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Local Development Framework Consultation

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Responses to Land Allocations - Publication Stage
Response from Mr David Bowler (Individual)
1. Mr David Bowler (Individual)   :   16 Apr 2012 21:28:00
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 - RN169M+ RN299# KENDAL WEST OF HIGH SPARROWMIRE
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.
The whole of the DPD is predicated on the fact that Kendal ‘requires’ in excess of 2,000 new homes in the forecast period, yet there has been little published detailed analysis of where these figures come from and whether they are truly still justified.

The development planned at sites RN169M and RN299# will erode the green gap between Kendal and Burneside and although there will still be a significant geographical separation between the areas of habitation there is no guarantee that it will not be further eroded with future development. The fact that the sites lie outside the present development boundary is a concern, as a stated part of the process underway is to establish new boundaries for development. This clearly has no value if current boundaries can be ignored with ease and therefore there is little value in assessing what the new boundaries should be.

Much is made of that fact that any development is sustainable, without really defining the interpretation of sustainability, but with the simple fact that valuable land used for the production of food is to be used for more housing means that this development cannot be seen as sustainable.

Great emphasis has been placed on providing affordable homes on these sites (and others), this is unlikely materialise as the costs associated with infrastructure, in particular sewers, will mean that the developer will need to maximise returns, and therefore as with elsewhere in Kendal this will mean ‘affordable’ properties are listed at 80-85% of market value, which with the distorted house prices the area suffers from, does not make them affordable to the young families and others in need of housing in the area.

With reference to utilities and infrastructure, United Utilities have stated that the investment for sewerage pipes to these sites is unlikely to happen in the timeframe of the DPD, which would make consideration of these sites irrelevant. Even if the infrastructure was to be provided, the wider issue of whether the current treatment plant can cope with expansion in the town has been raised as a genuine concern.

The northwest area of the proposed development lies within a drumlin field and would therefore be highly visible and intrusive to many points in and around Kendal, reports on site suitability prepared for SLDC actually highlight that development on the crest of the drumlin would be detrimental.

Presumably at a significant cost, a traffic report was commission from Atkins to analyse Kendal’s traffic problems. This highlighted that various junctions on Windermere Road were operating at or above full capacity in the forecast period of the report. This report did not include the proposed developments at sites RN169M and RN299 #, from which it must be concluded that the traffic problems predicted, would be further exacerbated.

Finally, while it may be claimed that the development proposals have been open to consultation, these sites in particular have been subject to significant changes at each round of consultation. The numbering of the site(s) has changed throughout the process as has the intended use and size of the site. Initially proposed for a small employment development, which then changed to a modest residential development, it is now a site for which 130-150 homes are planned. It is very difficult for members of the public to provide comments on proposals which change so dramatically in their nature; it is paying lip-service to consultation.
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.
These sites have been a classic example of 'drift', starting with a proposal for a modest employment development which has morphed into a large-scale residential development, which is outside of the development limits of the town. It would devalue the visual impact of one of the major routes into Kendal and would erode the valuable green gap between communities.
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