2 responses from Mr Keith Hildrew (Individual)
1. Mr Keith Hildrew (Individual) : 27 Apr 2012 14:06:00
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.
I am writing with reference to the above document and the process by which this
was completed. It is my belief that the process was unsound on a variety of points
and in view of the unsoundness the DPD should be withdrawn and reconsidered.
My reasons for claiming that the process was unsound are as follows:
1. When attempts to develop such areas have been proposed in the past, they
have been rejected, and development of higher hillsides round Kendal was
considered to be 'unduly prominent'. Although SLDC claim that
circumstances may have changed, it is not sound planning criteria to ignore
previous rulings based on sound principles. In particular previous site notes
by SLDC showed R121M to be unsuitable for development, which was also the
consistent view of Kendal Town Council over the past 3 years. It is not sound
practice to ignore the views of locally elected councillors on the importance
of maintaining green spaces around Kendal.
2. There were mistakes in the Gillespies Report despite this having been
accepted as sound by SLDC, which means that insufficient attention had
been paid to this process, therefore indicating unsound practice.
3. It is clear that insufficient attention had also been paid by the planner
responsible by not visiting the site in detail and assessing the nature of the
terrain as well as the full impact of such development. This is further
evidence of unsound practice. Also questions raised concerning the impact on
landscape, biodiversity and flooding have not been answered.
4. It would appear that core strategy policies have not been adhered to in this
document, especially on green infrastructure, maintaining green corridors,
watercourses and open spaces, in addition to landscape and settlement
character. This is particularly true of proposals to build roads - presumably
with street lighting etc- across the most sensitive areas (eg R56 and R141)
in order to gain access to R121. It is unreasonable and not sound practice not
to adhere to established core strategies.
5. Insufficient preparation and consideration has been given to specific
proposals - again evidence of unsound practice. For example, a stated
preferred option to allow access to R121 through Oak Tree Road was made
without even visiting the site to measure the width of the road, which would
have shown how unsuitable such a proposal was. Another example is not
giving full consideration to the flooding risk of such land and the effect this
might have on the Stock Beck Flood Alleviation Scheme. The volume of water
coming off the 3 fields in question has not been fully assessed - and this
means that the process of adopting such development is inherently
unreliable.
6. Further evidence provided to SLDC has not been taken into account when
reaching a decision. The Friends of the Lake District have given clear
indications of why R121M should not be developed in the report provided as
part of their evidence in March 2011. The independent Landscape Character
Assessment by Galpin stated that R121M was the most sensitive of all the
proposed development sites in terms of impact on the landscape. It seems
' unjustifiable and inflexible of SLDC not to take into account such findings.
7. There is little evidence that SLDC has seriously looked at any alternative
strategy for the area, or has in place a considered strategic plan to deal with
the problems that such development in Kendal will bring in terms of increased
traffic, air quality, sewerage and effect on general well-being. This makes
the process unsound and its proposals unjustified.
It cannot be sound practice to push ahead with development proposals which have
not been based on robust and credible evidence as shown above. I urge the
Inspector to take these views into account and rule the DPD to be unsound.
2. Mr Keith Hildrew (Individual) : 27 Apr 2012 14:16:00
Paragraph No.
1.10
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.
Finally, there is no evidence that SLDC has taken into consideration the
views of the community directly affected by these proposals. There has been
hardly any noticeable change in general since the first set of land allocations
was published, despite the overwhelming opposition of local residents and
objections from respected local organisations.