Local Development Framework Consultation

I have read the guidance notes

LA1.3 Housing Allocations - R151M-mod MILNTHORPE SOUTH OF MILNTHORPE

Yes

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 consistent with national policy.

Representation is made on behalf of myself and a number of other local residents/families who
previously authorised me to speak on their behalf at the SLDC Special Council meeting held on
18th January 2012 (copy of evidence attached containing 10 addresses and signatures). As a result
of the Council's approval to the LDF, which ignored our protests, the same group of people have
given me an extended mandate to represent them through public consultation and any subsequent examination by the Inspector.
Representation is made with regard to the "Soundness" of the DPD in the parts set out below, and I confirm that I have read the Guidance Notes for Making A Representation.

1.0 Development of Site,.R151M South of Milnthorpe is considered inappropriate, lacking
in justification, and inconsistent with the objectives of the Core Strategy
The approved DPD prop'osal is to build 70 dwellings on this site in 3 phases.
The frontal portion of the site sits directly on the A6, one of the prime routes into Cumbria
and the National Park, and currently provides a highly visible and historic boundary to the
village. Many of the properties along this definitive boundary are at least one hundred years
old, and a fine old Edwardian house with a turret sits in the centre. On the other (western)
side of the A6, the village edge is considerably enhanced by a fine stretch of the River Bela
and Dallam Park, part of the Arnside Silverdale Area of Outstanding Natural Beauty (AONB)
and an area of land that must be treated with extreme care and sensitivity.
The entire edge provides a fusion of views that may be described in a number of ways ranging
from beautiful to pleasing and comfortable, and what is important to note is that they stand in
the public domain and are available to all who enter and leave the village, the hub of which
sits around an old market square with a charter for a public market dating back to 1334. The
village is defined as a Key Service Centre for the region and is the first significant settlement
seen by visitors entering Cumbria.
As a further preamble I now draw upon several references taken from the Core Strategy
adopted by the SLDC on 20th October 2010:
• Section 2 CS1.1 Sustainable Development Principles (page 15) - 3 "There is a need to take
account of and enhance landscape character and features of those buildings and sites that
make a positive contribution to the special architectural or historic interest of the area ... "
• Section 2 CS1.1 Sustainable Development Principles (page 15) - 5 "It must be ensured
that a high quality, localised and appropriate design is incorporated into all developments
to retain distinctive character/sense of place and enhance the existing built environment."
• Section 6 Key issues .. 6.26 (page 69) "The area strategy aims to address the following
challenges: Maintaining and enhancing the natural, historic and other distinctive features
that contribute to the character of the local landscape and settlements ... and Recognising
the importance of the special qualities of the environment associated with the .. AONB and
its setting and character."

These references are but a few of many that have been drafted in a manner to recognise and sympathetically control the style and location of new development. Totally in keeping the DPD then contains the following:
• Section 3 Kendal and Surrounding Area (page 46) 3.2 "Factors influencing the location of
development in this area include: The Quality of the Built Heritage - long established
towns and villages with well defined character and form including ... Milnthorpe ... "
• Section 3 Kendal and Surrounding Area (page 76) 3.61 "Key local factors influencing the
location of new development in Milnthorpe are: Respecting the setting of the AONB and
Dallam Park in particular" and "Maintaining and enhancing the quality of the surrounding
landscape and the need to achieve urban edges which maintain or enhance the character
and appearance of the town when viewed from key approaches such as the A6 ... "
Furthermore, whilst the thrust of 3.65 is not in favour of protecting Site R151M from
development, it does confirm that:
• "Key issues for this site include mitigating landscape impacts, particularly around the
frontage of the site with the A6 where it forms the entry point to the village and
secondly lies opposite very high quality landscape in the form of Dallam Park in the
Arnside Silverdale AONB.
In addition, Policy IA2.11 Land South of Milnthorpe - states that development requirements
should:
• "make provision for ... a substantial, high quality landscaped frontage to the A6"
From all this, it is evident that the SLDC recognises both the historic and environmental
importance of this site and the strong need to mitigate the (detrimental) impact of their
approval to develop it. However, by applying the rational objectives and intended controls of
the Core and DPD strategy, I am of the strong opinion that with particular reference to the
criterion cited above, development of the site cannot be soundly justified. It is my sincere
view that the choice of this site reflects its convenience and availability to the SLDC as
opposed to its total suitability. In essence:
1. Development would not "maintain or enhance" the historic village boundary, but would
screen and cause visual harm to a pleasing elevation that has stood intact for over one
hundred years, and is appreciated by all who enter and leave the village along a key
approach to the South Lakes and the National Park.
2. Development would obscure an important part of the village's intrinsic and "well defined
character and form"
3. The challenge to "maintain or enhance ... distinctive features that contribute to the
character of the local landscape and settlements" has not been sympathetically recognised
or pursued.
4. High quality landscaping is merely a cosmetic attempt to conceal the true reality, the loss
of another slice of local character.
5. New housing including a proportion of the affordable type would be totally incompatible
with either the natural or the existing built environment; i.e. it would neither respect the
immediate proximity and setting of the adjacent AONB or the existing characterful and
mature village edge.
6. Removing a clear view of this (arguably) single prime boundary would further dilute the
historic nature of the village and a sense of place for its residents. I represent a number of
people who are at least second generation residents of Milnthorpe and they fully endorse
these feelings.
7. Approval would set a potentially harmful precedent for future ribbon development along
the same valley side facing the Arnside Silverdale AONB, representing further
encroachment on open land.
8. Development would result in the loss of high quality grazing land for both sheep and cattle that has been farmed for centuries, and I understan that the tenant farmer, not the
landowner, would be most unhappy about its loss!
9. The conclusion quoted in the Settlement Fact Files that "high quality development would
not have a detrimental impact on the AONB" is an opinion shared only by those with a
determined interest in developing the site. In my view it is subjective and unrepresentative
of the public's view point. The SLDC is bent on developing this site whatever objections
may be raised.

3.0 The DPD is not effective or deliverable, citing examples in Milnthorpe
Even if we agreed with the proposed development of Site R151M, we believe it necessary to
flag a case of flawed timing. Within the SLDC's Consultation Statement it is confirmed by
United Utilities (UU) "that improvements are required to the Strand Pumping Station before
development can proceed" or in slightly more specific terms " ... investment and modelling is
required before any development could take place." In this respect it is understand that UU will
apply for funds in 2014 for the budget period 2015 - 2020, and thereafter, if approved, a set
of programme priorities will be established.
By comparison, the DPD sets a clear target of 20 dwellings to be completed on this site in
Phase 1 by 2017 (71 dwellings in total for all Milnthorpe sites) regardless of the fact that even
assuming funding is obtained, UU may not even have started their infrastructure upgrade by
this date.
The same absence of proper detailed planning is reflected in the educational sector, and I am
not aware of any Cumbria County Council plans to accommodate the additional school places
that will certainly be required in Milnthorpe.
Taking a broader view, the DPD is required to be deliverable across the entire region and yet
the general consensus amongst those who have read the documentation in some detail is that
infrastructure planning remains, at best, a "position statement" that outlines the needs and
challenges without the certainty or glue of any coordinated commitments from delivery
partners."
Therefore, my conclusion on this point is that the DPD is not effective, sound infrastructure
delivery planning is absent and cannot be shown on any plausible critical path for development of sites in Milnthorpe. To enter into such a scale of high profile development on a presumption
that "everything will be fine on the night" reflects "scary" unsound principles.

Conclusion
In general I consider many aspects of the DPD to be unsound, but my particular concerns are
centred on Milnthorpe village and its southern edge where I live. I further endorse the separate
"Green Spaces" Representations on the soundness of the DPD.
Having devoted much time and energy to opposing the development of Site R151M including
representation at the Special Council Meeting on behalf of a South Milnthorpe Residents Group, I
consider it appropriate for me to complete my opposition by participating in an oral examination
with the planning inspector. I now respectfully request such an opportunity

YES, I wish to participate at the oral examination

Having devoted much time and energy to opposing the development of Site R151M including
representation at the Special Council Meeting on behalf of a South Milnthorpe Residents Group, I
consider it appropriate for me to complete my opposition by participating in an oral examination
with the planning inspector. I now respectfully request such an opportunity.

Please notify me

I have read the guidance notes

LA1.3 Housing Allocations - All Milnthorpe 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 consistent with national policy.

Representation is made on behalf of myself and a number of other local residents/families who
previously authorised me to speak on their behalf at the SLDC Special Council meeting held on
18th January 2012 (copy of evidence attached containing 10 addresses and signatures). As a result
of the Council's approval to the LDF, which ignored our protests, the same group of people have
given me an extended mandate to represent them through public consultation and any subsequent
examination by the Inspector.


2.0 The continuing development of Milnthorpe village due to its designation as a Key
Service Centre cannot be "indefinitely" justified
Further comment is added here in respect of Milnthorpe being designated as a Key Service
Centre, and I wish to reiterate objections cited by a senior member of the community within
The Planning Inspectorate's Report of 1996 under the head "South Lakeland Local Plan 2006"
page 6. The extracts I quote are:
• "No account is taken of the need to maintain the local character and distinctive sense
of locality when promoting Mi/nthorpe for development," and
• "... there has been a failure to protect Milnthorpe from a destabilising /eve/ of
development over a very long period and a halt should be called."
At the time, these objections were not upheld as it was decided "that development should
continue to be concentrated in the towns and villages" and the Council was "right to identify
larger settlements for the promotion of development." However, a further proviso indicated ''a
need to approach future developments ... cautiously, with the development boundary identified
as an important mechanism to retain ... character."
In the light of the SLDC returning to Milnthorpe, I would now argue more strongly than before
that the village has reached an optimum size and accommodating additional housing, traffic,
social services, education and the like should not be enforced. The DPD lacks a robust and
persuasive evidence base and a sustainable policy to counter the following:
1. The small and easily overcrowded village hub. Traffic from R151M and other sites having
to use the A6 would further congest the traffic lights and narrow village cross-roads,
particularly at peak times of day. Also bear in mind that a new village Spar with petrol
pumps on the A6, around one hundred yards south of the lights, and a new Booths
supermarket accessed off the very narrow Park Road, a similar distance from the lights,
will add yet more traffic problems. The entrance/exit to Booths is located at one of the
narrowest points of Park Road and between here and the traffic lights the road is only able
to accommodate one large HGV type of vehicle driving in a single direction. As a result of
this the traffic lights can be blocked to free flowing traffic.
2. In addition to housing, further industrial expansion is planned just off-centre of the village
along Park Road to the west, and then east of the village at The Mainline Business Park.
Both sites will need to use the narrow B road which intersects the A6 at the same traffic
lights in the heart of the village. For the 7 years I have lived in the village, large amounts
of space have always been available for rent in the existing industrial parks, and I would
seriously query the need for more. The South Lakes and the National Park are by their
special nature, primarily suited to tourism and leisure, and all forms of industrial expansion
should be carefully monitored.
3. Existing parking for the post office, dental and doctor's surgeries, and the pharmacy is
virtually non-existent, and in certain parts hazardous. Along with shoppers and other
casual visitors to the village, the only alternative to using the very restrictive and
invariably full village square car park is to use the off-centre pay and display car parks,
which charge typically high South Lakeland fees. This scenario discourages tourists and
locals alike and proof of this may be seen in the many letters of complaint that have been
published in the Westmorland Gazette over the years. On market days, cars often park in
the lay-by on the southern A6 edge of the village and the occupants then walk into the village to do their shopping.
4. The DPD acknowledges that the local primary school is at or near capacity, but no solution
has been tabled. Likewise, I believe that the Dallam secondary school is in a similar
position and the school has already expanded to the boundary with Ackenthwaite, contrary
to the Core Strategy principle that Milnthorpe and Ackenthwaite should not coalesce!
5. The fact that Milnthorpe services other nearby villages, some of which are also scheduled
for expansion.
6. The village sits in a valley and the general topography is not suited to further serious or
economic development. The retention of ridgelines and important views remain a major
issue and their protection is essential for the village to retain its character and sense of
location.
7. No brown field sites have been identified in Milnthorpe contrary to Core Strategy CS6. 6
"seeking to ensure that at least 28% of housing development takes place on previously
developed land and buildings" To my knowledge little if nothing has been adequately
pursued to meet this commitment as such space in Milnthorpe appears conveniently
"limited. H
As a consequence, I would respectfully request the SLDC to at least pause and reconsider far
more thoroughly all of the key issues affecting the village and its quality of life.
Moreover, the new National Planning Policy Framework (NPPF) has just been issued, out of
which I understand that Councils will be given further time to consider, Identify and protect
green spaces. I would also encourage the SLDC to abide by the spirit and intent of the recent
Localism Act, which promotes neighbourhood planning. The essence being that local
communities should be constructively engaged in the planning process on the basis that they
should possess a clearer and more sympathetic understanding of what they consider best for
their own towns and villages.
The SLDC should look beyond Milnthorpe for development and reconsider the Taylor Review
proposed by the Kendal Town Council (KTC), but rejected by the SLDC in respect of planning
around historic market towns/villages. I consider it prudent that the SLDC takes a longer term
view and commits now rather than later to the wiser "hub and spoke" form of planning
proposed by Taylor and the KTC. The NPPF would appear to provide the vehicle for pause and
reflection on what I and many others consider to be a flawed LDF/DPD.

YES, I wish to participate at the oral examination

Having devoted much time and energy to opposing the development of Site R151M including
representation at the Special Council Meeting on behalf of a South Milnthorpe Residents Group, I
consider it appropriate for me to complete my opposition by participating in an oral examination
with the planning inspector. I now respectfully request such an opportunity.

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.

Representation is made on behalf of myself and a number of other local residents/families who
previously authorised me to speak on their behalf at the SLDC Special Council meeting held on
18th January 2012 (copy of evidence attached containing 10 addresses and signatures). As a result
of the Council's approval to the LDF, which ignored our protests, the same group of people have
given me an extended mandate to represent them through public consultation and any subsequent
examination by the Inspector.


4.0 Strategy re affordable housing lacks a plausible evidence base
The chronic need in the South Lakes is for affordable, not open market housing, and to
address this cardinal requirement roughly one third of all housing has to be "affordable." To
overcome funding shortfalls, the method proposed by the SLDC is for developers to build both,
thus necessitating the acquisition of three times the amount of land - mainly green field sites -
realistically required. This will produce a potentially devastating and irreversible impact on the
environment, and to provide the number of affordable dwellings so urgently required, all 6,000
plus homes approved by the LDF will have to be completed.
The overall housing programme is phased through until 2025 and yet affordable homes are
immediately required! Concurrent with this scenario is the fact that the volume of open-market
housing proposed is not required in the current climate, existing and new houses are not
selling in the area, mortgages are difficult to come by, and even the affordable housing
currently under construction by developers is beyond the means and/or circumstance of those
in need; e.g. The Cock and Dolphin development in Kendal, 20 minutes drive from Milnthorpe.
A professional colleague of mine who works in the construction industry in the London area
and has knowledge of single scheme developments similar to those proposed by the SLDC
states that they are very difficult to operate effectively, and so what is the answer? My opinion
is that the SLDC should acknowledge the realities that abound in the economic climate,
continue to actively seek and encourage partnerships with housing associations and the like,
think creatively as to how appropriate funding may be obtained, and source suitable small
sites, brown or green, upon which to build affordable housing. Accept that traditionally
affordable homes fall within the remit of housing associations and concentrate efforts in this
field. To proceed otherwise would not be plausible.
At the Special Council Meeting held on 18'h January 2012, the senior PD member present
stated that insufficient smaller sites were available. This is incomprehensible given the amount
of land that appears available for large scale development, and suggests to me that the SLDC
is totally subject to the dictates of local landowners who are only willing to offer acreage that
turns in a more handsome profit. Are we as local residents to permit such greed at the
expense of our countryside, and accept the potentially ruinous nature of associated policies?
This is an extensive topic and for the sake. of brevity I have restricted my comments and
concerns. It is possible that whilst recognising the nationwide need for affordable housing, the
lack of central government funding to support its principles is encouraging councils to promote
flawed planning solutions.

YES, I wish to participate at the oral examination

Having devoted much time and energy to opposing the development of Site R151M including
representation at the Special Council Meeting on behalf of a South Milnthorpe Residents Group, I
consider it appropriate for me to complete my opposition by participating in an oral examination
with the planning inspector. I now respectfully request such an opportunity.

Please notify me

I have read the guidance notes

1.10

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.

Representation is made on behalf of myself and a number of other local residents/families who
previously authorised me to speak on their behalf at the SLDC Special Council meeting held on
18th January 2012 (copy of evidence attached containing 10 addresses and signatures). As a result
of the Council's approval to the LDF, which ignored our protests, the same group of people have
given me an extended mandate to represent them through public consultation and any subsequent
examination by the Inspector.

5.0 Public Consultation has not been effectively promoted and impartially evaluated
This may be expressed as follows:
The response of our local community has largely been ignored and consultation has been
minimal:
1. At the only parish council meeting held to engage with the public, the majority of those
present raised objections to the proposed sites, but more worryingly, at the same meeting
I overheard an invited representative from the SLDC remark that regardless of public
opinion, development of the scale proposed would go ahead.
2. From conversations with many in the local community, the SLDC/Pianning Department
received numerous objections to its proposed sites during open days held in the village.
3. The Parish Council's "unanimous" decision to approve the allocation of sites in Milnthorpe
cannot be considered a valid representative opinion. Wlth the exception of what i have cited above, no other forms of wider community polling were conducted and the decision
reflects the views of a small minority, those lay persons holding seats on the Council.
4. A potential conflict of interest lies within the system as some parish councillors live in the
adjacent village of Ackenthwaite where proposed development is minimal..!
5. Secondary consultation with the SLDC/Pianning Department on alternative sites proved to
be a cynical waste of time. Interested members of the public were issued with area maps
showing sites marked by the Planning Department (PD) as potential alternatives,
particularly in Ackenthwaite. However, these sites were then readily dismissed raising the
question of why they were promoted by the PD in the first instance? Perhaps to complete
the "box ticking" exercise! This raises the question, has the PD met the criteria " ...
appropriate strategy when considered against reasonable alternatives .. '?
At the Special Council Meeting on 1B'h January 2012, local councillors voted to approve the
LDF along party political lines - refer to the resultant voting - and those members who were
requested to help their constituents singularly failed to do so, either during earlier public
consultation or during the meeting itself.
For example, I quote a response received from my local councillor in Milnthorpe, after I had
expressed my disappointment at his lack of support in the said meeting: "Last Wednesday's
meeting was a necessary formality as the outcome was never in doubt. It was an opportunity
for speech making for those who like to, but the real work had been done before the meeting
.. " I do not possess the statistics for Milnthorpe, but in the Kendal area I presume that some
of the "real work" of the SLDC was to ignore the fact that over 98% of responders opposed the
DPD as written!
Documentation supporting the DPD is extensive and complex containing many thousands of
pages. I do not consider the format to be user-friendly, and to find information relating to a
particular settlement it is necessary to read or "skim" through excessive amounts of paperwork
taking up considerable time.
For these reasons, I consider individual members of the public to be seriously disadvantaged
when attempting, mainly in their spare time, to search for and evaluate evidence and the like
assembled by a full time body of professional staff over many months and years. And what of
those members of the public without computers, who would need to spend many hours and
days in their local libraries, and whose subsequent representation would then need to be
painstakingly handwritten?

YES, I wish to participate at the oral examination

Having devoted much time and energy to opposing the development of Site R151M including
representation at the Special Council Meeting on behalf of a South Milnthorpe Residents Group, I
consider it appropriate for me to complete my opposition by participating in an oral examination
with the planning inspector. I now respectfully request such an opportunity.

Please notify me