Local Development Framework Consultation

I have read the guidance notes

2.8

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 wish to make representation on the soundness of the proposed imposition of the current
Local Development Framework by South Lakeland District Council. There is in this
current plan numerous contradictions with the Core Strategy. Reports compiled by
Consultants for SLDC when developing the Core Strategy and eventually the
Development Plan have been used "piece meal". There are serious concerns about
locations, the magnitude of development and the omission of pertinent facts and a lack of
detailed infrastructure planning. This plan is unsound as the housing and employment land '
allocation is not based upon sound data evidence and is contradictory in many key areas. ·
1. The Imposition of the "top down" Local Development Plan
After the last general election the "top down" approach to community planning was
scrapped and the Regional Development Agency disbanded. Unfortunately in the South
Lakes area the arbitrary allocations of development across the area was accepted. This
policy is still being advocated and pursued by South Lakeland Districts Council even
though this approach is seriously flawed when demand, infrastructure criteria,
employment opportunities and the allocation of employment land is assessed.

1.1 Imposition
I would refer to the SLDC Cabinet meeting dated gth December 2010 item 5.7 Page 241
When referring to the Key Service Centres of Grange over Sands, Kirkby Lonsdale and
Milnthorpe the comment is made that, -"within the Key Service Centres, all of which are
in areas where housing need is high, new housing is distributed pro-rata by size based or
existing number of dwellings".
Firstly the ARC4 report page 9 states quite clearly that the "general market supply and
demand suggests that the open market is generally balanced at District level".
Secondly The Local Housing Need Surveys/Housing Need/TW shows that the District
Survey June 06 that expired in May 11 shows
Grange over Sands needs 75 affordable houses with in an allocation of 497
Kirkby Lonsdale needs 70 affordable houses with in an allocation of 118
Milnthorpe needs 55 affordable houses with in an allocation of 186
Thirdly on the 24th January 2011 South Lakes Housing the "housing stock manager" for
SLDC confirmed that "There are currently 79 people on the South Lakes Housing waiting
list who have Grange over Sands, as their first area of housing choice". This figure is a
"preference" and not necessarily all Grange local needs.

This pro rata split can be seen as being imbalanced, when the figures are compared to the
total allocation. The presumption that because a settlement is larger it can continue to
take more of the allocated development is not based upon sound evidence data. This
assumption does not take into account local constraints, essential services and
infrastructure limitations both existing and proposed. It also does not reflect community
VIeWS.

4. Allocation of Development between the three Service Centres Grange over Sands,
Milnthorpe and Kirkby Lonsdale
The allocation based upon access to services, infrastructure and employment is
unsound.
The criteria used is based upon the observations and recommendations in three "source"
documents these are;
The Douglas Wheeler Regeneration Study
The Core Strategy Document
ARC4report
Examining the three Key Service Centres there appears to be an imbalance of housing and
employment development across all three. The justification of this imbalance is primarily
based upon local constraints and infrastructure deficiencies. However local constraints
and infrastructure deficiencies seem to have been ignored when considering Grange over
Sands, with the flawed assumption that if the settlement is larger it can accommodate
more development. Using the source documents produced by SLDC there are a number
of contradictions, omissions and misleading information put forward to justifY the
allocation for each of the three service centres.
The figures for the total projected housing requirement (the district household survey) is
based upon a theoretical Labour Force-Led forecast. There are many local and National
influences that make this figure unreliable, non more so than the economic climate and the
lack of a manufacturing base in the Grange area. In the case of Grange there is more
housing development with minimal employment land. This is contrary to the Core y\
Strategy, the other three assessments taken from this same survey are more reliable and 1
should be considered in light of the employment development and economic environmental
sustainability of the Town. The economic driver for recovery and subsequent house
purchase (the majority of development will be for sale on the open market) will be
manufacturing, this is not a sector being developed in the immediate vicinity of Grange
over Sands and therefore the criteria for placing homes near to employment will not be
met.
However Table 4-6 POPGROUP modelling page 64 of the ARC4 report shows quite a
wide range in the estimated number of properties required. Given current employment
trends within Grange over Sands and the proposal to develop tourism, leisure and heritage
sectors the only scenarios to give a more accurate assessment are;
1. 5 year migration scenario.
2. 10 year dwelling-led scenario.
3. 10 year migration-led scenario.
There is further confirmation that these three scenarios for the District are a possible way
forward when page 9 of the ARC4 report states quite clearly that;
In summary, analysis of the general market supply and demand suggests that the
open market is generally balanced at District level, although there are some specific
imbalances which include;
An overall shortfall in Central Lakes, Dales and Kendal. Rural market area; and
across Windermere, Sedbergh, Kendal Rural and Furness rural service centres;
Shortfalls in detached properties, bungalows and properties with four or more
bedrooms across the District.
The relatively high cost of housing in relation to local wages/salaries is identified by the
District Council a result of holiday/second homes. The proposal originally of3 5% of
affordable has consistently be lowered, at the request of developers to around the 3 0%
mark with a possibility of this being much lower in certain areas. The remainder sold at
market valve will not address the holiday/second home acquisitions and subsequently will
have minimal effect on the district housing prices.
The Core Strategy Document (pl70) states as one of its primary aims that Grange will
"incorporate moderate new housing development in a way that is sensitive to local
landscape characteristics and historic assets within the surrounding of the town".
The proposed development equates to an overall increase of 30%. This certainly
cannot be described as moderate located entirely on the west side (East according to
Gilles pies) of the town in a corridor Y:. mile wide and no more the 1 %miles in
length. This inevitably requires building on green field sites with only two out of the
seven classed as brown field, one of these being a car park the other the civic amenity site.
Considering what has been highlighted in the ARC4 report in summary of the
general market supply, Grange area has not been identified as an area where there
is a significant shortage or demand, therefore the 30% allocation appears to be even
more excessive. It is worth noting at this stage SLDC have not or been unable to
answer the question or justify what is "moderate new housing development"
in relation to Grange-over-Sands.
Employment in Grange over Sands
The Core Strategy states that there will be a development of tourism, leisure and heritage
sectors. With the building of a supermarket on the "Batemans" site (not Hadwins as
stated) with care facilities proposed for the Kirkhead Road site. These will not provide
sufficient employment or the well paid jobs (in the town) to sustain the proposed number
of residents. This will inevitably lead to a continuance of the current trend, residents
having to travel for employment. This in its self, will impact significantly on the highways
infrastructure (to be addressed later). Milntborpe bas been allocated half of the
employment land 4.5ha for the three Key Service Centres with in percentage terms
considerably less than half of the housing development allocated to Grange over
Sands. Once again the description of the land allocation is "Incorporate moderate
new housing development in a way that is sensitive to the local landscape
characteristics and historic assets". In purely numeric terms Grange is allocated
59% of the three Key Service Centres housing allocation with less employment land,
whilst Milntborpe is allocated only 21% with 50% ofthe employment land
allocation. This assessment becomes more problematic when one considers
infrastructure, services and green environmental issues. There can be no doubt the LD F in
its present format will actually increase motor vehicle usage even though there may be a
policy of developing public transport. Convenience of travel and the topography of the
town will be a major consideration and therefore motor vehicle dependence for local
journeys will continue and increase. The employment trend in Grange has always been
towards self employment in services to the local community and the need to travel for well
paid jobs. This travelling is predominantly towards the east then north and south to the
larger towns and cities ofPreston, Lancaster, Kendal, Penrith and Carlisle. The
predominant form of travel for these longer distance commutes is still the private motor
vehicle because of convenience. There is an acknowledgement this trend will continue.
The other Key Service Centre within the group Kirkby Lonsdale again has the
description "Incorporate moderate new housing development in a way that is
sensitive to the local landscape characteristics and historic assets". Again in
percentage terms Kirby Lonsdale is to receive 20% of the housing allocation even
thought the town is better placed to accommodate more development when one
considers the existing infrastructure, services and green issues.
Infrastructure and Services across the three Key Service Centres
Milnthorpe
The Core Strategy states that the town "provides shopping, schools, employment, medical
and professional services".
There has been a need identified (by SLDC) for a transport assessment and travel plan
even though the town has the main A6 running north/south through the town, the A6070
giving alternative routes via Crooklands to Kendal and Lancaster (via the M6) and the
A65 to the north to travel east (via both the A6/ A590 and the A6070). The town also has
the advantage of easy motorway access to the north via the A6 and the A590 without
having to pass through other towns or villages. Milnthorpe is ideally placed on the
highway network to accommodate development without the need for significant expensive
improvement and more importantly without an adverse effect on the towns long term
economic sustainability. Water supply infrastructure whilst it will accommodate the
proposed development levels there is some concern that to increase the development
allocation the current pumping station would have insufficient capacity. United Utilities
are proposing to upgrade the water supply infrastructure to the town and are seeking
funding in 2014. This will enable Milnthorope to accommodate more housing
development in a phased way to compliment the employment development proposals. It
then begs the question why is this not being considered when the town is better placed to
accommodate development without any detrimental effects on the local economy, one
could argue it may actually support and enhance it. Furthermore if we are to consider
access to essential community services in relation to Grange over Sands we find;
Local Services. Distance from centre. Grange --distance from
Centre to service.
Secondary Schools 0m 2m
Nearest Hospitals - Kendal 6 m 15m
Lancaster 14.5m 27-30m
Railway Station (Arnside) 3m 0m
Motorway access 4.5m 14m
Trunk Road system 0m 4m (A590)

It is also worth noting from the locations of the proposed sites unlike Grange, the
development of Pedestrian and Cycleways to the town will have no physical restrictions in
preventing these being built to an acceptable standard and be cost effective. The town with
its employment land allocation (some 50% of the total for the three service centres) makes
it a more favourable option when one considers the criteria in the Core Strategy
Document. The important criteria considerations such as existing infrastructure, services
and the settlement's ability to support development in an economic sustainable way does
indicate that the allocation of development in this plan is unsound.

Kirkby Lonsdale
The town is identified as having both primary and secondary education together with
medical and professional services. This together with the A65 trunk road running west to
east from Cumbria into West Yorkshire. There is also good road access in all directions,
south to Lancaster and the M6 motorway via the A683 some 14m away and the M6
junction 36, some 6m away.
Essential community services in relation to Grange over Sands;
Local Services. Distances from centre. Grange - Distance
centre to
Secondary schools Om 2m
Nearest Hospitals--Kendal 10m 15m
Lancaster. 16.5m 27-30m
Railway Station (Oxenholme) 10m 0m
Motorway access 6m 14m
Trunk road Om 4m (A590)

The Core Strategy Document highlights in section 3.46 entitled "Local Factors", indicates
factors that influence the location of development. The third point in relation to Kirkby
Lonsdale states as a negative "The potential severance effect and difficulty of crossing the
A65 which is a major route linking West Yorkshire and Cumbria". This "potential
severance" is not insurmountable as many villages and small towns along its entire length
overcome this with pedestrian controlled crossings within speed restricted areas, the other
alterative is to provide pedestrian bridge crossings and possibly a further roundabout. It's
worth noting that Kirkby Lonsdale already has two speed cameras covering the main
section of the town on the A65 as well as a speed limit for the entire length of the
settlement, this will compliment any new development and eliminate any possibility of '
severance. Section 3.51 states "A significant part of Kirkby Lonsdale's housing and
employment land will be met in a single strategic allocation north of Kendal Road.
This site has minimal impact on the historic core of the town, can be well linked to
key facilities such as schools, supermarket, doctor's surgery and town centre'
visually contained and the employment element can be accessed directly from the
A65". This section also states "the need for suitable pedestrian and cycle links to the
town centre", this like Milnthrope is achievable.
There are in these statements an acknowledgement that the A65 forms a significant part of
the development plan in providing good access for employment traffic, it should also be
noted that this also provides residents with an excellent highway infrastructure for
personal travel.
An increase in development would not create severe traffic problems within the town
(with its associated air pollution) and will assist in the compliance of "Enhancing the
vitality and viability ofKirkby Lonsdale town centre for shopping, leisure, arts, culture,
tourism and employment" and the "need to manage biodiversity impacts".

Shopping outlets (supermarkets). .
The Core Strategy Document places great importance on the Key Service Centres having
supermarkets to service the communities. If we now compare the three Key Service
Centres and the development of supermarkets, which it seems is a requirement of the LDF
we find that ;
Milnthorpe will have two new supermarkets, Booths and Spar.
Kirkby Lonsdale already have a large Booths supermarket, which is in the process
of being enlarged.
Grange over Sands will have one small to medium supermarket, Booths, at a critical
highway pinch point within the town. Congestion at this junction is common place
now and will only become worse with the current proposals with a significant
detrimental impact on the environment.

If we then consider the impact of the development in Grange, Allithwaite and Flookburgh
together with the peninsula catchment area for this store, we can expect serious traffic
problems, and a deterioration in air quality. This will seriously effect the main tourist area
of the town. Furthermore this location is overlooked by one of the most prestigious hotels
on the peninsula, not a very attractive proposition for visitors or the proposed . .
development of tourism. 'when one considers the above its not hard to see there is no
consistent sustainable policy being applied to the allocation of development across the
three Key Service Centres.
The basic principal of providing outlets such as supermarkets in the three Service Centres
is to provide a service to the community and to limit motor vehicle travel. Its obvious
that were we have least development we have (in Milnthorpe and Kirkby Lonsdale)
the largest supermarket capacity. Similarly in Grange were there is the largest
population centre (even now) and the largest development programme we have the
smaUest supermarket capacity. This actually contradicts the Core Strategy criteria.
As the development proposals for Grange are on the West of the town (described as
east in the Gillespie report) on a high elevation, the objective of limiting motor
vehicle travel will not be achieved. It will still be considered more convenient to load
a car with shopping and drive from door to door rather than use public transport or
to negotiate the steep gradients on foot or by bicycle. The topography and gradients
within the town are an important factor to consider in line with Policies T4, T5 and
T13, this has been totally ignored by SLDC. The disregard for this important
consideration makes the plan non cohesive and ultimately unsound when viewed in
relation to the National Planning Guidelines, there is a considerable lack of detailed
information on the total deliverability package with many key components to
successful delivery aspirational. This plan is therefore unsound

YES, I wish to participate at the oral examination

To ensure all our concerns are addressed by the decision makers

Please notify me

I have read the guidance notes

1.9

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.

2. The Consultation Process
Throughout the consultation process the Council and its officers have not answered or ,
been unable to answer pertinent questions on the development allocations for the area.
The standard answer has been we note your comments, this has not resulted in any
meaningful dialogue with communities. In the case of Grange over Sands despite
representation made by residents and the Town Council nothing has changed from its
inception. The District Council have when confronted with any fact that is not
complimentary to their current plan tended to full back on "if we do not have a plan
developers will build were they want and win on appeal if we turn down applications".
Despite the Town Council and residents agreeing a plan must be formulated to meet the
communities needs for a sustainable economic future, there has never been an alternative
discussed. A more appropriate plan involving the Town Council and residents would
satisfY local needs and stand scrutiny at appeal. The only sensible way forward is to have
community involvement using the Core Strategy as the principal guiding document.
Throughout this entire process there has never been any constructive consultation on the , .
LDF proposals. All meetings with SLDC have taken the form of presentation. Despite '
many concerns being raised about the document, we have never received any answers or
reassurances from Council Officers or Councillors. When residents have requested that
SLDC Officers and Councillors meet with the Town Council to resolve the outstanding
issues, this has occurred, but at the insistence of SLDC the meeting was classed as
informal with no official minutes, no justification or change in the proposed development
for the town. Furthermore an application by the Town Council to become a Local
Planning Group in order to allocate development within the town to ensure a sustainable
economic future for Grange was rejected. SLDC by their actions have shown that Public
Consultation was in reality presentation and the LDF will proceed, as originally conceived.
In order to justifY this to the 98% of the respondents across the district who objected,
sections of the core strategy document relating to green open spaces and infrastructure
have become less specific and more generic with balance in favour of developers and a
justification of the current proposals . Even minor alterations to the Core Strategy at this
late stage is totally unacceptable and undemocratic. This is effectively altering the
previously accepted criteria in order to justifY the councils intransigent position without
consultation. I would now refer to page 36 of the Land Allocation DPD Consultation
Statement entitled Key Service Centres Grange over Sands in which it says.
Few people supported any of the suggested housing site options, although several sites did receive some support, in particular the sites involved in the Berners proposals.
Many comments expressed concerns about the overall amount of development proposed
for Grange, in light of infrastructure constraints (highways infrastructure in particular), the
services, facilities and jobs available in Grange, the area's popularity as a tourism
destination and the wider environmental capacity of the area to sustainably accommodate
additional development on this scale, including with regards to wildlife, settlement
character and surface water flood risk.
Many people questioned the need for any additional development in Grange other than for
affordable housing. The Parish Council reiterated many of the concerns raised by
residents.
Why then has SLDC continued with the current plan in light of these comments and "feed
back". This is another example of poor consultation and the imposition of a plan on the
community that finds it unacceptable in its present form. I would now make comment on
the time allowed by SLDC for final submission on the Local Development Framework.
This has been kept to the absolute minimum of six weeks, included in this time is the
Easter Holidays, effectively reducing the time for residents to make representations. This
becomes even more relevant when one considers access to all the relevant information
located in libraries and on their web site. The amount of information cannot be fully
considered by those who are in full time employment and/ or do not have access or the
skills to use the councils web site. The minimum six weeks is not acceptable in this case,
the time allocated should have been extended to the maximum of twelve weeks given the
amount of documentation involved.
It seems rather ironic that SLDC have consulted with Developers and Estate Agents to
seek their views on the development proposals and have by and large accommodated them
whilst, the views of residents have been "noted" with no significant changes. It therefore
suggests that the "prime movers" for the acceptance of the allocation are the commercial
companies who will most benefit from the proposals. One significant change as a result of
this is that there will be no local occupancy clauses attached to the proposed new homes in
Grange over Sands.

YES, I wish to participate at the oral examination

To ensure all our concerns are addressed by the decision makers

Please notify me

I have read the guidance notes

0.0 Whole Document

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.

3. Consultants Recommendations to the Council
SLDC have over this plan period (since its inception) employed a number of consultants to
prepare plans and make recommendations on how to proceed with a Local Development
Framework Plan. I list below the Consultants concerned, the date of their reports and
recommendations that have been ignored by SLDC.
a. Douglas Wheeler Associates Regeneration Study 2007
Using the original Core Strategy Document Section 8 Green infrastructure and the
recommendations for exclusion of certain land parcels it is clear parts of the Douglas
Wheeler Report have been ignored. As an example of this land identified as R89,
north of Carter Road ( 45 dwellings) has been included for development despite the
DWA Regeneration Study concluding .. "that residential development of the Allithwaite
Road/Carter Road site is likely to be controversial because of the "Greenfield" nature o,f
the site" and "Do not include this site in their final list of preferred developments".
b. Gillespie Report dated December 2008
This report and plan acknowledges there are some parts of Grange "to the east of the
B5277 where the coastal plain is open and allows attractive views toward the estuary.
Development in this area would impact significantly on these views and no development
should be considered to the east of Grange over Sands. East Grange lies tight to the
existing railway line and estuary edge along the east shore of the estuary. There is no
room for development within this area. The majority of sites facing the water have been
occupied and fall within the existing development boundary. Only four sites were put
forward by the Gillespies Report North of Grange Road, Kents Bank Road/Cartmel
Road, Kents Bank (see plan) Some of the conclusions of the Gillespie Report compliment
the DWA Regeneration Study Report, unfortunately the outcome has remained the same,
land that is not included or recommended for exclusion now forms part of the final land
allocation document. When these points have been raised with SLDC the comment now
used is that "we use a number of consultants to help formulate the plan". There has never
been any justification for the transgressions from these reports. What is obvious is that if
consultants are continually employed, there will be eventually one who will support the
current LDF policy. Given the statement from SLDC planners this appears to be the case.
When SLDC was questioned, "Does the strategy draw on a landscape character
assessment and is this available?".
Answer
Landscape assessment undertaken as part ofthe LDF evidence base includes the
Gillespies Employment and Housing Land Search Study (Examination Library
reference HOUS5a- HOU5j), which utilised Technical Paper 5, as well as the
Countryside Commission's Countryside Character Area classifications, to assess the
potential of settlements to accommodate housing and employment development.
Although this work was undertaken primarily to identify specific sites, it has also
played an important role in helping to determine the capacity of settlements to
accommodate development in terms oflandscape character and sensitivity.
The above statement includes "it has also played an important role in helping to determine
the capacity of settlements to accommodate development in terms of landscape character
and sensitivity''. Without a supportive infrastructure plan, stating what is required, how
and when it will be delivered and by whom, this important supportive part of the plan is
purely speculative as it is not based on factual data, it is therefore unsound.

YES, I wish to participate at the oral examination

To ensure all our concerns are addressed by the decision makers

Please notify me

I have read the guidance notes

LA1.3 Housing Allocations - R89 GRANGE-OVER-SANDS NORTH OF CARTER 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.

Furthermore this particular site satisfies seven out of the ten criteria for exclusion in the Green Infrastructure Section 8 of the Core Strategy Document when only one is required
for consideration. At present the topsoil (on top of limestone) greatly reduces localised
flooding, with more impermeable surface the risk will increase. This is of some concern as
the topsoil does prevent localised flooding as this has only occurred with torrential down
pours twice in the last eight years. Because of the nature of the site, predominantly
limestone beneath the topsoil there is a requirement to have a geological survey
undertaken prior to approval, this needless to say is never mentioned or referred to despite
bringing this to the attention of SLDC Planners. It is worth noting at this stage the Water
Company, United Utilities will not permit "run off' water to be discharged into their
sewers. The assessment of this site for flooding and the localised off site flooding due to
run off using the Environment Agency's criteria, is impractical and too course to reflect
the actual and projected theoretical problems.
We have over the last eighteen months also drawn to the attention of SLDC Planners that
this parcel of land is an important migration route for deer moving from the fells to the
foreshore and back daily. I would now refer you to this sites biodiversity survey that
states there is over "21 key species". This parcel ofland has also been given an
allocation of category 3 status, yet despite this it has been included in phase one
development in order to fulfill what is an overprovision based upon the Popgroup survey
in the ARC4 report. By including R89 in the development there is a contradiction with its
allocated category rating. There can be no doubt that to include a Category 3 site in phase
one where there is up to a 20% over provision in the LDF is unjustifiable and unsound.

There can be no doubt using this one example, Greenfield sites are being proposed that
have significant importance to local communities and not just the surrounding properties
as stated in the ARC4 report. Indeed many residents and visitors value these green open
spaces as it offers a break in the continuous urban development. There is no doubt these
green breaks are what makes the town attractive to both residents and visitors. Its worth
noting there is no distinction between privately owned green open spaces and ones that are
open to the public, both have local amenity value.

YES, I wish to participate at the oral examination

To ensure all our concerns are addressed by the decision makers

Please notify me

I have read the guidance notes

LA1.10 Existing Green Infrastructure

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.

Its worth noting that the Core Strategy Document appears to have been amended in
certain sections since the original production of the LDF plan, certain contentious sections
have become more generic than specific, relating to the considerations for developing
green open spaces. The new format actually "relaxes" the more stringent criteria laid
down in the original Core Strategy Section 8. As the public consultation and comments
were based upon the original Core Strategy (from both residents and our Town Council)
one must question the amendments, the Councils motives and current policy in relation to
public consultation

YES, I wish to participate at the oral examination

To ensure all our concerns are addressed by the decision makers

Please notify me

I have read the guidance notes

LA1.3 Housing Allocations - All Grange-over-Sands 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.

Grange over Sands
The Core Strategy states that tourism, leisure and heritage sectors are to be developed in order to achieve a sustainable local economy. The employment this
generates is predominantly low in numbers and low in remuneration together with
"seasonal" only posts. With the development of these sectors there will inevitably be more
"visitors" and more motor vehicles. As the town is served by an inadequate "B" road the
B5277 , even with our present population the road and town suffers from congestion.
Therefore there is no sound reasoning to assume that these development proposals will not have a serious impact upon the town. Indeed when one assess the loading, with the
impact of development in Grange and the proposals for Allithwaite and Flookburgh there
can be no doubt this will cause serious traffic and environmental problems. What cannot
be stated about Grange with this current plan, quoting SLDC's own statement on
the town centre, that sites will have "minimal impact on the historic core of the
town". This is a serious consideration for Kirkby Lonsdale but not for Grange despite the
town having listed buildings and a reputation for its Edwardian/Victorian architecture,
again there is a lack of consistent application of the Core Strategy, that makes the plan in
relation to Grange unsound.
I list below some of the contributory factors to the overloading of the highways
infrastructure.
(1) The increase in resident motor vehicles. The South Lakeland LDF Sustainability
Appraisal Scoping Report states "Most households in South Lakeland own a car,
with 34.3% of households owning two or more compared to 29.5% in the UK
(2001). "Reasonable levels of bus services are provided for the towns and larger villages,
but there is less provision in rural areas, resulting in problems for some households in
accessing jobs, services and education".
This scenario is applicable to Grange as motor vehicle travel will continue as at present in
order to access well paid jobs outside the district and travelling at a time that's convenient
to the individual at a comparatively low cost.
(2) The location of the proposed Supennarket (at Batemans and not Hadwins as stated) at
a critical junction within the town.
(3) The catchment area for the supennarket (south lakes peninsula, possibly from an
8 miles radius. This being midway between the town and other established supennarkets).
( 4) The location of the development totally on the western side (noted as east in the
Gillespie Report) of the town, together with the cumulative total for Allithwaite and
Flookburgh.
(5) The development of tourism, leisure and heritage sectors is commendable. With this
one has to accept an increased motor vehicle use with a requirement for parking. The
LDF as it stands actually reduces the amount of car parking space available within the
town.
(6) The pinch points on the highway system in the town are the main tourist areas of The
Esplanade, Main St, Y ewbarrow Terrace and Kents Bank Road. These are the very points
that cannot be improved and are the areas likely to suffer with a deterioration in air quality
due to congestion. With reference to the Sustainability Appraisal Scoping Report page
29 in the Climate Change and Energy section it clearly states "Also relating to
climate change are waste generation and car journeys. South Lakeland has high
levels of waste production and car use higher than the UK average." This is not
conducive with the development of tourism.
We can liken this to the problem already highlighted in Kendal, a fact mentioned in
Section 11 of the Local Development Framework entitled "Accessibility and
Transport", it refers to the problems currently being experienced in the town and its
impact on the local economy. The text says;
"These prevailing travel patterns, coupled with high volumes of tourist traffic, have
resulted in congestion at peak times, (Grange has this most of the spring and
summer with current traffic levels and parking spaces) particularly around the
centre. As a consequence, shoppers can be discouraged from visiting the town centre
because of the difficulty and/or expense of parking". In the core strategy, concern is
expressed about the impact the private motor vehicle has on the town now, without the
inevitable increase stating that "access is poor, limited mainly to the B5277/8 looping
off the A590 to run through Grange, Allithwaite and Cark, the B6271 from Lindale
and minor roads north of Cartmel. Grange over Sands is a highly walkable and
compact town. However, it suffers from problems associated with the impact ofthe
private car on the built environment. For pedestrians, the Grange over Sands
environment is noticeably poor. In general terms, footpaths are natTow and there is
a strong sense that the car is the dominant feature on Kents Bank Road and Main
Street. Improving linlmges, infrastructure and the quality of the pedestrian
environment are key priorities. There is insufficient firm data on whether
this can or will be delivered".
The LAD PD. by placing all the emphasis on development in Grange ~,
South, ignores the Core Strategy's warning (CS5.32) that "given the
problem of town centre congestion in Grange at peak times significantly
higher traffic levels could well threaten the core economic activity of the
town, namely tourism". An increase in population, on the scale proposed
in the plan, would certainly result in at least 30% (including Allithwaite
and Flookburgh) more traffic which would challenge its ambition of
"promoting the vitality of Grange Town Centre and promoting tourism"
(LADPD4.2)
There is no detailed plan for deliverabilitv or funding of important infrastructure to
support the development proposals
Furthermore there has been concern expressed by SLDC about the deterioration in air
quality due to standing traffic in Kendal. However Kendal does have one advantage, the
existing highway infrastructure allows a good free flow of traffic around the town, (a bye
pass) this is something that Grange will not be able to achieve hence the inevitable increase
in congestion and the grave concern about the unsound development policy being imposed
bySLDC.
(7) With this current LDF, construction traffic will be passing through the town centre for
twelve years, servicing the Grange sites and those in Allithwaite and Flookburgh. This
scenario is not conducive with the development of tourism and will inevitably have a
negative impact for years with an unknown long term outcome. This is an economic
gamble with the long term sustainability of the town.
If we are now to consider the detail in the Core Strategy Document particularly in relation
to supportive infrastructure and its satisfactory deliverability.
Pavements and Cycleways
Considering the location of the proposed development for the town to the west (east
according to Gillespies) on a high elevation this will involve a steep walk or cycle back
from the town centre services. The severity of the gradient on Risedale Hill in places is
1 :6, this will mean its only suitable for relatively fit and is not conducive to those who are
not. Whilst the distance from the new sites to the town is not excessive, the topography
does not make walking or cycling an attractive proposition. The footpath is only on one
side of the road as the road its self is narrow along this section. The width of the path
makes it difficult for pedestrians to pass comfortably and safely, indeed we often see the
roadway being used when child buggies or small groups (two or more) pass each other. A
secondary problem relating to this path is that larger vehicles when passing in opposite
directions "overlap" the pavement in order to maintain speed and avoid stopping on this
steep gradient. This occurs even when pedestrians are using the pavement and has the
potential to be dangerous, this risk will increase with greater use. If we are to consider a
cycle route along this road into town one has also to consider the return journey and the
number of individuals who will want to negotiate Risedale on the return. To simply mark
either side of this narrow road with a cycle lane will be unacceptable given the width of
the highway and the risk due to increased motor vehicle use. Quite clearly the private
motor vehicle will still be the favoured method of transport for visits to the town centre
services purely for convenience.
The second route for pedestrian and cycle access to the town is making use of the existing
footpath that runs from the bottom ofKentsford Rd through to the Promenade. This route
starts with steep steps from Kentsford Rd ( not conducive with cycling) onto a section of
undulating narrow elevated footpath alongside and above the railway line. Firstly from the
proposed development areas you have to descend to the bottom ofKentsford Rd, again
this is not user friendly particularly (carrying shopping) when returning. The section of
footpath adjacent the railway line is not wide enough for two people to pass comfortably
so there is no possibility of bicycles using this safely. It is completely out of the question
given the latest design criteria that this section can be used safely without serious conflict
between the user groups. To simply make use of this to support new development is
unacceptable. There is no possibility of widening this section because on one side we have
garden walls, some of which are retaining and on the other the railway track which is at a
lower elevation. The third route would be Carter Rd down to Cart lane descending the hill
to "pick up " the now wider "railway route" onto the promenade. Carter Rd down to Cart
Lane is very steep, (in places steeper than 1 : 6) no more than a single track road without a
pavement. This is the most difficult and potentially dangerous route for vulnerable users
(pedestrians and cyclists) into town.
The final section on the route presents other problems because of the railway line and the
capital investment required to improve safety for all users. The access and egress from the
promenade at both ends involves a "blind" 90 deg turns under the track, this has the
potential for not only conflict between the different user groups but also the potential for
increasing the risk of accident particularly at the Cart Road end where the access and
egress from the promenade is extremely narrow and "blind". There is also a height
restriction, an adult on an upright commuting bike will find the railway "bridge" much to
low. If pedestrian and cycleways are a serious part of the LDF they must be constructed
to a safe acceptable standard, unfortunately this will be extremely difficult and probably
hard to justifY economically. There certaiuly has not been enough survey work carried out
on the feasibility of providing such supportive infrastructure. To state in the Core
Strategy that Grange already has cycleways in the town is not just misguided but
totally untrue. What is true is that the NCN does pass through the town from Meathop
via the golf club road through the town centre on Kents Bank Road before rejoining the
B5227 then turning right over the fells via Low Fell Gate. This route will become more
hazardous with the increased numbers of motor vehicles on narrow congested roads
within the town. There is no where in the Strategy Document that considers the impact of
topography on these proposals. Its worth noting this route currently does not ascend
Risedale Hill or Cart Lane and uses main roads through the town. This cannot be
considered as a route that will support the proposed development plans and promote
cycling to access services, given the current traffic volumes, it's inevitable increase and the
degree of safety that's acceptable to everyone the young and old a like.
I would refer you to the report of an accident in The Westmoreland Gazette dated
Thursday March 22, 2012, that occurred on Main Street in Grange over Sands.
Hit-and-run driver appeal
A hit and run driver who struck a woman in Grange over Sands is being sought by
police. The motorist failed to stop after being in coUision with the pedestrian, who
was walking along the pavement in Main Street, on Monday. Police say that a black
vehicle struck the woman's arm as it was traveUing toward the clock tower. Anyone
who witnessed the incident should contact PC Oliver at Ulverston police station on
non-emergency number 101.
This confirms the inadequate width of pavement and carriageway on the B5277.
This being the main route that serves Grange, Allithwaite and Flookburgh I would refer
once again to Section 11 of the LDF that states "access is poor, limited mainly to the
B5277 /8 looping of the A590 to run through Grange, Allithwaite and Cark (via
Flookburgh) and "For pedestrians, the Grange over Sands environment is
noticeably poor. In general terms, footpaths are narrow and there is a strong sense
that the car is the dominate feature on Kents Bank Road and Main Street".
With regard to the National Planning guidelines, there has been no assessment on "The effect of the development on highway safety and the free flow oftraffic".
Policv T4 states "all development and associated highway proposals should provide
for safe, direct, convenient and attractive means of movement on foot".
Policy T5 on cycling says "when assessing development and associated highway
proposals, safe, direct, convenient and attractive provision for cyclists will be sought
and many include (a) detailed traffic management and traffic calming schemes to
ensure both cyclist safety and priority movement".
Policy T13 on traffic management and traffic calming "seeks the safe and
convenient movement of pedestrians and cyclists as well as for people in cars".
This current plan does not address any of these issues. The development fails to
demonstrate that safe, convenient and attractive access on foot and by cycle can be
achieved for Grange over Sands. The proposal would not give sufficient
encouragement to walking and cycling as an alternative means of transport to the
car and raises serious safety concerns. Again SLDC make reassuring aspirational
statements on deliverability, but do not have the prerequisite plan to ensure that
deliverability is in line with policies T4- T5- Tl3. There has been no cumulative
assessment of the traffic, and its implications upon the settlement in terms of safety,
environment and long term economic sustainability. When this is assessed it is considered
that given the obvious limitations of the B5277 and the LADPD CSS .32 there will be
considerable problems within the town, a failure to recognise this fact is a prime example
of a flawed decision making process, being undertaken by the Council without any local
knowledge of the settlement.
This is why residents and the Town Council are key to a successful development plan for
the town and why the current policy of justification at all costs with generic statements is
unsound.
The proposed level of development will only serve to make the town less attractive to
tourists and visitors, which is contrary to long term interest and sustainable
viability, which is the stated objective of the Core Strategy. I would once again
refer you to page 10 LAPD CS5.32
A590 High Newton Bye Pass
The inclusion of this road in the plan as being beneficial to development in Grange is quite
ludicrous. To get to the A590 the narrow B5227 going through the town or the narrow
unclassified roads in the surrounding rural area will have to be used. I would refer you to
section 7 Accessibility and Transport mentioning the B5277 "looping off the A590". The
inclusion of the A590 is not based on any local rationale, indeed both Allithwaite and
Flookburgh development plans express concern about the capacity of their local roads to
accommodate development, without any mention of further potential loading on the A590.
There is no sound planning link between these concerns about local traffic and the
cumulative loading on the highways infrastructure in Grange over Sands.

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