Response from Mr Christopher Graves (Individual)
1. Mr Christopher Graves (Individual) : 15 Apr 2012 22:58:00
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.
LA1.3 Housing Allocations - R675M-mod HOLME WEST OF BURTON ROAD
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.
I do not consider myself qualified to pass comment against this section
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.
I consider the overall “Soundness” of the proposed development of R675M questionable. My comments follow: (these refer to sections from the Holme Fact File (Ref 1 “South Lakeland Local Development Framework – Land Allocations Plan Document Holme Fact File - February 2012 Version”)
“Soundness”
"Justified"
"Evidence of participation of the local community and others having a stake in the area"
Local community has had some engagement in the process. An exhibition/display was held in the parish hall where the original proposals were shown.
Some scaling back of the developments has since occurred but many still consider the scale of the developments beyond those which a village with limited infrastructure (or suitable space to develop such necessary infrastructure) can sustain. Considerable development has taken place in the village with some 238 dwellings being added between 1991 & 2009 (Ref 1 “Key Characteristics - Housing”)
"Research/fact finding: the choices made in the plan are backed up by facts"
Some effort has been invested to develop the Holme Fact File (Ref 1), though this seems to understate the consequences of building a large number of new dwellings in an already quite built up village. Holme village risks losing more of its character as it becomes closer to a commuting suburb for people who commute to work – particularly in Lancaster or Kendal - though longer distance commutes are already a feature of life.
"Effective"
"Sound infrastructure delivery planning"
Holme General
There have been 238 dwellings built in Holme in the period 1991 to 2009 (with 119 of these built since 2003 - data from Ref 1 “Key Characteristics - Housing”). This increase in housing has not been matched by any commensurate increase in the village facilities.
The main access roads in the village (Station Road, North Road, Burton Road and Milnthorpe Road) have areas which are regularly double parked as existing residents have nowhere else to leave their vehicles. Additional traffic generated by new housing developments would need to utilise these main thoroughfares. The Parish Plan identifies parking and speeding (Ref 1 “Accessibility”) as dangers and the addition of more housing will not improve the parking issue.
Since the data was collected for the “Holme Fact File” (Ref 1 ‘Key Characteristics’ –The Economy”) the former Methodist chapel has now closed, and there is only the Parish Church (Holy Trinity).
There are business facilities in units at Dalton Hall, Levens Hall, Clawthorpe Hall and the new auction mart complex near Crooklands all within easy reach by car, though public transport is poor with buses at approximately hour intervals through the day through Burton to Lancaster and through Milnthorpe to Kendal and beyond.
Site R675M (proposed allocation)
Access to housing proposed on R675M is restricted to the opening between two dwellings onto Burton Road. This junction has poor sight lines in both directions:
Towards Burton the road rises to the listed humpbacked canal bridge a short distance away with very poor visibility of oncoming traffic.
Towards Milnthorpe the road is rising from the village centre and visibility is often obscured by parked vehicles
Access is referred to in the “Assessment Process” in a number of areas – generally relating to the much larger originally proposed R675 where there were a number of possible, though far from ideal, access possibilities. Site R675M does not have access to these other possible routes in/out and consequently “Highways Issues” including ‘Transport Assessment’ and ‘Transport Statement’(Ref 1) will need to be carried out and satisfactory conclusions reached by Cumbria County Highways. (Note Appendix 1E refers to access as “problematic”)
Pedestrian access to the site will be from the same point on Burton Road as vehicular access. This will mean that properties within the development will be sufficiently far from the village centre facilities to generate further local traffic journeys to service the new resident’s needs.
The “Assessment Process” (Ref 1) refers to the “Sustainability Appraisal” ‘negatively scoring issues including biodiversity interest and impact on listed buildings and structures canal bridges re site R675 and Pinders Farm re site RN94’. No mention is made of Bridge House – also listed – which adjoins R675M and which would be adversely affected by developments on site R675M.
Landscape issues raise a number of concerns (Ref 1 “Landscape Issues” ’The Cumbria Landscape Character Guidance’). The site is not flat and consequently their advice on developments “…of high quality and well related to the distinctive grain and scale of this landscape” and “avoiding siting development on prominent hill tops or cutting across slopes” should be adhered to so that future residents of Holme can enjoy the quality of life enjoyed by today’s residents. Any development is likely to “…disrupt the long held pattern” of farming as the current land use will be lost forever when the development commences.
It is a point of interest that the ‘open spaces such as orchards and gardens’ (are somewhat protected) whereas amenity enjoyed by many villagers of open fields is considered less important.
The owners of Bridge House face the prospective further irony prospect of being significantly overlooked by the proposed development R675M and yet unable to develop their ‘orchards and gardens’ to take advantage of the general relaxation of planning laws currently being rolled out should they or future owners wish to.
Although having no pond or other water feature the garden at Bridge House has frequently been visited by a variety of amphibians including toads, frogs and newts (supporting the comment of ‘’………..the site look to be rough grassland may have reptile and invertebrate interest’ Ref 1 “Biodiversity/Geodiversity”)
Flooding has been an issue in the past (as evidenced by Ref 1 “Flooding”), the more rapid run off of surface water from roofs and paved/tarmaced roads of the development will need to be carefully considered. The garden of Bridge House rises towards the site and the owners are concerned about this issue.
"Having no regulatory or national barriers to delivery"
Not qualified to make comment against this area
"Delivery partners who are signed up to it"
The Delivery Partners will inevitably have a vested interest in the proposed developments, where are the appropriate checks and balances? The consultation process has a democratic basis but many have failed to become engaged.
"Coherence with the strategies of neighbouring authorities"
Not qualified to make comment against this area
