2 responses from Mr J Wall (Individual)
1. Mr J Wall (Individual) : 16 Apr 2012 21:09:00
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Policy/Site No.
LA2.9 Strategic Employment Allocations, Kendal - LAND EAST OF BURTON ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
To make the document sound, the employment allocations need to be reconsidered and the less suitable sites and in particular, site M2M, should be deleted.
The latest employment evidence base study commissioned by the Council and undertaken by Lambert Smith Hampton clearly concludes that the Land Allocations document as it currently stands proposes more land than is required for employment - see for example paras. 9.35, 10.18 and 10.22 of the study. The document cannot be sound, nor can it be environmentally justifed if it advocates the development (and thus the permanent loss) of more greenfield land than is needed. Sites that are less suitable should therefore be removed from the plan in light of this up to date evidence.
M2M is less suitable for many reasons - a) the latest study concludes that this site is assessed as 'orange' in terms of suitability as an employment site (i.e. not green); b)the site has biodiversity value, including great crested newts and nesting waders as confirmed by responsese to earlier consultations; c) it forms a key part of the green gap which separates Kendal from the village of Oxenholme (development here would contribute to the coalescence of Oxenholme and Nataland as well as Oxenholme and Kendal) and inter and intra-visibility within the gap would be significantly increased rendering the integrity of the remaining bit of green gap compromised beyond the point at which the gap would become null and void; d) Cumbria County Council object to the development of this site due to coalescence; e) the only supporters of the site's proposed development have vested financial interests in the development of the site; f) there has been significant objection to/concerns raised about the development of this site from locals as well as organisations such as CCC and CWT; g) the site would be an extension to Oxenholme - this is a small village that does not even have the level of services required to qualify as a local service centre as set out in the adopted Core Strategy and therefore should actually have no allocations, additionally it would breach the railway line which currently acts as the currently unbreached and very defined boundary to this linear village; h) Cumbria Landscape Character Guidance and Toolkit (CLCGT) March 2011 identifies that M2M falls within 'Drumlin Field'. Importantly, this makes clear that in landscape terms, the area M2M is not part of the urban area of Kendal or indeed it's urban fringe - the document has a separate classification for urban areas. This site is part of an important area in landscape terms in that it provides a key part of the setting for Kendal - The Gateway to the Lakes - it has a rural feel and you get the sense of having left the urban environment. The CLCGT identifies that: areas of Drumln Field are quite rare in Cumbria, this area i8s one of only two tracts in the County, "the distinctive grain and interlocking appearance of the drumlin forms are sensitive to development that would change their appearance in the landscape", "The strong matrix of hedges and walls that criss cross and roller coaster up and down the drumlins are sensitive to changes to land management", " the rivers and watercourses that intersect the drumlins reinforce a sense of tranquility and are sensitive to....changes in land management" - the CLCGT vision for the Drumlin Field landscape is that it will be "conserved and enhanced to retain it's distinctive characteristics....It's unique topography will be maintained and enhanced as a striking asset" - it even says that "the intrusion of new farm buildings will be minimised" and that "any small scale development will be sited and aligned to complement the grain and form of the drumlins and that a good network of paths and recreational route will exist" so surely the intrusion of a large employment area that will remove a footpath is not conducive to this vision - this is a particularly sensitive tract as it's proximity to Kendal means it has already been compromised - any further compromise will mean that this tract is segregated from the main part of the typology to the south and thus it's integrity will be destroyed. The development of M2M will cut across a steep slope and sit very uncomfortably in the landscape whilst thr CLCGT states that development in this landscape typology should "Avoid prominent hill tops or cutting across slopes". There are further details in the CLCGT for this typology that identify that development in this location would be inappropriate.The fact file for Kendal suggests that mitigation measures would avoid harm to the landscape but a cursory glance would demonstrate that no amount of mitigation measures, even if all the new buildings had green roofs and walls, which I doubt would be a requirement, this valuable and sensitive tract of a rare landscape would be harmed beyond repair.
I would urge the Inspector to:
- consider the previous appeal decisions made on this site in the past, in all of which the relevant Inspector concluded that this site should not be developed
- view the site from Burton Road, junction of Oxenholme Road and Hayclose Road, several points on the Helm and from the railway bridge at the northern end of Oxenholme. Viewing the site from these points and in the context of the CLCGT clearly demonstrates the harm that development of this site would cause to the landscape and character of this area.
- Walk up Oxenholme Road at dusk to experience the surreal sense of wonderment at hearing the nesting / roosting waders chattering away to one another as they settle down for the night - you are momentarily transported to some wild location listening to exotic creatures and it is amazing when you realise you are actually on your own 'doorstep'.
- Recommend to the Council the removal of this site from the plan and reinstate the land as part of the Green Gap.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
NO, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
2. Mr J Wall (Individual) : 15 May 2012 14:24:00
Before completing this online representation please tick the box to show you have read the 'Guidance Notes for Making a Representation'
I have read the guidance notes
Policy/Site No.
LA1.7 Business and Science Park Sites - M2M-mod KENDAL LAND EAST OF BURTON ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not justified in that it is not founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
To make the document sound, the employment allocations need to be reconsidered and the less suitable sites and in particular, site M2M, should be deleted.
The latest employment evidence base study commissioned by the Council and undertaken by Lambert Smith Hampton clearly concludes that the Land Allocations document as it currently stands proposes more land than is required for employment - see for example paras. 9.35, 10.18 and 10.22 of the study. The document cannot be sound, nor can it be environmentally justifed if it advocates the development (and thus the permanent loss) of more greenfield land than is needed. Sites that are less suitable should therefore be removed from the plan in light of this up to date evidence.
M2M is less suitable for many reasons - a) the latest study concludes that this site is assessed as 'orange' in terms of suitability as an employment site (i.e. not green); b)the site has biodiversity value, including great crested newts and nesting waders as confirmed by responsese to earlier consultations; c) it forms a key part of the green gap which separates Kendal from the village of Oxenholme (development here would contribute to the coalescence of Oxenholme and Nataland as well as Oxenholme and Kendal) and inter and intra-visibility within the gap would be significantly increased rendering the integrity of the remaining bit of green gap compromised beyond the point at which the gap would become null and void; d) Cumbria County Council object to the development of this site due to coalescence; e) the only supporters of the site's proposed development have vested financial interests in the development of the site; f) there has been significant objection to/concerns raised about the development of this site from locals as well as organisations such as CCC and CWT; g) the site would be an extension to Oxenholme - this is a small village that does not even have the level of services required to qualify as a local service centre as set out in the adopted Core Strategy and therefore should actually have no allocations, additionally it would breach the railway line which currently acts as the currently unbreached and very defined boundary to this linear village; h) Cumbria Landscape Character Guidance and Toolkit (CLCGT) March 2011 identifies that M2M falls within 'Drumlin Field'. Importantly, this makes clear that in landscape terms, the area M2M is not part of the urban area of Kendal or indeed it's urban fringe - the document has a separate classification for urban areas. This site is part of an important area in landscape terms in that it provides a key part of the setting for Kendal - The Gateway to the Lakes - it has a rural feel and you get the sense of having left the urban environment. The CLCGT identifies that: areas of Drumln Field are quite rare in Cumbria, this area i8s one of only two tracts in the County, "the distinctive grain and interlocking appearance of the drumlin forms are sensitive to development that would change their appearance in the landscape", "The strong matrix of hedges and walls that criss cross and roller coaster up and down the drumlins are sensitive to changes to land management", " the rivers and watercourses that intersect the drumlins reinforce a sense of tranquility and are sensitive to....changes in land management" - the CLCGT vision for the Drumlin Field landscape is that it will be "conserved and enhanced to retain it's distinctive characteristics....It's unique topography will be maintained and enhanced as a striking asset" - it even says that "the intrusion of new farm buildings will be minimised" and that "any small scale development will be sited and aligned to complement the grain and form of the drumlins and that a good network of paths and recreational route will exist" so surely the intrusion of a large employment area that will remove a footpath is not conducive to this vision - this is a particularly sensitive tract as it's proximity to Kendal means it has already been compromised - any further compromise will mean that this tract is segregated from the main part of the typology to the south and thus it's integrity will be destroyed. The development of M2M will cut across a steep slope and sit very uncomfortably in the landscape whilst thr CLCGT states that development in this landscape typology should "Avoid prominent hill tops or cutting across slopes". There are further details in the CLCGT for this typology that identify that development in this location would be inappropriate.The fact file for Kendal suggests that mitigation measures would avoid harm to the landscape but a cursory glance would demonstrate that no amount of mitigation measures, even if all the new buildings had green roofs and walls, which I doubt would be a requirement, this valuable and sensitive tract of a rare landscape would be harmed beyond repair.
I would urge the Inspector to:
- consider the previous appeal decisions made on this site in the past, in all of which the relevant Inspector concluded that this site should not be developed
- view the site from Burton Road, junction of Oxenholme Road and Hayclose Road, several points on the Helm and from the railway bridge at the northern end of Oxenholme. Viewing the site from these points and in the context of the CLCGT clearly demonstrates the harm that development of this site would cause to the landscape and character of this area.
- Walk up Oxenholme Road at dusk to experience the surreal sense of wonderment at hearing the nesting / roosting waders chattering away to one another as they settle down for the night - you are momentarily transported to some wild location listening to exotic creatures and it is amazing when you realise you are actually on your own 'doorstep'.
- Recommend to the Council the removal of this site from the plan and reinstate the land as part of the Green Gap.
Please tick the box if you wish to be notified when the document is submitted, published and adopted.
Please notify me
