Response from Mr Darren Leather (Individual)
1. Mr Darren Leather (Individual) : 15 Apr 2012 20:16:00
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Policy/Site No.
LA1.3 Housing Allocations - RN117M KENDAL WEST OF VALLEY DRIVE
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
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.
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.
SLDC have chosen the sites which cost the least to develop (e.g. no compulsory purchase costs) and will make the most profit for the developer rather than those best for the health and well being of local people.
Plenty of more suitable sites, originally on the LA DPD maps for the SLDC district, have not been included on the latest maps.
The evidence above shows that these traffic problems in Kendal will not be fixed before the year 2025 therefore site RN117M is UNSOUND and must be removed from the LA DPD.
New extensions to settlements therefore may be relatively densely designed and built right up against the existing settlement,resulting in green fields being ‘swallowed up’. This will mean they are built on exactly the land of most value to the existing community – the fields or woods at the ends of their gardens, the green edge to the town. Local residents against new development may be accused of ignoring the needs of others for housing, but they have a genuine point. They may not have bought the right to their countryside views, but they certainly have paid for them, and these developments are on exactly the fields of most landscape value to existing residents."
The "Taylor Report" confirms that the proposed system is UNSUSTAINABLE and therefore the development of site RN117M (being a peripheral Green Gap site) is UNSOUND and must be removed from the LA DPD.
This confirms that development of the peripheral Green Gap site RN117M is not sustainable and therefore UNSOUND.
“The Council believes the Planning Authority should follow Taylor and adopt this model in preparing its final Land Allocations policies for Kendal, as the only way in which the NPPF demand for sustainable development can be achieved in the town. It is important to note that this is not in conflict with the Core Strategy positioning of Kendal as a Principal Service Centre, or with the requirements for meeting forecast housing demand. From Taylor, the requirements for sustainable development in rural market towns is clear: it cannot be delivered by allocating isolated sites around the town; a hub and spoke model is required. Even without the NPPF’s insistence on sustainable development, there are other intrinsic advantages to the hub and spoke model for Kendal. The Council’s previous Response to Consultation highlighted the major infrastructure challenges to be overcome in the town. These become far more soluble if development proceeds on hub-by-hub basis, when the infrastructure work can be concentrated on the corresponding spokes. For example, it is far simpler to improve bus services, cycling provision, etc. if only one or two ‘spokes’ have to be addressed.
The evidence in the EHLSS shows that there are suitable sites available (the scope of the SHLAS only covered sites within existing settlement boundaries, and is of less relevance), and there are options both for completely new communities on green field sites, or for breathing new life into existing communities.”
This confirms that the strategy is incorrect for Kendal and should be replaced by the “hub & spoke” strategy. It also confirms that the peripheral Green Gap site RN117M is unsustainable and therefore UNSOUND.
“Maintaining and enhancing the quality of the surrounding landscape and the need to achieve urban edges which maintain or enhance the character and appearance of the town when viewed from key approaches by road and rail and from important viewpoints such as Kendal Castle, The Helm, Kendal Fell and Scout Scar/Brigsteer Road; Promoting sustainable transport and achieving a positive impact on the Kendal Air Quality Management Area;
One of the main comments of the people who responded to the SLDC consultations and opposed them was the appearance of Kendal. This is imbedded in the above paragraph and has been totally ignored. The LA DPD is UNSOUND with regard to the above paragraph.Site RN117M IS MENTIONED IN THIS VIEW.
UTILITIES:
South Lakeland District Council does not hold or have access to data/information regarding the catchment area of the Kendal Sewerage Works.”
SLDC/UU admit that the headroom (i.e. spare capacity) is not excessive. Despite this SLDC have no results of any modelling and have not insisted that this modelling be carried out by UU. SLDC do not even know the catchment area for Kendal Sewage Works. There is nothing in the documentation on the SLDC web site to indicate that SLDC do have this information today . Therefore SLDC do not know how many dwellings can be built before Kendal Sewage Works needs a major upgrade costing many millions of pounds.
National Grid Gas Distribution own and operate the local gas distribution network in South Lakeland. The confidential nature of the process means National Grid are unable to confirm whether they are currently processing or have made any offers for connection within Cumbria"
States nothing here about National Grid Gas Distribution having "a statutory duty to develop and maintain an efficient and economical system of water supply within its area."
Meeting “Deliverability” is impossible without all the utility companies signing up to the timescales planned, they can have the proviso that it depends on building going ahead. How can the LA DPD possibly be monitored without signed commitment from the utility companies to the plan timescales. Until they are the LA DPD is UNSOUND.
This Infrastructure document is only a statement; there is no indication when the Infrastructure Delivery Plan will be available to the public or any indication that the timescales can be met. The LA DPD is UNSOUND until the Infrastructure Delivery Plan and the Kendal Transport Plan is available with all milestones agreed and signed off by the respective utility companies.
On a personal note I wish to appeal to those making these decisions:
To Think long and hard about what we are preventing for our future generations to enjoy.Green areas give people a feeling of well being,somewhere to escape the hustle and bustle of our everyday hectic lives.
Yes we need homes for the future,but not by ruining the calmness and tranquility of our green areas
Stay true to the beliefs of the majority of local people and re-assess this DPD,Kendal does not need to ruin it's green belt,,,,STOP THIS URBAN SPRAWL NOW!
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
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