2 responses from Mr John Terence Johnson (Individual)
1. Mr John Terence Johnson (Individual) : 4 May 2012 12:13:00
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
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
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.
Recommend removal of site R121M from any land allocations document in the belief that SLDC's DPD in unsound in respect of the site for reasons stated below:
I would like to question the soundness of South Lakeland District Council's Land Allocations
Development Plan Document in proposing land to the east of Castle Green Road (Site Reference
Rl21M) as being suitable for housing development in spite of substantial public opposition to the
proposal. Given that the visual impact of this high hillside agricultural site had previously been
considered by the Council to be worthy of County Landscape Designation and that the Council
fully acknowledges the site has complex flood issues due to substantial sheet water runoff and
underground watercourses which could see development severely impact on the recent Stock Beck
Flood Alleviation Scheme, it is very difficult to reconcile and justify the Council's criteria in
allocating the site for proposed development.
My understanding of "SOUNDNESS" of the DPD is that it be justified- founded on a robust and
credible evidence base, and yet right from the start of the Council's Land Allocations process Site
Rl21M was judged so negatively for development in SLDC's Fact File site notes that I fail to see
the justification for its continued inclusion as an allocated site. The flooding issue, together with
the substantial infrastructure issues to provide utility services, road access and deal with existing on
site bio-diversity issues which have all been acknowledged by the Council, have not been put to a
RISK/COST ASSESMENT to determine if proposed development of site Rl21M is viable,
sustainable, deliverable or just plain illogical. When and who will conduct a flood risk assessment.
I understand Cumbria County Council has recently become the Lead Local Flood Authority (LLFA)
in Cumbria. If Oak Tree Drive/ Rowan Crescent has an undersized and substandard culvert running
under them I would wish to know answers to the following as it has direct bearing on proposals for
SiteR121M:
1) Why is the culvert inadequate?
2) Who is responsible?
3) Why did SLDC planning not pick up the problem at the planning stage of these
developments?
4) Did the inadequate culvert contribute to the 1999 flooding of Lowther Park I Silverdale
Drive area- we locals remember seeing floodwaters. bursting through garden walls onto
Castle Green Road
5) Does it then really make sense to allow further development behind Oak Tree Road (site
Rl21M) where drainage waters would run into Stockbeck? All other eastern hillside land
draining into the Stock Beck Flood Alleviation Scheme have for good reason been removed
from SLDCs' Land Allocations so why not Site Rl21M?
The fact is that Site Rl21M was never robustly, physically examined at an early stage of the LDFLAND
ALLOCATIONS process to establish or contest sound local knowledge of the site provided
by well meaning individuals with yean of day to day knowledge of the vagaries of the site which is
known to act like an enormous sponge to absorb large amounts of rainfall and therefore assist the
slowdown of its progress to the lower level reaches of the town. Much of the
information/observations provided under the public consultation exercise was disregarded as
objections from residents who are affected by the proposed developments making community
involvement and engagement seem meaningless. The Council requested participation in its Land
Allocations exercise from the local Community/Stakeholders as required of them, but then
seemingly blinded by their desire to achieve targeted housing figures throughout the district, have
chosen to ignore all its own previous sound planning briefs! decisions. regarding Site R 121M,
Kendal Town Council's view that the site should not be developed, reports from Friends of the Lake
District that Rl21M should not be developed and the many residents whose alternative proposals
were just ignored. I attended consultation 'drop in' days with SLDC planning staff in attendance but
attempts to discuss objectively, concerns regarding land allocations were fended off with the
answer "We need to come up with the numbers" - at all cost it would appear!
I understand the present Government is on record as saying it is opposed to top-down targets and
has axed Labour's regional spatial strategies which set development plans for English regions over
15 to 20 years, preferring 'local neighbourhood' input on development strategy.
I fully understand the need to plan for the Town's housing needs but cannot condone the Council's
knee-jerk grab for highly sensitive hillside landscape such as SiteR121M to the ultimate detriment
of the Town's unique quality when other alternative brownfield sites have been proved to be
available and I understood were always a preferred option if available. I appreciate brownfield sites
will not accommodate all the Town's future housing needs but I am being site specific when I state
I am unable to believe a robust and credible evidence base has been established to justify Site
Rl21M 's inclusion for development to provide 60 dwellings, when it is clearly not the most
appropriate strategy to pursue when considered against reasonable alternatives - 60 dwellings
provided by the "Cock & Dolphin" and DSG redevelopment in Kirkland, not to mention the 90+
properties proposed for the redundant Kendal Auction Mart premises, clearly support my view that
much needed viable/sustainable affordable housing can be provided by the continued availability of
brownfield sites within the district. SLDC continue to maintain that Kendal's housing needs can
only be accommodated on green field sites!
The DPD cannot be considered sound as regards Site Rl21M when words like 'may include
railway drainage' are used (how can reliable decisions be taken on unsubstantiated information) and
'Given the constraint& on the site, it is e:.timated that the site could accommodate around 60
dwellings' (no evidence to suggest SLDC provided itself with sufficient detailed, cos ted and
co-ordinated information to support this statement).
I apologize for the somewhat protracted content of my letter and feel a visit to Site Rl21M by
yourself followed by discussion on its merits over a cup of tea may well have been a more
productive process. Nevertheless. I trust you will give my comments (representation) due
consideration in the hope you may agree that SLDC's DPD in regard to Site Rl21M is unsound and
the site should be removed from any Land Allocations Document as other less sensitive more viable
alternatives exist.
I confirm I have read the DPC Representation Guidance Notes.
I do not wish to participate at the oral examination but have given SOLEK authorisation to represent me at the oral stage of independent evaluation
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
2. Mr John Terence Johnson (Individual) : 4 May 2012 12:14:00
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
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
The DPD is not consistent with national policy.
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.
Recommend removal of site R121M from any land allocations document in the belief that SLDC's DPD in unsound in respect of the site for reasons stated below:
I would like to question the soundness of South Lakeland District Council's Land Allocations
Development Plan Document in proposing land to the east of Castle Green Road (Site Reference
Rl21M) as being suitable for housing development in spite of substantial public opposition to the
proposal. Given that the visual impact of this high hillside agricultural site had previously been
considered by the Council to be worthy of County Landscape Designation and that the Council
fully acknowledges the site has complex flood issues due to substantial sheet water runoff and
underground watercourses which could see development severely impact on the recent Stock Beck
Flood Alleviation Scheme, it is very difficult to reconcile and justify the Council's criteria in
allocating the site for proposed development.
My understanding of "SOUNDNESS" of the DPD is that it be justified- founded on a robust and
credible evidence base, and yet right from the start of the Council's Land Allocations process Site
Rl21M was judged so negatively for development in SLDC's Fact File site notes that I fail to see
the justification for its continued inclusion as an allocated site. The flooding issue, together with
the substantial infrastructure issues to provide utility services, road access and deal with existing on
site bio-diversity issues which have all been acknowledged by the Council, have not been put to a
RISK/COST ASSESMENT to determine if proposed development of site Rl21M is viable,
sustainable, deliverable or just plain illogical. When and who will conduct a flood risk assessment.
I understand Cumbria County Council has recently become the Lead Local Flood Authority (LLFA)
in Cumbria. If Oak Tree Drive/ Rowan Crescent has an undersized and substandard culvert running
under them I would wish to know answers to the following as it has direct bearing on proposals for
SiteR121M:
1) Why is the culvert inadequate?
2) Who is responsible?
3) Why did SLDC planning not pick up the problem at the planning stage of these
developments?
4) Did the inadequate culvert contribute to the 1999 flooding of Lowther Park I Silverdale
Drive area- we locals remember seeing floodwaters. bursting through garden walls onto
Castle Green Road
5) Does it then really make sense to allow further development behind Oak Tree Road (site
Rl21M) where drainage waters would run into Stockbeck? All other eastern hillside land
draining into the Stock Beck Flood Alleviation Scheme have for good reason been removed
from SLDCs' Land Allocations so why not Site Rl21M?
The fact is that Site Rl21M was never robustly, physically examined at an early stage of the LDFLAND
ALLOCATIONS process to establish or contest sound local knowledge of the site provided
by well meaning individuals with yean of day to day knowledge of the vagaries of the site which is
known to act like an enormous sponge to absorb large amounts of rainfall and therefore assist the
slowdown of its progress to the lower level reaches of the town. Much of the
information/observations provided under the public consultation exercise was disregarded as
objections from residents who are affected by the proposed developments making community
involvement and engagement seem meaningless. The Council requested participation in its Land
Allocations exercise from the local Community/Stakeholders as required of them, but then
seemingly blinded by their desire to achieve targeted housing figures throughout the district, have
chosen to ignore all its own previous sound planning briefs! decisions. regarding Site R 121M,
Kendal Town Council's view that the site should not be developed, reports from Friends of the Lake
District that Rl21M should not be developed and the many residents whose alternative proposals
were just ignored. I attended consultation 'drop in' days with SLDC planning staff in attendance but
attempts to discuss objectively, concerns regarding land allocations were fended off with the
answer "We need to come up with the numbers" - at all cost it would appear!
I understand the present Government is on record as saying it is opposed to top-down targets and
has axed Labour's regional spatial strategies which set development plans for English regions over
15 to 20 years, preferring 'local neighbourhood' input on development strategy.
I fully understand the need to plan for the Town's housing needs but cannot condone the Council's
knee-jerk grab for highly sensitive hillside landscape such as SiteR121M to the ultimate detriment
of the Town's unique quality when other alternative brownfield sites have been proved to be
available and I understood were always a preferred option if available. I appreciate brownfield sites
will not accommodate all the Town's future housing needs but I am being site specific when I state
I am unable to believe a robust and credible evidence base has been established to justify Site
Rl21M 's inclusion for development to provide 60 dwellings, when it is clearly not the most
appropriate strategy to pursue when considered against reasonable alternatives - 60 dwellings
provided by the "Cock & Dolphin" and DSG redevelopment in Kirkland, not to mention the 90+
properties proposed for the redundant Kendal Auction Mart premises, clearly support my view that
much needed viable/sustainable affordable housing can be provided by the continued availability of
brownfield sites within the district. SLDC continue to maintain that Kendal's housing needs can
only be accommodated on green field sites!
The DPD cannot be considered sound as regards Site Rl21M when words like 'may include
railway drainage' are used (how can reliable decisions be taken on unsubstantiated information) and
'Given the constraint& on the site, it is e:.timated that the site could accommodate around 60
dwellings' (no evidence to suggest SLDC provided itself with sufficient detailed, cos ted and
co-ordinated information to support this statement).
I apologize for the somewhat protracted content of my letter and feel a visit to Site Rl21M by
yourself followed by discussion on its merits over a cup of tea may well have been a more
productive process. Nevertheless. I trust you will give my comments (representation) due
consideration in the hope you may agree that SLDC's DPD in regard to Site Rl21M is unsound and
the site should be removed from any Land Allocations Document as other less sensitive more viable
alternatives exist.
I confirm I have read the DPC Representation Guidance Notes.
I do not wish to participate at the oral examination but have given SOLEK authorisation to represent me at the oral stage of independent evaluation
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
