Local Development Framework Consultation

I have read the guidance notes

LA1.3 Housing Allocations

Yes

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 consider that the process has been unsound for the following reasons

A) Certain relevant documents and facts appear not to have been considered:

A document prepared by Kendal Town Council advocating an alternative approach has not been considered and is nowhere referred to in the document or elsewhere. No appraisal or critique of this document has been issued.

An overwhelmingly negative and/or critical public response has resulted in very little change to the draft plan and some contentious sites have actually been expanded.

An excessively high forecast for population growth has been adopted, which does not accord either with current population trends or with the specific age profile of the area, which has a preponderance of older people.

The acknowledged problem of excessively high air pollution in Lowther Street has not been addressed, other than in a vague reference to traffic management. The expanded proposal R129M will significantly increase rush-hour congestion in this area.

There is no adequate consideration of brown field sites.


B) The proposed allocation for housing is utterly out of balance with the allocation for employment. This will encourage commuting out of the area, which is at odds with the criterion of environmental sustainability. It is also likely to increase second home ownership, which is a major problem in the area.

C) The process itself has been unsound in our judgment since:

In the second phase of consultation, extra land allocation has been made (e.g. an addition to R129M) which had previously been ruled out on environmental and amenity grounds. It appears to have been added simply because the owner is willing to sell it. The document states that the environmental impact will be 'mitigated by screening', which is hardly adequate and ignores the fact that the lie of the land makes this a near-impossibility. This land borders the Lake District National Park.

Public participation has been hindered because the design of the SLDC web-site, the council's preferred means of communication, is unwieldy and difficult to navigate, and posting representations to it has proved unreliable. This discourages participation. Errors in the documentation have misled residents about where development is proposed; site R129M was initially referred to as 'land south of Brigsteer Road' when it lies to the north.

CONCLUSION
We contend that :

i) undue emphasis has been placed on whether land is available for sale, rather than where development would be most appropriate

ii) once an outline approach had been defined, the council failed to consider alternative approaches or review its initial conclusions

iii) where obstacles have been identified, an inadequate reference to 'mitigation' has frequently been made, without any attempt to address the underlying issues.

These are serious deficiencies which cannot be corrected by tinkering with the text. The document should be withdrawn and fully re-appraised.

NO, I do not wish to participate at the oral examination

Please notify me

I have read the guidance notes

0.0 Whole Document

Yes

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.

An overwhelmingly negative and/or critical public response has resulted in very little change to the draft plan and some contentious sites have actually been expanded.

An excessively high forecast for population growth has been adopted, which does not accord either with current population trends or with the specific age profile of the area, which has a preponderance of older people.
CONCLUSION
We contend that :

i) undue emphasis has been placed on whether land is available for sale, rather than where development would be most appropriate

ii) once an outline approach had been defined, the council failed to consider alternative approaches or review its initial conclusions

iii) where obstacles have been identified, an inadequate reference to 'mitigation' has frequently been made, without any attempt to address the underlying issues.

These are serious deficiencies which cannot be corrected by tinkering with the text. The document should be withdrawn and fully re-appraised.

NO, I do not wish to participate at the oral examination

Please notify me

I have read the guidance notes

LA1.3 Housing Allocations - All Kendal sites

Yes

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 consider that the process has been unsound for the following reasons

A) Certain relevant documents and facts appear not to have been considered:

A document prepared by Kendal Town Council advocating an alternative approach has not been considered and is nowhere referred to in the document or elsewhere. No appraisal or critique of this document has been issued.
There is no adequate consideration of brown field sites.
B) The proposed allocation for housing is utterly out of balance with the allocation for employment. This will encourage commuting out of the area, which is at odds with the criterion of environmental sustainability. It is also likely to increase second home ownership, which is a major problem in the area.
CONCLUSION
We contend that :

i) undue emphasis has been placed on whether land is available for sale, rather than where development would be most appropriate

ii) once an outline approach had been defined, the council failed to consider alternative approaches or review its initial conclusions

iii) where obstacles have been identified, an inadequate reference to 'mitigation' has frequently been made, without any attempt to address the underlying issues.

These are serious deficiencies which cannot be corrected by tinkering with the text. The document should be withdrawn and fully re-appraised.

NO, I do not wish to participate at the oral examination

Please notify me

I have read the guidance notes

LA1.3 Housing Allocations - R129M KENDAL SOUTH OF UNDERBARROW ROAD

Yes

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.

The acknowledged problem of excessively high air pollution in Lowther Street has not been addressed, other than in a vague reference to traffic management. The expanded proposal R129M will significantly increase rush-hour congestion in this area.
There is no adequate consideration of brown field sites.
C) The process itself has been unsound in our judgment since:

In the second phase of consultation, extra land allocation has been made (e.g. an addition to R129M) which had previously been ruled out on environmental and amenity grounds. It appears to have been added simply because the owner is willing to sell it. The document states that the environmental impact will be 'mitigated by screening', which is hardly adequate and ignores the fact that the lie of the land makes this a near-impossibility. This land borders the Lake District National Park.
CONCLUSION
We contend that :

i) undue emphasis has been placed on whether land is available for sale, rather than where development would be most appropriate

ii) once an outline approach had been defined, the council failed to consider alternative approaches or review its initial conclusions

iii) where obstacles have been identified, an inadequate reference to 'mitigation' has frequently been made, without any attempt to address the underlying issues.

These are serious deficiencies which cannot be corrected by tinkering with the text. The document should be withdrawn and fully re-appraised.

NO, I do not wish to participate at the oral examination

Please notify me

I have read the guidance notes

1.9

Yes

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.

Public participation has been hindered because the design of the SLDC web-site, the council's preferred means of communication, is unwieldy and difficult to navigate, and posting representations to it has proved unreliable. This discourages participation. Errors in the documentation have misled residents about where development is proposed; site R129M was initially referred to as 'land south of Brigsteer Road' when it lies to the north.

NO, I do not wish to participate at the oral examination

Please notify me