Local Development Framework Consultation

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.

1.1 Community Involvement
Preston Richard Parish Council (“the PC”) has endeavoured throughout the Land Allocation Development Plan consultation process and its final review of SLDC’s Development Plan Document (“the DPD”) to adopt a helpful and pragmatic approach, with the involvement of the village community.
With the help of a small team of parishioners it has:
• Manned a help-desk at a SLDC Open Day
• Attended two meetings with SLDC Development Strategy Dept.
• Hosted two well attended Public Meetings , one with SLD representation present
• Informed residents of status with leaflets and an updated PC website
• Dedicated support email address for enquiries and feedback on proposals
• Hosted two ‘surgeries’ to advise residents on the DPD representation process.
1.2 The DPD Representation Process (March/April 2012)
Whilst there has been considerable public consultation, the first opportunity for parishioners to consider SLDCs final views on Land Allocation was not until the 12th January 2012 when a draft version of the document was made public. However not all of the supporting documentation and final version of the DPD was released until 18th March 2012.

Due to the substantial volume of material needing to be digested, the complexity of the ‘e-response’ process, the very technical nature of the questions, and just 6 weeks to respond within, many residents have found the process far too daunting and have been dissuaded from responding.

SLDC’s strategy of making supporting documentation available on-line and overtly favouring an e response over hardcopy disadvantaged older parishioners and those without computer skills or facilities. It was only after this PC challenged SLDC, that the initial limitation of just 500 words for commenting, (which they felt was unreasonable), that SLDC removed this limit.

The process adopted by SLDC therefore does not facilitate or encourage the full and proper involvement of all the community, and in our opinion not in accordance with the SLDC’s Statement of Community Involvement.

YES, I wish to participate at the oral examination

To ensure our views are considered and fully understood and to respond to any new information should it arise.

I have read the guidance notes

LA1.3 Housing Allocations - All Endmoor 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.

The DPD is not consistent with national policy.

1.0 Introduction
Endmoor is a rural village nestled in the local drumlin landscape, previously designated as an area of AGLV and LCI with a history of over 800 years. It developed rapidly in the 1800s benefiting from the rapid flowing Peasey Beck and a plentiful local wood supply for charcoal; later developing corn milling , flax processing and bobbin manufacture.

Gunpowder production which started in 1852, with supporting industry and trades such as cooperage and saw mills, generated significant employment for over 100 workers. As the village prospered, a tramway was constructed from Gatebeck to Crooklands connecting with the Lancaster Canal, but unfortunately, once production of gunpowder ceased in 1937, many workers were relocated by ICI and employment opportunities in the village diminished.

The majority of local trades and businesses closed, and with improved road links and the advent of the car, this decline of local employment and services including the local Co-op and convenience store continued. The development of small trading estates at Summerlands and Gatebeck has, to a limited extent, facilitated some local employment.

Today, the village supports a mixed community of young families, and a significant older population, in a mixture of historic terraced properties, bungalows and modern family houses and has a ‘sense of community‘. The village has very few local community services. Unfortunately the Post Office closed in 2011 (replaced by Outreach). Residents are heavily dependent on neighbouring Kendal, Milnthorpe and Kirkby Lonsdale for shops, restaurants, banks, dentists, doctors, pharmacies, social and educational services.
2.0 Overview of PC’s Position on the Proposal
Given what the present Government says about Local Democracy, the PC expect their carefully considered opinions in this representation to be heard and acted upon.
The Parish Council recognises the general need for additional housing and employment land allocation for the future and fully supports a fair and balanced, long term development of the village and its wider role in the South Lakes.
But this must be done in a way which is sensitive, sustainable and beneficial to the overall wellbeing of the village, its community and its long term future. Integration of all new developments should be done sympathetically utilising and complementing the natural topology of the landscape, preserving all drumlin features.
The PC strongly recommend that the overall number of new dwellings in the village be substantially reduced to enable the village to evolve in a sustainable way based on the needs of the village and local area. It is essential that any future development be in keeping with its character to preserve this for future generations. It should not be expected to accommodate a disproportionate number of dwellings purely because it has the potential capacity on these important Greenfield sites but without the services and infrastructure to support them.
Historically the village has comprised a number of bungalows and houses, with the majority of two storey dwellings utilising the natural contours between the Gatebeck Road and the Peasy Beck valley to blend in with the wider landscape. The exception to this was the most recent Sycamore Close which has been identified as an “abrupt urban edge” and consequently do not wish to repeat the same mistakes made with any new development.
Full details of the PCs objections and proposals are contained within this Representation, but in summary the PC do not believe that DPD is Sound because:-
• The impact the proposed size of developments would have on the village and surrounding drumlin landscape which has previously been acknowledged as an Area of Great Landscape Value and a Landscape of County Importance which is supported by previous Inspectors reports:-
o County Showfield - Ref 5/89/4103
o Crematorium - T/APP/M0933/A/99/1017017/P2
o Sillfield Wind Turbines - Ref: SL/2008/0900
• The Scale of development, its impact on the village and character
o Proposed density of housing in M41M & R670M
o 48% increase in number of houses in Village Development Boundary
o 30% increase in size of Village Development Boundary
• M41M site has previously been identified as an Area of Great Landscape Value in the County Showfield Inspectors report - Ref 5/89/4103
• The PC were not consulted on the increased numbers of dwellings on M41M from 68 to 100
• There is NO agreed Infrastructure Plan with United Utilities to upgrade the sewerage system to be able to support any new developments.
o United Utilities have not agreed to develop any existing or new sewerage works - UU Letter Ref DC/12/882
o No consultation by SLDC on the proposed Low Park works
• The PC were not consulted on choice of EN20 & EN33 as an employment site
o Lack of business case to support this choice of location
o Resultant increase in traffic volumes on Gatebeck Lane and resulting traffic safety issues
o Previous Crematorium Inspectors findings on Traffic issues (T/APP/M0933/A/99/1017615/P2)
o Existing sites in the area have significant spare capacity
• The inevitable negative impact these developments would have on the local tourism industry and its risk to jobs.
• The lack of evidence for such high numbers of new affordable housing in the village
o Only 4 families in the Parish on Housing waiting list
o Recent Housing Needs Survey found only 10 families in the Parish in need of affordable housing
o Services in the village do not match the needs of families in these houses

After careful consideration the PC propose the following:-
• To reject the proposed Employment sites EN20 & EN33
• No further new housing development until an agreed Infrastructure Plan is in place to address the critical Sewerage capacity limitations
• Reduce overall allocation of new dwellings from 125 down to 50 in keeping with the scale of the village and its sustainability.
o Reduce the total number of Affordable dwellings from 44 down to 10
? Commute the rest of the quota to more suitable locations
o Reduce dwellings on M41M from 100 down to 34 comprising of mixed bungalows and Affordable dwellings commencing in Phase 2&3
o Reduce dwellings on R670M from 25 down to 16 comprising of mixed bungalows and affordable dwellings commencing in Phase 3
o Explore additional Infill and Rounding within the Village Development Boundary.

3.0 Numbers of Dwellings proposed:-
The numbers of dwellings proposed in the DPD are not Sound as they are not founded on a robust and credible evidence base.
Rural Kendal Local Service Centres (LSC)
Contrary to DPD 2.16 P18, Endmoor has been requested to provide 125 new dwellings which based on their population and facilities, is disproportionate to that being requested of other Kendal Rural LSCs or neighbouring Key Service Centres, Milnthorpe and Kirkby Lonsdale. Unlike Milnthorpe & Kirkby Lonsdale, Endmoor does not have the services such as banks, doctors, pharmacies or dentists of its neighbours, yet Milnthorpe has a smaller proportional allocation of new housing (186) despite having a substantially larger population to Endmoor (2,100 v 1,300).
The number of affordable homes needs to be proportionate to realistic local demand combined with the needs of the village and relevant to the local area. In 2007 the Cumbria Rural Housing Trust conducted a Housing Needs Survey for Preston Richard parishioner’s housing needs up until 2012. From this they identified ten (10) households in need of affordable housing. Currently we are only aware of four (4) families who are registered on the Local Authority or Housing Association waiting list. Also there is currently one such dwelling, a three bed house available in the village at time of writing this response and the PC cannot be sure that other premises are not available.
The current proposal of 125 new dwellings in the village would necessitate 44 affordable dwellings (35% of 125). This number is totally inappropriate for Endmoor because there is
little demand and/or that the services in the village are not well matched to the needs of the people in such houses.
Unfortunately, the majority of young families wish to live in, or near a town, with good transport links or close to their place of employment and services. There is a serious risk that they would consider themselves isolated in our rural village.

In keeping with the Core Strategy and DPD policies, Local Service Centre allocation of new dwellings should reflect the current size and local needs of the village and its capacity for its services and infrastructure to accommodate them. Consequently the PC believes that the village cannot accommodate more than 50 new dwellings to be carefully phased over the next 15 years.

4.0 Waste Water (Sewerage) & Surface Water
4.1 Waste Water Network (Sewerage)
The DPD proposal is not Sound as it is not Justified by robust and credible evidence. It is not based on a sound strategy, does not conform to the Core Strategy and has been made without local community participation.

The DPD has correctly identified that Endmoor has a sewerage capacity issue which needs to be addressed to support any new development. Unfortunately there is no evidence of an agreed Infrastructure Plan with United Utilities (“UU”) for a solution to Endmoor’s sewerage limitation.

In a letter from UU, Ref DC/12/882 dated February 29th 2012, they state
Page2, para 3&9, Historically UU have considered consolidating Low Park, Crooklands and Endmoor Waste Water Treatment Works (WwTW) into one at Endmoor, but an engineering study has determined that is not a valid option. To upgrade the Endmoor WwTW to support additional capacity may require an electricity supply and long lead times.

Page 2, para 10,“As the developments do not have planning approval , they remain development aspiration for both SLDC and Story Homes, and therefore United Utilities has not undertaken any work to determine the needs, scope and/or location , if any, of the supporting infrastructure.”

This UU statement conflicts with SLDC’s wording in DPD - 02 Consultation Statement Document (“the CSD”) page 21; which states:-
• “Endmoor works are at capacity. Flows need to be directed from Endmoor and Crooklands to improved works at Low Park”.

But in the DPD under “Key issues affecting development in Endmoor”, para. 3.121, page 94; it does not mention the critical need for an agreed Infrastructure Plan with UU before plans for any development can proceed. But instead just mentions that “investment in the sewerage works is necessary”.

Contrary to the Statement of Community Involvement, SLDC has not involved Low Park residents or the local WwTW site land owner. Infact the first they were aware of plans for a new plant was when the draft CSD was released in January 2012.

The SLDC proposed expansion of the Low Park sewerage works is not Sound and is contrary in regard to numerous Core Strategy policies:-

CS 1 Sustainable Development Principles, CS8.1 Green Infrastructure and CS8.2 Protection and enhancement of landscape and settlement character.

The existing Low Park treatment works is within an area previously designated as AGLV and LCI, which has been the subject of Inspectors’ comments in its previous planning application appeals for developments in this area.
• County Showground Inspectors Report 22-Feb-1990 Ref 5/89/4103 (see para.3.2 )
• Crematorium site (see para 3.4 )
o T/APP/M0933/A/99/1017017/P2 Crematorium
o T/APP/M0933/A/99/1017615/P27 Re-siting of Haulage Depot
• Sillfield Wind Turbine Appeal Decision, September-2008 Ref: SL/2008/09007 para 24 & 39 refer to the character of the local drumlin landscape particularly when viewed from Low Park.

CS 10.2 “ safe access to the highway network without detriment to the amenity or
character of the locality”
• Access to the proposed works at Low Park is via Gatebeck Lane and Low Park Lane which are mostly single track, with few footpaths, and the former currently used by amongst other traffic, heavy haulage and quarry lorries (See this documents section 5.3 EN20 & EN33 in relation to traffic issues with Gatebeck Lane).
• A potentially much enlarged works will increase the number of tanker movements, with increase safety risks and further erode verges in the road network.

CS8.4 Biodiversity /Geodivesity. The proposed development of this site would result in the inevitable damage to the drumlin fields and risk the displacement and potential loss of birds and mammals.

The PC propose that NO future development in Endmoor should be considered until SLDC and UU have an agreed detailed infrastructure plan to support the safe and effective disposal of waste water.
The DPD and Consultation Statement Document need to be updated to reflect this critical requirement and its dependencies on future UU studies. The SLDC are requested to keep the PC and local community fully involved during the consideration of future plans.

The PC questions whether alternative sites could be found which may facilitate a cheaper gravity feed solution. e.g. Crooklands area.

4.2 Surface Water
In a letter from United Utilities, Ref DC/12/882 dated February 29th 2012; section on Surface Water, para 2, they refer to use or mimicking of the ‘sites ‘ natural discharge solutions. It also cites the investigation of a range of alternative solutions and emphasises that such surface water should not be discharged into the public combined sewerage network.

5.0 Proposed Development Sites
The proposed scale of development of both Greenfield sites to accommodate 125 new dwellings would appear to have been selected, based purely on their potential capacity for the number of new dwellings they can support and do not reflect the local needs of the village and its capacity to accommodate them. Consequently they are neither Justified or Sustainable as it contradicts a number of policies.

• CS1.1 Sustainable Development Principles Point 2 & 3, page 16
o It is vital to protect the countryside for its intrinsic beauty, diversity and natural resources …
• DPD Landscape and Settlement 2.23, page 20
o “… .the potential impact of the development on landscape and views, ..”
? The scale of the proposed development would seriously impact the appearance of the drumlins, a rare aspect of our national heritage and local landscape which must be preserved for future generations.
o County Showfield Inspectors Report on 22-Feb-1990 Ref 5/89/4103 rejected the proposed County Showfield development on M41M. In his findings he stated….
? Page 5 Conclusion
• 17. “ the resultant landscape would not be the same landscape and would not serve to perpetuate the qualities for which the area was originally identified and is now protected”
• 19. “I note that the AGLV pattern is such that it flows through the settlement of Endmoor in such a way as to make any immediate landscape change of maximum adverse impact”.
o The DPD, Endmoor Fact File, Feb-2012, Appendix 3; Sustainability Appraisal, page 86. The proposed developments resulted in a poor score …..
? Poor score on Open Space, Greenfield Land and impact on Landscape
• CS8.10, Design, page 110; The siting, design, scale and materials of all development should be of a character which maintains or enhances the quality of the landscape.
o The proposed dwelling density of 30/ha as stated in the DPD is out of scale with that of the village where the average density within the development boundary is aprox. 13.5/ha and Sycamore Close which is aprox. 17/ha1 (and that is without any open green space).
• DPD page 20, 2.23 Landscape and Settlement “… .the potential impact of the scale of development relative to settlement size, ..”
o The DPD plans would increase the number of houses within the existing village development boundary from aprox.257 to 382 (48%) and would increase the area from aprox.19.2ha1 to 24.8 ha1 (30%).
o The scale and substantial increase in dwelling density risk overwhelming the village and distorting the community balance by moving the centre and heart of the village to within the new development, north of Sycamore Close.
• DPD 2.16 page 18; 2.22 page 19; 2.28, page 21; The proposed 125 new dwellings are disproportionate to the current size of the village and not based on its Size or Capacity to be Sustainable due to the lack of infrastructure and services in the village. Nor do they show regard to the needs of the village and its capacity to support the development
o See this documents section 4.0 on Sewerage and Surface Water for full details.
• CS 1.2 Development Strategy page 17 “with a target of ensuring that 28% of new developments take place on existing buildings and previously developed land”
• CS1.1 Point 6) minimise the need to travel, page 16; CS10.2 Transport Impact of New Development, page 116;
o Because of the lack of employment and services in the local area, the majority of all new residents would need to travel to their place of work and services by car as the bus service is both limited and infrequent.
• CS7.4 Rural Economy, page 92; “The council recognises the environment as a critical driver in the local economy”.
o The local village economy is dependent on tourism supported by a number of fixed and touring caravan sites, B&B’s and the local Crooklands hotel. Tourists come to this area of outstanding landscape to be able to enjoy walking, cycling and sightseeing. But this tourism business would be put at significant risk and local jobs jeopardised if the scale of development and its associated traffic density was allowed to destroy the character of the village and surrounding area.
Biodiversity /Geodiversity

The proposed developments threaten the geodiversity of this environment and the biodiversity it supports.
• The Endmoor Fact File states that the whole village belongs to Landscape Character Type 7b Drumlin Field. This designation indicates sensitivity " .. to development which could change their appearance".
• The Cumbria Biodiversity Evidence Base believes that this landscape supports 7 key species of birds and mammals.
In accordance with CS1.1, CS8.1 & CS8.4 all possible steps should be taken to limit damage to the drumlin fields.

6.0 Conclusions & Summary
Whilst we are keen to ensure that we have sufficient capacity of affordable housing in the village to support current and future requirements of the local population, the number of dwellings must be proportionate to our requirements and ability to support them with strong evidence that young families can afford the properties and wish to live in our rural village with its limited services. Currently we are only aware of 4 people on the Housing waiting list and because the most recent Housing Needs Survey shows limited need for affordable housing in Endmoor, and propose that the number of new affordable homes be reduced to 10. Consequently any new development should be subject to the payment of a commuted sum to the Council so that the majority of the affordable housing is provided elsewhere in South Lakeland where the need is greater and the services are already in place.
Equally the PC want to make sure that there are sufficient numbers of bungalows available in the village to accommodate the current and future needs of the older members of the community to remain in the village as their housing requirements evolve. This would also free up housing stock for families to grow into.
The PC do not support the development of EN20 & EN33 for employment as they do not believe they are justified or sustainable. Instead they suggest that alternative employment sites with direct access to the A65 or closer to Kendal would more appropriate.
Once SLDC and United Utilities have an agreed detailed Infrastructure Plan and the results of The Highways Agency investigations are available, and only then, the PC would support the following reduced development of no more than 50 new dwellings.
M41M reduced to no more than 34 dwellings for delivery over phase 2 & 3, comprising of bungalows and starter homes sympathetically integrated through appropriate landscaping and the provision of open spaces and allotments.
R670M be reduced to no more than 16 dwellings for delivery in phase 3, comprising of bungalows and starter homes sympathetically integrated through appropriate landscaping and the provision of open spaces and allotments.

To help reduce the number of dwellings on these two sites further, the PC is keen to explore alternatives sites within the current village development boundary for small scale independent Infilling and Rounding Off. The PC are currently aware of a prospective planning application for 9 dwellings on a SLDC previously nominated site R83M (Birchfield) and would like to consider possible developments in Summerlands.
The PC have endeavoured to be constructive and pragmatic during the DPD consultation process and wish to maintain this approach with the SLDC and any future developers in the production of Development Brief(s) and plans.
The PC recognises that the National Planning Policy Framework provides the local community with a fresh opportunity to engage in the Local Plan process through Neighbourhood Planning to “shape and direct sustainable development in their village” The PC look forward to supporting and actively participating in such a plan at the earliest possible opportunity.

Fig 7.1 United Utilities Letter

Dear Peter

Proposal: SLDC Land Allocation Consultation

Thank you for your enquiry and seeking the views of United Utilities PLC on the following matter:

Ref. our telecom of 20th February, I am assisting Preston Richard Parish Council in the formulation of a response in the SLDC Land Allocation Consultation. As I mentioned there is some concern from local residents regarding the possibility of construction, post-2015, of an enlarged sewerage treatment plant at Low Park, Endmoor to replace 3 existing works at Low Park, Endmoor itself and Crooklands, to facilitate the possible construction of 125 dwellings on 2 sites in Endmoor and an industrial site at Gatebeck. The current works at Endmoor is situated in a sensitive drumlin landscape very close to existing dwellings.In particular we would be interested in knowing what criteria have been used to determine Low Park as the preferred site.

With you help we some better understanding of the planning and design issues involved to assist in the consultation process, hopefully by meeting you or your colleagues shortly.

United Utilities PLC supports growth and sustainable development within the North West.

United Utilities PLC would like to build a strong partnership with Local Planning Authorities [LPA] to aid sustainable development and growth.

Our aim is to proactively share our information; assist in the development of sound planning strategies, to identify future development needs and to secure the necessary long-term infrastructure investment.

Water and wastewater services are vital for the future health and well-being of the community and the protection of the environment. When developing future policies LPA should consider the impacts on the health and well-being its community, environment and ensure infrastructure capacity is available. If infrastructure deficiencies cannot be addressed, an alternative location and/or timescale should be sought where infrastructure capacity is available and it meets your development needs.

Inappropriate development could result in the closing of a hospital and/or school etc, due to the inappropriate development siphoning off the historical water or wastewater infrastructure capacity; no water supply for washing and catering facilities and/or sewerage flooding of the property/highway.

Historically United Utilities PLC had considered rationalising three wastewater treatment works [WwTW] and transferring the flows from Crooklands WwTW and Low Park WwTW to Endmoor WwTW. An engineering study has determined that this proposal is currently not a viable option.

In liaison, meetings with SLDC and via their consultation process United Utilities PLC has advised SLDC that an upgrade of the existing infrastructure will be required to support any future development at Endmoor. Failure to implement the additional infrastructure capacity needs, before the development is connected to the public networks could result in a loss of service to the existing customers; flooding from sewers and/or environmental damage.

United Utilities PLC has highlighted these issues to Storey Homes.

A scheme to increase in the infrastructure capacity in the Endmoor area had not be considered and/or submitted to Ofwat for approval for this Asset Management Plan [AMP ~ 1 April 2010 to 31 March 2015] therefore no current plans are in place to upgrade the infrastructure.

Both SLDC and Story Homes have been advised that Supply and Demand [increased capacity for growth] investment and approval could be sort from Ofwat for the next AMP [AMP6 ~ 2015 – 2020] and/or future AMPs.

The location, type, timescale of development and the future environmental consent imposed by the Environment Agency will determine the future investment needs, scope and location of the supporting infrastructure.

Endmoor WwTW is a small WwTW with no electricity supply, the processes functions by gravity. An electrical supply may be required to support any additional treatment processes and capacity needs and a long lead in time would be required to secure this supply.

As the developments do not have planning approval, they remain a development aspiration for both SLDC and Story Homes and therefore United Utilities PLC has not undertaken any work to determine the needs, scope and/or location, if any, of the supporting infrastructure.

United Utilities PLC does not have a monopoly on the supply of water and/or the treatment of sewage waste; alternative options are available to developers.

A major determinant in identifying future capacity needs is the management of surface water.


Surface Water
Site drainage should be a major consideration for LPA and developers when selecting possible development sites; ground conditions; local flooding issues; development layout; design and planning policy.

The treatment and processing of surface water [storm water; rainwater] is a not a sustainable solution; the sites’ current natural discharge solution should be continued and/or mimicked; if the existing surface water does not have an existing natural solution, United Utilities PLC questions the development of a flooded site.

Surfacewater should be managed at source and not transferred; if not this will only transfer the issue to another location; generally to a single pinch point, generating further problems in that location.

Developments must drain on a separate sewerage system, with only foul drainage connected into the foul sewerage network.

Every option should be investigate before discharging surface water into a public sewerage network.

Connecting surface water to the public sewerage network is not a sustainable solution and LPA should discourage this practice.

The priority options for the management of surface water discharges are:
Continue and/or mimic the site’s current natural discharge process
Store for later use
Discharge into infiltration systems located in porous sub soils
Attenuate flows into green engineering solutions such as ponds; swales or other open water features for gradual release to a watercourse and/or porous sub soils
Attenuate by storing in tanks or sealed systems for gradual release to a watercourse
Direct discharge to a watercourse
Direct discharge to a surface water sewer
Controlled discharge into the combined sewerage network ~ this option is a last resort when all other options have been discounted.

Development on greenfield sites shall not discharge surface water into the public combined sewerage network and shall not increase the rate of run-off into the public surface water network ~ this statement does not replace the priority options for surface water management above.

On previously developed land, a reduction of at least 30% will be sought, rising to a minimum of 50% in critical drainage areas ~ this statement does not replace the priority options for surface water management above

Any discharge to the public sewerage system must be via approved SuDS and will require an approved discharge rate.

Consideration should given for green infrastructure, low carbon, soft engineering SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.

http://www.ciria.com/suds/index.html

A discharge to groundwater or watercourse may require the consent of the Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding or the overloading of the public sewerage network]


LIABILITY
United Utilities PLC does not promise that the data will provide any particular facilities or functions. You must ensure that the data meet your needs. You are entirely responsible for the consequences of any use of the data, United Utilities PLC give you no warranty about the fitness for purpose or performance of any part of the data.

If an electronic format has been used, United Utilities PLC do not promise that the media on which the data are provided will always be free from defects, computer viruses, software locks or other similar code or that the operation of the data will be uninterrupted or error free. You should carry out all necessary virus checks prior to loading the data on to your computer system.

United Utilities PLC does not guarantee that the data will always be accurate, correct, complete, up to date or valid. United Utilities PLC gives you no warranty about the condition or satisfactory quality of any part of the data.

United Utilities PLC is only able to undertake to use reasonable endeavours to ensure that United Utilities PLC is providing you with an accurate a copy from our records.

United Utilities PLC are not in any circumstances (including if United Utilities PLC have been negligent) liable for any damage to property, loss of business capital, earnings, profit, reputation, goodwill or enjoyment or any other indirect or consequential loss or damage at all arising out of or in connection with this Agreement or its subject matter.

You accept that United Utilities PLC shall not be under any liability to you of any kind, which arising directly or indirectly, for any conditions, warranties, undertakings or representations of any kind, express or implied, statutory or otherwise, relating to the data.

If you have any queries and/or require any further information relating to this enquiry, please do not hesitate in contacting me.


Yours Sincerely



Dave Sherratt
Local Development Framework Lead
Developer Services & Asset Protection Team
United Utilities PLC

PLEASE SEE ATTACHED PHOTOS

YES, I wish to participate at the oral examination

LA1.3 Housing Allocations - M41M ENDMOOR NORTH OF SYCAMORE DRIVE

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 PC questions the density of development on M41M as it does not believe these solutions are available
• The Endmoor Fact File Sustainability Report, does not recognise surface water flood problems in periods of heavy rain associated with site M41M .

United Utilities and the developers need to investigate alternative approaches for managing and fully understand their consequences on the potential capacity for this site, if adopted.

5.1 M41M
The DPD proposal for 100 dwellings at 30/ha is not Sound as they are not founded on robust and credible evidence.
• Contrary to the public consultation process, the residents of Endmoor were only consulted on the proposed 68 new dwellings on the original M41 site and the overall feedback from the PC and villagers was that even 68 was too many for this site. The PC were NOT consulted on the proposed 100 dwellings on M41M before the publication of the current DPD.
• DPD 2.23 page 20; Landscape and Settlement “… .the potential impact of the development on landscape and views, ..”
o The scale of the proposed development would seriously impact the appearance of the drumlins and wider landscape.
• CS 9.3, page 99; Protection and enhancement of landscape and settlement character
o County Showfield Inspectors Report by on 22-Feb-1990 Ref 5/89/4103. Proposed County Showfield development on M41M were rejected.
• Contrary to Endmoor Fact File, Feb-2012, Appendix 3; Sustainability Appraisal, the lower, more eastern field, frequently floods after heavy rain and will need careful planning to accommodate this. See Surface Water section 4.0 in this document for details.
• DPD para 3.123, page 94; states that the northern edge of the village where there are currently just seven houses in Sycamore Close bordering the field, is “an abrupt urban edge” Building an additional 100 new homes will NOT “minimise visual impact”.
• DPD Policy LA2:14 page 95; states that “to ensure that landscape impacts are effectively mitigated” “ Development must make provision for ….. A Landscape and green infrastructure framework incorporating open space, strong landscaping and tree planting along the northern boundary……” This does not address the damaging impact that the new development would have overshadowing existing homes in Sycamore Close and must also make comparable provisions for the southern boundary adjacent to Sycamore Close.
• CS10.2 Transport Impact of New Development, page116;
o “The expected nature and volume of traffic generated can accommodated without detriment to the amenity or character of the surrounding area”
o As identified by the Highways Agency, it needs to undertake further work to understand the scale of impact resulting from the increased number of houses, on the capacity, operation and safety of the single access to this busy A65.
CS Sec 9.4 , CS8.2, Principles of Coalescence page 99; The proposed scale of development on M41M is contrary to these principles of coalescence and its importance in “keeping individual settlements distinct and protecting their individual character”. If this site were to be developed with the proposed numbers and density it would significantly add to the risk of future coalescence with Low Park, Gatebeck and Summerlands.

The development on M41M should be limited to no more than 34 dwellings comprising of bungalows and affordable housing integrated into the topology of the site and preserving the drumlins with appropriate landscaping and the provision of open space.

It is important to retain this site as two fields with their dividing ancient stone walls.
Dwellings in the most westerly field adjacent to the A65 should be limited to single story.

Both the northern and southern boundaries of the plot should be landscaped and policy LA2.14 updated to ensure that all boundaries are screened with sufficient open space between the development site and Sycamore Close to minimise any overshadowing and avoid abrupt boundaries.
Each dwelling should have adequate size gardens to support family use, with sufficient parking for at least two cars and more space (garage and drive) for the larger family
homes.

YES, I wish to participate at the oral examination

I have read the guidance notes

LA1.3 Housing Allocations - R670-mod ENDMOOR SOUTH OF BOWLING GREEN

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.

5.2 R670M
The proposed expansion of the village development boundary to allow the development of 25 houses on this ~1ha site is not Sound as they are not founded on robust and credible evidence.
• DPD page 20, 2.23; Landscape and Settlement “… .the potential impact of the development on landscape and views, ..”
• CS 9.3, page 99; Protection and enhancement of landscape and settlement character…
o The proposed scale of the development would seriously impact the local drumlin landscape and jeopardise these rare aspects of our national heritage.
o DPD 3.124, page 95, Proposes screening for eastern and southern boundaries, but does not take into account the effects it would have on existing dwellings.
• CS10.2 Transport Impact of New Development
o “provides safe and convenient access…. Including those with a disability”
o “is capable of being served by safe access to the highway…”
o “The expected nature and volume of traffic generated can be accommodated with no detriment to the amenity and character of the surrounding area”
? The new proposed development could be expected to generate at least 50 additional car and service vehicle journeys which would create an unacceptable increase in a dangerous level of traffic to:-
• Enyeat and Gatebeck Road which already has two dangerous junctions. See photo Fig 2 in section 7 of this document
• Create a 5 way hazardous junction
• Increased traffic flows on busy corner of the A65


The PC would support a reduced number of no more than 16 single storey dwelling sympathetically integrated into the topology of the site with appropriate landscaping and preserving the dry stone walls.

There also needs to be a new policy similar to LA2.14 for M41M, to ensure that all boundaries are screened to avoid abrupt boundaries.

Each dwelling should have adequate size gardens to support family use, with sufficient parking for cars.

A full highways study should be carried out to ensure safe traffic movements

YES, I wish to participate at the oral examination

I have read the guidance notes

LA1.8 Local Employment Allocations - EN20, EN33# ENDMOOR LAND NORTH OF GATEBECK LANE, GATEBECK

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.

5.3 EN20 & EN33 Employment Site
The proposed development site (3.2ha of a 7.2ha site for B2 and B8 usage) is brownfield, and, currently, used for limited storage/distribution . It sits in a long established sensitive drumlin feature landscape close to other existing employment sites and is accessed by Gatebeck Lane, a dangerous narrow and winding road.

The proposal is not Sound, as is does not conform to the Core Strategy and not sustainable and is not founded on robust and credible evidence.

• CS10.2 Transport Impact (“ Safe and convenient access on foot, cycle, public and private transport…. and “Safe access to the highway network without detriment to the amenity or character of the locality”)
o Gatebeck Lane is already very dangerous and totally unsuitable for heavy traffic , being single track in parts with blind bends and without footpaths. Its narrow verges set in ancient dry stone walls are eroding. (see Crematorium Planning Appeal evidence below)
• An agreed one-way system operates for quarry lorries and traffic is encouraged not to enter the village along Gatebeck Road due to risks to school children, thus funneling all traffic on to Gatebeck Lane but this is not always adhered to.
• A resident at the junction of A65/Gatebeck Lane points to this as an “accident black spot” and contends that local flooding (investigated by Highways Dept) has been caused by heavy traffic. These risks will only escalate should the development go ahead.
• Gatebeck is currently poorly served by public transport, and any proposals to improve public transport provision will, perversely, increase heavy traffic and road safety risks (unless smaller buses are used by the bus companies).

• CS1 Sustainable Development Principles point 2.3 (“protection of countryside and take account of …..landscape character”) and
• CS8.2. “ Development proposals should demonstrate that the location, scale, design and materials will protect ,conserve and, where possible enhance:
o The special qualities and local distinctiveness of the area”.
o “ Proposals for development should be informed by, and sympathetic to, the distinctive character landscapes types……”

• The site is set in a notable drumlin landscape and such significant development (even with landscaping) is completely inappropriate as would any steps to improve Gatebeck Lane to address safety access issues. (see Crematorium Planning Appeal evidence below).

• CS7.1 Meeting the employment requirement. There is clear evidence that the existing local employment sites are not at full capacity.
o A recent survey found that Gatebeck, Summerlands and Mainline Crooklands Road have considerable spare capacity. In particular, Summerlands, which benefits from convenient, safe access to the A65, has in excess of 20,000 sq, ft ( 2 warehouses and 2 units) available plus a 10,000 sq. ft plot with planning permission vacant over 12 months through lack of demand.
Therefore the proposed new development on EN20 & 33 is unwarranted for the foreseeable future.

The proposed development site was in 1999, the subject of a Planning Application Appeal for a Crematorium which raised specific concerns, which are, still valid today:
Planning Inspectorate Reports for :
• T/APP/M0933/A/99/1017017/P2 Crematorium
• T/APP/M0933/A/99/1017615/P2Re-siting of Haulage Depot

In deciding against the Appeal the Inspector recognized:
• “The site is in effectively underdeveloped open country side with a character and appearance typical of the drumlin field LCI in which it lies” (Para 8.)
• The value of these drumlin fields is at the very least undiminished and maybe enhanced today. The Crematorium “would seriously harm the distinctive character of this part of the LCI.” (para. 9) “…. inadequacies in forward visibility, road width and access each presenting a potential risk to highway safety . ” ( para.11)‘…..quite frequently the Crematorium would be likely to cause a significant increase in the amount of traffic using both Gatebeck Road and Gatebeck Lane, with an attendant increase in highway safety” para.12)
• Nearby tourist facilities would become less attractive (para.7)

The type of traffic and likely volumes associated with the rejected Crematorium proposal would have been a much lower risk to highway safety than the expected heavy goods vehicles and articulated lorries which would result in this proposed B2, B8 employment site.

• The County Showfield inspectors report on 22-Feb-1990 Ref 5/89/4103 further supports the sensitivity of the local drumlin landscape adjacent to Gatebeck Lane.
• Sillfield Wind Turbine Appeal Decision, September-2008 Ref: SL/2008/0900 refers to the sensitivity of the drumlin feature to the east of Low Park Lane.

• The PC considers this historical evidence is no less valid today and in fact with increased vehicle sizes and usage safety risks are likely to be more significant.
• At a Public Meeting arranged by PC on 30th January 2012 a significant number of Parishioners voiced strong concerns relating to the potential impact on road safety due to increased traffic on Gatebeck Lane and Gatebeck Road arising from this development.
• The PC and villagers were not consulted on the development of this site for employment until January this year.
• There is no evidence that alternative options with better access to the A65 have been fully explored or that the future capacity of existing sites at Gatebeck, Summerlands, Crooklands and the Mainline Industrial Estate (Crooklands Road) have been considered.

Reference to Employment Site E20 and E33 should be removed from the DPD on the grounds of it not in accordance with the various Core Strategy Policies and not justified.
The PC does not believe that there is sound evidence to support a business case for this site. Consequently the PC propose that alternative employment sites closer to Kendal or that other possible sites with good access to the A65 are more likely to be attractive for local employment.

YES, I wish to participate at the oral examination

To ensure our views are considered and fully understood and to respond to any new information should it arise.

Please notify me

I have read the guidance notes

LA2.14 Land North of Sycamore Drive, Endmoor

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.

Both the northern and southern boundaries of the plot should be landscaped and policy LA2.14 updated to ensure that all boundaries are screened with sufficient open space between the development site and Sycamore Close to minimise any overshadowing and avoid abrupt boundaries.

YES, I wish to participate at the oral examination

To ensure our views are considered and fully understood and to responde to any new information should it arise.

Please notify me