Response from Ms Lorraine Gibbard (Individual)
1. Ms Lorraine Gibbard (Individual) : 26 Apr 2012 15:00:00
Policy/Site No.
LA1.6 Strategic Employment Sites - E4M KENDAL LAND AT SCROGGS WOOD, MILNTHORPE ROAD
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.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
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.
Comments on soundness of submission in relation to Strategic Emoloyment Site
at Scroggs Wood, Milnthoroe Road, Kendal Ref E4M
Document referred to:-
South Lakeland Local Development Framework
Land Allocations Development Plan Document
Proposed Submission Edition March 2012
Strategic Employment site able to accommodate Bl Light Industrial, B2 General
Industrial and B8 Storage and Distribution and ancillary B1 (a) uses.
Site area 17.9 hectares
Point 1 Landscape Character
The document states that acceptable uses for the site are B 1 (b,c) , B2 and B8 plus
B1a ancillary. Page 3 7 refers
It also states that "Strategic Employment Sites are large sites of 5 ha or more" and
"aimed at larger businesses" Paragraph 2.45 Page 36 refers
The document then goes on to say that the land adjacent to Scroggs Woods should
conserve 'important site features' including the 'protection of drumlin
characteristics'. Table Page 68 refers
Surely this is a contradiction. The only way you can economically develop an
undulating site with drumlin characteristics using a mixture of industrial units and
storage facilities is to flatten areas of it so that the construction of distributor roads,
industrial units and the like are easily constructed with the minimum of financial
outlay.
It is not sound reasoning to suggest that drumlin characteristics can be preserved in a
site that has been allocated for industry and storage. Otherwise the site would be
uneconomic to develop and unattractive to potential businesses.
The document also states that there should be 'landscaping along the perimeter of the
site' and 'retained hedgerows' Page 37 refers. It also goes on to say that there should
be 'significant structural landscaping and robust boundary treatment along the
southern and eastern edges to ensure development is sympathetic to the existing
landscape character and views from the A6 (Milnthorpe Road) and A591. Paragraph
3.35 Page 67 refers.
Surely if the submission is to be considered sound, screening of the site from the A591
and A6 should be along the western boundary as there are no A roads on the eastern
boundary.
The site is also clearly visible from the residential areas acijacent and some form of
landscape/acoustic screening will be required to protect the properties from noise
and air pollution. No mention is made of light pollution and how this will be kept in
check in a farmed rural landscape.
Also it is not clear how screening of any significance can be effictive when the A591
,is elevated above the site by at least 30 metres and all of the site is clearly visible
from both the east and west.
The site is of County Significance and acijoins a river with SSI status (Otters are
returning to the area, significant numbers of migratory sea trout and salmon, also
white clawed crayfish). No mention is made as to how developing rural green belt
land along the river Kent valley can be seen as sound in an area that has significant
landscape value adjoining a river of major ecological importance.
Point 2 Sustainability
Sustainable development statements made about the site contradict statements about
unconstrained strategic employment sites aimed at larger businesses of which the
proposed Scroggs Woods site is one. The document refers to the "provision for the
relocation and developing of existing firms" Paragraph 2.45 Page 36 refers.
On the same page of the document reference is made to "the South Kendal Corridor
and M6 Jn 36"
What evidence has been provided to support the view that local businesses will
relocate to south Kendal? Common sense suggests that businesses in the north of the
town in the Shap Road industrial estates for example may well find the southern
employment site more attractive and relocate. More so when you consider that the
document ignores proposals to create a new road through Burneside connecting the
A591 to the northern employment sites. Have businesses been consulted on what
effict an employment site to the south would have on their own business and whether
they would consider relocation? Surely an employment site in the South of the town
would create redundant unattractive brown field sites to the north of the town as
businesses relocate to the south and the development continues unconstrained along
"the South Kendal Corridor? The unconstrained development of a new significant
employment site cannot be regarded as sustainable if employment areas to the north
of the town are abandoned in favour of the more favourable south.
Surely a better option would be to provide a new road through Burneside to serve the
northern employment sites and continue to service these areas. For this reason the
argument for sustainable development along the south Kendal corridor is not sound
as it would be detrimental to Kendal as a whole, and effectively make businesses in
the northern part of the town unsustainable. In order for the proposal in the south to
be considered sound, consultation should have taken place on the efficts it would
have on the northern employment areas.
Point 3 Flooding
The document refers to the possible need for "flooding mitigation measures to reduce
the risk of flooding from a watercourse to the north of the site". Paragraph 3.35 Page
67 refers.
What evidence has been gathered to determine the extent of flooding and its potential
effect on development and surrounding areas? Surely if the land allocation proposal
is to be considered sound there should be supporting evidence as to the degree of risk
of flooding either from the watercourse or the river Kent before submitting the site for
consideration and that this evidence should be complete and comprehensive prior to
its submission to the inspector.
Point 4 Delivery of Infrastructure
There is no evidence within the document to suggest that any agency (e.g. providers
of highways, gas, water, electricity, sewers, communications, public transport) will be
in a position to deliver the infrastructure required and enable development to take
place within the proposed timescales.
Policy CS7.2 of the adopted Core Strategy states that there is a requirement for a 9
hectare Strategic Employment Site by 2025. The proposal at Scroggs Wood is for
17.9 hectares with no evidence that there would be take-up of a site on this scale (it is
comparable in size with the Westmorland Business Park or Shap Road Industrial
Estate to the north of the town) or evidence that the resources would be available to
provide the necessary infrastructure not only for the 9.0 hectares referred to, but also
for a development or series of developments that nearly doubles the scale of the
proposed development.
As the document is inconsistent with regard to the size of development proposed and
with scant evidence that there will be sufficient infrastructure to support any scale of
development within the proposed timescale, then the proposal for an employment site
at Scroggs Woods can not be considered sound.
In conclusion I urge the inspector to reconsider the land allocation at Scroggs Woods
on the grounds that the proposal is not sound for the reasons stated above.