for 60 houses could be (365x60xl55litres) =3,394,500litres. There is no evidence showing how these will be managed or who will pay.
3.8 Rl21M has apparently recognised flooding issues and the resilience of the water and waste services for this site is critical. No evidence or studies have yet been produced to say how these will be met and at what cost.
3.9 The agricultural landscape character will be harmed by such a development. There is the added implication that were an access road to be built, then at a later stage more building alongside that road could be threatened.
3.10 Alarmingly, very little consideration has been given to pedestrian or cycle links to the site. If pedestrians are to access the Old Sedbergh Road from the NW comer, then there are no pavement sidewalks on much of that road. If they are to use Castle Green Lane then there is no pavement sidewalk on the NE side of that 40mph road. It is clear It has been considered only in terms of the use of cars which will put added pressure and N02(etc) air pollution on three pinch points into or around Kendal; Parkside Road, Anne Street!Longpool, and Sandylands and their junctions with the A684.
3.11 Under Policy LA2.3 of the DPD there are so many constraints and provisions for the site that this proves the site is unsustainable and not the best site for development. The number of features that will require mitigation, or assessment and approval, prove that the site is uneconomic and unsuitable for development as housing and for road and utility access. The evidence needed has not yet been gathered. It is all to happen at some future date. That is not Planning for Development but rather planning to have a plan later, maybe, provided the evidence does not contradict or prove to be uneconomic. The site
therefore is not immediately developable.
3.12 The tests and toolkits and appraisal questions have not been adequately applied or answered over the amended site. The fact that policy LA2.3 exists at all is evidence of this.
We urge the Inspector to visit tbe site.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
see rep 1
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
8. Mr & Mrs R Harvey (Individual) : 4 May 2012 11:45:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA2.3 Land East of Castle Green Road
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
SOUNDNESS: JUSTIFIED, EFFECTIVE comments
3. With particular reference to modified site R121M (lncluding parts of exR56 and exR141)
We fid Rl21M of this DPD Unsound because:
3.1 It disregards Kendal Town Council's preferences. We say it is not deliverable, not sustainable and there is no evidence base to support its inclusion in the DPD.
3.2 It is not the best location in sustainability and planning terms. The northern two fields make a land-locked site that is totally dependent upon access to a road via sites previously called R56 and Rl41. Without those pieces of land there can be no site access. If the triangle of land made up of exR56 and exR141 is removed then the whole site fails.
3.3 ExR56 and exR141 were previously marked as possible sites for housing, but they have now been deemed to be unsuitable far housing and are included in Rl21M purely to facilitate access. On the one hand there is the implied admission that that land cannot be suitable or damaged for houses, but may be suitable and damaged merely for a road and utility services.
3.4 The cost per unit length of road, lighting, water, electricity and gas, and Sustainable Urban Drainage System, before the proposed site for houses is reached, would probably take up a large proportion of the costs of such services over the whole site. The site is probably uneconomic.
3.5 ExR56 has been refused planning permission in the past and although circumstances may have changed the reasons and principles that informed that earlier decision probably have not To say that those Inspector's reasons "may no longer be relevant" could equally well be wrong. Reasons for giving planning permission, or not, surely are consistent over time?
3.6 ExR56 and exR141 are the most visible, and potentially most damaging to biodiversity, of the amended Rl21M. Street lighting alone will light up hitherto dark fields and woods and pond to the detriment of the landscape and the wildlife, especially Triturus cristatus. Local Environmental Groups have characterised this site as Sensitive. The proposed development is insensitive.
3. 7 The additional waste of 60 houses per year could amount to ( 60x507kg) =30420kg The additional water requirements per year for 60 houses could be (365x60xl55litres) =3,394,500litres. There is no evidence showing how these will be managed or who will pay.
3.8 Rl21M has apparently recognised flooding issues and the resilience of the water and waste services for this site is critical. No evidence or studies have yet been produced to say how these will be met and at what cost.
3.9 The agricultural landscape character will be harmed by such a development. There is the added implication that were an access road to be built, then at a later stage more building alongside that road could be threatened.
3.10 Alarmingly, very little consideration has been given to pedestrian or cycle links to the site. If pedestrians are to access the Old Sedbergh Road from the NW comer, then there are no pavement sidewalks on much of that road. If they are to use Castle Green Lane then there is no pavement sidewalk on the NE side of that 40mph road. It is clear It has been considered only in terms of the use of cars which will put added pressure and N02(etc) air pollution on three pinch points into or around Kendal; Parkside Road, Anne Street!Longpool, and Sandylands and their junctions with the A684.
3.11 Under Policy LA2.3 of the DPD there are so many constraints and provisions for the site that this proves the site is unsustainable and not the best site for development. The number of features that will require mitigation, or assessment and approval, prove that the site is uneconomic and unsuitable for development as housing and for road and utility access. The evidence needed has not yet been gathered. It is all to happen at some future date. That is not Planning for Development but rather planning to have a plan later, maybe, provided the evidence does not contradict or prove to be uneconomic. The site
therefore is not immediately developable.
3.12 The tests and toolkits and appraisal questions have not been adequately applied or answered over the amended site. The fact that policy LA2.3 exists at all is evidence of this.
We urge the Inspector to visit tbe site.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
see rep 1
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
