Response from Mrs Linda Brown (Individual)
1. Mrs Linda Brown (Individual) : 19 Apr 2012 14:40:00
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.
LA3.2 Mixed Use Allocation at Land South of Allithwaite Road, Kent's Bank, Grange-over-Sands
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
No
1.2 If NO please identify which test of legal compliance your representation relates to by selecting the relevant option(s) below and completing section 1.3.
Sustainability Appraisal has not been carried out and its baseline information and conclusions have not been used to inform the DPD
1.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD legally compliant, having regard to the test you have identified at question 1.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Reference: Land Allocations Development Plan Document- Publication Stage Representaion of MNI, MN16, MN2, MN25, R673, known collectively as MN25M
Test of Legal compliance: Sustainability Appraisal baseline information not used to inform the process an the outcomes of that process:
Test of Soundness: The strategy is NOT JUSTIFIED in that it is not founded on a robust and
crdible evidence base and/or is not considered the most appropriate when considered against the reasonable alternatives:
To be Legaly compliant and sound MN25M should be in the green or at least yellow on the
EVIDENCE BASED STUDIES and FACT FILE- APPENDIX 3 - SUSTAINABIL TY
APPRAISAL (colour coded).
According to the above study ofMN25M, many areas are in the:
RED - Biodiversity, Landscape Character, Greenfield site and coalescence.
ORANGE - Air Quality, Access to Educational Facilities and Built Environment.
Is this Evidence and Fact File just going to be ignored?
INFRASTRUCUTRE:
To be sound the SLDC Development Plan should have assessed the likely impact of the propsals on the Grange-over-Sands and district infrastruture; THIS HAS NOT BEEN DONE.
Major investment is needed in infrasture BEFORE any building is proposed, ie Roads, Drains,
Water supply, there is no provision for this in the SLDC Development Plan.
Why propose large building developments when there's already traffic problems ie: bottle-necks of Risedale Hill and Main Street
Surface water management needs to be carefully considered on MN25M. (Environment Agency)FACTFILEAPPENDIX lB.
Development of this size has the potential to increase Kents Bank by 40%, this will have an
adverse effect on local drainage in areas that are prone to flooding after heavy rainfall eg:
Allitbwaite Road beyond Risedale Hill, Greaves Wood Road and Kirkhead Road
MN25M is in Kents Bank not part of Grange-over-Sands as SLDC have stated Kents Bank is a seperate community with few amenities eg: shops, banks etc, car journeys will more than likely be taken to access these facilities adding to the traffic problems of Grange.
Site access would be difficult because of Protected Limestone Pavement in Greaves Wood (which has a tree preservation order) and bounded on two sides by Greaves Wood Road Bridleway, (this forms the eastern and southern boundaries), there's not a suitably access from Kirkhead road between the houses, whose back gardens form the western boundary. This leaves Allithwaite Road, which is a fast undulating road that poses sight line problems for drivers.
GREEN GAP and COALESCENCE
To be sound occording to THE CORE STRATEGY (POLICY CS8.2) states that Green Gaps will be identified on land which:
1) If developed, would cause or add to the risk of future coalescence of two or more settlements between which it is important to retain a distinction;
2) Helps to maintain a settelment's identity, setting and character;
3) Is predominantly open and maintains as open aspect;
4) Affords receational and biodiversity opportunities.
POLICY LA 1.9: GREEN GAPS states that the above should apply between Grange-over-Sands and Allithwaite.
There is NO evidence to state how large a Green Gap should be?
MN25M is a beautiful green field site with wonderful open views accross Morecambe Bay which forms the Green Gap.
The Green Gap between Grange and Allithwaite as it stands is ouly 550 meters approx.
BIODIVERSITY
MN25M is an important and sensitive wildlife area:
Bats roost in this area (protected spiecies ).
Evidence of: Water Vole, Badgers, Bats, Deer, Butterflies, Invertebrates, Breeding
Birds and various other sensitive key species (Cumbria Wildlife Trust)- FACT FILE APPENDIX IE.
Tree preservation order on mature trees and hedges rows (giving high biodiversity value) and Limestone Pavement Order with in site boundary.
It also states in the FACT FILE - APPENDIX 1E - That due to the sensitivity ofMN25M it should be excluded from allocation altogether- CUMBRIA WILDLIFE TRUST.
MN25M CANNOT BE MADE SOUND FOR THE REASONS STATED ABOVE
ALTERNATIVE SITES IN AND AROUND GRANGE-OVER-SANDS:
In the Grange-over-Sands Regeneration Study- Nov 2007 it stated:
5 priority sites had been identified for developing:
Berners pool and Berners Close car park and nursery site,
Lido, promenade (Rense existing buildings for arts/creative industries business use),
Kents Bank Road car paik (retailfresidential with basement car park),
Catholic Church field, Lindale Road (refurbish for small business units).
The above are All brown field sites which should be developed before Green field sites such as MN25M.
There seems to be no evidence that a survey has been completed to show what age group of people want to live in Grange (Grange does not need more second homes or retirement homes).
Currently there are over 120 dwellings on the market in Grange-over-Sands and a large number of these have been on the market for over two years.
*DO NOT Build a Booths supennarket in Grange, as Grange residents have repeatedly stated to SLDC they do not require one, as it would destroy the very heart of Grange's unique shops, with its award winning delicatesen. award winning bakery, Spar store, Co-op store, 2 chemists, 2 butchers, fabulous green grocers, two hardware stores where one can buy just about anything, Grange is famous for its shopping experience, destroy this and SLDC destroy tourism for Grange, this is it's lifes blood.
Don't build Booths and this would free Bateman's Garage brown field site for housing.
If the proposed bmlding was east of Grange-over-Sands this would stop daily traffic problems through Grange, particularly on Main Street and Risedale Hill.
Put the proposed industrial development on the current industrial sites on Mile End Road,
Flookbourgh, rather than building on a green field site like MN25M.
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.
Reference: Land Allocations Development Plan Document- Publication Stage Representaion of MNI, MN16, MN2, MN25, R673, known collectively as MN25M
Test of Legal compliance: Sustainability Appraisal baseline information not used to inform the process an the outcomes of that process:
Test of Soundness: The strategy is NOT JUSTIFIED in that it is not founded on a robust and
crdible evidence base and/or is not considered the most appropriate when considered against the reasonable alternatives:
To be Legaly compliant and sound MN25M should be in the green or at least yellow on the
EVIDENCE BASED STUDIES and FACT FILE- APPENDIX 3 - SUSTAINABIL TY
APPRAISAL (colour coded).
According to the above study ofMN25M, many areas are in the:
RED - Biodiversity, Landscape Character, Greenfield site and coalescence.
ORANGE - Air Quality, Access to Educational Facilities and Built Environment.
Is this Evidence and Fact File just going to be ignored?
INFRASTRUCUTRE:
To be sound the SLDC Development Plan should have assessed the likely impact of the propsals on the Grange-over-Sands and district infrastruture; THIS HAS NOT BEEN DONE.
Major investment is needed in infrasture BEFORE any building is proposed, ie Roads, Drains,
Water supply, there is no provision for this in the SLDC Development Plan.
Why propose large building developments when there's already traffic problems ie: bottle-necks of Risedale Hill and Main Street
Surface water management needs to be carefully considered on MN25M. (Environment Agency)FACTFILEAPPENDIX lB.
Development of this size has the potential to increase Kents Bank by 40%, this will have an
adverse effect on local drainage in areas that are prone to flooding after heavy rainfall eg:
Allitbwaite Road beyond Risedale Hill, Greaves Wood Road and Kirkhead Road
MN25M is in Kents Bank not part of Grange-over-Sands as SLDC have stated Kents Bank is a seperate community with few amenities eg: shops, banks etc, car journeys will more than likely be taken to access these facilities adding to the traffic problems of Grange.
Site access would be difficult because of Protected Limestone Pavement in Greaves Wood (which has a tree preservation order) and bounded on two sides by Greaves Wood Road Bridleway, (this forms the eastern and southern boundaries), there's not a suitably access from Kirkhead road between the houses, whose back gardens form the western boundary. This leaves Allithwaite Road, which is a fast undulating road that poses sight line problems for drivers.
GREEN GAP and COALESCENCE
To be sound occording to THE CORE STRATEGY (POLICY CS8.2) states that Green Gaps will be identified on land which:
1) If developed, would cause or add to the risk of future coalescence of two or more settlements between which it is important to retain a distinction;
2) Helps to maintain a settelment's identity, setting and character;
3) Is predominantly open and maintains as open aspect;
4) Affords receational and biodiversity opportunities.
POLICY LA 1.9: GREEN GAPS states that the above should apply between Grange-over-Sands and Allithwaite.
There is NO evidence to state how large a Green Gap should be?
MN25M is a beautiful green field site with wonderful open views accross Morecambe Bay which forms the Green Gap.
The Green Gap between Grange and Allithwaite as it stands is ouly 550 meters approx.
BIODIVERSITY
MN25M is an important and sensitive wildlife area:
Bats roost in this area (protected spiecies ).
Evidence of: Water Vole, Badgers, Bats, Deer, Butterflies, Invertebrates, Breeding
Birds and various other sensitive key species (Cumbria Wildlife Trust)- FACT FILE APPENDIX IE.
Tree preservation order on mature trees and hedges rows (giving high biodiversity value) and Limestone Pavement Order with in site boundary.
It also states in the FACT FILE - APPENDIX 1E - That due to the sensitivity ofMN25M it should be excluded from allocation altogether- CUMBRIA WILDLIFE TRUST.
MN25M CANNOT BE MADE SOUND FOR THE REASONS STATED ABOVE
ALTERNATIVE SITES IN AND AROUND GRANGE-OVER-SANDS:
In the Grange-over-Sands Regeneration Study- Nov 2007 it stated:
5 priority sites had been identified for developing:
Berners pool and Berners Close car park and nursery site,
Lido, promenade (Rense existing buildings for arts/creative industries business use),
Kents Bank Road car paik (retailfresidential with basement car park),
Catholic Church field, Lindale Road (refurbish for small business units).
The above are All brown field sites which should be developed before Green field sites such as MN25M.
There seems to be no evidence that a survey has been completed to show what age group of people want to live in Grange (Grange does not need more second homes or retirement homes).
Currently there are over 120 dwellings on the market in Grange-over-Sands and a large number of these have been on the market for over two years.
*DO NOT Build a Booths supennarket in Grange, as Grange residents have repeatedly stated to SLDC they do not require one, as it would destroy the very heart of Grange's unique shops, with its award winning delicatesen. award winning bakery, Spar store, Co-op store, 2 chemists, 2 butchers, fabulous green grocers, two hardware stores where one can buy just about anything, Grange is famous for its shopping experience, destroy this and SLDC destroy tourism for Grange, this is it's lifes blood.
Don't build Booths and this would free Bateman's Garage brown field site for housing.
If the proposed bmlding was east of Grange-over-Sands this would stop daily traffic problems through Grange, particularly on Main Street and Risedale Hill.
Put the proposed industrial development on the current industrial sites on Mile End Road,
Flookbourgh, rather than building on a green field site like MN25M.
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
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
I wish to express my views and hear others
