Response from Mr Alan Winstanley (Individual)
1. Mr Alan Winstanley (Individual) : 15 Apr 2012 10:59:00
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 - R129M KENDAL SOUTH OF UNDERBARROW ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
1.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
I don't have a single word of support.
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.
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.
CHANGES WHICH SHOULD BE MADE
1. The evidence base should be re-evaluated, mistakes being corrected and omissions rectified.
2. The DPD should not be approved until there is a credible infrastructure plan in place.
3. No site should be included until it is shown to be deliverable on transport grounds.
4. An alternative strategy (the "hub and spoke" approach) should be investigated.
REASONS FOR THE SUGGESTED CHANGES
(A) General
There is, without doubt, a need for affordable housing in South Lakeland. However, in order to make things financially attractive for landowners and developers, the DPD advocates that there is a need to build many more houses than are needed or justified so that a proportion of them can be offered as "affordable." Large areas of open countryside, much of it of high landscape value, will be developed in order to provide a relatively small number of affordable houses which could probably be accommodated in more suitable locations.
Furthermore, the Local Planning Authority's assumption regarding population growth in South Lakeland far exceeds the prediction of the Office of National Statistics and appears to be a gross exaggeration.
(B) Evidence
Little, if any, regard has been paid to the views of local residents concerning R129M. Despite overwhelming opposition from local people the site was retained and R143 was added to it.
No regard appears to have been given to the concern of residents about increased traffic within residential areas. Furthermore, R129M and R143 are situated at the top of a long and steep incline, and the LPA has disregarded evidence about the effect of this incline, which will result in additional consumption of fuel, increased emissions and added noise.
The potential for damaging surface water run-off, due to the limestone bedrock underlying site R129M, has not been considered.
(C) Infrastructure
Developments of the magnitude proposed in various parts of Kendal may require infrastructure mitigation some distance away: and yet there is no credible plan for infrastructure. The LPA makes assumptions that "delivery partners" will provide essential infrastructure, but infrastructure can not be made fit for purpose piecemeal, simply by relying on developer-driven planning applications. For the scale of development proposed for Kendal there should be an infrastructure plan covering sewerage, flooding possibilities, traffic management, education and health.
(D) Transport
At first, the LPA engaged consultants W S Atkins to advise on traffic management in Kendal in the light of the proposed scale of development. More recently, they chose not to re-engage independent consultants, but instead sought advice from Cumbria County Council. The County Council adopted a totally different approach and predicted a much reduced traffic growth rate. (This subject is covered in considerable detail in the submission of the Kendal Town Council.)
In view of the totally conflicting findings of Atkins and the County Council it is essential that there should be an independent audit to ascertain which findings are most reliable.
(E) Alternative approaches
In 2008 the Taylor Review argued that "doughnut development" was the wrong approach for sustainable rural market towns. The Review argued that the "hub and spoke" model was best for sustainability and that it caused fewer problems with town centre infrastucture. The "hub and spoke" solution appears to have received no consideration, and neither has the use of brown field sites. Instead, the allocations appear to reflect purely the wishes of landowners and developers.
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
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