Local Development Framework Consultation

LA1.6 Strategic Employment Sites - E4M KENDAL LAND AT SCROGGS WOOD, MILNTHORPE 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.

Scroggs Wood is an important green field site at a key entrance to Kendal, and SLDC has previously said that it would only be released in exceptional circumstances. There have been significant objections from many residents and Friends of the Lake District to development at Scroggs Wood.
There is a sense of a missed opportunity, and with the DPD’s current wording, it is unclear how the vision of creating skilled jobs through inward investment will be achieved. Further, there has been no evidence presented which demonstrates that large scale strategic development at Scroggs Wood is deliverable

In comparison, no information has been submitted to demonstrate that development on site E4 would be acceptable in landscape and visual impact terms. In actual fact, the South Lakeland Employment and Housing Land Search Study (SLEHLSS) of March 2009 states that ‘Scroggs Wood forms a strong boundary to the town and development to the south of this would be highly visible and therefore should not be permitted’.
Further, page 118 of the Kendal Fact File acknowledges:
‘Site Visit: The site is a large Greenfield site prominent in views from the A6 and in wider views and located in a key gateway position as you enter Kendal from the south’
As such, the Council’s evidence base itself concludes that the Scroggs Wood site should not be developed for any use.
Sites E57, M7 and E4 are considered to have a similar negative impact on the built environment. It is true that the sites are in proximity to heritage assets. Of limited mention however is the fact that site E4 is close to Watercrook Roman Fort Scheduled Ancient Monument.
The impact of development on this important designation has not been considered. Until an Environmental Statement has been undertaken on the site, the Council will be unclear as to the effect of the development on the environment and indeed whether some or any development can be supported. Such deliverability uncertainty again militates against the site’s allocation.
We trust that this representation will be taken into account as part of the consultation process and we request to take part in the oral examination of the Land Allocation DPD.

YES, I wish to participate at the oral examination

LA1.6 Strategic Employment Site - Site Omission

Site reference - E57
Location - Near Junction 36 of M6 motorway
Relevant Policy LA1.6 - Strategic Employment 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.

We welcome the acknowledgment at paragraph 2.49 in the publication edition of the Land Allocation DPD that sites E57 and M7 have potential for strategic employment use.

With the allocation of sites E57 and M7 at Junction 36, SLDC has a deliverable alternative which will create the necessary step change in the local economy and for which there is market interest from inward investment. Large scale development at Junction 36 has been recently tested through an Environmental Statement and judged to be acceptable.
We are aware that the Core Strategy sets a sequential approach to site selection. There is however no suitable alternative sites for strategic employment development in South Lakeland. As such, SLDC should amend Policy LA1.6 to consider strategic employment development at Junction 36 as the preferred option.

Time & Tide submitted a layout plan and visualisation of the proposed employment site in September 2011. The buildings will be significantly smaller in scale than the mart building and the use of an innovative layout utilising the existing topography, significant amount of green space and landscape buffers will ensure that the development effectively blends into the surrounding landscape.
The visualisations demonstrate how the use of environmentally sympathetic techniques such as grass sedum roofs, cedar panelling and stone facing can effectively blend the development into the surrounding landscape.

Sites E57, M7 and E4 are considered to have a similar negative impact on the built environment. It is true that the sites are in proximity to heritage assets. Of limited mention however is the fact that site E4 is close to Watercrook Roman Fort Scheduled Ancient Monument.

YES, I wish to participate at the oral examination

LA1.6 Strategic Employment Site - Site Omission

Site reference - M7.
Location - near to Junction 36 of the M6 Motorway.
Relevant Policy - LA1.6 - Strategic Employment 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.

We welcome the acknowledgment at paragraph 2.49 in the publication edition of the Land Allocation DPD that sites E57 and M7 have potential for strategic employment use.

With the allocation of sites E57 and M7 at Junction 36, SLDC has a deliverable alternative which will create the necessary step change in the local economy and for which there is market interest from inward investment. Large scale development at Junction 36 has been recently tested through an Environmental Statement and judged to be acceptable.
We are aware that the Core Strategy sets a sequential approach to site selection. There is however no suitable alternative sites for strategic employment development in South Lakeland. As such, SLDC should amend Policy LA1.6 to consider strategic employment development at Junction 36 as the preferred option.

Time & Tide submitted a layout plan and visualisation of the proposed employment site in September 2011. The buildings will be significantly smaller in scale than the mart building and the use of an innovative layout utilising the existing topography, significant amount of green space and landscape buffers will ensure that the development effectively blends into the surrounding landscape.
The visualisations demonstrate how the use of environmentally sympathetic techniques such as grass sedum roofs, cedar panelling and stone facing can effectively blend the development into the surrounding landscape.

Sites E57, M7 and E4 are considered to have a similar negative impact on the built environment. It is true that the sites are in proximity to heritage assets. Of limited mention however is the fact that site E4 is close to Watercrook Roman Fort Scheduled Ancient Monument.

YES, I wish to participate at the oral examination

2.49

We welcome the acknowledgment at paragraph 2.49 in the publication edition of the Land Allocation DPD that sites E57 and M7 have potential for strategic employment use.

YES, I wish to participate at the oral examination

2.45

The DPD has not had regard to national policy and does not conform generally with the adopted Core Strategy and (until it is abolished) the Regional Spatial Strategy

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.

We are however concerned that the Site Allocation DPD is not based on policy in the adopted Core Strategy. As such, the DPD must be considered unsound.
The Council acknowledge that there is a shortage of employment land. Page 52 of the report to SLDC Members dated 18 January 2012, states ‘consultation responses and liaison with the Council’s economic development service continues to suggest that there is an ongoing shortage of employment land to meet needs for inward investment, to diversify the economic base and to meet the needs of local firms and start-ups.’
Accordingly, the Core Strategy at Policy CS7.2 defines the sectoral split to help meet this shortage. 15ha should be allocated for Strategic Employment Sites, 30ha for Local Employment Sites and 15ha for Business / Science Parks.
A definition of the types of employment land is provided on page 89 of the Core Strategy. A strategic employment site is aimed at larger businesses, with the intention of meeting the needs of inward investors. In comparison, Core Strategy paragraph 8.14 states ‘the large amount of local employment sites would satisfy the local need to provide expansion sites and to encourage local businesses to retain in the area’.
We are therefore unclear why the Land Allocations DPD now states that strategic employment sites should allow for relocation and development of existing firms (paragraph 2.45). Clearly the Core Strategy states that Local Employment Sites will serve this purpose. The DPD is therefore unsound as it does not accord with the Core Strategy.

YES, I wish to participate at the oral examination

LA1.6 Strategic Employment 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.

Furthermore, draft Policy LA1.6 states that a wide range of employment uses will be acceptable at site E4 ‘Scroggs Wood’ (including B8 warehousing). It is therefore targeted at local businesses rather than strategic employment.
Rather than offering a step change in the local economy and providing many skilled new jobs, there is a risk that Scroggs Wood could instead be occupied by existing businesses who wish to relocate away from the highway constraints of Kendal Town Centre, or be occupied by a few large warehousing units offering a small number of low paid jobs.

There is a sense of a missed opportunity and with the DPD's current wording, it is unclear how the vision of creating skilled jobs through inward investment will be achieved.

YES, I wish to participate at the oral examination

1.12

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.

We are disappointed to see that the evidence base still includes inaccuracies. Appendix 1 of the submitted Sustainability Appraisal (SA) scores each site against a set of criteria. Inaccuracies are twofold. Firstly, the SA still provides inaccurate information in terms of availability of services to sites E57 and M7. Scores given to site E4 are also inaccurate. Secondly, there are inconsistencies when considering different sites with similar characteristics.
Inaccurate appraisal scores
Representations from Indigo Planning dated 15 April 2011 clarified that sites E57 and M7 could be adequately serviced by water supply. Discussions with United Utilities have established that it would cost no more than £100,000 to provide mains water to the site. A deliverable wastewater solution has been established at Moss End Business Village and at the auction mart under construction. We are unclear why therefore the site has been marked down due to ‘limited water and no wastewater apparatus to serve the development.’
Site E4 is assessed as being with Flood Zone 1 for fluvial flooding. This is incorrect. The South Lakeland SFRA 2007 clearly identifies a section of the site as lying within Flood Zone 3a given its proximity to the River Kent. As such, the evidence base is flawed.

Inconsistences between sites
The SA has inconsistencies between sites when considering water supply, landscape character and the built environment. United Utilities have commented that service provision to site E4 would be problematic and costly. Accordingly, the SA gives a corresponding negative score. There is however no distinction between this and the score given to sites E57 and M7 which can be adequately serviced.
Further, the SA marks site E57 has having a greater negative impact on landscape character than site E4. The SA surmises that development on site E57 has the potential for a significant negative effect on landscape character whereas development on site E4 will only have the potential for moderate negative effect. These scores are not based on any factual information submitted by Indigo to date (which has been tested through the planning process) but merely ‘maps, local knowledge and aerial photographs’ (page 6 of Appendix 1 of the SA).
These comments run at odds with the detailed landscape and visual impact assessment undertaken and accepted as part of the Environmental Statement accompanying the application for the adjacent auction mart.

SLDC, through the advice of an independent consultant, considered that the development (which comprises a large commercial building) would not change the landscape character of the area. The local drumlin landscape is of medium scale and would ‘hold’ the development.
Any visual impact of the development was also considered acceptable when
taking into account the mitigation measures proposed in the landscaping scheme.
The mart building itself extends to 6,740 sqm and is therefore a significant structure. It has been demonstrated that the visual impact of a building of this scale can be adequately mitigated in the location.
Time & Tide submitted a layout plan and visualisation of the proposed employment site in September 2011. The buildings will be significantly smaller in scale than the mart building and the use of an innovative layout utilising the existing topography, significant amount of green space and landscape buffers will ensure that the development effectively blends into the surrounding landscape.
The visualisations demonstrate how the use of environmentally sympathetic techniques such as grass sedum roofs, cedar panelling and stone facing can effectively blend the development into the surrounding landscape.
In comparison, no information has been submitted to demonstrate that development on site E4 would be acceptable in landscape and visual impact terms. In actual fact, the South Lakeland Employment and Housing Land Search Study (SLEHLSS) of March 2009 states that ‘Scroggs Wood forms a strong boundary to the town and development to the south of this would be highly visible and therefore should not be permitted’.
Further, page 118 of the Kendal Fact File acknowledges:
‘Site Visit: The site is a large Greenfield site prominent in views from the A6 and in wider views and located in a key gateway position as you enter Kendal from the south’
As such, the Council’s evidence base itself concludes that the Scroggs Wood site should not be developed for any use.
Sites E57, M7 and E4 are considered to have a similar negative impact on the built environment. It is true that the sites are in proximity to heritage assets. Of limited mention however is the fact that site E4 is close to Watercrook Roman Fort Scheduled Ancient Monument.
The impact of development on this important designation has not been considered. Until an Environmental Statement has been undertaken on the site, the Council will be unclear as to the effect of the development on the environment and indeed whether some or any development can be supported. Such deliverability uncertainty again militates against the site’s allocation.

YES, I wish to participate at the oral examination